Fun with Program Integrity

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Fun with Program Integrity

Division of Child Development and Early Education

3/26/2014 Work Support Strategies 2014 Leadership Summit

Subsidized Child Care Program

Program Integrity• Currently no State initiative• County level

—Referral to Program Integrity—Investigation by the Child Care Unit

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Focus of Program Integrity

Emphasis is on prevention and deterrents in the processes by which initial and continuing eligibility is determined:• Efficiency• Thoroughness• Integrity


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Wilson County

• Model Program–Piloted December 2000 - March 2001–Assigned Program Integrity Staff to review

Child Care cases–Results• 62 of 692 cases investigated• 18 cases (29%) had evidence of

suspected fraud


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Wilson County Discrepancies found• Failure to report father of child(ren) was in the home• Underreported income• Failure to report new employment• Failure to report job loss• Failure to report monetary contributions from sources

outside of the home• Failure to report marriage to the father of the child(ren)• Forged employers signature on wage verification forms• Altered check stubs


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Wilson County

• Made assignment of Program Integrity Staff to child care a permanent activity

• Staff of investigators who divert their time to child care as needed to complete activities

• Investigations are completed upfront before applicants are made eligible


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Wilson County

Process:• Review all agency records in other programs• Ask who the father of each of each child is

and where the father lives and document this information• Complete system inquiry checks• Compare bills to income


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Wilson County

Savings calculated as the amount of child care subsidy funds that would have been paid for the family over the certification period

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Wilson County

• Critical partnerships between Child Care Team and Special Investigations Team seeks to:–Maximize funding for eligible families– Encourage child support compliance–Promote personal and family responsibility– Ensure program integrity

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Child Care Fraud

• DCDEE often hears there is no fraud in child care– Corrections are required at the point of discovery– County reimbursement negatively affected– No recovery incentive

• Consider upfront investigations model– Utilize savings from prevention of improper

payments as justification for staff time.

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Subsidized Child Care Services Manual

DCDEE website:http://ncchildcare.nc.gov

• Select “County Staff”• Select “Manuals”• Select “Access the latest version of the Subsidized

Child Care Services Manual”


http://ncchildcare.nc.gov/

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Chapter 23

Fraudulent Misrepresentation and Overpayments• Two main areas

— Fraud— Inadvertent errors

• Details responsibilities of the LPA


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Convictions Possible for Fraud

• $1000 or less —Class I misdemeanor

• Greater than $1000—Class I felony


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Sanctions Imposed for Fraud

Types• Recipient• Provider


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Recipient Sanctions

Sanctions less than $10,000• First Sanction

—repay or repayment agreement• Second Sanction

—Ineligible for 3 months AND—Repay or repayment agreement

• Third Sanction—Permanent ineligibility—Second Sanction


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Recipient Sanctions

• Fraud determined for more than $10,000

or• Conviction of Fraud• Results in permanent ineligibility

even on the first occurrence


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Provider Sanctions

• First sanction–No new children for 12 months–Repay or enter into repayment agreement

• Second sanction–Permanent ineligibly–Repay or enter into repayment agreement–Removal of children receiving subsidy


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Provider Sanctions

• Fraud determined for more than $10,000

or• Conviction of Fraud• Results in permanent ineligibility

even on the first occurrence3/26/2014 Work Support Strategies 2014 Leadership Summit

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Sanctions

• The LPA imposes sanctions• 10A NCAC 10. 0308• Must provide appeal rights


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Chapter 24

• Appeals and Hearings• Details the process for appeals and

hearings• Types–Parents–Providers


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Parent Appeals

• Information contained on–Application of Child Care

Services–Child Care Voucher–Child Care Action Notice


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Process for Parent Appeals

• Contact Child Care Worker to request a local hearing

• 60 days after the effective date of the action• Local Appeal Hearing Officer’s Handbook• Next steps– State level hearing–Petition for judicial review in Superior Court


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Authority for Provider Appeals

• 10A NCAC 10 .0311– PROVIDER APPEAL TO LOCAL PURCHASING

AGENCY• 10A NCAC 10. 0312– APPEAL TO DIVISION OF CHILD DEVELOPMENT

AND EARLY EDUCATION SUBSIDY SERVICES REVIEW


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Provider Appeals

• Child Care Provider Agreement• Sanction letters• Appeal decision notifications


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Process for Provider Appeals

• Request local review Request local hearing by contacting LPA

• 30 days form the effective date of the determination of the initial review

• Local hearing• Next steps–DCDEE Subsidy Services Appeals Panel–Office of Administrative Hearings


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Contact Information

Kim Miller• Program Manager (Acting Section Chief)

Subsidy Services Section• [email protected]• 919-527-6594• Division of Child Development and Early

Education• http://ncchildcare.nc.gov3/26/2014 Work Support Strategies 2014 Leadership Summit

mailto:[email protected]

Documents

Fun with Program Integrity