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July 1, 2026

186 Appendix VI Client Investigations Client investigations are conducted to determine if a parent received subsidy funds that they are not eligible to receive, or if the parent has violated any statute or administrative rule. Local agencies must complete an investigation prior to establishing any overpayment. It is recommended that local agencies complete client investigations within 30 calendar days once assigned.

To investigate, agency workers must: • Analyze documents • Conduct interviews • Review case files • Review policy

These reviews determine whether a parent is receiving the correct subsidy amounts. Agency workers must determine if the parent submitted false information or materials to the department or local agency to obtain, maintain, or maximize the subsidy funds. This is known as an Intentional Program Violation (IPV). If the parent submitted false information or materials to the department or local agency, an IPV must be established and coded as an IPV in CWW and the Benefit Recovery Investigation Tracking System (BRITS). All investigation materials must be uploaded to the BRITS Referral Document section unless a local agency supervisor chooses to only use the Electronic Case File (ECF) due to investigation confidentiality concerns. This decision must be documented in the BRITS referral comment section.

Local agencies must have an established process for completing client investigations. Local agencies are encouraged to use client program integrity desk aids from the Child Care Program Integrity Resource Library.

Errors and violations occur typically at application or renewal, when a parent does not report a change within 10 calendar days, or when a parent commits fraud. An individual does not need to receive payment or services for the local agency to pursue an IPV if the violation occurred prior to the parent receiving subsidy at initial application or renewal.

Client Error Types

Client Error Type Definition Parent Errors When a parent untimely or fails to report a change within 10 calendar days that would decrease their subsidy amount. This results in an overpayment. An investigation must occur prior to establishing an overpayment.