100-10          ETHICAL CONDUCT

Employees of the Division of Public Assistance, in working with some of Alaska's low income and often vulnerable citizens, have a responsibility to preserve the division's credibility, and are therefore held to the highest standards of ethical conduct. Information contained in this section will provide employees guidance in handling ethics issues. Additional guidelines for ethical conduct are contained in the Code of Ethics handbook for public employees located online at http://www.law.state.ak.us/doclibrary/ethics.html.

100-10 A.      RESPONSIBILITIES OF MANAGERS AND SUPERVISORS

DPADivision of Public Assistance managers and supervisors must investigate any situation that may be in violation of the expectations outlined in this section. Violations will subject individuals to disciplinary actions, which could include termination of employment. In addition, managers and supervisors must ensure employees are made aware of and acknowledge the provisions contained in this section.

100-10 B.      ACCESSING AND USING CONFIDENTIAL INFORMATION

DPADivision of Public Assistance employees have access to an extensive array of confidential and sensitive information. Employees are responsible for protecting the confidentiality of any and all client information available to them from any source. This information is obtained from interviews with applicants and recipients, collateral contacts, documents, the Eligibility Information System (EISEligibility Information System), Alaska's Resources for Integrated Eligibility Services (ARIESAlaska's Resource for Integrated Eligibility Services), Case Management System (CMSCase Management System), and interfaces with other private and public databases; including, but not limited to, information from the Internal Revenue Service, Social Security Administration, other departments of the State of Alaska, and medical providers.

System information and all other sources of information may not be used for personal reasons. It may only be used for actions involving the determination of eligibility and the administration of public assistance programs. All allegations of improper access or unauthorized disclosure of confidential and sensitive information must be promptly investigated. Proof of these allegations could result in disciplinary action including dismissal from the Division. Failure to safeguard confidential information, including unauthorized use or disclosure, is a Class A misdemeanor and individuals may also be subject to civil, criminal, and administrative penalties for the improper receipt, use, and dissemination of that information.

Examples of authorized use of information:

• Any information needed to determine public assistance program eligibility for the cases assigned to you.
• Access and distribution of general information already disseminated to the public.

Examples of unauthorized use of information:

• A neighbor asks you to check up on an ex-spouse because she knows you have access to Department of Labor (DOLDepartment of Labor) records.
• A friend asks you to check for information concerning a potential tenant.
• You check to see if your spouse's ex-spouse has filed for child support payments.
• You check the Child Support interface for your daughter to find her CSSDChild Support Services Division caseworker's name.
• You check EISEligibility Information System to see your sister's Temporary Assistance check has been issued.
• You check ARIESAlaska's Resource for Integrated Eligibility Services to see if your Medicaid application has been processed.

100-10 C.      POTENTIAL CONFLICT OF INTEREST

1. Improper Use or Disclosure of Eligibility Information

DPADivision of Public Assistance employees may sometimes be approached by personal acquaintances, family, or friends to provide information about eligibility requirements for DPADivision of Public Assistance programs. Employees may provide information as long as the information is readily available to the general public. This includes general information about program policies and rules.

Employees may not give priority or preferential treatment to friends, acquaintances, or relatives concerning their cases. This includes using or disclosing any information that could result in a personal or financial benefit such as giving advice or tips on how to become eligible for public assistance benefits. Request for such information must be referred to the Public Assistance office. The caseworker cannot be the employee that is a friend, acquaintance, or relative.

Example of improper use or disclosure of eligibility information:

Your mother is receiving Adult Public Assistance and Medicaid benefits. She has $1500 in the bank and recently received a gift of $1000 in cash. You know that the resource limit for APAAdult Public Assistance and Medicaid is $2000. You tell your mother to not report his information to DPADivision of Public Assistance.

2. Processing Cases

Employees may not process or work on cases involving family, friends (this includes but is not limited to live-in or previous boyfriends, girlfriends, former spouses, neighbors, etc.), and personal acquaintances. This requirement is not limited to making eligibility determination and authorizing benefits. It includes taking any action in regards to the case, such as making collateral contacts, reviewing the case file and any client information, making notes on the CANOCase Notes screen, researching the interfaces, and requesting information related to the case.

For Public Assistance purposes and when determining what work can be completed by a DPADivision of Public Assistance employee, the definition of family members is any individual within the fourth degree of kinship (including in-laws). This means a DPADivision of Public Assistance employee cannot access or take any action on cases for the following relatives:

• 1st degree: Children, Parents, Grandchildren
• 2nd degree: Brothers & Sisters, Grandparents
• 3rd degree: Nephews & Nieces, Uncles and Aunts, Great Grandparents
• 4th degree: Grand Nephews, Grand Nieces, 1st cousins, Great Uncles and Aunts

Current DPADivision of Public Assistance employees must tell their supervisor if they are applying for or receiving Public Assistance benefits, or are included in a household applying or receiving benefits. These cases are considered confidential and are assigned to a supervisor or lead worker to maintain. Employees must never access or view their case on any systems or interfaces including, but not limited to EISEligibility Information System, ARIESAlaska's Resource for Integrated Eligibility Services, DOLDepartment of Labor, CSSDChild Support Services Division, IEVSInstant Eligibility Verification System, and CMSCase Management System for any reason (this is partial and not all inclusive). If a current DPADivision of Public Assistance employee applies for or receives assistance, the case must be referred by the office manager to DOSTDivision Operations Support Team for assignment.

