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State Survey Analysis Report

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APPENDIX 23. RELEVANT INFORMATION

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

11 State agencies responded to Question 23 (Appendix 23: pp. 135–137)
State Any other information relevant to improper payments in the program
Connecticut Connecticut strongly recommends against establishing a national target error rate for CCDF. As you can see, we have invested significant State funds and resources to both avoid and detect errors. Policy and regulatory variances between States make it difficult or impossible to establish uniform standards. One recommendation being considered by ACS is to measure error relative to each State’s own policies and practices. Such an approach would only serve to penalize States with more restrictive policies. Connecticut maintains that the program would be better served by providing guidance and direction to help States establish sound quality assurance programs and practices.

Connecticut also recommends addressing improper payments within the context of the goals of CCDF and the Child Care Bureau. For example, the definition of an improper payment may take on an entirely different perspective if continuity of care is the goal vs payment eligibility that is rigidly correlated to daily attendance an work hours. States must also have the flexibility to establish and move early childhood education agendas without risk of audit execptions.

The role of information and technology in reducing improper payments is an issue that has surfaced at numerous ACF conferences and discussions on improper payments. While child care expenditures and market rate costs have increased exponentially since the enactment of the Family Support Act of 1988,States received little support for developing the infrastructure and technology needed to administer the CCDF. Proposed TANF reauthorization legislation will only increase the pressures on States to meet this demand making diversion of block grant funds for administrative purposes even less feasible. As a result, child care management information systems are largely comprised of a patchwork of independent or proprietary systems. ACF can effect significant reductions in the amount of improper payments by providing States with the financial incentives to develop and fully functional and integrated child care systems.
District of Columbia RESPONSE: October 1, 2004, the ECEA implemented a revised automated module on attendance as well as revised and specific policies and procedures related to the monthly attendance reports for children enrolled in the child care subsidy program along with step by step procedures of what providers must do and what the ECEA must do. All providers were trained on the policies and procedures and the module was placed on computers that ECEA provided to all center based providers participating in the child care subsidy program. This system was implemented to set forth policy and procedure to effectively monitor the attendance of children at early care and education facilities, to ensure accurate recording of attendance for each enrolled child, and to facilitate accurate payment to all subsidized child care providers. Further, the policies and procedures are designed to reduce payment errors and to increase the accountability of providers and ECEA staff. The monthly attendance is the basis for payment. These policies and procedures are available from the ECEA. They are not on the Web site because they are pending final legal sufficiency review by the Department of Human Services Office of the General Counsel.
Kansas See number 24
Kentucky Currently updating policies and procedures to include sanctions of services/payment for fraudulent payments
Minnesota See attachment 3 & 4
New Hampshire The Department of Health and Human Services has convened an agency wide Improper Payments Task Force to examine our policies and procedures. The task force, consisting of individuals from the Office of Special Investigations, the Division of Family Assistance, the Bureau of Improvement and Integrity, the Child Development Bureau and the Office of Economic Services, has taken a leading role in addressing the issues around Improper Payments. This Task Force meets quarterly.
North Carolina Subsidy Services Consultants visit LPA’s to provide technical assistance and training for staff. Program Compliance Consultants monitor LPA's and conduct provider training when requested. The Program Compliance Consultants also conduct provider site visits to offer technical assistance about all aspects of enrollment in the Subsidized Child Care Program.
Ohio We would like to be able to collect improper payments via the Treasury Offset Program (TOP).
Oklahoma EBT system for Child Care…time and attendance tracking and payments
Washington The Quality Assurance section, under the Division of Management and Resources & Services (a partner division), is planning an on-going audit of child care. The plan is to audit approximately 25 providers each quarter. The audit would include auditing the child care subsidy records of each of the children being cared for by those providers. This will encompass all facets of the cases, from correct eligibility determination, income, copayments, and correct payment authorizations, and provider billing.
West Virginia We are interested in knowing whether or not anyone has done a cost/benefit analysis on various prevention strategies. For example, home visits would likely be very effective in reducing improper payments due to failure to report all household members; however, we suspect that the actual cost of home visits for each client would be excessive.
   
Those that did not provide an answer:  
Alabama  
Arizona  
California (DE)  
California (DSS)  
Georgia  
Maryland  
Massachusetts  
Mississippi  
Missouri  
Montana  
Nebraska  
Puerto Rico  
Utah  
Wisconsin  

Appendix 24 >>