Measuring Improper Authorizations for Payment in the Child Care Program:
Improper Authorization for Payment Data Collection Instructions [Approved August 31, 2007]
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V. CUSTOMIZING THE RECORD REVIEW WORKSHEET
States may customize a Record Review Worksheet (Attachment 1) based on the standards contained in their statutes, applicable regulations and policies in effect at the time of eligibility determination. The worksheet provides a standardized format to assess and record the information and documentation existing in the case record needed to determine if the child was eligible and authorized to receive the correct subsidy amount. The purpose of customizing the worksheet is to assist case record reviewers in documenting information during case record reviews. States may customize by adding, in Column 1, specific State requirements and, in Column 2, features that assist reviewers in summarizing their analysis. When completed, the customized Record Review Worksheet:
- Identifies the status of each element of eligibility and benefit calculation, based on the State plan and other State rules and procedures, as documented by the Lead Agency;
- Determines the amount of the subsidy payments authorized for the sample month; and
- Identifies any resulting errors.
- Review laws, regulations and policies regarding each element (application forms, qualifying head of household, etc.);
- Review the information on the Record Review Worksheet template (Attachment 1); and
- Based upon this review, develop a list of the appropriate State requirements for each element in Column 1 of the Record Review Worksheet and develop a list of features to assist reviewers in summarizing their analysis in Column 2.
States make no changes to Columns 3 or 4. Because reviewers use Column 3 for narrative purposes, there is no reason to customize that Column. The format for Column 4 must be retained in order to capture all of the information required in the Data Entry Form (Attachment 2).
States provide training and instruction to reviewers. This will assist States in certifying that the review process is consistent with their policies and ensuring consistency within the State in interpretation of what is an error. Using States’ customized Record Review Worksheet as a guide, reviewers conduct case record reviews of a random sample of cases that were authorized to receive a child care payment during the review period.
States must have ACF approval of revisions to the Record Review Worksheet template prior to using it in the record review. States send customized Record Review Worksheets to the Child Care Manager in the ACF Regional Office no later than the end of December of the calendar year prior to the reporting year. Approvals will be based primarily on review of the State plan but will include other formal State documents, such as State law, State regulations and State policies. States also assure and certify in the State Improper Authorizations for Payment Report that all the requirements of the child care error rate methodology are met.
The Record Review Worksheet template consists of four sections designed for the following data collection:
- Section I: State Child Care Program Forms – This is a review of application, recertification, and other forms documenting changes affecting eligibility to determine their presence, date on the form, completeness and that they are current to eligibility policies in the sample review month. Typical forms include the application form, rights and responsibilities notification form, referral form, parental choice form, and parent/provider agreement form, if applicable.
- Section II: Priority Group Placement – This is a review to determine if the child meets the criteria of State-designated priority groups. These groups are identified in the State plan. Examples include categories such as special needs, foster care, working families with very low incomes, TANF, etc.
- Section III: General Program Requirements - This is a review to determine if the parent of the client meets the State’s definition of parent, meets the State or county residency requirement, is working or attending a job training or educational program and meets other general program requirements of the State or county. This review is also to determine a child’s eligibility for a subsidy, if the number of hours of care authorized is consistent with the parent(s)' work/training status, and if services are provided by a legally operating provider.
- Section IV: Income and Authorizations – This is a review to determine if the household income meets State requirements, the accuracy of computations and the amount of the authorized payment. This section also includes computation of the gross improper authorization for payment amount. The amount of the improper authorization for payment is the difference between the amount of the authorized payment for the child in the sample review month and the amount that should have been authorized in the sample review month based on the case record review. The calculation of improper authorization includes both Overauthorizations and Underauthorizations.
- Column 1 - This column lists the basic elements of eligibility, income requirements, authorized subsidy amount and computations. In customizing the Record Review Worksheet template, States provide descriptions of the forms, documents and information to be considered by the reviewer, including any specific questions, prompts or form names that can assist the reviewer in identifying or assessing the accuracy of the specific element of eligibility.
- Column 2 – This column is for the reviewer to provide a detailed analysis of the case record.
- Column 3 – If an error is cited in the review of a specific element, the reviewer describes the cause(s) of the error(s) in Column 3
- Column 4 – This column provides codes for the reviewer to summarize the results of the case review findings.
For further information about completion of the customized Record Review Worksheet as part of the case record reviews, refer to Section VI of this document.
The following provides a detailed explanation of each section of the Record Review Worksheet template.
Review Identification Information
This information includes: "Child ID," "State," "County," "Sample Month/Year" and "Review Date."
Column 1: Elements of Eligibility and Payment Authorization
States retain the printed description for each element of Column 1. States may customize by adding below any printed element section details that reflect their laws, policies, and procedures. Examples for the elements follow.
Section I. State Child Care Program Forms
- Element 100 Application/Re-determination Forms — Determine presence, date, and completeness of required eligibility forms. Examples include (1) signed and dated CCDF application form, (2) child care agreement, (3) voucher or certificate, and (4) provider invoice. Specify conditions of dollar error, including (1) form expired, (2) no application form, and (3) no documentation of income and work hours.
States might choose to customize this section by listing each required form and providing for reviewer check-off for presence, date and completeness. An enhancement would be to provide the policy citation, including page number, for each required form.
Section II. Priority Group Placement
- Element 200 Priority Group Placement — Determine if client meets criteria of any State-designated priority groups, e.g., (1) teen parent in high school, (2) TANF recipients in eligible work activities, (3) working parents with very low incomes, and/or (4) foster parents.
Some States may find this area to be "Not Applicable" because they serve all eligible families. Others may wish to customize this section by listing any State-designated priority groups.
Section III. General Program Requirements
- Element 300 Qualifying Head of Household — 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., (1) parent, (2) step-parent, (3) legal guardian, (4) needy caretaker relative, or (5) spouse of same..
States might customize this section of the worksheet by listing the parent definition or providing regulation citations to prompt reviewers, for example:
- Does the client meet the definition of parent as defined by 45 CFR 98.20; or
- Other person standing in loco parentis (identification provided) defined in Rule XXX as temporary guardian of child.
- Element 310 Residency — Determine if client is a resident of the State and for what duration, if client is a resident of the county and for what duration, and whether there is an agreement regarding eligibility among counties.
Examples to customize the worksheet would be to provide choices for the reviewer to check-off, such as:Client is a resident of the State and for what duration;
- Client is a resident of the State and for what duration;
- Client is a resident of the county and for what duration; and
- There is an agreement regarding eligibility among counties.
- Element 320 Parental Work/Training Status — To receive services a child's parent or parents must be working or attending a job training or educational program, or have a child receiving or needing to receive protective services.
Examples to customize the worksheet include listing categories for the reviewer to check off, such as qualifying activity (working a minimum of 20 hours a week), schedule (attending a job training or educational activity 20 hours a week), disability, protective services case and other.
- Element 330 Qualifying Child — Determine if child is eligible for services, including (1) younger than 13 years, (2) younger than 19 years and physically or mentally incapable of caring for himself or herself, or under court supervision, or (3) meets other eligibility requirements defined in the State Plan. Determine if child meets citizenship requirements as set forth in Federal policy.
The above categories could be separately listed.
- Element 340 Qualifying Care — Determine number of hours needing authorization during review period, based on parental work/training status or child's protective services status. Determine hours and type of care authorized.
States might provide additional prompts for the reviewer. One example is to check to see if the hours of care are entered (on the automated system) and consistent and, if not, whether exceptions are noted on contacts or paper record.
- Element 350 Qualifying Provider Arrangement — Determine if services are provided by a center-based child care provider, a group home child care provider, a family child care provider, or an in-home child care provider that is legally operating and eligible to receive child care subsidies.
The worksheet could be customized by separately listing the qualifying provider categories for the reviewer to check-off or by providing the appropriate policy citation. Any limitations that a State imposes on in-home care may be reflected in this section.
- Element 360 Provider Requirements — 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.
States might provide additional prompts for the reviewer, such as: "Check the provider record status screen to see if a valid license or certificate was in effect as of the sample review month."Section IV. Income and Payment
Section IV. Income and Authorizations
- Element 400 Income — Describe income documentation verification for household members. Specify time period (e.g., based on 4 weeks prior to application) and all income to be considered based on State policies and definitions (e.g., head of household employment).
States may customize by separately identifying State-specific data, such as head of household employment income; spouse employment income; any changes in income reported; income during job training for parent/caregiver; child support, if included as part of income; Food Stamps, if included as part of income; and loss of income during eligibility period.
- Element 410 Income Eligibility —Determine if household income meets State requirements (e.g., family gross income must be within X% of State's median income).
The worksheet could be customized by citing the State policy or by providing elements of income policy in list form.
- Element 420 Payment Amount Authorized— Determine the amount of subsidy payment authorized for a sample review month. Determine if the amount authorized was based on income and family size, the State's payment rate schedule, and any sliding fee schedule, if applicable.
- Element 430 Authorizations/Computations — Compute the difference between the amount authorized to be paid in a sample review month and the amount that should have been authorized. This difference is the improper authorization for payment amount. Indicate if the error amount is an Overauthorization or Underauthorization. In cases without errors, this element is not applicable. Record as "NA."
Column 2: Analysis of Case Record
This Column contains the details for analysis of the case record. The analysis provides a summary of the case record information as it relates to the requirements stipulated in Column 1. States must retain the column heading "Analysis of Case Record," but may choose to customize Column 2 of the Record Review Worksheet to allow for coding to substitute for a reviewer’s written summary. In this example, Column 2 is customized by using "yes" or "no" columns. In addition, Column 1 also has been customized to include State-specific information.
Example of Column 2 Modification of the Record Review Template
310 RESIDENCY
ELEMENTS OF ELIGIBILITY & PAYMENT AUTHORIZATION (1)
ANALYSIS OF CASE RECORD (2) Determine if client is a resident of the State and if client is a resident of the county. Yes No Comments (1)Is the Client is a resident of the State? (a client statement indicating residency and intent to stay is sufficient for non TANF clients) (Section 414.095(2)(a)2, FS requirement for TCA clients – clients are not eligible for TCC unless previously served under TCA) (2)Child care authorized by county in which the parent resides? (School readiness funding and services are provided based on the county where the parent resides)
While it is not required, States may choose to ask reviewers to include photocopies of specific documentation of an authorization error to support the Column 2 analysis. For example, the reviewer could make a copy of the client’s driver’s license (used as proof of residency) that listed an out of State address.
Column 3 contains the findings of the case record review and provides any pertinent facts, questions, or conflicts in information as they relate to the requirements stipulated in Column 1. Because reviewers use this Column for narrative purposes, States do not customize Column 3.
VI. CONDUCTING CASE RECORD REVIEWS: >>States may not customize Column 4. Reviewers identify in Column 4 the codes that summarize the review findings from Column 3 of the customized Record Review Worksheet. The codes are the following:
- Error – The codes are “0” = no error, “1” = error;
- Reason for error – The codes are “Y” = Yes, the error is due to missing or insufficient documentation, “N” = No, the error is not due to use of missing or insufficient documentation, and "NA" if there is no error;
- Type of improper authorizations during sample review month – “U” = Underauthorization, “O” = Overauthorization, and "NA" = no improper authorization; and
- Total amount of improper authorization for payment–This is where the dollar amount of the improper authorization for payment is recorded. This is the difference between the authorized payment amount and the amount reviewers found during the review that should have been authorized.
Because this coding is transferred to Data Entry Forms and then consolidated to compute the error measures, States must not customize Column 4.