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At the outset it should be recognized that virtually all of the
Furthermore, I was extremely encouraged to note that the "theme" of the report both recognizes and reinforces the basic fact that effectiveness of the AFDC program is a joint responsibility of both state and federal governments. To operate in other than a climate of cooperation simply further breeches a state-federal partnership and detracts from our commitment to meet the needs of dependent children.
With respects to the specific contents of the report, there are several points which requires correction and others which merit consideration. On page four (4), top paragraph, the word "often" is inappropriate. Reviewers not only verify eligibility factors with the recipient but they always verify them with collateral sources. In chapter 2 (see page 8, paragraph 3, point 2), the reader may well misinterpret the statement that quality control systems "...do not allow for program and practice difference among states." It should be made clear that while the system does acknowledge permissible state practice, federal error rate calculation process (i.e., regression analysis formula) does not.
KALMAN R. HETTLEMAN
The page references in this appendix may not correspond to the page numbers in the final report.
On the matter of social security numbers (SSN) (see pages 26-27),
Two other technical points are (1) the absence of Maryland's data in the table on page 41 and (2) the meaning of the sentence ("Finding and reporting unrelated secondary errors...") on page 45.
Turning to more substantive issues, there are several points which
Subjects that were not addressed in the report are elaborated as
First, it should be recognized, and stated, that the current quality control system more adequately serves the management needs of the federal government than it does state governments. Specifically,
(1) statistically valid statewide samples cannot
(2) requirements for semi-annual reviews effectively
(3) state calculated error rates, and reviews, are
In light of these circumstances, I would suggest that the recommendations in Chapter 5 of the report be re-stated in a manner that encourages and supports greater flexibility on the part of the federal and state agencies in the area of statistical sampling design and methodology.
Second, little acknowledgement is given to the fact that the support
Finally, the report, but briefly, mentions the requirement for
Without summarizing the foregoing, I would also like to reinforce
If you wish further information or clarification on the points I have raised, please do not hesitate to contact me.
Richard G. Lacombe, Director
Kalman R. Hettleman, Secretary
I am responding to your request for comments on the draft report entitled "Opportunities for Getting Better Management Information from Quality Control.'
The report accurately expresses the sentiments of the New York State Department of Social Services and hopefully it will provide some impetus returning the Quality Control program to the status of an effective management tool rather than the guideline for fiscal sanctions.
Our only negative comment involves the suggestion to eliminate the administrative period and require the reporting of errors under five dollars. process of reporting misspent funds, the administrative period is one of the few rational principles in the program. The requirement to report and record changes in circumstance takes time over and above the necessity to provide a ten day notice in the event of a closing or reduction in 'grant. Thirty days does not seem to be an inordinate amount of time when you consider that it takes six months to release an audit report.
Secondly, errors under five dollars produce inconsequential results but impact the case error rate disproportionately. We realize that the payment error rate is the prime measure of efficiency. However, case error rates are public information and when these are taken out of context, they only tend to produce bad publicity.
Thank you for the opportunity to review and comment on this report and we hope your recommendations receive proper consideration by Congress and consequently, the Department of Health, Education and Welfare.
James A. Durkin, Director