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. [ ] 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. [ ] 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. [x] 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 a i CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who conducts eligibility determinations? [x] [x] [x] [ ] [x] Describe: Early Learning Coalitions (ELCs) and Redlands Christian Migrant Association (RCMA) determine eligibility, ssist parents with locating child care, issue payments to providers, monitor licensed and license- exempt providers for contract/pro gram compliance and operate quality mprovement activities. 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] Describe: Early Learning Coalitions (ELCs) and Redlands Christian Migrant Association (RCMA) determine eligibility, assist parents with locating child care, issue payments to providers, monitor licensed and license- exempt providers for contract/pro gram compliance and operate quality improvement activities. CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who issues payments? [x] [ ] [x] [ ] [x] Describe: Early Learning Coalitions (ELCs) and Redlands Christian Migrant Association (RCMA) determine eligibility, assist parents with locating child care, issue payments to providers, monitor licensed and license- exempt providers for contract/pro gram compliance and operate quality improvement activities. CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who monitors licensed providers? [x] [ ] [x] [ ] [x] Describe: The Department of Children and Families (DCF) and local licensing agencies (LLA) in four counties monitor licensed and license- exempt providers for health and safety. Who monitors license-exempt providers? [x] [ ] [x] [ ] [x] Describe: The Department of Children and Families (DCF) and local licensing agencies (LLA) in four counties monitor licensed and license- exempt providers for health and safety. CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who operates the quality improvement activities? [x] [ ] [ ] [ ] [x] Describe: Early Learning Coalitions (ELCs) and Redlands Christian Migrant Association (RCMA) determine eligibility, assist parents with locating child care, issue payments to providers, monitor licensed and license- exempt providers for contract/pro gram compliance and operate quality improvement activities. 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: Oversight of Services and Activities: The DEL administers early learning programs through grant awards to 30 ELCs that are registered not-for-profit 501(c)(3) organizations statutorily tasked with implementing early learning programs within their local service areas; the RCMA, a not-for-profit statewide entity that serves the unique populations of migrant and seasonal and former farm worker families. The DEL also oversees contracts with several additional organizations for the delivery of other aligned early learning program services and activities. Some services are also provided by other state agencies and coordinated with DEL. The DEL fulfills its fiscal and programmatic monitoring responsibilities for the DEL sub-recipients through several mechanisms. Each ELC/RCMA is responsible for submitting an ELC/RCMA School Readiness (SR) service delivery plan for review/approval by the DEL. ELC SR plans must include the ELC's operations, procedures for implementing the SR application and waiting list, eligibility, enrollment processes, use of contracted slots, parent access and parental choice, sliding fee scale (and policies on applying the waiver or reduction of fees), child screening, program assessment policies, use of observation-based child assessments as applicable, provider payment rates, a detailed description of quality activities and services, a detailed budget, a detailed accounting, policies and procedures for procurement, maintenance of tangible personal property, maintenance of records, information technology, and disbursement controls, a description of the procedures for monitoring CCDF (SR) program providers (including a parental complaint process), and documentation that the ELC has solicited and considered comments regarding its proposed program plan from the local community. Each ELC/RCMA must update its SR plan at least triennially but can amend their plan throughout this timeframe as needed. The DEL has a formal SR plan amendment process in place for submission, review, and approval of SR plan changes. The DEL also maintains Memoranda of Understanding with DCF and the local child care licensing agencies (LLAs) in Broward, Palm Beach, Pinellas, and Sarasota counties to perform mandatory health and safety inspections. Annual Risk Assessments: A preliminary risk assessment is performed at the beginning of the fiscal year by DEL's Financial Management Systems Assurance Section (FMSAS) to establish proposed monitoring priorities, testing tasks and sample sizes. During the planning phase for the fiscal and programmatic monitoring tasks, a final risk assessment is performed using information provided by each ELC/RCMA as part of the planning/data gathering process for monitoring engagements. Individual scores are compiled for each ECL/RCMA to reach a composite risk score. That score is compared to pre-set ranges to determine each entity's overall risk level (low, medium, high). This score is used to identify the number and type of sample items selected for testing. Internal Control Surveys: Each ELC/RCMA and DEL sub-recipient is responsible for completing an annual internal control questionnaire (ICQ). The completed questionnaire is submitted to and reviewed by the DEL Program Integrity (PI) staff and used as part of the annual financial monitoring process by the DEL's contracted fiscal monitors. Annual Budget, Revenue, and Expenditure Reporting: The DEL staff reviews annual budget, revenue, and expenditure reporting to ensure reporting of costs is in accordance with the uniform chart of accounts, and in compliance with state and federal targeted funds and restrictions. Programmatic Monitoring: DEL's PI Unit includes an Accountability Section (AS) that conducts ongoing programmatic reviews for each ELC/RCMA. This review process addresses compliance with the SR program. This is completed with a two-phase approach: 1.) Biennial Accountability Review ￿ AS staff conduct an onsite or desk review of each ELC, including Governance, Operations, Educational Service Delivery, Child Care Resource and Referral (CCR&R), and Data Accuracy (which includes data edit reports related to eligibility and standard billing group codes). 2.) Eligibility Review - AS staff conducts these tests on a biennial basis for all ELCs and RCMA. Tests include a random sample of SR eligibility files and SR payment validation files. Training: The DEL staff conduct periodic training sessions related to eligibility issues. The AS has developed standard statewide eligibility monitoring guides for ELCs to use when monitoring their sub-recipients (if applicable). Validation of each ELC's sub-recipient monitoring results is completed during the ELC accountability review. In addition to validating an ELC's sub-recipient monitoring results for SR eligibility, the AS has developed monitoring tools to evaluate compliance in the areas of governance, operations, educational service delivery, CCR&R, and data accuracy. For ELCs and RCMA who provide SR services directly, the AS uses these monitoring tools to directly evaluate compliance in the areas of governance, operations, educational service delivery, CCR&R, data accuracy, SR child eligibility, SR provider payment validation. Monitoring activities for all ELCs and RCMA include corrective action plan acceptance and technical assistance as it relates to each ELC's and RCMA programmatic monitoring review. Financial Monitoring: The DEL's FMSAS is responsible for various financial monitoring tasks of the DEL sub-recipients, including the ELCs. The DEL contracts for financial monitoring services with a qualified CPA firm licensed to practice within the State of Florida. The CPA firm conducts the annual financial compliance onsite monitoring visits under the direction of the DEL staff. Current financial monitoring tasks are detailed in DEL's financial monitoring tools and include the following categories (as applicable) for the DEL sub-recipients: - Preventive/Correction Action Plan Implementation - Financial Management Systems - Internal Control Environment - Cash and Revenue Management - DEL Statewide Information System Reporting and Reconciliation - Prepaid Program Items - Cost Allocation and Disbursement Testing - Travel - Purchasing - Contracting - Sub-recipient Monitoring Separate monitoring tools have been provided for selected sub-recipients (statewide contracts, universities, etc.). Other annual FMSAS monitoring tasks include but may not be limited to: review of annual Florida audit reports; notice to sub-recipients of monitoring findings; receipt of resulting preventive/corrective action plans; analysis of all preventive/corrective action plans to ensure timely review; revisions (as needed) and final approval of these plans; and preparation of periodic progress reports as requested by DEL management. The DEL also conducts internal reviews of DCF/LLA inspections to ensure that follow-up inspections are conducted when necessary. No. If no, describe: [ ] b. Schedule for completing tasks. [x] Yes. If yes, describe: The DEL conducts the following monitoring tasks: Biennially: Programmatic Monitoring Accountability Review, Eligibility Review Annually: Annual Risk Assessment, Internal Control Survey, Annual Budget, Revenue and Expenditure Reporting, Financial Monitoring, and Health and Safety Monitoring Monthly: Fiscal Desk Review As requested or deemed necessary: Training [ ] No. If no, describe: c. Budget which itemizes categorical expenditures in accordance with CCDF requirements. [x] Yes. If yes, describe: Fiscal Desk Reviews conducted by DEL's Financial Administration and Budget Services Unit focus on ELC expenditures to determine the allowability of reimbursed expenditures as a complement to the monthly invoice submission process and annual financial monitoring activities. These desk reviews select a limited number of sample items from administrative, quality, and other non-direct service expenditures. [ ] No. If no, describe: d. Indicators or measures to assess performance of those agencies. [x] Yes. If yes, describe: DEL reviews the results of fiscal monitoring activities as well as technical assistance requests from ELCs/contractors to determine and track the effectiveness of fiscal management practices. Compliance trends are identified to provide insight into areas of risk and improvement. [ ] 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. 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: