1.2 CCDF Policy Decision Authority

The Lead Agency has broad authority to administer (i.e., establish rules) and operate (i.e., implement activities) the CCDF program through other governmental, non-governmental, or public or private local agencies as long as the Lead Agency retains overall responsibility for the administration of the program. Administrative and implementation responsibilities undertaken by agencies other than the Lead Agency must be governed by written agreements that specify the mutual roles and responsibilities of the Lead Agency and other agencies in meeting the program requirements. 1.2.1 Entity establishing CCDF program rules Which of the following CCDF program rules and policies are administered (i.e., set or established) at the State or Territory level or local level? Identify whether CCDF program rules and policies are established by the State or Territory (even if operated locally) or whether the CCDF policies or rules are established by local entities, such as counties or workforce boards. Check one of the following: a. [ ] All program rules and policies are set or established by the State or Territory. (If checked, skip to question 1.2.2.) b. [x] Some or all program rules and policies are set or established by local entities or agencies. If checked, indicate which entities establish the following policies. Check all that apply: i. Eligibility rules and policies (e.g., income limits) are set by the: [x] State or Territory. [x] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: ii. Sliding-fee scale is set by the: [x] State or Territory. [ ] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: iii. Payment rates and payment policies are set by the: [x] State or Territory. [x] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: iv. Licensing standards and processes are set by the: [x] State or Territory. [ ] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: v. Standards and monitoring processes for license-exempt providers are set by the: [x] State or Territory. [x] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: vi. Quality improvement activities, including QIS, are set by the: [x] State or Territory. [x] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: vii. Other. List and describe any other program rules and policies that are set at a level other than the State or Territory level: 1.2.2 Entities implementing CCDF services The Lead Agency has broad authority to operate (i.e., implement activities) through other agencies, as long as it retains overall responsibility for CCDF. Complete the table below to identify which entity(ies) implements or performs CCDF services. Check the box(es) to indicate which entity(ies) implement or perform CCDF services. CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who conducts eligibility determinations? [ ] [x] [x] [ ] [ ] Describe: CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who assists parents in locating child care (consumer education)? [x] [x] [x] [x] [ ] Describe: Who issues payments? [ ] [ ] [x] [ ] [ ] Describe: Who monitors licensed providers? [x] [ ] [ ] [ ] [ ] Describe: Who monitors license-exempt providers? [x] [ ] [ ] [ ] [ ] Describe: CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who operates the quality improvement activities? [x] [ ] [x] [ ] [x] Describe: CDEC has contracts with 35 local ECCs (Councils) representing all 64 Colorado counties that implement quality improvement services such as coaching, professional development , technical assistance, and purchasing assistance for educational materials. Activities are outlined within formal agreements that each have a stated scope of work. A memorandu m of understandin g is executed with each child care program receiving supports and CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other services, which outlines how funding supports may be used and requirements to increase and/or maintain quality levels as measured through the Colorado Shines QIS. A monitoring plan is established and data is collected and reviewed to understand statewide investment in and impact of the QIS activities. Councils also have responsibiliti es to engage community members to understand how to support the early childhood needs within their communities, CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other which include supporting the early childhood workforce, family education, engagement and support, child health and wellbeing, access and affordability; many Councils sub- contract with institutes of higher education and other non-profit partners. Child care resource and referral agencies support all 64 counties within 16 catchment areas. A statewide call center provides enhanced referral support services for families seeking child CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other care options. All child care resource and referral agencies, except the statewide call center, are embedded within Councils. 1.2.3 Information systems availability For any activities performed by agencies other than the Lead Agency as reported above in 1.2.1 and 1.2.2, identify the processes the Lead Agency uses to oversee and monitor CCDF administration and implementation activities to retain overall responsibility for the CCDF program. Check and describe how the Lead Agency includes in its written agreements the required elements. Note: The contents of the written agreement may vary based on the role the agency is asked to assume or type of project but must include, at a minimum, the elements below. a. Tasks to be performed. [x] Yes. If yes, describe: In cases where other entities undertake implementation responsibilities, formal written agreements are developed that include a statement of work that outlines specific, measurable tasks in detail. Examples of these written agreements include the annual contracts CDEC executes with Early Childhood Councils (ECCs). The contracts include requirements and provisions. CDEC conducts monthly check-ins with Early Childhood Councils that include monitoring to the Scope of Work