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Improper Authorizations for Payment
October 21, 2008
Agenda
Background Information Generating a Sample of Cases for Review Conducting the Case Reviews Completing the Federal IAP Report Resources Q & A
Background Information
Improper Payments Information Act of 2002
In 2002, Congress passed the Improper Payments Information Act (IPIA).
– Required Federal agencies to identify programs that are vulnerable to improper payments and to estimate annually the amount of underpayments and overpayments made by these federal programs.
Improper Payments Information Act 0f 2002
The Child Care Development Fund (CCDF) which provides a block grant to states to support state child care subsidies was included in the list of federal programs that must comply with IPIA.
States are required to submit to Administration of Children and Families (ACF) the Improper Authorizations for Payment Report which will identify the state’s error rate in the expenditure of CCDF grant funds.
Improper Authorizations for Payment Report
ACF has issued specific instructions, forms and timelines that must be used for the preparation and submission of the report.
Report is based on review of 276 cases authorized for care between October 1, 2008 and September 30, 2009. 23 cases will be selected each month for this time period.
States must report once every three years. Minnesota’s first report must be submitted to ACF no
later than June 30, 2010.
Generating a Sample of Cases for Review
Generating a Sample of Cases for Review
Generating the sample of cases for review consists of the following two tasks:
1. Create the sampling frame
2. Selecting the sample.
Generating a Sample of Cases for Review
1. Create the sampling frame
The sampling frame includes all active cases (children) for whom a child care subsidy was paid during a sample review month.
A listing of active cases based on payments would be created for each county.
Generating a Sample of Cases for Review
1. Create the sampling frame
DHS will use payment information from the counties using the original MEC2 system, the Integrated system and from monthly payment reports sent to DHS’ Reports & Forecasts Division to create the list of active children for whom a payment was made during that month.
Other counties will need to submit a list of children that were paid each month by the 20th of the following month. – This list must include a unique child ID, county name
and sample month.
Generating a Sample of Cases for Review
1. Create the sampling frame
All county listings are then combined based on county caseload size, listing the counties with the largest caseload first down to the counties with the smallest caseload size.
A total of 12 sampling frames will be created, one for each month in federal fiscal year 2009 (October 1, 2008 – September 30, 2009).
Generating a Sample of Cases for Review
2. Selecting the sample.
A random sample of active cases will be selected from each month’s statewide listing. A different random sample of cases will be selected for each month of the review period.
Each monthly sample will include 23 review cases and a minimum of 3 replacement cases. A total of 276 cases will be reviewed.
23 cases is .08% of the average monthly children on which payments were made during SFY 2007.
Conducting the Case Reviews
Conducting the Case Review
Reviewers will conduct a desk record review (paper and electronic file) of 23 randomly selected active cases for each of the 12 review months. (October 1, 2008 – September 30, 2009) – The case record review is considered a quality control
function and is NOT to be carried out by persons making or approving the eligibility determinations.
– Reviewers must receive training and instructions to certify that the review process is consistent with policies and interpretation of what is an error.
Customize the Record Review Worksheet
Customize the Record Review Worksheet and submit to ACF for approval prior to sampling cases.– Minnesota will customize the record review worksheet according
to state policies, county optional policies and procedures and submit to ACF for approval.
Areas that can be customized to fit Minnesota laws that apply to families and providers are:– State child care program forms– Priority group placement– General program requirements– Income and Payments
Once approved, the record review worksheet will be used to conduct reviews to identify errors and improper authorizations of payments.
Case Review Definitions
Error – An error is an administrative error that results
when a reviewer determines during a case review that either a case was authorized to receive an incorrect payment amount or there was some other misapplication of policy or procedures, regardless of whether such misapplication results in an improper authorization of payment.
Case Review Definitions
– An improper authorization for payment is an amount authorized for payment during the client eligibility process that should not have been authorized or was authorized in an incorrect amount under applicable law, regulations, or policy.
– An improper payment which resulted from an improper authorization of payment is any payment of CCDF grant funds to an ineligible recipient, for an ineligible service or amount different than authorized based on eligibility.
Case Review Definitions
Documentation is a written or printed statement or copy of a document furnishing information to determine eligibility.– May also be information contained on
automated systems.– A case without proper documentation will be
considered an error, regardless of its impact on the authorized amount.
Error Definition
Elements of Eligibility and Payment Authorization
State Child Care Program Forms– CCAP application/redetermination forms – Provider acknowledgement/registration forms
Priority Group Placement– Child Care sub-programs - MFIP, TY, TYE or
BSF – BSF-designated priority groups- teen parents,
employed families and students
Elements of Eligibility and Payment Authorization
General Program Requirements - Family– Parent/s meet definition of parent for CCAP eligibility– Family meets county residency requirements
Parental Work/Training Status– Meet work requirements (work minimum 20 hours per week at
applicable minimum wage)– Approved employment plan – Approved educational plan
Qualifying child– Age eligible– Special needs– Meet other eligibility requirements - SRC
Elements of Eligibility and Payment Authorization
Provider Care and Arrangement– Number of authorized hours and type of care needed
based on parent’s hours of authorized activity and child’s age.
– Include special circumstances, special needs or School Readiness Connection (SRC) policy.
– Identify the type of arrangement, center based, family based, or in-home care provider that is legally operating and, eligible to receive CCAP payment.
Elements of Eligibility and Payment Authorization
Provider Requirements– Authorization/Registration of Child Care
Provider for the review period• Valid license• Registration forms completed, i.e. policies and
rates.
– County optional policies applicable to Provider registration
Elements of Eligibility and Payment Authorization
Income and Authorizations– Income documentation for family members,
including specific time period and all countable income based on State policies and definitions.
Income Eligibility – Determine if the family’s income meets State
requirements (net income is within 47% to 67% of SMI).
Elements of Eligibility and Payment Authorization
Payment Amount Authorized– Determine the amount of subsidy payment
authorized for a sample review month.– Determine if the amount authorized was
based on income and family size, payment rate schedule and sliding fee schedule (copayment).
Elements of Eligibility and Payment Authorization
Compute the difference between the amount authorized to be paid in a sample month and the amount that should have been authorized.
The difference is the improper authorization for payment amount.
Indicate if the error amount is an Overauthorization or Underauthorization.
This element is not applicable to cases without errors.
Conducting the Case Reviews
County Preparation for Case Reviews– Review cases at initial application, redetermination or
when processing a change to ensure documentation is in place to support eligibility and authorization to parent and child care services.
Utilize the Case Management Review process designated for CCAP cases – DHS Bulletin #08-03-03. – Payment and non-payment errors found are to be
corrected as part of the process.
Conducting the Case Review
Convert cases to MEC2 Integrated to support sampling process for case reviews. – Utilize case notes to support pertinent
information or procedures used to establish eligibility. For example county optional policies and procedures, etc.
Completing the Federal IAP Report
Case Review Data for IAP Report
Based on the reviews, errors will be measured in five areas:– Percentage of cases with an error– Percentage of cases with an improper authorization
for payment (overpayments and underpayments)– Percentage of improper payments (% of funds
authorized that are improperly authorized)– Average amount of improper authorization for
payment– Estimated annual amount of improper authorizations
for payment
IAP Report
Prepare and submit State Improper Authorizations for Payment Report (June 30, 2010)
DHS and counties will develop steps and strategies that will be implemented to reduce error rates identified in the report.
Upcoming Events
November 5 – Presentation at MACSSA Self Sufficiency Committee
December 31 – Conversion to the Integrated System Completed!
Resources
DHS bulletin #08-03-03 – Case Management Review Forms and Guides
DHS bulletin #08-68-13 – CCAP Case Reviews
Federal Rule, Instructions and Forms www.acf.hhs.gov/programs/ccb/law/guidance/current/pi2007-08/pi2007-08.htm
Questions & Answers
Questions
Please submit questions to your CCAP Policy Liaison– Regions 1, 8, 9 Joan Anderson– Regions 2, 3, 5, 7E Kelly Simons– Region 4, MLB Brenda Clark– Regions 10, 11 Merianne Peterson– Regions 6E, 6W, 7W Maya Sullivan