State Survey Analysis Report
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APPENDIX 13. PRIORITIES FOR PREVENTING AND REDUCING IMPROPER PAYMENTS
13. Please describe your top 3 priorities for preventing and reducing improper payments (e.g., training/meetings for providers on rules and responsibilities, training for agency staff on correct implementation of rules and responsibilities; clear communication with parents on rules and responsibilities; use of information technology.)
25 State agencies responded to Question 13 (Appendix 13: pp. 70–76) |
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| State | Priority 1 | Priority 2 | Priority 3 |
|---|---|---|---|
| Alabama | Better Training to Child Care Management Agencies. | More precise/plainly written guidelines that parents can understand the consequences. | More extensive training for providers with precise results/guidelines. |
| Arizona | Further refinement of the data matching process between Unemployment Insurance (UI) wage information and income as reported by child care applicant/ recipients. | Establishment of an administrative process and criteria for treatment of clients who have committed an “Intentional Program Violation” (IPV). | In addition to the current reviews of billing documents for newly contracted child care center and large home providers and providers identified in having difficulty in proper completion of billing documents, CCA has implemented random selection of child care providers to perform desk audits. These two populations make up 85.5% of the subsidy payments issued. |
| California (DE) | The CDE is currently has a three-pronged strategy for preventing and reducing improper payments in the CCDF program. At the State level, we are conducting a thorough review of all regulations related to the CCDF program, with the intent of adopting new regulations that: • Clarify State rules for determining, documenting, and verifying eligibility and need (hours of care). • Clarify local agency responsibility for independent verification of information on which eligibility, need, and provider payment is based, especially in situations where traditional documentation may be difficult (e.g., self-employment). • Clarify client and provider responsibility for submitting documentation or other data to determine eligibility and payment. |
At the local level, the State CCDF agency is conducting annual program audits of local agencies with the goal of determining local error rates in four different areas of program operation (eligibility, need (hours of care), provider payment, and parent fee); and implementing local procedures for the identification and referral of cases where the agency suspects that incomplete or inaccurate information has been intentionally provided. | The CCDF agency and the TANF agency are cooperating in developing procedures for the referral and investigation of cash-aided cases where the agency suspects that incomplete or inaccurate information was intentionally provided. |
| California (DSS) | CDSS-administered Stage One Child Care is currently collaborating with the counties and CDE to establish best practices to help identify payment errors and fraud. | Promoting counties efforts in early fraud programs and working with CDE to improve program integrity between all three stages of California’s child care program. | CDSS has established a program integrity workgroup comprised of county representatives and CDSS staff to look at specific issues in more detail. |
| Connecticut | Implement a Fraud Early Detection (FRED) program to screen and conduct site visits on pending applications | Increased integration and automated data matching between existing State databases | Client education |
| Georgia | use of information technology | training of caseworkers to identify problems at intake | training for agency staff on correct implementation of rules and responsibilities |
| Kansas | Kansas has implemented the Electronic Benefit Transfer (EBT) process for child care benefits which brought parents into the payment process and will help prevent some improper payments from occurring. Parents make transfers of benefits which they have received from their EBT card to providers to pay for child care. This eliminates the potential for most providers to charge for hours of child care that were not provided. Parents receive a one time benefit for the month and it is between the parent and the provider on how much the provider will be paid as well as when the provider will be paid. Retroactive payment based on actual hours of care has been eliminated and benefits available for the month will be considered proper payments if the family was eligible for the benefit at the first of the month. | Kansas currently has established an on-going child care provider audit. The audit is designed to check that each provider is charging the parent correctly. Kansas requires each provider to keep an attendance record for each of their State assisted children and that providers have a contract with these parents explaining how they bill for child care services rendered. This audit randomly chooses providers and ensures that providers are following the State requirements. If the provider is found not to be following the requirements a notice is sent to them requiring them to take corrective action and gives them a deadline to achieve the required practice. Ultimately, the provider either begins to follow the requirements or loses their ability to care for State assisted clients. | Kansas trains regional staff on policies and procedures to help insure accuracy in child care eligibility and benefits. Training on child care policy, child care eligibility procedures, entering correct income information and calculating the correct amount of hours needed is provided. Kansas also contracts with local area Resource and Referral Agencies to provide training to child care providers on the EBT system as well as other training which will ensure quality child care services are being rendered to our child care customers. Beginning January 3, 2006, our Quality Assurance (QA) area will begin to review child care cases to ensure that the proper child care plan has been set up by the case workers. QA will be reviewing hours authorized, hourly rates paid and proper documentation in case files to support the child care plan. |
| Kentucky | Enacting new policies & procedures for fraud & improper payments for clients/providers. | Updating information technology system statewide to verify program compliance for clients/providers. | Providing training to staff/clients/providers to increase awareness of new requirements. |
| Maryland | Information technology | Staffing | Clear communication with parents and providers |
| Massachusetts | provide training for contract and voucher agency staff on correct implementation of rules and responsibilities | communicate new policies and procedures to all providers and share with families | require parents to sign a financial compliance statement, that States all financial information is accurate and disclosed, placing responsibility on the parent |
| Minnesota | Continue to provide policy training and technical assistance to county workers who administer the program and fraud investigators. | Provide child care providers and families with standardized program reporting requirements, the importance of reporting timely and warnings about wrongfully obtaining public assistance. | Future Plans - Implementation of a statewide Child Care Assistance Eligibility System (MEC2 ) - Review of case specific licensed family child care providers in selected counties and findings will be used to develop protocol for case management review for child care providers - Development and application of case management protocol review system for child care assistance program. |
| Mississippi | See attached response | See attached response | See attached response |
| Missouri | Missouri has an automated system for child care eligibility and provider approval and payments. This system has system edits built to prohibit overpayments to providers when child care eligibility and child authorizations are entered by field staff. | Provider’s participating in the subsidy reimbursement program participate in subsidy orientation training in which they are educated on the rules and responsibilities of invoicing for reimbursement. | A Compliance Review Team is under development as part of a departmental initiative to prevent waste, fraud and abuse. Child care providers will be the first group of vendors to be reviewed. This team will conduct on site reviews with providers to determine their compliance with DSS billing requirements as well as other contractual requirements as defined by the department. |
| Montana | One of the top priorities that we have for preventing and reducing improper payment lies with CCUBS, The State of Montana’s comprehensive childcare system. CCUBS integrates all the functions required to provide subsidized childcare to qualified families in Montana. CCUBS core functions are to determine eligibility for childcare clients, match clients with State approved care providers, and facilitate payments to childcare providers for care that’s delivered. To this end CCUBS provides functions for client intake, eligibility determination, case management, invoice entry and management, invoice adjustment processing and provider management. CCUBS also includes a fully integrated licensing module that handles licensing and registration for all State-sanctioned child care providers, whether or not they are caring for subsidy children. The licensing functionality of CCUBS allows for managing and recording childcare facility inspections and complaints against providers. In addition to the above functionality of CCUBS, numerous interfaces connect the system to other DPHHS systems and to systems outside the agency. These interfaces include a connection to AWACS for warrant writing and a connection to State’s central accounting system, SABHRS. CCUBS also shares selected information with other human services systems. Because the CCUBS system integrates childcare payments with licensing functions, improper payments to unregulated providers is non-existent. | The Early Childhood Services Bureau reviews 10% of the total child care cases receiving subsidy each year. Randomly selecting and reviewing 10% of each Child Care Resource & Referral Eligibility Specialists caseload accomplishes this process. During this review process, the ECSB Program Specialist works with individual CCR&R Eligibility Specialists to identify where case errors occur, how to adjust or fix the errors, and how to prevent future errors from occurring. Intentional program violations may also be identified during the reviews. This review process also helps identify what the training needs are of the CCR&R Eligibility Specialists and the ECSB conducts annual training with this group. The training focuses on identified topics from the review process, as well as, any updated policy and Rule procedures. |
The Child Care Resource & Referral agencies conduct their own 10% reviews of each Eligibility Specialists caseload. This review process is required by each CCR&R in their contract, and does not include the same 10% sample reviewed by ECSB. Each CCR&R is required to share with ECSB their review findings. This allows the entire statewide subsidy program to have 20% of the total case load reviewed each year. |
| Nebraska | use of information technology | training/meetings for providers | clear communication with parents |
| New Hampshire | Use of Web Billing to reduce errors | Provider Handbook for all child care providers | Clear Internal Agency policies and procedures regarding improper child care payments |
| North Carolina | training/meetings for providers and agency staff | monitoring for compliance with program requirements | implementing an automated statewide system that will calculate the payment rate for providers and the parent co-payment |
| Ohio | Reviewing with clients and providers their reporting responsibilities. Posters, brochures, information sharing at conferences, and cracking down on those who fraud the program. | Ongoing training for agency staff to keep up on any changes to the rules and their correct implementation. | Monitoring county agencies on appropriate application of policy and providing them with technical assistance and training. |
| Oklahoma | Provider training and Handbook | Random provider audits | Information Technology---data reporting |
| Puerto Rico | Review of cases files | Verify eligibility of participants | Technical Assistance |
| Utah | Training of agency staff on correct implementation of policy and procedures. | Educating parents on policy and procedures. | Education providers on policy and rules. |
| Washington | The Division’s trainers currently offer subsidy / billing training to licensed providers across the State. Some trainers with our partner Division which delivers service for the subsidy program (Community Service Division - CSD) also provide training to providers. The Division of Child Care and Early Learning is currently researching the feasibility of requiring subsidy / billing training to all providers (licensed and exempt from licensing) in order to receive subsidy payments. CSD provides ongoing training to staff who deliver the service in the field, to ensure accurate payment authorization. | The Division is also working on a project to develop and procure a new automated system (e-Child Care), which we anticipate would greatly decrease the amount of improper payments. | Our current roadblock to proceeding with the project is funding. |
| West Virginia | Documentation of Need and Eligibility • West Virginia is constantly working to clarify and strengthen child care eligibility policy to prevent improper payments. Requiring specific forms of documentation for activities, income and billing from clients and providers reduces the ability of clients and providers to misrepresent their situation. For example, students receiving services must provide school schedules and grades. Employed clients must submit pay stubs and work schedules. • CCR&R agency staff receive training from State Level staff on Child Care Policy regarding documentation requirements and program rules on a quarterly basis. |
Quality Assurance Activities – • Two State level Child Care Consultants provide oversight and technical assistance to the CCR&R agencies. They perform a quarterly sampling of CCR&R cases to ensure compliance with appropriate procedures and policies. • Child Care Resource and Referral Agencies are required to perform a monthly sampling of child care cases to ensure compliance with appropriate procedures and policies. CCR&R agencies also audit every billing form submitted by providers by matching sign in and out sheets filled in by parents to the providers billing form and the parents’ work/school schedules. Sign in and out sheets that do not match billing forms or parents’ approved activity schedules require investigation. |
Use of information technology – • CCR&R agencies must use the State’s management information system, the Family and Children’s Tracking System (FACTS), to determine financial eligibility and calculate payment amounts due. • The FACTS system is programmed to calculate income, determine eligibility and assess co-payment amounts. The system contains controls to limit payments to eligible days and children only. • The system also prevents improper payments through checks and balances – payments must be entered at the local CCR&R office, verified by a supervisor at the local CCR&R office, approved by management at both the local and Lead Agency and then issued by the Lead Agency. These checks and balances prevent improper payments at the local and State level agencies. |
| Wisconsin | Use of IT | Review of current policy/process | Provider/local agency staff training |
| Those that did not provide an answer: | |||
| District of Columbia |
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Appendix 14 >>