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: Payments are issued directly to eligible providers via check or direct deposit on the second business day of the month following the month when care was provided. For example, payment for care provided in September would be made on the second business day of October. Idaho is developing a plan for prospective payments in alignment with the 2024 CCDF Rules. Idaho intends to apply for a transitional waiver while we work to implement prospective payments. b. Does the Lead Agency pay based on authorized enrollment for all provider types? [ ] 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: [x] 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: Idaho requires that rates charged by the child care provider must not exceed the usual and customary rates charged for child care to persons not entitled to receive benefits under ICCP. If a child care provider's established rates are not altered based on a child's attendance the subsidy payment is not altered. Idaho intends to apply for a transitional waiver as we develop additional strategies to pay by authorized enrollment not linked to a child's number of absences. 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: One-time fees for registering a child in a child care facility are payable above the local market rate if the fee is charged to all who enroll in the facility. Reimbursement cannot exceed $250 and must be usual and customary rates charged to all families. Registration fees are separate from local market rates. ( IDAPA 16.06.12.500.02). [ ] 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: All Idaho Child Care Program (ICCP) child care providers sign an 'ICCP Provider Agreement' annually which describes the provider's and the State's requirements and responsibilities while participating in the Idaho Child Care Program. Additionally, all new providers complete a subsidy orientation with an IdahoSTARS Resource Specialist to review the participation requirements billing practices for ICCP. The ICCP Provider Agreement and the orientation both reference Child Care IDAPA and ensure providers know, read and understand the rights and responsibilities, which include the dispute resolution process as identified as 'PROVIDER NOTIFICATION' in IDAPA 16.06.12.752. The ICCP Provider Agreement also reminds providers that they are subject to, and protected by, the entire chapter of IDAPA 16.06.12 "Rules Governing the Idaho ChildCare Program (ICCP)". This chapter explains payment policies (16.06.12.500.-505), and the dispute-resolution process (16.06.12.003 and 16.06.12.752). 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: Providers are notified of projected payment as soon as the client's eligibility is determined, if a family's projected payment amount changes, if the case closes, or requires the completion of a reevaluation to remain eligible. Providers receive a monthly statement of all issued payments with the payment. e. Describe the Lead Agency’s timely appeal and resolution process for payment inaccuracies and disputes: Administrative Appeals - ( IDAPA 16.06.12.003) All administrative appeals are governed by provisions of IDAPA 16.05.03, "Rules Governing Contested Cases Proceedings and Declaratory Rulings." Clients have 30 days from the date of a decision to request a fair hearing. Fair hearing officers review and responds to all requests within five calendar days of the "Fair Hearing Requested" task being set. They communicate the status of reinstatement/continuance of benefits pending the hearing result to the customer within five calendar days of the "Fair Hearing Requested" task being set, then work with the client to coordinate and manage all aspects of a fair hearing to completion. (Benefits Process Manual: "Fair Hearing Process"). Provider Notification - ( IDAPA 16.06.12.752) "When the Department determines actions defined in Sections 701 through 705, 750,and 751 [Overpayment, Intentional Program Violation, Denial of Payment, Funding Restrictions, Termination of Provider Status, Refusal to Enter Into An Agreement] of these rules are appropriate, it will send written notice of the decision to the provider or person. The notice will state the basis for the action, the length of the action, the effect of the action on that person's ability to provide services under state and federal programs, and the person's appeal rights." 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? Providers and advocacy groups continue to support the practice of allowing child care providers to charge above the Local Market Rate, as demonstrated in feedback provided for this plan. This policy encourages and maintains a majority of Idaho’s child care providers’ voluntary participation with the Idaho Child Care Program (ICCP). Idaho’s payments are timely, and providers receive accurate payment information each month. Providers have quick and easy access to DHW staff via email, phone call, or in-office visit to assist with any payment questions or issues. Families participating in ICCP continue to access every type of child care provider, including high quality providers participating in Idaho's QRIS program and NAEYC accreditation. More than 10% of all children participating in child care subsidy in Idaho are being served in programs considered to be high quality as defined in Idaho’s Quality Ratings and Improvement System. Ongoing Market Rate updates continue to ensure that providers participating in ICCP will maintain their participation with ICCP, and families will continue to be able to access Idaho's best child care choices.