1.2 CCDF Policy Decision Authority

The Lead Agency has broad authority to administer (i.e., establish rules) and operate (i.e., implement activities) the CCDF program through other governmental, non-governmental, or public or private local agencies as long as the Lead Agency retains overall responsibility for the administration of the program. Administrative and implementation responsibilities undertaken by agencies other than the Lead Agency must be governed by written agreements that specify the mutual roles and responsibilities of the Lead Agency and other agencies in meeting the program requirements. 1.2.1 Entity establishing CCDF program rules Which of the following CCDF program rules and policies are administered (i.e., set or established) at the State or Territory level or local level? Identify whether CCDF program rules and policies are established by the State or Territory (even if operated locally) or whether the CCDF policies or rules are established by local entities, such as counties or workforce boards. Check one of the following: a. [x] All program rules and policies are set or established by the State or Territory. (If checked, skip to question 1.2.2.) b. [ ] Some or all program rules and policies are set or established by local entities or agencies. If checked, indicate which entities establish the following policies. Check all that apply: i. Eligibility rules and policies (e.g., income limits) are set by the: [ ] State or Territory. [ ] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: ii. Sliding-fee scale is set by the: [ ] State or Territory. [ ] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: iii. Payment rates and payment policies are set by the: [ ] State or Territory. [ ] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: iv. Licensing standards and processes are set by the: [ ] State or Territory. [ ] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: v. Standards and monitoring processes for license-exempt providers are set by the: [ ] State or Territory. [ ] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: vi. Quality improvement activities, including QIS, are set by the: [ ] State or Territory. [ ] Local entity (e.g., counties, workforce boards, early learning coalitions). [ ] Other. Identify the entity and describe the policies the entity can set: vii. Other. List and describe any other program rules and policies that are set at a level other than the State or Territory level: 1.2.2 Entities implementing CCDF services The Lead Agency has broad authority to operate (i.e., implement activities) through other agencies, as long as it retains overall responsibility for CCDF. Complete the table below to identify which entity(ies) implements or performs CCDF services. Check the box(es) to indicate which entity(ies) implement or perform CCDF services. CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who conducts eligibility determinations? [x] [x] [ ] [x] [x] Describe: The child protective service agency, Department of Children and Families (DCF), determines eligibility for child care financial assistance for families with an open DCF case through a closed referral process to the Child Care Resource and Referral agency or a contracted early education and care provider. DCF verifies identity, Massachuset ts residency, and citizenship status for the child through the referral process. EEC CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other waives income for DCF families as the closed referral is for the child only and is considered a household of 1 for child care eligibility. Because of this, income for the child is waived as most common income sources for a child such as SSI or child support , or cash assistance are not countable income sources when determining eligibility. The referral acts as an authorization for child care for a period of 12 months. The parent or caregiver must provide CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other proof of identity of the parent/caregi ver listed on the referral to the CCRR or contracted provider to complete the eligibility process. Once identity is verified the child care is authorized for a period of 12 months. Additionally, EEC purchases high-quality early education and out-of- school time care through contracted seats in center-based and family child care (FCC) programs. These organizations perform eligibility for these CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other contracted seats in their Center based programs or family child care homes. For Family child care homes, the family child care system is responsible for determining eligibility. CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who assists parents in locating child care (consumer education)? [x] [x] [ ] [x] [x] Describe: Center-based (CBC) programs and family child care (FCC) systems can help parents find child care with providers in their system or network. Also, EEC contracts with Mass 211, the state's 2-1-1 agency to deliver information and referral services and management of EEC statewide Child Care Financial Assistance waitlist throughout the Commonwea lth with a primary focus on ensuring that all families have access to accurate and CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other meaningful consumer information, education, and referrals that meet their specific needs and assist families with selecting quality child care. Who issues payments? [x] [ ] [ ] [x] [x] Describe: Family child care (FCC) systems contracted through EEC issue payments directly to FCC educators/pr oviders that participate in their system. Who monitors licensed providers? [x] [ ] [ ] [ ] [ ] Describe: Who monitors license-exempt providers? [x] [ ] [ ] [ ] [ ] Describe: Who operates the quality improvement activities? [x] [ ] [ ] [ ] [ ] Describe: 1.2.3 Information systems availability For any activities performed by agencies other than the Lead Agency as reported above in 1.2.1 and 1.2.2, identify the processes the Lead Agency uses to oversee and