10.2 Fraud Investigation, Payment Recovery, and Sanctions

Lead Agencies must have the necessary controls to identify fraud and other program violations to ensure program integrity. Program violations can include both intentional and unintentional client and/or provider violations, as defined by the Lead Agency. These violations and errors, identified through the error-rate review process and other review processes, may result in payment or nonpayment (administrative) errors and may or may not be the result of fraud, based on the Lead Agency definition. 10.2.1 Strategies used to identify and prevent program violations Check the activities the Lead Agency employs to ensure program integrity, and for each checked activity, identify what type of program violations the activity addresses, describe the activity and the results of these activities based on the most recent analysis. a. [x] Share/match data from other programs (e.g., TANF program, Child and Adult Care Food Program, Food and Nutrition Service (FNS), Medicaid) or other databases (e.g., State Directory of New Hires, Social Security Administration, Public Assistance Reporting Information System (PARIS)). i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: OEC has access to and incorporates data from other programs within state agencies. This information is cross referenced when determining eligibility. Having access to other state agencies and program information allows OEC to better identify irregularities in attendance and/or billing patterns, as well as identify eligibility determinations that may have been made using inaccurate or incomplete data provided by the applicant. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: OEC has access to and incorporates data from other programs within state agencies. This information is cross referenced when determining eligibility. Having access to other state agencies and program information also allows to better identify irregularities in attendance or billing patterns, as well as identify eligibility determinations that may have been made using inaccurate or incomplete data provided by the applicant. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice:: OEC has access to and incorporates data from other programs within state agencies. This information is cross referenced when determining eligibility. Having access to other state agencies and program information also allows us to better identify irregularities in attendance or billing patterns, as well as identify eligibility determinations that may have been made using inaccurate or incomplete data provided by the applicant. b. [x] Run system reports that flag errors (include types). i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: OEC utilizes the Office of Information Technology to run reports to identify providers and casehead who have indicators that suggest that an intentional or unintentional violation or administrative error may have occurred. The reports reflect potential violations/errors. Examples of the types of reports/data elements are noted in the bulleted list below: • System report identifying active cases with no authorizations; • System report identifying cases active over five years; • System report identifying cases over the new income limits; • System report identifying cases with no children; • System report identifying case managers; • System report identifying cases with an invalid address; • System report identifying the percentage of authorizations assigned to a provider approved by the same case manager; and • Comparison of the capacity of a child care provider to the number of children they bill for. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: OEC utilizes the Office of Information Technology to run reports to identify providers and casehead who have indicators that suggest that an intentional or unintentional violation or administrative error may have occurred. The reports reflect potential violations/errors. Examples of the types of reports/data elements are noted in the bulleted list below: • System report identifying active cases with no authorizations; • System report identifying cases active over five years; • System report identifying cases over the new income limits; • System report identifying cases with no children; • System report identifying case managers; • System report identifying cases with an invalid address; • System report identifying the percentage of authorizations assigned to a provider approved by the same case manager; and • Comparison of the capacity of a child care provider to the number of children they bill for. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: OEC utilizes the Office of Information Technology to run reports to identify cases that have indicators that suggest that an intentional or unintentional violation or administrative error may have occurred. The reports reflect potential violations/errors. Examples of the types of reports/data elements are noted in the bulleted list below: • System report identifying active cases with no authorizations; • System report identifying cases active over five years; • System report identifying cases over the new income limits; • System report identifying cases with no children; • System report identifying case managers; • System report identifying cases with an invalid address; • System report identifying the percentage of authorizations assigned to a provider approved by the same case manager; and • Comparison of the capacity of a child care provider to the number of children they bill for. c. [x] Review enrollment documents and attendance or billing records. i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: OEC systems generate reports to assist with billing reviews and attendance information. Information from the reports can be compared to provider attendance and billing records. If errors are identified, they are investigated and can result in a provider/casehead overpayment, corrective action and/or termination from the Child Care Assistance program ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: OEC systems generate reports to assist with billing reviews and attendance information. Information from the reports can be compared to provider attendance and billing records. If errors are identified, they are investigated and can result in a provider/casehead overpayment, corrective action and/or termination from the Child Care Assistance program. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: OEC systems generate reports to assist with billing reviews and attendance information. Information from the reports can be compared to provider attendance and billing records. If errors are identified, they are investigated and can result in a provider/casehead overpayment. d. [x] Conduct supervisory staff reviews or quality assurance reviews. i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: CCDF Program Coordinators are required to review Family Support Specialists case records monthly to ensure accuracy in eligibility determination. CCDF Program Coordinators will follow up with the FSS on areas identified as needing improvement. In addition, the QA Unit also conducts random sample reviews to ensure case records are compliant with eligibility criteria. When areas are identified as needing improvement, the QA Unit meets with CCDF Program Managers to review and obtain corrective action. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: CCDF Program Coordinators are required to review Family Support Specialist (FSS) case records monthly to ensure accuracy in eligibility determination. CCDF Program Coordinators will follow up with the FSS on areas that are identified as needing improvement. In addition, the QA Unit also conducts random sample reviews to ensure case records are compliant with eligibility criteria. When areas are identified as needing improvement, the QA Unit meets with CCDF Program Managers to review and obtain corrective action. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: CCDF Program Coordinators are required to review Family Support Specialist (FSS) case records monthly to ensure accuracy in eligibility determination. CCDF Program Coordinators will follow up with the FSS on areas identified as needing improvement. In addition, the QA Unit also conducts random sample reviews to ensure case records are compliant with eligibility criteria. When areas are identified as needing improvement, the QA Unit meets with CCDF Program Managers to review and obtain corrective action e. [x] Audit provider records. i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Random facilities are audited each month. If errors are identified, they are investigated and can result in a provider/casehead overpayment, corrective action and/or termination for the Child Care Assistance program. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Random facilities are audited each month. If errors are identified, they are investigated and can result in a provider/casehead overpayment, corrective action and/or termination for the Child Care Assistance program. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: OEC may receive a referral or report regarding an agency error. If errors are identified, they are investigated and can result in a provider/casehead overpayment, corrective action and/or termination for the Child Care Assistance program. f. [x] Train staff on policy and/or audits. i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The CCDF Program staff conducts training sessions on policy and procedures and how they are implemented. The scope and type of training selected is based on the needs of the staff member and is categorized into 3 main areas: (1) new hires, (2) existing staff, and (3) other divisions within and other agencies. New hires to the CCDF Program are fully trained on all policies and procedures and how to use the various systems that are integral to operate the program. Existing staff are given policy, procedure, and systems training based on the needs of those staff and through ongoing monitoring of areas that need improvement. Existing staff also receive full training on any new policies, procedures, and/or systems as well as any changes to those items. Other divisions and other agencies are given policy, procedure, and systems training based on their needs and roles. The QA Unit also conducts updates, as needed, on policy and procedure clarification and best practices to ensure that staff training needs are met in a timely manner. This training helps staff identify signs of intentional or unintentional program violations. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The CCDF Program staff conducts training sessions on policy and procedures and how they are implemented. The scope and type of training selected is based on the needs of the staff member and is categorized into 3 main areas: (1) new hires, (2) existing staff, and (3) other divisions within and other agencies. New hires to the CCDF Program are fully trained on all policies and procedures and how to use the various systems that are integral to operate the program. Existing staff are given policy, procedure, and systems training based on the needs of those staff and through ongoing monitoring of areas that need improvement. Existing staff also receive full training on any new policies, procedures, and/or systems as well as any changes to those items. Other divisions and other agencies are given policy, procedure, and systems training based on their needs and roles. The QA Unit also conducts updates, as needed, on policy and procedure clarification and best practices to ensure that staff training needs are met in a timely manner. This training helps staff identify signs of intentional or unintentional program violations. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: The CCDF Program staff conducts training sessions on policy and procedures and how they are implemented. The scope and type of training selected is based on the needs of the staff member and is categorized into 3 main areas: (1) new hires, (2) existing staff, and (3) other divisions within and other agencies. New hires to the CCDF Program are fully trained on all policies and procedures and how to use the various systems that are integral to operate the program. Existing staff are given policy, procedure, and systems training based on the needs of those staff and through ongoing monitoring of areas that need improvement. Existing staff also receive full training on any new policies, procedures, and/or systems as well as any changes to those items. Other divisions and other agencies are given policy, procedure, and systems training based on their needs and roles. The QA Unit also conducts updates, as needed, on policy and procedure clarification and best practices to ensure that staff training needs are met in a timely manner. This training helps staff identify signs of intentional or unintentional program violations. g. [x] Other. Describe the activity(ies): The Department of Education (ADE) maintains an integrity hotline for all stakeholders, including the general public, to submit complaints. The information is published on the agency’s website at: https://ardhslicensing.my.site.com/elicensing/s/complaint/submit- complaint?tab=CC&language=en_US . Upon receiving a complaint, OEC will work with the CCDF staff to conduct an investigation to determine if a program violation or administrative error has occurred, and if so, whether any funds are due back to the Lead Agency. If the complaint reflects possibly intentional fraud or program violations, the QA Unit will work independently to conduct a thorough review of the program. The QA Unit will work with CCDF staff and appropriate departments and agencies to review all required information i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The CCDF Program staff conducts training sessions on policy and procedures and how they are implemented. The scope and type of training selected is based on the needs of the staff member and is categorized into 3 main areas: (1) new hires, (2) existing staff, and (3) other divisions within and other agencies. New hires to the CCDF Program are fully trained on all policies and procedures and how to use the various systems that are integral to operate the program. Existing staff are given policy, procedure, and systems training based on the needs of those staff and through ongoing monitoring of areas that need improvement. Existing staff also receive full training on any new policies, procedures, and/or systems as well as any changes to those items. Other divisions and other agencies are given policy, procedure, and systems training based on their needs and roles. The QA Unit also conducts updates, as needed, on policy and procedure clarification and best practices to ensure that staff training needs are met in a timely manner. This training helps staff identify signs of intentional or unintentional program violations. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The CCDF Program staff conducts training sessions on policy and procedures and how they are implemented. The scope and type of training selected is based on the needs of the staff member and is categorized into 3 main areas: (1) new hires, (2) existing staff, and (3) other divisions within and other agencies. New hires to the CCDF Program are fully trained on all policies and procedures and how to use the various systems that are integral to operate the program. Existing staff are given policy, procedure, and systems training based on the needs of those staff and through ongoing monitoring of areas that need improvement. Existing staff also receive full training on any new policies, procedures, and/or systems as well as any changes to those items. Other divisions and other agencies are given policy, procedure, and systems training based on their needs and roles. The QA Unit also conducts updates, as needed, on policy and procedure clarification and best practices to ensure that staff training needs are met in a timely manner. This training helps staff identify signs of intentional or unintentional program violations. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: The CCDF Program staff conducts training sessions on policy and procedures and how they are implemented. The scope and type of training selected is based on the needs of the staff member and is categorized into 3 main areas: (1) new hires, (2) existing staff, and (3) other divisions within and other agencies. New hires to the CCDF Program are fully trained on all policies and procedures and how to use the various systems that are integral to operate the program. Existing staff are given policy, procedure, and systems training based on the needs of those staff and through ongoing monitoring of areas that need improvement. Existing staff also receive full training on any new policies, procedures, and/or systems as well as any changes to those items. Other divisions and other agencies are given policy, procedure, and systems training based on their needs and roles. The QA Unit also conducts updates, as needed, on policy and procedure clarification and best practices to ensure that staff training needs are met in a timely manner. This training helps staff identify signs of intentional or unintentional program violations. 10.2.2 Identification and recovery of misspent funds Lead Agencies must identify and recover misspent funds that are a result of fraud, and they have the option to recover any misspent funds that are a result of unintentional program violations or agency errors. a. Identify which agency is responsible for pursuing fraud and overpayments (e.g., State Office of the Inspector General, State Attorney): OEC will conduct random and targeted reviews by requesting attendance records via email and/or a letter mailed to providers. Facility attendance and billing records are reviewed and compared to OEC system. Any discrepancies are identified and a determination of the type of improper payment is made. Overpayments are established where warranted and collection efforts are conducted by OEC, and payments are submitted to Finance for processing. If there are large irregularities and/or the agency suspect major fraud activity and/or misuse of funds, the lead agency, if needed, will submit the provider to the Office of Inspector General (OIG) for investigation. Improper payments will be reviewed and sent for collection efforts when applicable. b. Check and describe all activities, including the results of such activity, that the Lead Agency uses to investigate and recover improper payments due to fraud. Consider in your response potential fraud committed by providers, clients, staff, vendors, and contractors. Include in the description how each activity assists in the investigation and recovery of improper payment due to fraud or intentional program violations. Activities can include, but are not limited to, the following: i. [x] Require recovery after a minimum dollar amount of an improper payment and identify the minimum dollar amount. Describe the activities and the results of these activities based on the most recent analysis: The CCDF Program requires all improper payments, regardless of dollar amount, to be submitted back to the agency. OEC will conduct random and targeted reviews by requesting attendance records via email and/or a letter mailed to providers. Facility attendance and billing records are reviewed and compared to OEC system. Any discrepancies are identified and a determination of the type of improper payment is made. Overpayments are established where warranted and collection efforts are made via 1st, 2nd and 3rd Notices of Fiscal Action that are sent to providers ii. [x] Coordinate with and refer to the other State/Territory agencies (e.g., State/Territory collection agency, law enforcement agency). Describe the activities and the results of these activities based on the most recent analysis: Overpayments are established where warranted and collection efforts are made via 1st, 2nd and 3rd Notices of Fiscal Action. If a provider does not make a payment after forty-five (45) days, the provider's account will be submitted to ADE Finance for collection, the CCDF Program Participant Agreement will be submitted to the CCDF Program Administrator for approval of termination of the provider. If there are large irregularities and/or the agency suspects major fraud activity and/or misuse of funds, the lead agency, if needed, will submit the provider's name to the Office of Inspector General (OIG). Improper payments identified from the individual recipients of subsidy will be reviewed and sent to the CCDF Program Coordinator for review and collection efforts. The collaborative efforts of the CCDF Program, QA Unit, and Finance have led to most funds being recovered. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: When OEC is contacted by a provider who is requesting a repayment plan, the request is submitted for approval to the CCDF Program Administrator. Once approved, OEC creates a collections file to be signed by the provider and submitted to Finance. OEC tracks all repayment schedules and payments submitted by the provider until the outstanding balance is resolved. All repayment agreements are established with/by OEC and Finance. Repayment Agreements cannot exceed twelve (12) months. Payment holds will not be placed on the accounts of providers who are making scheduled monthly payments unless they are in violation of their repayment agreement terms. Providers on a payment plan may continue to bill CCDF for services. iv. [x] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: Finance will net outstanding balances due against future payments to the indebted provider. v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: OEC partners with Finance to intercept taxes in efforts to recover funds. vi. [ ] Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: vii. [x] Establish a unit to investigate and collect improper payments and describe the composition of the unit. Describe the activities and the results of these activities based on the most recent analysis: OEC conducts investigations and reviews of childcare providers who receive CCDF funding and caseheads who participate in the CCDF program viii. [ ] Other. Describe the activities and the results of these activities: c. Does the Lead Agency investigate and recover improper payments due to unintentional program violations? [ ] No. [x] Yes. If yes, check and describe below any activities that the Lead Agency will use to investigate and recover improper payments due to unintentional program violations. Include in the description how each activity assists in the investigation and recovery of improper payments due to unintentional program violations. Include a description of the results of such activity. i. [x] Require recovery after a minimum dollar amount of an improper payment and identify the minimum dollar amount. Describe the activities and the results of these activities based on the most recent analysis: The CCDF Program requires all improper payments, regardless of dollar amount, to be submitted back to the agency. OEC will conduct random and targeted reviews by requesting attendance records. Facility attendance and billing records are reviewed and compared to the OEC billing system. Overpayments are established where warranted and collection efforts are made via 1st, 2nd and 3rd Notices of Fiscal Action that are sent to providers ii. [x] Coordinate with and refer to the other State/Territory agencies (e.g., State/Territory collection agency, law enforcement agency). Describe the activities and the results of these activities based on the most recent analysis: Overpayments are established where warranted and collection efforts are made via 1st, 2nd and 3rd Notices of Fiscal Action. If a provider does not make a payment after forty-five (45) days, the provider's account will be submitted to ADE Finance for collection, the CCDF Program Participant Agreement will be submitted to the CCDF Program Administrator for approval of termination of the provider. If there are large irregularities and/or the agency suspects major fraud activity and/or misuse of funds, the lead agency, if needed, will submit the provider's name to the Office of Inspector General (OIG). Improper payments identified from the individual recipients of subsidy will be reviewed and sent to the CCDF Program Coordinator for review and collection efforts. The collaborative efforts of the CCDF Program, QA Unit, and Finance have led to most funds being recovered. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: When OEC is contacted by a provider who is requesting a repayment plan, the request is submitted for approval to the CCDF Program Administrator. Once approved, OEC creates a collections file to be signed by the provider and submitted to Finance. OEC tracks all repayment schedules and payments submitted by the provider until the outstanding balance is resolved. All repayment agreements are established with/by OEC and Finance. Repayment Agreements cannot exceed twelve (12) months. Payment holds will not be placed on the accounts of providers who are making scheduled monthly payments unless they are in violation of their repayment agreement terms. Providers on a payment plan may continue to bill CCDF for services. iv. [x] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: Finance will net outstanding balances due against future payments to the indebted provider. v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: OEC partners with Finance to intercept taxes in efforts to recover fund. vi. [ ] Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: vii. [x] Establish a unit to investigate and collect improper payments and describe the composition of the unit. Describe the activities and the results of these activities based on the most recent analysis: QA identifies improper payments for the special reviews conducts and it is turned over to FSU to begin the collection process. viii. [ ] Other. Describe the activities and the results of these activities: d. Does the Lead Agency investigate and recover improper payments due to agency errors? [ ] No. [x] Yes. If yes, check and describe all activities that the Lead Agency will use to investigate and recover improper payments due to agency errors. Include in the description how each activity assists in the investigation and recovery of improper payments due to administrative errors. Include a description of the results of such activity. i. [x] Require recovery after a minimum dollar amount of an improper payment and identify the minimum dollar amount. Describe the activities and the results of these activities based on the most recent analysis: The CCDF Program requires all improper payments, regardless of dollar amount, to be submitted back to the agency. OEC will conduct random and targeted reviews by requesting attendance records. Facility attendance and billing records are reviewed and compared to the OEC billing system. Overpayments are established where warranted and collection efforts are made via 1st, 2nd and 3rd Notices of Fiscal Action that are sent to providers. ii. [x] Coordinate with and refer to the other State/Territory agencies (e.g., State/Territory collection agency, law enforcement agency). Describe the activities and the results of these activities based on the most recent analysis: Overpayments are established where warranted and collection efforts are made via 1st, 2nd and 3rd Notices of Fiscal Action. If a provider does not make a payment after forty-five (45) days, the provider's account will be submitted to ADE Finance for collection, the CCDF Program Participant Agreement will be submitted to the CCDF Program Administrator for approval of termination of the provider. If there are large irregularities and/or the agency suspects major fraud activity and/or misuse of funds, the lead agency, if needed, will submit the provider's name to the Office of Inspector General (OIG). Improper payments identified from the individual recipients of subsidy will be reviewed and sent to the CCDF Program Coordinator for review and collection efforts. The collaborative efforts of the CCDF Program, QA Unit, and Finance have led to most funds being recovered. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: When OEC is contacted by a provider who is requesting a repayment plan, the request is submitted for approval to the CCDF Program Administrator. Once approved, OEC creates a collections file to be signed by the provider and submitted to Finance. OEC tracks all repayment schedules and payments submitted by the provider until the outstanding balance is resolved. All repayment agreements are established with/by OEC and Finance. Repayment Agreements cannot exceed twelve (12) months. Payment holds will not be placed on the accounts of providers who are making scheduled monthly payments unless they are in violation of their repayment agreement terms. Providers on a payment plan may continue to bill CCDF for services iv. [x] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: Finance will net outstanding balances due against future payments to the indebted provider. v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: OEC partners with Finance to intercept taxes in efforts to recover funds. vi. [ ]Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: vii. [x] Establish a unit to investigate and collect improper payments and describe the composition of the unit. Describe the activities and the results of these activities based on the most recent analysis: OEC conducts investigations and reviews of child care providers who receive CCDF funding and caseheads who participate in the CCDF program. viii. [ ] Other. Describe the activities and the results of these activities: e. What type of sanction will the Lead Agency place on clients and providers to help reduce improper payments due to intentional program violations or fraud? Check and describe all that apply: i. [x] Disqualify the client. Describe this process, including a description of the appeal process for clients who are disqualified. Describe the activities and the results of these activities based on the most recent analysis: : If a casehead has an improper payment, OEC will take the following action: *The CCDF Program Coordinator will receive an improper payment referral from Family Support Specialist (FSS) as any improper payments are discovered. *The CCDF Program Coordinator will complete the casehead file checklist and place the individuals on the casehead overpayment spreadsheet before submitting the file to Finance *The CCDF Program Coordinator will submit a copy of the improper payment list to the CCDF Program Manager, CCDF Program Administrator or designee, Finance, and QA Unit. *Finance may open a pending claim based on the list received from the CCDF Program Coordinator. *The CCDF Program Coordinator will submit the overpayment packet via email to Finance for each cashed/recipient listed. * Finance will handle files according to their policy and procedures. *Casehead will have seven (7) calendar days from one of the following: seven (7) days from the USPS first attempted delivery of certified mail; seven (7) days from the mailing date of regular mail; or seven (7) days from the delivery receipt of email or the actual receipt of the certified mail, whichever is earlier. ii. [x]Disqualify the provider. Describe this process, including a description of the appeal process for providers who are disqualified. Describe the activities and the results of these activities based on the most recent analysis: If a payment is not received, a third notice of action is mailed to the provider providing them with another (15) days. If a provider does not make a payment after (45) days, the provider's account will be submitted for collection action to Finance, the CCDF Program Participant Agreement will be submitted to the CCDF Program Administrator for approval of disqualification of the provider. *Provider will have fifteen (15) calendar days to appeal. *Once an appeal is received, the appeal hearing date notification will be mailed to the Provider from ADE. *Once a decision has been made, the ADE will notify the Provider in writing iii. [x] Prosecute criminally. Describe the activities and the results of these activities based on the most recent analysis: The Assistant Commissioner of the Office of Early Childhood can make referrals to the Office of Inspector General (OIG) or additional agencies if there are large irregularities and/or the agency suspect major fraud activity and/or misuse of funds. iv. [ ] Other. Describe the activities and the results of these activities based on the most recent analysis: Appendix 1: Lead Agency Implementation Plan The Appendix will be available for Lead Agencies to use in CARS after the Plan approval letter is issued. For each non-compliance, Lead Agencies must describe the following: • Action Steps: List the action steps needed to correct the finding (e.g., update policy manual, legislative approval, IT system changes, etc.). For each action step list the: o Responsible Entity: Indicate the entity (e.g., agency, team, etc.) responsible for completing the action step. o Expected Completion Date: List the expected completion date for the action step. • Overall Target Date for Compliance: List date Lead Agency anticipates completing implementation, achieving full compliance with all aspects of the findings. (Note: Compliance will not be determined until the FFY 2025-2027 CCDF Plan is amended and approved). Appendix 1: Form [Plan question with non-compliance and associated provision will pre-populate based on preliminary notice of non-compliance] A. Action Steps for Implementation B. Responsible Entity(ies) C. Expected Completion Date Step 1: Step 2 (as necessary): [Additional steps added as necessary] Overall Target Date for Compliance: