18 Miss. Code. R. 5-1-1.3
Program integrity is defined to include efforts that ensure effective internal controls over the administration of CCDF funds. The Lead Agency is responsible for monitoring programs and services, ensuring compliance with the rules of the program, promulgating rules and regulations to govern the overall administration of the plan and oversee the expenditure of funds by sub-grantees and contractors. (§ 98.11(b)) Accountability measures should address administrative error, which includes unintentional agency error, as well as address program violations, both unintentional and intentional, that may or may not result in further action by the Lead Agency, including those cases suspected of and/or prosecuted for fraud.
The description of internal controls may include, but is not limited to a description of processes to ensure sound fiscal management, to identify areas of risk or to establish regular evaluation of control activities.
Over the last four years, the Lead Agency has been dedicated to reducing errors in reporting, administrative processes, and payment for services. Strategies adopted under this plan will reflect a continuation of this ongoing effort. Strategies identified to ensure effective internal controls include, but are not limited to:
The State's Office of the State Auditor engages all divisions of the Mississippi Department of Human Services in ongoing audits. These audits include reviews of casefiles to ensure proper expenditure of funds. Upon compeletion of an audit, a meeting is held to discuss findings and plan to address any weaknesses in program operation before initiating the next audit.
Lead Agencies that use other governmental or non-governmental sub-recipients to administer the program must have written agreements in place outlining roles and responsibilities for meeting CCDF requirements (98.11 (a) (3))
Definition: A sub-recipient (including a sub-contractor and or sub-grantee) is a non-Federal entity that expends Federal awards (contract or grant) received from another entity to carry out a Federal program, but does not include a vendor nor does it include an individual who is a beneficiary of such a program. OMB Circular A-133 Section 210 provides additional information on the characteristics of a sub-recipient and vendor.
The description of monitoring may include, but is not limited to, a discussion of written agreements, fiscal management, review of policies and procedures to ensure compliance with CCDF regulations, monitoring/auditing contractors or grantees to ensure that eligible children are served and eligibility documentation is verified, and establishing performance indicators or measures related to improper payments.
The Lead Agency has in place subcontracts with various entities to provide child care slots. These subcontractors are monitored by the Mississippi Department of Human Services Division of Program Integrity in accordance with the regulations established for all entities engaged in contract services for the Lead Agency. These regulations can be found in the MDHS Subgrant/Contract Manual located at, http://www.mdhs.state.ms.us/pdfs/dpimanual/dpi_submanual.pdf.
Annual monitoring of subcontractors by the MDHS Division of Program Integrity includes a review of eligibility processes and requests for payment to ensure adherence to state and federal policies. Any findings as a result of the monitoring are settled in accordance with the established policies in the MDHS Subgrant/Contract Manual.
Program violations may include intentional and unintentional client and/or provider violations as defined by the Lead Agency. Administrative error refers to areas identified through the Error Rate Review process (98.100). Check which activities, if any, the Lead Agency has chosen to conduct.
| Type of Activity | IdentifyProgramViolations | IdentifyAdministrativeError |
| Share/match data from other programs (e.g. TANF, Child and Adult Care Food Program (CACFP), Food and Nutrition Service (FNS), Medicaid)) | [] | [] |
| Share/match data from other databases (e.g., State Directory of New Hires, Social Security Administration, Public Assistance Reporting Information System (PARIS)) | [] | [] |
Run system reports that flag errors Errors that would be identified through these reports include, but are not limited to children who have aged out of eligibility, authorizations attached to a provider left incomplete, authorizations that have expired but were not terminated, incomplete provider profiles, and fraud reports. | * | * |
| Review of attendance or billing records | * | * |
| Audit provider records | * | * |
| Conduct quality control or quality assurance reviews | * | * |
| Conduct on-site visits to providers or sub-recipients to review attendance or enrollment documents | * | [] |
| Conduct supervisory staff reviews | [] | * |
| Conduct data mining to identify trends | * | * |
| Train staff on policy and/or audits | * | * |
| Other. Describe______ | [] | [] |
| None | [] | [] |
For any option the Lead Agency checked in the chart above other than none, please describe
The Lead Agency will utilze the Child Care Information System (CCIS) to produce reports querried to help identify trends in the data, staff performance, and error rates. CCIS allows for case management and fiscal monitoring. The Lead Agency's CCIS interfaces daily with the information system housing TANF data to collect referrals and terminations of child care subsidy. This interface helps ensure timely and accurate access to subsidy services.
If the Lead Agency checked none, please describe what measures the Lead Agency has or plans to put in place to address program integrity:______
Check and describe in the chart below which strategies, if any, the Lead Agency will use for each of the following areas: Unintentional program violations (UPV), intentional program violations (IPV) and/or fraud, and administrative error as defined in your State/Territory. The Lead Agency has the flexibility to recover misspent funds as a result of errors. The Lead Agency is required to recover misspent funds as a result of fraud (98.60(i)).
| Strategy | UPV | IPVand/orFraud | Administrative Error |
| Require recovery after a minimum dollar amount in improper payment. Identify the minimum dollar amount $100 | * | * | [] |
| Coordinate with and refer to other State/Territory agency (e.g. State/Territory collection agency, law enforcement). Describe | [] | [] | [] |
| Recover through repayment plans | * | * | * |
| Reduce payments in subsequent months | * | * | * |
| Recover through State/Territory tax intercepts | [] | [] | [] |
| Recover through other means. Describe | [] | [] | [] |
| Establish a unit to investigate and collect improper payments. Describe composition of unit The MS Department of Human Services, Division of Program Integrity investigates improper payments. | * | * | * |
| Other. Describe | [] | [] | [] |
| None | [] | [] | [] |
For any option the Lead Agency checked in the chart above other than none, please describe
Through the development and implementation of the Child Care Information System (CCIS), transactional child care activity can easily be monitored and analyzed to determine the possible misuse of funds, the existence of fraudulent behavior, and the reduction and/or prevention of improper payments. The database system contains several parameters and edit checks designed to reduce the possible occurrence of improper payments.
The Lead Agency has also developed various internal control fiscal management reports that allow the CCA to obtain a "bird's eye" view of child care transactions across the State of Mississippi. The reports are structured by federal regulatory guidelines. Subgrantees prepare and submit a monthly report to the Lead Agency,
which are used in the development of monthly internal reports. In addition, the MDHS Department of Budgets and Accounting prepare reports quarterly. Thus, any significant irregularities in child care activity can easily be spotted and appropriate disciplinary actions immediately taken. Once possible improper payments have been identified, the Lead Agency will enact one of the following procedures:
[] None
* Disqualify client. If checked, please describe, including a description of the appeal process for clients who are disqualified
Any dispute concerning a question of fact under application/agreement which is not disposed of by agreement of the parties hereto shall be decided by the DECCD Director. In the review by the DECCD Director, the parent/provider shall be afforded an opportunity to be heard and offer evidence in support of the questioned decision under review. This decision shall be reduced to writing and a copy thereof mailed or furnished to the parent/provider and shall be final and conclusive, unless, within thirty (30) days from the date of the decision, the parent/provider mails or furnishes the Executive Director of the Mississippi Department of Human Services a written request for review. Pending final decision of the Executive Director or his designee, the Lead Agency Staff will proceed in accordance with the decision of the DECCD Director.
* Disqualify provider. If checked, please describe, including a description of the appeal process for providers who are disqualified
Any dispute concerning a question of fact under application/agreement which is not disposed of by agreement of the parties hereto shall be decided by the DECCD Director. In the review by the DECCD Director, the parent/provider shall be afforded an opportunity to be heard and offer evidence in support of the questioned decision under review. This decision shall be reduced to writing and a copy thereof mailed or furnished to the parent/provider and shall be final and conclusive, unless, within thirty (30) days from the date of the decision, the parent/provider mails or furnishes the Executive Director of the Mississippi Department of Human Services a written request for review. Pending final decision of the Executive Director or his designee, the Lead Agency Staff will proceed in accordance with the decision of the DECCD Director.
* Prosecute criminally
[] Other. Describe.______
Territories not required to complete the Error Rate Review should mark [] N/A here.
| Activities identified in ACF-402 | Cause/Type of Error (if known) | Actions Taken or Planned | Completion Date(Actual or planned) (if known) |
| The Lead Agency will perform internal reviews of the child care subsidy applications and all related supporting documentation, prior to the issuance of a child care certificate, to ensure accuracy and completeness. In addition, subgrantee training will be conducted on the MDHS Child Care Policy Manual, including but not limited to compliance with federal/state policies and regulation related to the subsidy program, procedures for issuing child care certificates, using CCIS and updated policies/regulations/procedures. | Unknown | 1. The Lead Agency will utilize CCIS to review staff workflow and ensure proper implementation according to established program policies. 2. Lead Agency staff is engaged in policy training each month at staff meetings. 3. CCIS prevents program staff from advancing through the eligibility process until all required documentation has been received and entered. | 1. CCIS updates were completed in January 2013. 2. This process is ongoing. 3. CCIS updates were completed in January 2013. |
18 Miss. Code. R. 5-1-1.3