Job Specification

Purpose of Position :

To contribute to the integrity of Ontario Disability Supports and Ontario Works programs through the application of subject matter expertise and the comprehensive analysis and evaluation of case audits, the investigation of potential fraud and non-compliance, and the inspection/quality assurance review of various areas of social assistance service delivery.

Duties / Responsibilities :

Ontario's social assistance programs, Ontario Disability Supports and Ontario Works, provide income and employment support for those in need. In this context, the position:
1. Conducts secondary reviews of eligibility decisions and case audits by critically analyzing and evaluating case file information, evidence and documentation to verify the client's eligibility (including inactive clients) for social assistance in accordance with legislation and established business processes and guidelines. Makes high level discretionary decisions to either uphold or overturn eligibility based on legislation and regulations, and in consideration of individual circumstances. Produces sound conclusions and documentation that serve as a basis for decisions. Provides notice in writing to recipients who are no longer eligible for assistance including reasons for ineligibility.
2. Conducts assessments of recipients' eligibility in response to complaints and information from a variety of sources (e.g. audit investigations, inspection samplings, etc.) by reviewing and analyzing client case files to verify if allegations are plausible and assessing evidence and documentation to determine appropriate action. Interviews and obtains information through other sources, such as immigration and other government agencies, financial institutions and employers through consents for disclosure of information, ensuring Freedom of Information and Protection of Privacy Act (FIPPA) requirements are met; reviews and determines relevance of information collected and whether there is evidence of intent to defraud. Interviews clients to gather information and inform them of complaint and assessment, their legislated rights and responsibilities.
3. Where situations warrant further investigation, conducts comprehensive investigations including review of pertinent information/evidence to determine the scope and investigative action plan. Prepares comprehensive investigation reports detailing outcome of contacts and data-gathering activities and chronological case reviews including evidence, conclusions and recommendations regarding eligibility and the applicable period and amount of overpayment. Makes recommendations to the Team Lead or Manager on the advisability of referral for prosecution and provides recommendations to field staff on applicable entitlement adjustments. Ensures the necessary supporting documentation is prepared for cases referred for prosecution and serves as a witness in criminal court, as required.
4. Takes a pro-active and collaborative approach to prevent abuse of social assistance programs by analyzing reports and data from information obtained through various sources (i.e. third-party interfaces, ad hoc samplings, etc.). Identifies trends and systemic issues and develops recommendation for enhancements to preventative and deterrence measures to support ongoing program integrity. Through complex data analysis, assists with the informing and development of key performance indicators and targets towards meeting the required objectives and outcomes for program integrity.
5. Ensures compliance with ministry legislation, regulations, policies and directives by monitoring and evaluating the service delivery of agencies/vendors through the review and analysis of complaints, financial, statistical and operational reports and conducting investigations of individuals or companies alleged to have exhibited unethical conduct by obtaining evidence, collecting and securing documents/information/data and making recommendations for action.
6. Uses a customer-focused service delivery approach by conducting case interviews with clients by phone or in person at various locations (onsite, homes or offsite); verifies client information through various sources (e.g. financial institutions, employers, landlords, accessing third party databases, etc.); review client case file in consideration of individual circumstances to ensure discretion has been applied as appropriate; assessment of arrears and overpayments for social assistance.
7. Reviews and assess case discrepancies and provides recommendations to the field and/or takes action as appropriate; makes recommendations or adjustments to the amount of income support as a result of case auditing findings and investigation through complex accounting and mathematical calculations that ensure clients receive benefits and services for which they are eligible.
8. Identifies knowledge gaps and training needs of regional/field staff and contributes expertise to the development of training and education tools, job aids and other resources that raise awareness of compliance and preventative measures and to support consistency in program delivery. Ensures that program deliverables are met by acting as a resource to program staff by providing support, advice and clarification of ministry legislation policy, procedures, standards and operational directives.
9. Participates in Internal Review/dispute resolution processes as required and prepares and presents submissions regarding appeals/benefit reviews to the Social Benefits Tribunal (SBT). As required, serves as a Commissioner of Oath for the ODSP program.
10. Conducts research and analysis of trends and developments in social assistance program integrity processes and best practices in other jurisdictions. Provides recommendations to the Team Lead and Manager on new and innovative compliance methodologies for consideration and possible inclusion in unit operational procedures. Maintains up to date knowledge of decisions of the Ontario Divisional Court affecting social assistance and identifies issues that may impact the ministry's programs.
11. Reviews future program/policy directions, initiatives and projects with a program integrity lens and provides information/data, analysis, advice and recommendations/options to support corporate decision-making and communication and planning strategies.
12. Drafts correspondence, briefing material, presentations and investigation/statistical reports; participates in the delivery of presentations to internal and external stakeholders on program integrity and compliance programs.
13. Participates in projects, committees and working groups to discuss issues that reinforce a collaborative approach to best practices in program integrity and other issues of mutual concern and cross-jurisdictional information gathering that ensures alignment with business processes and policies.
14. Manager has the right to assign additional duties.

