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: When a child care case is entered into ImpaCT (a system for data collection and eligibility determination), Care 4 Kids has access to the Department of Social Services information and data to see if the family is also receiving Medical and/or SNAP benefits. Care 4 Kids uses this information to determine other state benefits, and who in the family is receiving the awards. This process helps identify families that may intentionally withhold information or provide inaccurate information on their applications. In addition to SNAP and Medical benefits, Care 4 Kids also checks TANF, State Directory of New Hires, Social Security Administration, and unemployment databases. CCDF staff share updated lists of active family child care providers with our State Department of Education (CT SDE) where there is oversight of CACFP. As a result of this sharing, CT SDE communicated with 5 CACFP sponsoring organizations to verify enrollment in CACFP or to inquire about enrollment in CACFP. Additionally, The Work Number is used to verify income. If the employer participates in The Work Number, UWC is able to verify income information and identify any intentional or unintentional misrepresentation of the income the family is expected to receive. UWC averages about 2000 inquiries per month to verify income using The Work Number. These practices ensure proper use of CCDF funds by instituting an additional layer of verification of the family’s income. UWCT does not track the total instances of identified discrepancies between information reported on the C4K application vs. Information found in DSS ImpaCT. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: When a child care case is entered into ImpaCT (a system for data collection and eligibility determination), Care 4 Kids has access to the Department of Social Services information and data to see if the family is also receiving Medical and/or SNAP benefits. Care 4 Kids uses this information to determine other state benefits, and who in the family is receiving the awards. This process helps identify families that may intentionally withhold information or unintentionally provide inaccurate information on their applications. In addition to SNAP and Medical benefits, Care 4 Kids also checks TANF, State Directory of New Hires, Social Security Administration, and unemployment databases. CCDF staff share updated lists of active family child care providers with our State Department of Education (CT SDE) where there is oversight of CACFP. As a result of this sharing, CT SDE communicated with 5 CACFP sponsoring organizations to verify enrollment in CACFP or to inquire about enrollment in CACFP. Additionally, The Work Number is used to verify income. If the employer participates in The Work Number, UWC is able to verify income information and identify any intentional or unintentional misrepresentation of the income the family is expected to receive. UWC averages about 2000 inquiries per month to verify income using The Work Number. These practices ensure proper use of CCDF funds by instituting an additional layer of verification of the family’s income. UWCT does not track the total instances of identified discrepancies between information reported on the C4K application vs. Information found in DSS ImpaCT. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice:: The Care 4 kids case worker verifies family data through other state databases. If inaccuracies are noted, the case worker will reach out to the other state agency to confirm. UWCT does not track the total instances of identified discrepancies between information reported on the C4K application vs. Information found in DSS ImpaCT. 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: When a child care case is entered into ImpaCT (a system for data collection and eligibility determination), the system runs a Department of Social Services comparison to see if the family is also receiving Medical and/or SNAP benefits. Care 4 Kids uses this information to determine other state benefits, and who in the family is receiving the awards. This process helps identify families that may intentionally withhold information or provide inaccurate information on their applications. Additionally, The Work Number is used to verify income. If the employer participates in The Work Number, UWC is able to verify income information and identify any intentional or unintentional misrepresentation of the income the family is expected to receive. UWC averages about 2000 inquiries per month to verify income using The Work Number. These practices ensure proper use of CCDF funds by instituting an additional layer of verification of the family’s income. UWCT does not track the total instances of identified discrepancies between information reported on the C4K application vs. Information found in DSS ImpaCT ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: When a child care case is entered into ImpaCT (a system for data collection and eligibility determination), the system runs a Department of Social Services comparison to see if the family is also receiving Medical and/or SNAP benefits. Care 4 Kids uses this information to determine other state benefits, and who in the family is receiving the awards. This process helps identify families that may intentionally withhold information or unintentionally provide inaccurate information on their applications. Additionally, The Work Number is used to verify income. If the employer participates in The Work Number, UWC is able to verify income information and identify any intentional or unintentional misrepresentation of the income the family is expected to receive. UWC averages about 2000 inquiries per month to verify income using The Work Number. These practices ensure proper use of CCDF funds by instituting an additional layer of verification of the family’s income. UWCT does not track the total instances of identified discrepancies between information reported on the C4K application vs. Information found in DSS ImpaCT. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: When agency errors are identified, they are corrected and any trends identified are used to inform subsequent employee training and onboarding materials. UWCT does not track the total instances of identified discrepancies between information reported on the C4K application vs. Information found in DSS ImpaCT. 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: Case managers review submitted applications and renewals for completeness. If required information is missing, illegible or outdated, a Missing Information Notice is sent to obtain verified and correct documentation. C4K invoices are sent to providers on a monthly basis. The invoices list all children enrolled in C4K, the number of days/months approved based on what is reported on the Parent Provider Agreement Form (PPA), and the number of days the child attends. The provider attests to the information on the invoice and returns it to C4K for payment through the provider portal. United Way of CT has an internal Quality Assurance process, where cases are consistently reviewed using the same data elements as noted on the Federal Record Review Worksheet. The outcome of the reviews determines ongoing training and staff development topics. UWC reviews approximately 1000 cases annually. Ongoing training and staff development reduces case processing errors. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Case managers review submitted applications and renewals for completeness. If required information is missing, illegible or outdated, a Missing Information Notice is sent to obtain verified and correct documentation. C4K invoices are sent to providers on a monthly basis. The invoices list all children enrolled in C4K, the number of days/months approved based on what is reported on the Parent Provider Agreement Form (PPA), and the number of days the child attends. The provider attests to the information on the invoice and returns it to C4K for payment through the provider portal. United Way of CT has an internal Quality Assurance process they implement to ensure intentional and unintentional program violations are identified. Cases are reviewed for accuracy. If inaccurate information is identified, corrections are completed to ensure program integrity. UWC reviews approximately 1000 cases annually. Ongoing training and staff development reduces case processing errors. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: Cases are reviewed for accuracy. If inaccurate information is identified, corrections are completed to ensure program integrity. The outcome of the reviews determines ongoing training and staff development topics. UWCT does not track the total instances of identified discrepancies between information reported on the C4K application vs. Information found in DSS ImpaCT. Ongoing training and staff development reduces case processing errors. 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: Cases are reviewed for accuracy. If inaccurate information is identified, corrections are completed to ensure program integrity. The outcome of the reviews determines ongoing training and staff development topics. Ongoing training and staff development reduces case processing errors. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Cases are reviewed for accuracy. If inaccurate information is identified, corrections are completed to ensure program integrity. The outcome of the reviews determines ongoing training and staff development topics. Ongoing training and staff development reduces case processing errors. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: Parent Provider Agreement forms are reviewed for accuracy. If inaccurate information is identified, corrections are completed to ensure program integrity. The outcome of the reviews determines ongoing training and staff development topics. Ongoing training and staff development reduces case processing errors. e. [x] Audit provider records. i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Parent Provider Agreement (PPA) forms are reviewed for accuracy. If inaccurate information is identified, corrections are completed to ensure program integrity. The outcome of the reviews determines ongoing training and staff development topics. When discrepancies related to care and work schedules of the unlicensed relative providers are noted on the PPA, a referral is made to the DSS Fraud Early Detection Unit (FRED) to investigate. In FY23, there were eleven provider referrals made to FRED. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Parent Provider Agreement forms are reviewed for accuracy. If inaccurate information is identified, corrections are completed to ensure program integrity. The outcome of the reviews determines ongoing training and staff development topics. When discrepancies related to care and work schedules of the unlicensed relative providers are noted on the PPA, a referral is made to the DSS Fraud Early Detection Unit (FRED) to investigate. In FY23, there were eleven provider referrals made to FRED. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: Parent Provider Agreement forms are reviewed for accuracy. If inaccurate information is identified, corrections are completed to ensure program integrity. The outcome of the reviews determines ongoing training and staff development topics. 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: Care 4 Kids staff attend a 6-week new hire training on program regulations, policy, & procedures. Care 4 Kids staff attend mandatory ongoing quarterly trainings. Staff are consistently provided up to date policy & procedures to apply knowledge to case processing. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Care 4 Kids staff attend a 6-week new hire training on program regulations, policy, & procedures. Care 4 Kids staff attend mandatory ongoing quarterly trainings. Staff are consistently provided up to date policy & procedures to apply knowledge to case processing. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: Care 4 Kids staff attend a 6-week new hire training on program regulations, policy, & procedures. Care 4 Kids staff attend mandatory ongoing quarterly trainings. Staff are consistently provided up to date policy & procedures to apply knowledge to case processing. g. [x] Other. Describe the activity(ies): DSS Fraud Investigations i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Through a Memorandum of Agreement (MOA) between the OEC and the Department of Social Services (DSS), the OEC utilizes the DSS Fraud Early Detection Unit (FRED) as a system to detect and prevent errors before the agency approves benefits. This program is a fraud prevention program in which investigations are conducted by DSS to identify any intentional or unintentional violations for program eligibility including but not limited to verifying household composition and self-employment activities. Care 4 Kids refers active cases with suspected or identified fraud to DSS for investigation and criminal prosecution. In FY23, 592 referrals were made to FRED. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Through a Memorandum of Agreement (MOA) between the OEC and the Department of Social Services (DSS), the OEC utilizes the DSS Fraud Early Detection Unit (FRED) as a system to detect and prevent errors before the agency approves benefits. This program is a fraud prevention program in which investigations are conducted by DSS to identify any intentional or unintentional violations for program eligibility including but not limited to verifying household composition and self-employment activities. Care 4 Kids refers active cases with suspected or identified fraud to DSS for investigation and criminal prosecution. In FY23, 592 referrals were made to FRED. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: Through a Memorandum of Agreement (MOA) between the OEC and the Department of Social Services (DSS), the OEC utilizes the DSS Fraud Early Detection Unit (FRED) as a system to detect and prevent errors before the agency approves benefits. This program is a fraud prevention program in which investigations are conducted by DSS to identify any intentional or unintentional violations for program eligibility including but not limited to verifying household composition and self-employment activities. Care 4 Kids refers active cases with suspected or identified fraud to DSS for investigation and criminal prosecution. In FY23, 592 referrals were made to FRED. 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): The Department of Social Services Fraud Early Detection Unit. If a parent or provider are determined to have committed fraud or have an overpayment in excess of $2,000.00 they are referred to the Office of the Attorney General or the State Attorney’s Office. 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: $10.00 is the minimum dollar amount to require recovery. United Way of CT identifies if an improper payment has been made and reviews the amount of the improper payment. Overpayments of $10.00 or more are recouped from the parent or provider. Overpayments are referred to Department of Administrative Services for recovery of funds. For the period of January 1, 2022, through January 1, 2024, there were 412 cases recovered through state/territory tax intercepts by DAS and a total of $411,080.49 was collected. 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: United Way of CT refers cases with suspected or identified fraud to DSS for investigation and criminal prosecution. Overpayments are referred to DAS for processing and recovery of funds. For the period of January 1, 2022, through January 1, 2024, there were 412 cases recovered through state/territory tax intercepts by DAS and a total of $411,080.49 was collected. For the time frame of January 1, 2022, through January 1, 2024, 1367 Fraud Early Detection referrals were made to the Department of Social Services Investigations Division for the investigation of applicants. Of those referrals, 359 applications were denied or withdrawn resulting in $2,926.579 in cost savings and 401 applications were granted at a reduced rate resulting in $258,052 in cost savings. For the same time frame, 49 Active Case Assessment Program referrals were made to the Department of Social Services Investigations Division for the investigation of recipients’ current or historical eligibility. Of those referrals, 5 resulted in overpayments totaling $435,223, 3 resulted in cost savings totaling $73,725 and 2 recipients were disqualified. 