10.1 Effective Internal Controls

Lead Agencies must ensure the integrity of the use of CCDF funds through effective fiscal management and must ensure that financial practices are in place. Lead Agencies must have effective fiscal management practices in place for all CCDF expenditures. 10.1.1 Organizational structure to support integrity and internal controls Describe how the Lead Agency’s organizational structure ensures the oversight and implementation of effective internal controls that promote and support program integrity and accountability. Describe: Assignment of Authority and Responsibilities Related to Program Integrity: The Director of Program Administration holds the primary responsibility for overseeing program integrity. This role includes daily supervision of benefits issuance and policy compliance. Delegation of Duties: Duties are clearly delegated within the agency. The CCDF Co-administrator collaborates with the Director to oversee program operations, while the Office Manager handles the preparation and preliminary verification of benefits reports. Coordination of Activities: Coordination is achieved through regular monthly meetings involving the CCDF Co-administrator, the Director of Program Administration, and the fiscal team. These meetings ensure that all departments are aligned and informed about current caseloads, policy updates, and financial trends. Communication between Fiscal and Program Staff: Effective communication is maintained through the structured dissemination of verified reports. After the Director of Program Administration approves the benefits reports, they are uploaded to SharePoint and subsequently forwarded to the fiscal department, ensuring that both fiscal and program staff are consistently informed and engaged in all financial and programmatic decisions. Segregation of Duties: The process of benefit issuance is segregated among multiple staff members to prevent fraud and ensure accuracy. The Office Manager prepares the initial reports, which are then verified and signed off by the Director of Program Administration before being forwarded to the fiscal team for the final check and payment disbursement. Establishment of Checks and Balances to Identify Potential Fraud Risks: The agency employs a layered review process where each step of the benefit issuance and financial reporting involves multiple checks. This not only enhances accuracy but also helps in identifying discrepancies and potential fraud risks at early stages. Other Activities that Support Program Integrity: The agency also engages in periodic training sessions for all staff to reinforce the importance of program integrity, updates on policy changes, and techniques for fraud detection. This continuous education helps maintain a high standard of vigilance and compliance throughout the organization. Include the following elements in your description: 1. Assignment of authority and responsibilities related to program integrity. 2. Delegation of duties. 3. Coordination of activities. 4. Communication between fiscal and program staff. 5. Segregation of duties. 6. Establishment of checks and balances to identify potential fraud risks. 7. Other activities that support program integrity. 10.1.2 Fiscal management practices Describe how the Lead Agency ensures effective fiscal management practices for all CCDF expenditures, including: a. Fiscal oversight of CCDF funds, including grants and contracts. Describe: The Lead Agency maintains policies and procedures on subrecipient monitoring for all grant contracts. Grant contract monitoring activities include; a risk assessment of the subrecipient, completion of a Program Checklist, completion of a Contract Closure Assessment and periodic documentation review of the contract. Lead Agency program administrators review requests for reimbursement and supporting documentation to ensure that contracted vendors are expending funding in accordance with the requirements. b. Tracking systems that ensure reasonable and allowable costs and allow for tracing of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provision of this part. Describe: The Lead Agency employs a robust tracking system designed to ensure that all costs are reasonable, allowable, and compliant with the stipulated provisions. Our approach includes several key strategies to trace and validate the use of funds effectively: 1. Integrated Eligibility System: We utilize an advanced integrated eligibility system where all expenditures are coded accurately. This system facilitates the tracking of funds to the exact level of expenditure, ensuring compliance and transparency in fund utilization. 2. Regular Validation Meetings: Our financial officers conduct monthly meetings to review and validate expenditures. These sessions are crucial for maintaining fiscal discipline and ensuring that all costs align with program guidelines and budgetary constraints. 3. Dashboards for Tracking Payments: We have implemented a specialized dashboards that monitor both benefit and contract payments. This tool provides real-time data on financial activities, helping us to quickly identify and investigate any unusual spikes or declines in payments. 4. Monthly Validation by Director of Program Administration: The Director of Program Administration plays a pivotal role in our fiscal checks and balances by validating contract payments on a monthly basis. After this validation, the fiscal team conducts a thorough review before the final approval and disbursement of payments. 5. Fiscal Administration Staff Oversight: Our fiscal administration staff diligently review all requests for information to verify that expenditures are both reasonable and allowable under the stipulated guidelines. These mechanisms collectively ensure a high level of accuracy and adherence to fiscal rules, thereby affirming that our funds are used appropriately and in accordance with the provisions of this part. c. Processes and procedures to prepare and submit required state and federal fiscal reporting. Describe: To prepare and submit the required state and federal fiscal reports, the processes involve a thorough and coordinated effort by the fiscal department. This department carefully reviews and compiles expenditure data from the fiscal management system, ensuring accuracy through cross-referencing with technical reports and system case counts. After assembling the reports, an additional layer of security and verification is provided by the Director of Program Administration, who reviews and signs off on them before submission. This systematic approach ensures compliance with regulatory standards and maintains the integrity of financial reporting. d. Other. Describe: NA 10.1.3 Effectiveness of fiscal management practices Describe how the Lead Agency knows there are effective fiscal management practices in place for all CCDF expenditures, including: a. How the Lead Agency defines effective fiscal management practices. Describe: Effective fiscal management practices involve regular monitoring, transparent accounting procedures, and adherence to federal and state guidelines to ensure proper allocation and use of CCDF funds. This includes detailed monthly meetings, rigorous expenditure tracking, and multiple controls for payouts, supported by advanced fiscal projection tools. b. How the Lead Agency measures and tracks results of their fiscal management practices. Describe: The Lead Agency measures the effectiveness of fiscal management through performance indicators such as expenditure rates, compliance with budget allocations, and audit results. Tools like expenditure tracking systems and monthly financial reporting are utilized to monitor these indicators closely. c. How the results inform implementation. Describe: The results from tracking and measuring fiscal management practices are used to refine budget planning, improve allocation strategies, and enhance oversight mechanisms. This continuous feedback loop ensures that fiscal practices directly support program objectives and compliance requirements. d. Other. Describe: Additionally, the Lead Agency employs technology-based solutions to automate financial reporting and uses predictive analytics to forecast future financial scenarios, improving decision-making and fiscal responsiveness. 10.1.4 Identifying risk Describe the processes the Lead Agency uses to identify risk in the CCDF program including: a. Each process used by the Lead Agency to identify risk (including entities responsible for implementing each process). Describe: The Lead Agency sends all policy and procedure changes to other Lead Agency staff for review before implementation. This allows for questions and comments to be answered and reviewed before policy is finalized. Quality Control Unit staff notify the CCAP administrator and the policy and system support (PaSS) Training team of all errors or potential fraud found through case reviews, this includes but is not limited to improper payments. This allows for the training team to build and implement trainings based on actual case errors. The Child Care Assistance policy team reviews all intentional program violations (IPVs) for SNAP and TANF and determines if an IPV needs to be pursued for CCAP. Eligibility workers also go through a strict training an integrity protocol, after training on how to determine eligibility, cases worked by new workers in their first six months are reviewed by senior eligibility workers before approval or denial is determined. The Lead Agency closely monitors application rates, denials, approvals, and application churn to identify any barriers to the program from the application process. The Lead Agency also has access to a data dashboard which shows case payments and can assist in identifying ongoing case issues. The fiscal team for the Lead Agency meets monthly to monitor expenditures and review any unusual trends. b. The frequency of each risk assessment. Describe: Risk assessments are conducted with varying frequencies to ensure comprehensive oversight. Benefit issuance is cross- referenced daily to maintain accuracy. Overall expenditures are reviewed monthly in conjunction with fiscal and the CCAP team to track financial health. Additionally, the allocation of CCDF funds between early childhood programs and CCAP is thoroughly evaluated on a quarterly basis. These assessments include additional checks as needed if any discrepancies or inconsistencies are noted during regular reviews. This tiered approach ensures continuous monitoring and timely resolution of potential issues. c. How the Lead Agency uses risk assessment results to inform program improvement. Describe: The Lead Agency utilizes risk assessment results to inform program improvements by integrating financial projection tools that calculate changes in expenditures based on policy changes. By comparing actual outcomes with projected results, discrepancies are identified and addressed. Additionally, application counts and trends are continuously monitored via dashboards, enabling the agency to refine processes and address discrepancies in real-time. This systematic review helps in enhancing program accuracy and efficiency. d. How the Lead Agency knows that the risk assessment processes utilized are effective. Describe: The effectiveness of the risk assessment processes is confirmed through the alignment of financial projections with actual expenditures. When projections diverge from actual results, the agency conducts detailed analyses using dashboards that track applications, benefit issuance, and case progress. This capability to detect and investigate trends, including potential fraud, through correlation studies of overpayments and regional comparisons, demonstrates the robustness and reliability of the risk assessment processes. e. Other. Describe: The fiscal team creates comprehensive reports that are accessible to program administrators, CCDF administrators, and Directors of Early Childhood and Economic Assistance. These reports and the associated dashboards ensure transparency and facilitate ongoing monitoring, contributing to the overall integrity and improvement of the CCDF program. 10.1.5 Processes to train about CCDF requirements and program integrity Describe the processes the Lead Agency uses to train staff of the Lead Agency and other agencies engaged in the administration of CCDF, and child care providers about program requirements and integrity. a. Describe how the Lead Agency ensures that all staff who administer the CCDF program (including through MOUs, grants, and contracts) are informed and trained regarding program requirements and integrity. i. Describe the training provided to staff members around CCDF program requirements and program integrity: Policy changes are sent to the Human Service Zone’s in the month prior to the changes becoming effective to give workers time to review and ask questions before the policy is implemented. Training guides are created and distributed statewide as areas of needed training are identified or when policies or procedures are changed. The Lead Agency utilizes the policy and system support (PaSS) unit to deliver periodic program and policy training. Additionally, the Lead Agency utilizes E-Learning courses that covers policies and case processing that are available statewide. New workers have all cases reviewed by a supervisor for six months during a probationary period to ensure understanding and correct procedures are consistently followed when determining eligibility. ii. Describe how staff training is evaluated for effectiveness: The policy and system support (PaSS) unit monitors staff member trainings and takes feedback directly from participants. iii. Describe how the Lead Agency uses program integrity data (e.g., error rate results, risk assessment data) to inform ongoing staff training needs: The Lead Agency utilizes program integrity data to systematically inform ongoing staff training, ensuring these initiatives are thoroughly targeted to address operational needs. Our comprehensive approach integrates contributions from Quality Control (QC), Policy, Training teams, and Human Service Zone supervisors and directors, bolstered by proactive communications from the Policy and System Support team. Here’s a detailed breakdown of how each component plays a role in enhancing training and compliance: 1. Monthly Case Reviews by Quality Control Unit: Our QC unit meticulously reviews Child Care Assistance Program (CCAP) cases each month to identify common errors and trends, pinpointing specific training needs. 2. Live Group Training Sessions: Based on the errors identified, targeted live group training sessions are developed to directly address and rectify these issues, ensuring relevance and effectiveness in tackling daily operational challenges. 3. Just-In-Time Training for Critical Issues: For widespread or significant errors, "just-in-time" training sessions are swiftly organized. These sessions utilize anonymized case studies to ensure confidentiality while providing practical, real- world problem-solving experiences. 4. Collaborative Oversight and Review: All training content and methods undergo rigorous review by Quality Assurance, with oversight from the Quality Assurance Director, maintaining high standards of accuracy and applicability. 5. Policy and System Insights: The CCAP Policy Administrator collaborates closely with the training team to provide essential insights into policy and system operations, enhancing the depth and breadth of training content. 6. Strategic Meetings with Leadership: Significant errors and new policies are discussed in meetings with Human Service Zone supervisors and directors, ensuring broad-based communication and uniform compliance across all levels of the organization. 7. Monthly Newsletter by Policy and System Support: Our Policy and System Support team issues a monthly newsletter that highlights system procedures and addresses any recent system errors in processing. This newsletter serves as a crucial tool for keeping all staff updated on procedural changes and system functionalities. 8. Distribution of FYI Documentation: Additionally, FYI documentation is regularly distributed, which includes training updates on policy and case processing. This documentation is essential for keeping the staff informed and well-versed in the latest operational practices and procedural adjustments. These multifaceted strategies ensure that our training programs are not only responsive and specific but also comprehensive, enhancing both individual performance and overall program integrity across the agency. b. Describe how the Lead Agency ensures all providers for children receiving CCDF funds are informed and trained regarding CCDF program requirements and program integrity: i. Describe the training for providers around CCDF program requirements and program integrity: The Lead Agency requires that all providers receiving Child Care Assistance complete a CCAP Provider agreement before any funds can be issued. In addition, the Lead Agency has a "CCAP Provider Guidebook￿ and a ￿CCAP Billing Training￿ module available to all providers on the Lead Agency’s website. ii. Describe how provider training is evaluated for effectiveness: The training is evaluated for effectiveness based on outcomes. A successful training is evidenced through provider feedback and a reduction in errors and questions about processes from our providers. iii. Describe how the Lead Agency uses program integrity data (e.g., error rate results, risk assessment data) to inform ongoing provider training needs: The Lead Agency uses red flag reports to inform on-going provider training needs. A monthly report is used to track providers who may have submitted for a payment in error through the provider self-service portal. Providers are contacted when they show up on this report and informed of correct billing procedures. A separate report is also used to track CCAP payments for providers over their licensed capacity. These are reviewed monthly and the Early Childhood licensing team is contacted as needed for additional training support for these providers. 10.1.6 Evaluate internal control activities Describe how the Lead Agency uses the following to regularly evaluate the effectiveness of Lead Agency internal control activities for all CCDF expenditures. a. Error rate review triennial report results (if applicable). Describe who this information is shared with and how the Lead Agency uses the information to evaluate the effectiveness of its internal controls: The Lead Agency reviews reports with the fiscal team and the quality control team to identify concerns and areas for improvement then works in tandem with the Policy and System Support (PaSS) unit to create improvement plans centered on using data and reporting to identify better practices in procedure and workflow. b. Audit results. Describe who this information is shared with and how the Lead Agency uses the information to evaluate the effectiveness of its internal controls: Audit results are shared with all involved parties from the Lead Agency, if results are positive, programs and procedures continue as normal. If the Lead Agency receives an audit finding a meeting is coordinated with the relevant parties and a project is started to correct the procedure or policy that needs attention. A project manager is appointed who coordinates progress and provides updates. c. Other. Describe who this information is shared with and how the Lead Agency uses the information to evaluate the effectiveness of its internal controls: NA 10.1.7 Identified weaknesses in internal controls Has the Lead Agency or other entity identified any weaknesses in its internal controls? a. [x] No. If no, describe when and how it was most recently determined that there were no weaknesses in the Lead Agency’s internal controls. The Lead Agency has worked to improve internal controls via data management and dashboards along with cross team collaboration. At this time there are no concerns with internal controls. b. [ ] Yes. If yes, what were the indicators? How did you use the information to strengthen your internal controls?