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THE 31 DAYS OF FEBRUARYTHE 31 DAYS OF FEBRUARY
FebruaryFebruary
Su Mo Tu We Th Fr Sa Su Mo Tu We Th Fr Sa
1 2 3 4 5 6 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 8 9 10 11 12 13 14 15 16 17 18 19 20 21 15 16 17 18 19 20 21 22 23 24 25 26 27 28 22 23 24 25 26 27 28 29 30 3129 30 31
Virginia Department of Virginia Department of
Social ServicesSocial ServicesOffice of Audit Services/Fraud Office of Audit Services/Fraud
Management UnitManagement Unit
Child Care Provider Child Care Provider Fraud PilotFraud Pilot
VDSS Fraud Management approached Child VDSS Fraud Management approached Child Care and Development about creating a pilot Care and Development about creating a pilot
to investigate Child Care Provider Fraud. to investigate Child Care Provider Fraud.
LDSS primarily investigate Child Care LDSS primarily investigate Child Care recipients. Provider investigations too labor recipients. Provider investigations too labor
intensive.intensive.
FM and CCD worked together to begin Pilot in FM and CCD worked together to begin Pilot in November 2005 – 3 LDSS volunteered.November 2005 – 3 LDSS volunteered.
PurposePurpose Identify improper/erroneous payments and/or Identify improper/erroneous payments and/or
potential fraud. potential fraud.
Pursue criminal prosecution or administrative Pursue criminal prosecution or administrative action, as appropriate, and to collect overpaid action, as appropriate, and to collect overpaid funds.funds.
Identify Child Care policy and procedures that Identify Child Care policy and procedures that may contribute to erroneous payments to may contribute to erroneous payments to child care providers and assist in the child care providers and assist in the development of revisions.development of revisions.
Identify training needs for child care providers Identify training needs for child care providers and LDSS. and LDSS.
ProcessProcess Referrals from LDSSReferrals from LDSS
InvestigationInvestigation
Written Findings ReportWritten Findings Report
Corrective Action PlanCorrective Action Plan
ProsecutionProsecution
RestitutionRestitution
Investigator FunctionInvestigator Function
Obtain Attendance Records from Provider Obtain Invoices/Purchase of Service Orders
from LDSS. Compare Attendance Records to Invoices. Determine if payments were proper or
improper. If improper, determine if intent exists. Refer
for prosecution, as appropriate. Prepare Findings Report for Provider and LDSS. Obtain Repayment Agreement from Provider. Share findings with VDSS Child Care.
BILLING PROCESSBILLING PROCESS
Agreement for Purchase of ServicesAgreement for Purchase of Services Specific agreement for all LDSS Providers– Specific agreement for all LDSS Providers–
not per child (Purchase of Service Order)not per child (Purchase of Service Order) Outlines number of absences allowed, Outlines number of absences allowed,
paid holidays, registration fees, summer paid holidays, registration fees, summer activity fees, record retention policy, etc.activity fees, record retention policy, etc.
EnrollmentEnrollment Same conditions (absences, holidays, etc.) Same conditions (absences, holidays, etc.)
apply to General Publicapply to General Public
Attendance RecordsAttendance Records
Lack of standardization in recording Lack of standardization in recording attendance.attendance.
Providers use one or more methods to Providers use one or more methods to record attendance:record attendance: Parent sign in sheets Parent sign in sheets
Class attendance sheets Class attendance sheets Class meal sheets.Class meal sheets. Van pick upVan pick up
Attendance RecordsAttendance Records
Fails to provide attendance records upon Fails to provide attendance records upon request (lost, misplaced, thrown out). request (lost, misplaced, thrown out).
Submits attendance records that are Submits attendance records that are bogus or altered.bogus or altered.
Does not accurately record absences on Does not accurately record absences on invoices.invoices.
Double bills for service. Double bills for service.
Bills at higher reimbursable rate. Bills at higher reimbursable rate.
Bills higher fees than charges the public.Bills higher fees than charges the public.
Fails to give discount offered to public.Fails to give discount offered to public.
InvoicesInvoices
InvoicesInvoices Bills for service when child is absent a Bills for service when child is absent a
whole month.whole month.
Bills for service that would be disallowed Bills for service that would be disallowed by Agreement for Purchase of Services.by Agreement for Purchase of Services.
Fails to notify LDSS of child’s extended Fails to notify LDSS of child’s extended absences.absences.
Bills for children no longer in attendance Bills for children no longer in attendance (“disenrolled” on attendance).(“disenrolled” on attendance).
InvoicesInvoices
Bills for service when closed when Bills for service when closed when
these days are disallowed by Agreementthese days are disallowed by Agreement
(snow days, day after Thanksgiving, etc.)(snow days, day after Thanksgiving, etc.)
““31 Days of February”31 Days of February”
Caring for children in a location not Caring for children in a location not authorized by the Purchase of Services authorized by the Purchase of Services Order.Order.
StatisticsStatistics SF07 – Child Care Subsidy - $144.6 millionSF07 – Child Care Subsidy - $144.6 million Reviewed 22 ProvidersReviewed 22 Providers
Identified $398,953.39 in overpaymentsIdentified $398,953.39 in overpayments One conviction – 5 years with all but 3 One conviction – 5 years with all but 3
months suspended, served by home months suspended, served by home monitoring - $228,144.17monitoring - $228,144.17
One pending trial One pending trial Court Order/Repayment Agreement - Court Order/Repayment Agreement -
$322,569.68$322,569.68 Restitution - $84,275.12 Restitution - $84,275.12 6 paid in full6 paid in full
Prevention/FraudPrevention/Fraud AwarenessAwareness
Clear program rulesClear program rules
Provider trainingProvider training
Automated systemsAutomated systems
Monitoring and audits – both internal & externalMonitoring and audits – both internal & external
Fraud investigationsFraud investigations
Lessons LearnedLessons Learned--
Failure to communicate among Failure to communicate among programsprograms
Providers misunderstanding of payment Providers misunderstanding of payment
requirements and proceduresrequirements and procedures Complicated payment processComplicated payment process MonitoringMonitoring
Red Flag – no absencesRed Flag – no absences
PresentersPresenters
Sandy Smith – Fraud Program ManagerSandy Smith – Fraud Program Manager
(804) 726-7679 or (804) 726-7679 or [email protected]@dss.virginia.gov
Rob Rizzitello – InvestigatorRob Rizzitello – Investigator
(804) 726-7672 or (804) 726-7672 or [email protected]@dss.virginia.gov
