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: To identify parents that may be over income or no longer participating in any work activity, TWC matches child care program data with data from the state's UI program and state wage records. The data match identifies parents receiving child care who have filed for UI. Boards receive reports which prompt case workers to seek additional information about a parent’s status. If the parent is determined to no longer be participating in any work, education, or training activity at any level, they are placed on a three- month activity interruption/job search period. If the parent is determined to be participating in an appropriate work, training, or education activity, no action is taken by the Board. The UI data match also looks at quarterly wage records submitted by employers, and flags parents that may be over 85 percent of SMI. Boards receive reports that prompt case workers to seek additional information about a parent’s employment income. If the income is from an irregular fluctuation (such as extra hours worked during a seasonal period), no action is taken. If the Board determines that the parent exceeds the income eligibility threshold, it will take action to end CCS by providing appropriate notice to the parent and provider. If a Board identifies potential fraud while reviewing a parent’s employment status, the Board initiates fraud fact-finding in accordance with FDCM Letter 01-24 and subsequent issuances. If fraud is substantiated, the parent is subject to recoupment of subsidies provided when they were not eligible due to the intentional program violation. Results: Reports are sent to each of the 28 Board areas who then research each case and reach out to the client to inquire about the report and work to resolve the issue. These activities have increased accountability and integrity by ensuring CCDF is only expended on eligible families. Child Care and UI Early Warning Report Purpose and Discussion: The Child Care and UI Early Warning Report is a tool to assist Boards in the oversight of CCDF funds. SRM sends this report to Boards twice a month, normally on the first and third Wednesdays of each month. The report seeks to identify and assess customers who may have experienced a non- temporary change in work activities because they filed a UI claim advising TWC that they are not working. The objective is to prevent child care overpayments by identifying customers before their three-month job search period expires. Customers identified in the report are not necessarily ineligible for services. Potential child care eligibility issues are resolved by verifying customers' employment or training status using current local procedures. This also provides an opportunity for child care contractors to verify that customers have reported their UI benefits income for child care eligibility. Results: Boards connect unemployed parents with other workforce services. These activities help parents re-engage in work or education so they can continue their eligibility for subsidized child care beyond the three months of continued care. Identifying and assisting parents who become unemployed helps to ensure that limited funds are used to serve only eligible families and to promote their self-sufficiency. Child Care Income Report Purpose and Discussion: The Child Care Income Report is a tool to assist Boards in the oversight of CCDF funds. SRM sends this report to Boards quarterly. The report seeks to identify and assess customers who are potentially ineligible due to parental/custodial changes or underreporting of income. A customer identified in the report is not necessarily ineligible for services. The issue of eligibility can be established only after a thorough review of the customer's case file and may involve contacting the customer for further information. Results: Boards review the report and contact clients to review their reported income to identify if family income exceeds 85 percent SMI. If family income has increased over 85 percent of SMI while allowing for temporary and irregular fluctuations, the client’s child care is ended. These activities ensure that CCS are only paid for eligible children. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: TWC matches child care program data with data from the state's UI program and state wage records. Program violations identified may be intentional or unintentional. Results: Reports are sent to each of the 28 Board areas who then research each case and reach out to the client to inquire about the report and work to resolve the issue. These activities have increased accountability and integrity by ensuring CCDF is only expended on eligible families. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice:: TWC matches Social Security Numbers (SSN) voluntarily provided for children and families against the Social Security Administration’s records to identify mismatches, which are often due to data entry errors. Results: TWC shares the SSN Mismatch Report with Boards for follow up. Boards then communicate with the parent if needed, to correct and data errors. Child Care Cases/Clients with the SSN Report The child care cases with the Same SSN Report lists parent/guardian duplicated SSNs that have a payment in more than one workforce area in the same service month. The child care clients with the Same SSN Report lists children's duplicated SSNs that have a payment in more than one workforce area in the same service month. Note: An SSN is not required but may be voluntarily provided by the parent. Results: Boards review the reports and contact clients to determine if the SSN provided is correct. Boards will take action to resolve and correct data entry errors and may initiate fact-finding for potential fraud if appropriate. These activities help ensure CCS are only paid for eligible children and increases integrity of program data. 