Jay Hershberg

I would like to comment on the Eligibility Redermination During a Benefit Year as discussed on page 51218 (August 17, 2011). It states that "primary reliance on individuals would eliminate much of the administrative burden associated with periodic electronic data matching and any follow-uo with individuals." Where there is the potential of fraud, "administrative burden" should be of secondary importance and safeguarding public funds should be the primary objective. For example. Person XYZ indicates that he/she receives UI benefits. What is wrong with periodically checking with a state UI office to see if XYZ is still receiving UI benefits. If XYZ's name does not appear on the UI roles, then XYZ may be working and either is no longer eligible for public subsidies or is entitled to a lower subsidy. If XYZ is working, then the Wage Reporting Data maintained by a state could be checked with respect to income that XYZ may earn. Finally, people are routinely incarcerated in state or federal prisons. What is wrong with receiving information from the correctional authorities as to who was incarcerated during the last month or the past quarter. One can now see the headlines in local newspapers, XYZ still continues to receive health insurance subsidies through the exchanges as the exchanges do not periodically check with state and federal officials as to who has been incarcerated. According to the exchange, "we want to minimize the administrative burden associated with periodic electronic data matching and any follow-up with individuals."