2.5 Promoting Continuity of Care

Lead Agencies must consider children’s development and promote continuity of care when authorizing child care services and must establish a minimum 12-month period for each child, both at the initial eligibility determination and redetermination. 2.5.1 Children’s development Describe how the Lead Agency’s eligibility, enrollment, reporting, and redetermination policies promote continuity of care in order to support children’s development. The DEL implements several policies to provide for the utmost continuity of care for families. A web-based portal system reduces paperwork and hardship on parents by providing online access to eligibility documentation, eliminating required office visits and reducing disruptions to education/training or employment. To further reduce barriers for families experiencing hardships, DEL allows families that identify under TANF or who are marked Medicaid eligible under DCF to use the child care authorization submitted by the referring agency in place of required eligibility documentation. Documentation from Social Security Benefits and SNAP are also used. For example, a child’s US citizenship may be determined if the child is marked Medicaid eligible on a DCF child care authorization or the household size may be determined by the SNAP benefit printout. In addition to TANF, ELCs have the ability to set priority factors when considering children's development and promoting continuity of care when authorizing child care services. These factors may include children with special needs, or a child who has an IEP or FSP. The DEL coordinates efforts with state agencies that oversee implementation of the IDEA. The DEL works closely with the BEESS to align identification and referral information. The Florida DOH oversees Part C, Early Steps Program; and the FLDOE oversees Part B, Pre-kindergarten Programs for Children with Disabilities. Early Head Start grantees coordinate with the Early Steps Program to recruit and provide comprehensive services to infants and toddlers with disabilities. Timely processing of all eligibility documentation received ensures families a quick turnaround for eligibility services. Families are provided with a 12-month eligibility period upon initial eligibility determination and redetermination. Additionally, if a new child is added into a household that currently has authorized SR services, the previously established children in services may have their care authorization dates extended to align with the new sibling’s authorization date. At redetermination, if a family’s income exceeds the threshold for initial eligibility to qualify for CCDF assistance, but does not exceed 85% of State median income, they remain eligible for services and enter graduated phase-out. (Copayments aren’t raised during 12-month eligibility period unless a family is in graduated phase out and reports an increase in income but remains under the maximum income threshold for SR services) Income requirements do not take into account one-time bonuses and agencies can account for irregular income fluctuations. DEL implements policies and procedures that promote universal design to ensure that activities and environments are accessible to all children, including children with sensory, physical, or other disabilities. The DEL works with Head Start and VPK to provide wrap around services for children who qualify for CCDF services to create a package of arrangements that accommodates parents’ work schedules. 2.5.2 Minimum 12-month eligibility Lead Agencies must establish a minimum 12-month eligibility period for each child, both at the initial eligibility determination and at redetermination to support continuity in child care assistance and reduce barriers to families retaining eligibility. This requirement is: • Regardless of changes in income, Lead Agencies may not terminate CCDF assistance during the minimum 12-month period if a family has an increase in income that exceeds the Lead Agency’s income eligibility threshold but not the federal threshold of 85 percent of SMI; and • Regardless of temporary changes in participation in work, training, or educational activities. a. Does the Lead Agency certify that their policies or procedures provide a minimum 12- month eligibility period for each child at initial eligibility determination? [x] Yes. [ ] No. If no, describe: b. Does the Lead Agency certify that its definition of “temporary change” includes each of the minimum required elements? 1. Any time-limited absence from work for an employed parent due to such reasons as the need to care for a family member or an illness. 2. Any interruption in work for a seasonal worker who is not working between regular industry work seasons. 3. Any student holiday or break for a parent participating in a training or educational program. 4. Any reduction in work, training, or education hours, as long as the parent is still working or attending a training or educational program. 5. Any cessation of work or attendance at a training or educational program not listed above. In these cases only, Lead Agencies may establish a period of 3 months or longer. 6. Any change in age, including a child turning 13 years old during the minimum 12-month eligibility period. 