10.1 Effective Internal Controls

Lead Agencies must ensure the integrity of the use of CCDF funds through effective fiscal management and must ensure that financial practices are in place. Lead Agencies must have effective fiscal management practices in place for all CCDF expenditures. 10.1.1 Organizational structure to support integrity and internal controls Describe how the Lead Agency’s organizational structure ensures the oversight and implementation of effective internal controls that promote and support program integrity and accountability. Describe: The Department has established internal controls, including the segregation of duties to reduce the risk of errors and/or inappropriate actions; monitoring activities and reports to ensure accuracy of practices, policies and procedures; information processing controls to ensure activities comply with federal regulations; and ongoing communication of expectations, practices, policies, procedure, and duties to all CCDF staff as part of the control environment. The Department’s Director has assigned the authority and responsibilities related to program integrity to the CCDF Administrator and Economic Security Administrator. The Department’s entire CCDF program includes staff from the following divisions: -Fiscal - budget allocation, provider invoice audits and payments; -Quality Control/Quality Assurance - program integrity, quality control and assurance and identification of potential fraud risks; -Child Care Assistance Program Manager, Child Care Benefits & Eligibility Supervisors and Staff - determine, verify, and manage eligibility of program participants; and -Child Care Licensing Manager, Licensing Supervisors and Child Care Licensers - compliance with CCDF licensing and health and safety requirements. Each of these divisions have been delegated the identified duties related to administering the CCDF program and are coordinated to support each aspect of the program. Because each division only handles one aspect of the program, this ensures that there is segregation of duties among program staff. For example, provider invoices are audited by two fiscal staff members for accuracy and the staff member who audits the invoice does not enter the invoice for payment and payments are not processed by eligibility staff. Regular meetings are held with staff of the various divisions to review budgets, payments, error reports, licensing issues, and to provide updated training and guidance where appropriate. Include the following elements in your description: 1. Assignment of authority and responsibilities related to program integrity. 2. Delegation of duties. 3. Coordination of activities. 4. Communication between fiscal and program staff. 5. Segregation of duties. 6. Establishment of checks and balances to identify potential fraud risks. 7. Other activities that support program integrity. 10.1.2 Fiscal management practices Describe how the Lead Agency ensures effective fiscal management practices for all CCDF expenditures, including: a. Fiscal oversight of CCDF funds, including grants and contracts. Describe: For all Contracts utilizing CCDF funds, the expectations and outcomes for the Contractor are articulated thoroughly through the Contractor responsibilities. The Contractor submits invoices monthly along with required performance reports. The Department thoroughly reviews the itemized invoice to verify the expenditures are allowable and within the scope of the Contract as well as the performance reports show the outcomes of the Contract are being delivered. The invoice is approved and submitted for payment. In addition, the Department conducts monitoring visits, either in person or virtually, as well as having frequent communication via telephone and "Google Hangouts" with the Contractor and staff. b. Tracking systems that ensure reasonable and allowable costs and allow for tracing of funds to a level of expenditure adequate to establish that such funds have not been used in violation of the provision of this part. Describe: In the accounting system Wyoming On- Line Financial System (WOLFS), as part of our chart of accounts. there is a field that we call activity that determines what line on the federal report the expenditure will go on. There are also fields called program code and program period code that are used to know what federal fiscal year and grant the expense is to be charged. The public assistance cost allocation plan also has the formula for what will be charged to the programs for allocated costs or employees on time and effort. c. Processes and procedures to prepare and submit required state and federal fiscal reporting. Describe: Based on the above description regarding tracking systems that ensure reasonable and allowable costs, the fiscal reports are prepared by a fiscal staff and reviewed, verified, and approved by a fiscal supervisor. The fiscal reports are submitted to the federal system once reviewed, verified and approved by a fiscal supervisor. d. Other. Describe: 10.1.3 Effectiveness of fiscal management practices Describe how the Lead Agency knows there are effective fiscal management practices in place for all CCDF expenditures, including: a. How the Lead Agency defines effective fiscal management practices. Describe: DFS has an Accounting Policies & Procedures document that defines signature authority, documentation requirements, and separation of duties. The Department also has a Grants Management Policy & Procedures Manual that clearly identifies procedures for responsible management of its grant awards. These documents also describe our payment and expenditure process. The Department uses these two documents to ensure its CCDF program is administered within State and Federal guidelines. As such, effective fiscal management practices are defined as processes and procedures implemented that ensure payments using grant funds are accurate and timely and any overpayments identified quickly for recovery efforts. To determine whether these practices are effective, the Department also completes regular reconciliations between payments, invoices and financial tracking records. b. How the Lead Agency measures and tracks results of their fiscal management practices. Describe: The fiscal staff reconcile accounting and payment records weekly. Any discrepancies identified are investigated and corrected immediately. If similar discrepancies occur on a regular basis, the Department works to identify the source of the problem and correct it to ensure further issues do not occur. Additionally, program managers are provided with these weekly reports to review for accuracy and notify fiscal of any discrepancies that are noted. The Department’s CCDF Administrator and staff maintain cumulative records of expenditures to ensure compliance with grant payment requirements and adjustments are made as necessary. c. How the results inform implementation. Describe: The Department uses the results of its regularly weekly and quarterly expenditure reviews to identify areas where the Department may be deficient in meeting CCDF expenditure requirements. Any deficiencies are then discussed between the CCDF Administrator, CCDF staff, and fiscal staff to develop a plan of action to increase expenditures for the areas identified as deficient. This process is repeated regularly as needed to ensure the Department maintains compliance with CCDF requirements. The results are also used to identify areas of policies that may need to be updated and improvement of fiscal management practices. d. Other. Describe: 10.1.4 Identifying risk Describe the processes the Lead Agency uses to identify risk in the CCDF program including: a. Each process used by the Lead Agency to identify risk (including entities responsible for implementing each process). Describe: The Department has established internal controls, including the segregation of duties to reduce the risk of errors and/or inappropriate actions; monitoring activities and reports to ensure accuracy of practices, policies and procedures; information processing controls to ensure activities comply with federal regulations; and ongoing communication of expectations, practices, policies, procedure, and duties to all CCDF staff as part of the control environment. The Department’s Director has assigned the authority and responsibilities related to program integrity to the CCDF Administrator and Economic Security Administrator. The Department’s entire CCDF program includes staff from the following divisions: -Fiscal - budget allocation, provider invoice audits and payments; -Quality Control/Quality Assurance - program integrity, quality control and assurance and identification of potential fraud risks; -Child Care Assistance Program Manager, Child Care Benefits & Eligibility Supervisors and Staff - determine, verify, and manage eligibility of program participants; and -Child Care Licensing Manager, Licensing Supervisors and Child Care Licensers - compliance with CCDF licensing and health and safety requirements. Each of these divisions have been delegated the identified duties related to administering the CCDF program and are coordinated to support each aspect of the program. Because each division only handles one aspect of the program, this ensures that there is segregation of duties among program staff. For example, provider invoices are audited by two fiscal staff members for accuracy and the staff member who audits the invoice does not enter the invoice for payment and payments are not processed by eligibility staff. Regular meetings are held with staff of the various divisions to review budgets, payments, error reports, licensing issues, and to provide updated training and guidance where appropriate. The duties assigned to each division identified above ensure that errors are identified before payments are made to providers. Additionally, another staff members completes random sampling and comparison of submitted invoices/attendance verifications to actual provider child attendance records to ensure previously issued payments were not made improperly or based on provider fraud. b. The frequency of each risk assessment. Describe: The Department has established internal controls, including the segregation of duties to reduce the risk of errors and/or inappropriate actions; monitoring activities and reports to ensure accuracy of practices, policies and procedures; information processing controls to ensure activities comply with federal regulations; and ongoing communication of expectations, practices, policies, procedure, and duties to all CCDF staff as part of the control environment. The Department’s Director has assigned the authority and responsibilities related to program integrity to the CCDF Administrator and Economic Security Administrator. The Department’s entire CCDF program includes staff from the following divisions: -Fiscal - budget allocation, provider invoice audits and payments; -Quality Control/Quality Assurance - program integrity, quality control and assurance and identification of potential fraud risks; -Child Care Assistance Program Manager, Child Care Benefits & Eligibility Supervisors and Staff - determine, verify, and manage eligibility of program participants; and -Child Care Licensing Manager, Licensing Supervisors and Child Care Licensers - compliance with