CCAP Case Reviews

1. CCAP Case Reviews MFWCAA Conference September 30, 2009

2. Session Agenda • Introduction • Improper Authorizations for Payment (IAP) Reviews • Case Management Reviews (CMR) • Differences & Similarities of Both Reviews • Question & Answer

3. Improper Authorizations for Payment (IAP) Review Topics • Background Information • Generating a Sample of Cases for Review • Conducting the Case Reviews • Completing the Federal IAP Report

4. IAP Background Information

5. 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.

6. 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.

7. 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. • DHS Bulletin 08-68-13 & October 2008 Videoconference

8. Generating a Sample of Cases for IAP Review

9. Generating a Sample of Cases for IAP Review Generating the sample of cases for review consists of the following two tasks: 1. Create the sampling frame 2. Selecting the sample.

10. Generating a Sample of Cases for IAP Review • DHS will complete the selection of cases to be reviewed by the end of November • Local agencies will be notified beginning in December if any of their cases have been selected. • Local agencies will have 10 days to submit the records. • DHS will promptly return original records to local agencies.

11. Conducting the IAP Case Reviews

12. Conducting the IAP 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) • DHS Internal Audits staff will conduct the CCAP reviews • The reviewers will be trained in November on CCAP Policy & MEC2 Integrated • The reviews will begin in December and conclude in March

13. Customize the IAP 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.

14. IAP 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.

15. IAP Case Review Definitions • Improper authorization for payment • 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.

16. IAP 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 other than those used to administer CCAP. • A case without proper documentation will be considered an error, regardless of its impact on the authorized amount.

17. IAP Review Elements • Application/Redetermination Forms • CCAP application/redetermination forms • Child Support forms • Priority Group Placement • Child Care sub-programs - MFIP, TY, TYE or BSF

18. IAP Review Elements • Qualifying Head of Household • Parent/s meet definition of parent for CCAP eligibility • Residency • 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 • Citizenship

19. IAP Review Elements • Qualifying Care • Number of authorized hours and type of care needed based on parent’s hours of authorized activity, child’s age and child’s schedule. • Include special circumstances, special needs or School Readiness Connection (SRC) policy, • Qualifying Provider Arrangement • Identify the type of arrangement, center based, family based, or in-home care provider that is legally operating and, eligible to receive CCAP payment.

20. IAP Review Elements • Provider Requirements • Authorization/Registration of Child Care Provider for the review period • Valid license • Registration forms completed, i.e. policies and rates • W-9 on file • County optional policies applicable to Provider registration

21. IAP Review Elements • Income • Income documentation for family members, including specific time period and all countable income based on State policies and definitions. • Copayment determination • Income Eligibility • Determine if the family’s income meets State requirements (annual income is within 47% to 67% of SMI).

22. IAP Review Elements • 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).

23. IAP Review Elements • Authorizations / Computations • 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. • Indicate if the error is due to missing or insufficient documentation. • This is a summary of all errors that may have been identified in a case.

24. Completing the Federal IAP Report

25. 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 authorizations for payment (% of funds authorized that are improperly authorized) • Average amount of improper authorization for payment • Estimated annual amount of improper authorizations for payment

26. 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.

27. Case Management Review (CMR) Topics • Background - DHS Bulletin 08-03-03 • Conducting Full CCAP Reviews – Family & Provider • Conducting Targeted CCAP Reviews • Differences compared to IAP Reviews

28. CMR Background • Since 2000, DHS has provided guidance and forms to counties to conduct case management reviews, issued via bulletins in 2000, 2002 and 2003. • A CMR bulletin was issued again in 2008 to capture program and system changes and to add the CCAP to the process. • See Bulletin #08-03-03

29. CMR Background • A multi-program CMR workgroup was convened to work on updating the CMR processes issued in the 2008 Bulletin. • In addition, each program (FS, MFIP, Health Care and CCAP) had its own workgroup. • The CCAP workgroup involved local agency staff from multiple agencies.

30. CMR Background • The bulletin identifies a full review as a review of all programs a family might be receiving – MFIP, FS, Health Care and CCAP. • The bulletin identifies a partial review as a review of only Health Care or CCAP. • A targeted review focuses on specific elements within a case, on a specific policy or error prone area.

31. CMR Forms • Part I is to be used when reviewing MAXIS/MMIS data integrity • Part II is to evaluate expected outcomes of a case, ensure appropriate communications and verify benefit accuracy. It focuses mainly on MFIP/FS • Part III is an in-depth review of health care eligibility

32. CMR Forms • Part IV is an in-depth family review of child care assistance • Part V is an in-depth provider review of child care assistance • Part VI is a communication tool used to share results of the review between the reviewer and worker and summarize corrective action taken

33. Case Review – Part IV:CCAP – Family Review • DHS – 5312D is available through eDocs as a fillable form • This form identifies eight areas of family eligibility to be reviewed. • Areas to be reviewed include: • General Eligibility • Child Support Cooperation • Authorized Activities and Authorizing Care

34. Case Review – Part IV:CCAP – Family Review • Areas to be reviewed (continued): • Income Calculation • Copayment Determination • Payments and Payment Policies • Improper Payments • Overview – General Information

35. Case Review – Part V:CCAP – Provider Review • DHS – 5312E is available through eDocs as a fillable form • This form identifies two areas of provider eligibility to be reviewed. • Areas to be reviewed include: • Provider Elements • Overview – General Information

36. Case Review – Part VI • DHS – 5312F is available through eDocs as a fillable form • This form captures the reviewer’s comments and the worker’s responses. • This form also clearly identifies the corrective action taken based on the review.

37. Targeted Review:CCAP – Income/Copayment • DHS – 5316 is available through eDocs as a fillable form • This targeted review focuses on the Income Calculation and Copayment Determination processes • It also includes an Overview section

38. Differences with IAP Reviews • Case management reviews are conducted by local agencies while IAP reviews are conducted by state staff. • CMRs should occur on a regular ongoing basis and IAP reviews will occur on a three year cycle. • IAP reviews use a very specific sample selection process while local agencies direct how cases are selected for CMRs. • IAP reviews define a case as a child; case management reviews define a case as a family.

39. Differences with IAP Reviews • Both reviews consider eligibility determination and providers. CMRs are focused on payments made while IAP reviews are focused on whether the amount of child care authorized was appropriate. • The elements reviewed in each process are similar but are grouped in different ways. • Different forms are used for each type of review, reflecting the different groupings of elements.

40. Common Goals of Both Reviews • Improve accuracy in program administration • Improve payment accuracy • Improve case documentation • Identify policy & procedural changes

41. Resources • DHS bulletin #08-68-13 – CCAP Case Reviews • DHS bulletin #08-03-03 – Case Management Review Forms and Guides • Federal Rule, Instructions and Forms www.acf.hhs.gov/programs/ccb/law/guidance/current/pi2007-08/pi2007-08.htm

42. Questions & Answers

43. Questions • Please submit questions to your CCAP Policy Liaison • Regions 1, 11 Joan Anderson • Regions 2, 3, 7E, 7W Kelly Simons • Region 4, 5, 10 Brenda Clark • Regions 6E, 6W, 8, 9 Stacia Rosas