7. Any changes in residency within the State or Territory. [x] Yes. [ ] No. If no, describe: c. Are the policies different for redetermination? [x] No. [ ] Yes. If yes, provide the additional/varying policies for redetermination: 2.5.3 Job search and continued assistance a. Does the Lead Agency consider seeking employment (engaging in a job search) as an eligible activity at initial eligibility determination and/or at the minimum 12-month eligibility redetermination? (Note: If yes, Lead Agencies must provide a minimum of 3 months of job search.) Check all that apply: i. [ ] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at initial eligibility determination. If yes, describe: ii. [ ] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at redetermination. If yes, describe: iii. [x] No. The Lead Agency does not consider seeking employment (engaging in a job search) as an eligible activity at initial eligibility determination or redetermination. b. Does the Lead Agency continue assistance during the minimum 12-month eligibility period when a parent has a non-temporary loss or cessation of eligible activity? [ ] Yes. The Lead Agency continues assistance. [x] No, the Lead Agency discontinues assistance. i. If no, describe the Lead Agency’s policies for discontinuing assistance due to a parent’s non-temporary change: During the 12-month eligibility period, if a parent loses purpose for care due to a non-temporary loss of work or education activity, the parent will receive three months of continued services to obtain a new purpose for care (i.e., employment or education activity). If the parent does not re-establish a new purpose for care within a three-month period, the family’s services are discontinued. ii. If no, describe what specific actions/changes trigger the job-search period after each such loss or cessation: 1. For families receiving services based on child care authorization from a referring agency, the three-month job search period is triggered when the referring agency does not issue another referral upon expiration or termination of the previous referral. 2. For families that are income eligible, the three-month job search period is triggered by the parent self-reporting a loss in purpose for care (i.e., employment or education activity). iii. If no, how long is the job-search period where a family can continue assistance (must be at least 3 months)? The job-search period is three months c. The Lead Agency may discontinue assistance prior to the next minimum 12-month redetermination in the limited circumstances listed below. Check and provide the policy for all circumstances in which the Lead Agency chooses to discontinue assistance prior to the next minimum 12-month redetermination: i. [ ] Not applicable. ii. [x] Excessive unexplained absences despite multiple attempts by the Lead Agency or designated entity to contact the family and provider, including the prior notification of a possible discontinuation of assistance. Provide the Lead Agency’s policy defining the number of unexplained absences identified as excessive: If a child has five consecutive days of absences during their regularly scheduled attendance or more than ten unexplained absences where no verbal or written communication with the parent is provided and not including an extraordinary circumstance, during a calendar month the provider can submit written notification to the local coalition or its designee who in turn shall determine the need for continued care for the child. As mandated in Rule 6M-4.200(8)(a), F.A.C., ELCs must document three attempts to contact the family and the provider prior to disenrollment. The coalition shall document in the case file all attempts to contact the parent by the coalition, provider or referring agency, if applicable. If it is determined that services are no longer needed, the local coalition or its designee shall send a notice of termination to the parent and provider two weeks prior to the disenrollment or through the end of the authorization period, whichever ends sooner. An at-risk child may not be disenrolled without written approval from the appropriate child welfare office. iii. [x] A change in residency outside of the State or Territory. Provide the Lead Agency’s policy for a change in residency outside the State or Territory: Services are discontinued if a family moves out of the state of Florida. iv. [x] Substantiated fraud or intentional program violations that invalidate prior determinations of eligibility. Provide the Lead Agency’s definition of fraud/intentional program violations that lead to discontinued assistance: The ELCs are required to submit anti-fraud plans annually that include procedures for identifying fraud and due process procedures for clients. The ELCs must follow their DEL-approved anti-fraud plans to establish substantiated fraud amounting to termination prior to the conclusion of the 12-month period. In cases of intentional program violations, the ELCs are required to document instances of intentional program violations (IPVs) prior to termination. 2.5.4 Reporting changes during the minimum 12-month eligibility period Lead Agencies may only require families to report changes that impact a family’s eligibility, including only if the family’s income exceeds 85 percent of the SMI, taking into account irregular fluctuations in income, or there is a non-temporary change in the parent’s work, training, or education status, during the 12-month eligibility period. Lead Agencies may also require families to report that enable the lead agency to contact the family or pay providers, such as a new telephone number or address. Note: The response below should exclude reporting requirements for a graduated phase-out, which are described in question 2.5.5. Does the Lead Agency limit what families must report during the 12-month eligibility period to the changes described above? [x] Yes. [ ] No. If no, describe: 2.5.5 Policies and procedures for graduated phase-out of assistance at redetermination Lead Agencies that establish initial family income eligibility below 85 percent of SMI must provide a graduated phase-out of assistance for families whose income has increased above the Lead Agency’s initial income threshold at the time of redetermination but remains below the federal threshold of 85 percent of SMI. Lead Agencies that provide a graduated phase-out must implement a two-tiered eligibility threshold, with the second tier of eligibility (used at the time of eligibility redetermination) to be set at: (i) 85 percent of SMI for a family of the same size; or, (ii) An amount lower than 85 percent of SMI for a family of the same size but above the Lead Agency’s initial eligibility threshold that: (A) Takes into account the typical household budget of a family with a low income (B) Provides justification that the second eligibility threshold is: (1) Sufficient