monitor CCDF administration and implementation activities to retain overall responsibility for the CCDF program. Check and describe how the Lead Agency includes in its written agreements the required elements. Note: The contents of the written agreement may vary based on the role the agency is asked to assume or type of project but must include, at a minimum, the elements below. a. Tasks to be performed. [x] Yes. If yes, describe: As outlined in EEC’s written agreements, EEC and DCF will regularly share child care caseload data with EEC for analysis, caseload management, and coordination. CCRRs and contracted providers, whether a FCC system or center-based (CBC), as part of their contracts with EEC, agree to conduct eligibility determinations following our policies which include documents to submit, how to verify eligibility, and other processes to follow. EEC contracts with CCRRs and Mass 211 describe how they should assist in screening for waitlist eligibility, eligibility for child care financial assistance, helping families in finding child care and referring families to providers as well as the tool that they can use to pull information on child care availability. EEC contracts with CBC providers and FCC systems list that they can complete eligibility determinations for families that enroll in their programs, assist families in finding child care within their program networks or systems, and FCC systems are required to issue payment to their providers for child care services. Also, all contracts with Mass211, CCRRs, and contracted CBC providers and FCC systems outline expectations and tasks around a range of core service requirements for Family Services, Financial Assistance Services, Provider services and Community and State agency coordination that align with CCDF administration and implementation activities from eligibility services, consumer education, equal access, and program integrity. EEC received a preliminary non-compliance for written agreements with DTA in accordance with 45 CFR 98.11(a)(3) on January 11, 2023. The Lead Agency does not have a written agreement for administrative and implementation responsibilities for CCDF undertaken by the Department of Transitional Assistance (DTA). Currently EEC’s written agreement is primarily focused on TANF claiming and does not fully address CCDF responsibilities related directly to the full administration and implementation of CCDF. EEC is actively working through a complete overhaul of the written agreements with DTA and DCF to address all administrative and implementation responsibilities for CCDF. The revisions are being negotiated with DTA and DCF and EEC estimates updated executed new agreements by January 2025 that will address child care financial assistance desk reviews, random samplings of approved child care referrals as identified by EEC, cadence for regularly sharing case load data for analysis, caseload management and TANF and state funds claiming. In addition to all other administrative and implementation responsibilities. Though EEC only received a preliminary non-compliance for its written agreements with DTA, EEC is revising agreements with DTA and DCF collectively to ensure alignment in meeting the responsibilities of CCDF as it relates to the administrative and implementation of CCDF. [ ] No. If no, describe: b. Schedule for completing tasks. [x] Yes. If yes, describe: Caseload data will be shared biweekly for referral and caseload management for DTA and DCF and monthly for TANF claiming and other financial reporting. EEC meets monthly with the child protective service agency, DCF and TANF agency, DTA to address any policy, caseload and coordination issues. CCRRs and contracted providers including FCC systems are required to comply with timelines outlined in policy regarding eligibility determinations, issuing payments, reauthorization of eligibility, attendance, regular submission of KPIs, and monthly billing. EEC meets monthly with contracted CBC Providers and FCC systems and bi- monthly with CCRRs. Additionally, EEC has regional family access specialist assigned regionally to provide contract and program management oversight and technical assistance to CCRRs and all contracted CBC providers and FCC systems. EEC received a preliminary non-compliance on 1/11/23 for written agreements with DTA in accordance with 45 CFR 98.11(a)(3). The Lead Agency does not have a written agreement for administrative and implementation responsibilities for CCDF undertaken by Department of Transitional Assistance (DTA). Currently EEC’s written agreement is primarily focused on TANF claiming and does not address fully CCDF responsibilities related directly to the full administration and implementation of CCDF. EEC is actively working through a complete overhaul of the written agreements with DTA and DCF to address all administrative and implementation responsibilities for CCDF. The revisions are being negotiated with DTA and DCF and EEC estimates updated executed new agreements by January 2025 that will address child care financial assistance desk reviews, random samplings of approved child care referrals as identified by EEC, cadence for regularly sharing case load data for analysis, caseload management and TANF and state funds claiming. Though EEC only received a preliminary non-compliance for DTA, EEC is revising agreements with DTA and DCF collectively to ensure alignment in meeting the responsibilities of CCDF as it relates to the administrative and implementation of CCDF. [ ] No. If no, describe: c. Budget which itemizes categorical expenditures in accordance with CCDF requirements. [x] Yes. If yes, describe: EEC incurs the expenditures for all child care services, even for children who are referred for child care services by DCF and DTA. Children who are authorized for financial assistance are categorized by service need. On a monthly basis, EEC evaluates the expenditures of the previous month to determine the most appropriate funding stream for federal reimbursement or to keep the funding of the expenditures on state funded dollars. The written agreements between EEC, DTA, and DCF outline that any expenditure claimed against CCDF funding streams will not be used for other federal funding streams (prevention of ￿double dipping￿). In addition, expenditures that are identified to be claimed by DCF or DTA directly through their Executive Office of Health and Human Services Federal Revenue Unit for federal reimbursement will not be claimed against CCDF funding streams. Contracted Center-based Care Providers and Family child care (FCC) systems receive a single contract for child care that allows them to fill contracted seats with children of any age regardless of program type. They also receive a Administrative management contract for the required administrative services that will be reimbursed based on a budget and on a monthly basis through a Monthly Expenditure Report (MER). Contracted CBC providers receive an annual obligation based on the seat award amount multiplied by 5% percent and FCC systems receive an annual obligation on the seat award amount multiplied by the service days and the System Admin rate for the respective region. Lastly, CCRRs must submit budgets monthly and budget amendments up to twice per year. [ ] No. If no, describe: d. Indicators or measures to assess performance of those agencies. [x] Yes. If yes, describe: EEC will use caseload data to measure the number of child care referrals issued and the number of child care placements for each agency to assess performance. Our written agreements with contracted providers include indicators that must be submitted monthly and reviewed quarterly for progress. EEC received a preliminary non-compliance on 1/11/23 for written agreements with DTA in accordance with 45 CFR 98.11(a)(3). The Lead Agency does not have a written agreement for administrative and implementation responsibilities for CCDF undertaken by Department of Transitional Assistance (DTA). Currently EEC’s written agreement is primarily focused on TANF claiming and does not address fully CCDF responsibilities related directly to the full administration and implementation of CCDF. EEC is actively working through a complete overhaul of the written agreements with DTA and DCF to address all administrative and implementation responsibilities for CCDF. The revisions are being negotiated with DTA and DCF and EEC estimates updated executed new agreements by January 2025 that will address child care financial assistance desk reviews, key performance indicators, random samplings of approved child care referrals as identified by EEC, cadence for regularly sharing case load data for analysis, caseload management and TANF and state funds claiming. Though EEC only received a preliminary non-compliance for DTA EEC is revising agreements with DTA and DCF collectively to ensure alignment in meeting the responsibilities of CCDF as it relates to the administrative and implementation of CCDF. [ ] No. If no, describe: e. In addition to the written agreements identified above, describe any other monitoring and auditing processes used to oversee CCDF administration. EEC monitoring is conducted using five (5) major components: 1. Identification of CCRRs and Contracted Providers (including CBC and FCC systems) 2. Provider Risk Assessment Analysis Review (PRAAR), 3. Development of the On-Site Monitoring Review Schedule, 4. On-Site Monitoring Review (OSMR) and 5. Corrective Actions. 1. All federally funded CCRRs and contracted providers that are subject to monitoring by EEC are identified. The information is then generated in a report (OSMR Schedule - CCRR, Contract Provider Award Report) that identifies financial data and programs funded for the fiscal year. 2. Annually, a Provider Risk Assessment Analysis Review (PRAAR) is conducted using the CCRR and Contract Provider Award Report - OSMR Schedule for each CCRR and contracted provider funded by EEC. The PRAAR includes a review of the CCRR's or contracted provider’s current internal control systems, financial systems, current and prior IPA & A-133 audits, prior EEC provider reviews, review of federal funds awarded, and the number of contracts awarded to the provider by EEC. 3. An On-Site Monitoring Review Schedule (OSMRS) is prepared each fiscal year by the Audit Unit Supervisor based on the PRAAR. OSMRS are assigned to Fiscal Monitoring Staff based on regions assigned. Assigned regions and providers are rotated at the discretion of the Audit Unit Supervisor. The schedule can be modified for special circumstances as they are brought to the attention of the Audit Unit Supervisor. 4. The OSMRS is performed and conducted by the Financial Management Supervisor (FMS) and/or the Audit Unit Supervisor. 5. A Corrective Action plan and Audit Resolution is put in place for all errors and improper payments and where necessary, recoupment of improper payments will be applied. Additionally, through a collaborative monitoring approach EEC will provide contract and program management and technical assistance regionally to CCRRs and contracted providers. 1.2.4 Certification of shareable information systems. Does the Lead Agency certify that to the extent practicable and appropriate, any code or software for child care information systems or information technology for which a Lead Agency or other agency expends CCDF funds to develop is made available to other public agencies? This includes public agencies in other States for their use in administering child care or related programs. [x] Yes. [ ] No. If no, describe: 1.2.5 Confidential and personally identifiable information Certification of policies to protect confidential and personally identifiable information Does the Lead Agency certify that it has policies in place related to the use and disclosure of confidential and personally identifiable information about children and families receiving CCDF assistance and child care providers receiving CCDF funds? [x] Yes. [ ] No. If no, describe: