Jim Bates (Senior Research Associate) with McDonald and Associates
PowerPoint: Strategies to reduce Improper Payments in the CCDF Program
Joined McDonald about a year ago. Previously involved in child care in Wisconsin.
Presentation Agenda:
Data Collection Instructions (DCI)
Error measurement findings'
DCI Modifications'
Technical Assistance strategies
Goals of CCDF Program:
serve higher proportion of low-income children in high-quality care
increase the continuity
increase the supply of high-quality providers
enhance strong program integrity
Error rate process background
final rule published in September 2007
2002 IPIA (Improper Payments Act) and 2010 IPERA (Improper Payment Error Reduction Act)
renewal methodology October 2010
revision methodology September 2012
Reporting Cycles
1/3 of 50 States, DC and Puerto Rico report each year
First review cycle and second review cycles have been completed.
ACF-402 report is being replaced by ACF-404 report effective 2013
Error rate consists of percentage of IAP (Improper Authorizations for Payments)
percentage of overauthorizations
percentage of underauthorizations
Error rate is calculated on improper authorizations
For 2012 the percentage of IAP was 9.43%
8.68% Overissuances
0.75% Underissuances
2008 - 11.50%
2009 - 11.90%
2010 - 13.30%
2011 - 11.20%
2012 - 9.43%
Under new law, CCDF has to be under 10% or be under a corrective action plan. This is at OCC level and goes to OIC. There was not a corrective action plan for FFY12.
For 2012, 14,347 cases were reviewed. 14.14% had IAP errors. 51.61% were due to missing or insufficient documentation.
Missing or insufficient documentation - 34% involved income, 33% involved hours of care, 15% involved eligibility forms, 12% involved residency and 7% involved the provider.
"Other" Error Causes
45% involved income, 23% involved hours of care, 10% involved parental fee, 9% involved the eligibility begin date, 9% involved data entry and 4% involved income changes.
Number of States by Error Rates - 35 states were under 10%, 8 states were between 10-20%
Revised Review Details
Reasons for change - authorizations not accurate proxy for payments
authorizations 20% higher than actual payments
changes allow states to access amount if eligibility error based on actual authorizations
sampled cases - old - any child authorized for a sample month / new - a child for whom a payment was made for the sample month
review focus - subsidy amount / payment amount
sampling decisions, assurances, and field work preparation plan - field work preparation plan / mandatory portions of the fieldwork
record review worksheet - states may modify the RRW / states will modify the RRW (needs customization to meet individual states needs)
Fieldwork Preparation Plan
Mandatory Items -
project and review team leadership
review team composition
methods to ensure inter-reviewer consistency
error definition (Re: Threshold - if State defines as an error through their policy, it is an error. Example: If income changes by more than $200, it was not required to be reported under State policy. Therefore, these income variances could be accepted under these reviews.)
record retention measures
Comment: The focus is looking at what the worker had in front of them at the time they processed the case. If the client failed to report, the worker wouldn't have known. If the client reported and the worker should have acted then there is an error. If they didn't or couldn't have known at the time of their eligibility decision, it would not be considered an error for this process although you would pursue any overpayments.
Also, if policy requires workers to look at interfaces and electronic matches and they don't then it is an error. However, if that is not required under state policy, then it may not be an error.
Optional Items -
designee(s) for submission of final report
process
Key Definitions -
Subsidy amount - maximum amount the State will pay
sample month payment amount - the amount paid for services in the sample month.
Record Review Worksheet - Federal requirement - can use your own techniques/systems to populate the form
underpayments and overpayments are added together to determine the actual amount of total amount of improper payment (they are not netted)
Technical assistance to support review process and error measurement include:
State training workshops
Fieldwork plans, sampling plans and review worksheets
Case review scenarios
Final report submission and review
OCC National Error Measures Report
Comment: Partial payment months can be dropped if included and defined in your fieldwork plan. Delayed payments can also be dropped if your State fieldwork plan and sampling plan allow for it.
If payments reflect multi-month service, the State must define how they want to review those payments. Some States prorate the payments and others assign it to the month of payment. Either is ok as long as it is consistent and there is logic behind it.
Error Definition
core eligibility vs. business process items
define which errors affect core eligibility as opposed to business processes
all errors are important
determine what constitutes a reasonable/flexible review approach
all-state calls
IT guide
self assessment site visits
error definition workgroup
subsidy TA requests (e.g., fraud prevention and detection, policy reviews)
Goals of Self-assessment
assess internal controls
identify strengths and weaknesses
address areas at greatest risk of fraud, waste, abuse and mismanagement
formulate mitigation strategies
Grantee Internal Controls Self-Assessment Tool
50 + page document to look at CCDF regulations and walk through what State does, what works, what doesn't and how to improve
5 sections - Program Operations and Integrity; Eligibility Determinations and Reviews; Fraud Detection, Reporting and Recovery; Audit and Fiscal Monitoring and Information Systems
Self-Assessment process usually takes 2 full days. Focused on States with higher error rates and some States for their Best Practices.
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