to accommodate increases in family income over time that are typical for workers with low incomes and that promote and support family economic stability (2) Reasonably allows a family to continue accessing child care services without unnecessary disruption At redetermination, a child must be considered eligible if their parents are participating in an eligible activity even if their income exceeds the Lead Agency’s initial eligibility income limit as long as their income does not exceed the second tier of eligibility. Note that once determined eligible, the child must be considered eligible for a full minimum 12-month eligibility period, even if the parents’ income exceeds the second tier of eligibility during the eligibility period, as long as it does not exceed 85 percent of SMI. A child eligible for services via the graduated phase-out of assistance is considered eligible under the same conditions as other eligible children with the exception of the co-payment restrictions, which do not apply to a graduated phase-out. To help families transition from child care assistance, Lead Agencies may gradually adjust co-payment amounts in proportion to a family’s income growth for families whose children are determined eligible under a graduated phase-out. Lead Agencies may require additional reporting on changes in family income but must still ensure that any additional reporting requirements do not constitute an undue burden on families. Check and describe the option that best identifies the Lead Agency’s policies and procedures regarding the graduated phase-out of assistance. a. [ ] Not applicable. The Lead Agency sets its initial eligibility threshold at 85 percent of SMI and therefore is not required to provide a graduated phase-out period. (If checked, skip to question 3.1.1.) b. [x] The Lead Agency sets the second tier of eligibility at 85 percent of SMI. If checked, describe the policies and procedures: Upon redetermination, after 12 months, and if the family income is above 150 percent FPL (entry level) and below 85 percent SMI, the parent begins to phase out of the SR Program. During this graduated phase-out, as a family’s income increases, copayments will increase in gradual increments for family incomes above 150 percent FPL and up to 85 percent SMI. Once family income exceeds 85 percent SMI, the family is no longer eligible. i. [x] Lead Agency adjusts the family’s co-pay during the graduated phase-out period. If checked, describe how the Lead Agency gradually adjusts co-payment for families under a graduated phase-out period in proportion to a family’s income growth. Include information on the percentage or amount of change made in the co-payment during graduated phase-out: At the end of the initial 12- month eligibility period, if a family’s income is above 150 percent FPL, but at or below 85 percent of the SMI, the family will enter the graduated phase-out. As the family's income increases, the co-payment gradually increases based on the approved sliding fee scale. ii. [x] Lead Agency requires additional reporting requirements during the graduated phase-out period. If checked, describe: During graduated phase-out, the family shall report any changes in family size or income to the ELC within 10 calendar days. c. [ ] The Lead Agency sets the second tier of eligibility at an amount lower than 85 percent of SMI for a family of the same size but above the Lead Agency’s initial eligibility threshold. If checked, provide the following information: i. Provide the income level ($/month) and the percent of SMI for the second tier of eligibility for a family of three: ii. Describe how the second eligibility threshold takes into account the typical household budget of a low-income family: iii. Describe how the second eligibility threshold is sufficient to accommodate increases in family income over time that are typical for low-income workers and that promote and support family economic stability: iv. Describe how the second eligibility threshold reasonably allows a family to continue accessing child care services without unnecessary disruption: v. [ ] Lead Agency adjusts the family’s co-pay during the graduated phase-out period. If checked, describe how the Lead Agency gradually adjusts co-payment for families under a graduated phase-out period in proportion to a family’s income growth. Include information on the percentage or amount of change made in the co-payment during graduated phase-out: vi. [ ] Lead Agency requires additional reporting requirements during the graduated phase-out period. If checked, describe: 3 Child Care Affordability CCDF subsidies make child care more affordable for eligible families, providing access to a greater range of child care options that allow parents to work, go to school, or enroll in training and they allow parents to access higher quality care options that better support children’s development. CCDF requires some families participating in CCDF to pay an affordable co-payment set by the Lead Agency to cover a part of their care. But co-payments can be a significant and destabilizing financial strain on family budgets and a barrier to parent employment, and the CCDBG Act requires that the co-payment amount not be a barrier to families participating in CCDF. Lead Agencies may not set parent co-payments above 7% of family income regardless of gradual phase- out policies and regardless of the number of children receiving assistance. Lead Agencies are encouraged to set co-payments much lower than 7% to make child care more affordable for more families and have broad flexibility to waive co-payments for to many participants. Lead Agencies must ensure that the total payment to a child care provider is not reduced because of family’s lowered or waived co-payment. In this section, Lead Agencies will identify how they determine an eligible family’s co-payment, the policies in place to waive or ensure co-payments are affordable for families, and how the Lead Agency improves access for children and families in economically and/or socially marginalized communities.