Program Integrity for Wisconsin Shares Child Care Providers Child care providers should be aware of responsibilities and rules that may lead to overpayments and more serious enforcement options specific to MyWIChildCare EBT policy. The violation of Wisconsin Shares policies may result in an overpayment and recoupment. Refer to your Child Care Provider Guide for more information and assistance. New Program Integrity Requirements Effective March 11, 2018, Administrative Rule Chapter DCF 201 will be updated to include information related to protecting Wisconsin Shares Child Care Subsidy funds from fraud and misuse. The updated rule will address the MyWIChildCare system of issuing subsidy payments directly to parents. Set yourself up for success by reviewing this list below. Do Have a Written Payment Agreement with each parent who receives subsidy for a child attending your facility. You may use your own form or the template available on the DCF website (DCF-F-5224-E). Notify the local child care administrative agency if a child of parent receiving Wisconsin Shares has not attended within the previous 30 days. Don’t Charge a higher price for families receiving Wisconsin Shares than private pay families, unless the difference is due to the child’s age or special needs. Require a parent to disclose their subsidy account balance. Require a parent to provide their MyWIChildCare EBT card, account number, or personal identification number (PIN). Possess a photocopy, photo, or other image of a parent’s EBT card. Sell or purchase access to the parent’s subsidy account. Misrepresent provider information to receive a higher YoungStar rating. Best Practices Communicate your child care prices to parents Keep your child care information current and accurate - check your Provider Portal often Give parents proper notification of any changes Visit ebtedge.com for direct, 24/7 access to track your payments Communicate regularly with families Never keep a client's MyWIChildCare EBT card, account number or PIN Regarding Payment Payment Disputes The Department and your local child care agency will not resolve payment disagreements between families and providers. Child care providers will be expected to work with families to deal with payment errors or disputes. Disagreements should be handled one-on-one and in a confidential and respectful manner with families. Providers should encourage parents to review your transaction amounts and payment dates online or by calling to speak to MyWIChildCare customer service 1-877-201-7753, who can also help track down any transaction or payment history. Provide receipts and log all payments received from parents. Make sure families know what they are paying for and the period of time it covers. You must communicate openly and regularly with your families to prevent disagreements. If the Parent Overpays First, talk with the family and try to discuss the billing error and why it occurred. Use receipt and payment records to discuss. Make sure families know what they are paying for and the period of time it covers. You should communicate openly and regularly with your families to prevent overpayments and payment disagreements. After discussing the error with the parent, the overpayment must be corrected. This will require the provider to call their local authorizing agency to initiate the Voluntary Repayment Process. Notice Currently, Provider’s future subsidy payments are deduced when subsidy funds are owed to the state and the program still has authorizations. The provider’s funds are decreased until the debt is paid off. After the release of the MyWIChildCare initiative, all overpayments will be repaid out-of-pocket directly to the state. Providers may work with the Public Assistance Collections Unit (PACU) to set a repayment amount that is manageable for them. The provider then will have to submit monthly payments to the PACU monthly to repay this amount until the debt is paid off. A notice was sent out to all participating child care providers during February of 2017. The notice is provided below. Provider Overpayment Notice Change Spanish Hmong Intentional Violations An intentional program violation (IPV) occurs when one knowingly acts against policy to maximize their subsidy and/or for economic gain. This may include, but is not limited to the following: Falsifying your attendance records Asking parents for their MyWIChildCare card, their card number, or their pin – providers found in possession of any of the following may result in permanent suspension from the Wisconsin Shares Program Providers who make payments on behalf of parents. If parents need assistance accessing their funds/account they should call 1-877-201-7753 or go to ebtedge.com for assistance Providing cash, goods, or any service besides child care to parents in return for payment Investigation The Department may conduct an audit to ensure the compliance with the Wisconsin Shares Program. Any provider who is receiving, or has received, Wisconsin Shares payments are subject to an audit at any time. Audit Process Monitoring Visits: the Department will conduct unannounced visits to collect records, interview the provider and/or employees, and to monitor the operation of the facility. Investigation: Is the gathering of documents and reviewing of a variety of systems and history with the Wisconsin Shares Program. Findings: The findings from the record collection and observations will be communicated both in writing and verbally. Outcomes There are various outcomes that can result from an audit. Technical Assistance (TA) TA can be provided by the agency to maintain compliance with the Program rules and policies. Overpayment Issuance Pay back the funds that have been determined as misapplied. Stipulation in Lieu of Termination This is a signed document acknowledging that you understand the rules and will follow the rules. The Department will return to conduct a follow-up audit to assess practice of policy. Permanent Suspension If found to be intentionally violating the Wisconsin Shares Program, the provider can be terminated and may not be allowed to participate in the Wisconsin Shares Program. Appeal Process All actions or penalties established by the Department are subject to an appeal. The client has the right to request a fair hearing before an Administrative Law Judge (ALJ) who will review the findings, the decision, and the reason for appeal. Appeals Process Contact: Division of Hearings and Appeals 5005 University Avenue, Suite 201 P.O. Box 7875 Madison, WI 53707-7875 Or, fax it to 1-608-264-9885.