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Improper Payments Information Survey for the CCDF Program
OMB Approval No. 0970-0291, Expiration date 10-31-08
(This document is also available in Word and PDF.)

Instructions

In accordance with the Paperwork Reduction Act of 1995, collection of this information has been approved by the Office of Management and Budget (OMB) under OMB Control Number 0970-0291, expiration date 10-31-2008.  Submission of this information, however, is voluntary.  The public reporting burden for this collection of information is estimated to average 24 hours per response, including the time for reviewing instructions, gathering and maintaining the data needed, and reviewing the collection of information.  An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

Please enter the following information for the individual(s) completing this questionnaire and attachments, so we may contact them to clarify information, if necessary.

Date:                                                                                                                                                    

Name:                                                                                                                                                 

Title:                                                                                                                                                    

State Agency:                                                                                                                                      

(Area Code) Phone Number:                                                                                                                

E-mail Address:                                                                                                                                    

Please return the completed questionnaire and attachments in the enclosed business reply envelope.  Alternatively, you may fax your completed questionnaire and brief attachments to the attention of Moniquin Huggins at 202-690-5600, or preferably email an electronic copy of the questionnaire and any attachments to her at Moniquin.huggins@acf.hhs.gov.

If you have any questions or comments regarding your submissions, please contact Moniquin Huggins at 202-690-8490, or at Moniquin.huggins@acf.hhs.gov.

Please return the questionnaire and attachments within 60 days of receipt.

As a point of reference, under the Improper Payments Information Act of 2002, the term, “Improper Payment”

(a)  means any payment that should not have been made or that was made in an incorrect amount (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements; and

(b)  includes any payment to an ineligible recipient, any payment for an ineligible service, any duplicate payment, payments for services not received, and any payment that does not account for applicable discounts.

General Overview:  Policies and Infrastructure 

1. How does the CCDF Lead Agency define improper payments? 

 

2. Provide a description (electronic copy, if available) of the organizational structure of the agency in your State that handles improper payments in the child care program.  If available, please submit an organizational chart or provide the web site address where it can be found.

 

3. Please check all of the topics or activities listed below for which your State has policies or regulations in place for the program. (Please check all that apply.)

Steps involved in identifying a potential improper payment

Steps involved in verifying an improper payment

Establishing claims for improper payments

Collecting improper payments, including, for example, the authority to reduce payments to recover overpayments

Distribution of recovered improper payments

Sources of funding for addressing improper payments

Other (Please specify: )                                                                                              

Identification and Assessment of Improper Payments

4. For which of the following uses of program funds has your State performed an assessment or analysis to determine whether the program is at risk of improper payments? (Please check all that apply.)

 
Assessment/Analysis Performed
Agency error or fraud
Yes
No
Provider error or fraud
Yes
No
Client/Parent error or fraud
Yes
No
Payments to service providers
Yes
No
Payments to clients
Yes
No
Other (Please specify:)
Yes
No

 

5. Please describe your process for identifying and handling improper payments and include all aspects of the process through resolution:

 

6. Which methods, if any, did your state use to identify a total amount of improper payments for the program? (Please check all that apply.)

Calculation based on:

Findings from the state’s Single Audit

Other audit findings from state auditors

Findings from other state or local auditors, including legislative review entities (Please specify:) ______________________________________________________________________________

Findings from state or local fraud units (Please specify:) ______________________________________________________________________________

Reviews of service providers and/or contractors

Reviews of sampled cases, although not statistically representative of all program payments

Statistically representative sample of payments

Other (Please specify:) ____________________________________________________________________

 

7. Which of the following elements, if any, has your State maintained?  (Please check all that apply.)

A statistically valid sample of cases or payments is regularly selected and reviewed to verify eligibility and payment accuracy

An improper payments rate is calculated

Information on other client and case characteristics are collected

Other (Please describe:)                                                                                                   

None

 

8. Does your State calculate an improper payments (including fraudulent payments) rate, that is, a measure of the percentage of total payments that are determined to be improper? (Please check one response and provide the appropriate data.)

Yes.  Please describe the methodology used to arrive at the error rate.

Most recently completed fiscal year                       (Specify ending month/ year)                

Next most recently completed fiscal year                 (Specify ending month/ year)                 

No 

Information not available.

 

Describing Improper Payments:  Sources, Types, Causes

9. Does your State track information on the sources, types, or causes of improper payments in the program? (Please check one response.)

Yes

No 

 

10.   a.  Please rank the following sources of improper payments (1 to 7) for the program in your State over the past two fiscal years, beginning with one (1) indicating the primary source of improper payments.  Error is defined as an inadvertent mistake whereas fraud is defined as a willful misrepresentation. (Please rank each source below.)

___ Client error

___ Provider error

___ State Agency error

___ Local Agency error

___ Client fraud

___ Provider fraud

___ State Agency fraud

___ Local Agency fraud

___ Other (Please specify:)_________________________

 

10.  b.  Of all improper payments, what proportion would you estimate results from regulated providers versus from unregulated providers?

Regulated providers                         %

Unregulated providers                      %

What proportion of funds is provided to regulated providers versus unregulated providers?

Regulated providers                         %

Unregulated providers                      %

 

11.   Of all improper payments in your State, what proportion of those payments would you estimate are overpayments and what proportion would you estimate are underpayments?  An overpayment is defined as a payment larger than what should have been made/received or any payment that is received when none should have been received.  An underpayment is defined as a payment smaller than what should have been made/received or no payment was received when there should have been one..

Overpayments                                 %

Underpayments                               %

 

12.   To what extent, if any, have the following factors contributed to improper payments in your State over the past two fiscal years?  (Please check one answer in each row.

Factors contributing to improper payments Great extent Moderate extent Little extent No extent Don’t know
Related to clients          
a. Nonreporting/underreporting of income          
b. Client receiving payment in more than one jurisdiction          
d. Incorrect reporting of household size          
e. Incorrect citizenship or immigration status          
f. Incorrect information on client’s compliance with program requirements, such as participating in required activity          
g. Other (Please specify:)          
Related to providers          
h. Overstating performance          
i. Claiming for services not rendered          
j. Other (Please specify:)          

Prevention of 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.)      

 

14.  For each activity listed below, indicate whether or not your State performs it to verify the accuracy of information needed to determine eligibility for and/or proper amount of a program payment.  If yes, indicate when in the process the step or activity is performed and how often it is performed.

Steps or activities
 performed
Is the step/activity performed? If yes, at what stage in the process (e.g., pre-approval/approval; redetermination at  3 mos., 6 mos. or 12 mos. ;etc.)? If yes, how often? Please insert a checkmark by the 3 items you consider the most effective

a. Require documentation from client

Yes
No
     

b. Fingerprint clients

Yes
No
     

c. Access online databases

Yes
No
     

d. Match automated computer files

Yes
No
     

e. Conduct telephone, fax, or email contacts

Yes
No
     

f. Conduct home visits

Yes
No
     

g. Initiate a fraud investigation if warranted

Yes
No
     

h. Conduct program
integrity/quality control
review

Yes
No
     

i. Other (Please specify:)

Yes
No
     

 

15.  Data sharing is a method used to obtain and disclose information about individuals from within your agency, from other agencies and/or from independent, third party sources, including federal and State agencies or private companies.  These activities can be conducted before an initial payment is made to an individual or provider (pre-payment) and also after payment is made (post-payment) to verify eligibility and payment accuracy.   For each source listed below:

Indicate whether or not your agency or State utilizes this data source to better ensure accurate payments under the program.  If your State utilizes the source, indicate when in the process the source is used (before the payment is issued or at some point after the payment is issued), and/or indicate how often that source is used. (Please check all appropriate responses for each row.)

Data source Is the source used? If yes, when in the process? If yes, how often? Please insert a checkmark by the 3 items you consider the most effective)

a. Income Eligibility Verification System (IEVS)

Yes
No
     

b. Other human services programs in your agency/State

Yes
No
     

c. State department of labor or employment security

Yes
No
     

d. State directory of new hires

Yes
No
     

e. State department of motor vehicles

Yes
No
     

f. Public Assistance Reporting Information System (PARIS)

Yes
No
     

g. State data (from other States) on length of TANF receipt

Yes
No
     

h. State data (from other States) on potential concurrent TANF receipt

Yes
No
     

i.  State data (from other States) on client or provider debarment from benefits, for fraud or other infraction

Yes
No
     

j. Lottery agencies

Yes
No
     

k. Prisons and criminal justice agencies at State level

Yes
No
     

l. National Criminal Information Center (NCIC)

Yes
No
     

m. Local jails

Yes
No
     

n. Credit bureaus

Yes
No
     

o. Financial institutions

Yes
No
     

p. State tax intercepts

Yes
No
     

q. Immigration authorities

Yes
No
     

r. K-12 school systems

Yes
No
     

s. Community colleges

Yes
No
     

t. Other providers of services,
education, training

Yes
No
     

u. Child support

Yes
No
     

v. Social Security Administration (SSA) form W-2 (wage statements)

Yes
No
     

w. SSA Social Security
number verification

Yes
No
     

x. SSA Supplemental
Security Income (SSI) data

Yes
No
     

y. SSI death information

Yes
No
     

z. Other (Please specify:)

Yes
No
     

Recovery of Improper Payments

16.  For the most recently completed fiscal years, how much in program improper payments has your agency, or another agency within your State, recovered? (Please indicate your responses in the space provided below.)

Most recently completed fiscal year                   (Specify ending month/ year)               

Includes fraudulent improper payments

Next most recently completed fiscal year                     (Specify ending month/ year)                 

Includes fraudulent improper payments

Not tracked

 

17.  What penalties does your program mandate for clients, agencies, or providers, who commit an error leading to improper payments?

A.  Agency:

B.  Clients/Parents:

C.   Providers:

D.   County/Local Agency:

 

Fraud: Intentional Overpayments

18.  How does the CCDF Lead Agency define “fraud”?

 

19.  Does your agency maintain data on fraudulent payments in the program as a subset of your improper payments data? (Please check one response.)

Yes
Most recently completed fiscal year %          (Specify ending month/ year)               

Next most recently completed fiscal year %           (Specify ending month/ year)                 

Please list the methods you use for finding occurrences of fraud and indicate whether you would rate each method as very effective, somewhat effective, somewhat ineffective, or very ineffective.

No 
Does any other entity in your State maintain this information, such as a State fraud unit or Inspector General? If yes, please provide us with a contact name and phone number:

 

20.  What measures does your agency take to prevent collusion?

 

21.  What penalties does your agency mandate for clients, providers, or the agency for those who commit fraud leading to improper payments?

A.     Agency:

B.     Clients/Parents:

C.     Providers:

D.     County/Local Agency:

 

22.  Is your agency required to report, or to have information available, on improper payments to the State legislature, the Governor, or any other higher-level agencies? (Please check one response.)

Yes: Please provide a copy of the report(s), and indicate who received them.

No

 

Other

23.  Describe any other information that may be relevant to improper payments in the program that you wish to share with us.

 

24.  Please submit copies of pertinent sections of manuals and other State-issued guidance that you would like to make available, or provide the web site address where they can be found.

 

Thank you very much for your time and assistance!