Insights on Subsidized Child Care Programs in North Carolina

2017 Social Services Institute Spotlight on Subsidized Child Care Assistance

Welcome The objective of today s meeting is to discuss policy changes to the Subsidized Child Care Assistance (SCCA) Program to align with the Child Care Development Block Grant (CCDBG) Act of 2014 and the implementation of North Carolina Families Accessing Services through Technology (NC FAST)

Topics of Discussion Introduction Role of DCDEE Child Development Block Fund (CCDF) NC FAST Policies

Subsidized Child Care Assistance (SCCA) Program Division of Child Development and Early Education, Subsidy Services Section

Child Care Development Fund Block Grant of 2014 The Child Care and Development Block Grant (CCDBG), also called the Child Care and Development Fund, is the primary source of United States federal funding for child care subsidies for low-income families and funds to improve child care quality.

SCCA aligns with CCDF Family Friendly Policies Meeting the Needs of Certain Populations; Priority for Low-Income Populations Parental Choice of Providers Eligibility Period / Redetermination

NC FAST North Carolina Families Accessing Services through Technology (NC FAST) is a program designed to improve the way the NC Department of Health and Human Services and county departments of social services do business. Group Case Activation March 2017 June 2017 Pilot Counties Group A Counties Group B Counties Group C Counties Group D Counties July 2017 August 2017 November 2017

Subsidized Child Care Assistance (SCCA) Program The following policies have been implemented to align with provisions in the Child Care Development Fund Act of 2014 and to align with the implementation of NC FAST.

Policy Update 12 Month Eligibility/Continued Eligibility Once a child is determined eligible, the child must receive 12 months of continued eligibility unless a change occurs that impacts eligibility. Income during the 12 month eligibility period shall only be compared to 85% of State Median Income (SMI). (initial) Income must be re-evaluated at redetermination. If the income still exceeds 133% or 200% of the FPL and is at or below 85% of the SMI, the recipient shall receive a Graduated Phase Out of 90 calendar days. (redetermination) Admin Letter 08-16 Child Care Rule 10.1007

Policy Update Timeline for completing redeterminations o Policy requires redetermination not be initiated any earlier than forty-five (45) calendar days prior to the expiration of the recipient s certification period. Recipients will receive written notification of the expiration of their certification period. o This written notification will also include a request that the recipient complete and sign a new application in order to complete eligibility redetermination. o Written notifications will be mailed to the most recently reported home address. Admin Letter #10-16

Policy Update Annual Redetermination of Eligibility Complete the redetermination process by mail or phone upon request. Application must be postmarked no later than the last day of the eligibility period. Verifications needed to redetermine eligibility must be provided within 30 calendar days of the date of the signature on the redetermination application. Admin Letter #05-16

Policy Update Gainful Employment Definition Policy states that Local Purchasing Agencies (LPA) no longer have the option to define gainful employment. Gainful Employment is defined as making at least minimum wage and would also apply to employment outside of Self-Employment. Self/Gainful Employment Newly self-employed individuals receive 12 months to allow time to establish gainful employment. Admin Letters #01-16 and #02-17

Policy Update Graduated Phase Out The Graduated Phase Out of Eligibility was created for families that are over State Eligibility income criteria but at or below 85% of State Median Income (SMI). This applies when a family's gross countable monthly income exceeds Federal Poverty Levels (FPL) of: 133% for school age children 200% for preschool age children (0-5) and children with special needs Admin Letter #05-16

Policy Update 90 Day Transition Policy requires 90 days of continued child care assistance for the following instances when the parent is currently receiving child care assistance. Seeking employment following a job loss Transitions between training or education activities Job search following the 20 month post-secondary education time limit Medical/Maternity Leave Interruption in work for a seasonal worker between regular work seasons Student break or holiday for a parent participating in training or education Any other interruption in work, training, or education hours that does not exceed 90 days. Admin Letter #04-16, 05-16 *** REVISED LETTER**** 04-17

Policy Update Payment Suspension If the recipient chooses not to utilize child care assistance during a 90 day transition period, payment shall be placed in a suspended status. Temporary Break includes: Employment Education Skills Training Admin Letter #05-17

Policy Update Parental Fees Recipients will be responsible for paying parental fees of any amount that are assessed by the child care worker. NC FAST will automatically calculate the parental fee and assess the fee amount. NOTE: Previous policy stated $5.00 or less would not be assessed. Assessing Parental Fees There is one (1) parental fee for families receiving subsidized child care assistance, regardless of the number of children in care and regardless of the hours of care needed. In cases wherein the parental fee exceeds the cost of care, services cannot be authorized. Admin Letter #09-16

Policy Update Not Assessing Parental Fees Policy requires parental fees to be waived when the following apply: Child care services are provided in conjunction with a child protective services plan to enable the child to remain in his/her own home; Services are needed to support child welfare services as described in Chapter 5: Establishing Need and a Plan of Care; Children who are receiving foster care services and need child care services. The foster children must be in the custody of the county department of social services and Residing in a licensed foster care home, or placed with an adult other than their parents. Admin Letters #05-15 and 09-16

Policy Update Parental Fee s w/ Graduated Phase Out At the time of graduated phase out, parental fees will increase to reflect the family s new reported income. Admin Letter #03-17

Policy Update Parental Fee Adjustment Policy requires the recalculation of parental fees for any increase or decrease in countable monthly income. NOTE: Previous policy stated it was a $100.00 limit Increase in parental fee will begin the first of the month following a 10 workday notice period after the change is reported. Decrease in parental fee will begin in the month that the change is reported. Parental fee start date Policy requires parental fees for new applicants to be effective on the first day the child attends care. Admin Letter #02-16

Policy Update Reduction in parental fee Policy allows the decreased parental fee to be effective the first day of the current month only. Collection of unpaid parental fees Policy limits collection of past due parental fees to one (1) month prior to the provider s request for termination of services. Rounding the Daily Parental Fee Daily parental fees must be rounded to the nearest cent. Note: This is done automatically through NC FAST Admin Letter #06-15

Policy Update Blended Rate Payment rates for some preschoolers and school age children are changed to a blended rate. The blended rate is 83% of the provider s full-time approved subsidy rate. The 83% rate takes into account care provided for fifteen (15) school holidays, ten (10) teacher work days, and fifteen (15) emergency closure days For children who need full time summer care, a wraparound plan during the school year, and care during school closure days, a blended rate of 83% of the full time provider s approved subsidy rate for the specific age group will be paid for the entire year. Admin Letter #04-16

Policy Update Blended Rate Children who qualify for a Blended Rate Child attends the provider year-round Child attends the provider for either Before, After, or Before and After School care during the school year Child attends the provider on school closure days (Inclement Weather days, Teacher Workdays, or Holidays) Child attends full-time during Summer/Track-out Admin Letter #04-16

Policy Update Blended Rate Providers who qualify to care for children who are eligible for a Blended Rate Provides care during at least one of the following school closure days: Inclement Weather days, Teacher Workdays, or Holidays Provides full-time care during the Summer/Track-out Provides the appropriate services For pre-school age children: provides 3 Yr. Old, 4 Yr. Old, or 5 Yr. Old services For school age children: provides Before, After, or Before and After School services Admin Letter #04-16

Policy Update Parental Fee w/ Blended Rate When a provider is paid based on a blended rate, the parental fee will be 75%. The parental fee will apply to the entire eligibility period. Future Functionality: Parent fee with Blended Rate will be 83% of the full-time co-payment which is consistent with legislation. Admin Letter #09-16

Policy Update Department of Defense (DoD) DoD-certified child care facilities shall file with the Department a notice of intent to operate a child care facility in a form determined by the DoD The Department shall then issue a NC child care license to the DoD- certified child care facility. Out of State Providers Providers may request contracting as an Out of State Provider. Out of State Providers will be paid at the 1 star market rate or private paying rate whichever is lowest. DoD-Session Law 2014-214 section 12B.9(a) OSP- Admin Letter #07-16

Policy Update Changing Providers Policy states that LPAs can no longer limit the number of times a parent/responsible adult can change providers. Admin Letter #02-16

Policy Update Alternate Providers When the primary child care provider is not able to provide care for less than 30 calendar days, the recipient can choose to have care provided by an alternate provider. Admin Letter #02-17

Policy Update Use of Application All applications for child care services will be processed through NC FAST. Policy does require the last page of the application in NC FAST to be printed and signed. The DCDEE 0456 Application for Child Care Services will only be used in two circumstances. Recipient mails a printed DCDEE 0456. When child care is needed for a child in foster care. Admin Letter #02-17

Policy Update One Application for more than one case A recipient can submit one application for all children in the household. Admin Letter #02-17

Policy Update Application and Vouchers for CPS Will be signed by the parent. Admin Letter #02-17

Policy Update Assets Declaration CCDF Act of 2014 requires families declaring assets in excess of $1 Mil. are ineligible for Subsidized Child Care Assistance. Admin Letter #08-15

Policy Update Certification Period End Date Policy requires the certification period to end on the last day of the month of the certification period. Admin Letter #08-15

Policy Update Parental Choice Signature The recipient s signature on the voucher is needed to confirm the parental choice of a selected child care arrangement and to indicate that the recipient agrees to pay the provider if or when services are received after becoming ineligible for child care assistance. Admin Letter #01-17

Policy Update Foster Care Policy requires children in foster care to be the case head in their own case. Foster Parent Anyone other than that child s parent(s) or legal custodian(s) who is providing full time care for a child who is in the custody of a North Carolina County Department of Social Services. Admin Letter #03-16 Admin Letter #05-16

Policy Update Post-Secondary Education Policy provides twenty (20) months of subsidized child care assistance for post-secondary education or skills training with no extension through the end of the semester. Admin Letter #02-16

Policy Update Coding Foster Care Cases with Education as the Need Policy states that when a foster parent s only need for care is post-secondary education, this need must be coded to Developmental Needs. This has to be coded to developmental needs and tracked manually because of the way NC FAST functions currently. DCDL #07 -16

Policy Update Homelessness Families who reside in temporary living arrangements will be asked the type of temporary living arrangement and if this living arrangement is due to economic hardship. New policy requires all DSS/LPA s to prioritize families experiencing homelessness and to add prioritization of this population to their local policies. Include families experiencing homelessness when using the 4% Set aside. Admin Letter #08-17

Policy Update Tracking of Federal Land Trust Families may now be referred by the Eastern Band of Cherokee Indians for subsidized child care assistance to support Child Protective Services (CPS), Child Welfare Services (CWS) and Foster Care. Admin Letter #08-15

Policy Update Citizenship Requirements In order to met citizenship requirements the Child must be a U.S. Citizen or the child must be a legal U.S. Non Citizen. New policy states that we do not take into account the citizenship of the parent. Admin Letter #05-17

Policy Update Non-Parent Relative Caretakers Policy states nonparent relative and the caretaker s spouse are removed from the income unit. The income unit will be the child(ren) only. The nonparent relative caretaker will remain the case head. Admin Letter #04-15

Policy Update Conducting Periodic Reviews Periodic reviews are NO LONGER allowed. Admin Letter #04-15

Policy Update 10 Day Notice of Termination Policy will allow a ten (10) work day notice when three situations occur. This is a change in policy bc previously these 3 scenarios used to receive a 5 work day notice. The parent provides written or verbal notification that the service is no longer needed or wanted; The child moves out of the country; or The child had been admitted to an institution and is no longer able to use service, or immediate termination. Admin Letter #05-16

Policy Update Waiting List and Surveys Requires the Local Purchasing Agency (LPA) to be responsible for managing and prioritizing waiting list information within NC FAST while NC FAST is responsible for maintaining waiting list information including Waiting List Surveys. Functionality is not currently available in NC FAST; planning that this functionality will be available in the spring. Admin Letter #10-16

Policy Update Work First Transition Whenever a recipient has exhausted their 60-month maximum for Work First services, the recipient will receive a 90-day transition, if recipient does not have a need for care. If there is a need for care, recipient will continue to the end of the certification period. Admin Letter #02-17

Policy Update Reducing Services Policy states that lack of funding is not a reason to terminate services. Admin Letter #02-17

Policy Update Reporting Changes Change of address and telephone number. Change in members of the household. Child receiving child care services moves out of the home. Increase or decrease in income from job, child support, or other sources. Loss of current employment. Change in the number of hours child care is needed. Household assets or resources exceed $1 million dollars. Admin Letter #08-16

Policy Update Provider Participation Requirements New policy requires all providers who wish to participate in the Subsidized Child Care Assistance (SCCA) Program to use the NC FAST Provider Portal to enroll in the Subsidized Child Care Assistance Program. Providers will need to log in and complete initial NC FAST Provider Portal enrollment prior to receiving any payment. Admin. Letter #10-16

Policy Update Provider Participation Requirements Accept or reject children into their care. Vouchers will no longer be on paper, but will be sent electronically via the NC FAST Provider Portal for providers to accept or reject. Providers will also sign these vouchers electronically using an e-signature. Record and submit attendance rosters. Review and sign the Annual Provider Agreement. Update private paying rates for services. Admin. Letter #10-16

Policy Update Vouchers in NC Fast Provider Portal Vouchers are completed by the child care worker or the LPA, the parent, and the provider as follows: The child care worker will enter all information into NC FAST. The provider will be able to view vouchers in the NC FAST Provider Portal. Initially, the voucher will be listed as pending parent signature. After the parent signs the voucher, it will be pending provider signature. Admin. Letter #01-16

Policy Update Provider Rate Change A provider can only receive an increase in their subsidy payment rate once a year unless the increase in rates is the result of a provider receiving a higher star rated license or new market rates are established. Admin. Letter #05-16