Policy and Procedure Recommendations (PPR) Portal

NYPD

2017-03-27T00:00:00.000

As NYPD committed in December 2015, NYPD should use computerized systems to automatically flag Cases For Legal Action referrals to be forwarded to NYCHA, for arrest reports of NYCHA residents for specified penal law charges committed both on and off of NYCHA premises. NYPD representatives could then review such arrest reports to screen out juvenile or other confidential records before referring the remaining documents to NYCHA.

Accepted

Yes

2018-03-12T00:00:00.000

NYPD

2017-03-27T00:00:00.000

NYPD should report arrests of NYCHA residents for serious criminal charges specified in the Cases For Legal Action procedure ? for crimes committed both on, and off of, NYCHA premises.

Rejected

No

NYPD

2017-03-27T00:00:00.000

NYPD should amend Patrol Guide #214-07 to also mandate reporting of resident arrests for serious criminal charges specified in the Cases For Legal Action procedure, for crimes committed off of NYCHA premises.

Rejected

No

NYPD

2017-03-27T00:00:00.000

As previously recommended in DOI’s 2015 report, NYPD should expand the Trespass Notice Program, which currently authorizes trespass notices for felony sale of controlled substances, NYPD Patrol Guide #208-76, to additionally include the criminal charges specified in the Cases For Legal Action policy: all search warrants where contraband is recovered; murder, rape, robbery, assault, burglary, arson, and criminal sex acts and abuse; and all firearms offenses.

Rejected

No

HRA

2017-03-29T00:00:00.000

HRA should limit HRA employees’ ability to access and view EBT card numbers and enhance HRA’s ability to detect HRA employees’ unauthorized access to client data. To that end, HRA should implement the following: a. Periodic training for all HRA employees about the importance of safeguarding all client information, including social security numbers and EBT card information. b. A directive to all program staff prohibiting the scanning of EBT card images into the HRA One Viewer database. c. The creation of exception reports showing HRA employees who access cases in the One Viewer that are not assigned to them. Results of the exception reports should be forwarded to DOI for further investigation. HRA should limit HRA employees’ ability to access and view EBT card numbers and enhance HRA’s ability to detect HRA employees’ unauthorized access to client data. To that end, HRA should implement the following: a. Periodic training for all HRA employees about the importance of safeguarding all client information, including social security numbers and EBT card information. b. A directive to all program staff prohibiting the scanning of EBT card images into the HRA One Viewer database. c. The creation of exception reports showing HRA employees who access cases in the One Viewer that are not assigned to them. Results of the exception reports should be forwarded to DOI for further investigation.

Practice Already in Place

Practice Already in Place

2017-03-29T00:00:00.000

Agency self-reported practice already in place

HRA

2017-03-29T00:00:00.000

HRA and DOI should collectively recommend to OTDA that OTDA implement additional security challenges to its present IVR system handling EBT card account PIN modifications.

Accepted

Yes

2017-03-29T00:00:00.000

HRA

2017-03-29T00:00:00.000

HRA should work with OTDA to implement a notification system to EBT card account holders as follows: a. Whenever a PIN modification occurs, a letter, text message, and/or e-mail (if applicable) should be generated to the primary account holder detailing the date of the modification. This notification should instruct the primary account holder to contact BFI and DOI if the stated modification was not authorized. b. Whenever an EBT card transaction is completed by “keying in” rather than by card swiping at an EBT terminal, a letter, text message, and/or e-mail (if applicable) should be generated to the primary account holder detailing the date of the transaction, the retailer, and the amount of the transaction. This notification should instruct the primary account holder to contact BFI if the stated transactions were not authorized.

Accepted

Yes

2017-03-29T00:00:00.000

HRA

2017-03-29T00:00:00.000

HRA’s Office of Program Accountability (OPA) and BFI should partner with DOI to develop enhanced training for HRA investigators to evaluate SNAP payment complaints for possible internal fraud. This plan should incorporate identifying and reviewing the following: a. Any recent PIN changes in the subject account. b. Patterns of purchases outside the usual geographical area.

