ACF webinar walks states through completing the ACF‑404 error‑rate report

Katie Watts, error rate lead with the National Center on Subsidy Innovation and Accountability, led a webinar for year‑three states detailing how to complete the ACF 404 state improper‑payment report and use the OLDC submission system.

Watts told participants the year‑three cohort should continue using the prior data collection instructions (DCI) that were provided with the handouts rather than a recently approved revision. “The year three states are to refer to the prior DCI, the one that you’ve already been using…that is the one you are to be using in completing your ACF 404 report,” she said. She reminded states that the ACF‑404 is due June 30 and that the OLDC will auto‑calculate many fields.

The webinar focused on three report parts. Watts described part one (assurances and certifications, completed last in the OLDC and sometimes prepopulated), part two (quantitative error measures derived from the record review worksheet element 500) and part three (narrative responses that explain findings and planned corrective actions). She reiterated that the sample size for the review is fixed at 276 cases and that states should base many 404 entries on what reviewers recorded in element 500.

On numeric items and thresholds, Watts used an illustrative example to show how states tally errors and improper payments: item two counts any case with an error (example: 45 of 276, or 16.3%), item four counts only cases with an improper payment (example: 19), and item 12 is the state's error rate (example shown: 2.26%). She warned that an error rate above 10% would require the state to submit a corrective‑action plan.

Watts spent substantial time on missing or insufficient documentation (MID) errors. She explained that item counts for MID can count errors (more than one per case) and demonstrated how to populate item 18 (a table listing each MID error, the dollar amount, whether an additional inquiry was attempted, mitigation amounts and the rationale). She noted states must include all MID potential improper‑payment errors in item 18, even if those errors were mitigated through additional inquiry.

Regarding pooling factors and dollar math, Watts taught that states must calculate any pooling factor themselves before entering pooled‑fund adjustments into the OLDC; the OLDC does not provide a field for the pooling factor. She also described item 14A (total CCDF subsidy payments across the 12‑month review period) and item 14B (estimated annual improper payments, computed as error rate × annual payments).

On process and quality checks, Watts urged states to cross‑check related items so totals align (for example, item 7A vs. 8A/9A vs. item 18 and item 19). She warned that replacement sample cases require prior regional office approval and that submitting a 404 in the wrong report period in the OLDC requires redoing the report in the correct period.

When a participant raised a staffing question, Linda Windings, a child‑care program specialist with the Office of Child Care’s Oversight and Accountability Division, explained account access requirements for e‑signatures: “As long as the person who is certified and submitting has an account and has access … that’s the only way that they’ll be able to actually do the e‑sign.”

Watts closed with practical tips: test OLDC access early, save work often (the OLDC does not autosave), keep a Word backup, validate before certifying to see errors/warnings, and note that once submitted the federal office must release the report to allow edits. She invited states to request technical assistance and draft reviews and announced office‑hour drop‑in sessions on June 5 and June 26 at 3 p.m. Eastern.

For follow up, Watts gave contact guidance for state error‑rate specialists (Mike, Tamara or Danielle by state) and provided her email for general questions: kwatts@wrma.com. The webinar ended with an offer to review draft 404 reports before the June 30 submission deadline.