07.04.01 - Overpayments

Effective Date: 01/01/00
Revised:  12/18/06; 09/17/09; 06/10/13

Reference: 89 Ill. Adm. Code, Chapter IV, §50.130

Policy Statement:

The Department will recover overpayments from providers or parents and other relatives, as appropriate, through demand letters, referrals to the Comptroller's Office for withholding, referrals to collection agencies, reductions in future payments or public assistance benefits, or other means determined by the Department to be effective.

Applicability:

These procedures apply to all Site Contracted providers and CCR&Rs.

Procedures:

An overpayment includes, but is not limited to, a payment made that should not have been made, a payment for an ineligible recipient, any payment for an ineligible service, any duplicate payment, a payment for services not received, a payment for excess services, and any payment that does not account for applicable discounts.

  1. The cause of each overpayment shall be classified as administrative error, client error, or provider error.
    1. An overpayment shall be classified as an administrative error if the error was caused solely by actions taken by the department or its agent. An administrative error includes, but is not limited to, an error caused by:
      1. Incorrect application of any Federal or State regulation, policy or procedure;
      2. Data entry error;
      3. Oversight or omission;
      4. Calculation error; or
      5. Fraud committed by an individual who works for the CCAP program.
    2. A client error includes, but is not limited to, an error that occurs when:
      1. The client fails to report or falsely reports income or household composition that affects the amount of the parent copayment.
      2. The client would not have been eligible if income, hours of employment or education/training activity, the need for child care, or the household composition had been accurately reported.
      3. The client fails to timely report a change in income, hours of employment or school, household composition or provider arrangements and the change would have resulted in a lesser benefit received.
    3. A provider error includes, but is not limited to, an error that occurs when:
      1. The provider receives payment in excess of services rendered (i.e. parent changes providers with proper notification and the original provider bills for days beyond the last day of care);
      2. The provider receives duplicate payments for services provided;
      3. The provider does not comply with program policies (i.e. the provider charges the subsidized parent more than they charge private pay parents.)
      4. The provider bills for children no longer in their care;
      5. The provider bills for full time care when the children were only eligible for or attended part time care;
      6. The provider inaccurately reports his or her relationship to the child or the location at which care is given;
      7. The provider bills for more days than the child is approved; or
      8. The provider bills for licensed care but does not possess a DCFS license.
  2. As soon as an overpayment is identified, staff shall prepare an Overpayment Referral Packet.
    1. Complete the Child Care Overpayment Referral (IL444-1900 - Child Care Overpayment Referral (pdf)) and the Child Care Overpayment Calculation Worksheet (request from DHS.CCAP.Policy@illinois.gov).
      1. The Overpayment Referral and the Calculation Worksheet must be typed.
      2. Complete all blanks. If information does not apply, enter N/A.
      3. Check/indicate all program violations that apply.
      4. Provide a summary of the program violation(s). Be specific and concise, but do not use abbreviations.
    2. Gather supporting documentation.
      1. Include all written documentation to support or defend that an overpayment occurred. Documentation includes, but is not limited to, IPACS screen prints, child care application and/or redetermination forms, check stubs, school schedule, grades, SAMS warrant inquiry screen print. Other suggestions are listed on page 2 of the Overpayment Referral form.
      2. The Pre-Payment Detail Inquiry Screen and the Payment Inquiry (PF-11) screen prints for each overpayment month are mandatory. If these screen prints are missing, the referral packet will be returned.
      3. Supervisors should review and approve each overpayment referral. Supervisors must sign and date the referral on page 2.
  3. Distribution
    When preparing the overpayment packet, please do not staple pages together and only make single-sided copies.
    1. Send the original Overpayment Referral packet to:
      IDHS - Bureau of Child Care & Development (BCCD)
      100 South Grand Avenue East,2nd Floor
      Springfield, IL 62762-0002
    2. Keep a copy of the overpayment packet for the client file.
  4. Springfield BCCD will review the Overpayment Referral and will either approve or deny the claim.
    1. If the case does not meet the overpayment criteria, BCCD will deny the referral and notify the referring agency.
    2. If the case meets the criteria for overpayment, BCCD will issue the Overpayment letter. Copies of the letter will be sent to:
      1. the referring entity (CCR&R or Site) and
      2. IDHS Bureau of Collections. At this point, IDHS Bureau of Collections establishes the debt in CARS, issues the second and subsequent overpayment letters, and collects the payments.
  5. Payments
    All payments are handled by IDHS Bureau of Collections.  Providers who wish to have monthly payment reductions from future payments shall coordinate this option with Bureau of Collections and Bureau of Child Care & Development.
  6. All overpayment inquiries shall be directed to the BCCD, Policy and Customer Assistance Unit at DHS.CCAP.Policy@illinois.gov.
    1. If the debtor submits written documentation to reduce the debt, BCCD will issue a new letter indicating the new balance. The CCR&R/Site provider and Bureau of Collection will receive a copy of the new letter.
    2. If the debtor submits written documentation to eliminate the debt, BCCD will issue a letter to rescind the overpayment. The CCR&R/Site provider and Bureau of Collection will receive a copy of the letter.
  7. Sanctions
    BCCD will monitor the repayment history through the Bureau of Collections via the CARS system and will notify the CCR&R or Site when a sanction is to be imposed on the debtor.