items. Additionally, a quarterly report is required within their contract. This information is collected and reviewed by Quality Coordinators located within CDEC. CDEC additionally requires an annual report of performance. Finally, every three years, as required by statue, CDEC compiles a triennial report of performance and impact by each ECC. These reports are made available on the Colorado Department of Early Childhood website. CDEC also enters into annual performance contracts with Counties in the form of a Memorandum of Understanding (MOU). The MOU includes requirements and provisions that address each party’s duties and responsibilities to work in a collaborative manner to administer, financially support, and implement the Child Care Assistance Program using fair and objective criteria. Tasks include but are not limited to performance contract requirements and required duties of the County and CDEC. In addition, CDEC reviews and approves county requests for TANF Quality Transfers to CCCAP for quality child care activities. The request form includes how the county intends to use the funds as well as allowable activities. It also outlines the counties’ duties to report funds transferred quarterly. [ ] No. If no, describe: b. Schedule for completing tasks. [x] Yes. If yes, describe: Formal written agreements include a schedule for completing tasks. The Memorandum of Understanding (MOU) includes the tasks and expectations required for Counties and CDEC to administer the Program, including assurances for Counties to meet timely processing and accuracy requirements as outlined in 8 CCR 1403-1 in order to meet Colorado Child Care Assistance Program (CCCAP) performance measures. MOUs are effective for three years and are reaffirmed annually through an amendment signed by both parties. [ ] No. If no, describe: c. Budget which itemizes categorical expenditures in accordance with CCDF requirements. [x] Yes. If yes, describe: Formal written agreements include detailed budgets that itemize categorial expenditures in accordance with CCDF requirements. A budget accompanies the SOW and is specific to the tasks that need to be performed. Budget categories are aligned to the expenditures needed to complete requirements. [ ] No. If no, describe: d. Indicators or measures to assess performance of those agencies. [x] Yes. If yes, describe: CDEC maintains responsibility for core monitoring of subrecipients as outlined in CDEC Subrecipient Monitoring Procedures to include monitoring subrecipients’ activity, ensuring subrecipients meet the audit requirements, and ensuring fidelity in the administration of CCDF services. Core activities include but are not limited to performing applicable risk assessments, monitoring plans, subrecipient monitoring, and ensuring compliance with program requirements. Program requirements may include but are not limited to: an assessment of the documentation provided by the subrecipient, data maintained by the subrecipient, information obtained through observations, or formal monitoring plans to determine the subrecipient’s level of compliance with federal and CDEC expectations. In addition, the MOU defines how CDEC and Counties work together in partnership to jointly achieve CCCAP performance outcome measures related to timeliness and accuracy. [ ] No. If no, describe: e. In addition to the written agreements identified above, describe any other monitoring and auditing processes used to oversee CCDF administration. CDEC implements additional methods of monitoring of the Colorado Child Care Assistance Project (CCCAP), or implementation of child care subsidies, based on assessed risk, specific subrecipient attributes, and program resources. This monitoring includes but is not limited to checks and balances, risk-based reports, county monitoring visits, audit reviews, prior approval for high-risk activities, technical assistance and training, and collaboration with other county and state agencies. CDEC also utilizes three different levels of county monitoring reviews to include monthly, random case file reviews at the county level to ensure CCCAP eligibility determinations and subsidy payments are accurate based on CCCAP regulations and policies, CDEC monthly reviews of client case files to ensure accuracy and alignment with CCCAP regulations, and supervisory reviews of eligibility determinations and compliance with CCCAP regulations, child care authorizations, provider payments, and parent fees as part of county monitoring reviews. The findings of each county review are summarized for each County, and areas of concern and findings are clearly documented and followed up on by CCCAP staff to ensure the case under review is corrected and to prevent future errors. All of the reviews are conducted utilizing standardized definitions, review elements, review processes, and review tools to ensure consistency in reviews and accurately reflect errors and trends. The results from these reviews are compiled by the CCCAP staff and are used to monitor county performance, identify error trends and opportunities for improvement, and develop strategies to rectify or prevent ongoing violations. 1.2.4 Certification of shareable information systems. Does the Lead Agency certify that to the extent practicable and appropriate, any code or software for child care information systems or information technology for which a Lead Agency or other agency expends CCDF funds to develop is made available to other public agencies? This includes public agencies in other States for their use in administering child care or related programs. [x] Yes. [ ] No. If no, describe: 1.2.5 Confidential and personally identifiable information Certification of policies to protect confidential and personally identifiable information Does the Lead Agency certify that it has policies in place related to the use and disclosure of confidential and personally identifiable information about children and families receiving CCDF assistance and child care providers receiving CCDF funds? [x] Yes. [ ] No. If no, describe: