On January 10, the Administration for Children and Families (ACF) released a notice in the Federal Register (77 FR 1494) requesting comments on the Child Care and Development Fund's (CCDF) improper payment reports. The purpose of the request is to announce ACF's proposal to collect information on states' compliance with the Improper Payments Information Act of 2002 (IPIA) and the Improper Payments Elimination and Recovery Act of 2010. Section 2 of the IPIA of 2002 requires states to prepare and submit a report of errors connected with the administration of CCDF grant funds once every three years. The Office of Child Care (OCC) is completing the second three-year cycle of case record reviews. OCC has evaluated the case record review process to determine if "improper authorizations for payment" accurately capture actual "improper payments" as a result of these federal audits. In some cases, the OCC found that the authorizations for payment reflected the same figure as actual payments; in other cases, authorizations for payment represented a figure as much as "20 percent higher than actual payments." Some states have reported regulatory barriers in state law that hinder the recovery of over authorization or overpayment as the result of agency error.
APHSA's affiliate the National Association of State Child Care Administrators has recommended that ACF shift the focus of the CCDF error rate methodology to actual payments, and the OCC's action has taken APHSA's recommendation into consideration. In addition, the OCC agrees that this revision will create a streamlined process for allowing greater efficiency in conducting reviews and reducing administrative burdens on lead CCDF agencies.
Comments must be submitted in writing to the ACF Office of Planning, Research and Evaluation, 370 L'Enfant Promenade, S.W., Washington, DC 20447, Attn: ACF Reports Clearance Officer, or at firstname.lastname@example.org. The deadline to submit comments is March 9, 2012. The Federal Register notice can be found on the OCC web site at http://www.acf.hhs.gov/programs/occ/.