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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. All eligible families are approved for at least a 12-month eligibility period. Eligibility start dates for new applications will be based on the date care began, or up to one week prior to the application received date. Eligibility periods will end the last day of the 13th month if the start date is anything other than the 1st day of the month. New eligibility periods for cases being redetermined will always start on the first day of the month and end the last day of the 12th month. Neither families or providers are required to an interview as part of eligibility determination. Eligibility periods are only ended prior to the end of the 12th month in cases of income exceeding 85% SMI, relocation outside of Illinois, or after a 3-month grace period for a non-temporary loss of activity.
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?
Yes.
No. If no, describe: Currently Illinois sets the 12-month eligibility period based on the families application date. The eligibility period is not extended to allow for a child being added during that period to receive a full 12 months. Illinois is exploring how to implement policy and system changes to address this requirement. A waiver request to delay implementation of the new rule will be submitted.
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.
Yes.
No. If no, describe:
c. Are the policies different for redetermination?
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. 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.
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: CCAP cases will be granted a grace period of no fewer than 90 days if a parent/guardian ends participation in their approved activity permanently.
ii. If no, describe what specific actions/changes trigger the job-search period after each such loss or cessation: Notification of permanent loss of activity either verbally or in writing.
iii. If no, how long is the job-search period where a family can continue assistance (must be at least 3 months)? No fewer than 90 days
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. 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:
iii. 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: Once assistance program staff are notified of a family's relocating out of state, a cancelation is processed with an effective date that represents the information received from the family. Cancelation notices will be sent to the family and provider(s) including the following language: "You no longer live in Illinois. Families must reside in Illinois to be eligible for the child care assistance program.
iv. 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: an intentional program violation or an act of fraud in an effort to obtain eligibility, benefits, or financial gain or profit from the Child Care Assistance Program to which they would otherwise not be entitled.
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?
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. The Lead Agency sets the second tier of eligibility at 85 percent of SMI. If checked, describe the policies and procedures:
i. 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:
ii. Lead Agency requires additional reporting requirements during the graduated phase-out period. If checked, describe:
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:
Provide the income level ($/month) and the percent of SMI for the second tier of eligibility for a family of three: $4,684 per month for family size of 2, 70% SMI
Describe how the second eligibility threshold takes into account the typical household budget of a low-income family: The majority of the families participating in the Child Care Assistance Program, transition out of the program prior to reaching an income of 225275% FPL. For this reason, the Department believes that a second eligibility threshold of 275% FPL is consistent with the typical household budget of a low-income family.
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: Setting the exit level at 275% FPL allows families to continue an upward trajectory of income towards self-sufficiency. The exit level at 275% FPL was established because the state uses a significant number of TANF dollars to support the families that we serve and so while TANF exit is established at 225% FPL, a CCDF exit level at 275% FPL further accommodates increases in family income beyond TANF exit and will not create a negative impact in the family's finances.
Describe how the second eligibility threshold reasonably allows a family to continue accessing child care services without unnecessary disruption: The exit income level will allow for more earnings for the family while remaining in the assistance program. No additional reporting will be required for those that go above the entry level of 225% FPL. The percentage of income assessed as the parent co-payment remains consistent throughout the income scale.
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: Copay is assessed at the highest amount for the family size .
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 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.