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: At this time the Lead Agency is requesting a temporary waiver for meeting this provision, as the Department works to update systems and processes. Currently all system-automated weekly payments, which are the vast majority of payments, are made within 14 days of services. b. Does the Lead Agency pay based on authorized enrollment for all provider types? [x] 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: [ ] 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: 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: The Lead Agency pays reasonable registration fees on behalf of all CCAP households (in accordance with BESE Bulletin 139 Section 515). Allowable registration fees are based on the amount recorded in the provider certification agreement or the most current market rate survey, whichever is lower, and shall not exceed the state maximum. Payments for registration fees will be made to providers on behalf of all households once per certification period. [ ] 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: The Lead Agency has a written agreement with each CCAP provider that includes provisions on rates, copayment requirements, payments to providers, and audits and states that ￿Payment to the Provider is based on the authorized period that child care services are rendered for an eligible child needing care. CCAP payments are disbursed based on enrollment. Providers will receive notification in advance if this mode of payment changes. Also, Provider shall not charge the caregiver of a CCAP eligible child, including foster care, any more than the maximum rate charged to any caregiver who is paying privately for the same child care service. The Department will notify providers via email, newsletter, or webinar, of any proposed rate changes.￿ CCAP providers also have the following tools to review and research payments and understand payment practices: KinderConnect Provider Portal (has available provider reports and actual child attendance activity, and links to provider manuals and guides are available to print and review) Provider Remittance Advice Provider Agreement Louisiana Believes (LDOE website) ￿Publicly-Funded￿ tab LDOE webinars and trainings for providers These tools help providers know which days the Department will pay for, the remittance amount, what has already been paid, and the provider agreement, for example. The Lead Agency also researches all CCAP payment inquiries and provides access to providers to address conflicts and issues through the Provider Help Desk. 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: A provider ￿Notice of Certification￿ and ￿Notice of Termination￿ of services is sent to providers any time a case action is made or changes are made that will affect the amount paid to the provider. Notices are required to be sent at the time the action is taken. e. Describe the Lead Agency’s timely appeal and resolution process for payment inaccuracies and disputes: CCAP analysts, supervisors, and other Lead Agency staff guide payment inquiries directly to the Provider Help Desk or to the Regional Quality Control Program Specialist. Upon receiving notification of a payment issue or complaint, the Child Care Assistance Program specialist addresses the issue with the provider via the Provider Ticket System, phone, email, and/or letter correspondence. If the issue cannot be resolved upon initial contact, an appointment is created for the provider and the designated program specialist to ensure that the issue is properly resolved. Once all information regarding the payment issue is received, the program specialist will review the case by researching the documents and correspondence surrounding the case. Once all research has been completed and a solution has been reached, the provider will be contacted and informed of the payment decision. f. Other. Describe any other payment practices established by the Lead Agency: The Department reviews discrepancies that occurred typically within 30 days of the Department’s receipt of the notice of discrepancy. 4.4.3 Payment practices and parent choice How do the Lead Agency’s payment practices facilitate provider participation in all categories of care? The Lead Agency increased rates in 2022 to a minimum of the 75th percentile from the 2021 Market Rate Survey and additional narrow cost analysis and changed payment practices (first in the pandemic, in 2020, and then in bulletin in 2022) so that the provider receives the maximum allowable rate regardless of the amount charged by the provider, to ensure that payment rates are desirable. Child Care Assistance Program Bonus Payments are also provided to highly-rated providers participating in the quality improvement system, further incentivizing providers’ commitment to serving children in the subsidy program and to quality. The Lead Agency pays based on enrollment, at the state’s maximum rate, to a variety of providers that are available to families, including Type III Early Learning Centers, School Child Care Centers, Family Child Care Providers, In-Home Providers, and Military Child Care Centers.