4.4 Payment Practices to Providers

Lead Agencies must use subsidy payment practices that reflect practices that are generally accepted in the private pay child care market. The Lead Agency must ensure timeliness of payment to child care providers by paying in advance or at the beginning of delivery of child care services. Lead Agencies must also support the fixed cost of child care services based on paying by the child’s authorized enrollment, or if impracticable, an alternative approach that will not undermine the stability of child care programs as justified and approved through this Plan. Lead Agencies must also (1) pay providers based on established part-time or full-time rates rather than paying for hours of service or smaller increments of time, and (2) pay for reasonable, mandatory registration fees that the provider charges to private-paying parents. These policies apply to all provider types unless the Lead Agency can demonstrate that in limited circumstances the policies would not be considered generally-accepted payment practices. In addition, Lead Agencies must ensure that child care providers receive payment for any services in accordance with a payment agreement or an authorization for services, ensure that child care providers receive prompt notice of changes to a family’s eligibility status that could impact payment, and have timely appeal and resolution processes for any payment inaccuracies and disputes. 4.4.1 Prospective and enrollment-based payment practices Lead Agencies must use payment practices for all CCDF child care providers that reflect generally- accepted payment practices of providers serving private-pay families, including paying providers in advance or at the beginning of the delivery of child care services and paying based on a child’s authorized enrollment or an alternative approach for which the Lead Agency must demonstrate paying for a child’s authorized enrollment is not practicable and it will not undermine the stability of child care programs. Lead Agencies may only use alternate approaches for subsets of provider types if they can demonstrate that prospective payments and authorized enrollment-based payment are not generally-accepted for a type of child care setting. Describe the Lead Agency payment practices for all CCDF child care providers: a. Does the Lead Agency pay all provider types prospectively (i.e., in advance of or at the beginning of the delivery of child care services)? [ ] Yes. If yes, describe: [x] No, it is not a generally-accepted payment practice for each provider type. If no, describe the provider type not paid prospectively and the data demonstrating it is not a generally-accepted payment practice for that provider type, and describe the Lead Agency’s payment practice that ensures timely payment for that provider type: To date our payment process, quality controls and fraud detection have been established on Provider Invoicing that requires provider to confirm care of child and dates of leave from services. This helps assure that program payments are for services rendered and limit the efforts for an number of recoupment of overpaid funds. Ther are statutory limits on the amount of payments that can be recouped at one time and lends itself to having fund repayment extend over several quarters and multiple fiscal years. Some of these funds go directly into the State collection and are cannot be redirected into the exact program or service, depending on circumstance for recoupment. In addition, if a provider is no longer serving children in Care 4 Kids, the recoupment of overpaid funds will be difficult. This may especially be true for Relative Care where the turn-over of provider is based on their relative child needing care and ends with that child or family’s need for care. A process has not been established for a potential significant increase in collection of cost of care for last month care if child did not participate. A new payment process and system would need to be establish and may have significant Information and Technology costs as well as the need for additional process and recoupment staff. Connecticut will request a waiver to establishing prospective payments for a two-year period in order to align Provider Portal invoicing and Eligibility Certificate and payment processes with a prospective payment methods. Based on Connecticut's General Statutes and the efficiency and effectiveness of the Care 4 Kids invoicing and payment process and staff, payments are issued within 15 days for billing for services. b. Does the Lead Agency pay based on authorized enrollment for all provider types? [x] Yes. The Lead Agency pays all providers by authorized enrollment and payment is not altered based on a child’s attendance or the number of absences a child has. [ ] No, it is not a generally-accepted practice for each provider type. If no, describe the provider types not paid by authorized enrollment, including the data showing it is not a generally-accepted payment practice for that provider type, and describe how the payment policy accounts for fixed costs: [ ] It is impracticable. Describe provider type(s) for which it is impracticable, why it is impracticable, and the alternative approach the Lead Agency uses to delink provider payments from occasional absences, including evidence that the alternative approach will not undermine the stability of child care programs, and thereby accounts for fixed costs: 4.4.2 Other payment practices Lead Agencies must (1) pay providers based on established part-time or full-time rates rather than paying for hours of service or smaller increments of time, and (2) pay for reasonable, mandatory registration fees that the provider charges to private-paying parents, unless the Lead Agency provides evidence that such practices are not generally-accepted for providers caring for children not participating in CCDF in its State or Territory. a. Does the Lead Agency pay all providers on a part-time or full-time basis (rather than paying for hours of service or smaller increments of time)? [x] Yes. [ ] No. If no, describe the policies or procedures that are different than paying on a part- time or full-time basis and the Lead Agency’s rationale for not paying on a part-time or full-time basis: b. Does the Lead Agency pay for reasonable mandatory registration fees that the provider charges to private-paying parents? [x] Yes. If yes, identify the fees the Lead Agency pays for: Care 4 Kids will pay for mandatory registration fees. The maximum annual fee reimbursement per registration is $50 during the child's 12-month eligibility period. A registration fee can be charged two times during the child's 12-month eligibility period for a maximum benefit of $100. The registration fee can be paid to multiple providers. All providers, excluding unlicensed relatives, that charge a mandatory registration fee, will be reimbursed for the registration fee charged per child during the child's eligibility period. - Providers, excluding unlicensed relatives, who charge less than the established program maximum fee, will be reimbursed at the lower rate. - The mandatory registration fee per child may be reimbursed for a maximum number of occurrences, excluding unlicensed relatives, but will not exceed the established program maximum fee limit during the child's eligibility period. - For reimbursement of the registration fee, the provider will document the mandatory registration fee charged on the Parent Provider Agreement. Policy transmittal: C4K-POL- 01 revised. [ ] No. If no, identify the data and how data were collected to show that paying for fees is not a generally-accepted payment practice: c. Describe how the Lead Agency ensures that providers are paid in accordance with a written payment agreement or an authorization for services that includes, at a minimum, information regarding provider payment policies, including rates, schedules, any fees charged to providers, and the dispute-resolution process: The parent and provider are required to complete and sign a Parent Provider Agreement Form (PPA) which indicates the provider rate, the child's schedule and attestations for both the parent and provider. Certificates are then issued for services. The actual payment is based upon the submitted invoice for services. There are no fees charged to providers. A provider is paid based on their attestation in their monthly invoice, which is generated through the provider portal. If a provider feels that the amount paid to them is incorrect when the payment is received, the process is for the provider to contact Care 4 Kids within 30 days to report the dispute. At that point a Care 4 Kids worker is assigned to review the case and if based on the review a correction needs to be made to the provider, then an adjustment is made through the ImpaCT system and the case is resolved. All documentation of this process is recorded in the provider's case notes. The PPA provides the link to the Care 4 Kids website to access additional information about the Care 4 Kids program. The dispute-resolution process is noted on the Care 4 Kids website: https://www.ctcare4kids.com/provider- information/#invoiceinfo. d. Describe how the Lead Agency provides prompt notice to providers regarding any changes to the family’s eligibility status that could impact payments, and such a notice is sent no later than the day that the Lead Agency becomes aware that such a change will occur: Care 4 Kids mails a notice the same day there is a change in eligibility. For example, if Care 4 Kids discontinues a case, the Notice of Discontinuance goes out the same day. e. Describe the Lead Agency’s timely appeal and resolution process for payment inaccuracies and disputes: If a provider feels that the amount paid to them is incorrect when the payment is received, the process is for the provider to contact Care 4 Kids within 30 days to report the dispute. At that point a Care 4 Kids worker is assigned to review the case and if based on the review a correction needs to be made to the provider, then an adjustment is made through the ImpaCT system and the case is resolved. Based on CT's Regulations: the appeal process is open to families only. Families have 60 days to request a hearing. The OEC has 30 days to schedule a hearing. After a hearing is complete, OEC has 60 days to finalize the hearing decision. f. Other. Describe any other payment practices established by the Lead Agency: 4.4.3 Payment practices and parent choice How do the Lead Agency’s payment practices facilitate provider participation in all categories of care? Care 4 Kids create electronic invoices on the first of each month for each Child Care Certificate. Care 4 Kids providers log into the Provider Portal and submit their monthly invoice. The portal is mobile friendly and allow providers to submit online either on their smart phone or computer. The system is configured to ensure all necessary information is completed before the invoice is accepted for payment. This is an efficient process to ensure providers are paid timely. Care 4 Kids pays providers' full invoice for the entire month of service if the child attends one day during that service month. Payments are made in the order that the submission by the provider is received.