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"Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010. Presenters. Linda Saterfield , Acting Director, Human Capital Development Division - IDHS
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"Stopping Improper Payments Before They Start: The Past, Present, and Future ofProgram Integrity in Illinois". December 2, 2010
Presenters Linda Saterfield, Acting Director, Human Capital Development Division - IDHS Richard Martin, Manager, Program Integrity and Quality Assurance Unit – IDHS Michael Garner-Jones, Training ManagerBureau of Child Care – IDHS Paul Swaney, Director of Quality Improvement- Illinois Action for Children
Handouts • Slide show • Resource Guide • Web Resource List • Monitoring instrument
Introduction Linda Saterfield GAO Report Increased focus on accountability
History of Illinois CCAP • CCR&R System expanded from parent referrals to include assistance program • Inclusion of Site Administered program • All employment and educational related child care assistance programs in one agency • Aligned all eligibility to income, service, residency and age of child
History of Illinois CCAP State provides standardized policies, procedures, tools and guidelines Contracted agencies encouraged to use innovation and local resources to determine best practices for verifying eligibility State evaluates these best practices and standardizes for entire program Monitoring and quality assurance systems developed to ensure accountability
Current CCAP • Dual delivery system • Certificate Program – 16 CCR&Rs • Regional management for determination of eligibility and payments to all provider types • Site Administered Program – 44 Contracted Center Providers • Centers who determine eligibility for their own caseload • Payment done through IDHS • City of Chicago Family Support System • 200 Delegate Agencies • Case management system of their own
Current CCAP • Stopping improper payments before they happen • Lack of adequate number of monitors and investigators • Illinois has lowest ratio of State workers per capita in nation • Focus on early detection of ineligible families • Dedicated, well trained contract staff • Strong state-wide support network • Access to data from other State agencies the family may have interaction with • Identification of other resources
Year 1 IPP Results • Prompted focused trainings on problem areas • Webinars • Regional meetings • On-site • Policy and procedure review • Examination of varying interpretations • High level committees to clarify issues and reduce barriers • Refocus on federal guidelines to ensure program is family friendly, child focused, fair to providers and accountable
Can You . . . Perplex the Presenter?
Monitoring Data • Doing more with less. • Annual CCAP Caseload – • Families -155,520 • Children -289,256 • 16 CCR&Rs monitored - triannually • 44 Site Providers • 50-80 Certificate Providers monitored • Only 3-4 IDHS Monitors • Cases referred to BOI and other agencies for investigation
Monitoring Method • Philosophy • Sample pull • Tool • 10 review areas • Draft report • Agency responses • Final report • Corrective actions/next steps
IPACS Process(Illinois Public Aid Communication System) • The IPACS process uses an array of databases to validate the information provided by all customers at application and redetermination • The IPACS information is used with other relevant facts in determining eligibility • More recent documentation • Pay stubs
IPACS Process(Illinois Public Aid Communication System) Databases are accessible by all CCAP eligibility workers as part of the Child Care Tracking System Staff toggle from one system to another A key factor in identifying issues in the GAO study
IPACS TANF/SNAP/Medical PASDX (SSA and SSI payment information) AWVS (Automated Wage Verification System) KIDS (Child Support Enforcement records) Department of Public Health (Birth records) CPS On-Line (Chicago Public Schools)
Sample AWVS Screen MORE INFORMATION ON NEXT PAGE -- DEPRESS PA1 PAGE 1 04/17/2002 AWVS INQUIRY SYSTEM OF 2 SSNO: XXX XX XXXX YEAR: QTR: CLAIMANT: LAST NAME, FIRST NAME BIRTH: 12/15/1970 STREET ADDRESS SPOUSE: CITY OR TOWN STATE ZIPCODE COUNTY: 200 COOK ALIAS SSNO: CLAIM DATE: 12/31/2000 LATEST CHK: 07/18/2001 WKLY BASIC BEN: 111.00 BENEFIT PERIOD: 12/31/2000 THRU 12/30/2001 DEP ALLOWANCE: 36.00 MAX BEN AMT: 2,886.00 MAX BEN BAL: WK BEN AMT: 147.00 EMPLOYER ID/NAME/PLANT/ADDR/CITY/ST/ZIP ---------- WAGES BY QUARTER ---------- 1/2001 2/2001 3/2001 4/2001 1705724 EMPLOYER NO. 1 000 STREET ADDRESS CITY OR TOWN STATE ZIPCODE 252 92 4205110 EMPLOYER NO. 2 STREET ADDRESS CITY OR TOWN STATE ZIPCODE 1248 PAY DATE AMOUNT WKS PD PAY END-DT | PAY DATE AMOUNT WKS PD PAY END-DT 07/18/2001 147.00 01 07/07/2001 | 07/05/2001 294.00 02 06/30/2001 06/20/2001 294.00 02 06/16/2001 | 06/06/2001 294.00 02 06/02/2001 05/23/2001 294.00 02 05/19/2001 | 05/09/2001 294.00 02 05/05/2001 04/25/2001 294.00 03 04/21/2001 |