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: TWC provides Boards Child Care Fraud Detection Report Tools to help Boards detect potential fraud. Boards use the new TX3C Integrity Central application to proactively identify key indicators that suggest potential program violations of TWC’s attendance tracking policies. Although TWC policy requires Boards to reimburse providers based on enrollment authorization (except for relative providers), anomalies in attendance tracking can reveal both intentional and unintentional program violations related to parents’ requirements to meet TWC attendance standards. Investigation of Integrity Central indicators may result in fact-finding by the Board. If fraud is substantiated, the provider or parent responsible is subject to recoupment of funds authorized based on fraudulent information. Results: These reports have helped Texas identify and investigate potential fraud and fraud detection activities have also led to the substantiation of fraud. From September 1, 2022, to the end of State Fiscal Year 2023 (August 31, 2023), Texas’ 28 Boards opened 704 cases for fact-finding and closed 472. Of the 472 cases closed, $1,101,122 in overpayments were established. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Boards use the new TX3C Integrity Central application to proactively identify key indicators that suggest potential program violations of TWC’s attendance tracking policies. Although TWC policy requires Boards to reimburse providers based on enrollment authorization (except for relative providers), anomalies in attendance tracking can reveal both intentional and unintentional program violations related to parents’ requirements to meet TWC attendance standards. Investigation of Integrity Central indicators may result in fact-finding by the Board. If fraud is substantiated, the provider or parent responsible is subject to recoupment of funds authorized based on fraudulent information. Results: These reports have helped Texas identify and investigate potential unintentional program violations and identify areas where parent or provider communication can be improved. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: Board staff will review the following reports from TX3C to identify and correct internal errors: Children with Multiple Providers This report lists the children who have multiple schedules with different providers as of a specified effective date. WPI Override Report There are certain events that the system will either warn about, prevent entirely, or ignore, depending on the WPI (Warn, Prevent, Ignore) settings. If an event is set to Warn and Log, the operator can override the warning, but that override will be logged in the system. This report displays overrides that occurred during the specified period. Hours Claimed Discrepancy This report lists clients who claimed too many or too few hours over or under the authorized number during the specified period. If the discrepancy is greater than the limit specified in the region's Hours Claimed Discrepancy setting, it will be shown on this report. Optionally, the report can be limited to specific workers who approved the payments. Manual Payment Details This report provides details for payments that were paid between the specified Start and End Dates. The following is displayed in red: Overridden payments, split week from a previous payment, payment adjustments, additional payments, and payment capped at RMC. Payment Details This report returns payment detail information for paid payments that were made during the date range specified. The following are displayed in red: Overridden payments, split week from a previous payment, payment adjustments, and additional payments. Payment Override This report returns a list of overridden payments where the date of the override falls between the start and end dates specified. It shows both the operator who originated the payment and the one who overrode it. Payment Summary This report returns summary information for payments that were paid during the date range specified. The following are displayed in red: overridden payments, split week from a previous payment, payment adjustments, and additional payments. 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: Boards ensure that attendance is reviewed with each billing cycle. Boards also ensure that staff members conduct quality assurance reviews of enrollment documents and billing records. Records are also reviewed by Boards’ independent audit providers and SRM staff. Results: If local or independent monitoring activities discover any issues, Boards investigate and resolve the issues by reaching out to the client or completing additional reviews based on identified issues. This may involve a fraud investigation. Additionally, when SRM staff complete monitoring activities, findings are relayed to the Board for further training and any identified improper payments are recovered by TWC. These activities help ensure that CCS are only paid for eligible children, payments are accurate, and help; to increase integrity of program data. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Boards ensure that attendance is reviewed with each billing cycle. Boards also ensure that staff members conduct quality assurance reviews of enrollment documents and billing records. Records are also reviewed by Boards’ independent audit providers and SRM staff. Results: If local or independent monitoring activities discover any issues, Boards investigate and resolve the issues by reaching out to the client or completing additional reviews based on identified issues. This may involve a fraud investigation. Additionally, when SRM staff complete monitoring activities, findings are relayed to the Board for further training and any identified improper payments are recovered by TWC. These activities help ensure CCS are only paid for eligible children, payments are accurate, and help to increase integrity of program data. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: Boards ensure that attendance is reviewed with each billing cycle. Boards also ensure that staff members conduct quality assurance reviews of enrollment documents and billing records. Records are also reviewed by Boards’ independent audit providers and SRM staff. Results: If local or independent monitoring activities discover any issues, Boards investigate and resolve the issues by reaching out to the client or completing additional reviews based on identified issues. This may involve a fraud investigation. Additionally, when SRM staff complete monitoring activities, findings are relayed to the Board for further training and any identified improper payments are recovered by TWC. These activities help ensure CCS are only paid for eligible children, payments are accurate, and help to increase integrity of program data. 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: Boards ensure that Board or contractor staff conducts quality assurance reviews before eligibility determination, in response to risks identified through reports or other means and as random spot checks. Results: If issues are discovered, Board’s review with staff and resolve issues through internal processes or by contacting the client for additional information before eligibility can be determined. These activities help ensure CCS are only paid for eligible children and that payments are accurate. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Boards ensure that Board or contractor staff conducts quality assurance reviews before eligibility determination, in response to risks identified through reports or other means and as random spot checks. Results: If issues are discovered, Board’s review with staff and resolve issues through internal processes or by contacting the client for additional information before eligibility can be determined. These activities help ensure CCS are only paid for eligible children and that payments are accurate. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: Boards ensure that Board or contractor staff conducts quality assurance reviews before eligibility determination, in response to risks identified through reports or other means and as random spot checks. Results: If issues are discovered, Board’s review with staff and resolve issues through internal processes or by contacting the client for additional information before eligibility can be determined. These activities help ensure CCS are only paid for eligible children and that payments are accurate. e. [x] Audit provider records. i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: SRM conducts ACF Improper Payment testing every three years by looking at provider attendance records, provider billing, and ensuring that the provider is licensed and not on a corrective action plan. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: SRM conducts ACF Improper Payment testing every three years by looking at provider attendance records, provider billing, and ensuring that the provider is licensed and not on a corrective action plan. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: SRM conducts ACF Improper Payment testing every three years by looking at provider attendance records, provider billing, and ensuring that the provider is licensed and not on a corrective action plan. 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: TWC provides training and TA on program policies. Boards ensure that Board and contractor staff receive training locally and/or participate in TWC training and TA. TWC and the Boards also participate in a statewide Quality Assurance Network that meets quarterly to receive training, share best practices, and learn about quality assurance issues. Results: Training and TA activities help to increase accountability at the local level which in turn increases the integrity of the child care program by preventing staff errors, ensuring that funds are only expended upon eligible children, and that payment amounts are accurate. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: TWC provides training and TA on program policies. Additionally, Boards ensure that Board and contractor staff receive training locally and/or participate in TWC training and TA. TWC and the Boards also participate in a statewide Quality Assurance Network that meets quarterly to receive training, share best practices, and learn about quality assurance issues. Results: Training and TA activities help to increase accountability at the local level which in turn increases the integrity of the child care program by preventing staff errors, ensuring that funds are only expended upon eligible children, and that payment amounts are accurate. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: TWC provides training and TA on program policies. Additionally, Boards ensure that Board and contractor staff receive training locally and/or participate in TWC training and technical assistance. TWC and the Boards also participate in a statewide Quality Assurance Network that meets quarterly to receive training, share best practices, and learn about quality assurance issues. Results: Training and TA activities help to increase accountability at the local level which in turn increases the integrity of the child care program by preventing staff errors, ensuring that funds are only expended upon eligible children and that payment amounts are accurate. 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): TWC ensures investigation of fraud allegations is conducted. For recovery of improper payments from parents or providers are managed by the Boards. After a debt is final with no appeals or appeals have exhausted, the Board notifies TWC to place a warrant hold on debtor’s account with the State of Texas Comptroller. 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: If a repayment plan is in place, and a payment is missed with a current amount due of $100 or more, Boards wait 30 days and send final debt to TWC Collections for a warrant hold on the debtor’s account with the State of Texas Comptroller. 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: TWC's Office of Investigations coordinates with local law enforcement agencies and refers substantiated cases of fraud for prosecution. Results: From September 1, 2022, to the end of SFY23 (August 31, 2023), Texas’ 28 Boards opened 704 cases for fact-finding and closed 472. Of the 472 cases closed, $1,101,122 in overpayments were established. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: TWC and Board staff use the Program Integrity Reporting and Tracking System (PIRTS) to manage repayment plans due to fraud. Results: These activities help track fraud investigations at the local level and recover any improper payments which increases the accountability and integrity in the child care program. From September 1, 2022, to the end of State Fiscal Year 2023 (August 31, 2023), Texas’ 28 Boards opened 704 cases for fact-finding and closed 472. Of the 472 cases closed, $1,101,122 in overpayments were established. iv. [ ] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: v. [ ] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: vi. [ ] Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: vii. [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: TWC's Office of Investigations investigates and prosecutes potential fraud and assists the Boards with fact-finding efforts. Specific guidance on reporting and fact-finding fraud is addressed in WD Letter 21-16, Change 2, issued October 10, 2019, entitled Requirements for Reporting and Fact- Finding for Suspected Fraud, Waste, Theft, Program Abuse Cases, and Recovery of Improper Payments-Update. TWC's Office of Investigations has developed a Fact- Finder's Desk Aid to provide Boards with a framework for determining fraud. From September 1, 2022, to the end of State Fiscal Year 2023 (August 31, 2023), Texas’ 28 Boards opened 704 cases for fact-finding and closed 472. Of the 472 cases closed, $1,101,122 in overpayments were established. 