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