Making changes while maintaining program integrity
Family-friendly processes and program integrity
Lead Agencies have a lot of flexibility when determining a family’s eligibility for child care assistance. For example, Lead Agencies have flexibility to define terms such as “income” and “working” in ways that will best serve their population, and to establish documentation requirements that sufficiently demonstrate compliance with requirements while reducing barriers to participation for eligible families.
In all cases, Lead Agencies must document their policies and procedures for determining child care assistance eligibility as part of their CCDF Plan. Lead Agencies must have rigorous processes in place to detect fraud and improper payments, and these should be reasonably balanced with family friendly practices.
The OCC National Center on Subsidy Innovation and Accountability (NCSIA) found that, “Family-friendly policies not only benefit families but can promote the integrity of the program. In general, streamlined eligibility processes are less difficult to administer. Eliminating complex rules and eligibility practices reduces administrative workload burden…Lead Agencies with less complex eligibility processes generally have fewer administrative errors than those with complex program rules and practices.”
Recommended best practices
Internal controls
When changing documentation requirements to reduce family and administrative burden, especially if allowing families to self-certify certain information in their application, OCC encourages Lead Agencies to consider what controls, such as red flag reports, randomized spot checking of applications, and manager review, they can institute to reasonably verify the information and prevent fraud and abuse. OCC’s National Center for Subsidy, Innovation, and Accountability (NCSIA) offers technical expertise to support your efforts as you work to strengthen your internal controls. A tool such as the Grantee Internal Controls Self Assessment Instrument can assist you in assessing how well your policies and procedures meet the Child Care and Development Fund's (CCDF) regulatory requirements in the areas of program integrity and financial accountability (45 CFR 98.68).
Create an access and integrity scorecard
In order to reduce barriers for families while maintaining program integrity, OCC recommends developing a CCDF Access and Integrity scorecard that tracks both of these important goals, and can assist Lead Agencies in understanding the balance achieved over time.
This scorecard should contain measures that track burden on families, such as:
- Application burden
- The average time it takes for someone to submit an application
- The percent of people that start an application who complete it (“abandon rate")
- Eligibility decision timeliness
- The average time it takes an application to be adjudicated once submitted
- Verification delays
- The percent of applications that require additional documentation be submitted
Measures that provide information about program integrity, such as:
- Denials
- The percent of denials, broken down by reason
- Payment errors
- The percent of cases that resulted in payment errors, broken down by intentional violations, administrative errors, and family errors
- Amount or percent of total funds recaptured due to improper payments
Together, these measures can illustrate progress over time - when a change is implemented, the scorecard is able to help a Lead Agency understand whether their change resulted in reduced burden and how it may have affected program integrity. Without broadly measuring your program’s performance, it is not possible to understand whether your program is best serving families.
What's included in the Guide
Defining, collecting, and verifying eligibility information