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Reason(s) for non-compliance: • The Lead Agency does not always provide a minimum 12-month eligibility period for each child and does not limit termination of eligibility based on voluntary reporting to allowable reasons, as required by 98.21(a)(1). (Plan Questions 2.5.2a and 2.5.2c) • The Lead Agency does not allow for all permissible temporary changes to parents’ work, education, or training status, as required by 98.21(a)(1)(ii)(A), 98.21(a)(1)(ii)(B), 98.21(a)(1)(ii)(C), and 98.21(a)(1)(ii)(D). (Plan Question 2.5.2b) • The Lead Agency does not provide sufficient justification for the second eligibility threshold for graduated phase-out, as required by 98.21(b)(1)(ii)(A) and 98.21(b)(1)(ii)(B)(1). (Plan Questions 2.5.5cii and 2.5.5.ciii) Overall Target Completion Date: 07/01/2025 Action Step Number Action Step Description Target Completion Date 1 The Lead agency respectfully advises that effective July 1, 2023, the following change occurred which now renders the state compliant with this regulation: Based on children being authorized during any period in a month, families may avail childcare later during the month, but the renewal period is set to 12 months which starts from initial month. This can result in less than 12 months of child care for families. The Lead Agency initiated an eligibility system Change Request that now aligns with policy to address this situation. The finalized approach now provides families with 13 months for child care when the filing date is not on the first of the month. For Intake Child Care Cases, if the Child Care Program Filing Date is not on the first of the month, then Child Care review dates are set to 13 months instead of 12 months. Policy Reference: 11004.9.5 Establishing 12- Month Authorization for Child Care 11000 Child Care Subsidy Program (delaware.gov) 01/08/2025 The lead agency respectfully advises that per policy #11004.11 Determining and Reviewing Childcare, when a family experiences a temporary change in ongoing status as working or attending job training or education program, services are continued at the same level for no less than 90 days to allow time for job search or re- engagement in a training program. Documentation regarding compliance with these provisions will be submitted. 2 The lead agency will request TA/guidance regarding compliance with provision of sufficient justification for the second eligibility threshold for graduated phase out. 02/15/2025 3 Delaware will implement action steps from the requested Technical Assistance. 07/01/2025 4 Delaware will amend its plan to document compliance. 07/01/2025