If the applicant or recipient is a former DPADivision of Public Assistance employee who left employment within the last 12 months, the case must also be considered confidential and be assigned to a supervisor or lead worker to maintain.

Cases which include former DPADivision of Public Assistance employees who left employment over 12 months ago are not considered confidential cases. However, refer to section 3 to determine if the situation is questionable and poses a potential conflict.

Note:

DPADivision of Public Assistance employees must not access, view, search, or take any action on a case which involves family members, friends, acquaintances, or their own cases. This includes processing applications, making collateral contacts, reviewing case file or any other client information, sending notices on a case, accessing information on any interface or system, requesting information related to the case, or issuing benefits. If a DPADivision of Public Assistance employee is found working on cases involving family members, friends, acquaintances, or their own case, the employee will be subject to disciplinary action, including termination and being investigated for fraud.

3. Questionable Situations

Employees are sometimes placed in a situation of having to decide if a potential conflict exists when processing cases. If there is any doubt, the employee must immediately inform the supervisor and request to transfer the case or interview.

Examples of questionable situations:

• A former DPADivision of Public Assistance employee who left employment over 12 months ago applies for assistance in the office where they used to work and still maintain friendship with staff in the office.
• In small offices where options to transfer cases between employees are limited or do not exist.

When such situations occur, the ETEligibility Technician must contact the supervisor for advice on how to proceed. It is possible that the case could be transferred to another office for processing depending on the circumstances. Regardless, staff must process all cases according to standard procedures and not take any actions that could be perceived as unfair or granting favoritism.

100-10 D.      STAFF AND CLIENT RELATIONS

Division employees must conduct themselves professionally and limit contacts with clients to only those actions necessary to administer public assistance programs.

Division employees must, at all times, respect client confidentiality and not exploit their professional relationship with clients for private gain or personal advantage.

Specifically, DPADivision of Public Assistance employees must not:

• Use their position to pressure clients into any type of social contact.
• Seek any form of financial gain from DPADivision of Public Assistance-related contact with the client.
• Ask clients any questions that are not pertinent to determining eligibility for DPADivision of Public Assistance programs.
• Use information from client statements or the case file to make social or business contacts with that client or others.

100-10 E.      USE OF STATE EQUIPMENT

State employees are prohibited from using state time, resources, equipment, or facilities for their own personal or financial benefit. State equipment includes computers, copiers, phones, fax machines, postage machines, vehicles, materials, letterhead, and office supplies. State time includes scheduled work hours, except break and lunch periods. State facilities include owned, leased, and rented office and parking space.

Managers may establish policies for the use of equipment that allows personal use but protects the state from costs associated with that use. Employees must comply with the local and regional policy prior to making any personal use of equipment.

Examples of acceptable personal uses of state equipment by employees:

• Personal local calls on own time.
• Long distance calls made on own time, charged to own personal phone number, calling card, private toll-free number, or made as collect.
• Transmitting personal fax correspondence on own time if complying with a locally established policy which ensures no cost to the state.
• When specifically approved by management, the use of emails, copy machines, and fax machines for correspondence relating to professional organizations associated with DPADivision of Public Assistance business, such as the National Eligibility Workers Association (NEW).

Examples of unacceptable personal uses of state equipment:

• Using state postage or state letterhead to mail personal correspondence.
• Receiving personal fax correspondence unless in compliance with local and regional procedures.
• Transmitting long distance direct dial personal fax correspondence which incurs a charge to the state.
• Any personal long distance calls with incur a charge to the state, including direct dial and calls to 900 numbers.

100-10 F.      TRAVEL STATUS AND OFF-DUTY MISCONDUCT

DPADivision of Public Assistance employees are identified by the public as the "Division of Public Assistance." The reputation of the Division is influenced to a large degree by public belief in the integrity of its employees. Each employee is expected to make a dedicated effort to conduct their life so they will inspire the confidence and trust of the public.

The good conduct and reputation of the employees helps ensure the cooperation and support of the public, the cooperation of our partner agencies, and the mutual cooperation of all employees, which increases the effectiveness of the Division.

1. Conduct While in Travel Status

Employees in travel status for DPADivision of Public Assistance-related business are considered on-duty and subject to the same rules of conduct even after work hours.

2. Off-duty Misconduct

Off-duty misconduct can affect the employment status of Division staff. The following situations will cause management to investigate and take appropriate action because of off-duty misconduct:

• If the misconduct interferes with the employee's ability to work.
• If the misconduct jeopardizes the health or safety of Division staff or clients.
• If the misconduct harms the image and/or reputation of the agency in the community.