Second Error Rate Pilot Report
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Appendix E. West Virginia
A. Organizational Structure
The Office of Children and Family Policy of the West Virginia Department of Health and Human Resources administer the child care subsidy program, Adventures in Better Child Care (ABCC). The State contracts with six regional Child Care Resource and Referral agencies (CCR&R) to provide eligibility services to the State’s 55 counties. The CCR&R agencies also educate consumers on selecting appropriate child care and refer parents to providers in their area. In FY 2005, average per month assistance was provided through 3,370 providers to over 10,000 children in 5,900 families.
To allow families the choice to select the child care provider that best meets their needs, parents may use these care settings: the child’s home, registered family providers, registered informal family providers, registered relative family providers, certified family facilities, licensed child care centers, and unlicensed school-age child care programs.
B. Overview of the Child Care Eligibility Process
To be eligible for assistance, families must have an income below 150 percent of the Federal Poverty Level (FPL), be a resident of the State, a US citizen or a “qualified alien,” have children under the age of 13 (or age 19 for special care needs), be employed or in an approved education or training activity, and when applicable, cooperate with child support enforcement. Parents with earnings of less than 40 percent of Federal Poverty Level are exempt from fees. State foster children in approved foster homes are also exempt.
West Virginia’s subsidized child care program is a certificate system. Provider payments are made monthly and retrospectively. Payment for services includes a base rate for each type of care as well as incentive rates. Rates are based on the type of care, age of child, special needs of individual children, hours of care, nontraditional hours, and the accreditation status of the provider. Benefits are determined prospectively, i.e., for the upcoming month. Reauthorization of eligibility is every six months. A new certificate is issued at the six month mark following the completion of a “status check” (re-verification of need and income). Clients must report specific types of changes (identifying information, household composition, employment, need for job search, and provider changes) within five days of the change. With some exceptions for changes requiring verification, the change takes effect the following month.
C. Improper Payments
West Virginia defines an improper payment as a payment that should not have been made, or that was made in an incorrect amount due to worker error in determining and verifying eligibility and/or calculation and input of information in the Family and Children’s Tracking System (FACTS). Incorrect amounts include overpayments, underpayments, and inappropriate denials of payment. West Virginia identifies improper payments through a variety of methods detailed below.
- Use of information technology: The CCR&R agencies must use the State’s information system, FACTS, to determine financial eligibility and calculate payment amounts due. FACTS contains a number of edits that identify anomalies dealing with income, hours, child’s age, shift differential, duplicate eligibility, assessment periods, and multiple providers. All payments, while entered and approved by a supervisor at the local level, are approved by management at the Lead Agency level before issuance. This system of checks and balances also prevents improper payments.
- Documentation of Need and Eligibility Training: A Child Care Policy Specialist works with CCR&R agencies to identify problem policies, procedures and forms. Solutions are developed by committee and implemented in the CCR&R agencies through training and technical assistance provided quarterly.
- Quality Assurance Activities: Two Child Care Consultants provide support to the local CCR&R agencies through a quarterly sampling of cases to ensure compliance with policies and procedures. They also provide training in child care policy and use of the FACTS system
- Suspected Fraud Activities:
- If the CCR&R agency becomes aware that the client or provider is attempting to or has received payments to which they are not entitled, the worker must take corrective action to prevent further payments from occurring. The CCR&R agencies are required to cooperate with one another and share information, including payment forms, sign-in and sign-out sheets, documents, and records to reduce and prevent improper payments. When information is requested by other CCR&R agencies for this purpose, the CCR&R agencies shall respond within five days, unless extenuating circumstances exist.
- If over payment is due to error by the CCR&R agency or error on the part of the provider and the amount is less than $1,000, the CCR&R agency is responsible for negotiating the repayment. If the overpayment is $1,000 or greater and is due to misrepresentation by the client or provider, a referral is to be made to the Director of Investigation and Fraud Management.
D. Case Review Process
West Virginia made substantial modifications to the Record Review Worksheet, using check-off boxes, “Yes” and “No” fields, and coding to eliminate the need for extensive narrative recording. West Virginia completed the record review process and compiled the results prior to the site visit. The Review Team consisted of two Field Consultants and a Policy Specialist. All of the reviews occurred on site at the regional CCR&R agencies. The Review Team had already read 10 cases during one of its regular CCR&R audits. To improve the review process, the three reviewers completed several reviews jointly and consulted by telephone frequently. Because the Review Team reviewed the cases in regions, travel time was a considerable factor with several hours of driving time from one CCR&R agency to another.