Practice Already in Place

Practice Already in Place

2017-03-29T00:00:00.000

Agency self-reported practice already in place

HRA

2017-03-29T00:00:00.000

HRA’s OPA, in an ongoing partnership with DOI’s Data Analytics Unit, should devise a set of SNAP fraud indicators and investigatory steps that incorporate the following: a. An analysis of PIN change frequency for all EBT card account holders. b. An analysis of EBT card reissuances. c. Referral of cases that are deemed suspicious to DOI for further investigation.

Practice Already in Place

Practice Already in Place

2017-03-29T00:00:00.000

Agency self-reported practice already in place

HRA

2017-03-29T00:00:00.000

When public assistance clients told HRA of concerns about possible SNAP fraud on their EBT accounts, HRA did not direct those claims to their internal fraud investigations unit for evaluation. As a result, HRA should establish and disseminate policies for Job and SNAP Center caseworkers to evaluate whether certain SNAP complaints merit referral to BFI and should train all its Job and SNAP Center staff to make such referrals when appropriate.

Practice Already in Place

Practice Already in Place

2017-03-29T00:00:00.000

Agency self-reported practice already in place

HRA

2017-03-29T00:00:00.000

Some retailers in the EBT network do not enforce the rule that requires the EBT card account holder to present his or her EBT card to the retailer during all transactions, thereby allowing fraudulent actors to conduct transactions against any EBT account without having physical possession of the EBT card. HRA and DOI should collectively recommend to OTDA the following rules for retailers using the EBT system: a. Retailers should enforce the rule of having customers display their physical EBT card prior to keying in a transaction, as required under the Quest Operating Rules. b. In instances where the customer wishes to conduct a transaction by “keying-in,” the retailer should require that the customer swipe his or her card first. c. OTDA should track suspicious EBT card transactions and make this information available to law enforcement entities, including DOI.

Accepted

Yes

2017-03-29T00:00:00.000

DOHMH

2017-04-04T00:00:00.000

DOHMH should take measures to ensure that the target nonprofit adheres to the conflicts of interest provisions contained within standard DOMHM contracts.

N/A

N/A

Recommendation no longer applicable

DOHMH

2017-04-04T00:00:00.000

DOHMH should ensure that relevant staff members are familiar with the conflicts of interest provisions of DOHMH contracts and that potential violations are reported to the DOHMH management and, when appropriate, to DOI.

N/A

N/A

Recommendation no longer applicable

DOHMH

2017-04-04T00:00:00.000

To the extent that DOHMH funds continue to be used to fund the Executive Director's salary, DOHMH should determine whether it is appropriate to continue providing funding for her as a full-time employee, given the representation that the Executive Director does not always work in the target nonprofit's office.

N/A

N/A

Recommendation no longer applicable

DOHMH

2017-04-04T00:00:00.000

DOHMH should take measures to determine whether any DOHMH funds were involved in the above referenced "loans" and "advances" to the target employee, and, if so, ensure the target employee repays any balance due to the organization from such loans or advances.

Accepted

Yes

2017-06-07T00:00:00.000

Recommendation no longer applicable

DOHMH

2017-04-04T00:00:00.000

To the extent that DOHMH funds were used for impermissible travel expenses, DOHMH should seek to recover those funds.

Accepted

Yes

2017-06-07T00:00:00.000

Recommendation no longer applicable

DOHMH

2017-04-04T00:00:00.000

DOHMH should review the above referenced payments to determine whether any DOHMH funds were used in violation of its contracts with the target nonprofit, including in violation of any provisions requiring competitive bidding for subcontracting services.

Accepted

Yes

2017-06-07T00:00:00.000

ACS

2017-04-05T00:00:00.000

ACS should maintain tracking logs of the names and pedigree information of all WEP personnel or any temporary or transitional employee working for the agency, in any capacity, and allow this information to be readily available to ACS management and to DOI upon request.

Accepted

Yes

2017-06-13T00:00:00.000

ACS

2017-04-05T00:00:00.000

ACS should establish a system that mandates all persons that have any contact with mailed checks, including payroll checks, including returned checks, and with sensitive documents, sign a log showing their activity, time of activity, role and job title, which is easily accessible to ACS management and to DOI upon request.

Practice Already in Place

Practice Already in Place

2017-06-13T00:00:00.000

Agency self-reported practice already in place

ACS

2017-04-05T00:00:00.000

ACS should send by certified mail all employee paychecks or other correspondence that contains any item of monetary value, and any document this is sensitive in nature.

Rejected

No

ACS

2017-04-11T00:00:00.000

ACS should require that the target nonprofit document any compensation-related discussions or decisions in its board minutes and provide copies of board minutes to the agencies.

Accepted

Yes

2018-03-01T00:00:00.000

ACS

2017-04-11T00:00:00.000

ACS should update their respective Fiscal Manuals to include rules concerning bonus payments or salary changes by nonprofit vendors, as well as any disclosure requirements regarding the same.

Accepted

Yes

2018-03-01T00:00:00.000

ACS

2017-04-11T00:00:00.000

ACS should require that the target nonprofit disclose the salaries of key employees to the agencies, as well as any salary changes.

Accepted

Yes

2018-03-01T00:00:00.000

ACS

2017-04-11T00:00:00.000

ACS should inform the target nonprofit of agency rules concerning bonus payments or salary adjustments by contracted vendors.

Accepted

Yes

2018-03-01T00:00:00.000

ACS

2017-04-11T00:00:00.000

ACS should notify the target nonprofit of the requirements concerning the disclosure of salary information in contract budgets.

Accepted

Yes

2018-03-01T00:00:00.000

ACS

2017-04-11T00:00:00.000

ACS should require that the target nonprofit's board members and key employees complete the MOCS Capacity Building and Oversight Non-Profit Vendor Review Report process.

Accepted

Yes

2018-03-01T00:00:00.000

ACS

2017-04-11T00:00:00.000

ACS should require that the target nonprofit establish a written policy for compensation of key employees and submit a copy of the policy to the agencies.

Accepted

Yes

2018-03-01T00:00:00.000

DOHMH

2017-04-11T00:00:00.000

DOHMH should require all nonprofit vendors with deliverable based contracts, including contracts under the Infant Mortality Reduction Initiative, provide underlying line item budgets concerning the allocation of funds to employee salaries.

Accepted

Yes

2017-05-25T00:00:00.000

DOHMH

2017-04-11T00:00:00.000

DOHMH should update their respective Fiscal Manuals to include rules concerning bonus payments or salary changes by nonprofit vendors, as well as any disclosure requirements regarding the same.

Accepted

Yes

2017-05-25T00:00:00.000

DOHMH

2017-04-11T00:00:00.000

DOHMH should require that the target nonprofit establish a written policy for compensation of key employees and submit a copy of the policy to the agencies.

Rejected

No

DOHMH

2017-04-11T00:00:00.000

DOHMH should inform the target nonprofit of agency rules concerning bonus payments or salary adjustments by contracted vendors.

Rejected

No

DOHMH

2017-04-11T00:00:00.000

DOHMH should require that the target nonprofit disclose the salaries of key employees to the agencies, as well as any salary changes.

Rejected

No

DOHMH

2017-04-11T00:00:00.000

DOHMH should require that the target nonprofit document any compensation-related discussions or decisions in its board minutes and provide copies of board minutes to the agencies.

Rejected

No

DOHMH

2017-04-11T00:00:00.000

DOHMH should require that the target nonprofit's board members and key employees complete the MOCS Capacity Building and Oversight Non-Profit Vendor Review Report process.

Rejected

No

DOHMH

2017-04-11T00:00:00.000

DOHMH should notify the target nonprofit of the requirements concerning the disclosure of salary information in contract budgets.

Rejected

No

DCAS

2017-04-17T00:00:00.000

DCAS should send a Cease and Desist letter to contractor regarding the ballistic vests obtained from the non-uniform agencies.

Accepted

Yes

2017-05-18T00:00:00.000

DCAS

2017-04-17T00:00:00.000

DCAS should not allow contractor to obtain any additional ballistic vests from the City of New York.

Accepted

Yes

2017-05-18T00:00:00.000

DCAS

2017-04-17T00:00:00.000

DCAS should not renew or issue a new contract or small purchase order for the recycling/destruction of ballistic vests with the incumbent contractor.

Accepted

Yes

2017-05-18T00:00:00.000

DCAS

2017-04-17T00:00:00.000

Future Citywide contracts should clearly define the terms "recycling" and "destruction" of ballistic vests.

Accepted

Yes

2017-05-18T00:00:00.000

DCAS

2017-04-17T00:00:00.000

Future Citywide contracts for the recycling/destruction of ballistic vests should explicitly state that ballistic vests cannot be resold.

Accepted

Yes

2017-05-18T00:00:00.000

DCAS

2017-04-17T00:00:00.000

Future Citywide contracts for the recycling/destruction of ballistic vests should make it mandatory for the agency utilizing the requirements contract to monitor which ballistic vests are taken out of commission, and to maintain documentation for when the vests are sent for recycling/destruction.

Accepted

Yes

2017-05-18T00:00:00.000

DCAS

2017-04-17T00:00:00.000

Future Citywide contracts for the recycling/destruction of ballistic vests should make it mandatory for the agency utilizing the requirements contract to remove the agency name and logo from the ballistic vest prior to sending them for recycling/destruction.

Accepted

Yes

2017-05-18T00:00:00.000

DCAS

2017-04-17T00:00:00.000

For all future contracts, DCAS OCP should conduct a thorough background check on a contractor, including checking the company's website, prior to awarding a contract.

Accepted

Yes

2017-05-18T00:00:00.000

ACS

2017-04-17T00:00:00.000

ACS should circulate to all ACS/DYFJ staff a memorandum reminding employees of the agency's social media policy and policies regarding electronic devices usage during work hours and specifically inside detention facilities, issue a copy of said policies and procedures which require a written receipt with instructions to read, become familiar with, and adhere to said policies, and a copy of said policies placed in personnel files.

Accepted

Yes

2017-06-13T00:00:00.000

H+H

2017-04-20T00:00:00.000

Rape kits should be offered to sexual assault victims by CHS staff in cases of penetration by inanimate objects.

Accepted

Yes

2017-06-01T00:00:00.000

DOHMH

2017-04-24T00:00:00.000

That if, during a daycare inspection, an inspector finds any employee form or document which appears to have been altered, the inspector should then conduct a full review of all employee files at the daycare to determine if there are additional altered or fraudulent documents.

Accepted

Yes

2017-06-29T00:00:00.000

DYCD

2017-04-24T00:00:00.000

DYCD should require the taregt nonprofit and other afterschool program vendors to provide written notice to employees of restrictions on (i) personal use of organization computers and equipment and (ii) viewing inappropriate material on organization computers.

Accepted

Yes

2018-03-20T00:00:00.000

DYCD

2017-04-24T00:00:00.000

DYCD should require the target nonprofit to notify employees that reports of inappropriate conduct by an employee of its afterschool programs must be immediately brought to the attention of the proper supervisor.

Accepted

Yes

2017-05-24T00:00:00.000

DYCD

2017-04-24T00:00:00.000

DYCD should require the target nonprofit and other afterschool program vendors to have employees sign a certification on the written notice that acknowledges receipt and understanding of the aforementioned restrictions.

Rejected

No

ACS

2017-04-24T00:00:00.000

DOI recommends that ACS communicate with certain day care centers as to whether these organizations are in compliance with bidding requirements for consultants under ACS contracts and rules.

Accepted

Yes

2017-05-25T00:00:00.000