Resource Guide Recognized there were questionable cases that were managed differently throughout the State Asked CCR&R’s for suggestions on the most challenging cases and methods and resources used to resolve them Developed Resource Guide as a supplement to policy manual to assist staff with challenging cases
Resource Guide Philosophy Sets standard of being objective when determining eligibility Using non-judgmental language CCR&R staff determine eligibility; not to be investigators When program violation occurs, it is not the role of staff to determine if the violation occurred intentionally or not Promote customer service with a goal of helping families
Determining the status and income of non-parent adults claimed in the family unit Useful Approaches The Work Number website to verify client’s employment/income that appeared in AWVS www.worknumber.comAgency needs to sign a contract prior to using the WorkNumber. To verify the amount of refund on the reported tax form: https://sa1.www4.irs.gov/irfof/lang/en/irfofgetstatus.jsp Information needed to access this feature is a social security number and refund amount. If it has been over six months a submittal date is also needed. The website www.paycheckcity.com does not provide information about specific clients rather gives examples of check stubs that could have been printed from the website.
Examples Application for care from a relative who alleges custody of child w/o legal guardianship or written consent from either parent. One parent is denied based on income. Soon after the denial, the other parent applies for care. Useful Approaches Check child’s SSN in IPACS ACID page 1 to determine if child is active in an assistance unit. Verify custody by calling school to determine who is listed as parent/guardian. If the child attends a Chicago Public School, use PF15 for verification. If one parent is believed to be incarcerated check IDOC website (www.idoc.state.il.us) or for federal prisons check (www.bop.gov) for status.
Additional Tools Quality Reviews Trainings Policy Clarification System/Reports Appeals Problem Resolutions
Overpayments • Determined during monitoring, quality reviews or case work activities • Letter to responsible party • Referral to Bureau of Collections • Referral to Office of Comptroller • Referral to private collection agencies • Sanctions
Let’s See if We Can . . . Torment the Trainer
Illinois Action for Children • Approximately 48,000 active clients on the Child Care Assistance Program in Cook County • 55% of statewide caseload • Part of the Illinois Resource & Referral Agencies • Process over $350M in Child Care Assistance Program payments annually
Internal Controls • Ensure integrity within our organization • Annual ethical conduct agreement forms • Annual mandatory training for our 400 staff on program integrity violation prevention • Anonymous reporting line through EthicsPoint • Forms foundation of awareness for preventing program violations in Child Care Assistance Program
Web-Based Resources • Staff are equipped with, and encouraged to use, web-based resources including: • Department of Corrections, Bureau of Prisons • IRS • Google Maps • Work Number • Assessor’s Office • Others
Program Integrity Lead • We have a Program Integrity department devoted to reviewing cases • Even if you are unable to have a department, it is important to identify lead staff to develop consistency. • Referral mechanisms inside your processing groups to allow staff to refer cases for additional review • Best Practice Manual • Catching issues before they start
GAO Investigation • September 2010, Government Accountability Office (GAO) publishes report detailing the results of their attempts to gain access to Child Care Assistance in 5 states. • Illinois was the only state to prevent their attempts • Illinois was also the only state tested that uses a Resource & Referral model for processing eligibility of applicants.
Key Factors to Success • Online Resources • Staff Training • Internal Alert System to warn other staff of what to look for in subsequent attempts
Future of CCAP • CCMS • Automated links to other resources to assist staff/improve time • Ad Hoc Reporting • Alerts • Solidifies business flow • Review of State systems (IPACS) • Revisit policies and procedures • Time to update best practices
"Stopping Improper Payments Before They Start: The Past, Present, and Future ofProgram Integrity in Illinois". December 2, 2010