2.3 Prioritizing Services for Vulnerable Children and Families

Lead Agencies must give priority for child care assistance to children with special needs, families with very low incomes (considering family size), and children experiencing homelessness. A Lead Agency has the flexibility to prioritize other populations of children. Note: Statute defines children with disabilities, and CCDF rule gives flexibility to Lead Agencies to include vulnerable populations in their definition of children with special needs. CCDF defines “child experiencing homelessness” as a child who is homeless, as defined in Section 725 of Subtitle VII-B of the McKinney-Vento Act (42 U.S.C. 11434a). 2.3.1 Lead Agency definition of priority groups Describe how the Lead Agency defines: d. “Children with special needs.” A child who requires special services due to developmental/intellectual or social emotional disabilities, sensory or motor impairment, or chronic illness. Child Care benefits may be provided to protect children who cannot protect themselves from abuse, neglect, and exploitation, to enable a child to remain in the home while the parent(s) work toward rehabilitation or when the child is at risk of a health or social condition which may adversely affect the child. The social service child care reason is used for this purpose and may include: 1. "Parents with Crisis": a. Parent hospitalized or otherwise temporarily unable to provide adequate care for the child. This could be inpatient or outpatient, for physical health, mental health, or substance abuse treatment. There is no other adult to care for the child. b. Family in the process of Kansas Department for Children and Families Intake and Assessment through Prevention and Protection Services (PPS). c. Family receiving services through a family preservation contractor or Kansas Department for Children and Families PPS Social Worker. 2. Juvenile offenders in the custody of the Kansas Department of Corrections - Juvenile Services when the foster parent is employed and needs child care. 3. Children in Foster Care who are in the custody of the Secretary of Kansas Department for Children and Families who have been placed with a relative or non-related kin not licensed for Foster Care. This does not include foster children placed in a licensed foster home, as child care for those children is provided by the state's foster care contractors. 4. Children whose caretaker has placed them with a "Safe Families for Children" host family due to a family crisis, thereby avoiding placement of the children in Foster Care. These children are not in Foster Care. Child care for these children must be needed due to the employment or education/training of the adults in the "Safe Families for Children" host family. Parents Performing Essential Functions during a Disaster or Emergency. When a disaster or emergency has been declared by Kansas Government and child care is needed for parents to continue performing essential functions, eligibility for Child Care Assistance may be granted under the social service need reason. When a disaster or emergency has been declared, specific guidance will be provided in a separate Policy Memo for each event due to the limitations of funds and variations in the number of parents who may be eligible. Any financial eligibility tests applicable for these families will be outlined in the Policy Memo. In addition to an application, reasonable verification that the parent performs an essential function that was approved in the Policy Memo will be required. e. “Families with very low incomes.” Families participating in work programs who are receiving Cash Assistance or Food Assistance or who are Tribal TANF Work Program recipients. 2.3.2 Prioritization of child care services Identify how the Lead Agency will prioritize child care services for the following children and families. a. Complete the table below to indicate how the identified populations are prioritized. Population Prioritized Prioritize for enrollment in child care services Serve without placing on waiting list Waive co- payments as described in 3.3.1 Pay higher rate for access to higher quality care Use grants or contracts to reserve spots Other Children with special needs [x] [ ] [x] [x] [ ] [ ] Describe: Families with very low incomes [x] [ ] [x] [ ] [ ] [ ] Describe: Population Prioritized Prioritize for enrollment in child care services Serve without placing on waiting list Waive co- payments as described in 3.3.1 Pay higher rate for access to higher quality care Use grants or contracts to reserve spots Other Children experiencing homelessness, as defined by CCDF [x] [ ] [ ] [ ] [ ] [ ] Describe: (Optional) Families receiving TANF, those attempting to transition off TANF, and those at risk of becoming dependent on TANF [x] [ ] [x] [ ] [ ] [ ] Describe: a. Does the Lead Agency define any other priority groups? [ ] No. [x] Yes. If yes, identify the populations prioritized and describe how the Lead Agency prioritizes services: The priority list for Kansas also includes: Families receiving child care for a qualified Social Service reason. (This would include families with a temporary emergency need due to parents with crisis, juvenile offenders in the custody of the Kansas Department of Corrections Juvenile Services when the foster parent is employed and needs child care, children in foster care who are in the custody of the Secretary of the Department for Children and Families who have been placed with a relative or non-related kin not licensed for foster care, children whose caretaker has placed them with a Safe Families for Children host family due to a family crisis, thereby avoiding placement of the children in foster care, and children whose parents are performing essential functions during a disaster or emergency.); Teen parents completing high school/GED; Employed families whose income is at or below 185% of the federal poverty level. Priorities established by the lead agency for Child Care Assistance may be found at Kansas Economic and Employment Services Manual 2840. 2.3.3 Enrollment and grace period for children experiencing homelessness Lead Agencies must allow (after an initial eligibility determination) children experiencing homelessness to receive CCDF services while required eligibility documentation is obtained. Lead Agencies must establish a grace period that allows children experiencing homelessness and children in foster care to receive CCDF assistance while providing their families with a reasonable time to take any necessary actions to comply with State, Territory, or local immunization and other health and safety requirements. The length of such a grace period must be established in consultation with the State, Territorial, or Tribal public health agency. Note: Any payment for such a child during the grace period may not be considered an error or improper payment. a. Describe the strategies to allow CCDF enrollment of children experiencing homelessness while required eligibility documentation is obtained: When a child experiencing homelessness needs child care assistance, the agency may delay citizenship verification according to the following policy. This policy can apply to other situations when needed. As per Kansas Economic and Employment Services Manual 2145.1 - Citizenship Documentation Delay for Cash Assistance and Child Care Subsidy the application shall be processed and approved granting a reasonable opportunity period to the individual to provide verification. This period shall be 3 calendar months commencing from the date the case is authorized. If the verification is not received by the end of the reasonable opportunity period, benefits shall end allowing for timely and adequate notice. The reasonable opportunity period may be extended in situations where the individual is making a bona fide effort to obtain the verification, but circumstances outside his/her control are delaying the effort. A decision to extend the period must be thoroughly documented and supported in the case file. As per Kansas Child Care Regulation - The Kansas Department of Health and Environment grants the following allowances in Kansas Child Care Regulation to ease any barriers in community efforts to accommodate displaced families, children, and youth into existing regulated child care facilities. Displaced children and youth entering regulated child care facilities for temporary emergency care not required to provide documentation of current immunizations and health assessment for up to 60 days and facilities must obtain as much information as possible about the children's/youth's health needs including any current medications being taken and any know medication, food, or other allergies. b. Describe the grace period for each population below and how it allows them to receive CCDF assistance while providing their families with a reasonable time to take any necessary actions to comply with immunization and other health and safety requirements. i. Provide the policy for a grace period for: Children experiencing homelessness: Kansas Department of Health and Environment grants the following allowances to ease any barriers in community efforts to accommodate displaced families, children, and youth into existing regulated child care facilities: Displaced children and youth entering regulated child care facilities for temporary emergency care are not required to provide documentation of current immunizations and health assessment for up to 60 days. Kansas Department of Health and Environment considers a homeless child "displaced". Facilities are to obtain as much information as possible about the children's/youth's health needs including any current medications being taken and any known medication, food, or other allergies. If during enrollment for child care subsidy Kansas Department for Children and Families is unable to verify citizenship, verification shall be waived and a three (3) month reasonable opportunity period for the individual to provide the information shall be applied. If otherwise eligible, the applicant may be approved for assistance. The individual shall be contacted to provide the information and notified of the reasonable opportunity period. Children who are in foster care: Kansas Department of Health and Environment grants the following allowances to ease any barriers in community efforts to accommodate displaced families, children, and youth into existing regulated child care facilities: Displaced children and youth entering regulated child care facilities for temporary emergency care are not required to provide documentation of current immunizations and health assessment for up to 60 days. Facilities are to obtain as much information as possible about the children's/youth's health needs including any current medications being taken and any known medication, food, or other allergies. If during enrollment for child care subsidy Kansas Department for Children and Families is unable to verify citizenship, verification shall be waived and a three (3) month reasonable opportunity period for the individual to provide the information shall be applied. If otherwise eligible, the applicant may be approved for assistance. The individual shall be contacted to provide the information and notified of the reasonable opportunity period. ii. Does the Lead Agency certify that the length of the grace period was established in consultation with the State, Territorial, or Tribal public health agency? [x] Yes. [ ] No. If no, describe: c. Describe how the Lead Agency coordinates with licensing agencies and other relevant State, Territorial, Tribal, and local agencies to provide referrals and support to help families with children receiving services during a grace period comply with immunization and other health and safety requirements: Kansas Department for Children and Families designed an Early Childhood Program Services brochure and distributed to Food Assistance Programs across the state, which included The Emergency Food Assistance Program, Commodity Supplemental Food Program sites, soup kitchens, food banks and homeless shelters. Programs were asked to post the information and share with families utilizing their programs. The brochure is emailed out annually and may be accessed on Kansas Department for Children and Families’ website. It includes information for early childhood programs in Kansas such as Early Head Start, Head Start, Part C Infant-Toddler Services, Part B Special Education Services and Parents as Teachers. Another informational document that was developed and distributed to all Head Start and Early Head Start programs was the McKinney- Vento and Head Start: Ensuring Access to Early Education. This resource guide was designed to provide information on where the McKinney-Vento Programs are located and how to contact a local McKinney-Vento liaison. The purpose of this document is to promote better communication and coordination between Head Start and the local school districts. In addition, Kansas Department for Children and Families has awarded funding for a Statewide Infant-Toddler Network to Kansas Child Care Training Opportunities and funding for Consumer Education/Resource & Referral services awarded to Child Care Aware of Kansas (CCAK). Both contracts address homelessness education and outreach as part of these agreements. The Kansas Child Care Regulation through the Kansas Department of Health and Environment, which is funded primarily through lead agency CCDF funding, granted a policy exception that allows any child experiencing displacement due to a natural disaster, foster care placement or homelessness be permitted for enrollment while documentation of immunizations and/or a heath assessment is obtained. A facility is allowed up to 60 days to obtain documents. This was shared publicly by emails and letters to all licensed child care providers and sponsoring agencies. Per the instructions in the email and/or letters the exception will be posted next to the providers license on the parent board in plain view for everyone to see. This information and these instructions were also added to the Kansas Department of Health and Environment’s website. Communication about this policy is also part of the onsite survey process, where licensing specialists are expected to inquire and ask questions when children’s files are incomplete. The Child Care Facility Licensing Specialist Policy and Procedure Manual explains to the licensing specialists that documentation of current immunizations and health assessments are not required for up to 60 days for displaced children and youth. This policy was clarified with licensing specialists as this directive included all home displacement scenarios. An email directive along with all Kansas Department of Health and Environment nonregulatory consultation reminders was provided to the licensing specialists. Licensing specialists participate in quarterly training which always include retraining on the correct use of violations and consultations. Kansas Department of Health and Environment reviews all field violations and/or consultations statewide quarterly to ensure correct application. If violations are noted in which a consultation should have been offered, an immediate correction will be made and the notice provided to the facility will be amended. An explanation of the policy was added to the Kansas Department for Children and Families Provider Handbook given to all providers who apply to become a Kansas Department for Children and Families enrolled provider. To ensure that families are aware of these policies, along with having providers post the information on the parent boards, this wording regarding the policy was added to the Parent/Provider Partnership Handbook in October 2022. It has also been added to the Child Care in Kansas Consumer Education Website. This policy is found in the Kansas Economic and Employment Services Manual 10034.