Policy & Practice | Fall 2026

attendance, provider management, and payments as isolated activities, the system aligns them within a single operational framework. This integra tion creates built-in controls: Enrollment –> Authorization –> Attendance –> Payment Because these steps are intercon nected in a single system and visible to the appropriate participants, inconsis tencies become easier to identify and resolve before funds are disbursed. The result is a stronger foundation for program integrity, achieved without placing additional burdens on families or providers. 3. Validation Should Happen Throughout the Process, Not Just at the End Traditional program integrity approaches often rely heavily on ret rospective reviews. An issue occurs, a payment is made, and the agency dis covers the problem only later—often through an audit or investigation. A systems-based approach shifts valida tion earlier, catching inconsistencies before improper payments are made. One of the strongest examples discussed during the webinar was the use of multiple validation points throughout the subsidy life cycle. Within ECARES, providers must be properly licensed or authorized before enrollments can be generated. Attendance records are connected to approved authorizations and schedules. Payment information can be reconciled directly by providers. Families maintain visibility into their subsidy arrangements and can dispute payments if they believe something is incorrect. These stages act as check points, creating multiple opportunities to spot inconsistencies or inaccuracies and address them upstream. While no single control eliminates risk, multiple checkpoints working together create a stronger overall integrity framework. This layered approach reflects a broader insight that applies across human services programs: effective oversight is rarely the result of one large safeguard. It is often the outcome of many smaller safeguards working together.

fragmented processes, manual work arounds, inconsistent documentation, and outdated technology rather than deliberate deception. This distinction is crucial, as the solution changes depending on the cause. If an agency assumes every error is fraud, it will naturally invest in detection and investigation. But if many errors originate from opera tional complexity, then reducing complexity—through automation, integrated workflows, and clearer business processes—becomes one of the most effective integrity strategies available. This was a recurring theme at both APHSA events. Participants empha sized that program integrity improves when agencies examine the root causes of errors rather than focusing exclusively on identifying them after the fact. In Wyoming, modernization efforts began with a close examination of how families, providers, and agency staff interacted with the child care subsidy system. Rather than starting with technology, the state first reexamined its policies, business processes, and operational workflows. Business needs drove the technology—not the other way around. The result was more than a new technology platform; it was a redesigned way of delivering services, with workflows intentionally built to prevent errors at the source rather than detect them later. 2. Integrated Systems Create Natural Integrity Controls One of the most significant fraud risks in any program emerges when critical information is spread across disconnected systems. Eligibility determination may exist in one system, provider information in another, and attendance records and payment processing in still others. Every handoff introduces opportuni ties for error. Wyoming’s ECARES platform, powered by Vimo’s Child Care Exchange (CCX) solution, connects these traditionally separate functions within a unified ecosystem. Rather than treating eligibility, enrollment,

This approach was the central theme of two recent events hosted by the American Public Human Services Association (APHSA), Vimo, and the Wyoming Department of Family Services (DFS). In June, APHSA and Vimo presented the webinar, “Strengthening Integrity in Child Care Subsidy Programs: Addressing Fraud Risk Through Design, Not Disruption,” 2 featuring Carrie Gray, Senior Consultant in Child Care at Vimo, and Roxanne O’Connor, Senior Administrator for Wyoming DFS. Later, at APHSA’s National Human Services Summit, Vimo Vice President and Senior Director for Human Services Products and Innovation Raymond Han served as moderator for a panel dis cussion with Gray and Wyoming DFS Senior Administrator Kristie Gordy on “From Detecting Fraud to Preventing Error: A New Lens on Program Integrity in Human Services.” Together, these events explored a simple but powerful idea: program integrity is not just an enforcement issue—it is also a system design challenge. Using Wyoming’s Early Childhood Access Resources and Eligibility System (ECARES) as a case study, participants examined how thoughtful system design can reduce the risk of fraud and abuse while improving the overall experience for families, pro viders, and agency staff. Several key lessons emerged. 1. Most Improper Payments Begin with Process Gaps, Not Criminal Intent Public discussions about fraud often focus on bad actors. In many cases, however, payment errors stem from

Carrie Gray is a Change Agent within Vimo’s Child Care Practice.

Policy & Practice Fall 2026 30