Patrick Lucrezio, Branch Chief of the Quality Control Branch within the Program Accountability and Administration Division of SNAP; Dave Young, USDA-FNS Quality Control branch; and Laura Tapia, USDA-FNS Quality Control Branch Program Analyst.
"No need to be negative."
Case and Procedural Review Process (CAPER)
Patrick Lucrezio - this is his second personal NAIPM conference - 1st was in Little Rock
The procedural requirement concept - look at the notices but also the whole procedural requirements - live in a society where it is important to understand "rights" - courts have ruled that human service benefits are an individual's property which cannot be taken away without due process.
The negative error rate title has been changed to more accurately reflect the measurement. The new title is "Case and Procedural Error Rate".
The rate increased in 2012 due to a different set of evaluation matrixes being introduced. The 2012 CAPER rate is broken into 4 areas - Eligibility, Timeliness, Notices and Other.
Eligibility errors comprise 43% of the total CAPER findings. These include incorrect policy application, verification errors (verifications in the case record when termination/denial occurred) , and "other" (computer system problems and no case record)
Timeliness errors comprise 13% of the total CAPER findings. Almost 90% of the initial application timeliness as opposed to recertification application timeliness.
Notification errors comprise 28% of the total CAPER findings. These include failure to send a notice, incorrect information on the notice and unclear notice.
Other errors comprise 16% of the total CAPER findings. These include reporting requirements or early denials.
When FFY11 negative error rate is compared to the FFY12 CAPER rate, there is not a significant increase. (8.30% versus 11.61%)
Factors included in CAPER which were not evaluated under NER - alternative reasons for denial/termination/suspension contained in the record are no longer included in the review and a break in participation is no longer NSTR.
State agencies that have met the challenge - South Dakota, Alaska, Mississippi, North Dakota, New Hampshire and Maine.
Changes made with the announcement of the 2012 CAPER - name change, rate announced separately from the Active error rate, announcements sent to SNAP commissioners rather than governors and it was announced with a blog rather than through traditional press release.
Why were changes made? To emphasize the significant differences between NER and CAPER (apples vs. oranges)
What corrective actions can be implemented? (1) ensuring worker awareness of the importance of providing access to the program; (2) communicating top-level management commitment on the importance o ensuring that only appropriate negative actions are taken; (3) analyzing the data available to determine the root causes of invalid decisions; (4) having an effective case review process in place to identify and correct inaccurate and inappropriate negative actions; (5)
Examples of good notices: (1) contains all language required by regulations such as appeal rights/procedures; (2) contains sufficient information for the client to understand why they were denied/terminated/suspended; (3) all information contained int he notice must be accurate; and must be clear and understandable.
Notices which contain these items may lead to problems: (1) contradictory information; (2) explanations made only in terms of regulatory citations; and (3) calculations.
Questions: Goldsberg vs. Kelly was a Supreme Court case which ruled that agencies have to give clients procedural rights.
Q: What is significance of late notices? A: Regulations require 30 day timeframes if you fail to do that, you are out of compliance. Some States have waivers which may assist them with this and allow for early denials. But the waiver carries responsibilities. (10-day verification waiver) In this case, the client can still provide the verifications prior to the 30th day and the agency must reinstate the application from the original application date and process the case.
If denials are occurring one day late, you may have a system issue. But if missing it by several days, you may have a training issue.
Q: Where is FNS blog where CAPER rate was announced? A: Not sure of exact location but it does exist.
Q: Why is it a variance when a worker posts an improper action when worker completes a same day correction? A: FNS experience with this was that a client would receive 2 notices - one indicating that a case was denied and another sentence indicating they were approved. This is confusing to the client. They also were a piece of "break in participation" concerns which were eliminated under the new review practices.
Q: Suggestions from FNS and high performing States relating to the 30th day falling on a weekend? Citing errors on timeliness. A: If 30th day falls on a weekend, to be timely, the action must be taken on the following work day.
Comment: There will be more focus on CAPER and how to bring the rates down. Best practices will be identified and shared. From ND, one of their best practices is an electronic tool on individual workers computers which calculates the critic dates on each case. And their notices are templates which are very specific but which allow for worker input. For example, if verifications are not provided, the notice generates indicating this but the worker must list the specific missing verifications.
Q: How do ND's calendar work? A: Alert based messages are received. by the worker on the critical dates.
Q: With the changes in business process - task based vs. caseload, how are alerts handled? A: ND is very small State with worker caseloads.
Comment: Alaska also has a calendar based assistance for workers and are task based.
Q: If case is posted on day 30 and the notice is batched to go out on the 31st day, is it an error? A: Yes - as per regulations, client is to be noticed by 30th day. States need to ensure IS staff are producing notices in a timely manner.
Q: What about administrative closures such as closing a case which was improperly processed? A: The key to administrative closures is to determine the reason for the closure action in the first place. The intent must be documented. Example: multiple electronic applications submitted and all but one must be denied in order to correctly process.
Q: Scenario with computer system where it processes report based actions - esp. when reports are not received - but computer batch runs over the weekend and the process is in accessible to the worker. A: Will have to think about this. Computer system needs to be in sinc with regulations not vice versa.
Comment: Tie the action to the specific time and date and review actions as of that specific time. If circumstances change, such as client provides the necessary information after the worker posts the case, that circumstance does not negate the accuracy of the original decision if the sequence of events can be verified.
No comments:
Post a Comment