10 referrals are currently pending criminal court adjudication. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: The Department of Administrative Services will contact the parent/provider regarding repayment options. For the period of January 1, 2022, through January 1, 2024, there were 412 cases recovered through state/territory tax intercepts by DAS and a total of $411,080.49 was collected. iv. [x] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: If the provider is currently receiving payments, United Way of CT will reduce the provider’s monthly payment by 25% for intentional overpayments. For the period of January 1, 2022 through January 1, 2024, UWCT processed 696 intentional overpayments , of the 696, fifty three (53) were not paid in full and 643 were paid in full. v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: When an overpayment is not recovered from the parent/provider or DAS, their state tax refund will be intercepted until the full overpayment is recovered. When a case, if referred to DAS for collections and DAS staff farms the case out to a private collection agency, it is at that point that state/territory tax intercepts would be sought. For the period of January 1, 2022, through January 1, 2024, there were 412 cases recovered through state/territory tax intercepts. 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: The potential fraud identification unit is made up of a Recoupment Specialist, a lead and a manager. This unit works closely with DSS Fraud and Recovery. The Recoupment Specialist investigates the referrals from Eligibility Service Specialists for overpayments, calculates the overpayment amounts, and sends to DAS for recovery. Any cases that require extensive review for fraud are referred to DSS. For the time frame of January 1, 2022, through January 1, 2024, 1367 Fraud Early Detection referrals were made to the Department of Social Services Investigations Division for the investigation of applicants. Of those referrals, 359 applications were denied or withdrawn resulting in $2,926.579 in cost savings and 401 applications were granted at a reduced rate resulting in $258,052 in cost savings. For the same time frame, 49 Active Case Assessment Program referrals were made to the Department of Social Services Investigations Division for the investigation of recipients’ current or historical eligibility. Of those referrals, 5 resulted in overpayments totaling $435,223, 3 resulted in cost savings totaling $73,725 and 2 recipients were disqualified. 10 referrals are currently pending criminal court adjudication. 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: $10.00 is the minimum dollar amount to require recovery. United Way of CT identifies if an improper payment has been made and reviews the amount of the improper payment. Overpayments of $10.00 or more are recouped from the parent or provider. Overpayments are referred to Department of Administrative Services for recovery of funds. For the time period of January 1, 2022, through January 1, 2024, 2278 cases were processed by the UW of CT staff member who handles overpayments. Out of those 2278 cases processed 56 were referred to DAS, OAG or SAO for recoupment or prosecution measures. If there was no overpayment found or if they set up repayment plans, we would not refer to DAS. 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: United Way of CT refers cases with suspected or identified fraud to DSS for investigation and criminal prosecution. Overpayments are referred to DAS for processing and recovery of funds. For the period of January 1, 2022, through January 1, 2024, there were 412 cases recovered through state/territory tax intercepts by DAS and a total of $411,080.49 was collected. For the time frame of January 1, 2022, through January 1, 2024, 1367 Fraud Early Detection referrals were made to the Department of Social Services Investigations Division for the investigation of applicants. Of those referrals, 359 applications were denied or withdrawn resulting in $2,926.579 in cost savings and 401 applications were granted at a reduced rate resulting in $258,052 in cost savings. For the same time frame, 49 Active Case Assessment Program referrals were made to the Department of Social Services Investigations Division for the investigation of recipients’ current or historical eligibility. Of those referrals, 5 resulted in overpayments totaling $435,223, 3 resulted in cost savings totaling $73,725 and 2 recipients were disqualified. 10 referrals are currently pending criminal court adjudication. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: The Department of Administrative Services will contact the parent/provider regarding repayment options. For the time period of January 1, 2022, through January 1, 2024, 2278 cases were processed by the UW of CT staff member who handles overpayments. Out of those 2278 cases processed 56 were referred to DAS, OAG or SAO for recoupment or prosecution measures. If there was no overpayment found or if they set up repayment plans, we would not refer to DAS. iv. [x] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: If the provider is currently receiving payments, United Way of CT will reduce the provider’s monthly payment by 10% for unintentional overpayments. v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: When an overpayment is not recovered from the parent/provider or DAS, their state tax refund will be intercepted until the full overpayment is recovered. When a case if referred to DAS for collections and DAS staff farms the case out to a private collection agency, it is at that point that state/territory tax intercepts would be sought. However, For the period of January 1, 2022, through January 1, 2024, there were 412 cases recovered through state/territory tax intercepts. 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: The potential fraud identification unit is made up of a Recoupment Specialist, a lead and a manager. This unit works closely with DSS Fraud and Recovery. The Recoupment Specialist investigates the referrals from Eligibility Service Specialists for overpayments, calculates the overpayment amounts, and sends to DAS for recovery. Any cases that require extensive review for fraud are referred to DSS. For the time frame of January 1, 2022, through January 1, 2024, 1367 Fraud Early Detection referrals were made to the Department of Social Services Investigations Division for the investigation of applicants. Of those referrals, 359 applications were denied or withdrawn resulting in $2,926.579 in cost savings and 401 applications were granted at a reduced rate resulting in $258,052 in cost savings. For the same time frame, 49 Active Case Assessment Program referrals were made to the Department of Social Services Investigations Division for the investigation of recipients’ current or historical eligibility. Of those referrals, 5 resulted in overpayments totaling $435,223, 3 resulted in cost savings totaling $73,725 and 2 recipients were disqualified. 10 referrals are currently pending criminal court adjudication. 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? [x] No. [ ] 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. [ ] 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: ii. [ ] 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: iii. [ ] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: iv. [ ] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: v. [ ] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: vi. [ ]Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: vii. [ ] 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: 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: Clients are disqualified after a final determination that they committed fraud has been made by the court or disqualification hearing. Clients are disqualified for 3 months after the first finding of fraud, 6 months for the second finding, and 1 year for any subsequent findings for each occurrence. The parent may appeal the decision to the superior court within 45 days of the decision by serving a copy of their petition to appeal to the commissioner or attorney general. For the time frame of January 1, 2022, through January 1, 2024, 1367 Fraud Early Detection referrals were made to the Department of Social Services Investigations Division for the investigation of applicants. Of those referrals, 359 applications were denied or withdrawn resulting in $2,926.579 in cost savings and 401 applications were granted at a reduced rate resulting in $258,052 in cost savings. For the same time frame, 49 Active Case Assessment Program referrals were made to the Department of Social Services Investigations Division for the investigation of recipients’ current or historical eligibility. Of those referrals, 5 resulted in overpayments totaling $435,223, 3 resulted in cost savings totaling $73,725 and 2 recipients were disqualified. 10 referrals are currently pending criminal court adjudication. 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: Clients are disqualified after a final determination that they committed fraud has been made by the court or disqualification hearing. Clients are disqualified for 3 months after the first finding of fraud, 6 months for the second finding, and 1 year for any subsequent findings for each occurrence. The parent may appeal the decision to the superior court within 45 days of the decision by serving a copy of their petition to appeal to the commissioner or attorney general. For the time frame of January 1, 2022, through January 1, 2024, 1367 Fraud Early Detection referrals were made to the Department of Social Services Investigations Division for the investigation of applicants. Of those referrals, 359 applications were denied or withdrawn resulting in $2,926.579 in cost savings and 401 applications were granted at a reduced rate resulting in $258,052 in cost savings. For the same time frame, 49 Active Case Assessment Program referrals were made to the Department of Social Services Investigations Division for the investigation of recipients’ current or historical eligibility. Of those referrals, 5 resulted in overpayments totaling $435,223, 3 resulted in cost savings totaling $73,725 and 2 recipients were disqualified. 10 referrals are currently pending criminal court adjudication. iii. [x] Prosecute criminally. Describe the activities and the results of these activities based on the most recent analysis: Overpayments of $2000.00 or more are referred to DSS for prosecution. 10 referrals are currently pending criminal court adjudication. 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: