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CHILD CARE STABILIZATIONGRANTEE INTERNAL CONTROLSSelf Assessment InstrumentThis self assessment instrument was developed to supplement the brief “Strengthening StabilizationGrant Integrity with Internal Controls.” Together, the documents guide Lead Agencies when reviewingand evaluating their internal controls and fraud prevention strategies related to the child carestabilization grant.Self Assessment ElementsThe Child Care Stabilization Grantee Internal Controls Self Assessment Instrument includes threesections of elements with corresponding items and considerations. Section I: Provider Application and Eligibility– Grantee ensures consistent application of stabilization subgrant program rules across allpopulations and jurisdictions.– Grantee has routine internal control processes for determining that providers are eligible andqualified for the stabilization subgrant. Section II: Provider Payments– Grantee assures the accuracy of award payments for child care stabilization subgrants.– Grantee has overall responsibility for program integrity and financial accountability of thestabilization subgrant program. Section III: Prevention– Grantee program integrity and accountability efforts assure effective internal control over theadministration of stabilization subgrant funds.– Grantee uses internal and external information sources and collateral contacts to prevent fraud inthe stabilization subgrant program.June 20211
Child Care Stabilization Grantee Internal ControlsSelf-Assessment InstrumentSection I: Provider Application and Eligibility ElementsItem #1Grantee ensures consistent application of stabilization subgrant program rules across all populations andjurisdictions.P.L. 117-2 American Rescue Plan (ARP) Act of 2021Considerations — Grantee:Developed a process to accept applications andprocess them on a rolling basisPosts applications and certifications and they areeasily accessible on the Lead Agency’s websiteand provided in multiple languages1Developed written stabilization subgrant programpolicies and proceduresMaintains a system for documenting policy andprocedural clarificationsDeveloped stabilization subgrant program curriculaand provided training to staffImplemented stablization subgrant applicationquality reviews to ensure subgrant applications areprocessed timely and accuratelyYesMostlySomeNo Brief Description1 Tribes that do not have a child care website must post it on a website associated with the tribe so that child care providers know the application is legitimate and from a trustedsource. nts/occ/CCDF-ACF-IM-2021-02.pdfEvaluation ResultsFindingsMitigation and Action StepsPriority Level:Follow Up:June 2021LowYesMediumHighNo2
Child Care Stabilization Grantee Internal ControlsSelf-Assessment InstrumentSection I: Provider Application and Eligibility ElementsItem #2Grantee has routine internal control processes for determining that providers are eligible and qualified forthe stabilization subgrant.P.L. 117-2 American Rescue Plan (ARP) Act of 2021Considerations — Grantee:YesUses licensing data, vital statistics records,and other information sources to confirm theprovider’s eligibility on the date of applicationsubmissionMostlySomeNo Uses a consistent, documented process forconfirming a provider eligible and qualified asdefined in the ARP Act Reviews other assistance program data (e.g.Child and Adult Care Food Program, HeadStart, SNAP) to identify inconsistencies in theinformation reported to the program office onqualified providers Uses an independent provider and businessverification process (e.g., Secretary of State,Social Security Administration, DUNS, IRSfederal and state identification numbers) Brief DescriptionEvaluation ResultsFindingsMitigation and Action StepsPriority Level:Follow Up:June 2021LowYesMediumHighNo3
Child Care Stabilization Grantee Internal ControlsSelf-Assessment InstrumentSection II: Provider Payments ElementsItem #1Grantee assures the accuracy of award payments for child care stabilization subgrants.P.L. 117-2 American Rescue Plan (ARP) Act of 2021Considerations — Grantee establishesadequate internal controls to ensure:Appropriate segregation of roles andresponsibilities for eligibility determination, paymentprocessing, and payment issuanceProvider subgrant expenditures are defined andallowable in accordance with the ARP ActPrevention strategies implemented to reduceimproper payments resulting from fraud and/orunintentional program violationsProcesses in place to identify risk areas related tostabilization subgrant payment processingStabilization subgrant payment disbursements aremade in accordance with the ARP ActSystematic process to determine subgrant amountsthat support equity and high-quality child care whilelimiting burden on child care providersYesMostlySomeNo Brief DescriptionEvaluation ResultsFindingsMitigation and Action StepsPriority Level:Follow Up:June 2021LowYesMediumHighNo4
Child Care Stabilization Grantee Internal ControlsSelf-Assessment InstrumentSection II: Provider Payments ElementsItem #2Grantee has overall responsibility for program integrity and financial accountability of the stabilizationsubgrant program.P.L. 117-2 American Rescue Plan (ARP) Act of 2021Considerations — Grantee:YesEstablishes a structure that provides appropriateadministrative oversight and controlDefines and communicates key areasof administrative authority and reportingrelationships throughout the organization,including partner agencies, subrecipients, andcontractorsEstablishes institutional processes for monitoringARP Act activities and expenditures at all levelsof administrationMostlySomeNo Brief DescriptionEvaluation ResultsFindingsMitigation and Action StepsPriority Level:Follow Up:June 2021LowYesMediumHighNo5
Child Care Stabilization Grantee Internal ControlsSelf-Assessment InstrumentSection III: Prevention ElementsItem #1Grantee program integrity and accountability efforts assure effective internal control over theadministration of stabilization subgrant funds.P.L. 117-2 American Rescue Plan (ARP) Act of 2021Considerations — Grantee:YesEstablishes a program integrity and financialaccountability planning processDefines and communicates the importance ofprogram integrity and ethical values throughout theorganizationInforms providers and the public of their roles andresponsibilities for maintaining program integrityEvaluates the impact efforts to reduce programfraud, waste, and abuse have on program costsand workloadAssures program integrity efforts do not imposeunnecessary barriers to program access forqualified eligible providersProvides initial and ongoing technical assistanceand training to providers, including but not limitedto assistance in applying for subgrant funding,complying with reporting, and implementationrequirements Mostly Some No Brief DescriptionEvaluation ResultsFindingsMitigation and Action StepsPriority Level:Follow Up:June 2021LowYesMediumHighNo6
Child Care Stabilization Grantee Internal ControlsSelf-Assessment InstrumentSection III: Prevention ElementsItem #2Grantee uses internal and external information sources and collateral contacts to prevent fraud in thestabilization subgrant program.P.L. 117-2 American Rescue Plan (ARP) Act of 2021Considerations — Grantee:Accesses other program information systems toverify if a provider is qualified and eligibleProvides training on fraud and improper paymentprevention and detection resources and techniquesfor subgrant funding (e.g., data mining, regularpolicy and process updates)Coordinates with the auditors, quality control, andother oversight agencies and service providers inpreventing and detecting fraudEstablishes specific verification practices for errorprone or high-risk applications (e.g., high riskapplications may require an onsite visit)Uses established policies and processes to verifythe identity and address of eligible providersIdentifies subgrant applications with potential fraudrisks with an error-prone profile before determiningeligibility and authorizing subgrant paymentsYesMostlySome NoBrief DescriptionEvaluation ResultsFindingsMitigation and Action StepsPriority Level:Follow Up:June 2021LowYesMediumHighNo7
Self-Assessment Instrument June 2021. 3. Item #2. Grantee has routine internal control processes for determining that providers are eligible and qualified for . the stabilization subgrant. P.L. 117-2 American Rescue Plan (ARP) Act of 2021. Section I: Provider Application and Eligibility Elements. Considerations — Grantee: Yes
