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Child Care Subsidy Policy October 1, 2024 80 8.2 Improper Payment Prevention Strategies West Virginia uses a variety of means to prevent errors that result in improper payments. The PATH system is designed to take the information entered in the system by the CCR&R case manager and use it to determine eligibility. This eliminates many of the errors, except for errors in the data entry itself. As part of the required Quality Assurance plan, each CCR&R agency shall have a process to internally monitor eligibility determinations, payment processing, and PATH data entry. In addition, state level staff work with CCR&R agencies to identify problem policies, procedures and forms that may lead to errors. Solutions are developed by committee and supported in the field through training and technical assistance supplied by the child care consultants. Strategies developed to prevent and reduce errors and improper payments include the following: 8.2.1. CCR&R agencies must use the State’s management information system, the Family and Children’s Tracking System (PATH), to determine financial eligibility and calculate payment amounts due. The system also has controls to limit payments to eligible days and children only. 8.2.2. CCR&R agencies must use State developed child care policy and procedures. 8.2.3. CCR&R agencies must develop and implement Quality Assurance Plans to review and oversee eligibility determinations, case maintenance, and payment processing. 8.2.4. Family child care providers must submit sign in and out sheets to verify attendance along with their billing forms, and centers are asked on a random basis to submit their sign in and out sheets along with their billing forms. 8.2.5. CCR&R agencies must audit billing forms and compare work and school schedules to times shown on the sign in and out form to verify child care usage complies with time approved. 8.2.6. Child care providers who submit incorrect or improper billing forms must attend a retraining session on proper billing procedures. After attending two retraining sessions, if the provider fails to comply with appropriate billing procedures, the provider can be denied participation in the certificate system. 8.2.7. Subsidy clients must submit verifications for activities and income. For example, adult learners receiving services must provide school schedules and grades. Employed clients must submit pay stubs for one month’s period and work schedules. Case managers review pay stubs carefully, reviewing for unreported overtime, bonuses, and incentives in the year-to-date columns. 8.2.8. CCR&R case managers can implement a thirty-day penalty closure for clients who violate subsidy policy rules and responsibilities. If a parent fails to fulfill these responsibilities, the case manager shall give a written warning regarding specific problems, noting that subsequent abuses may result in a 30-day penalty closure.