OCSE Administrative Changes (no regulatory or statutory changes foreseen)
1. The NCCSD recommends that the OCSE conduct DRAs
only on the incentive performance measure(s) that the State had a finding of unreliable data for the prior FFY audit period and to complete all States’ DRAs as soon as possible, but no later than April 1 of the year following the end of each FFY. However, OCSE must conduct a DRA on all of the incentive performance measures for each State at least once every three years. Conducting DRAs only on the measures States previously failed will expedite the completion of the audit process. Completion of DRAs prior to April 1 may allow States time to implement corrective actions and computer system programming changes to report reliable data before the deadline to submit the federal reports for the following FFY reporting cycle. As an example, if a State did not have a finding of unreliable data for the order establishment, current support, arrears collections, and cost effectiveness measures; but did have a finding of unreliable data for the PEP for FFY-2001; the federal OCSE should only conduct the DRA for FFY-2002 on the PEP data. (See attachment for survey results)
2. The NCCSD recommends penalty letters required pursuant to 45 CFR 305.66 should be sent to States within 30 days after the final DRA report is issued, if applicable.
3. The NCCSD recommends that the DRA working audit guide be provided to each State IV-D agency. All States agree that the consistent application of DRA review procedures is critically important to the correct calculation and allocation of federal incentive payments for each State. Use of the working audit guide will assist States to: a) have a clear understanding of the correct reporting requirements for each of the performance measures; b) maintain data integrity within State computer systems; c) identify and develop staff training programs for correct data entry; and d) be assured that the review procedures are applied uniformly amongst the States.
4. The NCCSD urges OCSE to change the sampling selection criteria to use “children” for both the Statewide PEP and the IV-D PEP. The incentive formula allows States an option to measure the paternity establishment percentage by using the Statewide PEP calculation, or by using the IV-D PEP calculation. The DRA sample for the Statewide PEP calculation is based on “children” selected from the State’s universe, however, the DRA sample for the IV-D PEP calculation is based on the selection of “cases” within the IV-D caseload. Recognizing that there may be multiple children in IV-D cases, and that the DRA process reviews all of the children in cases selected for States electing to use the IV-D PEP, there is inconsistency in the audit procedures for States depending on whether the State elects to be measured by the Statewide PEP or the IV-D PEP.
Regulatory and/or Statutory Changes
5. The NCCSD recommends OCSE to initiate revisions to the current statutes and regulations so that a one year corrective action period begins on October 1 of the FFY following the FFY for which a DRA finding was made that a state had unreliable data for purposes of imposing the penalty provisions. As an example, if a DRA determined a state reported unreliable data for FFY-2002, the one year corrective action period would begin October 1, 2003. The state would have until September 30, 2004 to complete the corrective actions and report reliable data for the FFY-2004 period before a penalty could be imposed. Corrective actions to ensure data reliability may involve making computer system programming changes, but also requires line worker training to ensure data entry integrity.
NCCSD Recommendations regarding DRA and Penalty Provisions
June 19, 2003
Attachment
NCCSD requested all states to provide pass/fail information for each performance measure regarding the Data Reliability Audits for 2000, 2001 and 2002. We received data from 44 out of 54 states. A summary of that data, divided into 4 “tiers” follows at the end of this attachment.
All states within tier 1, 22 of 44 states (50%), passed all measures for 2 or 3 consecutive years. By using these states as an example, an audit for 50% of the states would only need to be conducted once every 3 years if a state passes either 2 or 3 years consecutively. OCSE could eliminate approximately 50% of the states from an audit every year, and could stagger these
audits to use the auditor’s time most efficiently and effectively. This would allow audits to be completed in a timelier manner, and to allow auditors to work more closely with states that needed additional assistance.
Similarly, in the second tier, if OCSE only needed to audit a measure that had not passed for
at least 2 consecutive years, then 6 of the 44 states could receive an abbreviated audit on 1 measure; 1 state on 2 measures. As discussed above, this would shorten the time to complete the DRA.
Tier 1
Pass all measures all three years: 13 states
Pass all measures 2002 and 2001: 6 states
Pass all measures 2001 and 2000, no data yet available 2002: 3 states
Tier 2
Pass all measures 2002, same measures failed both 2000 and 2001: 3 states
Failed 2002 on one measure, same measure failed 2000 and 2001: 2 states
Failed same measure 2002 and 2000; passed 2001: 1 state
Failed all years on same 2 measures: 1 state
Tier 3
Passed 2002, failed a different measure in 2000 and 2001: 7 states
Passed 2002; failed 2001, passed 2000: 3 states
Tier 4
Failed 2002, passed 2001 and 2000: 1 state
Failed 2002, 2001 (diff measures), passed 2000: 1 state
2002 unknown; fail 2001; Pass 2000; 2 states
2002 unknown; passed 2001; failed 2000: 1 state