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Child Care & Development Division

Program Integrity and Improvement Review Guide

Overview

Tuesday, March 29, 2022

CAPPA Presentation

Welcome from the Deputy Director of CCDD

Maria Guadalupe “Lupe” Jaime-Mileham, EdD

Introductions and Housekeeping

• Joycelyn Ward Richardson, Consultant, Program Quality Improvement Branch

• Vanessa Saunders, Staff Services Manager, Program Improvement and Integrity Section

• Jumaane Cowan, Analyst, Program Improvement and Integrity Section

• Program Improvement and Integrity Section Staff

• Housekeeping

Agenda

• Welcome

• Purpose

• Overview of the Review Guide

• Feedback

• Content Topics:

• What is the Program Integrity and Improvement Guide?

• Review Guide Updates

• Pilot Guide

• Error Terms and Definitions

• Elements of the Review Guide

• Closer look into the Review Guide – Breakout Rooms

• Questions

Purpose

The purpose of this presentation is to give you a general overview of the Program Integrity and Improvement Review Guide and how the CCDD and contractor staff can utilize this tool for a family file/error rate review and finally to receive feedback regarding the changes.

Time to be honest: Are you wearing pajamas right now?

A. No!

B. 100% Yes

C. Business on top, pajamas on the bottom

D. I literally changed a minute ago

What is the Program Integrity and Improvement (PII) Review Guide

PII Review Guide

The PII Review Guide was developed to implement federal and state guidelines for reducing errors in child care programs. It also provides clearly written information that can be used in state and federal error rate reviews.

Review Guide Updates

New for this fiscal year:

• Combined AP and Center-based guides

• Regulation Updates (Title 5, WIC)• Adding the timeline for recertifications• New abandonment of care regulation added• Income regulation was updated

• Included language in our introduction to clarify that the questions within the guide are not inclusive of all requirements

• Definitions• Change from Administrative Error to Error

• Email Inbox for feedback ReviewGuideInput@dss.ca.gov

Let’s take a closer look at definitions and layout of the PII Review Guide.

Definitions

Error Terms and Definitions (1)

Improper payment: defined as any payment of CCDF grant funds that should not have been made or that was made in an incorrect amount(including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements governing the administration of CCDF grant funds and includes:

• any payment of CCDF grant funds to an ineligible recipient,

• any payment of CCDF grant funds for an ineligible service,

• any duplicate payment of CCDF grant funds and

• payments of CCDF grant funds for services not received.

(Title 45, Part 98.100(d)(1))

Error Terms and Definitions (2)

• Error: any violation or misapplication of statutory, contractual, administrative, or other legally applicable requirements governing the administration of CCDF grant funds, regardless of whether such violation results in an improper payment. (Title 45, Part 98.100(c))

• Noncompliance Finding: when a contractor is out of compliance with applicable laws, regulations, or contractual provisions. (5 CCR Section 18023(a)(1))

Table of Contents (1)

1. CCDD-801A Monthly Population Report

2. Initial Certification and Recertification (Application for Services)

3. Parent’s Right to Voluntarily Report Changes

4. Contract Eligibility

5. Eligibility

6. Family Size

7. Income Calculation

8. Need for Services

Table of Contents (2)

9. Family Fee

10. Notice of Action

11. Center-based Contracts Attendance

12. Reimbursement Factors for Child Care Development Programs Center-based Contracts Day Designation

13. Family Child Care Home Education Networks – CCTR Contract Only

14. Attendance – Alternative payment/Family Child Care Home Education Network Contracts

15. Reimbursement Determination for Alternative Payment/Family Child Care Education Network Contracts

Table of Contents (Resource Tools)

1. Process to Select Sample Size

2. Error Determination Process

3. Method to Determine Improper Payment Error Amounta) Sample Improper Payment Error Rate Determination Worksheet

4. Error Rate Reduction Plan Processa) Sample Error Rate Reduction Plan Form

Elements of the Review Guide

Elements of the Review Guide: Question Number

Element of the Review Guide : Review Question

Elements of the Review Guide: Findings (1)

Elements of the Review Guide: Findings (2)

Elements of the Review Guide: Findings (3)

Let’s take a closer look at the PII Review Guide

sections

Breakout (1)

How to Use Breakout Rooms

Breakout Room Navigation

Once in your Breakout Room, your bottom navigation will change slightly, providing you with a new Ask for Help button, which will invite the host to your breakout room, and a Leave Breakout Room button, which will return you to the Main Room.

Breakout Rooms (1)

Room 1 – Section 2 - Initial Recertification and Recertification

Room 2 – Sections 3 and 5 - Parent’s Right to Voluntarily Report Changes

and Child Protective Services/At Risk

Room 3 – Section 4 – Contract Eligibility (Stages 2 and 3)

Room 4 – Section 5 B - Need for Services Employment Income, Self-Employment

Income and Self-Certification of Income

Room 5 – Section 5 C, D, E – Need for Services Current Aid Recipient,

Homelessness, Exceptional Needs

Room 6 – Sections 6 and 7 – Family Size and Income Calculation

Room 7 – Sections 8 A, B and C – Need for Services Employment, Self-

Employment and Sleep/Travel Time

Discussion (1) Write down your breakout room number

1. Write down your breakout room number

2. Once in your room:• Determine who will take notes

• Elect someone to share out when we come back together

3. Answer the following questions about your assigned section:• In your assigned section, what documentation will be reviewed to

determine compliance?

• In the Findings column of your section be prepared to discuss 2 findings. Why would it be considered a finding of Improper Payment, Error or Non-Compliance

• What is something you noticed while reviewing this section?

20-Minute BREAKOUT Room (1)

Breakout Room Report OutFeedback and Discussion (1)

Use four minutes to share out:

• Breakout Room Number

• PII Review Guide Section reviewed

• What documents would you utilize to determine compliance?

• What types of errors could come out of that section and why?

• Finally, what is something interesting you noticed while reviewing this section?

Let’s take a closer look at the PII Review Guide

sections…

Breakout (2)

Breakout Rooms (2)

Room 1 – Sections 8 E and F – Need for Services Educational Programs, and Vocational Training

Room 2 – Sections 8 G, H, and I – Need for Services Parental Incapacitation, Homeless, and Seeking Permanent Housing

Room 3 – Sections 8 J and K, and 9 – Need for Services Child Protective Services,

and At Risk, and Family Fee

Room 4 – Sections 14 and 15 A and B Attendance Alternative Payment, and

Reimbursement determination (electronic Reimbursement and Timely Provider

Payments)

Room 5 - Sections 15 C, D,E –Attendance Licensed Child Care Center/Licensed

Family Home. Licensed Exempt Provider, Multiple Providers

Room 6 – Sections 15 F, G and H – Regional Market Rate Selection, Provider

Reimbursement, Reimbursable Hours of Care

Room 7 – Sections 8 D and 10 -Seeking Employment and Notice of Action

Discussion (2) Write down your breakout room number

1. Write down your breakout room number

2. Once in your room:1. Determine who will take notes2. Elect someone to share out when we come back together

3. Answer the following questions about your assigned section:1. In your assigned section, what documentation will be reviewed to

determine compliance? 2. In the Findings column of your section be prepared to discuss 2

findings. Why would it be considered a finding of Improper Payment, Error or Non-Compliance

3. What is something you noticed while reviewing this section?

20-Minute BREAKOUT Room (2)

Breakout Room Report OutFeedback and Discussion (2)

Use four minutes to share out:

• Breakout Room Number

• PII Review Guide Section reviewed

• What documents would you utilize to determine compliance?

• What types of errors could come out of that section and why?

• Finally, what is something interesting you noticed while reviewing this section?

Let’s take a closer look at the PII Review Guide’s Resource Tools

Process to Select Sample Size

To complete a sample size, go to Raosoft

Input the following in the boxes:

• Margin = 10%

• Confidence Level = 90%

• Population size = the total number of children reported to CCDD on the 801A data report for the selected sample month

• Response distribution = 15%

Error Determination Process

When errors (Excluding improper payments) exceed the threshold percentage establish by the CCDD, the contractor will develop a Corrective Action Plan.

1. Analyze the identified errors to determine how and why the errors were made;

2. Develop the process necessary to remedy the errors;

3. Develop specific training for all staff involved;

4. Develop a Quality Assurance Process to validate the accuracy of documentation and processes; and

5. Establish a timeline for implementation.

Method to Determine Improper Payment Error Amounts

There is a section to help a contractor determine the Improper Payment error amount, the following slides are the examples that are in the PII Review Guide

Example 1: Improper Payment Determination

Example: Provider was reimbursed $500 for the sample month:

• If there is missing/insufficient documentation for the entire sample month, the error equals the cost of services provided.

Example:

$500.00 - Provider Reimbursement (plus)$000.00 - Correctly Calculated Reimbursement

$500.00 - Improper Payment Error Amount

Example 2: Improper Payment Determination

Example: Provider was reimbursed $500 for the sample month:

• If there is missing/insufficient documentation for any portion of the month, the error will equal the difference between what was reimbursed, and the correctly determined reimbursement based on sufficient documentation.

Example:

$500.00 - Provider Reimbursement (minus)$275.00 - Correctly Calculated Reimbursement

$225.00 - Improper Payment Error Amount

Error Rate Determination

The contractors Error Rate is based on the total dollars in error

Formula to determine Error Rate Percentage:

Total dollars in ERROR

divided by

the total dollars REIMBURSED will

equal

the ERROR RATE PERCENTAGE

Error Rate Reduction Process

When an error rate is 10 percent or above, the contractor shall develop an Error Rate Reduction Plan.

To develop an Error Rate Reduction Plan, the contractor should:

1. Analyze the identified errors to determine how and why the errors were made;

2. Develop the process necessary to remedy the errors;

3. Develop specific training for all staff involved;

4. Develop a Quality Assurance Process to validate the accuracy of documentation and processes; and

5. Establish a timeline for implementation.

Sample Error Rate Reduction Form

Final Thoughts/Questions

Next Steps

• Take back feedback from todays review/discussion

• Edit the PII Review Guide accordingly

• Present the PII Review Guide at a Statewide webinar

• Date to be determined

• Final edits to the PII Review Guide based on feedback from Statewide webinar

• Post the final PII Review Guide to the CCDD Website

Thank You!

Please email us with any comments or questions:

Review Guide Input Inbox:ReviewGuideInput@dss.ca.gov