Beyond Compliance: Strengthening Program Integrity in Child Care Assistance Programs

Child Care Assistance Programs (CCAP) operating under the Child Care and Development Fund (CCDF) support access to child care for eligible families while advancing child care quality and health and safety standards. Like many large public benefit programs, CCAP operations are inherently complex. They involve high transaction volumes, time-sensitive eligibility and authorization decisions, large provider networks, and administration across multiple systems. 

Recent, highly publicized cases involving fraud and state child care subsidy programs have increased attention on how agencies manage risk across large, distributed provider networks. During periods of heightened scrutiny, agencies are often asked not only whether they meet requirements, but whether their day-to-day operations reliably prevent, detect, and respond to fraud and improper payment risk. Scrutiny may center on provider management and oversight, the reliability of attendance and billing processes and documentation, and whether payments consistently align with authorizations.  

These are operational areas where volume and complexity can magnify gaps and create exposure. This makes it especially important to distinguish between compliance and program integrity, not just what is required, but how the program operates in practice.  

Key Takeaways 

• Compliance is essential, but program integrity involves broader strategies, including governance structures, internal controls, payment integrity, and fraud risk management.  
• Fraud risk management should be embedded in program workflows. Prevention, detection, and response are most effective when built into routine workflows and updated as risks change. 
• Sustained integrity requires cross-functional alignment across program operations, IT, finance, and vendor partners.  

Compliance must remain a foundational pillar for state programs. Agencies must meet federal regulatory requirements, fulfill commitments under the State Action Plan, withstand audits, and respond to routine oversight activities. However, compliance alone is not a complete risk strategy. Programs can be committed to compliance and still face exposure when policies must be carried out through complex workflows, multiple systems, and an evolving regulatory landscape. These operational realities can also create opportunities for fraud to exploit gaps. Risk is reduced when regulatory requirements are operationalized into repeatable operating practices across eligibility, provider management, and payment processing, with clear ownership and consistent follow-through.   

From Compliance to Program Integrity 

Leading agencies treat compliance as the starting point and build toward program integrity. The U.S. Treasury and CFO Council Antifraud Playbook defines program integrity as an umbrella encompassing governance structures, internal controls, payment integrity, and fraud risk management, not merely compliance with requirements. Program integrity reflects how effectively operations keep eligibility, authorizations, verification, and payments aligned.  

Within a broader program integrity strategy, fraud risk management provides a structured way to identify risks and align controls and monitoring activities. The GAO Framework for Managing Fraud Risks organizes leading practices into four components: Commit, Assess, Design and Implement, and Evaluate and Adapt, with an emphasis on prevention. For agency leaders, this means clear ownership, a current fraud risk profile informed by a fraud risk assessment, targeted controls in the highest-risk workflows, and routine testing and refinement of controls as risks change.  

CCDF’s program integrity requirements reflect a similar focus by emphasizing internal controls that support integrity and accountability while maintaining continuity of services. They also require agencies to identify, investigate, and recover fraudulent payments and impose sanctions when fraud is found.  

Where Risk Concentrates in CCAP 

An end-to-end view of CCAP operations helps clarify where risk is most likely to arise. Risk tends to concentrate in the following operational areas: 

• Eligibility and redetermination 
• Authorization and overrides 
• Provider enrollment and monitoring 
• Attendance and verification 
• Provider changes and/or transfers 
• Billing, rate application, and payments 
• Recovery, sanctions, and appeals 

Common integrity-strengthening practices in these areas include: 

• Clarify governance and decision ownership for eligibility changes, authorization overrides, provider enrollment and monitoring, payment approvals, and corrective actions, including clear escalation paths and consistent documentation of decisions.  
• Embed payment integrity and preventive controls into workflows with consistent exception routing and documentation expectations that support effective review. 
• Engage cross-functional stakeholders across program operations, IT, finance, and vendor partners.  
• Strengthen fraud identification by formalizing database linkages and record matching where available; establishing consistent reviews of attendance and billing records; monitoring override and exception trends; performing quality control reviews; and training staff on monitoring and audit processes.  
• Implement a fraud risk management framework that emphasizes prevention, detection, response, and evaluates and adapts controls as risks change.  

In a high-volume program administered across multiple systems and a large provider network, compliance is essential, but it is only the beginning. Program integrity is the commitment to consistent execution that supports timely payments, credible oversight, and reliable response when risks emerge, while maintaining continuity of services for families who rely on care.  

Aligning Experience for Success  

At EisnerAmper, we understand the importance of compliance, program integrity, and fraud risk management. With relevant prior experience, our team is uniquely equipped with the knowledge, experience, and resources to usher your agency toward success.