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Child Care & Development Division
Program Integrity and Improvement Review Guide
Overview
Tuesday, March 29, 2022
CAPPA Presentation
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
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 [email protected]
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
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?
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?
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?
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?
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.
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:[email protected]