E. Automation
The Families and Children Tracking System (FACTS) is a customized statewide automated case management system for all Child Welfare, Child Care, and Adult Service Programs. In August 2000, the State modified FACTS to include case management and payment functionality for the Child Care Program. This change fully implemented the transition of the contracted CCR&R agencies to an automated system for on-line and real time determination of eligibility for child care services and an automated determination for child care payments. The FACTS System utilizes information entered by the CCR&R staff to determine eligibility. This eliminates many errors, with the exception of those caused by faulty data entry. The system has payment controls for eligible days and for eligible children.
The FACTS system also provides staff with the capability of accessing the State’s TANF, Food Stamp and Medicaid system - RAPIDS. This allows additional verification of information provided in the eligibility process.
The major goals of the system are to improve the organization’s capacity for:
- Program compliance and planning;
- Accurate data collection for State and Federal reporting;
- Program quality assurance efforts;
- Case record management; and
- Information collection and analysis.
F. Next Steps
This section includes a summary of the West Virginia response to the error causes and corrective actions taken based on the finding of the pilot.
- West Virginia will conduct refresher policy training with the CCR&R directors. The directors will then provide the training to their staff. It is felt that by training the directors rather than the staff that the directors will become more involved in eligibility activities.
- Technical assistance staff will continue to perform random quarterly case audits. Prior to the pilot, the FACTS electronic record was the object of the review. An expanded review will now include the physical case record.
- CCR&R agencies must develop and implement Quality Assurance Plans. The plans will now require inclusion of payment accuracy initiatives if a CCR&R agency has an error rate that is above the State mean.
- Family child care providers must submit sign-in and sign-out sheets to verify attendance along with their billing forms. CCR&R agencies must audit billing forms and compare work and school schedules to times shown on the sheets to verify that the child care usage complies with time approved.
- Child care providers who submit incorrect or improper billing forms must attend a retraining session on proper billing procedures.
- Two State level Child Care Consultants will continue to sample CCR&R cases to ensure compliance with appropriate policies and provide training and technical assistance on policy, procedures, and the use of FACTS. The consultants also provide follow up to ensure the CCR&R corrective action plans are completed.
West Virginia Site Visit Participants
Charlie Young – Director, Bureau for Children and Families Policy
Kay Tilton, Director, Division of Early Care and Education
Deidre Craythorne, Policy Specialist, Division of Early Care and Education
Mary Hayden, Field Consultant, Division of Early Care and Education
Shannon Richards, HHR Specialist, FACTS Project
Raechelle Miller, HHR Specialist, FACTS Project
Judy Currry, Child Care Program Manager
Brenda Howell, Director, FACTS
Susan Richards, Director, Training
Exhibit E-1. West Virginia Record Review Worksheet
Client Study ID# _____________________ County: _______________________
Client FACTS ID# ____________________ Date Reviewed: ___ / ___ / ___
SECTION I. STATE CHILD CARE PROGRAM FORMS |
|||
|---|---|---|---|
| 100 APPLICATION FORMS ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) Determine presence, date, and completeness of required eligibility forms, may include: |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
(1) Signed and dated application (ECE-CC-1) or review form (DAY-0614) or signature page (DAY-0617) effective for 10-05 |
___ 0 |
___ 1 |
___ 2 |
(2) Child care parent services agreement (signed DAY 0162) |
___ 0 |
___ 1 |
___ 2 |
(3) Certificate (completed DAY-0176) |
___ 0 |
___ 1 |
___ 2 |
(4.a.) Provider invoice. (ECE-CC-10 A) |
___ 0 |
___ 1 |
___ 2 |
Is form completely filled out? |
___ 0 |
___ 1 |
___ 2 |
Are Sign In/Out Sheets attached? (if required) |
___ 0 |
___ 1 |
___ 2 |
Does Provider Signature match signature in provider file? |
___ 0 |
___ 1 |
___ 2 |
Do parent signatures match signatures in parent’s paper file? |
___ 0 |
___ 1 |
___ 2 |
Do the number of days billed match sign in/out sheet? |
___ 0 |
___ 1 |
___ 2 |
Does sign in/out sheet match parent’s work/school schedule in FACTS? |
___ 0 |
___ 1 |
___ 2 |
Was payment entered correctly? |
___ 0 |
___ 1 |
___ 2 |
Was payment form signed by worker? |
___ 0 |
___ 1 |
___ 2 |
Was form signed by approving supervisor? |
___ 0 |
___ 1 |
___ 2 |
(4.b.) Specify conditions of dollar error, including |
___ 0 |
___ 1 |
___ 2 |
(1) form expired- (expired certificate-DAY-0176) |
___ 0 |
___ 1 |
___ 2 |
(2) No application form (signed ECE-CC-1 /DAY-0614 or DAY-0617) |
___ 0 |
___ 1 |
___ 2 |
(3) No documentation of income and work hours. ( copies of pay stubs or ECE-CC-1B or 1C, if self-employed-check application form for work hours and check the employment screen for all adults in FACTS) |
___ 0 |
___ 1 |
___ 2 |
FINDINGS (3) |
|||
SECTION II. PRIORITY GROUP PLACEMENT |
|||
|---|---|---|---|
| 200 PRIORITY GROUP PLACEMENT ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) Determine if client meets criteria of State-designated priority groups, e.g., ( West Virginia’s State plan only addresses priorities for foster and adoptive parents, since we operate without a waiting list, so we changed the priorities list.) |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
(1) foster parents (check general information screen to see if role is a foster parent and if child is checked as a foster child. If so, check finance screen to make sure foster parent income was disregarded) |
___ 0 |
___ 1 |
___ 2 |
| (2) adoptive parent (check general information screen to see if role in case is adoptive parent. If so, check finance screen to make sure adoption subsidy amounts were disregarded) | ___ 0 |
___ 1 |
___ 2 |
FINDINGS (3) |
|||
SECTION III. General Program Requirements |
|||
|---|---|---|---|
| 300 QUALIFYING HEAD OF HOUSEHOLD ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) Determine if client meets parent definition (parent means a parent by blood, marriage or adoption and also means a legal guardian, or other person standing in loco parentis), e.g., (check general information screen to see if the client is one of the following:) |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
(1) parent |
___ 0 |
___ 1 |
___ 2 |
| (2) step-parent | ___ 0 |
___ 1 |
___ 2 |
| (3) legal guardian | ___ 0 |
___ 1 |
___ 2 |
| (4) caretaker | ___ 0 |
___ 1 |
___ 2 |
| (5) relative | |||
FINDINGS (3) |
|||
| 310 RESIDENCY ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) Determine if (WV has a statewide system, so we are checking only if the client is a resident of the State. We also added “ is the child a US citizen or a qualified eligible alien) |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
Client is a resident of the State (check address on address screen) |
___ 0 |
___ 1 |
___ 2 |
| Is child a US citizen? ( Check race/ethnicity screen) | ___ 0 |
___ 1 |
___ 2 |
| Is Child a qualified eligible alien? ( Check race/ethnicity screen) | ___ 0 |
___ 1 |
___ 2 |
Client is a resident of the county and for what duration. There is an agreement regarding eligibility among counties. |
___ 0 |
___ 1 |
___ 2 |
FINDINGS (3) |
|||
| 320 HOUSEHOLD MEMBERS ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) To receive services a child's parent or parents must be |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
Working (check employment screen and finances screen to see if work has been verified or check pay stubs in record) |
___ 0 |
___ 1 |
___ 2 |
| Attending a job training or educational program. ( check education screen and see if and how education was verified- check paper file to see if verification is in file) | ___ 0 |
___ 1 |
___ 2 |
FINDINGS (3) |
|||
| 330 QUALIFYING CHILD ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) Determine if child (ren) is eligible for services, including (WV does not pay for children in foster care unless the foster parents are working/attending school, so we changed this to “for protective services reasons) |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
(1) younger than 13 years (check date of birth on client general information screen –if over 13, see #2) |
___ 0 |
___ 1 |
___ 2 |
| (2) younger than 18 years and physically or mentally incapable of caring for himself or herself, or under court supervision ( see if verification of physical or mental incapacity or court supervision is on file in record) | ___ 0 |
___ 1 |
___ 2 |
| (3) in child care for protective services reasons (Check in Child Care assessment to see if CPS safety or treatment plan is checked. Is a copy of safety or treatment plan or a Safety First Plan on file? | ___ 0 |
___ 1 |
___ 2 |
FINDINGS (3) |
|||
| 340 QUALIFYING CARE ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
Determine hours authorized. (check employment/education screens and services to see if hours of care are entered and consistent- If not, exceptions are noted on contacts or paper record) |
___ 0 |
___ 1 |
___ 2 |
| Determine required number of hours of care during authorized schedule. (Check to see if number of hours authorized matches pay stubs, school schedules or other documentation) | ___ 0 |
___ 1 |
___ 2 |
FINDINGS (3) |
|||
| 350 QUALIFYING PROVIDER ARRANGEMENT ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) Determine if services are provided within a legally operating provider type. (Check the provider record status screen to see if a valid license or certificate was in effect as of October 2005 ) |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
| Center-based child care provider | ___ 0 |
___ 1 |
___ 2 |
| group home child care provider | ___ 0 |
___ 1 |
___ 2 |
| family child care provider | ___ 0 |
___ 1 |
___ 2 |
| an in-home child care provider | ___ 0 |
___ 1 |
___ 2 |
| other provider of child care services for compensation that is licensed, regulated, or registered under applicable State or local law, including informal, relative or legally operating school-age child care? | ___ 0 |
___ 1 |
___ 2 |
FINDINGS (3) |
|||
| 360 PROVIDER REQUIREMENTS ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) If provider status screen shows a valid license, regulatory requirements are met, so this is a duplicate question for WV. |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
| Determine if regulatory requirements are met. Regulatory requirements means requirements necessary for a provider to legally provide child care services in a State or locality, including registration requirements established under State, local, or tribal law. | |||
FINDINGS (3) |
|||
SECTION IV. INCOME AND PAYMENTS |
|||
|---|---|---|---|
| 400 INCOME ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) Describe income documentation verification for each member of the household. Specify time period and all income to be considered, e.g., based on 4 weeks prior to application: Collect the following data: (WV does not require reporting of changes in income during the six month period; b. food stamps are not considered income; and c. loss of income does not need to be reported.) |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
| (1.) head of household employment income (Check record to see if pay stubs or other acceptable income verification is on file that document the 1-mo. period prior to review or application. Verification can be any of the below) | ___ 0 |
___ 1 |
___ 2 |
(1.a.) 2 pay stubs if paid bi-weekly or twice monthly, 4 pay stubs if paid weekly |
___ 0 |
___ 1 |
___ 2 |
(1.b.) Three months of pay stubs if income fluctuates |
___ 0 |
___ 1 |
___ 2 |
(1.c.) New Employment Verification Letter |
___ 0 |
___ 1 |
___ 2 |
(1.d.) Self Employment income verification (must also have copy of applicable business licenses, Registration and Tax Return- if available) |
___ 0 |
___ 1 |
___ 2 |
(2) spouse employment income (Check record to see if pay stubs or other acceptable income verification is on file that document a 1-mo. Period) |
___ 0 |
___ 1 |
___ 2 |
(2.a.) 2 pay stubs if paid bi-weekly or twice monthly, 4 pay stubs if paid weekly |
___ 0 |
___ 1 |
___ 2 |
(2.b.) Three months of pay stubs if income fluctuates |
___ 0 |
___ 1 |
___ 2 |
(2.c.) New Employment Verification Letter |
___ 0 |
___ 1 |
___ 2 |
(2.d.) Self Employment income verification (must also have Copy of business licenses/Registration and Tax Return- if available) |
___ 0 |
___ 1 |
___ 2 |
| (3) any changes in income reported West Virginia does not require reporting of income changes within the eligibility period, therefore there would be no error within this data element. | |||
| (4) income during job training for parent/caregiver | ___ 0 |
___ 1 |
___ 2 |
| (5) child support, if included as part of income (check FACTS or application to see if child support is verified) | ___ 0 |
___ 1 |
___ 2 |
| (6) Food Stamps, if included as part of income West Virginia does not count food stamps as income, therefore there would be no error within this data element. | |||
| (7) loss of income during eligibility period. West Virginia does not require reporting of income changes within the eligibility period therefore there would be no error within this data element. | |||
| (8) Other countable income documented (SSI, TANF, Spousal Support, gifts, etc.) | ___ 0 |
___ 1 |
___ 2 |
FINDINGS (3) |
|||
| 410 INCOME ELIGIBILITY ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) (WV’s automated system calculates income and compares it with the sliding fee scale, so we opted to check for mathematical errors in averaging income or data entry.) |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
| Determine if household income meets State requirements (Check income verification in paper record against that in FACTS to see if any mathematical or data entry errors were made by the case worker?) | ___ 0 |
___ 1 |
___ 2 |
FINDINGS (3) |
|||
| 420 PAYMENTS, GENERAL ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) |
ANALYSIS OF CASE RECORD (2) | ||
| No Error | Client Error | Agency Error |
|
| Determine if payments were made. A sliding fee scale based on income and the size of the family and may be based on other factors as appropriate. West Virginia’s pilot sample consists only of clients for whom a payment was made for the service month of October 2005, therefore there are no errors possible for this data element. | |||
FINDINGS (3) |
|||
| 430 PAYMENTS, COMPUTATIONS ELEMENTS OF ELIGIBILITY & PAYMENT DETERMINATION (1) |
ANALYSIS OF CASE RECORD (2) | ||
No Error |
Client Error |
Agency |
|
| 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 |
___ 1 |
___ 2 |
FINDINGS (3) |
|||
| Data Summary | |
| State | West Virginia |
| County | |
| Child ID | |
| Study Period Month | |
| One or more eligibility errors during pilot period 0= no errors, 1= one or more errors |
|
| Total amount of improper payment during review month | |
| Total Payment Amount during review month (shown in FACTS Client Payment Information screen) | |
Appendix F. Record Review Worksheet Template >>
June, 2007