CCDF licensing and health and safety requirements. Each of these divisions have been delegated the identified duties related to administering the CCDF program and are coordinated to support each aspect of the program. Because each division only handles one aspect of the program, this ensures that there is segregation of duties among program staff. For example, provider invoices are audited by two fiscal staff members for accuracy and the staff member who audits the invoice does not enter the invoice for payment and payments are not processed by eligibility staff. Regular meetings are held with staff of the various divisions to review budgets, payments, error reports, licensing issues, and to provide updated training and guidance where appropriate. The duties assigned to each division identified above ensure that errors are identified before payments are made to providers. Additionally, another staff members completes random sampling and comparison of submitted invoices/attendance verifications to actual provider child attendance records to ensure previously issued payments were not made improperly or based on provider fraud. The Department, through the processes detailed above, assesses risk regularly (weekly & monthly). c. How the Lead Agency uses risk assessment results to inform program improvement. Describe: The Department has established internal controls, including the segregation of duties to reduce the risk of errors and/or inappropriate actions; monitoring activities and reports to ensure accuracy of practices, policies and procedures; information processing controls to ensure activities comply with federal regulations; and ongoing communication of expectations, practices, policies, procedure, and duties to all CCDF staff as part of the control environment. The Department’s Director has assigned the authority and responsibilities related to program integrity to the CCDF Administrator and Economic Security Administrator. The Department’s entire CCDF program includes staff from the following divisions: -Fiscal - budget allocation, provider invoice audits and payments; -Quality Control/Quality Assurance - program integrity, quality control and assurance and identification of potential fraud risks; -Child Care Assistance Program Manager, Child Care Benefits & Eligibility Supervisors and Staff - determine, verify, and manage eligibility of program participants; and -Child Care Licensing Manager, Licensing Supervisors and Child Care Licensers - compliance with CCDF licensing and health and safety requirements. Each of these divisions have been delegated the identified duties related to administering the CCDF program and are coordinated to support each aspect of the program. Because each division only handles one aspect of the program, this ensures that there is segregation of duties among program staff. For example, provider invoices are audited by two fiscal staff members for accuracy and the staff member who audits the invoice does not enter the invoice for payment and payments are not processed by eligibility staff. Regular meetings are held with staff of the various divisions to review budgets, payments, error reports, licensing issues, and to provide updated training and guidance where appropriate. The duties assigned to each division identified above ensure that errors are identified before payments are made to providers. Additionally, another staff members completes random sampling and comparison of submitted invoices/attendance verifications to actual provider child attendance records to ensure previously issued payments were not made improperly or based on provider fraud. The Department, through the processes detailed above, assesses risk regularly (weekly & monthly). The Department uses the results of the above processes to identify changes and adjustments that need to be made to mitigate risk. Policy & Procedures, Rules, processes and training may be updated to ensure program improvement d. How the Lead Agency knows that the risk assessment processes utilized are effective. Describe: The Department has established internal controls, including the segregation of duties to reduce the risk of errors and/or inappropriate actions; monitoring activities and reports to ensure accuracy of practices, policies and procedures; information processing controls to ensure activities comply with federal regulations; and ongoing communication of expectations, practices, policies, procedure, and duties to all CCDF staff as part of the control environment. Based on the established internal controls and subsequent adjustments, the Department believes the risk assessment/evaluation process is effective e. Other. Describe: 10.1.5 Processes to train about CCDF requirements and program integrity Describe the processes the Lead Agency uses to train staff of the Lead Agency and other agencies engaged in the administration of CCDF, and child care providers about program requirements and integrity. a. Describe how the Lead Agency ensures that all staff who administer the CCDF program (including through MOUs, grants, and contracts) are informed and trained regarding program requirements and integrity. i. Describe the training provided to staff members around CCDF program requirements and program integrity: The Department has a specialized trainer within the Child Care Assistance Program who is responsible for all training related to the program policy. The Child Care Assistance Program Manager also is actively involved and supports the trainer with any needs they may have. Training is delivered in person, webinar, or a combination of both, and via email. Additionally, the Child Care Assistance Program Manager holds weekly huddles with child care eligibility staff and supervisors to review performance measures and quality assurance reports to identify and discuss errors and compliance with program requirements to ensure integrity of the program. Training is also provided to staff during these weekly huddles as needed. ii. Describe how staff training is evaluated for effectiveness: The Department has an employee to conduct quality assurance of cases. The quality assurance staff reviews an average of 13 child care eligibility case files a month to ensure eligibility was determined correctly. In addition, the Department's Child Care Assistance Program supervisors review a minimum of three (3) cases per staff per month to ensure eligibility was determined correctly. The Department's Child Care Assistance Program Manager is responsible for reviewing all findings from the Child Care Assistance supervisors and quality assurance staff. iii. Describe how the Lead Agency uses program integrity data (e.g., error rate results, risk assessment data) to inform ongoing staff training needs: The Department has an employee to conduct quality assurance of cases. The quality assurance staff reviews an average of 13 child care eligibility case files a month to ensure eligibility was determined correctly. In addition, the Department's Child Care Assistance Program supervisors review a minimum of three (3) cases per staff per month to ensure eligibility was determined correctly. The Department's Child Care Assistance Program Manager is responsible for reviewing all findings from the Child Care Assistance supervisors and quality assurance staff. b. Describe how the Lead Agency ensures all providers for children receiving CCDF funds are informed and trained regarding CCDF program requirements and program integrity: i. Describe the training for providers around CCDF program requirements and program integrity: Providers must complete a 203b Registration Form For Unlicensed Child Care Providers which includes CCDF program requirements and responsibilities to receive child care assistance on behalf of a child. No formal training sessions are held for CCDF providers; however, the field fiscal staff are most often the first point of contact for potential license-exempt providers and these staff provide detailed information and explanations of the requirements of CCDF as well as their responsibilities relating to time and attendance of CCDF- eligible children. If additional training is needed, the provider is referred to the Child Care Assistance Program Manager or the Department’s Licensing Technical Assistance Coach. The Department’s Licensing staff provide regular and ongoing training and guidance to licensed providers about the CCDF program requirements and responsibilities. ii. Describe how provider training is evaluated for effectiveness: The Department's fiscal staff audit all child care invoices submitted by providers monthly or bi- monthly. Following the fiscal audit of the invoice, a different fiscal staff enters the billing information into the child care payment system and payment is generated. iii. Describe how the Lead Agency uses program integrity data (e.g., error rate results, risk assessment data) to inform ongoing provider training needs: The Department uses the results of the above processes to identify changes and adjustments that need to be made to ensure providers receive the appropriate training. Policy & Procedures, Rules, and processes may be updated to ensure program improvement and to meet the needs of the providers. 10.1.6 Evaluate internal control activities Describe how the Lead Agency uses the following to regularly evaluate the effectiveness of Lead Agency internal control activities for all CCDF expenditures. a. Error rate review triennial report results (if applicable). Describe who this information is shared with and how the Lead Agency uses the information to evaluate the effectiveness of its internal controls: The error rate review triennial report is shared with the Economic Security Division Senior Administrator, child care district manager, benefit specialist supervisors, and child care benefit specialists. The team reviews the results and assesses the rules, policy and procedures to identify areas of improvement. Additionally, training (individual and group) is developed to target specific areas where errors occurred. b. Audit results. Describe who this information is shared with and how the Lead Agency uses the information to evaluate the effectiveness of its internal controls: Audit results are shared with the Economic Security Division Senior Administrator, child care district manager, benefit specialist supervisors, child care benefit specialists and the Department’s fiscal team. The team reviews the results and assesses the rules, policy and procedures to identify areas of improvement (changes are made to rules, policy and/or procedures as a result of the review). Additionally, training (individual and group) is developed to target specific areas where errors occurred. c. Other. Describe who this information is shared with and how the Lead Agency uses the information to evaluate the effectiveness of its internal controls: 10.1.7 Identified weaknesses in internal controls Has the Lead Agency or other entity identified any weaknesses in its internal controls? a. [ ] No. If no, describe when and how it was most recently determined that there were no weaknesses in the Lead Agency’s internal controls. b. [x] Yes. If yes, what were the indicators? How did you use the information to strengthen your internal controls? The Department fiscal policies were updated March 24, 2024.