HomeMy WebLinkAboutMINUTES - 03232004 - C70 - Contra
TO: BOARD OF SUPERVISORS
FROM: INTERNAL OPERATIONS COMMITTEE Costa
1 2004 - County
DATE: MARCH ��
SUBJECT: FOOD STAMP ERROR DATE UPDATE lu
SPECIFIC REQUESTS)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS
1. ACCEPT attached report from the Employment and Human Services Director providing an
update on the statewide and county food stamp error problem, and describing the
Department's success in lowering the County's error rate below the federal tolerance level for
federal fiscal year 2002/03.
2. ACKNOWLEDGE that as a result of corrective strategies implemented by the Department, the
County's estimated food stamp error rate for FFY 2003 will be approximately 4.62%, a 67%
improvement over the 13.99% rate in FFY 2001 that earned this County a federal sanction, and
safely below the preliminary cumulative FFY 2003 federal tolerance level of 6.29%.
3. RECOGNIZE that the California Department of Social Services (CDSS) and the U.S.
Department of Agriculture-Department of Food and Nutrition Services (FNS) made no negative
findings in their audits of the County's food stamp program performed in January and
September 2003, respectively.
4. COMMEND the Employment and Human Services Director and his staff for identifying
contributing factors to the problem, initiating the necessary steps to reduce excessive errors,
and returning the County to an acceptable error rate, thereby avoiding fiscal sanctions.
5. RECOGNIZE that the federal government has informed the State of California that it will not
grant the requested indemnification from quality control reviews and potential fiscal penalties
during California's transition to the Quarterly Status Reporting/Prospective Budgeting cycle and
the CALWIN system, and that reinvestment dollars that have sustained quality control efforts
may not be available in future years.
6. RECOGNIZE that budgeted"reinvestment"funds (that is, the fiscal penalties that this County
was permitted by the federal government to reinvest in food stamp error reduction strategies)
may become exhausted before the end of County fiscal year 2004{05 and that the error
reduction strategies supported by reinvestment funds will need to be sustained in future years
to assure high quality program administration and avoid potential fiscal sanctions.
7. DIRECT the Employment and Human Services Director to report back to the Internal
Operations Committee in March 2005 on the County's food stamp performance in FFY 2004.
CONTINUED ON ATTACHMENT. YES SIGNATURE:
RECOMMENDATION OF COUNTY ADMINISTRATOR _-1,:::�kECOMME TI N OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S)y_
GAYL . U 1-KEMA, CHAIR MRK DeSAULNIER
ACTION OF BOARD ON March 23. 20(Y4 _APPROVE AS RECOMMENDED X OTHER
MOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE AND CORRECT
COPY OF AN ACTION TAKEN AND ENTERED
X UNANIMOUS(ASSENT _ Bone 1 ON THE MINUTES OF THE BOARD OF SUPERVISORS
ON THE DATE SHOWN
AYES: NOES: ATTESTED: MARCH 23,2003
ABSENT: ABSTAIN: JOHN SWEETEN,CLERK OF THE BOARD OF
SUP ISORS AND COUNTY ADMINISTRATOR
s
CONTACT: JULIE ENEA(925)335-10'77 BY � DEPUTY
CC: INTERNAL OPERATIONS COMMITTEE STAFF
EMPLOYMENT&HUMAN SERVICES DIRECTOR
COUNTY ADMINISTRATOR
Food Stamp Error tete March 1, 2004
Internal Operations Committee gage 2
BACKGROUND
On February 5, 2002, the Board of Supervisors received a letter from the State Department of
Health and Human Services appealing to the Board to make a strong commitment to
improving California's overall performance in administering the Food Stamp Program. The
letter indicated that Contra Costa County's error rate for 2001 was expected to be above the
federal tolerance level for Food Stamp Program errors. To affirm the Board's commitment to
improving overall performance, the Board, on May 21, 2002 directed the Internal Operations
Committee (IOC) to review the County's Food Stamp Program performance with the
Employment and Human Services Department (EHSD), and oversee the preparation of the
Corrective Action Plan.
