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Report to Congressional Addressees: 

United States Government Accountability Office:
GAO: 

September 2010: 

Child Care and Development Fund: 

Undercover Tests Show Five State Programs Are Vulnerable to Fraud and 
Abuse: 

GAO-10-1062: 

GAO Highlights: 

Highlights of GAO-10-1062, a report to congressional addressees. 

Why GAO Did This Study: 

Through the Child Care and Development Fund (CCDF), the U.S. 
Department of Health and Human Services (HHS) subsidizes child care 
for low-income families whose parents work or attend education or 
training programs. In fiscal year 2009, the CCDF budget was $7 
billion. States are responsible for determining program priorities and 
overseeing funds. Providers—who range from child care centers to 
relatives—bill the state for caring for approved children. Unregulated 
relatives represent 12 percent of providers in the CCDF program. In 
response to program fraud and abuse, GAO (1) proactively tested 
selected states’ fraud prevention controls, (2) examined closed case 
studies of fraud and abuse, and (3) interviewed parents waitlisted for 
child care about the effect of this lack of assistance on their 
families. 

To do this, GAO investigators posed as parents and unregulated 
relative providers in 10 scenarios in five states with no waiting 
lists that each received more than $100 million in CCDF funding for 
fiscal year 2009. These states did not require fingerprint criminal 
history checks or site visits. For case studies of past program fraud, 
GAO reviewed criminal court records and interviewed agency officials. 
GAO spoke with parents on waiting lists in six states for their 
perspectives on the effect of being unable to obtain childcare. 
Results cannot be projected beyond these states or unregulated 
relative providers. 

What GAO Found: 

The five states GAO tested lacked controls over child care assistance 
application and billing processes for unregulated relative providers, 
leaving the program vulnerable to fraud and abuse. Posing as 
fictitious parents and relative providers, GAO successfully billed for 
$11,702 in child care assistance for fictitious children and parents. 
In most cases, states approved GAO’s fictitious parents who used 
Social Security numbers of deceased individuals and claimed to work at 
nonexistent companies. One state also approved a fictitious child care 
provider with a deceased person’s Social Security number, creating the 
possibility that a criminal using a stolen identity could obtain 
federal subsidies to care for children. In two other states, GAO 
successfully billed for hours exceeding those authorized without 
submitting proof of additional hours worked. One state successfully 
prevented both fictitious applicants from being accepted, but had weak 
payment controls. 

GAO identified five recent closed criminal cases in which parents and 
providers defrauded the CCDF program. These cases involved parents 
falsifying eligibility documentation, providers billing states for 
fictitious children, and collusion between parents and providers to 
obtain payment for services that were never provided. 

Table: Examples of Fraud in Child Care Assistance Programs: Closed 
Criminal Cases from 2007-2009: 

Amount: $122,615; 
State: Oregon; 
Case Details: 
* Claiming to be separated, a married couple living together qualified 
separately for child care assistance using two fictitious providers. 
* Husband used fake IDs to cash checks paid to fictitious providers.
* Husband sentenced to 8 years in prison, wife sentenced to 3.5 years. 

Amount: $361,000; 
State: Wisconsin; 
Case Details: 
* Two providers gave parents fraudulent documentation to help them 
qualify for child care assistance, then offered them free housing in 
exchange for enrolling their children at the providers’ facility.
* One provider sentenced to 5 years in prison, other provider 
sentenced to 30 days. 

Amount: $150,310; 
State: Indiana; 
Case Details: 
* Two providers fraudulently billed the state for hours during which 
child care could not have been provided. 
* One provider failed to disclose that a twice-convicted felon lived 
in the day care home and interacted with the children. 
* Two providers were sentenced to 2 years in prison. 

Source: GAO. 

[End of table] 

Fraudulent payments reduce program funds available for eligible 
parents who depend on child care assistance to maintain employment or 
attend education programs. In some states, waiting lists are 1 to 2 
years long. Parents on waiting lists said that without child care, 
they contend with multiple hardships—facing financial difficulties, 
quitting their job or education program, and worrying about negative 
effects on their children’s development. 

In response, many of the states tested noted that they have plans to 
implement new controls, but expressed concern about associated cost 
and legal implications. HHS officials commented they have recently 
taken actions to address issues of CCDF integrity, including issuing 
program guidance on verification procedures and conducting conference 
calls on program integrity. 

View [hyperlink, http://www.gao.gov/products/GAO-10-1062] or key 
components. For more information, contact Gregory D. Kutz at (202) 512-
6722 or kutzg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Vulnerabilities Identified in Five States' Fraud Prevention Controls: 

Case Studies Indicate That Child Care Assistance Programs Are 
Vulnerable to Fraud: 

Eligible Children May Not Receive Child Care Services in Some States 
Because of Significant Waitlists: 

Corrective Action Briefing: 

Appendix I: Scope and Methodology: 

Appendix II: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Monthly Income Thresholds by Family Size in the States We 
Tested: 

Table 2: Results of Undercover Parent and Provider Child Care 
Applications: 

Table 3: Vulnerabilities Identified in Undercover Tests of the CCDF 
Programs by State: 

Table 4: Case Studies of Fraud in the CCDF Program: 

Table 5: Summary of Selected CCDF Waiting List Families: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

September 22, 2010: 

Congressional Addressees: 

The Child Care and Development Fund (CCDF) received $7 billion in 
fiscal year 2009, including $2 billion from the American Recovery and 
Reinvestment Act of 2009 (Recovery Act), primarily to help eligible 
low-income families pay for child care. Administered by the U.S. 
Department of Health and Human Services (HHS) as a block grant to the 
states, the CCDF subsidizes child care for low-income children under 
age 13 whose parents work or attend educational or job training 
programs.[Footnote 1] After a parent enrolls in the program, their 
chosen child care provider--a child care center, an in-home provider, 
or a relative--bills the state for the care provided and the state 
pays either the parent or provider directly. States may contribute 
matching funds and are responsible for determining program priorities 
and overseeing funds.[Footnote 2] States share responsibility with HHS 
for protecting the financial integrity of the CCDF program, but the 
program can be administered by public or private sector entities, 
including individual counties or nonprofits. 

HHS estimated that the improper payment rate for CCDF in fiscal year 
2008 was 11.9 percent.[Footnote 3] In addition, multiple parents and 
providers have been convicted of fraudulently obtaining CCDF funds. 
For example, there is a recent case in which a Wisconsin child care 
provider was convicted of stealing $361,000 by claiming to have cared 
for children who did not attend her child care center. Fraudulent 
payments reduce funds available for qualified families that depend on 
CCDF-funded child care and prevent other families from enrolling in 
the program. Given the risk of fraud and abuse in the program, and the 
Comptroller General's authority to undertake work, we (1) proactively 
tested selected states' fraud prevention controls for CCDF eligibility 
and billing, (2) examined case studies of fraud and abuse within the 
CCDF program, and (3) interviewed parents waitlisted for child care 
about the effect that this lack of assistance had on their families. 

To proactively test selected states' fraud prevention controls, we 
created bogus child care providers to bill states for caring for 
fictitious children. We identified six states that received more than 
$100 million in CCDF funding for fiscal year 2009 and did not require 
providers to be fingerprinted or undergo site visits.[Footnote 4] Of 
these, we selected the five states receiving the most American 
Recovery and Reinvestment Act funding to develop 10 undercover cases. 
We selected two counties in Illinois, Michigan, New York, Texas, and 
Washington, states that had no waiting lists, and, where possible, 
that included large cities. We chose counties that did not have 
waiting lists to ensure that we did not prevent real families from 
obtaining assistance. We used only relatives as providers because 
these providers are generally subject to less regulation than larger 
child care centers, and did not require us to establish physical child 
care centers or have our undercover investigators fingerprinted. As 
such, our results cannot be applied to licensed child care providers, 
such as child care centers, nor can our results be projected to all 
state CCDF programs. We used commercially available hardware and 
software to counterfeit identification and employment documents for 
fictitious parents, children, and providers. Once accepted into a 
program, we billed the program for care provided to the fictitious 
children, but voided and returned any checks we received to program 
officials at the end of our investigation[Footnote 5]. To select our 
five case studies of past program fraud, we identified criminal 
convictions for child care assistance fraud nationwide using online 
databases and other Internet resources. From these, we selected cases 
involving a high dollar amount of fraud or containing other elements 
of fraud, such as stolen identities. We reviewed court documents and 
when possible interviewed investigators and prosecutors involved with 
the selected cases to obtain additional details. To examine the effect 
of being unable to obtain child care on low-income families, we 
contacted 11 states that had active waiting lists between November 
2009 and March 2010. We obtained the names of parents on waitlists for 
child care assistance from the agencies that administer the program in 
those states.[Footnote 6] Starting from the top of these lists, we 
selected a nonrepresentative sample of 166 parents to contact and 
interviewed the 41 who responded to our inquiries. We did not attempt 
to verify the accuracy of the information that they provided to us, 
and our results cannot be projected to the entire population of 
families currently waiting for child care assistance. We conducted our 
investigation from May 2009 through September 2010 in accordance with 
the standards prescribed by the Council of the Inspectors General on 
Integrity and Efficiency. A detailed discussion of our scope and 
methodology is presented in appendix I. 

Background: 

The CCDF is the primary federal funding source to help states 
subsidize the cost of child care for low-income parents and to improve 
the quality of care. For a parent to be eligible for CCDF funds, their 
children must be younger than 13 years old and living with them; 
parents must be working, or enrolled in school or training.[Footnote 
7] States may design their programs and establish work requirements, 
payment rates, family copayments, and other program rules within the 
broad parameters outlined by the federal law and regulations. States 
may add additional eligibility requirements, including different 
income thresholds, but must set the maximum family income eligibility 
requirement at or below 85 percent of the state median income for 
families of the same size. Table 1 shows the eligibility thresholds 
applicable to our fictitious families in the states we tested. 

Table 1: Monthly Income Thresholds by Family Size in the States We 
Tested: 

State: Illinois; 
Family of three income threshold: $2,934; 
Percent of state median income for a family of three: 58%; 
Family of four income threshold: $3,534; 
Percent of state median income for a family of four: 59%. 

State: Michigan; 
Family of three income threshold: $1,990; 
Percent of state median income for a family of three: 38%; 
Family of four income threshold: $2,367; 
Percent of state median income for a family of four: 38%. 

State: New York; 
Family of three income threshold: $3,052; 
Percent of state median income for a family of three: 56%; 
Family of four income threshold: $3,675; 
Percent of state median income for a family of four: 56%. 

State: Texas; 
Family of three income threshold: $3,710; 
Percent of state median income for a family of three: 85%; 
Family of four income threshold: $4,417; 
Percent of state median income for a family of four: 85%. 

State: Washington; 
Family of three income threshold: $3,052; 
Percent of state median income for a family of three: 56%; 
Family of four income threshold: $3,676; 
Percent of state median income for a family of four: 57%. 

Source: State CCDF Implementation Plans submitted to HHS for fiscal 
years 2010-2011. 

[End of table] 

Families may choose to purchase care from any legally operating child 
care provider, which may include child care centers, home-based 
providers, family members, neighbors, and after-school programs. 
Providers must be approved by the state to receive CCDF subsidies. HHS 
requires that states have licensing standards for child care 
providers, but federal law does not determine these standards or which 
type of providers they apply to.[Footnote 8] Some states require 
relative providers to undergo background checks with fingerprints, 
criminal and sex-offender checks, or home inspections, but other 
states have less stringent requirements. According to HHS, in 2008, 58 
percent of children in the program were cared for in a licensed center-
based child care facility, 13 percent were cared for in a licensed or 
regulated home-based center, 12 percent by an unregulated relative 
provider, and 17 percent in a variety of other arrangements.[Footnote 
9] 

State and county CCDF agencies may pay child care providers or 
families directly. Payments to families may be in the form of a child 
care certificate that may be used only as payment or deposit for child 
care services. In some states, providers can directly bill the state 
through automated systems and have funds directly deposited into a 
personal bank account or receive a check by mail. In addition, 
families are required to contribute to the cost of care, in the form 
of a copayment, unless states exempt families below certain income 
thresholds from this requirement. CCDF rules also provide some 
guidance on establishing reimbursement rates for child care providers 
and require that a specified portion of funds be set aside for 
activities designed to enhance child care quality.[Footnote 10] 

The Child Care and Development Block Grant Act of 1990 first 
authorized block grants to be given to states for child care 
assistance and the Personal Responsibility and Work Opportunity 
Reconciliation Act of 1996 further expanded the grants to states 
creating the current CCDF.[Footnote 11] In fiscal year 2009, $7 
billion was expended for the CCDF block grants, of which $2 billion 
was attributable to the passage of the Recovery Act in 2009. CCDF has 
discretionary, mandatory, and matching components. In order to receive 
the matching component, a state must meet a number of spending 
requirements.[Footnote 12] States may also transfer money in CCDF 
programs from the Temporary Assistance for Needy Families (TANF) and 
Social Services Block Grants. Regarding Recovery Act funds provided to 
states for CCDF, as of September 3, 2010, HHS reported that it had 
disbursed to the states $1.2 billion of the $1.9 billion allocated for 
the CCDF. 

States must designate a lead agency to administer program funds and 
submit a plan to be approved by HHS. In 2004, we reported that states 
generally had responsibility for determining the types and extent of 
internal controls to put in place for CCDF, with few federal 
regulations and limited guidance in that area.[Footnote 13] Of the 16 
states we reviewed, almost all reported that they had performed some 
activities to assess the extent to which their programs were at risk 
of improper payments, but these activities often did not cover all 
payments that could be at risk. Since that report, HHS reported that 
it has engaged in several activities to help states continue to focus 
on improving their internal controls. For example, in response to the 
recommendations in our 2004 report, HHS organized, through the Child 
Care Bureau, a federal project team to draft an approach to address 
internal controls, using GAO's report Internal Controls: Internal 
Control Management and Evaluation Tool as a guide.[Footnote 14] This 
effort included drafting tools for states to use to conduct internal 
control self-assessments, estimates of payment error rates, and 
guidance for developing cost-benefit assessments of internal control 
processes; identifying and sharing best practices among states for 
minimizing improper payments; and taking actions to expand the system 
that matches state enrollment data across several programs to include 
CCDF. We did not review whether the states in our proactive tests and 
case studies took steps to strengthen controls based on these 
initiatives. 

Vulnerabilities Identified in Five States' Fraud Prevention Controls: 

Our proactive testing revealed that CCDF programs in the 5 states we 
tested were vulnerable to fraud because states did not adequately 
verify the information of children, parents, and providers and lacked 
adequate controls to prevent fraudulent billing. In 7 of 10 cases in 
four states, our fictitious parents and children were admitted into 
the CCDF program because states did not verify the personal and 
employment information provided by the applicants.[Footnote 15] Three 
of those states paid $11,702 in child care subsidies to our fraudulent 
providers, and two states allowed the providers to over bill for 
services beyond their approved limit. Only one state successfully 
prevented our fictitious applicants from being admitted into the 
program, but officials from that state told us they perform only 
limited background checks on providers and cannot immediately detect 
over billing. Table 2 provides information about each of our 
undercover tests. 

Table 2: Results of Undercover Parent and Provider Child Care 
Applications: 

Case: 1; 
State: Washington; 
Scenario: Single mother with two children, ages 6 and 4; 
Status: Approved; received $3,145 for 5 months; 
Case details: 
* Parent was approved 3 weeks after completing a brief phone interview 
without requesting the applicant's employer pay stubs. No 
identification documents were required for the parent or children; 
* Department of Social and Health Services (DSHS) failed to detect the 
Social Security number (SSN) of a deceased individual used by the 
parent and the incorrect SSN used by the children. Officials told us 
that it is not a program requirement to verify SSNs for beneficiaries 
of the program; 
* DSHS also did not perform any checks to determine that the parent's 
employer was fictitious; 
* DSHS initially denied the fictitious provider's application because 
the provider's name and SSN did not match. However, the provider was 
allowed to resubmit with the same personal information and a different 
Social Security card with a real SSN. Provider was approved within 12 
days; 
* Parent and provider were able to bill for hours exceeding the 
authorized amount by informing the caseworker that the parent had 
worked an additional 20 hours that month. No documentation was 
required; 
* Parent and provider also billed for 30 school holiday hours for each 
child even though the provider was not authorized to provide care 
during school hours. DSHS officials stated that any overbilling of 
holiday hours would be caught during random audits that are conducted 
monthly on some providers. However, no audit was conducted in this 
case. 

Case: 2; 
State: Washington; 
Scenario: Single mother with three children, ages 10, 6, and 4; 
Status: Approved; received $1,572 for 2.5 months; 
Case details: 
* Parent was approved 12 days after completing a brief phone interview 
and submitting fabricated pay stubs and an employment verification 
letter; 
* DSHS failed to detect the SSN of a deceased individual used by the 
parent and the incorrect SSNs used by the children. Officials told us 
that they are not required to verify beneficiaries' SSNs; 
* DSHS initially denied the fictitious provider's application because 
the provider's name and SSN did not match; 
* Provider resubmitted using a different first name, SSN, driver's 
license photograph and birth date, but the same last name, address and 
phone number. Even though DSHS had previously rejected a similar 
provider using the same address, and both applications claimed only 
one person lived there, DSHS failed to investigate the second 
application further. The application was approved within 7 days; 
* Provider successfully billed for 16 school holidays for each school-
aged child during a month of only 22 school days. DSHS officials 
stated that any overbilling of holiday hours would be caught during 
random audits that are conducted monthly on some providers. However, 
no audit was conducted in this case. 

Case: 3; 
State: New York; 
Scenario: Single mother with two children, ages 6 and 4; 
Status: Approved; received $1,630 for 2 months; 
Case details: 
* Parent was approved for assistance after a 30 minute in-person 
interview where she presented photocopies of false Social Security 
cards, birth certificates, a driver's license, and a death certificate 
for her spouse; 
* Department of Social Services (DSS) failed to detect the SSN of a 
deceased person used by the parent and the incorrect SSNs used by the 
children; 
* DSS accepted a fabricated letter as proof that the applicant did not 
receive survivor benefits for her deceased spouse; 
* Provider passed the background check, even though she had submitted 
an SSN that did not match her name. This creates a risk that someone 
with a criminal background could steal an identity to qualify for 
child care payments. State officials told us they are not legally 
permitted to verify SSNs, even for relative child care providers; 
* Provider received payment for 2 months of child care. We ceased 
proactive tests and returned assistance checks after media reports of 
county budget cuts in the child care assistance program. 

Case: 4; 
State: New York; 
Scenario: Single mother with three children, ages 10, 6, and 4; 
Status: Approved; received $4,003 for 5 months; 
Case details: 
* Parent was approved for assistance 4 weeks after applying by mail 
using photocopies of fraudulent Social Security cards, birth 
certificates, a utility bill, pay stubs, and a marriage certificate; 
* Caseworker initially did not approve the application, which 
contained fraudulent Social Security cards showing the same SSN for 
the parent and one of her children. However, the caseworker accepted 
the parent's explanation that the Social Security Administration had 
issued her the wrong Social Security card and approved her application 
when she submitted a card bearing a different SSN; 
* Provider passed the background check, even though he had submitted 
the SSN of a deceased person. This creates a risk that someone with a 
criminal background could steal an identity to qualify for child care 
payments. State officials told us they are not legally permitted to 
verify SSNs, even for relative child care providers; 
* County workers used an electronic system to prevent over billing by 
comparing hours billed to hours authorized and hours worked. In one 
instance, the provider claimed to have provided 140 hours of care to 
one child, but the parent's pay stubs showed she had worked only 60 
hours during that time; 
* Caseworkers compared the billed hours to the pay stubs, detected the 
discrepancy and reduced the payment to the provider. However, they 
still permitted him to bill for an extra 2.5 hours a day that the 
parent supposedly spent at lunch or in transit, even though she worked 
just 10 minutes from the provider's house. 

Case: 5; 
State: Michigan; 
Scenario: Single mother with two children, ages 6 and 4; 
Status: Approved, paid $1,352 for 3 months; 
Case details: 
* Department of Human Services (DHS) lost the fictitious parent's 
initial applications on two occasions, one by fax and one by mail. 
Caseworker then discovered the faxed application 2 months later; 
* On a third application attempt, parent was approved within 30 days 
after reapplying in person with photocopies of her driver's license, 
Social Security cards, and pay stubs. Case worker did not ask to see 
original documents; 
* DHS officials said they use state wage, employment, public 
assistance and child support databases to verify applicant 
information, and an SSA database to verify parent and child SSNs. 
Officials told us the system detected that the names and SSNs of our 
fictitious applicants did not match, but a caseworker inappropriately 
approved them for child care assistance; 
* Provider was approved to receive payment for 3 months of child care 
assistance. State officials told us that a check was issued, but was 
returned to DHS due to an error at the rental mailbox store; 
* Using the online billing system, provider attempted to bill for more 
hours than she was authorized to provide care. The system detected the 
discrepancy and successfully prevented payment for these hours. 

Case: 6; 
State: Michigan; 
Scenario: Single mother with three children, ages 10, 6, and 4; 
Status: Parent denied; provider never reviewed due to parent denial; 
Case details: 
* Department of Human Services lost the fictitious parent's faxed 
application. When the parent resubmitted the application by mail, a 
caseworker initially claimed that it had not been processed, then said 
that the office's mail was not being forwarded from the post office. 
The caseworker told her that if she reapplied in person, it would take 
30 days to process the application; 
* The applicant reapplied in person, submitting photocopied documents. 
Case worker did not interview the applicant or ask to see original 
documents; 
* DHS denied the first application 4 months after it had originally 
been submitted and had no record of receiving our second application. 
However, the third application, which was submitted by the parent in 
person, was processed within 6 days; 
* Applicant was denied because the identity of the parent and children 
could not be verified. 

Case: 7; 
State: Texas; 
Scenario: Single mother with two children, ages 6 and 4; 
Status: Parent approved; provider denied; 
Case details: 
* Parent was approved for assistance after a 20 minute in-person 
interview where she presented photocopies of Social Security cards, 
pay stubs, birth certificates, and a driver's license. Case worker did 
not ask to see original documents; 
* Provider was originally rejected for using an SSN that did not match 
her name. Case workers accepted her explanation that the Social 
Security Administration had issued her the wrong Social Security card 
and allowed her to reapply with a new SSN; 
* Provider passed a background check; 
however, licensing staff at the Texas Department of Family and 
Protective Services (DFPS) became suspicious of her multiple addresses 
and out-of-state driver's license. The staff member requested that the 
provider appear in person with all original documentation, at which 
point we stopped our application. 

Case: 8; 
State: Texas; 
Scenario: Single mother with three children, ages 11, 6, and 4; 
Status: Parent approved; provider initially approved, then denied; 
Case details: 
* Parent completed a 15 minute in-person interview where she presented 
photocopies of Social Security cards, pay stubs, birth certificates, 
and a driver's license. Case worker did not ask to see original 
documents; 
* Texas Workforce Solutions (TWS) approved the parent for assistance, 
even though she had used the SSN of a deceased individual and her 
children had used incorrect SSNs. TWS also did not perform any checks 
to determine that the parent's employer was fictitious; 
* TWS officials told us that they do not have a system to verify the 
parent and children's SSNs; 
* DFPS had no record of receiving our initial provider application. 
Our second provider passed a background check and was approved 13 days 
after he submitted an application, but his operation was closed when 
DFPS could not reach him by phone. 

Case: 9; 
State: Illinois; 
Scenario: Single mother with two children, ages 6 and 4; 
Status: Parent denied; provider review not completed due to parent 
denial; 
Case details: 
* Parent's initial application was denied 7 weeks after caseworkers 
compared parent and child information against state public assistance, 
wage and child support databases. Caseworkers also used Internet 
resources to identify the parent, provider, and employer addresses as 
nonexistent; 
* Parent resubmitted the application using the same personal 
information with actual street addresses for her residence and 
employer. Provider also submitted a new application with an actual 
street address, valid SSN, and a fraudulent out-of-state driver's 
license; 
* New application was denied because caseworkers had put a warning on 
the case file alerting staff to the previously submitted fraudulent 
documentation; 
* Illinois officials told us they do not currently require relative 
providers to undergo a sex offender check or a fingerprint background 
check, but they plan to implement these screenings in October 2010; 
* In addition, they do not require parents to submit pay stubs on an 
ongoing basis, but rely on 6-month recertification to detect changes 
in work hours. This creates an opportunity for providers to over bill. 

Case: 10; 
State: Illinois; 
Scenario: Single mother with three children, ages 10, 5, and 4; 
Status: Parent denied; provider denied; 
Case details: 
* Parent's initial application was denied 3 months after she applied. 
Caseworkers compared parent and child information against state public 
assistance, wage and child support databases. Caseworkers also used 
Internet resources to identify the parent and provider's home 
addresses as fictitious and the employer as nonexistent; 
* Parent resubmitted the application using the same personal 
information with actual street addresses for her residence and 
employer. Provider also submitted a new application with a valid SSN, 
a nonexistent street address, and a fraudulent out-of-state driver's 
license; 
* Resubmitted application was denied when caseworkers read the case 
file notes, which documented previous problems with the parent and 
allowed the caseworker to identify discrepancies between the 
applications; 
* Illinois officials told us they do not currently require relative 
providers to undergo a sex offender check or a fingerprint background 
check, but they plan to implement these screenings in October 2010; 
* In addition, they do not require parents to submit pay stubs on an 
ongoing basis, but rely on 6-month recertification to detect changes 
in work hours. This creates an opportunity for providers to over bill. 

Source: GAO. 

[End of table] 

Several common themes emerged from our proactive testing, showing the 
specific vulnerabilities in the states' CCDF programs. 

Lack of Effective Controls to Verify Parent and Child Information: 
Four states did not consistently verify the SSNs and addresses of our 
fictitious parents and children, potentially allowing unscrupulous 
providers to use nonexistent children to bill for additional 
subsidies. While HHS policy does not permit states to require that 
parents or children submit SSNs, all of the states we tested gave 
parents the option of submitting this information. However, we found 
that some states did not verify this information when it was provided. 
For example, Texas and New York did not verify our fictitious parent 
and children's SSNs, which belonged to deceased people. Furthermore, 4 
states accepted photocopies of the parent's driver's license, the 
children's birth certificates, and all Social Security cards.[Footnote 
16] While there is no federal requirement preventing states from 
accepting photocopies, they are much more difficult to identify as 
fraudulent than originals.[Footnote 17] In contrast to New York and 
Texas, Illinois, Michigan, and Washington compared information 
provided by the parent to data in state public assistance databases 
and, in Illinois and Michigan, state child support databases. In 
Michigan and Washington, caseworkers found that the applicants were 
not in these databases but conducted no further verification of their 
information. In one case, a Michigan caseworker also checked the 
applicants' names and SSNs with the Social Security Administration 
(SSA), but inappropriately enrolled the family in the program even 
after the system identified their names and SSNs as mismatched. 
Michigan denied the other parent because they were not able to verify 
her identity or that of her children. Illinois denied both fraudulent 
applications after the public assistance and child support database 
matches found no record of the family, leading to further checks that 
identified other inconsistencies in the applications.[Footnote 18] 

Lack of Effective Controls to Verify Parent Income Eligibility: Four 
states lacked effective controls to verify the parent's income by 
contacting the employer directly or comparing the parent's income to 
state data, instead accepting fabricated pay stubs as proof of income. 
Without adequate verification of income, states cannot provide 
reasonable assurance that only eligible parents are accepted into the 
program. There is no federal requirement for what income documentation 
states must collect, but in all 5 states, parents were required to 
provide pay stubs and asked to declare other sources of income, such 
as Social Security, TANF, and/or child support. Caseworkers in New 
York, Texas, and Washington accepted photocopies of fabricated pay 
stubs from fictitious businesses and did not have effective controls 
to verify the existence of the employer, the validity of the company 
address, or the wages reported by the applicants. While officials in 
Michigan and Illinois told us they use state employment data to verify 
income at the time of application, only Illinois successfully 
prevented both our fictitious applicants from being accepted into the 
program.[Footnote 19] Illinois caseworkers said that when they saw 
that the applicant's employer did not appear in the state database, 
they attempted to contact the business directly and were unable to 
reach a live employee. Caseworkers then verified the fictitious 
address we provided for the employer and discovered that it was in the 
middle of Lake Michigan, which caused them to deny the application. 

Lack of Effective Controls to Verify the Background of Relative Child 
Care Providers: The five states we tested did not conduct thorough 
provider background checks, generally failing to conduct nationwide 
background checks, verify SSNs, or compare provider information to sex 
offender registries. Michigan, Texas, and Washington conducted 
relative provider background checks using only state conviction data, 
creating the possibility that a provider with a criminal history in 
one state could be approved to care for children simply by moving to 
another state. New York and Illinois officials said they do not verify 
relative providers' criminal background, instead matching provider 
information against state child abuse databases and, in New York, 
against the state sex offender registry. SSNs are a key element in the 
verification of a person's identity, and all the states we tested 
required that providers submit their SSNs. However, there is no 
federal requirement that states verify SSNs. This creates the 
possibility that criminals, including registered sex offenders, using 
stolen identities could obtain federal subsidies to care for children. 
We found that New York did not verify our fictitious providers' SSNs, 
approving two child care providers using SSNs that did not match their 
names, one of which belonged to a deceased person.[Footnote 20] 
Michigan officials told us that they also do not verify provider SSNs 
while officials in Illinois said they do not currently compare 
relative provider information to lists of registered sex offenders, 
potentially putting children at risk. However, officials said they 
plan to implement this screening in October 2010. While we did not 
test states that require fingerprinting, nationwide fingerprint 
background checks provide more assurance of an applicant's identity 
than background checks without fingerprints. Our tests were limited to 
scenarios in which the provider was an unlicensed relative; therefore, 
our results cannot be applied to licensed child care providers, such 
as day care centers, which are typically subject to greater regulation. 

Lack of Effective Controls to Flag Suspicious Applications for Further 
Review: Three of four states did not have controls to flag fictitious 
parents and providers who reapplied to the program after their initial 
application had been identified as potentially fraudulent, creating 
the risk that applicants rejected for fraud will be able to gain 
admittance into the program simply by submitting slightly different 
information.[Footnote 21] In Washington, one fictitious provider's 
application was initially rejected because a query of a federal 
database found that his name and SSN did not match. We then created a 
new fictitious provider that shared the same last name, mailing 
address, home address, and phone number as the rejected provider, but 
had a different first name, SSN, driver's license photograph, and 
birth date. Even though the Department of Social and Health Services 
(DSHS) had previously rejected a similar provider using the same 
address, and both applications claimed only one person lived there, 
DSHS failed to investigate the second application further. Instead, 
the application was approved in 7 days. In the other Washington case 
and in one Texas case, caseworkers questioned why the provider's SSN 
did not match her name but allowed her to submit a different SSN after 
she claimed that the SSA had issued her the wrong card.[Footnote 22] A 
caseworker in New York accepted the same explanation from a parent who 
initially used a Social Security card bearing the same SSN as her 
daughter. By contrast, after rejecting both of our parent applications 
as fraudulent, Illinois caseworkers added warnings to the case file 
notes to alert other staff to the previously identified fraud. When we 
submitted new applications with slightly different information, 
caseworkers linked the new applications to the rejected applications 
and prevented our fictitious parents from being approved for child 
care assistance. 

Weak Controls to Prevent Fraudulent Billing: All three states in which 
we tested billing procedures had some controls to prevent overbilling, 
but vulnerabilities in two states allowed providers to obtain payment 
for more hours than they were authorized to provide care. In 
Washington, the automated billing system prevented providers from 
claiming more than their authorized hours for regularly scheduled 
care, but allowed them to bill for additional "school holiday" hours 
without any documentation. Exploiting this vulnerability, both 
providers billed for excessive holiday hours; one provider 
successfully billed for 30 school holiday hours for each of the two 
children she cared for, even though she was not authorized to provide 
care during school hours. Furthermore, the same provider obtained 
payment for an additional 20 hours of care by having the parent tell 
her caseworker that she had worked extra hours that month. The 
caseworker did not require the parent to submit any documentation 
before authorizing the additional hours. New York required one parent 
to submit her pay stubs as proof of hours worked and used an 
electronic system to compare these to the hours billed by the 
provider. When our provider attempted to bill for 140 hours in April 
2010, but the parent's pay stubs showed she had worked only 60 hours, 
caseworkers identified the discrepancy and reduced the provider's 
payment. However, they allowed the provider to bill for an extra 2.5 
hours each day for time that the parent spent at lunch or in transit, 
even though she worked just 10 minutes from the provider's house. 
[Footnote 23] Michigan used an automated system in which parents and 
providers separately reported the number of hours of care provided. 
The system compared these two reports to each other and to the hours 
of care authorized, detected that the provider had over billed by 5 
hours every 2 weeks and reduced the payment to the authorized amount. 
We were not able to test controls over unauthorized billing in 
Illinois and Texas, but officials told us that parents are not 
required to submit pay stubs on an ongoing basis, and provider bills 
are compared only to the number of hours the provider is authorized to 
provide care.[Footnote 24] If a parent began working fewer hours but 
did not report the schedule change, a provider could continue to bill 
at the authorized level until 3 to 6 months later, when the parent 
submitted pay stubs as part of the recertification process.[Footnote 
25] 

Delays in Processing Applications: In three counties in three states, 
3 months or more elapsed between the date our fictitious applicants 
submitted their application and the date an agency first responded to 
the application.[Footnote 26] Parents applying to CCDF programs have a 
reasonable expectation of a timely decision on their applications. 
While there is no federal standard for timeliness, some states we 
tested established program standards for response times. For example, 
Michigan program requirements state that a decision be rendered within 
45 days and Washington requires that a decision be made within 30 
days. In our proactive tests, approval time frames for parent 
applicants ranged from the same day to over 4 months, with an average 
of 42 days to render a decision. In three cases, 3 months elapsed from 
the date a parent or provider submitted an application to the date the 
agency first responded. For example, one agency in Illinois received 
the parent's application on September 3, 2009, but did not begin 
verifying the parent's eligibility until November 16, 2009, finally 
issuing a denial letter on December 2, 2009. During this time, our 
undercover investigators repeatedly tried to call the agency, but 
frequently received a voicemail stating that calls would not be 
accepted due to the volume of calls and paperwork. Program officials 
told us that at the time of our application, that office was 
backlogged, but that normally, an applicant would receive a final 
determination within 45 days. Despite Michigan's program standard of a 
response within 45 days, DHS denied our parent's first application 4 
months after it was originally submitted and lost her second 
application. However, her third application, which was submitted 
months later, was processed within 6 days. Michigan officials told us 
that at the time of our first two applications, both counties were in 
the process of adopting a new software program. The review process for 
one provider in Texas took 4 months. In the other case, the agency had 
no record of the first provider application and rendered a decision on 
the second within 13 days. By contrast, both counties in Washington 
approved parent and provider applications within 2 months of receipt. 
Table 3 shows the vulnerabilities we identified in our ten undercover 
tests of the CCDF programs by state. 

Table 3: Vulnerabilities Identified in Undercover Tests of the CCDF 
Programs by State: 

State: Illinois; 
County: 1; 
Lack of effective controls to verify parent or child SSN, or parent 
address: [Empty]; 
Lack of effective controls to verify parent employment: [Empty]; 
Lack of effective controls to verify the background of providers: 
[Check][A]; 
Lack of effective controls to flag suspicious applications for further 
review: [Empty]; 
Weak controls to prevent fraudulent billing: [Check][A]; 
Delays in processing application: [Empty]. 

State: Illinois; 
County: 2; 
Lack of effective controls to verify parent or child SSN, or parent 
address: [Empty]; 
Lack of effective controls to verify parent employment: [Empty]; 
Lack of effective controls to verify the background of providers: 
[Check][A]; 
Lack of effective controls to flag suspicious applications for further 
review: [Empty]; 
Weak controls to prevent fraudulent billing: [Check][A]; 
Delays in processing application: [Check]. 

State: Michigan; 
County: 1; 
Lack of effective controls to verify parent or child SSN, or parent 
address: [Check]; 
Lack of effective controls to verify parent employment: [Check]; 
Lack of effective controls to verify the background of providers: 
[Check]; 
Lack of effective controls to flag suspicious applications for further 
review: [Empty]; 
Weak controls to prevent fraudulent billing: [Empty]; 
Delays in processing application: [Empty]. 

State: Michigan; 
County: 2; 
Lack of effective controls to verify parent or child SSN, or parent 
address: [Empty]; 
Lack of effective controls to verify parent employment: [Empty]; 
Lack of effective controls to verify the background of providers: 
[Check][A]; 
Lack of effective controls to flag suspicious applications for further 
review: [Empty]; 
Weak controls to prevent fraudulent billing: [Empty]; 
Delays in processing application: [Check]. 

State: New York; 
County: 1; 
Lack of effective controls to verify parent or child SSN, or parent 
address: [Check]; 
Lack of effective controls to verify parent employment: [Check]; 
Lack of effective controls to verify the background of providers: 
[Check]; 
Lack of effective controls to flag suspicious applications for further 
review: [Empty]; 
Weak controls to prevent fraudulent billing: x[C]; 
Delays in processing application: [Empty]. 

State: New York;
County: 2; 
Lack of effective controls to verify parent or child SSN, or parent 
address: [Check]; 
Lack of effective controls to verify parent employment: [Check]; 
Lack of effective controls to verify the background of providers: 
[Check]; 
Lack of effective controls to flag suspicious applications for further 
review: [Check]; 
Weak controls to prevent fraudulent billing: [Check]; 
Delays in processing application: [Empty]. 

State: Texas; 
County: 1; 
Lack of effective controls to verify parent or child SSN, or parent 
address: [Check]; 
Lack of effective controls to verify parent employment: [Check]; 
Lack of effective controls to verify the background of providers: 
[Check]; 
Lack of effective controls to flag suspicious applications for further 
review: [Check][B]; 
Weak controls to prevent fraudulent billing: [Check][B]; 
Delays in processing application: [Check]. 

State: Texas; 
County: 2; 
Lack of effective controls to verify parent or child SSN, or parent 
address: [Check]; 
Lack of effective controls to verify parent employment: [Check]; 
Lack of effective controls to verify the background of providers: 
[Check]; 
Lack of effective controls to flag suspicious applications for further 
review: [Check][B]; 
Weak controls to prevent fraudulent billing: [Check][B]; 
Delays in processing application: [Empty]. 

State: Washington; 
County: 1; 
Lack of effective controls to verify parent or child SSN, or parent 
address: [Check]; 
Lack of effective controls to verify parent employment: [Check]; 
Lack of effective controls to verify the background of providers: 
[Check]; 
Lack of effective controls to flag suspicious applications for further 
review: [Check]; 
Weak controls to prevent fraudulent billing: [Check]; 
Delays in processing application: [Empty]. 

State: Washington; 
County: 2; 
Lack of effective controls to verify parent or child SSN, or parent 
address: [Check]; 
Lack of effective controls to verify parent employment: [Check]; 
Lack of effective controls to verify the background of providers: 
[Check]; 
Lack of effective controls to flag suspicious applications for further 
review: [Check]; 
Weak controls to prevent fraudulent billing: [Check]; 
Delays in processing application: [Empty]. 

Source: GAO. 

[A] Based on statements by state child care officials, not proactive 
tests. We were unable to test certain controls in some states because 
of delays in application processing or a denial earlier in the 
application process. 

[B] The current Texas system is paper-based, limiting caseworkers' 
ability to verify applicant information, prevent reapplication and 
detect over billing. Officials said these issues will be corrected in 
a new electronic system. 

[C] We were not able to test controls over billing in one New York 
county because we withdrew our fictitious family after the program 
budget was cut. However, county officials told us that unlike the 
other New York county we tested, they do not yet have an electronic 
system to compare hours billed to hours authorized. Consequently, this 
comparison is still done manually by caseworkers. 

[End of table] 

To prevent fraud, waste, and abuse, it is essential for states to have 
a well-designed system that includes preventive controls, detection 
and monitoring, and investigations, according to GAO's fraud 
prevention model.[Footnote 27] Preventative controls in a program like 
CCDF would involve comparing applicant-provided information to 
government or third-party data and establishing controls to prevent 
the payment of unauthorized bills. Detection and monitoring would 
involve data mining for fraudulent applicant information and 
suspicious billing transactions, while investigation and prosecution 
of those caught committing fraud in the CCDF would serve as a 
deterrent to others contemplating defrauding the program. However, the 
CCDF regulations do not require states to implement specific measures 
to prevent or detect fraud, resulting in application processes and 
requirements that vary considerably by location. For example, in 
Washington, one of our fictitious parents was approved after giving a 
caseworker her information over the phone interview and having a 
woman, purporting to be her employer, call DSHS to verify her work 
schedule. In a New York county, the parent was required to provide 
photocopies of birth certificates and Social Security cards for all 
household members, a death certificate for the deceased spouse, pay 
stubs, a form signed by her landlord, a driver's license, and a letter 
from SSA stating that she did not receive survivors' benefits. 

Case Studies Indicate That Child Care Assistance Programs Are 
Vulnerable to Fraud: 

Similar to our fictitious applications, we identified five closed 
criminal cases in which parents and providers defrauded the CCDF 
program.[Footnote 28] The parents and providers in these cases used 
similar methods to our proactive testing including falsifying 
documentation to claim eligibility, billing the state for fictitious 
children, and colluding to obtain payment for services that were never 
provided. Table 4 provides a detailed summary of cases in which 
individuals were convicted of fraudulently obtaining CCDF funds; a 
more detailed narrative on each case follows the table. 

Table 4: Case Studies of Fraud in the CCDF Program: 

Case: 1; 
State: Indiana; 
Amount: $150,310; 
Month and Year of conviction(s): March 2009/July 2009; 
Case details: 
* Two providers fraudulently obtained CCDF funds by billing for hours 
during which they could not have provided care; 
* One of the women illegally obtained the license for the home-based 
child care center by failing to disclose that a twice-convicted felon 
lived in the house and interacted with children, according to an 
investigator's report; 
* The investigator found that the other woman convinced parents to 
give her their electronic access cards, which record the number of 
hours their children spent in child care. She used these cards to over 
bill the state and in one case, paid kickbacks to a parent in exchange 
for the card; 
* Parents and investigators noted that the child care provided 
inadequate care, including failing to feed children or change diapers; 
* One provider pled guilty to welfare fraud and was sentenced to 2 
years in jail. The other provider pled guilty to the same charges and 
also received 2 years. 

Case: 2; 
State: Missouri; 
Amount: $112,242; 
Month and Year of conviction(s): December 2008; 
Case details: 
* A provider fraudulently billed the CCDF program by submitting false 
invoices to the state and forging parent signatures on attendance 
sheets; 
* According to investigators, some children in her care were 
neglected, including three children found locked in a car when the 
parent came to pick them up; 
* Investigators found that the owner also ran an unlicensed child care 
center out of her apartment with up to 25 children under the 
supervision of just one adult; 
* The owner pled guilty to mail fraud and was later sentenced to 15 
months in prison and $112,242 in restitution. 

Case: 3; 
State: Oregon; 
Amount: $122,615; 
Month and Year of conviction(s): August 2007/January 2008; 
Case details: 
* Claiming to be separated, a married couple living together qualified 
separately for the CCDF program, then collected payments using two 
fictitious child care providers. In fact, the unemployed father cared 
for his children, making the couple ineligible for child care 
assistance; 
* According to the investigator's report, the husband forged pay stubs 
from a business called "Ablazed and Mystifying Women," which he 
claimed was a warehouse, to establish his eligibility for the program; 
* The investigator found that the husband stole the Social Security 
number of his half brother in order to create one of the fictitious 
providers and collected the funds using false identification; 
* The husband pled guilty to several counts of theft and identity 
theft and was sentenced to 8 years in prison. The wife pled guilty to 
theft, forgery and unlawfully obtaining public funds. She was 
sentenced to 3.5 years in prison. 

Case: 4; 
State: Washington; 
Amount: $8,806; 
Month and Year of conviction(s): September 2008; 
Case details: 
* Five providers participated in a scheme to fraudulently bill the 
CCDF program and one of them assisted others in obtaining false names 
and Social Security numbers to apply for child care licenses; 
* According to the indictment, one provider falsified and stole Social 
Security numbers to assist third parties she knew to be ineligible in 
obtaining child care licenses. Two other providers gave false 
references for these third parties; 
* All five providers met with a potential grand jury witness and 
encouraged her to lie to the grand jury and investigators, according 
to a trial memorandum; 
* Four of the women pled guilty to conspiracy to make false statements 
and the fifth pled guilty to theft of public funds. All of them were 
sentenced to three years of probation and all but one of them was 
required to pay restitution. 

Case: 5; 
State: Wisconsin; 
Amount: $361,000; 
Month and Year of conviction(s): April 2009/August 2009; 
Case details: 
* Two providers colluded with parents to help them fraudulently 
qualify for the CCDF program and then offered free housing and 
kickbacks to parents who enrolled their children in their child care 
center; 
* One provider recruited parents with large numbers of children to 
register at the child care center. She then charged the state for full-
time care even though some children never attended and others came 
sporadically, according to the complaint filed by the prosecutor; 
* The pair also bought several rental properties which the prosecutor 
said one provider offered free of charge to the parents of enrolled 
children. As part of the scam, court transcripts show that the 
provider had parents apply for government housing subsidies, which she 
illegally accepted in lieu of rent; 
* One provider pled guilty to theft by fraud and was sentenced to 5 
years in jail, 12 years of extended supervision and $300,000 in 
restitution. The other provider pled guilty to a computer crime and 
was sentenced to 30 days at the house of corrections followed by 
probation. 

Source: GAO. 

[End of table] 

Case 1: Two providers fraudulently billed Indiana for $150,310 worth 
of CCDF funds and operated a child care facility in a home where a 
convicted felon lived. According to the investigator's report, the 
fraud began even before the pair opened their first home-based child 
care facility, when the provider who held the child care license 
(license holder) failed to disclose that her stepfather, a twice- 
convicted drug offender, lived in the home. The stepfather had access 
to CCDF funds through joint bank accounts with both providers, 
according to investigators, who also observed him transporting 
children for child care operations. A parent of one child enrolled in 
the child care home even told investigators that she was instructed 
not to mention the stepfather to investigators because "he wasn't 
supposed to be there." 

Once the child care home opened, the unlicensed provider (operator) 
led its day-to-day operations. As part of the scheme, she began 
requesting electronic access cards from parents of children enrolled 
at the child care home, according to the investigator's report. These 
electronic access cards recorded the hours a child spent in a child 
care facility, allowing the operator to inflate the number of hours 
she billed the state for child care.[Footnote 29] Several parents 
interviewed by investigators acknowledged that they freely gave the 
operator their electronic access cards but one parent said the 
operator threatened to take away her spot if she did not provide the 
access card. Many parents acknowledged to investigators that the cards 
had been fraudulently swiped at times when care could not have been 
provided for a variety of reasons including the parent having a 
conflicting work schedule, the child having been moved to another 
child care facility, or the child being in another state at the time. 
While some parents claimed their electronic access cards were used 
without their knowledge, the investigator found that others were aware 
of the scheme or actively participating in it. For example, one parent 
provided her swipe card to the operator in exchange for cash payments 
every 2 weeks.[Footnote 30] 

Several parents also alleged that the provider mistreated their 
children, and the investigator observed that the child care facility 
was dirty and possibly unsafe. For example, several parents said that 
their children were not being fed all day, even though the child care 
home received subsidies from a federal nutrition program.[Footnote 31] 
Parents also alleged that their infants' diapers were not changed, 
resulting in rashes. One parent claimed that the operator put her two 
children, ages 10 and 12, in a closet as punishment. In addition to 
the alleged mistreatment, several parents told the investigator that 
the operator attempted to extract additional payment from them by 
charging cash co-payments in excess of the amount permitted by the 
state, or by convincing them to buy her groceries using their 
electronic access cards to the Supplemental Nutrition Assistance 
Program (SNAP). 

About a year after they opened their first child care home, the 
license holder received a license for a second child care home. Like 
the first facility, the new child care home was run primarily by the 
operator with assistance from the license holder and provided 
additional opportunities for fraudulent billing. For example, the 
second facility was not always open during its regular hours and the 
two child care facilities did not have enough staff to cover all of 
the shifts for which they were supposedly open. When questioned by 
investigators, the operator claimed she was covering both sites by 
working "24 hours a day and 7 days a week." 

The scheme was discovered when a caseworker noted that the operator's 
own children were receiving subsidies to attend the child care home 
where she worked. Furthermore, several clients referred to the 
operator as the owner of the child care home, even though she was not 
licensed. In March 2009, the license holder pled guilty to welfare 
fraud, a class D felony, and the operator made the same plea in July 
2009. Both were sentenced to 2 years in a state department of 
corrections jail. 

Case 2: The owner of a Missouri child care center fraudulently billed 
the state for over $112,242 in CCDF funds, neglected some children in 
her care, and operated a second unlicensed child care center from her 
home. Over 6 years, the child care center's owner fraudulently 
obtained CCDF funds by falsifying invoices and attaching altered or 
forged attendance sheets as support for her claims, according to the 
plea agreement. For example, the owner forged parent signatures and 
attendance times, in some cases incorrectly spelling parents' names on 
the attendance sheets. Several parents admitted to the investigator 
that they never signed any sign attendance sheets for the child care 
center but others said that when they first enrolled their children in 
the child care center, the owner had them sign blank attendance 
sheets. One of these parents signed a single attendance sheet her 
first month and the owner told her she would "take care of everything 
for (the parent) after that." Using these falsified attendance sheets, 
the owner billed full time hours for children who attended part time 
and billed for children who never attended her child care center or 
children who had left the child care center. 

In addition to financial fraud, investigators uncovered instances of 
neglect during their interviews with parents. For example, one parent 
said she went to pick up her children at the child care center, but 
found them at the owner's house locked in a car. Another parent said 
that when she arrived at the facility one day, no one could tell her 
where her daughter was. The parent found her daughter outside 
unattended. The investigators also found that the owner illegally 
billed the state for care provided at an unlicensed child care center 
that she ran out of her apartment. For example, one parent paid cash 
for child care provided at the unlicensed home, even though the owner 
billed for care supposedly provided to the same child at the licensed 
child care center. The parent confirmed that she was not eligible to 
receive CCDF funds and that her child was too young to be enrolled in 
the licensed facility. Furthermore, a former employee testified that 
she watched as many as 25 children at one time in the apartment. 
Investigators noted that the owner moved children from the licensed 
facility to her apartment in the evenings to avoid exceeding the 
required worker-to-child ratio at her licensed facility. 

The owner attempted to obstruct the investigation into her child care 
center, according to the investigator's report. She encouraged parents 
to lie to investigators about the forged signatures, told one parent 
to ignore interview requests and harassed another parent by 
threatening to have her fired. Despite her attempts, the owner was 
charged and pled guilty to mail fraud in December 2008. She received 
15 months in prison, and was required to pay $112,242 in restitution. 

Case 3: An Oregon couple created fictitious child care providers using 
falsified documents and stolen Social Security numbers in order to 
fraudulently obtain $122,616 in CCDF funds. The scam started when each 
parent claimed to be living at a separate address with the children, 
according to the investigator's report. The husband applied for the 
CCDF program using a relative's address in Lake Oswego, Oregon, even 
though he lived in Portland with his wife and children. The husband 
began receiving child care benefits in June 1998 and the wife began 
receiving separate benefits for the same children just one month 
later. Investigators later determined that the husband was the 
children's caregiver, which should have disqualified the family from 
the program. 

To collect the CCDF funds, the couple created fictitious child care 
providers who supposedly cared for their children out of their private 
residences, according to the investigator's report. Using a 
fraudulently obtained Social Security number, a fake name, and the 
address of a commercial mailbox store in Vancouver, Washington, the 
husband applied to become a child care provider. Once the fictitious 
provider was accepted into the program, the husband submitted a 
monthly bill showing the number of hours of care provided and used the 
mailbox to receive checks from the state, which he cashed using the 
fictitious provider's identity. The couple created a different 
fictitious provider to collect the wife's child care subsidies using 
the same method. In this case, however, the husband stole the Social 
Security number and birth date of his half brother, who lived in 
Washington and had never worked in Oregon. 

The investigators found that in order to maintain eligibility for the 
CCDF program, the husband falsified employment records to show that he 
was working. He provided pay stubs similar to those sold at office 
supply stores that showed his employer as "Ablazed and Mystifying 
Women," which he described as a warehouse. In fact, there was no such 
business in Vancouver, no government agency had any records of the 
business, and the investigator was unable to find the building when 
she drove to the address. Furthermore, the husband's alleged home 
address was a 30 minute drive from his supposed employer, but he had a 
suspended driver's license and no vehicles registered in his name. 
However, he did have a driver's license and three vehicles illegally 
registered in the name of one of the fictitious child care providers. 

A caseworker referred the husband for investigation because his 
employment records looked false, according to the investigator's 
report. When the couple became aware of the investigation, they 
attempted to disrupt the investigation. The wife requested that the 
investigator not call her anymore and the husband claimed to have a 
series of family emergencies that prevented him from meeting with 
investigators. The father pled guilty to two counts of theft, five 
counts of identity theft, three counts of aggravated theft, and two 
counts of theft by deception and was then sentenced to 8 years in 
prison and $137,215 of restitution. The mother pled guilty to one 
count of unlawfully obtaining public funds, one count of forgery, two 
counts of identity theft, and two counts of theft by deception and was 
then sentenced to 3.5 years in prison. 

Case 4: Five women colluded to fraudulently bill Washington for $8,806 
in CCDF funds and in some cases, assisted others in illegally 
obtaining child care licenses. For approximately 6 years, the five 
women received funds from the CCDF program and the food reimbursement 
program as child care providers, according to the indictment.[Footnote 
32] The five women billed for fictitious children and children who 
attended school during the hours the women claimed to be caring for 
them. One woman billed for the same child twice, using the child's 
real name and identifying information and also using a false name with 
the child's real identifying information. 

Two of the women assisted others in applying for child care provider 
licenses using false identities even though the women had reason to 
believe the individuals were ineligible due to criminal history or 
immigration status, according to the indictment. One of the women 
provided one applicant with a fake name and Social Security number, 
and provided another applicant the name and Social Security number of 
one of the children under her care. Two other women provided fake 
references for the ineligible applicants' false identities.[Footnote 
33] 

After they became aware of an investigation into their activities, the 
five women met twice with a potential witness for the grand jury and 
tried to convince her to lie to investigators. A federal investigation 
led to an indictment by the U.S. Attorney's Office in August 2007 
charging all five women with conspiracy to make a false statement 
relating to a health care program and theft of public funds. Four of 
the women pled to conspiracy to make a false statement and one pled to 
theft of public funds. Each woman was sentenced to three years of 
probation along with restitution for the amount stolen from the 
program.[Footnote 34] 

Case 5: Two providers operating a large child care center in Wisconsin 
obtained over $360,000 in CCDF funds by colluding with parents to help 
them fraudulently qualify for child care assistance, then offered free 
housing and kickbacks to parents in exchange for enrolling their 
children in the child care center. One of the women held the child 
care license from the state, while the other operated the child care 
center. According to the prosecutor, the operator had previously run 
licensed child care centers, but these were closed and her license 
revoked due to improper billing. However, no charges were filed 
against her. Having lost her license, the operator went into business 
with her daughter, who obtained a child care license from the state in 
her name. Court transcripts note that at first, the child care center 
operated out of various private residences and served a small number 
of children. Later, it expanded into a new facility that was licensed 
to serve 64 children per shift, with three shifts each day. 

According to the complaint filed by the prosecutor, the operator 
solicited mothers to register their children at the child care center, 
particularly those with large numbers of children. She then charged 
the state for full-time care for each child, about $200 per week, even 
though some children did not attend the child care center at all and 
others only attended sporadically. To help these women meet the 
eligibility requirements for the CCDF program, she forged 
documentation showing that they were employed at her child care 
center. Some of these women never worked at the child care center 
while others worked for a limited period of time. In at least one 
case, the operator used CCDF funds to pay a kickback to one woman 
whose children were enrolled at the center. 

To generate more income, the prosecutor said that the operator and 
license holder used funds from the CCDF program to buy several rental 
properties, which the operator offered as rent-free housing to parents 
who enrolled their children in her child care center. As part of this 
agreement, the operator provided the parents with proof of employment 
that allowed them to apply for rental assistance from the city of 
Milwaukee. According to the prosecutor, the operator received the 
rental subsidy for those families accepted into the program and did 
not charge them any rent, a violation of the rental subsidy program's 
policy. 

In April 2009, the operator pled guilty to theft by fraud and was 
sentenced to 5 years in jail followed by 12 years of extended 
supervision and $300,000 in restitution payments to the state. The 
license holder pled guilty to a computer crime for giving her mother 
access to the child care billing system and was sentenced to 30 days 
at the house of correction followed by probation. During the 
daughter's sentencing, the judge noted that the program "was a joke 
with little if any oversight." 

Eligible Children May Not Receive Child Care Services in Some States 
Because of Significant Waitlists: 

Not all eligible families that want to receive CCDF assistance are 
currently able to receive it for a variety of reasons, and fraud and 
abuse in the program may further reduce the availability of CCDF 
funds.[Footnote 35] This lack of child care assistance forces some 
families to cut back on spending for daily needs, working hours, and 
education. Of the 41 waitlisted parents we interviewed, 16 described 
multiple hardships--facing financial difficulties, quitting their job 
or education program, and worrying about negative impacts on their 
children's development.[Footnote 36] Twenty-four parents said they had 
budget problems which forced some to cut back on spending for daily 
essentials such as groceries, clothing, gasoline, electricity, car 
payments, health insurance, or their child's lunch money. Some parents 
told us they had taken out loans or depleted family savings to pay for 
child care. Twenty-four parents reported problems maintaining stable 
employment or enrollment in education, in some cases having to turn 
down or quit jobs that did not pay enough to cover child care 
expenses. Nine parents also told us that a lack of child care caused a 
variety of negative effects on their children, including one parent 
who reported having to send her child to an unlicensed relative who 
does not offer the educational activities that a high-quality child 
care center might. Another parent said that her two developmentally 
disabled children would receive better care at a child care center 
than they currently receive from their elderly grandparents. See table 
5 for the experiences of 10 applicants we contacted. These applicants 
expressed issues common to many of the parents we interviewed. We did 
not attempt to verify the applicants' statements. 

Table 5: Summary of Selected CCDF Waiting List Families: 

Case: 1; 
State: Alabama; 
Months waitlisted: 1; 
Case details: 
* The mother, a single parent of three children, works full time as a 
therapeutic counselor; 
* She spends almost a third of her monthly income on child care even 
though she started sending her children to a lower quality child care 
operation; 
* She said she has cut back on household necessities such as food, 
electricity, and gasoline to pay for child care. 

Case: 2; 
State: Indiana; 
Months waitlisted: 4; 
Case details: 
* The mother, a single parent of one child, works at a fast food 
restaurant while attending nursing school; 
* She relies on family and friends to care for her 6-month-old 
daughter but often has to miss work or school when they are not 
available; 
* She said that her supervisor at work is getting upset with her for 
coming in late or missing work due to child care issues. 

Case: 3; 
State: Alabama; 
Months waitlisted: 12; 
Case details: 
* The mother, a single parent of two children, works full time as a 
certified nursing assistant; 
* After being on the waiting list for a year, she lost her spot for 
missing a recertification date while she was moving. She reapplied and 
has been waiting for about 2 years total; 
* She does not have money to pay for child care and relies on her 
family for child care. When they cannot care for her children, she has 
to miss work. 

Case: 4; 
State: Massachusetts; 
Months waitlisted: 24; 
Case details: 
* The mother, a single parent of two children, works part time as a 
hairstylist; 
* She said that the $55 per week payment for child care is "killing 
her" and that she is "in the worst financial situation of (her) life;" 
* She said that if she obtained child care assistance, she could begin 
working full-time hours again. 

Case: 5; 
State: Massachusetts; 
Months waitlisted: 12; 
Case details: 
* The mother, a single parent of two children, works part time as a 
pharmacy technician; 
* She does not work the full-time day shift at the pharmacy because 
the money she would earn would barely equal the cost of child care for 
her children; 
* She said that if she obtains child care assistance, she could work 
during the day and make more money to support her family. 

Case: 6; 
State: Massachusetts; 
Months waitlisted: 6; 
Case details: 
* The mother, a single parent of three children, works full time as a 
nurse's aide; 
* She said that if she received child care, she could go back to 
school to become a registered nurse, which would allow her to earn 
more money to support her family. 

Case: 7; 
State: Minnesota; 
Months waitlisted: 7; 
Case details: 
* The mother, a single parent of three children, works part time as a 
personal care assistant; 
* She had to cut back from full time to part time hours because she 
does not have child care. This change in hours caused her to lose her 
health insurance and tighten her budget. 

Case: 8; 
State: Texas; 
Months waitlisted: 1; 
Case details: 
* This married couple has two children. The mother works full time and 
the father stays home to care for the children during the day; 
* The father said that he was employed but that his income barely 
covered child care so he quit his job to watch the children. He said 
that the position is still open for him if he can find child care. 

Case: 9; 
State: North Carolina; 
Months waitlisted: 1; 
Case details: 
* The mother, a single parent of two children, works at a fast food 
restaurant part time; 
* She relies on her cousin to provide child care, but her cousin has 
not been reliable. The mother has had to miss work, come in late, and 
change her schedule at the last minute; 
* She is also worried that her younger child is missing out on early 
educational opportunities he could get in child care. 

Case: 10; 
State: North Carolina; 
Months waitlisted: 7; 
Case details: 
* The mother, a single parent of two children, works full time 
processing patients' medical bills; 
* She does not earn enough to pay her bills each month and has tried 
to cut her budget by reducing their groceries, electricity usage, and 
her own health insurance. She has had to borrow money to maintain the 
household; 
* She said that she would like to go back to school, but is not sure 
if she will be able to do so. 

Source: GAO. 

[End of table] 

According to state program administrators, Recovery Act funds for the 
CCDF program have enabled some states to reduce or eliminate waiting 
lists or expand CCDF eligibility to cover additional families, but 
many eligible families remain without child care assistance. States' 
CCDF implementation plans for fiscal years 2008 to 2009 identified 25 
states that have processes to maintain some type of waiting list when 
demand exceeds available funds.[Footnote 37] We contacted 11 states 
that had active waiting lists between November 2009 and March 2010. 
Mississippi used Recovery Act funds to process all of the children on 
their waiting list, eliminating 7,000 individuals from the waiting 
list in April 2009. Arkansas also eliminated its waiting list but 
later reinstated it due to an increase in new applications. In 
Florida, officials used Recovery Act funding to allow children to stay 
in the program for longer periods. In North Carolina, officials told 
us Recovery Act funds allowed them to respond to the state's high 
unemployment rate by expanding eligibility to unemployed parents who 
needed child care to search for a job. However, California told us 
that Recovery Act funds have not had a noticeable impact on the size 
of its waiting list of 134,880 families. Furthermore, New Hampshire 
had to institute a waiting list due to the increase in demand, though 
program officials acknowledged that Recovery Act funds delayed the 
implementation of the waiting list. In one of the counties we tested 
in New York, cuts to the child care budget during our undercover tests 
eliminated 1,091 children from the program. However, due to the low-
income fraudulently reported by the parents, their fictitious children 
would have continued to receive assistance if we had not withdrawn 
them from the program.[Footnote 38] 

Corrective Action Briefing: 

Between July 16 and September 10, 2010, we briefed HHS officials and 
CCDF program officials in Illinois, Michigan, New York, Texas, and 
Washington on the results of our work. We suggested a number of 
actions that HHS and states should consider to reduce fraud and abuse 
in CCDF programs, including: 

* Require applicants, household members, and providers to submit 
Social Security numbers in order to receive child care assistance. 

* Evaluate the feasibility of validating applicant and family member 
identity information with SSA. 

* Establish more stringent verification requirements for eligibility, 
including validating applicant-provided information using state 
databases of wage, employment, public assistance, and child support 
information; contacting employers directly to verify employment; and 
using Internet resources to verify address information. 

* Implement a system to alert staff to child care applications 
previously rejected for fraud to prevent the applicant from 
resubmitting in the same county or another county. 

* Evaluate the feasibility of requiring all providers, including 
relative providers, to undergo national fingerprint criminal history 
checks and screenings against the national sex offender registry and 
state child abuse databases. 

* Establish more stringent verification of bills submitted by child 
care providers, including requiring program staff to verify that the 
number of reported hours of child care correspond to the number of 
hours worked by the parent; denying unsupported claims for extra hours 
worked; and restricting the number of hours that a provider can bill 
over the authorized amount without documentation. 

Each of the states we tested already had some of these controls in 
place or has plans to implement some of them in the near future. For 
example, Illinois, Washington, and Michigan conduct some verification 
of applicant information against state child support and public 
assistance databases. Several counties in New York use an electronic 
system to compare hours worked on parents' pay stubs to the hours 
billed by providers, and officials told us they plan to put the system 
into use state wide. Texas officials told us that they intend to 
implement a new, electronic billing system that will include controls 
to prevent over billing. However, in some cases, officials cited 
concerns about the cost and legal implications of increased 
verification. For example, Texas expressed concern that conducting 
fingerprint criminal history checks on providers would impose 
additional costs on the program. Some states noted that they are not 
permitted to require parents to submit SSNs, while New York state 
officials told us they do not have the legal authority to verify SSNs 
submitted by parents or providers. HHS did not respond to issues 
surrounding the collection and verification of SSNs at the time of our 
briefing. Recognizing that preventing fraud often involves additional 
costs, some of our suggested corrective actions allow for HHS and 
states to evaluate the feasibility of control activities. 

Responding to our findings, HHS commented that they have recently 
taken actions to address issues of CCDF integrity. For example, HHS 
officials said that program guidance issued in August 2010 discussed 
recommended documentation and verification procedures, including data 
matching with wage and employment databases; data matching with other 
public assistance databases; and background checks and training for 
providers. The guidance also highlighted on-site visits to providers 
to review attendance and enrollment records. Officials noted that an 
electronic system, the Public Assistance Reporting Information System, 
uses an SSN match across states to identify red flags of individuals 
enrolled in benefit programs in multiple states. Only eight states 
currently use this system for CCDF, but officials said the August 2010 
program guidance encouraged more states to join. In addition, 
officials said that HHS has an ongoing conference call series on 
program integrity, which has covered promising practices on how to use 
data mining and automated reports to highlight cases that need further 
scrutiny. 

HHS officials also commented on upcoming initiatives related to fraud 
prevention. For example, officials said that state CCDF applications 
for fiscal years 2012-2013 will have a stronger focus on integrity, 
including questions on the verification of eligibility information, 
and procedures for identifying, investigating, and recovering 
fraudulent payments. In the coming year, HHS's Self-Assessment 
Instrument for Internal Controls & Risk Management will be revised and 
piloted in more states, and will include fiscal and program evaluation 
and stricter controls to prevent over billing. 

We are sending copies of this report to the Secretary of Health and 
Human Services and the child care program offices of Illinois, 
Michigan, New York, Texas, and Washington. In addition, the report is 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

Please contact me at (202) 512-6722 or kutzg@gao.gov if you have any 
questions concerning this report. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. GAO staff who made major contributions to this 
report are listed in appendix II. 

Signed by: 

Gregory D. Kutz: 
Managing Director: 
Forensic Audits and Special Investigations: 

List of Addressees: 

The Honorable Mitch McConnell: 
Republican Leader: 
United States Senate: 

The Honorable Joseph I. Lieberman: 
Chairman: 
The Honorable Susan M. Collins: 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Charles Grassley: 
Ranking Member: 
Committee on Finance: 
United States Senate: 

The Honorable Michael Enzi: 
Ranking Member: 
Committee on Health, Education, Labor, and Pensions: 
United States Senate: 

The Honorable George Miller: 
Chairman: 
Committee on Education and Labor: 
House of Representatives: 

The Honorable Edolphus Towns: 
Chairman: 
The Honorable Darrell Issa: 
Ranking Member: 
Committee on Oversight and Government Reform: 
House of Representatives: 

[End of section] 

Appendix I: Scope and Methodology: 

To proactively test selected states' fraud prevention controls, we 
identified 26 states that received more than $100 million from the 
Child Care and Development Fund (CCDF) for fiscal year 2009. From 
these states, we identified six that did not require providers to be 
fingerprinted or undergo site visits and selected the five states 
receiving the most American Recovery and Reinvestment Act (Recovery 
Act) funding. We focused on these criteria because fingerprint checks 
could have identified our investigators as federal employees and site 
visits would have required us to maintain a physical address for our 
fictitious child care operator. In addition, we selected counties 
within the five states that contained large cities, where possible, 
and did not have waiting lists for assistance to ensure that we did 
not prevent real families from obtaining assistance. We tested two 
counties in Illinois, Michigan, New York, Texas, and Washington to 
develop our 10 undercover tests. 

Though all types of providers are potentially able to commit fraud, we 
chose to test cases in which a relative is paid to provide care 
because these providers are generally subject to less regulation than 
larger child care centers. Relative providers cared for 12 percent of 
children in the CCDF program in 2008, while other types of providers 
accounted for the rest. As such, our results cannot be applied to 
licensed child care providers, such as child care centers, nor can our 
results be projected to all state CCDF programs. We used commercially 
available hardware and software to counterfeit identification and 
employment documents for bogus parents, children, and providers. Once 
accepted, we billed the program for care provided to the fictitious 
children. We provided fraudulent pay stubs showing the hours worked by 
parents and reported those hours through automated systems or 
completed invoices we submitted to the state or county for payment. We 
received several child care assistance checks, which we did not cash 
and returned to program officials at the end of our investigation. 
During our tests, media reports indicated that the child care 
assistance budget in one county had been reduced. We immediately ended 
our undercover test in this county and returned the voided check. 

To select our case studies, we identified criminal convictions of 
child care assistance fraud nationwide using online databases and 
internet resources to identify closed cases. As part of the selection 
process, we focused on cases involving a high dollar amount of fraud 
or containing other elements of fraud such as stolen identities. 
Ultimately, we selected 5 cases from Indiana, Missouri, Oregon, 
Washington, and Wisconsin. We reviewed applicable court documents for 
each case. When possible, we also interviewed investigators and 
prosecutors in charge of the selected cases to obtain additional case 
details. 

