Second Error Rate Pilot Report
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Appendix D. Oregon
A. Organizational Structure
The Child Care Division (CCD), which administers the child care program, is within the Oregon Employment Department. CCD, in partnership with Oregon’s child care community, sets the State level priorities for spending on child care services. It contracts with other agencies and organizations to provide specific services. One of those agencies is the Oregon Department of Human Services (DHS). DHS manages the integrated child care subsidy program for children of low-income working parents and post secondary student parents.
There are three types of care in the DHS child care subsidy program. Through Certified Care the CCD certifies approximately 1000 child care centers and 250 certified family homes. Centers care for more than 13 children in a non-residential facility. Certified family homes can care for up to 16 children, including the provider’s own children in a residential setting. Registered Care is provided through approximately 5000 family child care businesses. These providers are registered for two years at a time and can care for up to 10 children, including their own, in their own home. Lastly, some child care is exempt from regulation, including providers caring for three or fewer children, providers caring for children from only one family, school district programs, care provided in the child’s home or by a relative of the child, and limited duration programs such as summer camps.
In addition, CCD provides child care funding to over 200 community-based organizations that serve the following high-risk families, including:
- Teen parents participating in approved high school or GED completion programs;
- Parents participating in State-approved substance abuse programs;
- Migrant and seasonal farm workers; and
- Parents who have children with special needs.
In FY2005, average per month assistance was provided through 13,826 providers to over 21,300 children in 10,700 families. Approximately 78 percent of the children were served in family home settings.
B. Overview of the Child Care Eligibility Process
The CCD child care subsidy programs help low-income families achieve self-sufficiency by providing the child care assistance necessary for employment or participation in other activities that promote self-sufficiency. Several types of child care assistance are combined to form the Integrated Child Care Program (ICC). They are:
- Employment Related Day Care (ERDC) assists low-income working parents. Parents in this program pay a share of the child care;
- Temporary Assistance to Needy Families (TANF) child care assistance assists low-income working parents who are receiving TANF cash benefits; and
- JOBS child care assists parents receiving TANF or Food Stamps pay for child care so they can participate in DHS-approved self-sufficiency activities.
Reauthorization of eligibility (Anticipating with Periodic Review/APR) varies in length. The primary determinant of the length of the APR period is the projected stability of the client’s income. The most common period is six months. Clients must report within 10 days those changes that are expected to continue in either the source of income or rate of pay. The month the change is effective depends on when during the previous month the report is made and whether the change results in a significant increase or decrease in the co-pay.
C. Improper Payment Process
Oregon defines an improper payment as one made for care that was not provided or one made to an ineligible provider or on behalf of a client who was not eligible for the total amount paid. Oregon identifies improper payments through a variety of methods, including:
- A monthly desk audit of 200 randomly selected billing forms;
- A monthly match with TANF, Food Stamps, and Medicaid to identify ineligible providers and questionable child care payments;
- Reports via the hot line number included in notices sent to clients and providers; and
- Monthly record reviews of 5000 Food Stamp cases. Approximately 95 percent of child care recipients receive Food Stamps. In these cases both the Food Stamp and child care subsidy eligibility is subject to review. Oregon plans on expanding a database that currently contains the Food Stamp review information to capture Child Care review results.
1. Suspected Fraud
Within the DHS Office of Payment Accuracy, three staff members in the Overpayment Writing Unit are responsible for completing the calculation of child care overpayments. Legal action may result in addition to collection of the overpayment. The Overpayment Writing Unit may refer cases to the Investigations Unit to establish intent based on a pattern of behavior, clear falsification, or behavior contrary to reasonable expectation.
Client fraud occurs when a client attempts to establish eligibility, increase the amount of assistance, or prevent a reduction by:
- Intentionally making a false or misleading statement;
- Misrepresenting, concealing, or withholding facts; or
- Intentionally taking or failing to take an action, such as leaving a child in care when not participating in activities authorized by DHS.
- Bills for more child care than actually provided, such as duplicate billing;
- Collects payment directly from a client after the DHS's payment for its services has been garnished or after overpayment recovery actions have reduced the amount paid;
- Fails to list required persons on the provider application to participate in the subsidy program; and
- Applies for participation on behalf of another provider who would not be eligible to participate.
In situations of a closed case, the Overpayment Writing Unit sends the customer a series of recovery notices. In instances where there is either no response to the notices or no payment, the case is referred to the Department of Revenue which uses tax intercepts and private collection action to recover overpayments.
D. Case Reviews
Oregon made very few modifications to the Record Review Worksheet template. The Review Team consisted of five Quality Control (QC) Staff Persons who have responsibility for TANF and FS case reviews. Following training on child care policy and procedures, the Review Team reviewed the cases centrally. The Project Team Leader reviewed all cases with errors a second time and discovered that the Review Team went beyond the level of a desk audit, expecting greater detail in documentation than what had been anticipated or required of the child care review process. As a result, the Review Team reviewed a subset of cases a third time and changed some review results accordingly.
E. Automation
DHS uses several automated systems in support of the child care program. The Client Maintenance System (CMS) is used in determining eligibility for TANF, Medicaid, Food Stamps, and ERDC. The Service Authorization System is the subsidy payment system for ERDC cases. Both systems contain various edits, tables, and charts to support payment accuracy. The ERDC application process includes a match with other DHS systems as well as child support, Employment Department wage and unemployment records, and the Social Security Benefit system. CMS calculates the provider payment based on the family’s co-pay, the provider’s usual charge, hours authorized and billed, age of the child(ren), type of care, and provider’s zip code.
F. Next Steps
After reviewing the improper payment data Oregon listed the following corrective action strategies:
- Currently, there is no process for ensuring that income errors identified in Food Stamp cases are dealt with in the companion Employment Related Day Care (ERDC) case. Oregon plans to modify the Food Stamp targeted review process and database that contains review information to ensure that income errors identified in any Food Stamp case are corrected in companion ERDC case.
- Each year, the Oregon Department of Human Services (DHS) conducts in all areas of the State a series of “Accuracy Summits” that focus on techniques to reduce errors in the Food Stamp program. DHS plans to include workshops to improve ERDC accuracy in the next series of summits that begins in July 2007.
- DHS produces a monthly newsletter that focuses on techniques to reduce Food Stamp errors. The newsletter will now include information about other programs, including ERDC. A recent newsletter included an article about correctly determining co-pay amounts in ERDC cases. Future newsletters will contain information about ERDC payment accuracy, including an article about the results of the pilot review.
- The Governor’s recommended budget for the next biennium includes increased funding to build on the efforts that have worked to improve accuracy in the Food Stamp program. This funding would allow DHS to extend Targeted Review outcome measures to the Child Care programs in local offices by FY2008. This comprehensive Program Integrity infrastructure provides a method for gathering timely, local performance data and will enable the Department to develop corrective action measures.
Oregon Site Visit Participants
Mark Anderson – Manager, Child Care and Refugee Programs
Cassie Day – Program Analyst/Trainer CAF Child Care Unit
Rhonda Prodzinski – Program Analyst CAF Child Care Unit
Carol Bennett – Overpayment Writer CAF
Lisa Stegman – Business Analyst CAF Program Systems Support
Peggy Cain – Program Trainer
Kathy Van-Brocklin – Operations Manager Direct Pay Unit
Janet Dornhecker – Program Manager CAF Food Stamp Reinvestment Unit
Robert O’Shea – Manager, Overpayment Writing Unit
Chris Bravo – Investigator
Exhibit D-1. Oregon Record Review Worksheet
CLIENT ID# |
STATE: Oregon |
COUNTY: |
DATE: |
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ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) |
ANALYSIS OF CASE RECORD (2) |
FINDINGS (3) |
RESULTS (4) |
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SECTION I. STATE CHILD CARE PROGRAM FORMS |
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100 APPLICATION/RE-DETERMINATION FORMS |
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100 RESULTS |
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Determine presence, date, and completeness of required eligibility forms, may include (1) signed and dated application form or (2) narration from case manager for case(s) transitioning from TANF to Employment related Day Care. Specify conditions of dollar error, including (1) incomplete application after 45 day processing time frame, (2) no application form, and (3) no narration regarding transition or extension of application processing time frame. |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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SECTION II. PRIORITY GROUP PLACEMENT |
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200 PRIORITY GROUP PLACEMENT |
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200 RESULTS |
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N/A |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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SECTION III. GENERAL PROGRAM REQUIREMENTS |
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300 QUALIFYING CARETAKER |
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300 RESULTS |
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Determine if client meets definition of caretaker. A caretaker is the person, regardless of age, who is responsible for the care, control and supervision of the dependent child. The caretaker does not have to be related to the child. Caretaker status ends when the responsibility for care, control and supervision is given to another person for 30 days or more. |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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310 RESIDENCY |
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310 RESULTS |
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Determine if client is a resident of the State of Oregon. |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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320 ELIGIBILITY GROUPS |
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320 RESULTS |
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Requirement for caretaker to be employed or participating in DHS-approved self-sufficiency activities. The ERDC program is used only for clients not receiving TANF, unless the adult is not included in the TANF benefit group |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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330 QUALIFYING CHILD |
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330 RESULTS |
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Determine if child(ren) is eligible for services, including (1) younger than 12 years, (2) younger than 18 years and physically or mentally incapable of caring for himself or herself. Need for care of older children must be documented. |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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340 QUALIFYING CHILD CARE NEED/HOURS |
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340 RESULTS |
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Determine if there is a child care need and authorized hours. Determine if the co-pay is less than the child care subsidy amount. |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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350 LISTABLE PROVIDER |
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350 RESULTS |
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Determine if provider of child care service(s) is a listed or in the process of becoming listed through the Department of Human Services |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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360 PROVIDER REQUIREMENTS |
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360 RESULTS |
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N/A |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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SECTION IV. INCOME AND PAYMENTS |
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400 INCOME |
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400 RESULTS |
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Describe income verification for each member of the filing group. Specify time period and all income, earned or unearned, to be considered. If historical income is not representative of future income review explanation of how anticipated income was calculated. |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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410 INCOME ELIGIBILITY |
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410 RESULTS |
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Determine if income meets State requirements (e.g., gross income must be within 150% of the Federal Poverty Level). |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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420 PAYMENTS, GENERAL |
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420 RESULTS |
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Determine if the co-pay requirement was met. |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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430 PAYMENTS/COMPUTATIONS |
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430 RESULTS |
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Determine difference in dollar amount of child care benefits authorized versus the amount that should have been authorized--indicate if it is an overpayment or underpayment. |
0 |
No Error |
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1 |
Client Error |
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2 |
Agency Error |
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June, 2007