The IOC has continued to monitor the food stamp error rate with EHSD, and has reported to
the Board of Supervisors with updates on June 25, 2002, and January 7 and October 28,
2000. The reports described the corrective actions planned and implemented by EHSD and
indicated a steady improvement in the County's error rate. The EHSD Director clarified early
on that the error rate was primarily related to worker errors in determining eligibility, and not to
worker or client fraud in either eligibility determination or benefits issuance. Based on that
information, EHSD developed a corrective action plan and has taken a series of steps to
implement that plan over the 14 months.
We are pleased to be able to report to you that the corrective strategies implemented by
EHSD have resulted in a 67% reduction in the County's food stamp error rate for FFY 2003.
The current error rate of 4.62% is below the preliminary cumulative FFY 2003 federal
tolerance level of 6.29%, demonstrating that EHSD has effectively met the challenge of
reducing the County's error rate in a responsible fashion.
Note also that the California Department of Social Services (CRSS) and the U.S. Department
of Agriculture-Department of Food and Nutrition Services (FNS) made no negative findings in
their audits of the County's food stamp program performed in January and September 2003,
respectively. The auditors acknowledged many "best practices" implemented by EHS,
including staff's thorough understanding of quality control efforts and a top-down commitment
to quality control.
The charts in the attached report depict long-term experience in the County, State, and
Federal error rates, and monthly experience since October 2002 in the County's error rates.
We noted the wide variation in error rates from month to month, which we understand are
attributable to the random sampling of cases each month. One discernable trend is a
consistent spike in the error rate during the month of June. In the attached report, the EHS
Director advises that the June spike results from the method used by the FNS to sample
cases and does not result from an increase in the number of errors during June. The FNS
takes a larger sample of cases during the Fall and Winter months and a smaller sample of
cases during the Summer months, making the Summer average appear higher.
In addition, our Committee continues to be concerned about pending events that may
negatively impact error rates:
♦ Exhaustion in FY 2004/05 of reinvestment funds to maintain error reduction efforts (of the
$899,000 available, $753,000 was budgeted in fiscal years 2002/03 and 2003/04, leaving
a balance of$146,000 for fiscal year 2004/05)
♦ Conversion from monthly to quarterly status reports*
s Conversion to the new Quarterly Status Reporting/Prospective Budgeting cycle
♦ Implementation of the new CalWIN welfare payment and tracking system scheduled for
roll-out in Summer 2005*
♦ The Governor has proposed a 9% cut to the Food Stamp Program for fiscal year 2004/05
For these reasons, the IOC recommends that this issue be kept on referral and that the
Employment and Human Services Director be directed to report back to the IOC in March
2005 to provide an update on the County's performance for FFY 2004.
"The United States Depertrmnt of Agriculture—Food and Nufrttion Service, ft oversight agency for food stamps, fres r'nthrmed the State of
Caftmm that if will not grant the requested indamnlficatiorr from qualify control reviews and pofentlal fiscal penalties during Callfomia's
fransifion to the Quarterly Status ReportinglProspectfve Budgeting cycles and the CaIWIN systems.
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EMPLOYMENT AND HUMAN SERVCES
CONTRA COSTA COUNTY
To: Supervisor Federal Glover Date. March 1, 2004
Supervisor Gayle B. Uilkema
Internal Operations Committee
From. John B. Cullen, Director
Subject. Food Stamp,Error Efate
Recommendations
ACCEPT the report presented by the EHSD Director on the status of efforts to im-
pact the Food Stamp error rate;
REPORT DIT to the Board of Supervisors regarding success in achieving the goal
of lowering Contra Costa's rate below the Federal Tolerance Level.
FOOD STAMP ERROR RATE AND CORRECTIVE ACTION UPDATE
CURRENT STATUS /RESULTS
This report is in follow up to our October 2003 presentation on the Food Stamp Er-
ror Rate. The committee asked that we return at this time to provide an update on
our corrective action activities and the results in lowering the error rate for the most
recent Federal Fiscal Year(FFY), October 2042 through September 2003.