Staffing and Licensing :

Security screening (e.g. Canadian Police Information Centre (CPIC)) checks are required due to work in the Vulnerable Services Sector.

Occasional travel throughout the Province to conduct investigations/interviews or attend meetings.

Knowledge :

The position requires the following knowledge:
 Government/ministry strategic direction, goals and objectives related to the Ontario Disability Support and Ontario Works Programs, and detailed knowledge of the intent, interpretation and application of related ministry legislation and regulations (e.g. ODSP Act, Ontario Works Act, and the Social Assistance Reform Act) and related regulations, policies, processes, systems and funding arrangements to ensure program integrity through the analysis and evaluation of case audits, the investigation of potential fraud and non-compliance, and the inspection/quality assurance review.
 The broad range of issues and barriers faced by people with disabilities and the community and government resources and services available to assist clients with disabilities with emergencies, supports and employment opportunities.
 Relevant internal ministry and other government programs, such as legal services, and the processes for complaint assessment, internal reviews, and of appeal proceedings at the Social Benefit Tribunal.
 Investigative and fact-finding/auditing protocols, tools, techniques, methodologies and techniques, interviewing methods, and evidence collection methodologies to: investigate complex issues in a diligent manner and logical order and extract evidence that is pertinent to the elements of the potential allegation; plan and conduct investigations and audits to review eligibility, determine appropriate eligibility decisions, and identify any infractions/abuse by recipients, vendors or third parties; use social media, inter-ministerial/government agency databases and interfaces for information gathering.
 Risk assessment methodologies, program oversight, accountability, and control methodologies and principles to perform quality risk-based case audits, analyze trends and patterns in information, and build clear pictures of both individual and systemic eligibility issued from different sources of information.
 Interpretation and application of the Freedom of Information and Protection of Privacy Act (FIPPA) to ensure self-compliance and compliance of others with respect to the retrieval of client information from numerous external sources.
 Project management principles and methods to support the development of investigative action plans, determine scope and timelines, and to prioritize/coordinate multiple concurrent activities.
 Research methodologies to identify trends and developments in social assistance program integrity processes and best practices and to formulate recommendations for the introduction of innovative compliance methodologies for consideration by the Team Lead or Manager.
 Divisional court and quasi-judicial protocols/procedures to prepare for trial/court/hearings, prepare for testimony, present evidence in a judicial or quasi-judicial environment.
 Computer and software applications (e.g. word processing, spreadsheet, program-specific database applications, Intranet/Internet) to prepare statistical reports, work with ad hoc spreadsheets, conduct research and fact-finding.

Skills :

Position requires:
Active listening and communication skills to respond appropriately and professionally when interacting with others, including in high stress, and contentious situations; to use both verbal and non-verbal behavior in communications; to respond professionally and effectively when interacting with others considering cross cultural sensitivity.

Analytical skills to: determine review/investigation requirements and develop plans; classify, cluster and segment data/information retrieved from case file reviews, other data sources (e.g. Consumer Credit Reports, Social Assistance Technologies, Tax information etc.), investigations and interviews to determine/assess continued social assistance eligibility, identify areas of potential fraud, and to monitor and test programs to assess program integrity and compliance with provincial legislation and regulations; develop comprehensive recommendations and supportive solutions; identify trends and patterns in information to build clear pictures from a complex assortment of sources.
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Consultation and presentation skills to present and defend findings and recommendations to Team Lead and Manager; participate in training of regional/filed staff; provide testimony in court and at hearings.

Interpersonal, teamwork and collaboration skills to work in a team environment and acknowledge the diverse opinions of others, address relevant concerns, minimize conflict, and promote harmony; share information gleaned from reviews and investigations; develop internal best practices.

Interviewing skills to elicit information from social assistance recipients in order to identify potential irregularities in personal and financial information.

Mathematical skills to calculate, compute and monitor social assistance supports and benefits, and complex overpayment/arrears, according to eligibility criteria and prepare statistical reports.

Objectivity, confidentiality and fairness to treat all cases equally in accordance with provincial legislation and operational policies and processes, and to maintain a high level of consistency and reliability in applying the requirements of the unit in the program integrity process.

Organizational and planning skills to identify and set priorities and review and manage a high volume of case files and other competing priorities; to ensure that relevant issues are addressed within mandated timeframes and legislative requirements.

Relationship building, consultation and advisory skills to establish linkages with key stakeholders internally and across ministries and with external stakeholders (community agencies, vendors); provide guidance/direction and advice to regional/field staff; facilitate program integrity reviews and investigations; seek opportunities to contribute to the enhancement of unit operational procedures and processes.

Verbal and written communication skills and techniques to: prepare comprehensive reports, analytical reviews and statistical reports, briefing materials and correspondence; to participate in the development of training and presentation material; present findings to Team Lead, Manager and other branch staff; and provide succinct advice to internal staff.

Freedom of Action :

The position works under the general supervision of the Manager, Program Integrity and within the parameters of established legislation, regulations and ministry/division policies, processes and procedures and the Program Integrity Mandate, accountability framework, loss prevention strategy and control measures. The position works in a team environment (co-located and virtual) where coverage for co-workers, information sharing, and support is expected.
The position works independently in performing daily activities exercising judgement and initiative to establish multiple work priorities and caseloads and to resolve issues within established policies, procedures, guidelines and legislation. The position uses judgement to operate effectively and make informed decisions independently without the aid of management, yet still know and understand situations where they require management intervention, consultation or decisions. Judgement and decision making are used in assessing the client situation by: determining client's financial eligibility; providing information, support and advice to clients, employers and community partners in making referrals and deciding on follow up; identifying issues and action plans and deciding on follow-up; understanding the impact of other programs, social changes and changing legislation of a large variety of acts, on ODSP; exercising discretion to ensure client confidentiality; developing requirements and plans. Position exercises latitude in decision making by independently planning and conducting case reviews and investigations and making appropriate eligibility decisions; meeting tight deadlines that impact on legislative integrity and client satisfaction; interviewing and determining how best to obtain evidence/information. Political acuity is used in maintaining internal and external relationships to gather information, obtain data, develop consensus, and collaborate on projects.

The position is relied on to make sound decisions respecting the eligibility of clients for continued receipt of social assistance. Errors or inattentiveness in reviewing all documentation in case files, fact-finding data and client personal circumstances could lead to incorrect decisions leading to potential hardship of clients, public criticism of the programs, media attention, complaints to management/senior management, the Minister's Office and MPP's.

Serious concerns/problems as well as issues not covered by established policies and procedures are escalated to the Manager, other senior staff or a program area. Work is reviewed through consultation with the Manager and assessed for quality, soundness of decisions, adherence to legislation, program policies and procedures and achievement of performance targets.