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. [ ] Require recovery after a minimum dollar amount of an improper payment and identify the minimum dollar amount. Describe the activities and the results of these activities based on the most recent analysis: ii. [ ] Coordinate with and refer to the other State/Territory agencies (e.g., State/Territory collection agency, law enforcement agency). Describe the activities and the results of these activities based on the most recent analysis: iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: TWC and Board staff use PIRTS to manage repayment plans due to administrative error. Results: As described in Section 8.1.6.b.iii, from September 1, 2022, to the end of SFY23 (August 31, 2023), Texas’ 28 Boards opened 704 cases for fact-finding and closed 472. Of the 472 cases closed, $1,101,122 in overpayments were established. iv. [x] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: TWC’s child care case management system allows Boards to correct some administrative errors and overpayments within the system and automatically adjusts future provider payments accordingly. v. [ ] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: vi. [ ] Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: vii. [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: As described in Section 8.1.6.c.vii, TWC's Office of Investigations assists Boards with fact-finding efforts and repayment collection for improper payments. 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. [ ] Require recovery after a minimum dollar amount of an improper payment and identify the minimum dollar amount. Describe the activities and the results of these activities based on the most recent analysis: ii. [ ] Coordinate with and refer to the other State/Territory agencies (e.g., State/Territory collection agency, law enforcement agency). Describe the activities and the results of these activities based on the most recent analysis: iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: TWC and Board staff use the PIRTS to manage repayment plans due to unintentional program violations. Results: As described in Section 8.1.6.b.iii, From September 1, 2022, to the end of SFY23 (August 31, 2023), Texas’ 28 Boards opened 704 cases for fact-finding and closed 472. Of the 472 cases closed, $1,101,122 in overpayments were established. iv. [x] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: TWC’s child care case management system allows boards to correct some errors related to unintentional program violations within the system and automatically adjusts future provider payments accordingly. v. [ ] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: vi. [ ]Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: vii. [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: TWC's Office of Investigations investigates and prosecutes potential fraud and assists the Boards with fact-finding efforts. Specific guidance on reporting and fact-finding fraud is addressed in WD Letter 21-16, titled Requirements for Reporting and Fact-Finding for Suspected Fraud, Waste, Theft, Program Abuse Cases, and Recovery of Improper Payments. TWC's Office of Investigations has developed a Fact-Finder's Desk Aid to provide Boards with a framework for determining fraud. From September 1, 2022, to the end of SFY23 (August 31, 2023), Texas’ 28 Boards opened 704 cases for fact-finding and closed 472. Of the 472 cases closed, $1,101,122 in overpayments were established. 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: CCS rule §809.113(b)(2) requires Boards to prohibit future eligibility for subsidized child care if a parent owes repayments due to a fraud determination (provided that the prohibition does not result in a Choices or SNAP E&T participant becoming ineligible for child care). A parent may request an appeal pursuant to TWC Chapter 823 Integrated Complaints, Hearings, and Appeals rules. Chapter 823 requires that parents request an appeal within 14 calendar days of the adverse action. Boards must provide an opportunity for informal resolution of a complaint or appeal. If no final informal resolution is reached, Boards must provide an opportunity for a hearing to resolve an appeal or complaint. If the adverse action is upheld, the parent may request an appeal to TWC Appeals. Results: These activities help ensure CCS are only expended on eligible children and increases program integrity by increasing recoupment of improper payments. 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: CCS rule §809.113(a)(5) lists actions a Board may take to address provider violations, including prohibiting future eligibility for subsidized child care if a provider is found to have committed fraud. A provider may request an appeal pursuant to TWC's Chapter 823, Integrated Complaints, Hearings, and Appeals rules. Chapter 823 requires that providers request an appeal within 14 calendar days of the adverse action. Boards must provide an opportunity for informal resolution of a complaint or appeal. If no final informal resolution is reached, Boards must provide an opportunity for a hearing to resolve an appeal or complaint. If the adverse action is upheld, the provider may request an appeal to TWC Appeals. Results: These activities help ensure that child care subsidies are only paid to eligible providers for allowable services and increases program integrity by increasing recoupment of improper payments. iii. [x] Prosecute criminally. Describe the activities and the results of these activities based on the most recent analysis: As described in Section 8.1.6.b.ii, TWC's Office of Investigations investigates potential fraud and refers substantiated cases for prosecution by law enforcement and during the timeframe of September 1, 2022, to the end of SFY23 (August 31, 2023) no cases were referred for prosecution. 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: