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: Eligibility workers verify various child care eligibility factors, such as employment, income, citizenship, age, residency, etc. through access to shared information from other programs like Cash Assistance, FNS and Medicaid. Other databases are used to assist with verifying or identifying income, such as social security administration. Public Assistance Reporting Information system matches are used to ensure that residency requirements are met and identify duplications in the program with another state. When the Child Care Provider Integrity Education and Support Unit (CCPIES) completes their audits, they do a thorough review of the parent/recipient case. This includes, but is not limited to, reviewing all child care plans, case processes, information gathered at the time of application/review and any updates or changes made on the case. When these reviews are completed on the child care recipients, the unit utilizes and reviews the information gathered by other programs like Cash Assistance, Food Assistance, Medicaid, Child and Adult Care Food Program, Kansas Department of Health and Environment records, Childcare Licensing And Regulation Information System (CLARIS), Social Security Administration, and Public Assistance Reporting Information system to ensure the household composition, members, and information submitted by the recipient to the program worker is consistent. When a review or audit is completed for child care providers, the reviewer checks to see if the provider receives assistance and ensures that they are reporting this income for Cash Assistance, Food Assistance or Child Care Assistance cases. During a review or audit of a Child Care Assistance case or Kansas Department for Children and Families enrolled provider, the Child Care Provider Integrity Education and Support Unit assesses any information or documentation which may have been misread or miscommunicated by the worker/recipient/provider to determine if it was an agency error or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. For Intentional Program Violations, if an improper payment is discovered, a claim would be created for the Child Care Recipient or Child Care Provider to return the funds back to the lead agency. For Child Care Recipients, if an Intentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit has the option to take the Child Care Recipient through the process of Administrative Disqualification through the Office of Administrative Hearings to determine a fraud judgement. If the recipient is found to have committed fraud by Office of Administrative Hearings, the recipient is required to return the improper payment to the lead agency and the Child Care Recipient adult(s) will be flagged as having committed Child Care Fraud. Per our state policy KEESM 11221.2, the children will continue to be eligible for Child Care Assistance. Currently, for Child Care Providers, if an intentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit has the option to request the Child Care Provider’s agreement with the lead agency be terminated. The request and all supporting evidence of the intentional program violation is sent to Child Care Enrollment, who then reviews it with the lead agency’s Leadership, and they are the ones who decide whether the Child Care Provider’s Kansas Department for Children and Families agreement will be terminated. If the lead agency’s Leadership agrees to terminate the Kansas Department for Children and Families agreement with the Child Care Provider, then Child Care Enrollment will end the agreement and the Child Care Provider will be required to return the improper payment back to the lead agency. If the lead agency’s Leadership allows the Child Care Provider to keep their agreement with DCF, the Child Care Provider will still be required to return the improper payment and a follow up audit will take place in the future. The Child Care Provider Integrity Education Support unit does not have the ability to take Intentional Program Violations to Civil court as there are not adequate Kansas Department for Children and Families’ attorneys available to do so. However, depending on the dollar amount of the improper payment for the Intentional Program Violation, Child Care Provider Integrity Education Support unit can request to take the Child Care Recipient or Child Care Provider to criminal court. For this request, Child Care Provider Integrity Education Support unit would need to present the case to the County District Attorneys office and the County District Attorney would decide if they wanted to take the case. If the County District Attorney agrees to take the Intentional Program Violation to criminal court, the County District Attorneys will review the case and request Child Care Provider Integrity Education Support unit complete an affidavit and obtain any other evidence needed for the County District Attorney to take it to criminal court for the judicial process. If the County District Attorney refuses to take the case, depending on whether it is a Child Care Recipient or Child Care provider, Child Care Provider Integrity Education Support unit would have the options as already stated above. In both situations, if there is a combined case of the Child Care Program and Food Assistance or TANF involved, Child Care Provider Integrity Education Support unit works with the Fraud Special Investigators with obtaining the evidence as well as the chosen process for fraud determination. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Eligibility workers verify various child care eligibility factors, such as employment, income, citizenship, age, residency, etc. through access to shared information from other programs like Cash Assistance, FNS and Medicaid. Other databases are used to assist with verifying or identifying income, such as social security administration. Public Assistance Reporting Information system matches are used to ensure that residency requirements are met and identify duplications in the program with another state. When the Child Care Provider Integrity Education and Support Unit (CCPIES) completes their audits, they do a thorough review of the parent/recipient case. This includes, but is not limited to, reviewing all child care plans, case processes, information gathered at the time of application/review and any updates or changes made on the case. When these reviews are completed on the child care recipients, the unit utilizes and reviews the information gathered by other programs like Cash Assistance, Food Assistance, Medicaid, Child and Adult Care Food Program, Kansas Department of Health and Environment records, Childcare Licensing And Regulation Information System (CLARIS), Social Security Administration, and Public Assistance Reporting Information system to ensure the household composition, members, and information submitted by the recipient to the program worker is consistent. When a review or audit is completed for child care providers, the reviewer checks to see if the provider receives assistance and ensures that they are reporting this income for Cash Assistance, Food Assistance or Child Care Assistance cases. During a review or audit of a Child Care Assistance case or Kansas Department for Children and Families enrolled provider, the Child Care Provider Integrity Education and Support Unit assesses any information or documentation which may have been misread or miscommunicated by the worker/recipient/provider to determine if it was an agency error or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. For Unintentional Program Violations, if an improper payment is discovered, a claim would be created for the Child Care Recipient or Child Care Provider to return the funds back to the lead agency. For Child Care Recipients, if an Unintentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit provides an education to the Child Care Recipient and explains the improper payment. If there are changes or updates that are required to the case due to the Unintentional Program Violation, Child Care Provider Integrity Education Support unit informs the eligibility workers of the changes and/or updates to be made. The Child Care Recipient is required to return the improper payment back to the lead agency. For Child Care Providers, if an Unintentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit provides an education to the provider by way of a Corrective Action Plan and a Follow Up audit is required to ensure the violation was corrected. If there are changes or updates that are required to the case due to the Unintentional Program Violation, Child Care Provider Integrity Education Support unit informs the Child Care Enrollment of the changes and/or updates to be made. If there is an improper payment, the Child Care Provider is required to return the improper payment back to lead agency. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice:: Eligibility workers verify various child care eligibility factors, such as employment, income, citizenship, age, residency, etc. through access to shared information from other programs like Cash Assistance, FNS and Medicaid. Other databases are used to assist with verifying or identifying income, such as social security administration. Public Assistance Reporting Information system matches are used to ensure that residency requirements are met and identify duplications in the program with another state. When the Child Care Provider Integrity Education and Support Unit (CCPIES) completes their audits, they do a thorough review of the parent/recipient case. This includes, but is not limited to, reviewing all child care plans, case processes, information gathered at the time of application/review and any updates or changes made on the case. When these reviews are completed on the child care recipients, the unit utilizes and reviews the information gathered by other programs like Cash Assistance, Food Assistance, Medicaid, Child and Adult Care Food Program, Kansas Department of Health and Environment records, Childcare Licensing And Regulation Information System (CLARIS), Social Security Administration, and Public Assistance Reporting Information system to ensure the household composition, members, and information submitted by the recipient to the program worker is consistent. When a review or audit is completed for child care providers, the reviewer checks to see if the provider receives assistance and ensures that they are reporting this income for Cash Assistance, Food Assistance or Child Care Assistance cases. During a review or audit of a Child Care Assistance case or Kansas Department for Children and Families enrolled provider, the Child Care Provider Integrity Education and Support Unit assesses any information or documentation which may have been misread or miscommunicated by the worker/recipient/provider to determine if it was an agency error or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. If an Agency Error is discovered, Child Care Provider Integrity Education Support unit informs the eligibility workers of the error if it is a Child Care Recipient case for the changes and/or updates to be made. If an Agency Error is discovered with regards to Child Care Providers, Child Care Provider Integrity Education Support unit informs Child Care Enrollment of the error for the changes and/or updates to be made. If there are any Child Care Recipient improper payments due to Agency Error, it is for Eligibility staff to decide whether a claim is created for the Child Care Recipient to return the funds back to the lead agency. Child Care Provider Integrity Education Support unit does not create claims for improper payments due to agency errors. 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: The Data Analysts under Management Support reviews system generated data to identify any concerns or problematic inconsistencies. System generated data reports are sent regularly, monthly to the Kansas Department for Children and Families program managers to further assess any potential risks identified from these reports. The reports pertaining to the child care program are sent to the Child Care program manager, Child Care Enrollment as well as to the Child Care Provider Integrity Education Support Unit to review for any irregularities and potential fraud risks. The Child Care Provider Integrity Education Support unit receives the following reports: Semi-Annual High Dollar Report for centers and licensed homes. This report is provided yearly. This report is generated annually in January to provide dollar amount received from both centers and licensed homes which were paid over a certain amount. The amount for licensed homes is 20k. When the report is generated, if the daycare provider meets or exceeds that amount, then they will appear on the report to review for red flags and a provider audit review will be completed. Audits are completed with In Person visits as well as by Mail Audits to the daycare provider home or center to review their business records. Records requested consists of attendance, payment, enrollment records. Excessive Large Balance Alerts. This report is sent sporadically when the EBT manager receives an alert. The EBT Manager generates a report and sends it to the CCPIES unit. This is an alert to notify a large EBT subsidy balance on a recipient’s card. Generally, with these reports, review of the client’s case is completed first to determine what the approved subsidy amount for their household is and when the last payment was made to a daycare provider. A review of the recipients’ case is done to determine the status of the case, when payments are being made, who they are being made to. If, after reviewing the case file, it is determined the large balance is not questionable, then there is no need to pursue any further review or investigation. However, if information is found to be questionable, a deeper dive into the recipient case, along with their payment history and providers paid is reviewed. Oftentimes if the balance is found to be questionable, past payments are also questionable, leading to auditing the provider(s) this recipient has used or is requesting. Audits are completed with In Person visits as well as by Mail Audits to the daycare provider home or center to review their business records. Records requested consists of attendance, payment, enrollment records. Unauthorized Payment Report. This report is sent once a month. This report is generated for Kansas Department for Children and Families IN HOME and OUT of HOME Providers. As an INHOME or OUT OF HOME Provider, the provider can only care for and accept EBT Child Care benefits from those they are authorized to care and accept EBT payment from. When the INHOME/OUT OF HOME provider applies, they request care for specific families of whom they are related to. If they meet their requirements, they are approved to care for and accept EBT from only those families. This report lists INHOME and OUT OF HOME providers who accept EBT payment from unauthorized families. When an unauthorized payment is received, a review of the case, payers and payees involved, and transaction is made to determine if the payment was authorized. If it isn't, an overpayment is created. No other investigation would be needed for these types of issues. Providers who are also Recipients Report. This report is sent once a month. This report is generated to determine if any Kansas Department for Children and Families daycare providers, who are also Kansas Department for Children and Families Child Care recipients, pay themselves. Per Kansas Department for Children and Families policy, Providers may apply for child care for their own children but care cannot be paid to their facility if they are the owner. However, an exception has recently been made for Foster Care Child Care (FC CC,) for those situations to be approved on a case-by-case basis by the FC CC Leadership. In these situations, generally after a review of the provider and eligibility file, a determination can be made if there will be an overpayment or not. No other investigation is usually necessary for these types of cases. Fraud Referral Reports. These alerts, referrals or reports are sent when received or ready for the Child Care Provider Integrity Education Support Unit to review the recipient or provider. Fraud referrals are sent to our Child Care Provider Integrity Education Support (CCPIES) Unit in various ways. Hotline referrals are received most regularly; however, we receive referrals from within the agency, outside of the agency, 'anonymous' calls/tips, etc. Generally, when a referral from within the agency, client or provider is made, it is emailed directly to the CCPIES unit. Oftentimes it is emailed to the Child Care Enrollment Unit, who then forwards it to the CCPIES unit. When a fraud hotline referral is made, the report goes to the fraud unit and a fraud # or alert is generated by the fraud unit. If the referral is a combined benefits case (Food Assistance/Cash Assistance AND CC), then the fraud unit investigates their Food Assistance/Cash Assistance and then sends it to the Child Care Provider Integrity Education Support (CCPIES) Unit to review the Child Care portion for potential fraud. IF the case is a child care recipient only or deals with only the child care provider, the referral is immediately sent to the CCPIES Unit to review and investigate for potential fraud and errors and to pursue overpayment and or fraud disqualification. With regards to the daycare providers, an audit is generally done for an initial contact to determine if further investigation is necessary. Audits are completed with In Person visits as well as by Mail Audits to the daycare provider home or center to review their business records. Records requested consists of attendance, payment, enrollment records. Kansas Eligibility Enforcement System (KEES) generated reports. These reports are regularly ran to identify system or potential process concerns. The eligibility system, KEES, contains edits that prevent the authorization of excessive hours, prevent the overlap of plans for the same child at the same time, determines the hours to be authorized when schedules are entered to prevent and reduce errors. Warnings are also created when the system recognizes something that requires a closer look by the eligibility worker, like child care plans being created for a provider who is almost at capacity or when a child is on another child care program. Provider rates are automated to prevent incorrect rates from being entered on the child care plan. System rules streamline the application of many of the child care policies based on data that is entered by eligibility workers. Data matches are used with Kansas wage and unemployment compensation and Social Security Administration to assist with verifying or identifying income. Fraud Navigator is a tool accessed through the EBT system to monitor real- time transactions including child care payments for suspicious payment activity, such as excessive transaction amounts. When an error or inconsistency is identified, a report is generated and assessed to be sent to the appropriate departments for further review and resolution or investigation. The above reports are reviewed to assess if it was a system error, agency error, or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. Child Care eligibility staff processes any agency or unintentional program violations within the child care eligibility recipient case. If a potential intentional program violation is identified for a child care eligibility recipient, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. Whereas If either unintentional or intentional program violations are identified for child care providers, the case is referred to the Child Care Provider Integrity Education Support Unit (CCPIES). For Intentional Program Violations, if an improper payment is discovered, a claim would be created for the Child Care Recipient or Child Care Provider to return the funds back to the Department for Children and Families (DCF). For Child Care Recipients, if an Intentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit has the option to take the Child Care Recipient through the process of Administrative Disqualification through the DCF Office of Administrative Hearings (OAH) to determine a fraud judgement. If the recipient is found to have committed fraud by OAH, the recipient is required to return the improper payment to DCF and the Child Care Recipient adult(s) will be flagged as having committed Child Care Fraud. Per our state policy KEESM 11221.2, the children will continue to be eligible for Child Care subsidy. Currently, for Child Care Providers, if an intentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit has the option to request the Child Care Provider’s agreement with DCF be terminated. The request and all supporting evidence of the intentional program violation is sent to Child Care Enrollment, who then reviews it with DCF Leadership and they are the ones who decide whether the Child Care Provider’s DCF agreement will be terminated. If the DCF Leadership agrees to terminate the DCF agreement with the Child Care Provider, then Child Care Enrollment will end the agreement and the Child Care Provider will be required to return the improper payment back to DCF. If DCF Leadership allows the Child Care Provider to keep their agreement with DCF, the Child Care Provider will still be required to return the improper payment and a follow up audit will take place in the future. DCF CCPIES does not have the ability to take Intentional Program Violations to Civil court as there are no DCF attorneys available to do so. However, depending on the dollar amount of the improper payment for the Intentional Program Violation, CCPIES can request to take the Child Care Recipient or Child Care Provider to criminal court. For this request, CCPIES would need to present the case to the County District Attorneys office and the county D.A. would decide if they want to take the case. If the D.A. agrees to take the Intentional Program Violation to criminal court, the D.A. will review the case and request CCPIES complete an affidavit and obtain any other evidence needed for the D.A. to take it to criminal court for the judicial process. If the D.A. refuses to take the case, depending on whether it is a Child Care Recipient or Child Care provider, CCPIES would have the options as already stated above. In both situations, if there is a combined case of the Child Care Program and Food Assistance or TANF involved, CCPIES works with the Fraud Special Investigators with obtaining the evidence as well as the chosen process for fraud determination. Based on the mentioned ￿red flag/outlier’ reports the agency uses -INTENTIONAL PROGRAM VIOLATION DATA From January 2024 to July 2024: 1 74 Fraud referrals received / 6 Fraud referrals have been reviewed. 1.1 3 closed with no program violation and no improper payment. 1.2 1 CC Provider, $3900 improper payment. Potential Fraud, Judgement not obtained as no Civil action available. Education and Corrective Action given. 1.3 1 CC Recipient received Fraud judgement, $43,658.80. 1.4 1 Combined CC Recipient and CC Provider. CCPIES is currently working with the DCF Fraud unit on a combined program fraud case and is currently going through the Criminal court process. 1.4.1 Anticipated CC Improper Payment for Intentional Violation 1.4.2 Child Care Recipient: $83,228.82 1.4.3 Child Care Provider: $83,228.81 1.4.4 These amounts are for Child Care program violations only. 2 23 High Payment Potential Fraud Alerts reviewed and completed. 2.1 13 closed with no fraud discovered, no improper payment. 2.2 10 Improper Payments, totaling $74,951.36- No fraud discovered, education provided. 3 13 Unauthorized Payments Potential Fraud reviewed and completed. 3.1 13 Child Care Provider Improper payments - total $36,022.48 3.2 13 Potential Fraud, Judgement not obtained as no Civil action available. ALL 13 Child Care Providers had their DCF Provider Agreement terminated ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The Data Analysts under Management Support reviews system generated data to identify any concerns or problematic inconsistencies. System generated data reports are sent regularly, monthly to the Kansas Department for Children and Families program managers to further assess any potential risks identified from these reports. The reports pertaining to the child care program are sent to the Child Care program manager, Child Care Enrollment as well as to the Child Care Provider Integrity Education Support Unit to review for any irregularities and potential fraud risks. The Child Care Provider Integrity Education Support unit receives the following reports: Semi-Annual High Dollar Report for centers and licensed homes. This report is provided yearly. This report is generated annually in January to provide dollar amount received from both centers and licensed homes which were paid over a certain amount. The amount for licensed homes is 20k. When the report is generated, if the daycare provider meets or exceeds that amount, then they will appear on the report to review for red flags and a provider audit review will be completed. Audits are completed with In Person visits as well as by Mail Audits to the daycare provider home or center to review their business records. Records requested consists of attendance, payment, enrollment records. Excessive Large Balance Alerts. This report is sent sporadically when the EBT manager receives an alert. The EBT Manager generates a report and sends it to the CCPIES unit. This is an alert to notify a large EBT subsidy balance on a recipient’s card. Generally, with these reports, review of the client’s case is completed first to determine what the approved subsidy amount for their household is and when the last payment was made to a daycare provider. A review of the recipients’ case is done to determine the status of the case, when payments are being made, who they are being made to. If, after reviewing the case file, it is determined the large balance is not questionable, then there is no need to pursue any further review or investigation. However, if information is found to be questionable, a deeper dive into the recipient case, along with their payment history and providers paid is reviewed. Oftentimes if the balance is found to be questionable, past payments are also questionable, leading to auditing the provider(s) this recipient has used or is requesting. Audits are completed with In Person visits as well as by Mail Audits to the daycare provider home or center to review their business records. Records requested consists of attendance, payment, enrollment records. Unauthorized Payment Report. This report is sent once a month. This report is generated for Kansas Department for Children and Families IN HOME and OUT of HOME Providers. As an INHOME or OUT OF HOME Provider, the provider can only care for and accept EBT Child Care benefits from those they are authorized to care and accept EBT payment from. When the INHOME/OUT OF HOME provider applies, they request care for specific families of whom they are related to. If they meet their requirements, they are approved to care for and accept EBT from only those families. This report lists INHOME and OUT OF HOME providers who accept EBT payment from unauthorized families. When an unauthorized payment is received, a review of the case, payers and payees involved, and transaction is made to determine if the payment was authorized. If it isn't, an overpayment is created. No other investigation would be needed for these types of issues. Providers who are also Recipients Report. This report is sent once a month. This report is generated to determine if any Kansas Department for Children and Families daycare providers, who are also Kansas Department for Children and Families Child Care recipients, pay themselves. Per Kansas Department for Children and Families policy, Providers may apply for child care for their own children but care cannot be paid to their facility if they are the owner. However, an exception has recently been made for Foster Care Child Care (FC CC,) for those situations to be approved on a case-by-case basis by the FC CC Leadership. In these situations, generally after a review of the provider and eligibility file, a determination can be made if there will be an overpayment or not. No other investigation is usually necessary for these types of cases. Fraud Referral Reports. These alerts, referrals or reports are sent when received or ready for the Child Care Provider Integrity Education Support Unit to review the recipient or provider. Fraud referrals are sent to our Child Care Provider Integrity Education Support (CCPIES) Unit in various ways. Hotline referrals are received most regularly; however, we receive referrals from within the agency, outside of the agency, 'anonymous' calls/tips, etc. Generally, when a referral from within the agency, client or provider is made, it is emailed directly to the CCPIES unit. Oftentimes it is emailed to the Child Care Enrollment Unit, who then forwards it to the CCPIES unit. When a fraud hotline referral is made, the report goes to the fraud unit and a fraud # or alert is generated by the fraud unit. If the referral is a combined benefits case (Food Assistance/Cash Assistance AND CC), then the fraud unit investigates their Food Assistance/Cash Assistance and then sends it to the Child Care Provider Integrity Education Support (CCPIES) Unit to review the Child Care portion for potential fraud. IF the case is a child care recipient only or deals with only the child care provider, the referral is immediately sent to the CCPIES Unit to review and investigate for potential fraud and errors and to pursue overpayment and or fraud disqualification. With regards to the daycare providers, an audit is generally done for an initial contact to determine if further investigation is necessary. Audits are completed with In Person visits as well as by Mail Audits to the daycare provider home or center to review their business records. Records requested consists of attendance, payment, enrollment records. Kansas Eligibility Enforcement System (KEES) generated reports. These reports are regularly ran to identify system or potential process concerns. The eligibility system, KEES, contains edits that prevent the authorization of excessive hours, prevent the overlap of plans for the same child at the same time, determines the hours to be authorized when schedules are entered to prevent and reduce errors. Warnings are also created when the system recognizes something that requires a closer look by the eligibility worker, like child care plans being created for a provider who is almost at capacity or when a child is on another child care program. Provider rates are automated to prevent incorrect rates from being entered on the child care plan. System rules streamline the application of many of the child care policies based on data that is entered by eligibility workers. Data matches are used with Kansas wage and unemployment compensation and Social Security Administration to assist with verifying or identifying income. Fraud Navigator is a tool accessed through the EBT system to monitor real- time transactions including child care payments for suspicious payment activity, such as excessive transaction amounts. When an error or inconsistency is identified, a report is generated and assessed to be sent to the appropriate departments for further review and resolution or investigation. The above reports are reviewed to assess if it was a system error, agency error, or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. Child Care eligibility staff processes any agency or unintentional program violations within the child care eligibility recipient case. If a potential intentional program violation is identified for a child care eligibility recipient, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. Whereas If either unintentional or intentional program violations are identified for child care providers, the case is referred to the Child Care Provider Integrity Education Support Unit. For Unintentional Program Violations, if an improper payment is discovered, a claim would be created for the Child Care Recipient or Child Care Provider to return the funds back to DCF. For Child Care Recipients, if an Unintentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit provides an education to the Child Care Recipient and explains the improper payment. If there are changes or updates that are required to the case due to the Unintentional Program Violation, CCPIES informs the eligibility workers of the changes and/or updates to be made. The Child Care Recipient is required to return the improper payment back to DCF. For Child Care Providers, if an Unintentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit provides an education to the provider by way of a Corrective Action Plan and a Follow Up audit is required to ensure the violation was corrected. If there are changes or updates that are required to the case due to the Unintentional Program Violation, CCPIES informs the Child Care Enrollment of the changes and/or updates to be made. If there is an improper payment, the Child Care Provider is required to return the improper payment back to DCF. Based on the mentioned ￿red flag/outlier’ reports the agency uses - UNINTENTIONAL PROGRAM VIOLATION DATA From January 2024 to July 2024: 1 80 Child Care Recipient Cases Reviewed 1.1 0 Child Care Recipient improper payments established. 2 34 Child Care Provider Cases Reviewed and 9 Child Care Providers Audited 2.1 25 Improper payments, totaling $86,826.42. 2.2 Education and Corrective Actions were provided on all 43 Child Care Providers. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: The Data Analysts under Management Support reviews system generated data to identify any concerns or problematic inconsistencies. System generated data reports are sent regularly, monthly to the Kansas Department for Children and Families program managers to further assess any potential risks identified from these reports. The reports pertaining to the child care program are sent to the Child Care program manager, Child Care Enrollment as well as to the Child Care Provider Integrity Education Support Unit to review for any irregularities and potential fraud risks. The Child Care Provider Integrity Education Support unit receives the following reports: Semi-Annual High Dollar Report for centers and licensed homes. This report is provided yearly. This report is generated annually in January to provide dollar amount received from both centers and licensed homes which were paid over a certain amount. The amount for licensed homes is 20k. When the report is generated, if the daycare provider meets or exceeds that amount, then they will appear on the report to review for red flags and a provider audit review will be completed. Audits are completed with In Person visits as well as by Mail Audits to the daycare provider home or center to review their business records. Records requested consists of attendance, payment, enrollment records. Excessive Large Balance Alerts. This report is sent sporadically when the EBT manager receives an alert. The EBT Manager generates a report and sends it to the CCPIES unit. This is an alert to notify a large EBT subsidy balance on a recipient’s card. Generally, with these reports, review of the client’s case is completed first to determine what the approved subsidy amount for their household is and when the last payment was made to a daycare provider. A review of the recipients’ case is done to determine the status of the case, when payments are being made, who they are being made to. If, after reviewing the case file, it is determined the large balance is not questionable, then there is no need to pursue any further review or investigation. However, if information is found to be questionable, a deeper dive into the recipient case, along with their payment history and providers paid is reviewed. Oftentimes if the balance is found to be questionable, past payments are also questionable, leading to auditing the provider(s) this recipient has used or is requesting. Audits are completed with In Person visits as well as by Mail Audits to the daycare provider home or center to review their business records. Records requested consists of attendance, payment, enrollment records. Unauthorized Payment Report. This report is sent once a month. This report is generated for Kansas Department for Children and Families IN HOME and OUT of HOME Providers. As an INHOME or OUT OF HOME Provider, the provider can only care for and accept EBT Child Care benefits from those they are authorized to care and accept EBT payment from. When the INHOME/OUT OF HOME provider applies, they request care for specific families of whom they are related to. If they meet their requirements, they are approved to care for and accept EBT from only those families. This report lists INHOME and OUT OF HOME providers who accept EBT payment from unauthorized families. When an unauthorized payment is received, a review of the case, payers and payees involved, and transaction is made to determine if the payment was authorized. If it isn't, an overpayment is created. No other investigation would be needed for these types of issues. Providers who are also Recipients Report. This report is sent once a month. This report is generated to determine if any Kansas Department for Children and Families daycare providers, who are also Kansas Department for Children and Families Child Care recipients, pay themselves. Per Kansas Department for Children and Families policy, Providers may apply for child care for their own children but care cannot be paid to their facility if they are the owner. However, an exception has recently been made for Foster Care Child Care (FC CC,) for those situations to be approved on a case-by-case basis by the FC CC Leadership. In these situations, generally after a review of the provider and eligibility file, a determination can be made if there will be an overpayment or not. No other investigation is usually necessary for these types of cases. Fraud Referral Reports. These alerts, referrals or reports are sent when received or ready for the Child Care Provider Integrity Education Support Unit to review the recipient or provider. Fraud referrals are sent to our Child Care Provider Integrity Education Support (CCPIES) Unit in various ways. Hotline referrals are received most regularly; however, we receive referrals from within the agency, outside of the agency, 'anonymous' calls/tips, etc. Generally, when a referral from within the agency, client or provider is made, it is emailed directly to the CCPIES unit. Oftentimes it is emailed to the Child Care Enrollment Unit, who then forwards it to the CCPIES unit. When a fraud hotline referral is made, the report goes to the fraud unit and a fraud # or alert is generated by the fraud unit. If the referral is a combined benefits case (Food Assistance/Cash Assistance AND CC), then the fraud unit investigates their Food Assistance/Cash Assistance and then sends it to the Child Care Provider Integrity Education Support (CCPIES) Unit to review the Child Care portion for potential fraud. IF the case is a child care recipient only or deals with only the child care provider, the referral is immediately sent to the CCPIES Unit to review and investigate for potential fraud and errors and to pursue overpayment and or fraud disqualification. With regards to the daycare providers, an audit is generally done for an initial contact to determine if further investigation is necessary. Audits are completed with In Person visits as well as by Mail Audits to the daycare provider home or center to review their business records. Records requested consists of attendance, payment, enrollment records. Kansas Eligibility Enforcement System (KEES) generated reports. These reports are regularly ran to identify system or potential process concerns. The eligibility system, KEES, contains edits that prevent the authorization of excessive hours, prevent the overlap of plans for the same child at the same time, determines the hours to be authorized when schedules are entered to prevent and reduce errors. Warnings are also created when the system recognizes something that requires a closer look by the eligibility worker, like child care plans being created for a provider who is almost at capacity or when a child is on another child care program. Provider rates are automated to prevent incorrect rates from being entered on the child care plan. System rules streamline the application of many of the child care policies based on data that is entered by eligibility workers. Data matches are used with Kansas wage and unemployment compensation and Social Security Administration to assist with verifying or identifying income. Fraud Navigator is a tool accessed through the EBT system to monitor real- time transactions including child care payments for suspicious payment activity, such as excessive transaction amounts. When an error or inconsistency is identified, a report is generated and assessed to be sent to the appropriate departments for further review and resolution or investigation. The above reports are reviewed to assess if it was a system error, agency error, or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. Child Care eligibility staff processes any agency or unintentional program violations within the child care eligibility recipient case. If a potential intentional program violation is identified for a child care eligibility recipient, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. Whereas If either unintentional or intentional program violations are identified for child care providers, the case is referred to the Child Care Provider Integrity Education Support Unit. If an Agency Error is discovered, CCPIES informs the eligibility workers of the error if it is a Child Care Recipient case for the changes and/or updates to be made. If an Agency Error is discovered with regards to Child Care Providers, CCPIES informs Child Care Enrollment of the error for the changes and/or updates to be made. If there are any Child Care Recipient improper payments due to Agency Error, it is for Eligibility staff to decide whether a claim is created for the Child Care Recipient to return the funds back to DCF. CCPIES does not create claims for improper payments due to agency errors. Based on the mentioned reports the agency uses, 0 Agency Errors established in 2024. 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: When the Child Care Provider Integrity Education and Support Unit (CCPIES) completes their audits, they do a thorough review of the parent/recipient case. This includes, but is not limited to, reviewing all child care plans, case processes, information gathered at the time of application/review and any updates or changes made on the case. When these reviews are completed on the child care recipients, the unit utilizes and reviews the information gathered by other programs like Cash Assistance, Food Assistance, Medicaid, Child and Adult Care Food Program, Kansas Department of Health and Environment records, Childcare Licensing And Regulation Information System (CLARIS), Social Security Administration, and Public Assistance Reporting Information system to ensure the household composition, members, and information submitted by the recipient to the program worker is consistent. When a review or audit is completed for child care providers, the reviewer checks to see if the provider receives assistance and ensures that they are reporting this income for Cash Assistance, Food Assistance or Child Care Assistance cases. The Child Care Provider Integrity Education Support unit reviews child care enrollment record; all documents submitted by the provider to child care enrollment for their agreement with Kansas Department for Children and Families, provider business records which include parent provider contracts, attendance records and payment records. During a review or audit of a Child Care Assistance case or Kansas Department for Children and Families enrolled provider, the Child Care Provider Integrity Education and Support Unit assesses any information or documentation which may have been misread or miscommunicated by the worker/recipient/provider to determine if it was an agency error or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. When any program violation is identified by the Child Care Provider Integrity Education Support unit during a site visit/audit; the Child Care Provider Education Support Unit is responsible for assessing and processing any unintentional or intentional program violations with regards to child care eligibility or child care providers. The Child Care Provider Integrity Education Support unit does not take action on Agency errors, rather they notify the child care program and policy manager to take appropriate action providing reminders or requesting training to eligibility staff if warranted. For Intentional Program Violations, if an improper payment is discovered, a claim would be created for the Child Care Recipient or Child Care Provider to return the funds back to DCF. For Child Care Recipients, if an Intentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit has the option to take the Child Care Recipient through the process of Administrative Disqualification through the DCF Office of Administrative Hearings (OAH) to determine a fraud judgement. If the recipient is found to have committed fraud by OAH, the recipient is required to return the improper payment to DCF and the Child Care Recipient adult(s) will be flagged as having committed Child Care Fraud. Per our state policy KEESM 11221.2, the children will continue to be eligible for Child Care subsidy. Currently, for Child Care Providers, if an intentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit has the option to request the Child Care Provider’s agreement with DCF be terminated. The request and all supporting evidence of the intentional program violation is sent to Child Care Enrollment, who then reviews it with DCF Leadership and they are the ones who decide whether the Child Care Provider’s DCF agreement will be terminated. If the DCF Leadership agrees to terminate the DCF agreement with the Child Care Provider, then Child Care Enrollment will end the agreement and the Child Care Provider will be required to return the improper payment back to DCF. If DCF Leadership allows the Child Care Provider to keep their agreement with DCF, the Child Care Provider will still be required to return the improper payment and a follow up audit will take place in the future. DCF CCPIES does not have the ability to take Intentional Program Violations to Civil court as there are no DCF attorneys available to do so. However, depending on the dollar amount of the improper payment for the Intentional Program Violation, CCPIES can request to take the Child Care Recipient or Child Care Provider to criminal court. For this request, CCPIES would need to present the case to the County District Attorneys office and the county D.A. would decide if they want to take the case. If the D.A. agrees to take the Intentional Program Violation to criminal court, the D.A. will review the case and request CCPIES complete an affidavit and obtain any other evidence needed for the D.A. to take it to criminal court for the judicial process. If the D.A. refuses to take the case, depending on whether it is a Child Care Recipient or Child Care provider, CCPIES would have the options as already stated above. In both situations, if there is a combined case of the Child Care Program and Food Assistance or TANF involved, CCPIES works with the Fraud Special Investigators with obtaining the evidence as well as the chosen process for fraud determination. Based on the mentioned ￿red flag/outlier’ reports the agency uses -INTENTIONAL PROGRAM VIOLATION DATA From January 2024 to July 2024: 1 74 Fraud referrals received / 6 Fraud referrals have been reviewed. 1.1 3 closed with no program violation and no improper payment. 1.2 1 CC Provider, $3900 improper payment. Potential Fraud, Judgement not obtained as no Civil action available. Education and Corrective Action given. 1.3 1 CC Recipient received Fraud judgement, $43,658.80. 1.4 1 Combined CC Recipient and CC Provider. CCPIES is currently working with the DCF Fraud unit on a combined program fraud case and is currently going through the Criminal court process. 1.4.1 Anticipated CC Improper Payment for Intentional Violation 1.4.2 Child Care Recipient: $83,228.82 1.4.3 Child Care Provider: $83,228.81 1.4.4 These amounts are for Child Care program violations only. 2 23 High Payment Potential Fraud Alerts reviewed and completed. 2.1 13 closed with no fraud discovered, no improper payment. 2.2 10 Improper Payments, totaling $74,951.36- No fraud discovered, education provided. 3 13 Unauthorized Payments Potential Fraud reviewed and completed. 3.1 13 Child Care Provider Improper payments - total $36,022.48 3.2 13 Potential Fraud, Judgement not obtained as no Civil action available. ALL 13 Child Care Providers had their DCF Provider Agreement terminated ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: When the Child Care Provider Integrity Education and Support Unit (CCPIES) completes their audits, they do a thorough review of the parent/recipient case. This includes, but is not limited to, reviewing all child care plans, case processes, information gathered at the time of application/review and any updates or changes made on the case. When these reviews are completed on the child care recipients, the unit utilizes and reviews the information gathered by other programs like Cash Assistance, Food Assistance, Medicaid, Child and Adult Care Food Program, Kansas Department of Health and Environment records, Childcare Licensing And Regulation Information System (CLARIS), Social Security Administration, and Public Assistance Reporting Information system to ensure the household composition, members, and information submitted by the recipient to the program worker is consistent. When a review or audit is completed for child care providers, the reviewer checks to see if the provider receives assistance and ensures that they are reporting this income for Cash Assistance, Food Assistance or Child Care Assistance cases. The Child Care Provider Integrity Education Support unit reviews child care enrollment record; all documents submitted by the provider to child care enrollment for their agreement with Kansas Department for Children and Families, provider business records which include parent provider contracts, attendance records and payment records. During a review or audit of a Child Care Assistance case or Kansas Department for Children and Families enrolled provider, the Child Care Provider Integrity Education and Support Unit assesses any information or documentation which may have been misread or miscommunicated by the worker/recipient/provider to determine if it was an agency error or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. When any program violation is identified by the Child Care Provider Integrity Education Support unit during a site visit/audit; the Child Care Provider Education Support Unit is responsible for assessing and processing any unintentional or intentional program violations with regards to child care eligibility or child care providers. The Child Care Provider Integrity Education Support unit does not take action on Agency errors, rather they notify the child care program and policy manager to take appropriate action providing reminders or requesting training to eligibility staff if warranted. For Unintentional Program Violations, if an improper payment is discovered, a claim would be created for the Child Care Recipient or Child Care Provider to return the funds back to DCF. For Child Care Recipients, if an Unintentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit provides an education to the Child Care Recipient and explains the improper payment. If there are changes or updates that are required to the case due to the Unintentional Program Violation, CCPIES informs the eligibility workers of the changes and/or updates to be made. The Child Care Recipient is required to return the improper payment back to DCF. For Child Care Providers, if an Unintentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit provides an education to the provider by way of a Corrective Action Plan and a Follow Up audit is required to ensure the violation was corrected. If there are changes or updates that are required to the case due to the Unintentional Program Violation, CCPIES informs the Child Care Enrollment of the changes and/or updates to be made. If there is an improper payment, the Child Care Provider is required to return the improper payment back to DCF. Based on the mentioned ￿red flag/outlier’ reports the agency uses - UNINTENTIONAL PROGRAM VIOLATION DATA From January 2024 to July 2024: 1 80 Child Care Recipient Cases Reviewed 1.1 0 Child Care Recipient improper payments established. 