The Employment and Human Services Department (EHSD) has successfully com-
pleted the latest Federal reporting period with an error rate below the Federal toler-
ance level established by the United States Department of Agriculture (-USDA),
Food and Nutrition Services (FINS). While the official numbers will not be final-
ized until June 2004, the preliminary cumulative Federal tolerance level for FFY
2003 is 6.29% and the EHSD error rate for FFY 2003 is 4.62%. The Contra Costa
County results are a 56% reduction from the FFY 2002 10.56% error rate, and a
67%reduction from FFY 2001's 13.99�',�� (see Attachments 1 and 2). The threat of
future fiscal sanctions may be eliminated if California maintains this level of im-
provement.
Internal Operations Committee
Food Stamp Error Rate
March 1, 2004
Page 2 of 9
BACKGROUND IN ERRORS AND CORRECTIVE ACTION
While previously mentioned in our reports dated June 10, 2002, december 6, 2002,
July 21, 2003 and October 13, 2003, we believe that there are a variety of factors
that have contributed to this Food Stamp error rate problem.
• Line staff has a broad responsibility for CaIWORKs, Medi-Cal and Food
Stamps and all support services (transportation, child care, housing, etc.)
for their assigned families.
• Over the past eight years, the national, state and local focus has been on
the implementation of the Welfare-to-Work program with its emphasis
on employment rather than Food Stamp eligibility determinations.
• Transfer of experienced staff from ?Non-Assistance Food Stamps and
Medi-Cal assignments to more rewarding CaIWORKs assignments
has resulted in predominately less experienced staff responsible for
benefit determination.
• Growing complexity and regular changes in the Food Stamp program
rules and regulations have made it difficult to keep staff trained., as well
as to routinely identify and correct payment errors.
• State budget reductions in the past two fiscal years have reduced state
funding for CalWORKs and Medi-Cal staffing. This has forced larger
workloads in these areas, further eroding worker time available for Food
Stamps program management.
These factors have a significant impact with our ability to maintain the lowered er-
ror rate. Further budget reductions and uncertainties may complicate our ability to
continue to implement the same corrective action measures.
FFY 2003 RESULTS
During FFY 2003 the trend of a higher error rate during the summer months (May-
September) continued. The major contributing factor to our summer month spike is
systemic. FINS requires 282 completed QC reviews for each FFY. To ensure that
the department meets this mandate, a larger number of reviews are completed early
in the FFY to allow for flexibility should adjustments be necessary. This results in
fewer cases sampled during the final months in the review period, thereby diluting
the total pool of benefits in the latter months of the FFY. Consequently, each error
cited in the latter months disproportionately affects the error rate as compared with
the earlier months. .
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Food Stamp Error Rate
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Potential Remedy.
• Adjust the sampling methodology to balance the number of QC cases
sampled throughout the entire FFY, and
• Concurrently, drop fewer cases in each month's sample.
> Examine the nature of our dropped cases, and
➢ Train QC staff in successful methods to avoid dropped cases.
An overhaul of administration of the Food Stamp program has produced positive
results. We have developed a comprehensive Corrective Action Plan (CAP) as a
blue print for our error reduction efforts. The CAP builds upon efforts identified in
the prior year reports (June and December 2002, July and October 2003). These
efforts include:
• Food Stamp Corrective Action activities have been assigned to the East
County Operations Division Manager, who also has responsibility for
Food Stamps policy.
• In order to improve communication and interdepartmental cooperation,
the functions of Food Stamp Policy, Quality Control and Corrective Ac-
tion have been restructured to report to the Food Stamps Program man-
ager.
• A Quality Control Error Citation Workgroup meets monthly to review
formally identified case errors and attempt to structure formal rebuttals to
State-cited errors, identify casual factors, develop procedures to avoid fu-
ture errors and to brainstorm creative methods to reduce the error rate.
• Senior executive staff meet monthly with the Corrective Action Food
Stamp Program Division Manager, Food Stamp Program Analyst, Pro-
gram Integrity Coordinator, QC supervisor and other key staff to give
overall policy direction and to ensure that the necessary resources are
made available for corrective action efforts.
• We developed and launched a new, comprehensive 15-module Food
Stamp training program for eligibility staff. "Training session topics have
been carefully designed to focus on those program areas we have
identified as contributing to our error rate, including determination of
income, income and shelter deductions, determination of household
composition, non-citizen eligibility, resource determination and work
registration requirements.
+ Commencing in March 2003, all staff and supervisors responsible for
Food Stamps have been required to take a monthly online quiz. This quiz
is open book, open resources so workers are able to access their Food
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Food Stamp Error Rate
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Stamp Handbook, training materials, Hot 'Pips and desk guides while tak-
ing the test. The results of the quizzes are used to customize future train-
ing to address problem areas. Additionally, the results of the quiz may be
used in coaching and counseling sessions with poorly performing staff as
necessary.
• Effective in May 2003, intake supervisors started targeted reviews of
Food Stamp cases prior to transferring thein to the continuing units.
These case reviews are subject to a random "re-review" and become part
of the accuracy and accountability reports. The analysis of intake re-
views has provided a comprehensive method of identifying error trends
and training needs for the department.
«� A training session will be conducted in March 2004 for newly appointed
supervisors and experienced supervisors who need a refresher course on
how to correctly complete the supervisory case review.
+ Short term, "get the errors down" strategies have been implemented in-
cluding Operation dean Sweep, Hot Topics Focused Reviews and Hot
Tip policy clarifications for staff to review and correct. Hot Tips con-
tinue to be instrumental in delivering messages and reminders to staff.
STRATEGIES IMPLEMENTED SINCE OCTOBER 2003
• Since our report in October 2003, 1 6.5 hours of training was dedicated to
providing staff an overview of Quarterly Reporting and Prospective
Budgeting (QRI'B) changes scheduled for implementation in June 2004.
303 staff attended. Due to the complexity of these changes, Staff Devel-
opment, the Food Stamp Program Analyst, and CalWORKs Program
Analyst conducted this overview.
• A Program Integrity Coordinator (PIC) was hired on November 17, 2003
and is responsible for all corrective action activities. The PIC reports di-
rectly to the Food Stamp Program Manager.
• Twenty-four (24) new Eligibility Workers were hired on January 12,
2004 and assigned to the CalWORKs and Medi-Cal programs. Of the 24
hired, 12 will have Food Stamp responsibilities in tandem with their
CalWORKs assignment. Food stamp training efforts have been targeted
to this group to ensure that staff is able to effectively process food stamp
actions upon their arrival in the district offices.
• EHSD remains committed to previous "improve the ongoing accuracy"
strategies which include:
➢ Implementation of an ongoing process of supervisory reviews to as-
sure accuracy and accountability in the Food Stamp Program,
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Food Stamp Error Rate
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➢ Review of a sampling of these cases to guarantee valid reviews have
been conducted,
➢ Distribution of the resulting accuracy rates to all operational managers
and unit supervisors,
Ongoing training for line staff,
➢ Separate training for supervisors,
➢ Creation of Food stamp policy desk guides, and
➢ New and fully assembled handbooks were distributed to each unit and
unit supervisor in January 2004, to supplement the online version of
the Food Stamp handbook.
FUTURE STRATEGIES
• In preparing for the June 2004 implementation of QRPB policy changes,
formal training sessions will be conducted in. April 2004 for approxi-
mately 250 Food Stamp staff.
• Computer Based 'Training (CBT) is being developed to provide experi-
enced staff with a means to improve and enhance current skills and pro-
gram knowledge. It is anticipated that this will become fully operational
by May 2004,
• An online Supervisory Review application has been developed to auto-
mate the Supervisory Review process. Several supervisors participated in
a pilot of the project in November 2003. We anticipate completion of the
online Supervisory Review tool in August 2004. This application will of-
fer a vehicle to access the results of all supervisory reviews in "real
tune".
• The creation of a Program Integrity Unit, supervised by the PIC, which
will be responsible for targeted reviews of casework accuracy and re-
views of supervisory case reviews.
• Creation of a Department Corrective Action Committee. Committee will
be chaired by the Program Integrity Coordinator and comprised of super-
visors and workers from each of the District offices responsible for the
Food Stamp Program. It will be a forum to discuss and receive feedback
regarding Food Stamp error trends and corrective action activities with
line staff.
• Development of a department newsletter dedicated to corrective action
strategies. Newsletter is intended to support the importance of our cor-
rective action activities and highlight our strategies to maintain a low er-
ror rate. The newsletter will be issued quarterly to all line staff responsi-
ble for the Food Stamp Program. It will identify the QC errors cited dur-
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ing the last three months and the actions taken at the QC Error Citation
Workgroup to mitigate the errors.
EHSD SUCCESSES
With the aforementioned strategies, and commitment of staff, EHSD has been able
to demonstrate significant improvement in the past FFY. The Food Stamp error rate
has been reduced by 56% from 10.56% in FFY 2002, to 4.62% in FFY 2003.
As result of our restructuring and placing Food Stamp Policy, Quality Control and
Corrective Action with the Food Stamp Program Manager, interdepartmental coop-
eration has shown: tremendous improvement. There is greater participation among
responsible staff as corrective action discussions are now taking place immediately
after the possibility a Quality Control error has been identified. There is a more co-
hesive and collaborative work environment working toward a rebuttal of Quality
Control error citations.
Guidelines for the completion of QC case reviews are mandated in the FNS 310,
Quality Control Review Handbook. In July 2003 all Quality Control staff, the Food
Stamp Program Analyst, and the Food Stamp Program Manager attended training
along with other QC counties on the correct use of the FNS 310, which changed the
way QC does business. In addition, training is to be conducted in February 2004
that addresses the QC culture change that is occurring at State and Federal levels,
which will impact the way that the County QC operates.
As a means to recognize staff and their contributions to improved payment accu-
racy, certificates will be distributed in March for individuals who had a QC case re-
view and no case errors. Each district office will also receive a plaque for efforts
made to significantly lower our error rate. EHSD's Director will present these in an
all staff meeting. In attendance during these presentations will be the respective
Program Directors, Food Stamp Program Manager, FS program Analyst, QC super-
visor, and Program Integrity Coordinator.
OUTSIDE AUDITORS
FNSregularly audits counties' QC systems. In September 2003, FNS completed
Contra Costa's audit with favorable results. The objective of the review was to ex-
amine the role QC plays in corrective action, and the process EHSD employs to en-
sure the integrity and correctness of the State only QC sample. The results are as
follows:
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• The "re-review of completed cases gives us a picture of County QC
staff s understanding of both certification and QC policy", and that "QC
has established effective working relationships with all parts of the
agency with whom they interface".
• FNS was also "extremely impressed by the communication among enti-
ties in the County." In addition, they were "pleased to find the program
manager's dedication to payment accuracy and program improvement has
been embraced throughout all levels of the Food Stamp Program".
• ,Acknowledged Best Practices included:
A QC contacts program analyst in order to ensure validity of the error as
well as provide insight into error trends as they develop.
➢ QC error citation monthly meeting in which all reviews cited with an
error are discussed among the QC supervisor, Eligibility supervisors,
Division Manager, Program Analyst, and Program Manager.
> Files were well organized.
➢ All QC reviews, are second party reviewed by the QC supervisor with
or without an error cited.
• Other best practices included:
➢ Interest and commitment demonstrated by the Contra Costa County
Board of Supervisors' Internal Operations Committee and EHSD's
Department Director to payment accuracy.
➢ Communication provided via the ".Hot Tip", monthly bulletins, and
monthly quizzes are an excellent means for sharing policy updates
and reminders, as well as identifying areas in which staff need train-
ing.
9 The development of the Program Integrity Unit.
S> On line availability to staff of policy guidance, manuals, and an-
nouncements.
The California Department of Social Services (CDSS) completed a separate audit in
January 2403. Strengths identified during this review include:
• Active and informed commitment to payment accuracy from the Director
and senior management, including the Corrective Action Manager, which
is a key to improving and maintaining payment accuracy.
• A strong two-tiered secondary review process that provides an accurate
measure of accountability for all county staff, a proactive error prevention
capability and an enhanced program and policy knowledge among line
staff.
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Food Stamp Error Rate
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'age 8 of
• Development of the food stamp handbook, an effective tool in reducing
the errors caused by incorrect application of food stamp policy and regu-
lations.
• Use of Discoverer database system in a proactive way to detect and cor-
rect error prone area.
FUTURE IMPACTS
Although our efforts to achieve and sustain an error rate that is at or below the Fed-
eral tolerance level have been successful, there are several major changes within the
next two years that could possibly affect the Food Stamp error rate.
In June 2004, EHSD will convert from monthly reporting and retrospective budget-
ing to {quarterly Status Reports (QSR) and prospective budgeting (PB). Due to the
learning curve associated with the implementation of this program change, it is an-
ticipated that there will be an increase in the error rate. FNS has informed Califor-
nia that they will not grant a"hold harmless" period for this program change. In an
attempt to alleviate this possible increase in the error rate, Staff Development will
provide training prior to implementation. This training will take place April 2004.
Corrective action activities will immediately follow the training session. "These will
include: QSR. related concepts in the Food Stamp quiz and exercises developed to
allow unit supervisors and staff an opportunity to practice and discuss the new pol-
icy concepts.
EHSD is involved with the design and development of a new welfare payment and
tracking system.. The system, CalWIN, requires an investment of staff resources as
we prepare to changeover to this new system in October 2005. As implementation
of CaIWIN draws closer, additional staff resources must be dedicated to the conver-
sion. With this change in systems, we are anticipating the potential for an increase
in the error rate. EHSD staff is working closely with the California Department of
Social Services (CRSS) and FNS to proactively address error prone new system
procedures.
In addition, reinvestment funds may not be available in future years to sustain many
of the efforts initiated during the past two fiscal years. Reinvestment funds are
county dollars that were owed to the Federal government during the past two years
as a fiscal sanction for our previously high Food Stamp error rate, which we were
permitted to `reinvest" in corrective action activates. These funds have been a cru-
cial element in funding additional staff positions responsible for various Food
Stamp corrective action activities. Program Integrity staff being hired during this
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fiscal year will be paid for with reinvestment Funds. County dollars will be needed
to fund the Program Integrity Unit (PIU). One Program Integrity Coordinator
(PIC), four Program Integrity Assistants (PIA,), and one Senior Level Clerk will
staff' this unit. The approximate cost for this unit is $753,0000 (4.5 fully-loaded
FTEs). Additionally, the overtime for staff and supervisors to complete additional
quality control reviews has been financed by reinvestment funds. These efforts will
need to be sustained in future years to assure that we have the capability to conduct
systematic reviews of supervisory actions, to perform ongoing monitoring of pro-
gram accuracy, and to provide technical assistance to Food Stamp staff.
The reinvestment funds that we anticipate using to fund the PIU will be county dol-
lars. Reinvestment of $899,000 county dollars will offset the federal fiscal Banc-
tion. If our county chooses not to reinvest these funds, a sanction of $899,000
county dollars must be paid to the USIA.
Due to workload and staffing shortages at the State level, an area of concern is the
lack of policy direction available to the EHSD's Food Stamp Program Analyst. The
California Department of Social Services has formally advised counties that ana-
lysts may not contact their department with Food Stamp polio questions unless it
relates to a specific QC error citation. With the limited ability to ask questions as
they arise, counties will be forced to make decisions based on a consensual agree-
ment with other counties.
E\SwkrTood StwWsWS Ermr hate to 10 Corson 03-04.doc
02,'18/04
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