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ACF webinar for year‑3 states clarifies case review rules, MID table process, PII limits and reporting deadlines
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Summary
A webinar from the Administration for Children and Families’ National Center on Subsidy Innovation and Accountability walked year‑3 states through front‑end vs. back‑end error definitions, how to complete columns 2–5 and the MID table, PII rules for worksheets, and key deadlines including the ACF‑404 due 06/30/2025.
Katie Watts, error‑rate lead with the National Center on Subsidy Innovation and Accountability, led a webinar for year‑3 states that detailed how to conduct CCDF case record reviews, how to use the MID (missing or insufficient documentation) table and when states must file corrective action plans.
Watts opened by reminding attendees that the review covers only front‑end eligibility errors — those that occur at eligibility determination, redetermination or subsequent case actions — and not back‑end issues such as payment or billing problems. "This error rate review only includes front end errors," she said, and she offered several side‑by‑side examples to show how otherwise similar outcomes can fall into different categories depending on when the error occurred.
Why it matters: the state improper payments report (the ACF‑404) is due 06/30/2025. "If your error rate is over 10%, you would be required to submit a corrective action plan," Watts said, specifying that any required plan must be filed within 60 days of the ACF‑404 submission deadline.
The bulk of the session walked attendees through practical worksheet guidance. Watts described the distinct purposes of columns 2, 3 and 4: column 2 is the analysis (customized by state policy), column 3 is a brief summary of findings (no new analysis), and column 4 applies a standardized coding scheme (item 1: 0/1 for error; item 2: NA/Y/N for MID; item 2a when applicable). She stressed that reviewers should use comment boxes in column 2 to record calculations and documentation used for verification, but should avoid duplicating analysis in column 3.
On replacement cases and interagency records, Watts reminded lead agencies that replacements require regional approval and that the CCDF lead agency remains responsible when other entities perform eligibility tasks. Written agreements and access to supporting documentation are regulatory requirements so reviewers can validate eligibility decisions made by partner entities.
A substantial portion of the training covered the MID table and the "additional inquiry" process. Watts laid out the six steps: enter the child ID (required for all 276 sample worksheets), determine whether an element has a potential MID improper payment, decide if an additional inquiry can be conducted using state‑available resources, perform that inquiry when allowed, complete the MID table rows, and return to update the element with any newly found information. She emphasized that additional inquiries may use only sources available within the state and may not involve contacting clients or employers.
Watts used examples to show how mitigation is recorded: contact with another agency (the SNAP office in the example) can provide income verification and reduce a potential improper payment; in that case the MID table must record the mitigated amount and reviewers update the element summary accordingly. She also warned that totals on the MID table are not straight arithmetic across elements; reviewers must account for sample‑month payment logic when computing case totals.
The training clarified coding expectations for element 500 (the case summary): column 1 should cite all elements with errors and item 2 aggregates MID‑related findings using the MID table data and the handout flowchart. Watts recommended that states consult the handout distributed before the webinar when handling cases with multiple errors.
Privacy and file handling were highlighted. Asked whether including a child's date of birth in a comment box would be considered personally identifiable information, Watts answered, "Yes. It is considered PII, birth date." She instructed states not to include PII in worksheets sent for joint case reviews, and to remove cover sheets with PII before sharing files; receiving PII triggers a reportable offense.
Watts closed by listing technical assistance the center can provide — reviewing worksheet templates, checking completed worksheets, and answering ambiguous cases — and reminding attendees of the deadline for submitting customized record‑review worksheet templates (December 31) and the joint case‑review call that typically happens after roughly three months of reviews.
The webinar included questions from state participants about when to use comment boxes, how to treat declaratory statements of relationship, and whether previously completed reviews must be altered to comply with new guidance; presenters recommended sharing examples with regional offices for tailored advice and said states would not be required to retroactively change finished worksheets in bulk.
Next steps: states should ensure their worksheet templates and sampling plans let reviewers access documentation from partner entities, confirm how they will handle replacement cases with their regional office in advance, and begin filling the MID table child IDs for all sample worksheets.
