P100 Home Searches—Where’s the Fraud?
P100 Home Searches—Where’s the Fraud?
Report by Hilda Chan, Soros Justice Advocacy Fellow 2012-2014April 11, 2014 – Since 1997, San Diego County has required all families applying for welfare (“CalWORKs”) to submit to warrantless, suspicionless, unannounced home searches and interrogations by District Attorney Investigators. As of June 2013 about 150,000 families, or about 9,300 families each year, have been subject to these searches. This policy, called Project 100% (“P100”), is cost-ineffective, duplicates existing staff work, and has not been shown to achieve its stated purposes of verifying eligibility, detecting fraud, or deterring fraud.
“They looked under the beds, under everything. For the first time, my daughters saw me as someone who could not protect them. My daughter asked, ‘Mom, are they going to kill you?’”–S.G., a working mother of three girls
San Diego County remains the sole locality in the nation that has imposed a blanket home search policy on families applying for CalWORKs. All other localities use targeted investigations, initiating investigations only after a discrepancy is detected in an application.For 10 years, Los Angeles County implemented a modified blanket home search program, using social workers rather than law enforcement officials. Its home search program was discontinued in 2009 because it was highly cost-ineffective—it cost $4.7 million annually but uncovered fraud in less than ½ percent of homes searched. Abandonment of its blanket home search policy allowed 83 staff to be redeployed to alleviate workload in other areas.In San Diego County, at least $28.5 million—$1.76 million per year—in CalWORKs funds has been diverted from aid to needy families to fund the DA’s costs of the County’s blanket search program. While these costs are likely underestimated, the cost-avoidance figures have been verified to be overestimates. Unfortunately, historically flawed data classification methods have made it impossible to more precisely assess P100’s cost-effectiveness. Even accepting the County’s figures and flawed data classification methods, however, P100 is still cost-ineffective. P100's yearly cost of $1.76 million could instead be used to hire 42 new welfare-to-work employment counselors to assist clients on the road to self-sufficiency.Despite claims of P100’s efficacy, County officials cannot demonstrate that the home searches actually detect or deter fraud. For the past 18 years, the DA’s Office has represented to public and legislative officials that P100 detects fraud in 25 percent of all applicants that would otherwise have been granted. The welfare agency, called Health and Human Services Agency (HHSA), has verified that this purported fraud rate has been historically inflated, systematically including non-fraudulent situations and denials unrelated to P100 such as:
- Applications withdrawn for any reason
- Denials because the applicant was not home during the DA investigator’s two surprise visits
- Denials resulting from the normal eligibility process, rather than P100 results
- Cases denied due to P100 investigations but subsequently approved after reapplication or fair hearing.
Dr. Richard Berk, UCLA Professor, Department of Statistics, concluded in his 2002 study of P100:I have seen nothing that would lead to a credible conclusion that Project 100% has succeeded in increasing fraud detection at the levels claimed by the Chief of the Public Assistance Fraud Division of the DA’s Office.Data trends suggest that P100 is no more effective in determining eligibility than the normal, less invasive eligibility verification tools relied upon by other localities. If P100 actually added a new, effective layer of fraud or ineligibility detection, the application denial rate would have risen at the introduction of P100. This did not occur; the CalWORKs application denial rate of 43 percent remained exactly the same in the 6 months before and after P100’s inception in June 1997. P100 also does not deter ineligible families from applying; the application rate increased slightly at P100’s introduction. Both the welfare agency and the DA’s Office have been aware that “the numbers just don’t add up.”Other counties in California have opposed legislation that sought to impose P100 home searches on all families statewide that apply for cash aid.For the sake of fiscal responsibility and good governance, the San Diego County’s Board of Supervisors must end P100 blanket home searches and return to the smarter, more cost-effective policy of targeted investigations.