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program integrity for eligibility determinations, CAPS has a stand-alone Quality Assurance & Training (QA&T) unit that performs quality assurance reviews of eligibility determinations made by staff. These quality assurance reviews are used to monitor and assess policy implementation, ensure program integrity, and determine training effectiveness. The QA&T unit does not determine eligibility but does administer the quality assurance process by reviewing the work of others and providing training for staff in areas that need improvement. Cases are selected from a random sample of initial eligibility, changes during the eligibility period, and redeterminations completed each month. Cases processed by newer staff are monitored more frequently than staff who have more experience processing eligibility. To further ensure program integrity, the QA&T unit also supports staff by conducting ongoing focused training in areas with the highest error rate in determining eligibility. CAPS also created a new functional area, CAPS Provider Relations, that includes four teams, one of which is the Quality Assurance and Payments team. Staff on this team support program integrity by receiving and reviewing child care provider invoices, ensuring accurate and timely payments for child care providers, and overseeing and completing quality assurance processes to support accurate payments. Quality Assurance and Payments also identifies training and technical assistance needs that providers may have and communicates those needs to the Education and Outreach team to offer technical assistance and create training sessions to support provider needs.

2) Delegation of duties: DECAL’s executive and senior leadership determines the level of authority for each division to fulfill organizational responsibilities. All divisions must submit contracts and grant agreements to the Finance and Legal division for review and approval. The Legal division ensures contracts are legally compliant and diminishes financial risk for DECAL. All non-contracted expenses must be approved by one-level above the buyer/purchaser before submission to Finance. Budget and procurement staff conduct reviews of payment requests to validate appropriateness with budget, cost-allowability and State policies.

3) Coordination of activities: Finance and Legal divisions conduct annual contracting and purchasing training to all business owners of each division of DECAL. CAPS sends directors and managers to Finance and Legal training. The Child and Parent Services Deputy Commissioner and Directors manage access and payment authorizations in the CAPS eligibility system (GACAPS). The staff who approve payments for providers, the Quality Assurance & Payment Manager/Coordinator, do not have permissions to approve a provider’s enrollment in CAPS, which is completed by the Enrollment Services team. Finance staff do not have access to authorizations within GACAPS. CAPS staff do not have recording and payment access in the State’s accounting and banking systems. Payments are made by a payment vendor, contracted by DECAL. DECAL Finance wires funding to the payment vendor.

4) Communication between fiscal and program staff: The Finance division conducts quarterly budget meetings with Deputy Commissioners and Directors for all DECAL programs and cost centers which includes CAPS staff. These meetings serve multiple purposes like reviewing budget- to-expenses variances, validating all expenses charged to the correct program and reviewing appropriateness.

5) Segregation of duties. The Lead Agency relies on checks and balances and separation of duties to ensure program integrity. Examples of this are evident in the processes and the structure of the Lead Agency and the CCDF program. In the CCDF program, the Lead Agency has a stand-alone Quality Assurance and Training Unit (QA&T) that performs quality assurance reviews of eligibility