To examine the impact of being unable to obtain child care on low- 
income parents, we contacted officials in states and counties with 
active child care assistance waiting lists to obtain names of parents 
currently eligible for child care assistance. States' CCDF 
implementation plans for fiscal year 2008 to 2009 identified 25 states 
that have processes to maintain some type of waiting list when demand 
exceeds available funds.[Footnote 39] However, these waiting lists 
fluctuate over time and we could not identify a centralized list of 
all states with active waiting lists. We confirmed active waiting 
lists in 11 of the states from November 2009 through March 2010. Of 
these 11 states, Alabama, Indiana, Massachusetts, Minnesota, North 
Carolina, and Texas provided us with contact information for 
individuals on state waiting lists, which we used to contact parents 
directly.[Footnote 40] Starting from the top, we selected a 
nonrepresentative sample of 166 parents to contact and interviewed the 
41 who responded to our inquiries. We collected information such as 
the number and ages of children and the parents' job title and income 
to determine demographic information. However, we did not attempt to 
verify the accuracy of the information that they provided to us. Our 
results are not representative of the entire population of families 
currently in need of child care assistance. 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Gregory D. Kutz, Managing Director, 202-512-6722, kutzg@gao.gov: 

Acknowledgments: 

In addition to the individual named above, the following individuals 
made key contributions to this report: Cindy Brown-Barnes, Assistant 
Director; Andrew O'Connell, Assistant Director; Joshua Bartzen; Gary 
Bianchi; Eric Charles; Grant Fleming; Matthew D Harris; Christine 
Hodakievic; Aaron Holling; Jason Kelly; Barbara Lewis; Jeffrey 
McDermott; Andrew McIntosh; Sandra Moore; George Ogilvie; Kimberly 
Perteet; Gloria Proa; Lerone Reid; Ramon Rodriguez; Timothy Walker; 
and John Wilbur. 

[End of section] 

Footnotes: 

[1] In some states, parents looking for employment are also eligible 
for child care assistance. 

[2] Each state's annual federal CCDF allocation consists of separate 
mandatory, matching, and discretionary funds. A state does not have to 
obligate or spend any state funds to receive the discretionary and 
mandatory funds. However, to obtain matching funds, a state must meet 
certain requirements. 

[3] The Improper Payments Information Act of 2002 defines improper 
payments as any payment that should not have been made or that was 
made in an incorrect amount (including overpayments and underpayments) 
under statutory, contractual, administrative, or other legally 
applicable requirements. It includes any payment to an ineligible 
recipient, any payment for an ineligible service, any duplicate 
payment, payments for services not received, and any payment that does 
not account for credit for applicable discounts. 

[4] A fingerprint background check could potentially have identified 
our investigators as GAO employees. 

[5] During our tests, media reports indicated that the child care 
assistance budget in one county had been significantly reduced. We 
immediately ended our undercover test in this county and returned the 
voided check. 

[6] In some states, the administration occurs at the state level and 
waiting lists are maintained at that level. In other states, these 
lists are maintained at local levels by counties or local workforce 
boards. 

[7] 45 C.F.R. § 98.20. States may provide assistance to children under 
age 19 physically or mentally unable to care for themselves. CCDF 
funds are also available for children in protective services. 

[8] While the block grant does not require states to develop new 
requirements if existing ones comply with the statute, it does 
stipulate that these requirements cover the following areas: 
prevention and control of infectious diseases, building and physical 
premise safety, and minimum health and safety training appropriate to 
the provider setting. 

[9] These represent average monthly percentages of children served in 
different types of care. Other care arrangements included care by 
licensed providers in the child's home or a group home, care by 
unlicensed nonrelatives in the child's home, a family or a group home, 
and invalid/not reported entries. 

[10] 45 C.F.R. § 98.51 In addition to the set aside for quality within 
CCDF, states are also required to spend at least 4 percent of their 
CCDF funds on activities to improve child care quality. 

[11] 42 U.S.C. § 618. 

[12] In order to receive these funds, a state must: (1) provide 
matching funds at the state's current Medicaid match rate; (2) 
obligate the federal and state share of matching funds in the year in 
which the matching funds are awarded; (3) obligate all of its 
mandatory funds in the fiscal year in which the mandatory funds are 
awarded; (4) obligate and expend its maintenance of effort (MOE) funds 
in the year in which the matching funds are awarded. (MOE means a 
state must continue to expend its own funds at the level it was 
matching the former Aid to Families with Dependent Children-linked 
child care programs in fiscal year 1994 or fiscal year 1995, whichever 
was greater.) 

[13] GAO, TANF And Child Care Programs: HHS Lacks Adequate Information 
to Assess Risk and Assist States in Managing Improper Payments, 
[hyperlink, http://www.gao.gov/products/GAO-04-723] (Washington D.C.: 
June 18, 2004). 

[14] GAO, Internal Control Management and Evaluation Tool, [hyperlink, 
http://www.gao.gov/products/GAO-01-1008G] (Washington, D.C.: August 
2001). 

[15] States administer their programs independently and can adopt a 
variety of organizational and administrative structures for 
implementing child care assistance programs funded through CCDF. To 
avoid any confusion, the following cases all use the term CCDF program 
as a general description of the state programs that use CCDF funds. 

[16] In Washington, parents were not required to submit driver's 
licenses, birth certificates or Social Security cards. 

[17] New York officials told us they are not legally permitted to 
verify parent, child or provider SSNs. 

[18] Texas officials told us that they can run some limited checks on 
state wide child care cases to identify duplicate parent and child 
SSNs, but this is done on a quarterly basis, not at the time a parent 
applies to the program. 

[19] Texas officials told us that they also use state unemployment 
insurance data to verify applicant-provided employment information, 
but due to state laws about business registration, not all employers 
are in their database. In addition, these checks are run on a 
quarterly basis, not at the time of application. 

[20] New York state officials told us that they are not legally 
permitted to verify parent, child or provider SSNs. 

[21] We only tested reapplication processes in four states. In 
Michigan, one of our providers was accepted into the program the first 
time she applied and the other provider's initial application process 
took so long that we did not have a chance to reapply. 

[22] The Texas caseworker later grew suspicious about the provider's 
multiple addresses and out-of-state driver's license and requested 
that the provider appear in person with all original documentation, at 
which point we stopped our application. The provider was approved in 
Washington. 

[23] According to New York officials, caseworkers were unable to 
calculate the distance between the provider's house and the parent's 
employer because they were located in a different county than the 
child care office. 

[24] In these states, our fictitious providers and/or parents were not 
accepted into the program. 

[25] Texas officials said they are implementing a new electronic swipe 
card billing system, in which parents will use an electronic access 
card to record the time their child arrives at and departs from child 
care. The electronic data will be transmitted automatically, 
eliminating the need for the provider to submit bills. For relative 
providers, parents will use a phone-based system to record the child's 
time in and time out. 

[26] One other case took over 3 months from the time the application 
was submitted to the final decision, but this was due to agency 
requests for additional documentation. 

[27] For further information on the fraud prevention model see: GAO, 
8(a) Program: Fourteen Ineligible Firms Received $325 million in Sole 
Source and Set Aside Contracts, [hyperlink, 
http://www.gao.gov/products/GAO-10-425] (Washington, D.C.: March 30, 
2010); Service-Disabled Veteran-Owned Small Business Program: Case 
Studies Show Fraud and Abuse Allowed Ineligible Firms to Obtain 
Millions of Dollars in Contracts, [hyperlink, 
http://www.gao.gov/products/GAO-10-108] (Washington, D.C.: October 23, 
2009). 

[28] States administer their programs independently and can adopt a 
variety of organizational and administrative structures for 
implementing the CCDF program. To avoid any confusion, the following 
cases all use the term child care assistance as a general description 
of the programs that accept funds from the CCDF program. 

[29] Indiana parents are required to swipe the card in a device 
maintained by the provider when the child arrives at the child care 
facility and when the child departs at the end of the day, though 
swiping after the fact is allowed for 13 days after the transaction. 
Some states track the number of hours of care using sign-in sheets 
maintained by providers and signed by parents or hours reported 
separately by parents and providers. Some states make payments based 
on hours submitted by providers alone. In two of three states in which 
we tested billing procedures, both the parent and the provider were 
required to certify the number of hours of care provided, either by 
signing an attendance sheet or recordings hours electronically using a 
personal identification number (PIN). 

[30] This woman was involved in another child care fraud case where 
she falsified pay stubs to receive approximately $2,452. Most of the 
parents in this case were not charged. 

[31] State investigators referred this case to the United States 
Department of Agriculture Office of Inspector General, but the office 
chose not to pursue it. 

[32] The child and adult care food program food reimbursement 
subsidies are administered by the Columbia Basin Educational 
Association through the Washington State Office of the Superintendent 
of Public Instruction (OSPI) and funded through grants from the United 
States Department of Agriculture (USDA). 

[33] One of these women was an unindicted conspirator named in the 
indictment. This woman was charged separately from this case and pled 
guilty to identity theft and theft. 

[34] One of the women was not ordered to pay any restitution. 

[35] We recently reported on multiple factors that could have 
contributed to a decline in the number of children served by CCDF from 
fiscal years 2006 to 2008. These included state decisions about 
resource allocation, decreasing Temporary Assistance for Needy 
Families funds transferred to CCDF, and changes in state-level 
requirements. In addition, the recession may have affected the 
availability of providers, parents' child care choices or parents' 
ability to meet work-related requirements. See GAO, Multiple Factors 
Could Have Contributed to the Recent Decline in the Number of Children 
Whose Families Receive Subsidies GAO-10-344 (Washington D.C.: May 5, 
2010). 

[36] We recently reported that research has linked access to child 
care subsidies to increases in the likelihood of low-income mothers' 
employment. See [hyperlink, http://www.gao.gov/products/GAO-10-344], 
p. 26. 

[37] States are allowed to choose whether or not to maintain a waiting 
list as part of their implementation plan. Furthermore, states may 
have a process in place to maintain a waiting list, but not actually 
maintain one at a given point in time depending on demand for child 
care. The absence of any waiting list process does not necessarily 
mean that there is not excess demand for child care assistance in a 
given state. 

[38] The New York county decreased the eligibility level from 200 
percent of the poverty limit to 125 percent of the poverty limit. 
However, our fictitious families were still under 125 percent so they 
would have remained on the program. 

[39] States are allowed to choose whether or not to maintain a waiting 
list as part of their implementation plan. Furthermore, states may 
have a process in place to maintain a waiting list, but not actually 
maintain one at a given point in time depending on demand for child 
care. The absence of any waiting list process does not necessarily 
mean that there is not excess demand for child care assistance in a 
given state. 

[40] Some states maintain waiting list information at different 
administrative levels, such as county or local board level and 
referred us to the appropriate level. We were not able to obtain 
waiting list information from every state we contacted. 

[End of section] 

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