connecticut department of social services care 4 kids child care subsidy program program integrity...
TRANSCRIPT
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CONNECTICUT DEPARTMENT OF SOCIAL SERVICES
CARE 4 KIDS CHILD CARE SUBSIDY PROGRAM
PROGRAM INTEGRITY METHODS
October 27, 2010
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CONNECTICUT DSS STAFF
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Michael P. Starkowski, Commissioner
Peter Palermino, State Administrator
Theresa Emery, Public Assistance Consultant
Don Beltrame, Public Assistance Consultant
Brian McGuiness, Investigation Supervisor
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AGENDA
• Overview of Care 4 Kids Subsidy Program• History of Program Integrity Methods -
Questions and Answers
• Current Administrative Controls- Questions and Answers
• Fraud Preventive Measures/Results- Questions and Answers
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CONNECTICUT CHILD CARE SUBSIDY PROGRAM
• Outsourced to Statewide R&R Agency, which determines eligibility, processes invoices, etc.
• $100 Million Annual State/Federal Benefits
• 22,000 Kids/15,000 Families Monthly
• Applications - 1,800/month
• Redeterminations – 1,250/month
• 1,400 licensed / 3,500 unlicensed providers
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Connecticut Child Care Subsidy Program Organizational Chart
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DSS QUALITY CONTROL REVIEWS
• Started QC reviews when subsidy program was outsourced in 1997
• Reviews parallel federal SNAP review process
• Statistically valid sample of 100 cases per quarter
• Measured contractor and client error
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QC ERROR FINDINGS(1997-2003)
• Contractor error averaged 5% - 6%
• Client error averaged 15% - 18%
• Client error ranged as high as 23%
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CONTRACTOR ERROR CATEGORIES/INCIDENCE
(1997 – 2003)
• Income computed incorrectly or verified (38%)• Family co-pay not deducted (13%)• Reported or known changes not pursued (9%)• Approved care hours not verified (8%)• Ineligible provider arrangement approved (7%)• School schedule overlapped care hours (5%)• Incorrect household composition (5%)
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CLIENT ERROR CATEGORIES/INCIDENCE
(1997-2003)
• Unreported job loss/did not attend training (24%)
• Misrepresentation of:– Work hours or shift (22%) – Income (4%)
• Provider not available during care hours (15%)
• Unreported:– Income (10%) – Spouse in household (6%) – Change in employment (5%)
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QUESTIONS AND ANSWERSQUESTIONS AND ANSWERS
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CORRECTIVE ACTIONSCORRECTIVE ACTIONS
• Change regulations & procedures• Enhance staff training and development• Increase monitoring (DSS and Contractor)
• Mine data and expand access to other state databases
• Develop fraud detection/prevention strategies
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REGULATION AND PROCEDURE CHANGESREGULATION AND PROCEDURE CHANGES
• Payment for care based on:• A range of hours vs. strict per hour rates (e.g. half and full-
time)
• Enrollment vs. actual attendance
• No change in co-payment between redeterminations
• Go paperless (document imaging)
• Increase utilization of third party verifications
• Amend vendor fraud statute to include child care providers and lifetime disqualification penalty
• Mandate compliance with QA and Investigations
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STAFF TRAINING AND DEVELOPMENTSTAFF TRAINING AND DEVELOPMENT
• Fund 2 full-time contractor training positions
• Establish 3 month training program for newly hired staff
• Increase use of policy transmittals, reminder bulletins and desk aids
• Targeted training and refresher training of error prone categories
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MONITORING
• Greater coordination between DSS and contractor
• Maintain an on-site presence
• Corrective action planning meetings
• Monthly desk reviews by contractor
• Additional system edits
• Annual audits by DSS Child Care Team and state auditor
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DATA MININGDATA MINING• Unlicensed providers with:
– Out-of-state residence– PO Boxes
• Excessive care hours authorized• Number of children in care exceeds
provider limit• Multiple providers reside at same address• System screen data not populated
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DATABASE INTERFACES
• Depts. of Labor, Motor Vehicle, Corrections dbases
• DSS Public Assistance mainframe (EMS)
• TANF E&T dbase• Child Support dbase
and Paternity Registry
• Child abuse/neglect data match
• IRS/TIN data match• NAEYC data match• Licensed provider data
match• Medicaid provider
disability data match
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QUESTIONS AND ANSWERSQUESTIONS AND ANSWERS
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FRAUD PREVENTION MEASURES AND RESULTS
• FRaud Early Detection (FRED) unit created 2005:• Home visits and verification of information• Follow-up home-visits for error prone providers
• Active Case Assessment Program (ACAP) unit created 2007
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DSS QUALITY ASSURANCEDSS QUALITY ASSURANCEORGANIZATION CHARTORGANIZATION CHART
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FRAUD EARLY DETECTION (FRED)
• Purpose – identify, investigate and determine errors before paying benefits.
• Staff – 4 full-time non-law enforcement investigators and 1 unit supervisor
• Complete 120 referrals/mo: 1,421 in SFY 10
• Cost Avoidance –$4.4 million SFY 10
–$15.8 million SFY 08-10
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FRED REFERRAL SOURCES
• 1-800 Fraud hotline• C4K contractor via automated system• DSS eligibility staff• Database matches• Other, i.e. special projects, provider referrals,
law enforcement agencies
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FRED PROCESS REFERRALS
Top 5 Targeted Error Prone Categories
• Self-employment
• Cash employment
• Questionable household composition
• 2nd & 3rd shift work hours
• Young Male Providers
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FRED PROCESS INVESTIGATION
Investigation Steps:• Case reviews and contractor interviews• Database and Internet searches• Third party verification - landlords, employers,
property records, banks, court records, etc.,• Field visit to home, work or child care site• Subpoena authority
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ACTIVE CASE ASSESSMENT PROGRAM (ACAP)
• Parallel to FRED but with active cases
• Staff – 4 full-time non-law enforcement investigators and 1 supervisor
• Investigate historical and current eligibility
• Prepare Arrest Warrant Affidavit
• Testify in court proceedings
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ACAP ACTIVITY(2007 – 2009)
• Completed 1,220 investigations • 142 arrest warrant affidavits
- 50 criminal convictions - 92 accelerated rehabilitation (AR) granted
• 121 program disqualifications• $500,000 cost avoidance in SFY 10• $700,000 recovered in SFY 10
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ACAP ACTIVITY ACAP ACTIVITY (cont.)
• #1 Priority is prosecution• $8,450 - Avg. claim value• $136,000 highest value case• Most adjudicated with full restitution • Lifetime disqualification if provider
convicted or given A&R
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FRED/ACAP PARTNERSHIPSFRED/ACAP PARTNERSHIPS
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QUESTIONS AND ANSWERSQUESTIONS AND ANSWERS
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FOR MORE INFORMATION CONTACT:
CT Child Care Subsidy Program – Child Care Team:Peter Palermino – (860) [email protected]
Don Beltrame (860) [email protected]
Office of Quality Assurance - Fraud & Recoveries Division:Stephen J. Markowski (860) [email protected]
Brian McGuiness (860) [email protected]
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