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: The Lead Agency shares match data from other programs through the Benefit Recovery Investigation Tracking Systems (BRITS). When a referral is created by any program, if the parent also receives child care subsidy, then a referral is created for child care investigation. The outcome in the referral and investigation may result in an intentional program violation. The Lead Agency follows continuous improvement practices and regularly evaluates fraud, waste, and abuse prevention and detection methods to inform best practices. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency shares match data from other programs through the Benefit Recovery Investigation Tracking Systems (BRITS). When a referral is created by any program, if the parent also receives child care subsidy, then a referral is created for child care investigation. The outcome in the referral and investigation may result in an unintentional program violation. The Lead Agency follows continuous improvement practices and regularly evaluates fraud, waste, and abuse prevention and detection methods to inform best practices. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice:: The Lead Agency shares match data from other programs through the Benefit Recovery Investigation Tracking Systems (BRITS). When a referral is created by any program, if the parent also receives child care subsidy, then a referral is created for child care investigation. The outcome in the referral and investigation may result in an agency error. The Lead Agency follows continuous improvement practices and regularly evaluates fraud, waste, and abuse prevention and detection methods to inform best practices. 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 Lead Agency develops red flag reports that collect and analyze data from clients and providers receiving CCDF funds. Each red flag is programmed with a threshold to measure results that may indicate further investigation is needed for a particular client or provider. Examples of client red flag reports are: Unusual Parent Schedule (parent schedule does not align with child care need); Current Weekly Authorized Hours Greater Than 50; Current Schedules for Approved Parent Activity; EBT Cards Replaced within 12 Months; Funds About to Expire; Inactive EBT Cards for More Than 30 Days with a Balance; Expungement; and Multiple Providers Including Child Care Need Schedule. Examples of provider red flag reports are: Unusual Payment Timing; Payment Grouping; Provider Over Capacity; Child Mobility; and Unusual Revenue Growth. The outcome of the red flag referral may result in an intentional program violation. The lead agency follows continuous improvement practices and regularly evaluates fraud, waste, and abuse prevention and detection methods to inform best practices. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency develops red flag reports that collect and analyze data from clients and providers receiving CCDF funds. Each red flag is programmed with a threshold to measure results that may indicate further investigation is needed for a particular client or provider. Examples of client red flag reports are: Unusual Parent Schedule (parent schedule does not align with child care need); Current Weekly Authorized Hours Greater Than 50; Current Schedules for Approved Parent Activity; EBT Cards Replaced within 12 Months; Funds About to Expire; Inactive EBT Cards for More Than 30 Days with a Balance; Expungement; and Multiple Providers Including Child Care Need Schedule. Examples of provider red flag reports are: Unusual Payment Timing; Payment Grouping; Provider Over Capacity; Child Mobility; and Unusual Revenue Growth. The outcome of the red flag referral may result in an unintentional program violation. The lead agency follows continuous improvement practices and regularly evaluates fraud, waste, and abuse prevention and detection methods to inform best practices. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency develops red flag reports that collect and analyze data from clients and providers receiving CCDF funds. Each red flag is programmed with a threshold to measure results that may indicate further investigation is needed for a particular client or provider. Examples of client red flag reports are: Unusual Parent Schedule (parent schedule does not align with child care need); Current Weekly Authorized Hours Greater Than 50; Current Schedules for Approved Parent Activity; EBT Cards Replaced within 12 Months; Funds About to Expire; Inactive EBT Cards for More Than 30 Days with a Balance; Expungement; and Multiple Providers Including Child Care Need Schedule. Examples of provider red flag reports are: Unusual Payment Timing; Payment Grouping; Provider Over Capacity; Child Mobility; and Unusual Revenue Growth. The Lead Agency completes FIP audits every three years to identify agency errors and conducts Targeted Case Reviews to ensure that subsidy funds are being used appropriately. The outcome of the red flag referral may result in an agency error. The lead agency follows continuous improvement practices and regularly evaluates fraud, waste, and abuse prevention and detection methods to inform best practices. 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: The Lead Agency requires providers to have a written payment agreement with each family that receives Wisconsin Shares subsidy for a child to attend their facility. Payment agreements are reviewed during the course of a provider investigation. If a provider is found to be out of compliance with the requirement to have a written payment agreement with each family receiving subsidy, the provider may receive technical assistance or sanction for multiple violations. Provider attendance records are also reviewed during provider investigations. Inaccuracies or discrepancies in provider records found during the course of an investigation may result in provider overpayments. Providers are responsible for repaying funds received when the provider was in violation of limits on regulated capacity related to the number of children in care. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. In 2023, the Lead Agency and local agencies established a total of $369,325.85 in client intentional program violation overpayments. In 2023, the Lead Agency and local agencies established a total of $1,131,284.68 in provider overpayments for intentional, unintentional provider violations and agency errors. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency requires providers to have a written payment agreement with each family that receives Wisconsin Shares subsidy for a child to attend their facility. Payment agreements are reviewed during the course of a provider investigation. If a provider is found to be out of compliance with the requirement to have a written payment agreement with each family receiving subsidy, the provider may receive technical assistance or sanction for multiple violations. Provider attendance records are also reviewed during provider investigations. Inaccuracies or discrepancies in provider records found during the course of an investigation may result in provider overpayments. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. Providers are responsible for repaying funds received when the provider was in violation of limits on regulated capacity related to the number of children in care. In 2023, the Lead Agency and local agencies established a total of $599,088.22 in unintentional client overpayments. In 2023, the Lead Agency and local agencies established a total of $1,131,284.68 in provider overpayments for intentional, unintentional provider violations and agency errors. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency requires providers to have a written payment agreement with each family that receives Wisconsin Shares subsidy for a child to attend their facility. Payment agreements are reviewed during the course of a provider investigation. If a provider is found to be out of compliance with the requirement to have a written payment agreement with each family receiving subsidy, the provider may receive technical assistance or sanction for multiple violations. Provider attendance records are also reviewed during provider investigations. Inaccuracies or discrepancies in provider records found during the course of an investigation may result in provider overpayments. Providers are responsible for repaying funds received when the provider was in violation of limits on regulated capacity related to the number of children in care. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. In 2023, the Lead Agency and local agencies established a total of $30,930.23 in client overpayment claims for agency error. In 2023, the Lead Agency and local agencies established a total of $1,131,284.68 in provider overpayments for intentional, unintentional provider violations and agency errors. 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: The Lead Agency requires providers to have a written payment agreement with each family that receives Wisconsin Shares subsidy for a child to attend their facility. Payment agreements are reviewed during the course of a provider investigation. If a provider is found to be out of compliance with the requirement to have a written payment agreement with each family receiving subsidy, the provider may receive technical assistance or sanction for multiple violations. Provider attendance records are also reviewed during provider investigations. Inaccuracies or discrepancies in provider records found during the course of an investigation may result in provider overpayments. Providers are responsible for repaying funds received when the provider was in violation of limits on regulated capacity related to the number of children in care. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. In 2023, the Lead Agency and local agencies established a total of $369,325.85 in intentional client program violations. In 2023, the Lead Agency and local agencies established a total of $1,131,284.68 in provider overpayments for intentional, unintentional provider violations and agency errors. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency requires providers to have a written payment agreement with each family that receives Wisconsin Shares subsidy for a child to attend their facility. Payment agreements are reviewed during the course of a provider investigation. If a provider is found to be out of compliance with the requirement to have a written payment agreement with each family receiving subsidy, the provider may receive technical assistance or sanction for multiple violations. Provider attendance records are also reviewed during provider investigations. Inaccuracies or discrepancies in provider records found during the course of an investigation may result in provider overpayments. Providers are responsible for repaying funds received when the provider was in violation of limits on regulated capacity related to the number of children in care. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. In 2023, the Lead Agency and local agencies established a total of $599,088.22 in unintentional client program violations. In 2023, the Lead Agency and local agencies established a total of $1,131,284.68 in provider overpayments for intentional, unintentional provider violations and agency errors. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency requires providers to have a written payment agreement with each family that receives Wisconsin Shares subsidy for a child to attend their facility. Payment agreements are reviewed during the course of a provider investigation. If a provider is found to be out of compliance with the requirement to have a written payment agreement with each family receiving subsidy, the provider may receive technical assistance or sanction for multiple violations. Provider attendance records are also reviewed during provider investigations. Inaccuracies or discrepancies in provider records found during the course of an investigation may result in provider overpayments. Providers are responsible for repaying funds received when the provider was in violation of limits on regulated capacity related to the number of children in care. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. In 2023, the Lead Agency and local agencies established a total of $30,930.23 in client agency error program violations. In 2023, the Lead Agency and local agencies established a total of $1,131,284.68 in provider overpayments for intentional, unintentional provider violations and agency errors. e. [x] Audit provider records. i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency reviews provider attendance records during the process of provider investigations. Inaccuracies or discrepancies in provider records found during the course of an investigation may result in provider overpayment. Providers are also responsible to repay funds received when the provider was in violation of limits on regulated capacity related to the number of children in care. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. In 2023, the Lead Agency completed 75 provider investigations, which included random visits, red flag referrals, fraud mailbox referrals, and referrals regarding providers who received funds during a closed status. In 2023, the Lead Agency and local agencies established a total of $369,325.85 in client overpayment claims for intentional program violations. In 2023, the Lead Agency and local agencies established a total of $1,131,284.68 in provider overpayments for intentional, unintentional provider violations and agency errors. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency reviews provider attendance records during the process of provider investigations. Inaccuracies or discrepancies in provider records found during the course of an investigation may result in provider overpayment. Providers are also responsible to repay funds received when the provider was in violation of limits on regulated capacity related to the number of children in care. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. In 2023, the Lead Agency completed 75 provider investigations, which included random visits, red flag referrals, fraud mailbox referrals, and referrals regarding providers who received funds during a closed status. In 2023, the Lead Agency and local agencies established a total of $599,088.22 in client overpayment claims for unintentional program violations. In 2023, the Lead Agency and local agencies established a total of $1,131,284.68 in provider overpayments for intentional, unintentional provider violations and agency errors. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency reviews provider attendance records during the process of provider investigations. Inaccuracies or discrepancies in provider records found during the course of an investigation may result in provider overpayment. Providers are also responsible to repay funds received when the provider was in violation of limits on regulated capacity related to the number of children in care. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. In 2023, the Lead Agency completed 75 provider investigations, which included random visits, red flag referrals, fraud mailbox referrals, and referrals regarding providers who received funds during a closed status. In 2023, the Lead Agency and local agencies established a total of $30,930.23 in client agency error overpayments. In 2023, the Lead Agency and local agencies established a total of $1,131,284.68 in provider overpayments for intentional, unintentional provider violations and agency errors. 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: Lead Agency staff who are responsible for completing audits utilize operations manuals as well as training from management on how to apply policy to complete audits and investigations. Staff also receive policy updates through Operations Memos and unit meetings. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: Lead Agency staff who are responsible for completing audits utilize operations manuals as well as training from management on how to apply policy to complete audits and investigations. Staff also receive policy updates through Operations Memos and unit meetings. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: Lead Agency staff who are responsible for completing audits utilize operations manuals as well as training from management on how to apply policy to complete audits and investigations. Staff also receive policy updates through Operations Memos and unit meetings. The Lead Agency follows continuous improvement practices and regularly evaluates program policy and outcomes to inform best practices for stakeholder training and technical assistance. g. [x] Other. Describe the activity(ies): Sanctions and Overpayments i. [x] Intentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency only collects client overpayments for agency errors if the client was ineligible for the amount of subsidy received. The Lead Agency does not collect client overpayments for agency errors that are solely related to the child’s authorization, if the client was eligible for the amount of subsidy received. All client intentional program violations and associated sanctions go through an approval process. The Lead Agency utilizes an Enforcement Model for provider violations. The first instance of a provider violation that is not considered a serious violation will result in the Lead Agency providing a signed Technical Assistance Letter regarding the issue(s) in order to ensure the provider understands all program requirements. Instances of a serious provider violation may result in the provider being issued a forfeiture for each violation. Serious provider violations include; providers who are found to be in possession of a photocopy, photo or other image of a parents EBT card; providers who are found to be in possession of a parent’s subsidy account number or PIN; and providers who fail to notify the local agency when a child who receives subsidy to attend their facility has not attended within the previous 30 calendar days. If a provider commits an intentional program violation, they are suspended from the program. All investigations that involve a provider intentional program violation go through a lead agency approval process prior to sanctions being established. ii. [x] Unintentional program violations. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency only collects client overpayments for agency errors if the client was ineligible for the amount of subsidy received. The Lead Agency does not collect client overpayments for agency errors that are solely related to the child’s authorization, if the client was eligible for the amount of subsidy received. The Lead Agency utilizes an Enforcement Model for provider violations. The first instance of a provider violation that is not considered a serious violation will result in the Lead Agency providing a signed Technical Assistance Letter regarding the issue(s) in order to ensure the provider understands all program requirements. Instances of a serious provider violation may result in the provider being issued a forfeiture for each violation. Serious provider violations include; providers who are found to be in possession of a photocopy, photo or other image of a parents EBT card; providers who are found to be in possession of a parent’s subsidy account number or PIN; and providers who fail to notify the local agency when a child who receives subsidy to attend their facility has not attended within the previous 30 calendar days. iii. [x] Agency errors. Describe the activities, the results of these activities, and how they inform better practice: The Lead Agency only collects client overpayments for agency errors if the client was ineligible for the amount of subsidy received. The Lead Agency does not collect client overpayments for agency errors that are solely related to the child’s authorization, if the client was eligible for the amount of subsidy received. The Lead Agency utilizes an Enforcement Model for provider violations. The first instance of a provider violation that is not considered a serious violation will result in the Lead Agency providing a signed Technical Assistance Letter regarding the issue(s) in order to ensure the provider understands all program requirements. Instances of a serious provider violation may result in the provider being issued a forfeiture for each violation. Serious provider violations include; providers who are found to be in possession of a photocopy, photo or other image of a parents EBT card; providers who are found to be in possession of a parent’s subsidy account number or PIN; and providers who fail to notify the local agency when a child who receives subsidy to attend their facility has not attended within the previous 30 calendar days. 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): The Lead Agency is responsible for monitoring, investigating, and pursuing fraud and overpayments for provider errors and fraud. The Lead Agency and local agencies are both actively responsible for monitoring, investigating, and assessing overpayments for client error and fraud. 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: Any funds in excess of $1 that are loaded to a parent's EBT card, for which the parent was ineligible and which the parent paid to the provider, are recovered. Additionally, funds paid to the provider during a period of ineligibility are recovered through a client or provider overpayment/collections process. 