- TO:
- ALL COUNTY OFFICES
- FROM:
- ALYSON CAMPBELL, DIRECTOR
- SUBJECT:
- PROGRAM IMPROVEMENT PLAN (PIP)
DISCUSSION:
At the suggestion of the Food Stamp Corrective Action Work Group, the name of the Corrective Action Plan (CAP) is changed to Program Improvement Plan (PIP). The purpose of this memorandum is to introduce the new form and instruct staff on PIP development. The following subjects are addressed:
- Program Improvement Plan (PIP)
- Federal Requirements
- When to complete a PIP
- The PIP Process
- Sources of Data, and
- Training.
Program Improvement Plan (PIP)
The Program Improvement Plan (PIP) identifies program deficiencies or problem areas and actions to correct those problems. Deficiencies are identified through various sources of data such as case reviews, customer feedback, and management reports.
Once identified, the severity and scope of the deficiency is evaluated. Possible solutions should include input from all levels of staff and be specific when identifying tasks, dates of completion, and responsible parties. The PIP is a living document subject to changes and revisions and is an opportunity to think outside the box to develop creative new ideas for program improvement. PIPs are monitored, reviewed, and evaluated by county staff to ensure tasks are completed and revisions made if necessary.
PIPs are used for all program types. PIPs can be especially beneficial when dealing with customer service problems if the County Manager deems this to be an appropriate response. A PIP is an opportunity to create new ways of addressing problems, processes, and concerns.
A PIP is most successful when completed by all levels of staff. Tasks are developed and implemented by all staff members. Communicate the goals and progress of the PIP to all staff, not just management or the staff directly involved.
Code of Federal Regulations 7CFR 275.15, 275.16, and 275.17 require agencies to analyze and evaluate management information to identify deficiencies in program operations. The information must include causal factors along with their relationships to errors and error trends. This data is used to develop the PIP. PIPs are monitored for progress and effectiveness.
PIP development and implementation is required when deficiencies are identified which result in errors or poor customer service. PIPs must be completed for the Food Stamp Program if:
- the positive payment error rate is 6% or greater,
- the negative error rate is 1% or greater,
- errors or error trends are identified through case reviews,
- errors or poor customer service is identified through a review of local hearing decisions,
- deficiencies are indentified as a result of an FNS (Food and Nutrition Service) review, GAO (Government Accountability Office) audits, contract audits, Quality Control ME (Management Evaluation) review, or USDA (United States Department of Agriculture) audits or investigations, and
- under issuances, improper denials, or improper terminations of benefits, are a result of state agency rules, practices, or procedures.
PIPs may also be completed any time for any program, when the supervisory or management staff deem it necessary. County or region staff do not have to wait for State Office to request a PIP. PIP development is determined on many levels. A PIP can be done by Income Maintenance Supervisors, County Managers, Eligibility Specialists, or Regional Administrators. Local management staff must address deficiencies anytime program operations result in errors or when less than adequate services are provided to participants.
A good Program Improvement Plan begins with good data. Staff must gather and analyze data to determine if an error trend or deficiency exists. Determine the causal factor and root cause of the deficiency, if appropriate. The root cause offers possible explanations as to why the error/deficiency occurred. Determine the scope of the error/deficiency.
EXAMPLE: Mr. J, Little County Income Maintenance Supervisor, is reviewing a Quality Control review for one of his eligibility specialists, Mrs. W. The review shows that an overpayment of $95.00 was found. The reviewer states that unemployment compensation was not projected as income at the time of the last application.
The worker failed to recognize that the EU member was receiving the benefit on the IMES. A review of previous case readings discloses that Mrs. W has had this error before on other case readings.
Mr. J reviews the county’s Quality Control tracking log and finds that several other eligibility specialists have had this error. Mr. J meets with his staff to discuss possible reasons for the error and they discuss possible solutions to resolve the deficiency. Mr. J and his staff decide a PIP is needed.
Data is used to identify the error element, cause of the error, when the error occurred, the geographic extent of the error, the type of most recent action, how or where QC found the error. Additional information may include if the error is an overpayment or underpayment, and the number of cases and dollar errors. Involve staff from all levels when brainstorming potential Program Improvement Plans.
Completed PIPs are emailed to the Income Maintenance Program and Policy Unit at colefspolicy@dss.mo.gov , cole.mhnpolicy@dss.mo.gov , or fsd.coletapolicy@dss.mo.gov as appropriate. Do not wait until all actions are complete and the PIP is ready to close to submit the PIP. The Program Improvement Plan (PIP) form and instructions are located in D:\fsforms and in the IM Forms Manual, Volume II.
Regional and county staff must monitor the various reports available through the Case Review System and Managed Reporting. Review Quality Control findings, Management Evaluation findings, fair hearings, customer complaints, and employee suggestions. The following are reports that are particularly beneficial sources of data.
- Payment Accuracy Summary
- Causal Factor Summary
- Eligibility Element Comments
- Eligibility Element Overview Trend
- Expedited Details for Management Staff
- Currency Details for Management Staff
- Payment Error Case List
- Customer Service Feedback
- Claims Timeliness
- Food Stamp Quality Control Positives
- Food Stamp Quality Control Negatives
Further training on Program Improvement Plans and development will begin shortly. The training is for administrative staff including County Managers and Family Support Division Eligibility Specialist Supervisors.
Central Office Analysis
Effective April 1, 2010, Quality Control staff began doing in depth error tracking analysis. QC will be working closely with IM Field Operations and county staff to identify areas of concern and preparation of PIPs. The Food Stamp Program and Policy Unit and Quality Control Unit continue to work together to identify statewide trends and address possible solutions.
NECESSARY ACTION:
- Review this memorandum with appropriate staff.
JM/SB