How Medicaid and SNAP Fraud Is Detected in New York: The Databases HRA and DSS Cross-Check

Most Medicaid and SNAP fraud cases in New York begin with a computer match, not a tip. The agency that approved your benefits compares what you reported on your application or recertification against wage reports, tax data, Social Security records, DMV files and other databases. When the records disagree, a referral is generated. In New York City the referral goes to the Human Resources Administration's Bureau of Fraud Investigation (BFI). Outside the five boroughs it goes to the county Department of Social Services fraud unit, working under rules set by the State Office of Temporary and Disability Assistance (OTDA). This page explains which matches run, what they catch and how far back they reach.

Who Runs the Investigation Depends on Where You Live

New York administers SNAP and most Medicaid through local social services districts. The detection machinery is the same statewide, but the office you will hear from is not.

• New York City: HRA's Bureau of Fraud Investigation handles SNAP, Cash Assistance and Medicaid recipient cases for all five boroughs. BFI investigators review computer referrals, request records, schedule interviews and refer larger cases to the borough District Attorney.
• Nassau, Suffolk, Westchester and upstate counties: Each county DSS has its own fraud or special investigations unit. These units run the Front End Detection System (FEDS) required by 18 NYCRR Part 348, which screens applications for fraud indicators before benefits are approved, and they handle post-approval matches referred through the state Welfare Management System.
• Medicaid through NY State of Health: Households that enrolled in Medicaid through the state marketplace are verified through the federal data services hub. Problem cases can be referred to the Office of the Medicaid Inspector General (OMIG) or back to the local district.

The county-versus-city distinction matters for timing. County units are smaller and often move faster from match to interview. BFI handles a far larger volume and its letters can arrive a year or more after the match that generated them.

The Named Matching Programs

Federal law requires every state to run an Income and Eligibility Verification System (IEVS), 42 U.S.C. § 1320b-7, for SNAP, Medicaid and cash assistance. New York satisfies that mandate with a set of recurring matches that produce reports for eligibility workers and fraud investigators. The ones that generate most referrals are:

• Resource File Integration (RFI): The state's consolidated match report. It pulls New York State Wage Reporting System data, unemployment insurance payments, Social Security and SSI benefit amounts and IRS unearned income (interest, dividends, 1099 income) into one printout tied to the case. An RFI hit showing wages for a household member who was reported as unemployed is the single most common starting point for a BFI case.
• New York State Wage Reporting System: Every employer in New York files quarterly wage reports listing each employee's gross wages. The match runs by Social Security number. It catches W-2 employment that was not reported, including jobs held by a spouse or adult child in the household.
• National Directory of New Hires (NDNH): A federal database of new-hire reports, quarterly wages and unemployment claims from all states. It catches employment that began after the last recertification and employment in New Jersey, Connecticut and other states that the New York wage match would miss.
• PARIS (Public Assistance Reporting Information System): A quarterly interstate match run by the federal Administration for Children and Families. It flags people receiving SNAP or Medicaid in two states at once, and it matches against Veterans Affairs and federal civilian payroll files.
• Social Security Administration prisoner and death matches: SSA's Prisoner Update Processing System and the Death Master File identify household members who are incarcerated or deceased but still counted in the SNAP household.
• Asset Verification System (AVS): For Medicaid applicants and recipients who are 65 or older, blind or disabled, New York uses an electronic query to banks and financial institutions to find accounts, including closed accounts and accounts the applicant did not list. AVS does not apply to SNAP.
• Department of Taxation and Finance: State personal income tax returns, filing status, dependents claimed and business registrations. A return filed jointly with a spouse who is not in the SNAP household is a standard referral.
• Department of Motor Vehicles: License and registration addresses and vehicle ownership. An address mismatch is a lead, not proof of anything, but investigators use it to question where the household lives.
• SAVE (Systematic Alien Verification for Entitlements): A Department of Homeland Security database used to confirm immigration status for non-citizen household members.
• Child support records: The state Office of Child Support Services holds payment histories and the non-custodial parent's employer information, both of which are compared against the household's reported income and composition.

One tool that is often assumed to still exist does not. New York stopped finger-imaging SNAP applicants in 2012. Duplicate-participation checks now run through PARIS and Social Security number matching rather than fingerprints.

Records Investigators Pull After the Match

The automated matches above generate the referral. Once an investigator opens the file, the search widens to records that are not matched automatically but are available on request or by subpoena:

• Bank statements, obtained by subpoena or by a records request to the bank once an account is identified.
• Employer payroll records and personnel files, including the address and emergency contact the employee gave the employer.
• School enrollment, emergency contact and address records from the New York City Department of Education or a suburban district, which investigators use to test claims about which parent lives with the children.
• NYCHA, Section 8 and Homes and Community Renewal tenant files, which list every authorized occupant of the apartment.
• Utility accounts, cable and internet accounts, and the names on them.
• Marriage, divorce and birth records from the Department of Health or the NYC Office of Vital Records.
• Property records from ACRIS in New York City or the county clerk elsewhere.
• Passport and travel records in cases where residence outside the United States is suspected.
• Social media profiles, which investigators review for evidence of employment, cohabitation or residence.

Investigators do not need a warrant for most of these records. The application you signed authorized the agency to verify the information you provided, and the agency has standing data-sharing agreements with the sources listed above.

The Discrepancies That Most Often Become Cases

• Wages on the RFI or NDNH report for a household member who was listed as having no income.
• A joint state tax return with a spouse the applicant reported as absent from the home.
• A child claimed as a dependent on the tax return of a parent who is not in the SNAP household.
• Benefits open in two states at the same time on the PARIS match.
• Self-employment or business registration with the Department of State or Department of Taxation and Finance that was not disclosed.
• A bank account found through AVS that was not listed on a Medicaid application for an applicant over 65.
• A household member who is incarcerated or deceased but still counted in the SNAP budget.
• A DMV address, lease or NYCHA tenant file that places the applicant at a different residence, or places an additional adult in the home.
• Unemployment insurance or workers' compensation payments that do not appear on the recertification.

A note on vehicles and assets. New York uses broad-based categorical eligibility for SNAP, so most SNAP households in New York have no resource test at all. A car in your name does not by itself create a SNAP overpayment. Vehicle and property records matter in SNAP cases because of what they say about residence and household composition, and because they can point to income that supports a lifestyle the reported budget would not. Resource limits do still apply to Medicaid for applicants who are 65 or older, blind or disabled, which is why AVS findings carry more weight in those cases.

SNAP and Medicaid Are Matched Against Different Household Rules

The same facts can be a problem for one program and not the other. SNAP defines a household as the people who purchase and prepare food together, 7 CFR 273.1. Medicaid for most adults and children uses a tax-based household, so a spouse or dependent on your return is generally in your Medicaid household even if you say you live apart. A joint tax return therefore hits a Medicaid case harder than a SNAP case. Cases built on a claimed separation turn on these rules, and we cover them on our page about separation claims for food stamps and Medicaid.

Tips Still Happen, but Matching Produces the Volume

HRA and OTDA both operate fraud hotlines and investigators do follow up on complaints from former partners, landlords and neighbors. In our experience those cases are a small share of the files. The RFI and NDNH reports run every quarter on every open case, which is why a household can be flagged years into a benefit period without anyone having complained.

Case Patterns We See

The following are composites of recurring fact patterns in files we have handled. They are described to show how detection works, not to suggest how any particular case will end.

• Spouse's W-2 job on the wage match: A Brooklyn SNAP and Medicaid household listed the husband as unemployed. He took a W-2 position mid-year. The employer's quarterly wage report appeared on the RFI, and BFI opened a case for the full period from the start date to the next recertification. Our work in a case like this focuses on when the job actually began, whether the household had a reporting obligation under its reporting rules at that point, and whether the overpayment was computed on gross wages that include periods before the duty to report arose.
• Claimed separation contradicted by school and DMV records: A Queens mother reported that the children's father did not live in the home. The investigator obtained the Department of Education emergency contact card listing the father at the same address, a DMV registration for a car garaged at the address in his name, and a joint tax return. The question in a file like this is whether the agency can prove he was a member of the household under the SNAP purchase-and-prepare rule, as opposed to a parent who kept a mailing address and visited. Those are different facts with different consequences.
• Medicaid asset case from AVS on a county application: A Nassau County applicant over 65 applied for community Medicaid and listed one checking account. The AVS query returned a second account at a different bank with a balance above the resource limit for part of the look-back period. The county DSS sent a notice seeking recovery under Social Services Law § 145-b. The defense in that setting is about ownership (accounts titled for convenience versus accounts the applicant controlled), the months in which the resource limit was actually exceeded, and the difference between an inadvertent omission and an intentional misstatement.

What the HRA Bureau of Fraud Investigation Letter Looks Like

A BFI letter is printed on HRA letterhead, identifies a case number and the name of the assigned investigator, and asks you to appear for an interview on a stated date. It typically lists documents to bring: photo identification, your lease, pay stubs for all household members, bank statements for a stated period, and tax returns for stated years. The letter usually does not say what match triggered the review. The list of documents requested is the best clue. A request for a spouse's pay stubs means a wage match; a request for school records means a household composition question; a request for bank statements on a Medicaid case means an AVS or IRS unearned-income hit.

County DSS letters are similar in form. Some counties send a questionnaire to complete and return before any interview is scheduled. What to do after the letter arrives, how the interview is used, and how an Administrative Disqualification Hearing proceeds are covered separately on our administrative disqualification hearing page. Our first-offense food stamp fraud page covers disqualification periods, repayment and criminal referral for a first case.

How Far Back They Look

The review period in most files runs from the date the discrepancy began to the date it was discovered or the next recertification, whichever is earlier. There are limits.

• SNAP claims: Federal rules at 7 CFR 273.18(c) govern how the overpayment is calculated. For an intentional program violation or an inadvertent household error, the agency must go back at least twelve months before discovery, and it may not include any month more than six years before the agency became aware of the overpayment. The six-year cap is often overlooked in BFI claim letters that reach back to the start of a long-running case.
• Intentional Program Violation findings: IPV disqualification is governed by 7 CFR 273.16 and 18 NYCRR Part 359. The disqualification periods are 12 months for a first IPV, 24 months for a second and permanent for a third, 7 CFR 273.16(b). The agency must prove the violation by clear and convincing evidence at an Administrative Disqualification Hearing, 7 CFR 273.16(e)(6).
• Civil recovery: Social Services Law § 145-b lets a social services district sue for three times the amount obtained by a false statement. The applicable limitations period under the CPLR depends on the theory of recovery, and that question affects how many years of alleged overpayment the district can reach in court.
• Criminal charges: Welfare fraud under Penal Law Article 158 is graded by dollar amount: fifth degree (a class A misdemeanor) with no dollar threshold, Penal Law § 158.05; fourth degree (class E felony) over $1,000, § 158.10; third degree (class D felony) over $3,000, § 158.15; second degree (class C felony) over $50,000, § 158.20; first degree (class B felony) over $1,000,000, § 158.25. Prosecutors also charge Offering a False Instrument for Filing in the First Degree, Penal Law § 175.35, for signed applications containing false statements, and grand larceny under Penal Law Article 155. Under CPL § 30.10 the limitations period is five years for felonies and two years for misdemeanors, running from each false filing or each benefit issuance depending on the charge.

Medicaid recipient overpayments are not governed by 7 CFR 273.18. They are pursued under Social Services Law §§ 145-b and 366 and by OMIG, and there is no Medicaid equivalent of the SNAP IPV disqualification period.

Why the Match Is Not the End of the Analysis

A computer match establishes that two databases disagree. It does not establish an overpayment, and it does not establish intent. Wage reports can be attributed to the wrong Social Security number. A spouse can be on a tax return and genuinely live elsewhere. A child can be enrolled in a school near a grandparent's apartment. An AVS account can belong to an adult child who added a parent's name for convenience. The agency has to convert the match into a budget showing what the household should have received each month, and for an IPV finding or a criminal charge it has to prove that the misstatement was knowing. Those are the points at which a defense is built, and they are the reason the records should be reviewed by counsel before anyone sits for an interview.

Frequently Asked Questions

Does HRA check tax returns?

Yes. HRA and county districts receive state Department of Taxation and Finance return data and IRS unearned income data through IEVS. Filing status, dependents claimed and reported income are all compared against the case.

Can SNAP see my bank account?

Not automatically. New York does not run a bank match on SNAP cases, and most New York SNAP households have no resource test. An investigator can request or subpoena bank statements once a case is open, and interest or dividend income from an account will appear on the IRS unearned income match. For Medicaid applicants who are 65 or older, blind or disabled, the Asset Verification System does query banks directly.

Does my DMV address matter for food stamps?

It is one of the records compared. A DMV address that differs from the SNAP case address is a lead for the investigator, who will then look for a lease, utility bills and other records to decide where the household actually lives and who lives there. The DMV address alone is not proof of residence.

How far back do they look?

Typically to the start of the discrepancy. For SNAP overpayments, federal rules bar the agency from counting any month more than six years before the overpayment was discovered. Criminal charges are limited to five years for felonies and two years for misdemeanors under CPL § 30.10. Medicaid recovery has no fixed federal cap and depends on the CPLR limitations period for the recovery theory used.

Will I know what triggered the investigation?

The letter usually does not say. The documents requested indicate the type of match. Counsel can request the agency's case record, including the RFI or match report, before the interview.

I own a store that accepts EBT. Is this page for me?

No. Retailer trafficking and disqualification cases are brought by USDA Food and Nutrition Service under 7 CFR Part 278, not by HRA or county DSS. See our page for USDA SNAP retailer violations.

Related Pages

• Medicaid and SNAP fraud defense in New York: overview of the practice and links to each stage of a case.
• Administrative Disqualification Hearings: the interview, the hearing and the IPV standard of proof.
• First-offense food stamp fraud: disqualification periods, repayment agreements and criminal referral.
• Separation claims for food stamps and Medicaid: household composition rules and how separation cases are proven.

About the Author

This page was written by Albert Goodwin, a New York attorney whose practice includes defense of SNAP, Cash Assistance and Medicaid recipient investigations before HRA's Bureau of Fraud Investigation, county social services districts and the OTDA Office of Administrative Hearings. Last reviewed: June 2025.