2 34 Child Care Provider Cases Reviewed and 9 Child Care Providers Audited 2.1 25 Improper payments, totaling $86,826.42. 2.2 Education and Corrective Actions were provided on all 43 Child Care Providers. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: When the Child Care Provider Integrity Education and Support Unit (CCPIES) completes their audits, they do a thorough review of the parent/recipient case. This includes, but is not limited to, reviewing all child care plans, case processes, information gathered at the time of application/review and any updates or changes made on the case. When these reviews are completed on the child care recipients, the unit utilizes and reviews the information gathered by other programs like Cash Assistance, Food Assistance, Medicaid, Child and Adult Care Food Program, Kansas Department of Health and Environment records, Childcare Licensing And Regulation Information System (CLARIS), Social Security Administration, and Public Assistance Reporting Information system to ensure the household composition, members, and information submitted by the recipient to the program worker is consistent. When a review or audit is completed for child care providers, the reviewer checks to see if the provider receives assistance and ensures that they are reporting this income for Cash Assistance, Food Assistance or Child Care Assistance cases. The Child Care Provider Integrity Education Support unit reviews child care enrollment record; all documents submitted by the provider to child care enrollment for their agreement with Kansas Department for Children and Families, provider business records which include parent provider contracts, attendance records and payment records. During a review or audit of a Child Care Assistance case or Kansas Department for Children and Families enrolled provider, the Child Care Provider Integrity Education and Support Unit assesses any information or documentation which may have been misread or miscommunicated by the worker/recipient/provider to determine if it was an agency error or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. When any program violation is identified by the Child Care Provider Integrity Education Support unit during a site visit/audit; the Child Care Provider Education Support Unit is responsible for assessing and processing any unintentional or intentional program violations with regards to child care eligibility or child care providers. The Child Care Provider Integrity Education Support unit does not take action on Agency errors, rather they notify the child care program and policy manager to take appropriate action providing reminders or requesting training to eligibility staff if warranted. If an Agency Error is discovered, CCPIES informs the eligibility workers of the error if it is a Child Care Recipient case for the changes and/or updates to be made. If an Agency Error is discovered with regards to Child Care Providers, CCPIES informs Child Care Enrollment of the error for the changes and/or updates to be made. If there are any Child Care Recipient improper payments due to Agency Error, it is for Eligibility staff to decide whether a claim is created for the Child Care Recipient to return the funds back to DCF. CCPIES does not create claims for improper payments due to agency errors. 0 Agency Errors established in 2024 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: Eligibility workers verify various child care eligibility factors, such as employment, income, citizenship, age, residency, etc. through access to shared information from other programs like Cash Assistance, FNS and Medicaid. Other databases are used to assist with verifying or identifying income, such as social security administration. Public Assistance Reporting Information system matches are used to ensure that residency requirements are met and identify duplications in the program with another state. Supervisory case reviews are used to assess error trends and determine additional training needs. Supervisors and program improvement staff complete and record the results of case reads in the Case Review System (CARES), The data is available at the worker, unit, regional, or state level. The case reviews may lead to errors identifying program violations. Child Care eligibility staff processes any agency or unintentional program violations within the child care eligibility recipient case. If a potential intentional program violation is identified for a child care eligibility recipient, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. Whereas if either unintentional or intentional program violations are identified for child care providers, the case is referred to the Child Care Provider Integrity Education Support Unit. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Eligibility workers verify various child care eligibility factors, such as employment, income, citizenship, age, residency, etc. through access to shared information from other programs like Cash Assistance, FNS and Medicaid. Other databases are used to assist with verifying or identifying income, such as social security administration. Public Assistance Reporting Information system matches are used to ensure that residency requirements are met and identify duplications in the program with another state. Supervisory case reviews are used to assess error trends and determine additional training needs. Supervisors and program improvement staff complete and record the results of case reads in the Case Review System (CARES), The data is available at the worker, unit, regional, or state level. The case reviews may lead to errors identifying program violations. Child Care eligibility staff processes any agency or unintentional program violations within the child care eligibility recipient case. If a potential intentional program violation is identified for a child care eligibility recipient, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. Whereas if either unintentional or intentional program violations are identified for child care providers, the case is referred to the Child Care Provider Integrity Education Support Unit. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: Eligibility workers verify various child care eligibility factors, such as employment, income, citizenship, age, residency, etc. through access to shared information from other programs like Cash Assistance, FNS and Medicaid. Other databases are used to assist with verifying or identifying income, such as social security administration. Public Assistance Reporting Information system matches are used to ensure that residency requirements are met and identify duplications in the program with another state. Supervisory case reviews are used to assess error trends and determine additional training needs. Supervisors and program improvement staff complete and record the results of case reads in the Case Review System (CARES), The data is available at the worker, unit, regional, or state level. The case reviews may lead to errors identifying program violations. Child Care eligibility staff processes any agency or unintentional program violations within the child care eligibility recipient case. If a potential intentional program violation is identified for a child care eligibility recipient, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. Whereas if either unintentional or intentional program violations are identified for child care providers, the case is referred to the Child Care Provider Integrity Education Support Unit. e. [x] Audit provider records. i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: When the Child Care Provider Integrity Education and Support Unit completes their audits, they do a thorough review of the parent/recipient case. This includes, but is not limited to, reviewing all child care plans, case processes, information gathered at the time of application/review and any updates or changes made on the case. When these reviews are completed on the child care recipients, the unit utilizes and reviews the information gathered by other programs like Cash Assistance, Food Assistance, Medicaid, Child and Adult Care Food Program, Kansas Department of Health and Environment records, Childcare Licensing And Regulation Information System (CLARIS), Social Security Administration, and Public Assistance Reporting Information system to ensure the household composition, members, and information submitted by the recipient to the program worker is consistent. When a review or audit is completed for child care providers, the reviewer checks to see if the provider receives assistance and ensures that they are reporting this income for Cash Assistance, Food Assistance or Child Care Assistance cases. The Child Care Provider Integrity Education Support unit reviews child care enrollment record; all documents submitted by the provider to child care enrollment for their agreement with Kansas Department for Children and Families, provider business records which include parent provider contracts, attendance records and payment records. During a review or audit of a Child Care Assistance case or Kansas Department for Children and Families enrolled provider, the Child Care Provider Integrity Education and Support Unit assesses any information or documentation which may have been misread or miscommunicated by the worker/recipient/provider to determine if it was an agency error or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. When any program violation is identified by the Child Care Provider Integrity Education Support unit during a site visit/audit; the Child Care Provider Education Support Unit is responsible for assessing and processing any unintentional or intentional program violations with regards to child care eligibility or child care providers. The Child Care Provider Integrity Education Support unit does not take action on Agency errors, rather they notify the child care program and policy manager to take appropriate action providing reminders or requesting training to eligibility staff if warranted. For Intentional Program Violations, if an improper payment is discovered, a claim would be created for the Child Care Recipient or Child Care Provider to return the funds back to DCF. For Child Care Recipients, if an Intentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit has the option to take the Child Care Recipient through the process of Administrative Disqualification through the DCF Office of Administrative Hearings (OAH) to determine a fraud judgement. If the recipient is found to have committed fraud by OAH, the recipient is required to return the improper payment to DCF and the Child Care Recipient adult(s) will be flagged as having committed Child Care Fraud. Per our state policy KEESM 11221.2, the children will continue to be eligible for Child Care subsidy. Currently, for Child Care Providers, if an intentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit has the option to request the Child Care Provider’s agreement with DCF be terminated. The request and all supporting evidence of the intentional program violation is sent to Child Care Enrollment, who then reviews it with DCF Leadership and they are the ones who decide whether the Child Care Provider’s DCF agreement will be terminated. If the DCF Leadership agrees to terminate the DCF agreement with the Child Care Provider, then Child Care Enrollment will end the agreement and the Child Care Provider will be required to return the improper payment back to DCF. If DCF Leadership allows the Child Care Provider to keep their agreement with DCF, the Child Care Provider will still be required to return the improper payment and a follow up audit will take place in the future. DCF CCPIES does not have the ability to take Intentional Program Violations to Civil court as there are no DCF attorneys available to do so. However, depending on the dollar amount of the improper payment for the Intentional Program Violation, CCPIES can request to take the Child Care Recipient or Child Care Provider to criminal court. For this request, CCPIES would need to present the case to the County District Attorneys office and the county D.A. would decide if they want to take the case. If the D.A. agrees to take the Intentional Program Violation to criminal court, the D.A. will review the case and request CCPIES complete an affidavit and obtain any other evidence needed for the D.A. to take it to criminal court for the judicial process. If the D.A. refuses to take the case, depending on whether it is a Child Care Recipient or Child Care provider, CCPIES would have the options as already stated above. In both situations, if there is a combined case of the Child Care Program and Food Assistance or TANF involved, CCPIES works with the Fraud Special Investigators with obtaining the evidence as well as the chosen process for fraud determination. INTENTIONAL PROGRAM VIOLATION DATA From January 2024 to July 2024: 1 74 Fraud referrals received / 6 Fraud referrals have been reviewed. 1.1 3 closed with no program violation and no improper payment. 1.2 1 CC Provider, $3900 improper payment. Potential Fraud, Judgement not obtained as no Civil action available. Education and Corrective Action given. 1.3 1 CC Recipient received Fraud judgement, $43,658.80. 1.4 1 Combined CC Recipient and CC Provider. CCPIES is currently working with the DCF Fraud unit on a combined program fraud case and is currently going through the Criminal court process. 1.4.1 Anticipated CC Improper Payment for Intentional Violation 1.4.2 Child Care Recipient: $83,228.82 1.4.3 Child Care Provider: $83,228.81 1.4.4 These amounts are for Child Care program violations only. 2 23 High Payment Potential Fraud Alerts reviewed and completed. 2.1 13 closed with no fraud discovered, no improper payment. 2.2 10 Improper Payments, totaling $74,951.36- No fraud discovered, education provided. 3 13 Unauthorized Payments Potential Fraud reviewed and completed. 3.1 13 Child Care Provider Improper payments - total $36,022.48 3.2 13 Potential Fraud, Judgement not obtained as no Civil action available. ALL 13 Child Care Providers had their DCF Provider Agreement terminated ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: When the Child Care Provider Integrity Education and Support Unit completes their audits, they do a thorough review of the parent/recipient case. This includes, but is not limited to, reviewing all child care plans, case processes, information gathered at the time of application/review and any updates or changes made on the case. When these reviews are completed on the child care recipients, the unit utilizes and reviews the information gathered by other programs like Cash Assistance, Food Assistance, Medicaid, Child and Adult Care Food Program, Kansas Department of Health and Environment records, Childcare Licensing And Regulation Information System (CLARIS), Social Security Administration, and Public Assistance Reporting Information system to ensure the household composition, members, and information submitted by the recipient to the program worker is consistent. When a review or audit is completed for child care providers, the reviewer checks to see if the provider receives assistance and ensures that they are reporting this income for Cash Assistance, Food Assistance or Child Care Assistance cases. The Child Care Provider Integrity Education Support unit reviews child care enrollment record; all documents submitted by the provider to child care enrollment for their agreement with Kansas Department for Children and Families, provider business records which include parent provider contracts, attendance records and payment records. During a review or audit of a Child Care Assistance case or Kansas Department for Children and Families enrolled provider, the Child Care Provider Integrity Education and Support Unit assesses any information or documentation which may have been misread or miscommunicated by the worker/recipient/provider to determine if it was an agency error or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. When any program violation is identified by the Child Care Provider Integrity Education Support unit during a site visit/audit; the Child Care Provider Education Support Unit is responsible for assessing and processing any unintentional or intentional program violations with regards to child care eligibility or child care providers. The Child Care Provider Integrity Education Support unit does not take action on Agency errors, rather they notify the child care program and policy manager to take appropriate action providing reminders or requesting training to eligibility staff if warranted. For Unintentional Program Violations, if an improper payment is discovered, a claim would be created for the Child Care Recipient or Child Care Provider to return the funds back to DCF. For Child Care Recipients, if an Unintentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit provides an education to the Child Care Recipient and explains the improper payment. If there are changes or updates that are required to the case due to the Unintentional Program Violation, CCPIES informs the eligibility workers of the changes and/or updates to be made. The Child Care Recipient is required to return the improper payment back to DCF. For Child Care Providers, if an Unintentional Program Violation is discovered, the Child Care Provider Integrity Education Support unit provides an education to the provider by way of a Corrective Action Plan and a Follow Up audit is required to ensure the violation was corrected. If there are changes or updates that are required to the case due to the Unintentional Program Violation, CCPIES informs the Child Care Enrollment of the changes and/or updates to be made. If there is an improper payment, the Child Care Provider is required to return the improper payment back to DCF. UNINTENTIONAL PROGRAM VIOLATION DATA From January 2024 to July 2024: 1 80 Child Care Recipient Cases Reviewed 1.1 0 Child Care Recipient improper payments established. 2 34 Child Care Provider Cases Reviewed and 9 Child Care Providers Audited 2.1 25 Improper payments, totaling $86,826.42. 2.2 Education and Corrective Actions were provided on all 43 Child Care Providers. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: When the Child Care Provider Integrity Education and Support Unit completes their audits, they do a thorough review of the parent/recipient case. This includes, but is not limited to, reviewing all child care plans, case processes, information gathered at the time of application/review and any updates or changes made on the case. When these reviews are completed on the child care recipients, the unit utilizes and reviews the information gathered by other programs like Cash Assistance, Food Assistance, Medicaid, Child and Adult Care Food Program, Kansas Department of Health and Environment records, Childcare Licensing And Regulation Information System (CLARIS), Social Security Administration, and Public Assistance Reporting Information system to ensure the household composition, members, and information submitted by the recipient to the program worker is consistent. When a review or audit is completed for child care providers, the reviewer checks to see if the provider receives assistance and ensures that they are reporting this income for Cash Assistance, Food Assistance or Child Care Assistance cases. The Child Care Provider Integrity Education Support unit reviews child care enrollment record; all documents submitted by the provider to child care enrollment for their agreement with Kansas Department for Children and Families, provider business records which include parent provider contracts, attendance records and payment records. During a review or audit of a Child Care Assistance case or Kansas Department for Children and Families enrolled provider, the Child Care Provider Integrity Education and Support Unit assesses any information or documentation which may have been misread or miscommunicated by the worker/recipient/provider to determine if it was an agency error or whether it was an unintentional or intentional program violation to decide if further action or investigation is necessary. When any program violation is identified by the Child Care Provider Integrity Education Support unit during a site visit/audit; the Child Care Provider Education Support Unit is responsible for assessing and processing any unintentional or intentional program violations with regards to child care eligibility or child care providers. The Child Care Provider Integrity Education Support unit does not take action on Agency errors, rather they notify the child care program and policy manager to take appropriate action providing reminders or requesting training to eligibility staff if warranted. If an Agency Error is discovered, CCPIES informs the eligibility workers of the error if it is a Child Care Recipient case for the changes and/or updates to be made. If an Agency Error is discovered with regards to Child Care Providers, CCPIES informs Child Care Enrollment of the error for the changes and/or updates to be made. If there are any Child Care Recipient improper payments due to Agency Error, it is for Eligibility staff to decide whether a claim is created for the Child Care Recipient to return the funds back to DCF. CCPIES does not create claims for improper payments due to agency errors. 0 Agency Errors established in 2024 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 KEES eligibility system has built in rules that apply most eligibility factors for a child care assistance determination based on information entered by an eligibility worker. This automates much of the child care policy. The KEES user manual provides detailed instructions on the system. Access to eligibility records is limited to individuals with a job description that requires access. Only limited positions are allowed access to approve eligibility on the system, others are only given read-only access. Implementation meetings occur when changes are made to the policy log and staff need to be made aware of the new policy, instructions and training materials are developed as needed to help implement new policies, and questions are collected regarding new policies and the answers are shared with all staff. Regional trainers do onsite training on topics when needed, supervisors meet with staff on a regular basis to inform them of new information or known issues, and desk aids staff use for interviews are updated when needed due to policy changes. Regional trainers do onsite training on topics when needed, supervisors meet with staff on a regular basis to inform them of new information or known issues, and desk aids staff use for interviews are updated when needed due to policy changes. In addition to completing the Child Care Personal Trainer, eligibility staff also attend instructor led training. Instructor led training provides a combination of lecture, collaborative and hands-on learning. In addition to learning these themes, staff complete simulated cases in a practice system environment in order to receive hands-on experience. Following the more structured portion of training, new staff work with either their supervisors or the regional case readers to evaluate ongoing case work for up to 60 days. The supervisors and case readers are able to monitor training needs and provide a refresher if needed. The Child Care Provider Integrity Education Support unit not only attends the implementation and policy meetings, but they are also required to train on child care eligibility, child care enrollment policies and procedures, and fraud. The Child Care Provider Integrity Education Support unit trains with the fraud special investigators and attends regular meetings and conferences with the fraud unit to stay current with fraudulent activities, red flags, and any changes or updates to polices or procedures pertaining to all program violations. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The KEES eligibility system has built in rules that apply most eligibility factors for a child care assistance determination based on information entered by an eligibility worker. This automates much of the child care policy. The KEES user manual provides detailed instructions on the system. Access to eligibility records is limited to individuals with a job description that requires access. Only limited positions are allowed access to approve eligibility on the system, others are only given read-only access. Implementation meetings occur when changes are made to the policy log and staff need to be made aware of the new policy, instructions and training materials are developed as needed to help implement new policies, and questions are collected regarding new policies and the answers are shared with all staff. Regional trainers do onsite training on topics when needed, supervisors meet with staff on a regular basis to inform them of new information or known issues, and desk aids staff use for interviews are updated when needed due to policy changes. Regional trainers do onsite training on topics when needed, supervisors meet with staff on a regular basis to inform them of new information or known issues, and desk aids staff use for interviews are updated when needed due to policy changes. In addition to completing the Child Care Personal Trainer, eligibility staff also attend instructor led training. Instructor led training provides a combination of lecture, collaborative and hands-on learning. In addition to learning these themes, staff complete simulated cases in a practice system environment in order to receive hands-on experience. Following the more structured portion of training, new staff work with either their supervisors or the regional case readers to evaluate ongoing case work for up to 60 days. The supervisors and case readers are able to monitor training needs and provide a refresher if needed. The Child Care Provider Integrity Education Support unit not only attends the implementation and policy meetings, but they are also required to train on child care eligibility, child care enrollment policies and procedures, and fraud. The Child Care Provider Integrity Education Support unit trains with the fraud special investigators and attends regular meetings and conferences with the fraud unit to stay current with fraudulent activities, red flags, and any changes or updates to polices or procedures pertaining to all program violations. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: The KEES eligibility system has built in rules that apply most eligibility factors for a child care assistance determination based on information entered by an eligibility worker. This automates much of the child care policy. The KEES user manual provides detailed instructions on the system. Access to eligibility records is limited to individuals with a job description that requires access. Only limited positions are allowed access to approve eligibility on the system, others are only given read-only access. Implementation meetings occur when changes are made to the policy log and staff need to be made aware of the new policy, instructions and training materials are developed as needed to help implement new policies, and questions are collected regarding new policies and the answers are shared with all staff. Regional trainers do onsite training on topics when needed, supervisors meet with staff on a regular basis to inform them of new information or known issues, and desk aids staff use for interviews are updated when needed due to policy changes. Regional trainers do onsite training on topics when needed, supervisors meet with staff on a regular basis to inform them of new information or known issues, and desk aids staff use for interviews are updated when needed due to policy changes. In addition to completing the Child Care Personal Trainer, eligibility staff also attend instructor led training. Instructor led training provides a combination of lecture, collaborative and hands-on learning. In addition to learning these themes, staff complete simulated cases in a practice system environment in order to receive hands-on experience. Following the more structured portion of training, new staff work with either their supervisors or the regional case readers to evaluate ongoing case work for up to 60 days. The supervisors and case readers are able to monitor training needs and provide a refresher if needed. The Child Care Provider Integrity Education Support unit not only attends the implementation and policy meetings, but they are also required to train on child care eligibility, child care enrollment policies and procedures, and fraud. The Child Care Provider Integrity Education Support unit trains with the fraud special investigators and attends regular meetings and conferences with the fraud unit to stay current with fraudulent activities, red flags, and any changes or updates to polices or procedures pertaining to all program violations. g. [ ] Other. Describe the activity(ies): i. [ ] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: ii. [ ] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: iii. [ ] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: 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): Kansas Department for Children and Families is responsible for pursuing fraud and overpayments. If a potential intentional program violation is identified for a child care eligibility recipient or provider, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. If the child care recipient or provider has an Food Assistance or Cash Assistance program themselves, or if they are associated with a child care recipient with a combined Food Assistance/Cash Assistance program which the fraud unit is investigating for fraud- the fraud unit collaborates with the Child Care Provider Integrity Education Support unit to pursue fraud and overpayments. However, if it is a child care program only case, whether recipient or child care provider- the Child Care Provider Integrity Education, Support unit pursues fraud and overpayments. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections ￿ The Central Collections Unit monitors the recovery of the claim. 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: Kansas Department for Children and Families is responsible for pursuing fraud and overpayments. If a potential intentional program violation is identified for a child care eligibility recipient or provider, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. If the child care recipient or provider has an Food Assistance or Cash Assistance program themselves, or if they are associated with a child care recipient with a combined Food Assistance/Cash Assistance program which the fraud unit is investigating for fraud- the fraud unit collaborates with the Child Care Provider Integrity Education Support unit to pursue fraud and overpayments. However, if it is a child care program only case, whether recipient or child care provider- the Child Care Provider Integrity Education, Support unit pursues fraud and overpayments. All recovery claims are set up in our KEES system. If the Child Care Recipient has an active case, the claim for the EBT repayment can be set up to automatically recoup a percentage of benefits from their monthly subsidy (10% if it is an Unintentional Client Error and 20% if it is an Intentional Client Fraud error.) If the Child Care Recipient has an existing balance on their EBT card, they can request the repayment to come from the balance on their EBT card. The recipient would have to submit a formal, handwritten request to the EBT department for the EBT Repayment to be taken off of their balance on their EBT card. If the recipient is found to have committed fraud, the recipient is required to return the improper payment to DCF and the Child Care Recipient adult(s) will be flagged as having committed Child Care Fraud. Per our state policy KEESM 11221.2, the children will continue to be eligible for Child Care subsidy. With regards to DCF Child Care Providers, since their EBT account is set up to accept funds from DCF Child Care Recipients, there is no way for Child Care Providers to make payments on claims using their EBT account, as their EBT account is connected to their personal or business bank account. Child Care Providers must either pay by personal check, money order or debit/credit card for EBT Repayments. If a Child Care provider is found to have committed fraud, the Child Care Enrollment would be notified to determine whether the DCF Child Care provider will continue their DCF CC Provider agreement. DCF Child Care enrollment would discuss with their leadership whether the DCF agreement would be terminated or remain open. If the DCF Child Care provider remains open, continued education and Corrective Action is given. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections The Central Collections Unit monitors the recovery of the claim. INTENTIONAL PROGRAM VIOLATION DATA From January 2024 to July 2024: 1 74 Fraud referrals received / 6 Fraud referrals have been reviewed. 1.1 3 closed with no program violation and no improper payment. 1.2 1 CC Provider, $3900 improper payment. Potential Fraud, Judgement not obtained as no Civil action available. Education and Corrective Action given. 1.3 1 CC Recipient received Fraud judgement, $43,658.80. 1.4 1 Combined CC Recipient and CC Provider. CCPIES is currently working with the DCF Fraud unit on a combined program fraud case and is currently going through the Criminal court process. 1.4.1 Anticipated CC Improper Payment for Intentional Violation 1.4.2 Child Care Recipient: $83,228.82 1.4.3 Child Care Provider: $83,228.81 1.4.4 These amounts are for Child Care program violations only. 2 23 High Payment Potential Fraud Alerts reviewed and completed. 2.1 13 closed with no fraud discovered, no improper payment. 2.2 10 Improper Payments, totaling $74,951.36- No fraud discovered, education provided. 3 13 Unauthorized Payments Potential Fraud reviewed and completed. 3.1 13 Child Care Provider Improper payments - total $36,022.48 4 Potential Fraud, Judgement not obtained as no Civil action available. ALL 13 Child Care Providers had their DCF Provider Agreement terminated. 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: Kansas Department for Children and Families is responsible for pursuing fraud and overpayments. If a potential intentional program violation is identified for a child care eligibility recipient or provider, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. If the child care recipient or provider has an Food Assistance or Cash Assistance program themselves, or if they are associated with a child care recipient with a combined Food Assistance/Cash Assistance program which the fraud unit is investigating for fraud- the fraud unit collaborates with the Child Care Provider Integrity Education Support unit to pursue fraud and overpayments. However, if it is a child care program only case, whether recipient or child care provider- the Child Care Provider Integrity Education, Support unit pursues fraud and overpayments. All recovery claims are set up in our KEES system. If the Child Care Recipient has an active case, the claim for the EBT repayment can be set up to automatically recoup a percentage of benefits from their monthly subsidy (10% if it is an Unintentional Client Error and 20% if it is an Intentional Client Fraud error.) If the Child Care Recipient has an existing balance on their EBT card, they can request the repayment to come from the balance on their EBT card. The recipient would have to submit a formal, handwritten request to the EBT department for the EBT Repayment to be taken off of their balance on their EBT card. If the recipient is found to have committed fraud, the recipient is required to return the improper payment to DCF and the Child Care Recipient adult(s) will be flagged as having committed Child Care Fraud. Per our state policy KEESM 11221.2, the children will continue to be eligible for Child Care subsidy. If a Child Care provider is found to have committed fraud, the Child Care Enrollment would be notified to determine whether the DCF Child Care provider will continue their DCF CC Provider agreement. DCF Child Care enrollment would discuss with their leadership whether the DCF agreement would be terminated or remain open. If the DCF Child Care provider remains open, continued education and Corrective Action is given. With regards to DCF Child Care Providers, since their EBT account is set up to accept funds from DCF Child Care Recipients, there is no way for Child Care Providers to make payments on claims using their EBT account, as their EBT account is connected to their personal or business bank account. Child Care Providers must either pay by personal check, money order or debit/credit card for EBT Repayments. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections The Central Collections Unit monitors the recovery of the claim. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: Kansas Department for Children and Families Enrolled Child Care Providers have the option through repayment plans to pay via lump sum payments or by installments on their recovery as they do not receive subsidy directly from Kansas Department for Children and Families. Child care recipients have the following options through repayment plans for recovery, as they receive subsidy directly from Kansas Department for Children and Families. Per Kansas Department for Children and Families KEESM Policy 11126.1 Methods of Collecting Payments - Claims shall be collected in one or more of the following ways: Lump Sum Payments shall be collected from households in one lump sum cash payment if the household is financially able. However, the household shall not be required to liquidate all of its resources to make this one lump sum payment. If the household is financially unable to pay the entire amount of the claim at one time and prefers to make a lump sum cash payment as partial payment of the claim, it shall be accepted. Installments - If the household is not currently participating in the program with the overpayment and has insufficient liquid resources or is otherwise financially unable to pay the claim in one lump sum, a payment schedule shall be negotiated by the Central Collections Unit (CCU). Once negotiated, the amount to be repaid each month through installment payments shall remain unchanged. Both the household and the agency shall have the option to initiate renegotiation of the payment schedule if they believe that the household's economic circumstances have changed enough to warrant such an action. If the household requests renegotiation, but the CCU feels that the household's economic circumstances have not changed enough to warrant the requested settlement (such as the fact that the household's source of income has not changed) then the CCU may continue renegotiation until a settlement can be reached. Offsetting - For collection to be made by offsetting the amount of the claim against restored benefits, the amount of benefits due the household shall be determined and deducted from any outstanding claim balances. Refer to 11115. A notice of action shall be sent to inform the household of the restored benefit amount and the amount still due on the claim or the amount of restored benefits due after applying them to any outstanding claim. Benefit Reduction - If a household is currently participating in the program with the overpayment, collection action for ALL types of claims shall be accomplished by benefit reduction. When benefit reduction is being utilized the regular benefit shall be reduced as follows; or the client may agree to a larger benefit reduction amount: Fraud Claims Cash and Child Care - The benefit shall be reduced by the greater of 20% of the household’s monthly benefit or $10 per month. Client and Agency Claims Cash and Child Care - The benefit shall be reduced by the greater of 10% of the household’s monthly benefit or $10 per month. NOTE: If benefit reduction is occurring for an agency or client error claim, and the household subsequently has a fraud claim established, the agency should cease benefit collection on the agency/client error claim and initiate benefit reduction on the fraud claim. EBT Repayments - For cash, child care and food assistance, clients can make payments on a claim using their EBT account. Refer to KEES user manual for EBT repayment procedures. Once a claim is created on the KEES system: If the Child Care Recipient has an active case, the claim for the EBT repayment can be set up to automatically recoup a percentage of benefits from their monthly subsidy (10% if it is an Unintentional Client Error and 20% if it is an Intentional Client Fraud error.) If the Child Care Recipient has an existing balance on their EBT card, they can request the repayment to come from the balance on their EBT card. The recipient would have to submit a formal, handwritten request to the EBT department for the EBT Repayment to be taken off of their balance on their EBT card. The KEES user manual has additional, detailed information regarding EBT repayment procedures for Recipients. With regards to DCF Child Care Providers, since their EBT account is set up to accept funds from DCF Child Care Recipients, there is no way for Child Care Providers to make payments on claims using their EBT account, as their EBT account is connected to their personal or business bank account. Child Care Providers must either pay by personal check, money order or debit/credit card for EBT Repayments. All improper payment claims created for EBT Repayment is sent to Kansas Department for Children and Families Central Collections. The Central Collections Unit monitors the recovery of the claim. If repayments are not made, the Central Collections Unit sends recovery notices to the Child Care Recipient and/or Child Care Provider. If repayment is not made Child Care Provider debts are placed in the Kansas Debt Recovery System and repayment is taken out of State Taxes. iv. [x] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: Kansas Department for Children and Families Enrolled Child Care Providers have the option through repayment plans to pay via lump sum payments or by installments on their recovery as they do not receive subsidy directly from Kansas Department for Children and Families. Child care recipients have the following options through repayment plans for recovery, as they receive subsidy directly from Kansas Department for Children and Families. Per Kansas Department for Children and Families KEESM Policy 11126.1 Methods of Collecting Payments - Claims shall be collected in one or more of the following ways: Lump Sum Payments shall be collected from households in one lump sum cash payment if the household is financially able. However, the household shall not be required to liquidate all of its resources to make this one lump sum payment. If the household is financially unable to pay the entire amount of the claim at one time and prefers to make a lump sum cash payment as partial payment of the claim, it shall be accepted. Installments - If the household is not currently participating in the program with the overpayment and has insufficient liquid resources or is otherwise financially unable to pay the claim in one lump sum, a payment schedule shall be negotiated by the Central Collections Unit (CCU). Once negotiated, the amount to be repaid each month through installment payments shall remain unchanged. Both the household and the agency shall have the option to initiate renegotiation of the payment schedule if they believe that the household's economic circumstances have changed enough to warrant such an action. If the household requests renegotiation, but the CCU feels that the household's economic circumstances have not changed enough to warrant the requested settlement (such as the fact that the household's source of income has not changed) then the CCU may continue renegotiation until a settlement can be reached. Offsetting - For collection to be made by offsetting the amount of the claim against restored benefits, the amount of benefits due the household shall be determined and deducted from any outstanding claim balances. Refer to 11115. A notice of action shall be sent to inform the household of the restored benefit amount and the amount still due on the claim or the amount of restored benefits due after applying them to any outstanding claim. Benefit Reduction - If a household is currently participating in the program with the overpayment, collection action for ALL types of claims shall be accomplished by benefit reduction. When benefit reduction is being utilized the regular benefit shall be reduced as follows; or the client may agree to a larger benefit reduction amount: Fraud Claims Cash and Child Care - The benefit shall be reduced by the greater of 20% of the household’s monthly benefit or $10 per month. Client and Agency Claims Cash and Child Care - The benefit shall be reduced by the greater of 10% of the household’s monthly benefit or $10 per month. NOTE: If benefit reduction is occurring for an agency or client error claim, and the household subsequently has a fraud claim established, the agency should cease benefit collection on the agency/client error claim and initiate benefit reduction on the fraud claim. EBT Repayments - For cash, child care and food assistance, clients can make payments on a claim using their EBT account. Refer to KEES user manual for EBT repayment procedures. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections ￿ The Central Collections Unit monitors the recovery of the claim. v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: Kansas Department for Children and Families Child Care Provider debts and all debts except Food Assistance are taken out of State Taxes. Kansas has chosen to use the federal Treasury Offset Program only for our Food Assistance overpayments. Child care debts are placed in the Kansas Debt Recovery System only vi. [x] Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: Per Kansas Department for Children and Families KEESM policy 11126.3 Claims Discharged through Bankruptcy - If local agency staff have knowledge of bankruptcy proceedings against any household owing a food assistance, cash or child care claim, Central Office Legal Department and Central Collection Unit shall be notified immediately. Collection activity shall cease immediately pending the outcome of the court proceedings. Collection action should be resumed (or initiated) after and in conformance with the final court action. Per Kansas Department for Children and Families KEESM policy 11126.6 Expunged Benefits - Expunged food assistance, cash and child care benefits for a client are to be used to reduce the amount of any active claims that the client has. Expunged cash and child care benefits are benefits that have been aged off and not returned to the system and EBT account within 120 days for cash and child care, from the date they were initially made available. 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 Child Care Provider Integrity Education Support unit was created to not only educate child care providers and recipients, this unit also reviews and investigates child care program related fraud, child care program violations and improper payments, both intentional and unintentional. The Child Care Provider Integrity Education Support unit currently consists of (1) working supervisor and (2) program consultants. All staff within the Child Care Provider Integrity Education Support unit educates, audits, and investigates child care program related fraud, child care program violations and improper payments. This unit is under the Program Integrity department. If an improper payment (intentional or unintentional) overpayment for a recipient and/or provider is discovered and established by the Child Care Provider Integrity Education Support Unit, the unit may start the process to recover the overpayment. The Child Care Provider Integrity Education Support Unit calculates the overpayment, creates the claim on the KEES system, and sends the claim to the Central Collections Unit to recover the overpayment. The Central Collections Unit monitors the recovery of the claim. 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: Per Kansas Department for Children and Families KEESM Policy 11120 Overpayments and Claims - An overpayment is assistance that is over the amount to which the client is entitled. One or several months of overpayment become a claim when the cause of the overpayment(s) is due to the same or related causes; agency error, unintentional client error, intentional fraud error. A claim shall be established against any household that has received more assistance than it is entitled to receive. UNINTENTIONAL PROGRAM VIOLATION DATA From January 2024 to July 2024: 1 80 Child Care Recipient Cases Reviewed 1.1 0 Child Care Recipient improper payments established. 2 34 Child Care Provider Cases Reviewed and 9 Child Care Providers Audited 2.1 25 Improper payments, totaling $86,826.42. 2.2 Education and Corrective Actions were provided on all 43 Child Care Providers. All recovery claims are set up in our KEES system. If the Child Care Recipient has an active case, the claim for the EBT repayment can be set up to automatically recoup a percentage of benefits from their monthly subsidy (10% if it is an Unintentional Client Error and 20% if it is an Intentional Client Fraud error.) If the Child Care Recipient has an existing balance on their EBT card, they can request the repayment to come from the balance on their EBT card. The recipient would have to submit a formal, handwritten request to the EBT department for the EBT Repayment to be taken off of their balance on their EBT card. With regards to DCF Child Care Providers, since their EBT account is set up to accept funds from DCF Child Care Recipients, there is no way for Child Care Providers to make payments on claims using their EBT account, as their EBT account is connected to their personal or business bank account. Child Care Providers must either pay by personal check, money order or debit/credit card for EBT Repayments. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections. The Central Collections Unit monitors the recovery of the claim. 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: Coordination with outside agencies does not happen often when related to unintentional improper payments. However, there still may be instances, the state may collaborate with outside agencies. For instance, if medical fraud is involved, the state would collaborate with the Medical Inspector General’s office/AG office, or if the safety of children are involved- the state may collaborate with not only the social workers, but also KDHE and law enforcement. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections ￿ The Central Collections Unit monitors the recovery of the claim. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: Kansas Department for Children and Families Enrolled Child Care Providers have the option through repayment plans to pay via lump sum payments or by installments on their recovery as they do not receive subsidy directly from Kansas Department for Children and Families. Child care recipients have the following options through repayment plans for recovery, as they receive subsidy directly from Kansas Department for Children and Families. Per Kansas Department for Children and Families KEESM Policy 11126.1 Methods of Collecting Payments - Claims shall be collected in one or more of the following ways: Lump Sum Payments shall be collected from households in one lump sum cash payment if the household is financially able. However, the household shall not be required to liquidate all of its resources to make this one lump sum payment. If the household is financially unable to pay the entire amount of the claim at one time and prefers to make a lump sum cash payment as partial payment of the claim, it shall be accepted. Installments - If the household is not currently participating in the program with the overpayment and has insufficient liquid resources or is otherwise financially unable to pay the claim in one lump sum, a payment schedule shall be negotiated by the Central Collections Unit (CCU). Once negotiated, the amount to be repaid each month through installment payments shall remain unchanged. Both the household and the agency shall have the option to initiate renegotiation of the payment schedule if they believe that the household's economic circumstances have changed enough to warrant such an action. If the household requests renegotiation, but the CCU feels that the household's economic circumstances have not changed enough to warrant the requested settlement (such as the fact that the household's source of income has not changed) then the CCU may continue renegotiation until a settlement can be reached. Offsetting - For collection to be made by offsetting the amount of the claim against restored benefits, the amount of benefits due the household shall be determined and deducted from any outstanding claim balances. Refer to 11115. A notice of action shall be sent to inform the household of the restored benefit amount and the amount still due on the claim or the amount of restored benefits due after applying them to any outstanding claim. Benefit Reduction - If a household is currently participating in the program with the overpayment, collection action for ALL types of claims shall be accomplished by benefit reduction. When benefit reduction is being utilized the regular benefit shall be reduced as follows; or the client may agree to a larger benefit reduction amount: Fraud Claims Cash and Child Care - The benefit shall be reduced by the greater of 20% of the household’s monthly benefit or $10 per month. Client and Agency Claims Cash and Child Care - The benefit shall be reduced by the greater of 10% of the household’s monthly benefit or $10 per month. NOTE: If benefit reduction is occurring for an agency or client error claim, and the household subsequently has a fraud claim established, the agency should cease benefit collection on the agency/client error claim and initiate benefit reduction on the fraud claim. EBT Repayments - For cash, child care and food assistance, clients can make payments on a claim using their EBT account. Refer to KEES user manual for EBT repayment procedures. Once a claim is created on the KEES system: If the Child Care Recipient has an active case, the claim for the EBT repayment can be set up to automatically recoup a percentage of benefits from their monthly subsidy (10% if it is an Unintentional Client Error and 20% if it is an Intentional Client Fraud error.) If the Child Care Recipient has an existing balance on their EBT card, they can request the repayment to come from the balance on their EBT card. The recipient would have to submit a formal, handwritten request to the EBT department for the EBT Repayment to be taken off of their balance on their EBT card. The KEES user manual has additional, detailed information regarding EBT repayment procedures for Recipients. With regards to DCF Child Care Providers, since their EBT account is set up to accept funds from DCF Child Care Recipients, there is no way for Child Care Providers to make payments on claims using their EBT account, as their EBT account is connected to their personal or business bank account. Child Care Providers must either pay by personal check, money order or debit/credit card for EBT Repayments. All improper payment claims created for EBT Repayment is sent to Kansas Department for Children and Families Central Collections. The Central Collections Unit monitors the recovery of the claim. If repayments are not made, the Central Collections Unit sends recovery notices to the Child Care Recipient and/or Child Care Provider. If repayment is not made Child Care Provider debts are placed in the Kansas Debt Recovery System and repayment is taken out of State Taxes. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections ￿ The Central Collections Unit monitors the recovery of the claim. iv. [x] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: Per Kansas Department for Children and Families KEESM Policy 11126.1 Methods of Collecting Payments: Benefit Reduction - If a household is currently participating in the program with the overpayment, collection action for ALL types of claims shall be accomplished by benefit reduction. When benefit reduction is being utilized the regular benefit shall be reduced as follows; or the client may agree to a larger benefit reduction amount: Fraud Claims Cash and Child Care - The benefit shall be reduced by the greater of 20% of the household’s monthly benefit or $10 per month. Client and Agency Claims Cash and Child Care - The benefit shall be reduced by the greater of 10% of the household’s monthly benefit or $10 per month. NOTE: If benefit reduction is occurring for an agency or client error claim, and the household subsequently has a fraud claim established, the agency should cease benefit collection on the agency/client error claim and initiate benefit reduction on the fraud claim. Kansas Department for Children and Families Enrolled Child Care Providers have the option through repayment plans to pay via lump sum payments or by installments on their recovery as they do not receive subsidy directly from Kansas Department for Children and Families. Child care recipients, however, have the option to reduce payments for recovery, as they receive subsidy directly from Kansas Department for Children and Families. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections ￿ The Central Collections Unit monitors the recovery of the claim. v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: Kansas Department for Children and Families Child Care Provider debts and all debts except Food Assistance are taken out of State Taxes. Kansas has chosen to use the federal Treasury Offset Program only for our Food Assistance overpayments. Child care debts are placed in the Kansas Debt Recovery System only. vi. [x] Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: Per Kansas Department for Children and Families KEESM policy 11126.3 Claims Discharged through Bankruptcy - If local agency staff have knowledge of bankruptcy proceedings against any household owing a food assistance, cash or child care claim, Central Office Legal Department and Central Collection Unit shall be notified immediately. Collection activity shall cease immediately pending the outcome of the court proceedings. Collection action should be resumed (or initiated) after and in conformance with the final court action. Per Kansas Department for Children and Families KEESM policy 11126.6 Expunged Benefits - Expunged food assistance, cash and child care benefits for a client are to be used to reduce the amount of any active claims that the client has. Expunged cash and child care benefits are benefits that have been aged off and not returned to the system and EBT account within 120 days for cash and child care, from the date they were initially made available. 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 Child Care Provider Integrity Education Support unit was created to not only educate child care providers and recipients, this unit also reviews and investigates child care program related fraud, child care program violations and improper payments, both intentional and unintentional. The Child Care Provider Integrity Education Support unit currently consists of (1) working supervisor and (2) program consultants. All staff within the Child Care Provider Integrity Education Support unit educates, audits, and investigates child care program related fraud, child care program violations and improper payments. This unit is under the Program Integrity department. If a potential intentional program violation is identified for a child care eligibility recipient or provider, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. If the child care recipient or provider has a Food Assistance or Cash Assistance program themselves, or if they are associated with a child care recipient with a combined Food Assistance/Cash Assistance program which the fraud unit is investigating for fraud- the fraud unit collaborates with the Child Care Provider Integrity Education Support unit to pursue fraud and overpayments. If the recipient is found to have committed fraud, the recipient is required to return the improper payment to DCF and the Child Care Recipient adult(s) will be flagged as having committed Child Care Fraud. Per our state policy KEESM 11221.2, the children will continue to be eligible for Child Care subsidy. With regards to DCF Child Care Providers, since their EBT account is set up to accept funds from DCF Child Care Recipients, there is no way for Child Care Providers to make payments on claims using their EBT account, as their EBT account is connected to their personal or business bank account. Child Care Providers must either pay by personal check, money order or debit/credit card for EBT Repayments. If a Child Care provider is found to have committed fraud, the Child Care Enrollment would be notified to determine whether the DCF Child Care provider will continue their DCF CC Provider agreement. DCF Child Care enrollment would discuss with their leadership whether the DCF agreement would be terminated or remain open. If the DCF Child Care provider remains open, continued education and Corrective Action is given. If an improper payment (intentional or unintentional) overpayment for a recipient and/or provider is discovered and established by the Child Care Provider Integrity Education Support Unit, the unit may start the process to recover the overpayment. The Child Care Provider Integrity Education Support Unit calculates the overpayment, creates the claim on the KEES system, and sends the claim to the Central Collections Unit to recover the overpayment. The Central Collections Unit monitors the recovery of the claim. 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: Per Kansas Department for Children and Families KEESM Policy 11120 Overpayments and Claims - An overpayment is assistance that is over the amount to which the client is entitled. One or several months of overpayment become a claim when the cause of the overpayment(s) are due to the same or related causes; agency error, unintentional client error, intentional fraud error. A claim shall be established against any household that has received more assistance than it is entitled to receive. 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. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: Kansas Department for Children and Families Enrolled Child Care Providers have the option through repayment plans to pay via lump sum payments or by installments on their recovery as they do not receive subsidy directly from Kansas Department for Children and Families. Child care recipients have the following options through repayment plans for recovery, as they receive subsidy directly from Kansas Department for Children and Families. Per Kansas Department for Children and Families KEESM Policy 11126.1 Methods of Collecting Payments - Claims shall be collected in one or more of the following ways: Lump Sum Payments shall be collected from households in one lump sum cash payment if the household is financially able. However, the household shall not be required to liquidate all of its resources to make this one lump sum payment. If the household is financially unable to pay the entire amount of the claim at one time and prefers to make a lump sum cash payment as partial payment of the claim, it shall be accepted. Installments - If the household is not currently participating in the program with the overpayment and has insufficient liquid resources or is otherwise financially unable to pay the claim in one lump sum, a payment schedule shall be negotiated by the Central Collections Unit (CCU). Once negotiated, the amount to be repaid each month through installment payments shall remain unchanged. Both the household and the agency shall have the option to initiate renegotiation of the payment schedule if they believe that the household's economic circumstances have changed enough to warrant such an action. If the household requests renegotiation, but the CCU feels that the household's economic circumstances have not changed enough to warrant the requested settlement (such as the fact that the household's source of income has not changed) then the CCU may continue renegotiation until a settlement can be reached. Offsetting - For collection to be made by offsetting the amount of the claim against restored benefits, the amount of benefits due the household shall be determined and deducted from any outstanding claim balances. Refer to 11115. A notice of action shall be sent to inform the household of the restored benefit amount and the amount still due on the claim or the amount of restored benefits due after applying them to any outstanding claim. Benefit Reduction - If a household is currently participating in the program with the overpayment, collection action for ALL types of claims shall be accomplished by benefit reduction. When benefit reduction is being utilized the regular benefit shall be reduced as follows; or the client may agree to a larger benefit reduction amount: Fraud Claims Cash and Child Care - The benefit shall be reduced by the greater of 20% of the household’s monthly benefit or $10 per month. Client and Agency Claims Cash and Child Care - The benefit shall be reduced by the greater of 10% of the household’s monthly benefit or $10 per month. NOTE: If benefit reduction is occurring for an agency or client error claim, and the household subsequently has a fraud claim established, the agency should cease benefit collection on the agency/client error claim and initiate benefit reduction on the fraud claim. EBT Repayments - For cash, child care and food assistance, clients can make payments on a claim using their EBT account. Refer to KEES user manual for EBT repayment procedures. Once a claim is created on the KEES system: If the Child Care Recipient has an active case, the claim for the EBT repayment can be set up to automatically recoup a percentage of benefits from their monthly subsidy (10% if it is an Unintentional Client Error and 20% if it is an Intentional Client Fraud error.) If the Child Care Recipient has an existing balance on their EBT card, they can request the repayment to come from the balance on their EBT card. The recipient would have to submit a formal, handwritten request to the EBT department for the EBT Repayment to be taken off of their balance on their EBT card. The KEES user manual has additional, detailed information regarding EBT repayment procedures for Recipients. With regards to DCF Child Care Providers, since their EBT account is set up to accept funds from DCF Child Care Recipients, there is no way for Child Care Providers to make payments on claims using their EBT account, as their EBT account is connected to their personal or business bank account. Child Care Providers must either pay by personal check, money order or debit/credit card for EBT Repayments. All improper payment claims created for EBT Repayment is sent to Kansas Department for Children and Families Central Collections. The Central Collections Unit monitors the recovery of the claim. If repayments are not made, the Central Collections Unit sends recovery notices to the Child Care Recipient and/or Child Care Provider. If repayment is not made Child Care Provider debts are placed in the Kansas Debt Recovery System and repayment is taken out of State Taxes. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections ￿ The Central Collections Unit monitors the recovery of the claim. iv. [x] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: Per Kansas Department for Children and Families KEESM Policy 11126.1 Methods of Collecting Payments: Benefit Reduction - If a household is currently participating in the program with the overpayment, collection action for ALL types of claims shall be accomplished by benefit reduction. When benefit reduction is being utilized the regular benefit shall be reduced as follows; or the client may agree to a larger benefit reduction amount: Fraud Claims Cash and Child Care - The benefit shall be reduced by the greater of 20% of the household’s monthly benefit or $10 per month. Client and Agency Claims Cash and Child Care - The benefit shall be reduced by the greater of 10% of the household’s monthly benefit or $10 per month. NOTE: If benefit reduction is occurring for an agency or client error claim, and the household subsequently has a fraud claim established, the agency should cease benefit collection on the agency/client error claim and initiate benefit reduction on the fraud claim. Kansas Department for Children and Families Enrolled Child Care Providers have the option through repayment plans to pay via lump sum payments or by installments on their recovery as they do not receive subsidy directly from Kansas Department for Children and Families. Child care recipients however, have the option to reduce payments for recovery, as they receive subsidy directly from Kansas Department for Children and Families. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections ￿ The Central Collections Unit monitors the recovery of the claim. v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: Kansas Department for Children and Families Child Care Provider debts and all debts except Food Assistance are taken out of State Taxes. Kansas has chosen to use the federal Treasury Offset Program only for our Food Assistance overpayments. Child care debts are placed in the Kansas Debt Recovery System only. vi. [x]Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: Per Kansas Department for Children and Families KEESM policy 11126.3 Claims Discharged through Bankruptcy - If local agency staff have knowledge of bankruptcy proceedings against any household owing a food assistance, cash or child care claim, Central Office Legal Department and Central Collection Unit shall be notified immediately. Collection activity shall cease immediately pending the outcome of the court proceedings. Collection action should be resumed (or initiated) after and in conformance with the final court action. Per Kansas Department for Children and Families KEESM policy 11126.6 Expunged Benefits - Expunged food assistance, cash and child care benefits for a client are to be used to reduce the amount of any active claims that the client has. Expunged cash and child care benefits are benefits that have been aged off and not returned to the system and EBT account within 120 days for cash and child care, from the date they were initially made available. 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: Child Care eligibility staff processes any agency or unintentional program violations within the child care eligibility recipient case. If a potential intentional program violation is identified for a child care eligibility recipient, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. If a potential intentional program violation is identified for a child care eligibility recipient or provider, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. If the child care recipient or provider has an Food Assistance or Cash Assistance program themselves, or if they are associated with a child care recipient with a combined Food Assistance/Cash Assistance program which the fraud unit is investigating for fraud- the fraud unit collaborates with the Child Care Provider Integrity Education Support unit to pursue fraud and overpayments.. Whereas if either unintentional or intentional program violations are identified for child care providers, the case is referred to the Child Care Provider Integrity Education Support Unit. The Central Collections Unit monitors the recovery of the claim 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: Administrative Disqualification hearings are only for Kansas Department for Children and Families child care subsidy recipients. They cannot be for Kansas Department for Children and Families enrolled child care providers as the provider accepts subsidy from clients and not directly receiving subsidy from Kansas Department for Children and Families. Once Child Care Provider Integrity Education Support Unit establishes program violations for intentional improper payments, an Administrative Disqualification Hearing request is submitted to the Kansas Department for Children and Families Office of Administrative Hearings, using the ES-3112, Kansas Department for Children and Families form. There is no dollar threshold to take the recipient to Administrative Disqualification Hearing. It is up to agency discretion with regards to the amount and supporting evidence obtained whether to submit the request for Administrative Disqualification Hearing. For Administrative Disqualification Hearings, there is no limitation of how far back you can go to request fraud disqualification. If a referral for Administrative Disqualification is being sent, the improper payment claim is set to ￿pending’ status until a finding is returned from the administrative judge. Once a request for Administrative Disqualification is submitted, the agency and recipient/household member is notified within 90days that an Administrative Disqualification Hearing has been scheduled. The hearing is often held via conference call or TEAMS virtual meeting. The recipient/household member has the option to waive their rights to an Administrative Disqualification Hearing. Persons who waive their rights are to be disqualified and a fraud judgement is set. After the hearing is held, the administrative judge will send the judgement finding to the agency and recipient/household member. If the judgement is found to be disqualification, the claim will be changed from ￿pending’ to ￿fraud’ and the child care case will show a fraud judgement penalty has been imposed and recovery will begin. Child Care recipients have the option to appeal their disqualification and their improper payment claims (intentional or unintentional.) The child care recipient may provide the request by submitting it in writing. Once a recipient has requested an appeal, the agency must take immediate action. Within 15 days after the appellant has filed a request for a fair hearing, the agency shall furnish the appellant, or appellant’s representative, and the Office of Administrative Hearings with a copy of the summary. Once the request for an appeal has been submitted to the Kansas Department for Children and Families Office of Administrative Hearings, the agency and recipient/household member is notified within 90days that an Appeal hearing has been scheduled. The hearing is often held via conference call or TEAMS virtual meeting. After the hearing is held, the administrative judge will send the judgement finding to the agency and recipient/household member. If the judgement is found to uphold the initial judgement/agency action, a findings letter will be sent and there will be no changes to the claim or disqualification. However, if the hearing decision is favorable to the recipient, the agency shall promptly make corrective payments or remove the fraud finding. If the recipient disagrees with the administrative judge finding, they also have the option to request for a State Appeals Committee review, where the committee reviews the decision of the hearing officer. This request to the State Appeals Committee must be made within 18 days of the date of the administrative hearing decision. Per KEESM policies 11221.2, 11250, 1600, 1613, 1614, 1617 After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections ￿ The Central Collections Unit monitors the recovery of the claim. The agency has had 0 Administrative Disqualification Hearings for Child Care Recipients in 2024. CCPIES is currently working with the DCF Fraud unit on a combined program fraud case and is currently going through the Criminal court process. 1 1Combined CC Recipient and CC Provider. 1.1 Anticipated CC Improper Payment for Intentional Violation 1.2 Child Care Recipient: $83,228.82 1.3 Child Care Provider: $83,228.81 1.4 These amounts are for Child Care program violations only. If the recipient is found to have committed fraud, the recipient is required to return the improper payment to DCF and the Child Care Recipient adult(s) will be flagged as having committed Child Care Fraud. Per our state policy KEESM 11221.2, the children will continue to be eligible for Child Care subsidy. With regards to DCF Child Care Providers, since their EBT account is set up to accept funds from DCF Child Care Recipients, there is no way for Child Care Providers to make payments on claims using their EBT account, as their EBT account is connected to their personal or business bank account. Child Care Providers must either pay by personal check, money order or debit/credit card for EBT Repayments. If a Child Care provider is found to have committed fraud, the Child Care Enrollment would be notified to determine whether the DCF Child Care provider will continue their DCF CC Provider agreement. DCF Child Care enrollment would discuss with their leadership whether the DCF agreement would be terminated or remain open. If the DCF Child Care provider remains open, continued education and Corrective Action is given. 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: Administrative Disqualification hearings are only for Kansas Department for Children and Families child care subsidy recipients. They cannot be for Kansas Department for Children and Families enrolled child care providers as the provider accepts subsidy from clients and not directly receiving subsidy from Kansas Department for Children and Families. Currently, there is no sanction to disqualify a Kansas Department for Children and Families Child Care Enrolled provider. Child Care providers, however- have the option to appeal their improper payment claims (intentional or unintentional.) The child care provider may provide the request by submitting it in writing. Once a recipient has requested an appeal, the agency must take immediate action. Within 15 days after the appellant has filed a request for a fair hearing, the agency shall furnish the appellant, or appellant’s representative, and the Office of Administrative Hearings with a copy of the summary. Once the request for an appeal has been submitted to the Kansas Department for Children and Families Office of Administrative Hearings, the agency and child care provider is notified within 90days that an Appeal hearing has been scheduled. The hearing is often held via conference call or TEAMS virtual meeting. After the hearing is held, the administrative judge will send the judgement finding to the agency and child care provider. If the judgement is found to uphold the initial judgement/agency action, a findings letter will be sent and there will be no changes to the claim. However, if the hearing decision is favorable to the child care provider, the agency shall promptly make correct the claim. If the child care provider disagrees with the administrative judge finding, they also have the option to request for a State Appeals Committee review, where the committee reviews the decision of the hearing officer. This request to the State Appeals Committee must be made within 18 days of the date of the administrative hearing decision. The agency has had 0 Child Care Provider Appeals in 2024. INTENTIONAL PROGRAM VIOLATION DATA From January 2024 to July 2024: 1 74 Fraud referrals received / 6 Fraud referrals have been reviewed. 1.1 3 closed with no program violation and no improper payment. 1.2 1 CC Provider, $3900 improper payment. Potential Fraud, Judgement not obtained as no Civil action available. Education and Corrective Action given. 1.3 1 Combined CC Recipient and CC Provider. CCPIES is currently working with the DCF Fraud unit on a combined program fraud case and is currently going through the Criminal court process. 1.3.1 Anticipated CC Improper Payment for Intentional Violation 1.3.2 Child Care Recipient: $83,228.82 1.3.3 Child Care Provider: $83,228.81 1.3.4 These amounts are for Child Care program violations only. 2 23 High Payment Potential Fraud Alerts reviewed and completed. 2.1 13 closed with no fraud discovered, no improper payment. 2.2 10 Improper Payments, totaling $74,951.36- No fraud discovered, education provided. 3 13 Unauthorized Payments Potential Fraud reviewed and completed. 3.1 13 Child Care Provider Improper payments - total $36,022.48 3.2 13 Potential Fraud, Judgement not obtained as no Civil action available. ALL 13 Child Care Providers had their DCF Provider Agreement terminated If the Child Care Provider is found to have committed Fraud through the Criminal Courts, CCPIES will notify Child Care Enrollment. Child Care Enrollment will discuss with their leadership to determine whether the Child Care Providers DCF agreement will be terminated. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections. The Central Collections Unit monitors the recovery of the claim. iii. [x] Prosecute criminally. Describe the activities and the results of these activities based on the most recent analysis: If a potential intentional program violation is identified for a child care eligibility recipient or provider, the case is referred to the fraud and Child Care Provider Integrity Education Support unit for further assessment. If the child care recipient or provider has an Food Assistance or Cash Assistance program themselves, or if they are associated with a child care recipient with a combined Food Assistance/Cash Assistance program which the fraud unit is investigating for fraud- the fraud unit collaborates with the Child Care Provider Integrity Education Support unit to pursue fraud and overpayments.. If the fraud unit wishes to prosecute criminally, the fraud unit will take the combined case and proceed with requesting the case be prosecuted criminally. It is with the discretion of the fraud unit, Chief of Investigations and legal whether the case should be prosecuted criminally. If it is decided to prosecute criminally, the case must be presented to the county District Attorneys office to review. It is then at the discretion of the county District Attorneys office whether they want to prosecute criminally. If the county District Attorneys office agrees to prosecute criminally, the state is responsible for typing up the affidavit for the county district attorney and obtaining additional evidence and witness statements to assist the district attorney with their case. Criminal hearings take place at the county courthouse, where the case would be located. However, if it is a child care program only case, whether recipient or child care provider- the Child Care Provider Integrity Education, Support unit pursues fraud and overpayments. If the Child Care Provider Integrity Education Support unit believes the case should be prosecuted criminally, they would need to request the fraud unit, Chief of Investigations and legal to review the case. It would be at the discretion of the fraud unit, Chief of Investigations and legal whether the case could be prosecuted criminally, as the fraud unit would have to assist with taking the case to criminal court. After an improper payment claim is created, it is sent to Kansas Department for Children and Families Central Collections ￿ The Central Collections Unit monitors the recovery of the claim. CCPIES is currently working with the DCF Fraud unit on a combined program fraud case and is currently going through the Criminal court process. 1. 1 Combined CC Recipient and CC Provider. 1.1 Anticipated CC Improper Payment for Intentional Violation 1.2 Child Care Recipient: $83,228.82 1.3 Child Care Provider: $83,228.81 1.4 These amounts are for Child Care program violations only. If the Child Care Recipient is found to have committed Fraud through the Criminal Courts, the Child Care recipient will be disqualified for the Child Care Program, however the children will remain eligible for the Child Care subsidy. If the Child Care Provider is found to have committed Fraud through the Criminal Courts, CCPIES will notify Child Care Enrollment. Child Care Enrollment will discuss with their leadership to determine whether the Child Care Providers DCF agreement will be terminated. 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: