To comply with the federal Improper Payments Information Act of 2002, as amended by the Improper Payments Elimination and Recovery Act of 2010 and the federal Single Audit Act of 1984 (P.L. 98-502) with amendments in 1996 (P.L. 104-156), the Office of Management and Budget (OMB) Circular A-133 and the Minnesota Office of Legislative Auditor, DHS randomly selects CCAP cases to be reviewed each month. Agencies are required to submit selected case files to DHS for review.
The DHS case review examines the following areas:
· Presence, date, and completeness of required eligibility forms including applications, redetermination forms, change report forms, and child support enforcement forms.
· Subprogram received by the family.
· Determine if applicant meets parent definition including documentation of the applicant’s relationship to the selected child and the applicant’s identity.
· Determine if applicant meets residency requirements including documentation of residency.
· Determine if child’s parent or parents are in an authorized activity that is appropriate to the CCAP subprogram including documentation of the participation.
· Determine if the selected child is eligible for CCAP including whether the child is of the appropriate age to receive CCAP and documentation of their age, and whether the child meets citizenship & immigration requirements and supporting documentation.
· Determine number of hours needing authorization based on the parent’s participation in an authorized activity and the child’s needs, including documentation of parent and child schedules. Determine if there is a difference between the worker’s authorized hours and the reviewer’s authorized hours.
· Determine the type of child care provider, that the provider met registration requirements including complete provider registration and acknowledgment forms, and complete parent acknowledgement form for each legal non licensed provider.
· Determine if the income and expenses, family size, copayment fee, maximum rate were accurate including documentation of counted income and expenses, identity and relationships of all family members and provider accreditations.
Agency actions that do not comply with CCAP policy may be determined to be errors with or without a potential financial impact. The responsible agency may be subject to corrective action plan requirements for specific cases. Errors with a potential financial impact are subject to overpayment / underpayment policies.
One of the most successful tools in attaining and maintaining high payment accuracy is a good case management review system. Case management reviews can help to determine root cause(s) of errors and therefore identify specific areas needing corrective action, such as policy clarification, refresher training, changes in office procedures, improved case record documentation, etc.
There are a number of different approaches to case management reviews. For example a full case review would encompass all aspects of a family's CCAP case information and/or a child care provider's information. A targeted review is focused on specific elements within a case, a specific policy or error prone areas.
DHS strongly encourages counties and tribes to conduct their own case management reviews. This practice can reduce errors that DHS might identify at the time of the DHS case review.
DHS created a case management review process and forms for counties and tribes to utilize. These forms may be accessed through eDocs. Counties and tribes may choose to create their own process and forms that have been customized to reflect their administrative practices and optional policies. County and tribal developed forms must be submitted and approved by DHS as part of or as an amendment to their County or Tribal Child Care Fund Plan.
Listed below are common errors found in DHS CCAP case reviews. Errors may result in overpayments and have negative impacts on families.
· Acting on Reported Changes
- Changes are reported by families and not acted on, or are processed incorrectly by agency workers. For instance, a family reports a change in their income but the agency worker doesn’t obtain the verification. Or, sometimes the family reports a change and the agency worker obtains verification but doesn’t make the change, even if the change resulted in a new copayment.
- In some cases, changes are reported or new information is received, but not acted on by the agency worker. Not processing the family changes often lead to another error because notices are not generated to inform families and providers of changes. CCAP agencies must act on changes within 10 days, and proper documentation and processing of changes need to occur. When applicable, a worker must allow families 15 days to return verifications and give the family information about the types of verification required.
- See Chapters 8.1 (Changes in circumstances) and 12 (Notices).
· Copayment Calculated Incorrectly
- Copayment errors occur when incorrect income and deduction information is entered in MEC2. Examples include: incorrect income and deduction amounts and incorrect payment frequency such as semi-monthly instead of biweekly. Carefully code all income and deduction sources identified on the application so MEC² can accurately calculate the copayment. Explain in case notes how the income and deduction amounts were deteremined.
- Another common error associated with incorrect copayments is incorrect self-employment amounts due to inappropriately applying allowable deductions. Carefully consider which self-employment expenses meet the allowable deductions policy. Explain in case notes how self-employment income was determined.
- Copayment errors also occur when the CCAP family is determined incorrectly. Carefully code the family members so MEC² can accurately calculate the copayment.
- See Chapters 5.3 (Determining the CCAP family), 6.15 (Annualizing income), 6.15.6 (Annualizing self employment income), 6.18 (Income deductions) and 6.21 (Family copayment).
· Incorrect Authorized Hours
- Errors with authorized hours occur when the incorrect number of hours for the participant’s authorized activity and child’s participation in pre-school, Head Start or school are determined. Authorizing care for participants with employment plans, flexible schedules and for school-aged children have been particularly error-prone. Carefully evaluate these factors based on authorizing care policies when determining authorized hours for each eligible child. Explain in case notes how authorized hours were determined.
- See Chapters 9.1 (Child care authorization), 9.1.3 (Authorizing care – School release days), 9.1.6 (Authorizing care – Flexible schedules), 9.1.9 (Authorizing care – Multiple providers), 9.1.12 (Weekly authorization to high quality providers), 9.12 (Authorized hours – Students), 9.15 (Authorized hours – Employment), 9.15.1 (Authorized hours – Self employment),
9.18 (Authorized hours – Job search), 9.21 (Authorized hours – Combinations of activities), and 16.1 (CCAP authorizations for clients with an EP).
Minnesota Statutes 256.017, subd. 1
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45 CFR Part 98 Subpart K
OMB Circular A-133