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Child Care Subsidy Policy October 1, 2024 79 CHAPTER 8: Improper Payments: Prevention, Identification, Measurement and Recoupment 8.0 Improper Payments Overview The Federal Improper Payments Act of 2002 has created special concern about improper payments and their recovery in all federally funded programs. An improper payment occurs when the funds go to the wrong recipient, the recipient receives the incorrect amount of funds, or the recipient obtains or uses the funds in an improper manner. By strengthening financial management controls so that Federal agencies can better detect and prevent improper payments, the Federal Government can better ensure that taxpayer dollars are spent wisely and efficiently. Everyone involved in the administration of the child care subsidy program should understand what can be done to maintain program integrity; what constitutes misrepresentation; what action should be taken in cases where misrepresentation is suspected; and the methods and procedures for performing these functions. 8.1 Maintaining Program Integrity It is the responsibility of every Child Care Resource and Referral employee and every DoHS employee to minimize the opportunity for improper payments by performing his duties as outlined in this Child Care Policy Manual. It is essential that the case manager fully understands these policies and procedures. The primary burden for the prevention of misrepresentation rests on the CCR&R case manager. The case manager must make sure that the application, status check forms, and supporting verifications have been fully completed, properly signed, dated, and any conflicting or missing information brought to the attention of the client for clarification or completion. Reviewing the case record and verifications thoroughly prior to issuing a certificate to the client will aid the case manager in reducing errors and preventing misrepresentation. Clients can be expected to give information only in relation to their understanding of program requirements. Case managers should ensure that clients and providers fully understand their rights and responsibilities as subsidy program participants, and that this be documented in the PATH record. Great care should be taken to ensure that:  Clients and providers understand their respective application and status check forms.  They are aware of their responsibility to report any changes in circumstances.  Clients and providers are aware that attempts to obtain assistance through misrepresentation will be subject to legal penalties. Although the client is the primary source of information and is fully responsible for it, the case manager should not hesitate to verify questionable or inconsistent information any time there is doubt about a client’s situation. The signature page of the child care application and status check gives the case manager the authority to investigate discrepancies and suspicions.