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. In order to ensure consistent relationships that support a child’s continued development, the Lead Agency ensures continuity of care in instances of unforeseen circumstances (such as a parent dying), changes in family dynamics (such as a parent going to jail), and changes in eligibility status with other agency programs (i.e., DCFS). The Lead Agency will also allow a presumptive eligibility period of up to 30 days, following the re-certification anniversary date (which is the deadline for application for redetermination), to ensure continuity of child care services to support children’s development, as redetermination is determined. 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. [x] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at initial eligibility determination. If yes, describe: (Bulletin 139 Section 509 A(5)e.b.) If the head of household is actively seeking employment and/or training, the employment and/or training requirements for household certification may be waived for 90 days. To become certified as a CCAP household in accordance with this exception, the household must meet all certification requirements other than the employment and/or training activities and must submit all documentation required for certification, as well as documentation establishing that the Head of Household is actively seeking employment and/or training. A household certified for CCAP in accordance with this exception will be certified for 90 days, with eligibility for services beginning on the day the household is certified. At the end of 90 days from the date of certification, certification under this exception ends. However, during the 90-day certification period, if the Head of Household submits documentation establishing employment and/or training meeting the requirements, then the household may remain certified without interruption in accordance with the general certification requirements. Households are not eligible for this exception at initial application if there is a statewide waitlist of eligible participants implemented. ii. [x] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at redetermination. If yes, describe: An application for household certification under this exception will be denied if the household has previously been certified under this exception within the past 24 months. 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? [x] 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: ii. If no, describe what specific actions/changes trigger the job-search period after each such loss or cessation: iii. If no, how long is the job-search period where a family can continue assistance (must be at least 3 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: Excessive absences are failure of a child to attend at least one day in the prior certified month. An "unexplained absence" is an absence for which the Head of Household has not provided verbal or written notification to the provider or the Lead Agency about the absence. The Lead Agency conducts an underutilization check monthly. Families with children missing 30 days or more are notified of possible termination if children are not attending. Families with children missing 60 days or more are notified of termination of the CCAP services for failure to attend. 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: All households must reside in Louisiana to be eligible for child care services. Households living in Louisiana for any purpose other than a vacation meet the residency requirement. Households do not have to establish a permanent home or intend to remain in the state to be eligible. When a household reports the residential address has changed to residency outside of the state, the case should be closed following procedures of CCAP closures or terminations and notices sent to the last provided address. 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: Violations may include any act of fraud, such as the submission of false or altered documents or information; intentionally making a false or misleading statement; or misrepresenting, concealing, or withholding relevant facts (noted in BESE Bulletin 139 Section 519, ￿Termination or Refusal of Renewal of Household Certification and Eligibility Periods for Households￿). 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. [x] 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: 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.