HomeMy WebLinkAbout20032955.tiff STATE OF COLORADO
CCI� i f :
rt _ a
Colorado Department of Human Services
people who help people uw`
Office of the Executive Director
1575 Sherman Street•Denver,Colorado 80203 Bill Owens
303.866.5096•Fax 303.866.5010 Governor
‘N.\N. cdhs.statcco.us.marva.hammonsi(estate.co.us Marva Livingston Hammons
Executive Director
September 17, 2003
David E. Long, Chair
Weld County Board of County Commissioners
9015 10th Street
P.O. Box 758
Greeley, CO 80632
Dear County Commissioners:
Your written response to my offer of input from your county regarding the Go/No-Go decision on CBMS
is appreciated. Although my specific request was that I be provided the detailed analysis of how each
county determined the county cost of conversion leading to the estimate of$28 million, I welcomed the
additional information on issues or concerns about the project. This follow-up letter to you summarizes
where we are to date in our consideration of the issues or concerns you raised. We will also be sending a
generic communication to interested persons- including legislators, commissioners, county directors- that
contains similar information.
Cost to Counties for Conversion
The latest estimate from the counties revised the $28 million estimate downward by 40% to $17.1 million.
Even so, the range of variance among the counties for cost per case to convert and cost per hour was
extreme. I have routed to Marie Peer, County Director of Moffat County, and president of CSSDA, a
copy of the spreadsheet and asked for additional input in order to understand better the information
provided to me by the counties. You may also be aware that HCP&F is working with us and the JBC to
determine if PRWORA funds can be made available to offset reasonable costs. Final decisions on that
option have not yet been made.
Data Conversion Extension
Additional time is being built-in to the process for conversion activities by the counties.
Data Element/Data Entry:
CBMS is designed to require only those data elements that are necessary for correctly determining
eligibility, interfacing with payment systems, and meeting mandatory requirements. In CBMS, the
amount of required data will vary depending upon the complexity of the case, the number of individuals
associated with the case (household members), and the number of programs for which the client is
applying. The county representatives have accurately represented that there are approximately 2,550 data
Our Mission Is To Design And Deliver Quality Human Services That Improve The Safety And Independence Of The Peog 2003-2955
Letter to Commissioners/Director
9-18-03
Page 2
elements, 1,078 Reference Tables, 170 data sheets, and 405 required fields. However, there is no single
individual, case, or household that will have this much information that needs to be manually captured for
entry into CBMS. In addition, the following actions have been taken to facilitate the conversion process:
1. Over 2,014 fields of data that are currently captured in the Legacy systems CBMS is replacing will
be automatically uploaded. As discrepancies are identified, the project team is correcting as many
errors as possible to reduce the cleanup effort of the counties.
2. A prioritization scheme has been developed, with input from the counties, to help the counties'
optimize their data collection efforts.
3. For the data elements that have to be manually entered, templates have been developed for staff to
use which speed the process and can help with accuracy.
Auto Authorize Batch EDBC
Another concern of the county representatives is the nightly EDBC batch run. Specific concerns they
have identified include:
"Incorrect benefit issuance."
W "The primary worker hasn't authorized the case."
qb "Changes in the allotment without alerts to workers or to supervisors."
14:> "Erases some alerts sent to workers or supervisors upon completion of EDBC run."
tk> "High risk of internal fraud."
EDBC, on its own, will not cause any benefits to be incorrect. Changes in allotments do not occur
without alerts to workers or to supervisors. Should a change in a case occur from another authorized
worker, all primary caseworkers would be sent an alert informing them that changes had been made to the
case. Alerts are not erased from the system.
CBMS should not increase the risk of internal fraud over the risks that are currently present. In fact,
because of the integration of several legacy systems into one, better documentation, and enhanced
reporting, the risk of fraud is reduced. Security within CBMS is associated with each individual worker's
user ID (not terminal ID). Thus, the system tracks every individual who inputs into the system. The only
way internal fraud can occur is between workers who give their security information for accessing the
system to one another or if the worker does not sign-off or lock the screen when away from the personal
computer. If internal fraud is committed, the audit trail within CBMS will allow for identification of the
worker who committed fraud and provide evidence to assist in any prosecution.
Interruption of Benefits
In response to the concern that the conversion to CBMS must not result in unintended interruption of
benefits, a "Benefits Freeze Flag" has been designed and will be placed on each converted household.
The purpose of this flag is to allow benefits to continue, unaltered, until a worker updates information on
Letter to Commissioners/Director
9-18-03
Page 3
a case and an authorized worker authorizes the issuance of the modified benefits. Counties have
requested that the "Benefits Freeze Flag" remain on the converted cases for up to twelve months. The
flag is already planned to be in place for at least three months. The exact length of time the "Benefits
Freeze Flag" will remain on the case is under consideration for extension beyond the planned three
months.
Live Pilot vs. Non-Production Pilot
The objective of the CBMS Pilot is to ensure that all processes associated with CBMS are verified. Data
from the Legacy systems will be converted into the CBMS database for all Pilot participants. The key
differences between the CBMS Pilot (which will be a Non-Production Pilot) and a "Production" Pilot are
the methods by which payments and interfaces will be verified. The Pilot for CBMS will still verify
critical interfaces to and from third parties. Benefit payment amounts will also be verified in the Colorado
Financial Management System (CFMS), but will not be sent to the client's bank. This key difference
means that all steps short of an actual benefits payment will be completed. Thus, benefits will not be paid
based on data in CBMS during the Pilot, actual benefits will continue to be paid via the Legacy systems.
This will minimize the risk of jeopardizing clients' current benefits in the Legacy systems. A"Production
Pilot" would result in a phased implementation, even if the only two phases were Pilot and
implementation of all the other counties. A phased approach would have required some third party
interfaces partners to accept (or send) two differently formatted files for the same interface. The risk of
error in processing multiple interfaces would be greatly increased.
Maintain Legacy Systems for 1 year
The current plan is to maintain the Legacy systems for at least three months. It is possible to maintain
them for at least a year and that option is under serious consideration.
Client Correspondence
The State concurs with this concern and is currently working on a resolution.
Mitigation Plan/Contingency Plan to Pay Clients if CBMS Does Not Work
The CBMS Project Team delivered a draft of the CBMS Contingency Plan in June 2003, with the final
version due in September 2003. If nothing else, keeping the Legacy systems available would allow us to
cut a benefits check in the same amount as when the Legacy systems were frozen.
Hold Counties Harmless for Rules Engines Errors
Errors caused solely by the rules engines will not be charged to counties.
I understand your concerns about risk to clients and risk to the counties. I hope that this information and
our commitment to ongoing updates to you are helpful.
Sincerely,
s on
Executiv Direc or
Hello