An improper payment is any payment EEC made to you that was incorrect or not authorized under applicable law, regulations, policies, or contract terms. EEC can identify, investigate, and recoup these payments — sometimes long after they were made.

What Counts as an Improper Payment

Improper payments are not always intentional. Common examples include:

• Billing for days when a child did not attend (without proper enrolled-but-not-attending conditions being met)
• Billing for children who are no longer in your program ("ghost enrollment")
• Billing full-time rates when a child was only authorized for part-time care
• Double billing (billing both as primary and substitute for overlapping periods)
• Billing for children whose financial assistance was terminated
• Administrative errors in your billing submissions
• Miscalculation of parent fees that results in overbilling to EEC

Even an honest mistake qualifies as an improper payment if EEC paid you more than you were entitled to.

What Counts as a PIPV

A Provider Intentional Program Violation (PIPV) is a step beyond an improper payment — it involves knowing and deliberate efforts to violate policy. Examples:

• Intentionally falsifying attendance or billing records
• Intentionally enrolling or billing for families you knew were ineligible
• Intentionally manipulating client documents

PIPVs can result in program termination, referral to the Attorney General's Office, and are treated separately from ordinary billing errors.

If You Discover a PIPV or Fraud

If you, as a contracted provider or CCR&R, discover evidence of PIPV or fraud in your own program or by a staff member, you must report it to EEC's Audit Compliance and Resolution Unit. EEC will conduct a full review to determine the extent of non-compliance and potential recoupment.

The Recoupment Process

What EEC determines: For contracted providers, EEC's Audit Compliance and Resolution Unit determines the recoupment period. For voucher providers, the CCR&R determines it (often following a review triggered by a complaint, audit, or billing anomaly).

Recoupment period: The period of time during which overbilling occurred. EEC calculates what it should have paid versus what it did pay and seeks to recover the difference.

Your obligation: Once EEC notifies you of a recoupment finding, you must respond. EEC will pursue collection through Commonwealth financial systems if you do not.

Common Triggers That Lead to Investigations

• A child stops attending and you continue billing (ghost enrollment)
• A parent files a complaint about their child's placement
• Routine EEC fiscal monitoring of contracted programs
• Inconsistencies in attendance records versus billing records
• Accepting children before their authorization is confirmed in CCFA

Protecting Yourself

The best protection against improper payments is accurate, timely record-keeping:

• Track attendance carefully in CCFA (see Attendance Tracking (2.7))
• Verify active authorization before accepting any subsidized child (see Voucher Verification (2.8))
• Contact your CCR&R immediately when a child stops attending
• Don't bill for care you didn't provide

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Next Steps

• Attendance tracking to avoid billing errors: See Attendance Tracking (2.7)
• Voucher verification before care starts: See Voucher Verification (2.8)
• Billing questions: Contact your CCR&R's CCFA Administrator
• To report suspected fraud: Contact EEC's Audit Compliance and Resolution Unit at eecsubsidymanagement@mass.gov
• If facing fraud allegations: Consult a lawyer before responding