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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VIII. COMPLETING AND SUBMITTING THE STATE IMPROPER AUTHORIZATIONS FOR PAYMENT REPORT
The State Improper Authorizations for Payment Report consists of three Parts:
- Part I - Program Assurances and Certifications
- Part II - Error Measures Reporting
- Part III - State Response to Error Measures Findings
The process that follows is for States that chose to create an Improper Payments Planning Team. If other strategies are selected, States complete the tasks consistent with their alternative strategies.
- Project coordinator solicits from the reviewers observations about the review process and the findings.
- Project coordinator convenes Team to analyze the findings, reviewer observations
,and discuss causes. - Individual Team members consult with various staffs and bring findings/recommendations to the team (e.g., the quality control (QC) representative, the information technology (IT) representative).
- Team considers information from the various offices (e.g., QC and IT) and agrees on findings/recommendations to include in the report.
- Assigned Team member prepares draft of report.
- Team reviews, comments, approves report for submission to Lead Agency administration for approval.
- Assigned Team member obtains necessary approvals.
- Assigned Team member submits State Improper Authorizations for Payment Report electronically to the Regional Child Care Manager in their ACF Regional Office. Assigned Team member also sends original signature page to the Regional Child Care Manager.
Part I - Program Assurances and Certifications
States insert identifying information of the agent authorized to assure and certify that:
- The data collection process, including sample selection and case record reviews, adhered to all requirements of the "Measuring Improper Authorizations in the Child Care and Development Fund (CCDF) Program" instructions and regulations at 45 CFR 98 Subpart K;
- The reviews were not conducted by persons who make or approve the eligibility determinations or be under the supervision of persons responsible for eligibility determinations;
- All reviewers have been trained to ensure that the review process is consistent with State policies and that there is consistency within the State in interpretation of what is an error;
- The State agrees to retain Record Review Worksheets, Data Entry Forms, the State Improper Authorizations for Payment Report and any revisions, and any other records pertinent to the case reviews and submission of error rate reports for five years from the date of submission of the State Improper Authorizations for Payment Report or final revision submitted, whichever date is later; and
- The State understands that this information, including the sampled case records and calculations, is subject to Federal review.
The required information is "Submission Date," "Name," "Signature," "Title,” “State,”" State Agency," "Telephone Number," "E-mail Address," and "Federal Fiscal Year."
Part II - Error Measures Reporting
Following completion of the Data Entry Forms, States consolidate all the data in order to compute the error measures for input into the State Improper Authorizations for Payment Report. It is recommended that States enter all data fields from each Data Entry Form into a database or spreadsheet for error measure computation. Using software to consolidate all of the data improves accuracy and allows for easier analyses of the results from the case record review process.
Once the data have been entered into a spreadsheet or database, States use the table in Part II of the State Improper Authorizations for Payment Report to record information necessary to compute and record error measures.
The following are the templates for Part II of the State Improper Authorizations for Payment Report.
Improper Authorizations for Payment Reporting |
||
| Item # | ||
|---|---|---|
| 1. | Number of cases sampled | |
| 2. | Total amount of authorizations for payment for sampled cases in the review period | $ |
| 3. | Total number of sampled cases with improper authorizations for payment | |
| 4. | Total amount of improper authorizations for payment for the review period (gross amount of underpayment and overpayment authorizations) | $ |
| 4A. | Total amount of improper underpayment authorizations for payment for the review period. | |
| 4B. | Total amount of improper overpayment authorizations for payment for the review period | |
| 5. | Total number of improper authorizations for payment due to missing or insufficient documentation | |
| 6. | Percentage of cases with an error | |
| 7. | Percentage of cases with an improper authorization for payment | |
| 8. | Percentage of improper authorizations for payment | |
| 9. | Average amount of improper authorizations for payment | $ |
| 10. | Estimated annual amount of improper authorizations for payment | $ |
| 10A. | Check the appropriate response. 1. _____ Review not based on a sample drawn from pooled funds. 2. _____ Review based on a sample drawn from pooled funds and State has applied the pooling factor found on the most recent ACF-800 reporting form. 3. _____ Pooling factor from the most recent ACF-800 reporting form, if applicable. |
|
| 10B. | If the State checks #1 or #2 in 10A, skip 10B and proceed to #11. 1. _____ Pooling factor different from that found on the most recent ACF-800 reporting form. 2. Explain the derivation of this pooling factor. _______________________________________________________ _______________________________________________________ _______________________________________________________ _______________________________________________________ |
|
11. Number of replacement cases used each month of the 12 month review period and valid reasons for those replacements.
| Month | Reason(s) for Replacement Cases (please list) |
# Times Reason Used |
|---|---|---|
| October | ||
| November | ||
| December | ||
| January | ||
| February | ||
| March | ||
| April | ||
| May | ||
| June | ||
| July | ||
| August | ||
| September | ||
If there are more than three replacement cases in a single month, and there are more than three reasons, States place an asterisk after the name of the month and include the additional information below the table.
General Instructions:
Round all entries to the nearest dollar. Omit cents. If the result contains .50 cents or more, round up to the nearest dollar. If the result contains .49 cents or less, round down to the nearest dollar. The instructions for all Items in Part II follow. Note that the term "authorization" means subsidy payment authorized during eligibility determination or redetermination. (See Glossary)
1. Number of cases sampled – The sample size for all states is set at 271 (or 276) cases.
2. Total amount of authorizations for payment in cases selected for sampling in the review period – Compute the sum of all authorizations for payment for the 271 (or 276) sampled cases. The amount of payment authorized is captured on Line 10 of each of the 271 (or 276) Data Entry Forms.
3. Total number of sampled cases with improper authorizations for payment – Compute the sum of all cases with either an Overauthorization or Underauthorization. This would be the total number of cases with an amount other than "0" in Line 7 of the Data Entry Form.
4. Total amount of improper authorizations for payment for the review period – Compute the sum of all improper authorizations for payment listed in Line 7 of the Data Entry Form.
4A. Total amount of improper underauthorizations for payment for the review period- Compute the sum of all improper authorizations for payment listed in Line 7 of the Data Entry Form that also have a "U" listed in Line 8 of the Data Entry Form.
4B. Total amount of improper overauthorizations for payment for the review period - Compute the sum of all improper authorizations for payment listed in Line 7 of the Data Entry Form that also have an "O" listed in Line 8 of the Data Entry Form.
5. Total number of improper authorizations for payment due to missing or insufficient documentation – Compute the sum of all cases with a “Yes” coding in Line 9 of the Data Entry Form.
6. Percentage of cases with an error – Divide the total number of all cases with an error (any case with an error coding in Line 6 of the Data Entry Form) by 271 (or 276) and multiply by 100.
7. Percentage of cases with an improper authorization for payment – Divide the total number of all cases with an authorization error (see #3 above) by 271 (or 276) and multiply by 100.
8. Percentage of improper authorizations for payment (for the review period) – Compute the sum of all amounts listed in Line 8 of the Data Entry Forms (see #4 above) divided by the sum of all authorizations for payment for the 271 (or 276) sampled cases (see #2 above) multiplied by 100. Add Underauthorizations to (not subtract from) the total of Overauthorizations.
9. Average amount of improper authorization for payment – Compute the sum of all amounts listed in Line 7 of the Data Entry Forms (see #4 above) divided by the total number of cases with an amount other than zero in Line 7 of the Data Entry Form (see # 3 above).
10. Estimated annual amount of improper authorizations for payment– Multiply the percentage of authorizations made in error for the review period (see # 8 above) by the total dollar amount of child care authorizations during the 12 month review period.
If a State combines (pools) funds and conducted its review based on a sample drawn from a universe of cases served by these pooled funds, the State shall calculate the total dollar amount of child care authorizations in one of two ways to reflect the proportion of these funds that are CCDF funds:
- By applying the pooling factor found on the most recent ACF-800 reporting form to calculate the dollar amount; or
- By applying a pooling factor different from that found on the most recent ACF-800 reporting form.
10A.Check the appropriate response.
- Review not based on a sample drawn from pooled funds.
- Review based on a sample drawn from pooled funds and state has applied the pooling factor found on the most recent ACF-800 reporting form.
- Pooling factor from the most recent ACF-800 reporting form, if applicable.
10B. If the State checks #1 or #2 in 10A, skip 10B and proceed to #11. If the State did not check #1 or #2 in 10A, complete #1 and #2 in 10B.
- Pooling factor different from that found on the ACF-800 reporting form.
- Explain the derivation of this pooling factor.
11. Number of replacement cases used each month of the 12 month review period and reason for each replacement. If there are more than three replacement cases in a single month, and there are more than three reasons, the State places an asterisk after the name of the month and includes the information below the table.
Part III - State Response to Error Measures Findings
Using the coordination process selected, States provide narrative responses, or enter data into tables provided, in Part III.
Note: States complete and submit Part III A only as part of their first cycle reporting. States complete and submit Part III B only for all subsequent reporting cycles.
Part III A. (for first reporting cycle only)
States complete Part IIIA and include it as part of their first "State Improper Authorizations for Payment Reports." This first report is the only report for which Part IIIA is completed.
12A. In addition to the State assurances and certifications that the improper authorizations for payments data collection process, including case record reviews, adhered to all requirements of the "Measuring Improper Authorizations for Payment in the Child Care and Development Fund (CCDF) Program" instructions, describe your fieldwork preparation, sampling method, and record review process.
States provide a brief overview of their improper authorizations for payment data collection activity including processes for coordinating tasks and preparing responses for the State Improper Authorizations for Payment Report, sampling methodology, method used to collect and consolidate data, preparation and training provided to case record review staff, and the record review process. (For example, did reviewers conduct reviews as part of established site visits or did county staff pull and send records to a central State location?)
13A. Estimate the percentage of improper authorizations for payment that is attributable to missing or insufficient documentation. (Example - 30 percent of the cases with an improper authorization for payment were due to missing or insufficient documentation.) Provide examples of the most frequently missed or insufficient documentation.
Provide examples of the most frequently identified causes of improper authorizations for payment other than missing or insufficient documentation.
To obtain this estimate, divide the total number of errors attributable to missing or insufficient documentation (Item #10 of Data Entry Form) by the total number of cases with errors (Item #7 of the Data Entry Form).
14A. What are the actions that will be taken to correct the causes of improper authorizations for payment that were identified during the case record review process in order to reduce errors in the future?
States may use their coordination process (Team or other procedure) to determine steps that could be taken to address the various causes of improper authorizations for payment that were identified. (For example, Teams could decide that supervisors of new child care eligibility workers will review all eligibility determinations for six months rather than the current three months.)
15A. What is the amount of actual improper payments the State expects to recover as a result of the review? Base this amount on the total amount of improper overauthorizations for payment for the review period, found in 4B.
Include in State responses how many cases the State already has referred for investigation/further action to recover these funds, as well as any other actions being taken to date. Quality control staff and State fraud teams can provide past data upon which to base expected recovery data.
16A. Describe the information systems and other infrastructure that assist the State in identifying and reducing improper authorizations and improper payments. If the Lead Agency does not have these tools, describe actions to be taken to acquire the necessary information systems and other infrastructure.
States provide a brief overview of the ways in which automation is used to prevent improper authorizations and improper payments and to support identification and recovery efforts. (For example, a State child care information system that is integrated with the child support information system will prevent eligibility determinations that do not consider child support income.)
17A. Detail the actions the State is currently taking or plans to take in the future to ensure that the Lead Agency and eligibility workers will be accountable for reducing improper authorizations and improper payments. Describe any Federal or State statutory or regulatory barriers which may limit the State’s corrective action in reducing and recovering improper payments.
Include in the response to this question actions such as use of performance measures to address accuracy of eligibility determination. An example of a State regulatory barrier is the setting of a threshold under which alleged improper payments will not be pursued.
18A.What are the error rate targets for the next reporting cycle? Enter the targets for percentage of cases with an error, percentage of cases with an improper authorization for payment, percentage of improper authorizations for payment, average amount of improper authorization for payment, and estimated annual amount of improper authorizations for payment into the table provided. It is expected that State targets will anticipate continual improvement.
States enter data into the table provided. No narrative is necessary.
Part III B. (for reporting cycles after the first reporting cycle only)
States complete Part IIIB and include it as part of all "State Improper Authorizations for Payment Reports" after the first report is submitted.
12B. In addition to the State assurance and certification that the improper authorizations for payment data collection process, including sample selection and case record reviews, adhered to all requirements of the "Measuring Improper Authorizations for Payment in the Child Care and Development Fund (CCDF) Program" instructions, describe your fieldwork preparation, sampling method, and record review process.
States provide a brief overview of their improper authorizations for payment data collection activity including processes for coordinating tasks and preparing responses for the State Improper Authorizations for Payment Report, sampling methodology, method used to collect and consolidate data, preparation and training provided to case record review staff, and the record review process. (For example, did reviewers conduct reviews as part of established site visits or did county staff pull and send records to a central State location?)
13B. Estimate the percentage of improper authorizations for payment that is attributable to missing or insufficient documentation. Provide examples of the most frequently missed or insufficient documentation.
To obtain this estimate, divide the total number of errors attributable to missing or insufficient documentation (Item #10 of Data Entry Form) by the total number of cases with errors (Item #7 of the Data Entry Form).
Provide examples of the most frequent identified causes of the improper authorizations for payment other than missing or insufficient documentation.
14B. What are the actions that will be taken to correct the causes of improper authorizations for payment identified during the case record review process in order to reduce errors in the future?
States may use their coordination process (Team or other procedure) to determine steps that could be taken to address the various causes of improper authorizations for payment that were identified. (For example, Teams could decide that supervisors of new child care eligibility workers will review all eligibility determinations for six months rather than the current three months.)
15B. What is the amount of actual improper payments the State expects to recover as a result of the review? Base this amount on the total amount of improper overauthorization for payment for the review period, found in 4B.
Include in State responses how many cases the State has referred for investigation/further action to recover these funds, as well as any other actions being taken to date. Quality control staff and State fraud teams can provide past data upon which to base expected recovery data.
16B. Describe the information systems and other infrastructure that assist the State in identifying and reducing improper authorizations and improper payments. If the Lead Agency does not have these tools, describe actions to be taken to acquire the necessary information systems and other infrastructure.
States provide a brief overview of the ways in which automation is used to prevent improper authorizations and improper payments and to support identification and recovery efforts. (For example, a State child care information system that is integrated with the child support information system will prevent eligibility determinations that do not consider child support income.)
17B. Detail the actions the State is taking or plans to take to ensure that the Lead Agency and eligibility workers will be accountable for reducing improper payments? Describe any Federal or State statutory or regulatory barriers which may limit the State’s corrective action in reducing and recovering improper payments.
States provide a brief overview of the ways in which automation is used to prevent improper authorizations and payments and to support identification and recovery efforts. (For example, a State child care information system that is integrated with the child support information system will prevent eligibility determinations that do not consider child support income.)
18B. Provide the error rate targets for the prior and current cycles and targets for the next cycle for: percentage of cases with an error, percentage of cases with an improper authorization for payment, percentage of improper authorizations for payment, average amount of improper authorization for payment, and estimated annual amount of improper authorizations for payment. Enter the data into the table provided. It is anticipated that State targets will anticipate continual improvement.
States enter data into the table provided. No narrative is necessary.
For the second reporting cycle, the data is found in Items #6-10 of the first State Improper Authorizations for Payment Report submitted by States. The targets are at Item #17A of that report.
For the third, and subsequent reporting cycles, the data and targets are at Item #17B of the previous report.
19B. Describe if the State met targets set in the previous cycle and, if not, provide an explanation of why the State did not meet its targets.
States indicate if the data for the current cycle, reported in Item #17B, met the targets established. States explain why any targets were not met. (For example, a State may have exceeded the target reduction in percentage of improper authorizations for payment for the review period, but the percentage of cases with errors increased. The errors that were made included new areas needing corrective action or errors due to migration to a new automated system).
20B. Discuss causes of errors and improper authorizations for payment identified in the prior cycle and actions that were taken to correct those causes in order to reduce error rates.
If targets for the current cycle were met, States identify the causes of errors in the prior cycle and the responses that were effective in helping to meet the target. (For example, if manual miscalculation of eligible hours of subsidized child care was a major cause of error in the prior cycle, an effective response might have been a switch to automated calculation of eligible hours.)
APPENDIX A: >>