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.” Michigan defines special needs as children receiving Social Security Income (SSI). They are eligible for income waived CDC under the definition of FIP- Related that includes a child who needs care may qualify under this eligibility group if the child needing care receives FIP or SSI. e. “Families with very low incomes.” Families with income at or below 100% of FPL. 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] [ ] [ ] [ ] [ ] Describe: Families with very low incomes [ ] [x] [x] [ ] [ ] [ ] Describe: Children experiencing homelessness, as defined by CCDF [ ] [x] [x] [ ] [ ] [x] Describe: Expedited processing and presumptive eligibility. (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: Foster children, children with open CPS, migrant children: income waived eligibility, serve without waitlist, foster children also receive expedited processing and presumptive eligibility. 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: A 45-day presumptive eligibility period can be approved with the following: application, interview, verification of identity (SSA match is sufficient), the applicant’s statement of a qualifying need reason. 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: The Lead Agency worked to develop policy guidance for Child Development and Care (CDC) Immunization Requirements ensuring that all children are age-appropriately immunized. In response to this requirement. Child Development and Care (CDC) program worked across state agencies to align as much as possible with other agencies to ensure parents do not have different rules across different programs. The document provides an overview summary and details relating to how this affects eligibility in Michigan. The elements of this guidance document include details about answers, interview discussion, requirements, exceptions, grace period, penalties, compliance, and examples. The grace period guidance is the time between eligibility determinations when a child who is not in compliance with the immunization requirement remains eligible for CDC. The grace period will typically last for the family’s 12-month continuous eligibility period, but could be less if a child was added to an open case. Immunization compliance for most cases would be confirmed at the 12-month redetermination. If the child is not immunized by the 12-month redetermination, they would no longer be eligible. Once enrolled into a licensed program R.400.8143 (10) (10) A center that enrolls a homeless child pursuant to the section 722 of the McKinney- Vento homeless education assistance improvements act of 2001, as amended by section 9102 of every student succeeds act, 42 USC 11432, shall not be cited for noncompliance when a homeless child is unable to produce health and immunization records. The licensee shall file any documentation of referring a child to the local educational agency liaison for homeless children and youths. Children who are in foster care: At application, applicants are asked if the child is up to date on immunizations. If not, the child must be up to date by the 12-month redetermination or reapplication (if denied for another reason) or have a religious or medical objection that prevents the child from being up to date. 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: The Lead Agency worked across state agencies to develop aligned policy guidance for Child Development and Care (CDC) Immunization Requirements ensuring that all children are age-appropriately immunized. Exceptions for immunizations happen when a child is exempt from the immunization requirement or if one of the following is true: • The child is under two months of age. • Immunizations are medically inappropriate for the child. • Immunizations are contrary to the family’s religious beliefs. The grace period is the time between eligibility determinations when a child who is not in compliance with the immunization requirement remains eligible for CDC. The grace period will typically last for the family’s 12-month continuous eligibility period but could be less if a child was added to an open case. Parents are informed during the application process that noncompliance with the immunization requirement at redetermination, member add process, or at re-application will be denied eligibility. Compliance exists once immunizations have begun. Coordination between the child care scholarship program and child care licensing is within the licensing rules for enrollment and attendance include immunization requirements for attendance. When a child is enrolled in a program the following rules and requirements apply for immunizations. Child Care Centers: R 400.8143 Children’s records. (3) For children under school-age, at the time of a child’s initial attendance, a center shall obtain, keep on file, and make accessible in the center 1 of the following: (a) A certificate of immunization showing a minimum of 1 dose of each immunizing agent specified by the department of health and human services (DHHS). (b) A copy of a waiver addressed to DHHS and signed by the parent stating immunizations are not being administered due to religious, medical, or other reasons. (4) When a child under school-age whose immunizations were not up to date at the time of enrollment has been in attendance for 4 months, an updated certificate showing completion of all additional immunization requirements as specified by DHHS must be kept on file, unless there is a signed statement by a licensed health care provider stating immunizations are in progress. (5) A center shall report to DHHS, by October 1 of each year and using the method established by the DHHS, immunizations for all children enrolled, under section 9211(2) of the public health code, 1978 PA 368, MCL 333.9211(2). (6) Within 30 days of a child’s initial attendance, a center shall obtain, keep on file, and make accessible in the center a record of a physical evaluation of the child that notes any restrictions and is signed by a physician or the physician’s designee. An electronic record from a physician’s office will be accepted. The physical evaluation must be performed within 1 of the following time limits: (a) For an infant, within the preceding 3 months. (b) For toddlers, within the preceding 6 months. (c) For preschoolers, within the preceding 12 months. (7) Physical evaluations must be updated as follows: (a) Yearly for infants and toddlers. (b) Every 2 years for preschoolers. (8) Upon enrollment and annually thereafter, a center shall obtain and keep on file at the center a signed statement from a school-age child’s parent confirming all of the following: (a) The child is in good health with activity restrictions noted. (b) The child’s immunizations are up to date. (c) The immunization record or appropriate waiver is on file with the child’s school. (9) A center shall ensure that, if a parent objects to a physical examination or medical treatment on religious grounds, then the parent provides a signed statement annually that the child is in good health and that the parent assumes responsibility for the child’s state of health while at the center. (10) A center that enrolls a homeless child pursuant to the section 722 of the McKinney-Vento homeless education assistance improvements act of 2001, as amended by section 9102 of every student succeeds act, 42 USC 11432, shall not be cited for noncompliance when a homeless child is unable to produce health and immunization records. The licensee shall file any documentation of referring a child to the local educational agency liaison for homeless children and youths. Family and Group Homes: R 400.1907 Child’s record. (c) Documentation that immunizations and boosters, as recommended by the state department of health and human services, are any of the following: (i) Have been completed. (ii) Are in progress. (iii) Are not being administered due to religious, medical, or other reasons based on a waiver signed by the parent. License Exempt Provider (Unrelated) standard requires ￿a provider is aware of immunization schedule and shares updates with parent￿. When a parent needs assistance with accessing immunizations, they are referred to a health provider or to the local Health Department for more information on immunization offerings, including immunization clinics for families.