DHS case reviews

Program, Compliance & Audit (PC&A) Case Reviews

The federal government requires states and territories to conduct child care subsidy case reviews in compliance with 1) the federal Improper Payments Information Act of 2002 (IPIA), as amended; 2) the Improper Payments Elimination and Recovery Act of 2010 (IPERA); 3) the Improper Payments Elimination and Recovery Act of 2012 (IPERIA); and 4) Executive Order 13520 – Reducing Improper Payments – 2009. The IPIA requires agencies to adhere to guidance prescribed by 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 A-123 and the Minnesota Office of Legislative Auditor.

PC&A case review considers worker actions that affected the review month and CCAP policies in place at the time of those actions. PC&A examines documentation available to the worker when they took action for the following areas:

· Required eligibility forms.

· Family’s subprogram.

· Applicant’s eligibility.

· Residency requirements.

· Child's eligibility.

· Authorized activities.

· Hours authorized.

· Provider’s registration and authorization requirements.

· Maximum rates and provider accreditations.

· Income and expenses, family size and copayment fee.

· Identity and relationships of all family members.

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 required to complete a corrective action plan form for specific cases. Errors with a potential financial impact are subject to overpayment and underpayment policies. See Chapter 14 (Overpayments) to determine when to assess an overpayment. See Chapter 9.57 (Correcting Underpayments) to determine when to assess an underpayment.

CCAP Accuracy Reviews

· The department randomly selects CCAP cases for review approximately once every quarter. This is to comply with the Legislative Auditor recommendation to expand its quality assurance reviews of local human service agencies.

· Case accuracy reviews focus on policies used when establishing eligibility, authorizing care, registering the provider or making payments.

· See Chapter 16.44 (Accuracy Review Reporting) for more information about these reviews.

CCAP agency reviews

The department strongly encourages CCAP agencies to conduct their own case management reviews. 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. Three options for conducting case reviews are below.

Completing CCAP case review form

CCAP agencies can use the DHS-5312D-ENG (PDF) Family Review Form for internal review.

Completing case accuracy review forms

Case accuracy review forms remain available on eDocs for CCAP Agency use once department review of a policy is complete. Current case accuracy review forms can be found on eDocs by searching form number 7356. Case accuracy review forms include DHS-7356 and forms with the same number followed by a letter.

Agency-created process and forms

CCAP agencies may create their own process and forms customized to reflect their administrative practices and optional policies. Forms developed by CCAP agencies must be submitted and approved by the department as part of or an amendment to their County or Tribal Child Care Fund Plan.

Common errors found in DHS CCAP case reviews

Listed below are common errors found in DHS CCAP case reviews.

Copayment calculation

Common copayment errors occur when:

· Income and expense calculations are not consistent with verifications on file. Examples include wrong timeframe used to annualize income and unemployment calculated incorrectly.

· Self-employment income calculated incorrectly.

· Data is entered incorrectly into MEC2. Examples include incorrect wage information, entering incorrect payment frequency and not determining income using the last 30 days of income or the last six months of child support income.

· Case notes do not identify the method used to determine income when something other than the most current 30 days or the last six months of child support are used.

Carefully code all income and deduction sources identified on the application or redetermination so MEC² can accurately calculate the copayment. Explain in case notes how the income and deduction amounts were determined. It is important to review Case Data windows and eligibility results in MEC2 before approving.

See the following CCAP manual chapters for more information:

· 5.3 Determine the CCAP Family

· 6 Income Eligibility

· 6.15 Annualizing Income

· 6.15.6 Annualizing Self-Employment Income

· 6.18 Income Deductions

· 6.21 Family Copayment

Authorized hours calculation

Common authorized hours errors occur when:

· More or less care is authorized than the child was eligible for and is inconsistent with the verification.

· Fewer hours are authorized than identified in the employment plan without a reason.

· An incorrect child’s school schedule is used.

· Documentation of authorized hours calculation in case note is different than the hours shown on the service authorization.

Errors occur when the number of hours determined based on the family’s authorized activity, child’s school schedule and provider’s availability are incorrect. Carefully evaluate these factors based on authorizing care policies. Explain in case notes how authorized hours were determined.

See the following CCAP manual chapters for more information:

· 9.1 Child Care Authorization

· 9.1.1 Authorizing Care-Employment

· 9.1.1.1 Authorizing Care-Self-Employment

· 9.1.2 Authorizing Care-Students

· 9.1.3 Authorizing Care-School Release Days

· 9.1.4 Authorizing Care-Job Search

· 9.1.5 Authorizing Care-Employment Plans

· 9.1.6 Authorizing Care-Flexible Schedules

· 9.1.7 Authorizing Care-Combinations of Activities

· 9.1.9 Authorizing Care-Multiple Providers

· 9.1.10 Authorizing Care-Switching Providers and Back-Up Providers

· 9.1.12 Weekly Authorization to High Quality Providers

· 9.1.15 Authorizing Care-Expedited Child Care

Verifications

Common verification errors occur when:

· Relationship verification including documentation establishing step-parent relationship is missing.

· Self-employment income verification is inaccurate or insufficient.

· Work schedule for one or both of the parentally responsible individuals is missing.

· Income and deduction verification is missing.

Verifications are required to determine eligibility of the individuals within the CCAP family. Work schedules are required to authorize care appropriately. Obtain and review all required verifications before determining eligibility and authorizing care for a family.

See the following CCAP manual chapters for more information:

· 7 Verification

· 7.3 Verification - Initial Application

· 7.4 Verification - 12-Month Eligibility Period

· 7.6 Verification - Eligibility Redetermination

· 7.9 Income Verification

· 7.27 Schedule Verification - Employment and Education

Authorized activity

Common authorized activity errors occur when:

· Continued authorization is allowed beyond the Extended Eligibility timeframe.

· Eligibility for employment or self-employment is approved when minimum work requirements are not met.

Carefully evaluate activity verification before determining eligibility for a family.

See the following CCAP manual chapters for more information:

· 4.6 CCAP Authorized Activities

· 4.6.6 Authorized Activities Outside an Employment Plan

· 8.1.9 Changes in Activity

· 9.1.1.1 Authorizing Care - Self-Employment

· 9.15.6 Extended Eligibility

Legal authority

Minnesota Statutes 142E.14, subd. 2
Minnesota Statutes 142A.10
Minnesota Statutes 256.017, subd. 1
45 CFR Part 98 Subpart K
P.L. 98-502
P.L. 104-156
OMB Circular A-133