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: The Lead Agency has coordinated investigative efforts with a variety of entities at the local, state, and federal level. This includes, but is not limited to, Child Support offices, local sheriff’s departments, local police departments, Department of Health Services, Office of the Inspector General, Department of Workforce Development Unemployment Fraud Units, Department of Public Instruction Food Program Fraud Unit, Department of Revenue, and Federal level investigations involving Wisconsin providers or clients. Collaboration ranges from referral sharing, discussion, coordinating of investigation activities, collaborative interviewing, and providing open record requests to support external investigation. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: The Lead Agency has coordinated investigative efforts with a variety of entities at the local, state, and federal level. This includes, but is not limited to, Child Support offices, local sheriff’s departments, local police departments, Department of Health Services, Office of the Inspector General, Department of Workforce Development Unemployment Fraud Units, Department of Public Instruction Food Program Fraud Unit, Department of Revenue, and Federal level investigations involving Wisconsin providers or clients. Collaboration ranges from referral sharing, discussion, coordinating of investigation activities, collaborative interviewing, and providing open record requests to support external investigation. iv. [ ] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: At Delinquency, the balance of any overpayment(s) is referred to the Wisconsin Department of Revenue (DOR) for interception of any tax refund and credit, authorized under Wis. Statutes, s.49.85. Collection revenue in 2023 for client repayment plans, tax intercept, lien and levy totaled $1,415,229.43. Collection revenue in 2023 for provider voluntary repayment plans $130,067.16. In 2023, $133,392.70 was recovered via DOR. vi. [x] Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: At Delinquency, the balance is subject to both lien and levy collection actions. These actions are authorized under Wis. Statutes, s.49.195. A wage levy compels the debtor's employer to withhold up to 25% of the debtor's earnings and submit it to the State for payment. A warrant (lien) can be issued against the debtor as well. This creates a lien on all real and personal property and hinders the ability to purchase/sell property until the lien is satisfied. Collection revenue in 2023 for client repayment plans, tax intercept, lien and levy totaled $1,415,229.43. Collection revenue in 2023 for provider voluntary repayment plans $130,067.16. In 2023, $133,392.70 was recovered via DOR. 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 Lead Agency established a program integrity unit to investigate improper payments and collect Wisconsin Shares that were improperly authorized. The Lead Agency provides program integrity services for Milwaukee County and provides guidance and technical assistance to local agencies responsible for establishing overpayments for clients in the balance of the state. In 2023, the Lead Agency received 2,305 referrals from red flag reports and the Child Care Fraud mailbox. After initial screening, referrals that are determined to be unsubstantiated and not warranting further investigation are closed. If the referral identifies an error that is correctable with technical assistance, technical assistance is provided verbally, or a technical assistance letter is mailed to the provider. A formal investigation is recommended if screening uncovers additional violations by the provider, a history of noncompliance, and/or indications of fraud or overpayment. In 2023, the Lead Agency screened all 2,305 provider referrals and completed 75 formal investigations. Of the provider formal investigations, 27 resulted in no overpayment, 20 resulted in overpayment only, 5 resulted in overpayment and stipulation that the provider would follow program rules, and 23 resulted in provider permanent suspension from the Wisconsin Shares program. In 2023, $1,131,284.68 in provider overpayments, and $630,018.45 in client overpayments were established due to unintentional client violation. viii. [x] Other. Describe the activities and the results of these activities: The Lead Agency conducts quarterly TCRs by selecting random samples of case files from each local agency to identify administrative errors and program areas that the local agency may need assistance with. The Lead Agency provides in-person and online training and/or technical assistance to local agencies as needed. The Lead Agency also conducts the FIP review every three years. These reviews focus on eligibility determination, authorization development, and correct issuance of subsidy funds 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: Any funds in excess of $1 that are loaded to a parent's EBT card, for which the parent was ineligible and which the parent spent, are recovered. Additionally, funds paid to the provider during a period of ineligibility are recovered through a provider overpayment/collections process. 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: The Lead Agency coordinates investigative efforts with a variety of entities at the local, state, and federal level. This includes, but is not limited to child support offices, local sheriff departments, local police departments, DHS Office of Inspector General (OIG), Department of Workforce Development (DWD) Unemployment Fraud Units, DPI Food Program Fraud Unit, Department of Revenue (DOR), and federal level investigations involving Wisconsin providers or clients. Collaboration ranges from referral sharing, discussion, coordination of investigation activities, collaborative interviewing, and providing open record requests to support external investigations. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: The Lead Agency allows repayment agreements via monthly payments as follows: if the overpayment is under $500, the debtor must pay monthly installments of at least $50 per month; if the overpayment is over $500, the debtor must pay in equal monthly installments over 36 months. However, the minimum monthly payment is $20 per month. Collection revenue in 2023 for client repayment plans, tax intercept, lien and levy totaled $1,415,229.43. Collection revenue in 2023 for provider voluntary repayment plans $130,067.16. In 2023, $133,392.70 was recovered via DOR. iv. [ ] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: At Delinquency, the balance of any overpayment(s) is referred to DOR for interception of any tax refund and credit, authorized under Wis. Statutes, s. 49.85. Collection revenue in 2023 for client repayment plans, tax intercept, lien and levy totaled $1,415,229.43. Collection revenue in 2023 for provider voluntary repayment plans $130,067.16. In 2023, $133,392.70 was recovered via DOR. vi. [x] Recover through other means. Describe the activities and the results of these activities based on the most recent analysis: At Delinquency, the balance is subject to both lien and levy collection actions. These actions are authorized under Wis. Statutes, s.49.195. A wage levy compels the debtor's employer to withhold up to 25% of the debtor's earnings and submit it to the State for payment. A warrant (lien) can be issued against the debtor as well. This creates a lien on all real and personal property and hinders the ability to purchase/sell property until the lien is satisfied. Collection revenue in 2023 for client repayment plans, tax intercept, lien and levy totaled $1,415,229.43. Collection revenue in 2023 for provider voluntary repayment plans $130,067.16. In 2023, $133,392.70 was recovered via DOR 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 Lead Agency established a program integrity unit to investigate improper payments and collect Wisconsin Shares and YoungStar funds that were improperly authorized. The Lead Agency provides program integrity services for Milwaukee County and provides guidance and technical assistance to local agencies responsible for establishing overpayments for clients in the balance of the state. The unit includes a staff of 7 auditors who screen all child care program integrity referrals received by the Lead Agency. In 2023, the Lead Agency received 2,305 referrals from red flag reports and the Child Care Fraud mailbox. After initial screening, referrals that are determined to be unsubstantiated and not warranting further investigation are closed. If the referral identifies an error that is correctable with technical assistance, technical assistance is provided verbally, or a technical assistance letter is mailed to the provider. A formal investigation is recommended if screening uncovers additional violations by the provider, a history of noncompliance, and/or indications of fraud or overpayment. In 2023, the Lead Agency screened all 2,305 provider referrals and completed 75 formal investigations. Of the provider formal investigations, 27 resulted in no overpayment, 20 resulted in overpayment only, 5 resulted in overpayment and stipulation that the provider would follow program rules, and 23 resulted in provider permanent suspension from the Wisconsin Shares program. In 2023, $1,131,284.68 in provider overpayments, and $630,018.45 in client overpayments were established due to unintentional client violation. viii. [x] Other. Describe the activities and the results of these activities: Agency conducts quarterly targeted case reviews by selecting random samples of case files from each local agency to identify administrative errors and program areas that the local agency may need assistance with. The Lead Agency provides in- person and online training and/or technical assistance to local agencies as needed. The Lead Agency also conducts the FIP review every three years. These reviews focus on eligibility determination, authorization, and correct issuance of subsidy funds. The lead agency emphasizes training and technical assistance for child care providers and families enrolled in the program when an error is discovered. Staff who complete program integrity activities are provided resources and guidance to assist them in providing technical assistance to external stakeholders 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: Any funds in excess of $1 that are loaded to a parent's EBT card, for which the parent was ineligible and which the parent spent, are recovered. Additionally, funds paid to the provider during a period of ineligibility are recovered through a provider overpayment/collections process. 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: The Lead Agency coordinates investigative efforts with a variety of entities at the local, state, and federal level. This includes, but is not limited to child support offices, local sheriff departments, local police departments, DHS OIG, DWD Unemployment Fraud Units, DPI Food Program Fraud Unit, DOR, and federal level investigations involving Wisconsin providers or clients. Collaboration ranges from referral sharing, discussion, coordination of investigation activities, collaborative interviewing, and providing open record requests to support external investigations. iii. [x] Recover through repayment plans. Describe the activities and the results of these activities based on the most recent analysis: The Lead Agency allows repayment agreements via monthly payments as follows: if the overpayment is under $500, the debtor must pay monthly installments of at least $50 per month; if the overpayment is over $500, the debtor must pay in equal monthly installments over 36 months. However, the minimum monthly payment is $20 per month Collection revenue in 2023 for client repayment plans, tax intercept, lien and levy totaled $1,415,229.43. Collection revenue in 2023 for provider voluntary repayment plans $130,067.16. In 2023, $133,392.70 was recovered via DOR iv. [ ] Reduce payments in subsequent months. Describe the activities and the results of these activities based on the most recent analysis: v. [x] Recover through State/Territory tax intercepts. Describe the activities and the results of these activities based on the most recent analysis: At Delinquency, the balance of any overpayment(s) is referred to DOR for interception of any tax refund and credit, authorized under Wis. Statutes, s.49.85. Collection revenue in 2023 for client repayment plans, tax intercept, lien and levy totaled $1,415,229.43. Collection revenue in 2023 for provider voluntary repayment plans $130,067.16. In 2023, $133,392.70 was recovered via DOR. 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: The Lead Agency established a program integrity unit to investigate improper payments and collect Wisconsin Shares funds that were improperly authorized. The Lead Agency provides program integrity services for Milwaukee County and provides guidance and technical assistance to local agencies responsible for establishing overpayments for clients in the balance of the state. In 2023, the Lead Agency received 2,305 referrals from red flag reports and the Child Care Fraud mailbox. After initial screening, referrals that are determined to be unsubstantiated and not warranting further investigation are closed. If the referral identifies an error that is correctable with technical assistance, technical assistance is provided verbally, or a technical assistance letter is mailed to the provider. A formal investigation is recommended if screening uncovers additional violations by the provider, a history of noncompliance, and/or indications of fraud or overpayment. In 2023, the Lead Agency screened all 2,305 provider referrals and completed 75 formal investigations. Of the provider formal investigations, 27 resulted in no overpayment, 20 resulted in overpayment only, 5 resulted in overpayment and stipulation that the provider would follow program rules, and 23 resulted in provider permanent suspension from the Wisconsin Shares program. In 2023, $1,131,284.68 in provider overpayments, and $630,018.45 in client overpayments were established due to unintentional client violation. 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: Clients who have committed an intentional program violation follow a three-strike rule. After the first violation, a client is suspended from receiving program funds for six months. After the second violation, the client is suspended for 12 months. A third violation results in the client being permanently suspended from the program. Clients are notified in writing of all decisions and violations and have 30 days to appeal the program violation. If there is an associated overpayment with the program violation, the client has 45 days to appeal the amount of overpayment. Requests for appeals are sent to the Wisconsin Department of Administration (DOA), Division of Hearings and Appeals (DHA). DHA will then assign an Administrative Law Judge (ALJ) to hold a hearing for the appeal. 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: Providers who are found by an investigation to have committed an intentional program violation are terminated from the program and are permanently suspended from receiving Wisconsin Shares authorizations. Providers are notified in writing of all decisions and violations and have 30 days to appeal the program violation. If there is an associated overpayment with the program violation, the provider has 30 days to appeal the amount of overpayment. Requests for appeals are sent to the DHA, which will then assign an ALJ to hold a hearing for the appeal. iii. [x] Prosecute criminally. Describe the activities and the results of these activities based on the most recent analysis: The Lead Agency has the option to refer providers or clients to the local District Attorney for criminal prosecution based on the severity of the program violation and the established fraudulent dollar amount. 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: