How will changes to eligibility change State processes to protect against improper payments?

Determining whether payments have been made correctly depends on the rules the state establishes within the limitations of how federal funds may be used. The law requires States to consider a child to be eligible for the full 12 month period despite temporary changes in the parent’s status as working or participating in training or education activity and despite an increase in income above the State’s threshold (as long as income does not exceed the Federal limit of 85% SMI).   This means that it is not necessary to have strict policies that require reporting of minor changes in circumstances as the changes would not likely impact eligibility.  It also minimizes risk of a State issuing an improper payment just by virtue of the fact that the law provides for continuous eligibility for families over the 12 month period.  States also may put in place policies that freeze copayment levels during the 12-month eligibility period, eliminating the need for most reports of modest changes in income, while permitting families to report those changes so that their copayment can be adjusted if their income falls and their ability to pay is reduced.

ACF encourages States to have in place strong internal controls and program integrity efforts to help ensure that program dollars are going to low-income eligible children and families for which assistance is intended; however, it is important to ensure that these efforts do not inadvertently impair access for eligible families.