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] Describe: Local government agencies typically administer all of their Child Care Assistance Program responsibiliti es, which include determining eligibility, assisting parents with locating child care, monitoring licensed family child care providers and monitoring legal nonlicensed providers. Some local government agencies sub- contract with community- based organizations to determine eligibility; families work with the sub- CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other contracted agency to submit verifications and the sub- contracted agency determines whether the family is eligible. Who assists parents in locating child care (consumer education)? [ ] [ ] [x] [x] [ ] Describe: Who issues payments? [x] [ ] [x] [ ] [x] Describe: The CCDF Lead Agency issues payments; local government agencies or their sub- contracted agency process bills and determine payment amounts. CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who monitors licensed providers? [x] [ ] [x] [ ] [x] Describe: The Minnesota Department of Human Services implements the comprehensi ve background studies required under Chapter 5.7 of this plan, under the authority of Minn. Stat. § 142A.02, subd. 1(c) and chapter 245C. Some local government agencies sub- contract with a community- based organization to initially license, conduct monitoring visits, conduct investigation s, issue licensing CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other actions and background studies of legal nonlicensed providers and licensed family child care providers. Local government agencies identify which organization they sub- contract with and submit a copy of the contract as part of the biannual County and Tribal Child Care Fund Plan review process. CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other Who monitors license-exempt providers? [x] [ ] [x] [ ] [x] Describe: The Minnesota Department of Human Services implements the comprehensi ve background studies required under Chapter 5.7 of this plan, under the authority of Minn. Stat. § 142A.02, subd. 1(c) and chapter 245C. Some local government agencies sub- contract with a community- based organization to initially license, conduct monitoring visits, conduct investigation s, issue licensing CCDF Activity CCDF Lead Agency TANF Agency Local Government Agencies CCR&R Other actions and background studies of legal nonlicensed providers and licensed family child care providers. Local government agencies identify which organization they sub- contract with and submit a copy of the contract as part of the biannual County and Tribal Child Care Fund Plan review process. 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: Tasks are clearly identified within each contractual agreement with an outside agency that performs administration and implementation duties on behalf of the Lead Agency. The department enters into contractual agreements with the Child Care Aware (CCR&R) agencies to provide consumer education services as well as services related to implementing Parent Aware, Minnesota’s Quality Rating and Improvement System. The Parent Aware duties include recruitment of programs, coaching and professional development advising, administration of quality improvement grants, and rating of programs. Within Minnesota, counties and some Tribes are responsible for determining eligibility for child care assistance. If the county or Tribal agency subcontracts some or all of this administrative responsibility, it establishes contractual standards and monitors subcontracts developed with local agencies to administer the child care assistance program. There are 81 agencies representing 87 counties and some of the Tribes that are responsible for the administration of the Child Care Assistance Program (CCAP) in Minnesota. Of those 81 agencies, seven use a subcontractor for all or part of administration of the CCAP. Counties and Tribes are required to complete, submit and receive approval of a biennial Child Care Assistance Program County and Tribal Child Care Plan. This plan, in addition to Minnesota Statute and Rule, includes local policies and procedures used when administering the Minnesota Child Care Assistance Program. [ ] No. If no, describe: b. Schedule for completing tasks. [x] Yes. If yes, describe: Each contractual agreement includes work plans that outline deliverables and timelines. [ ] No. If no, describe: c. Budget which itemizes categorical expenditures in accordance with CCDF requirements. [x] Yes. If yes, describe: Each contractual agreement includes a budget which itemizes eligible expenditures in accordance with CCDF requirements. [ ] No. If no, describe: d. Indicators or measures to assess performance of those agencies. [x] Yes. If yes, describe: Each contractual agreement includes reporting requirements and performance indicators. Contracts are monitored through regular contact with vendors as well as site visits to review program deliverables. Financial reconciliation of budget against expenditures occurs per the Minnesota Office of Grants Management. [ ] 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. The department conducts risk assessments of subrecipients who respond to a Request for Proposal that is allocating CCDF funds prior to establishing a grant contract. In addition, annual grant monitoring reviews and biannual financial reconciliations are conducted per the monitoring policy requirements of the Minnesota Department of Administration Office of Grants Management - Policy on Grant Monitoring (Minn Statute 16B.97 and 16B.98). 1) Monitor all state grants over $50,000 at least once during the grant term and before final payment is made and grants over $250,000 every year, and 2) Reconcile grants over $50,000 at least once during the grant period or before final payment is made. For grantees that have multiple grant contract agreements in place, risk assessments include a sampling method for conducting financial reconciliations. 3) For professional/technical contracts the department ensures deliverables are complete and approved before authorizing payment. The purpose of monitoring visits is to review and ensure progress against the grant’s goals, address any problems or issues before the end of the grant period, and build rapport between the state agency and the grantee. Agency staff cover topics including statutory compliance, challenges faced by the grantee, modifications made to the grant program, program outcomes, grantee policies and procedures, grantee governance, and training and technical assistance needs. The goal of financial reconciliations is to identify potential risk factors by matching a grantee’s request for payment for a given period with supporting documentation for that request, such as purchase orders, receipts, and payroll records. Grant risk factors include, but are not limited to, grantee staff turnover, prior performance, results of pre-award financial review, and delayed or missing performance reports. Child Care Services uses standardized forms and procedures for monitoring visits and financial reconciliations so grant management information is tracked consistently. Agency staff document monitoring and reconciliation plans and outcomes and retains the information on file as part of their written grants policies and procedures. Monitoring and reconciliations involve both state agency staff (and/or contractors) and the grantee, and they occur before final payment is made. Monitoring and reconciliations may be conducted on-site or by telephone, but on-site is preferred. The annual monitoring also entails the collection of records that assist us in assessing risk of that agency. The site visit check list is included along with this description. All the documents collected from grantees and stored by Child Care Services are part of our assessment of risk and ensuring each grantee is meeting state and federal requirements for subrecipients who are grantees. In addition to the annual grant monitoring that is conducted, Child Care Services program staff meet regularly with subrecipients to assess implementation of their respective pass-through grant programs. Through this process, policy, or implementation changes such as timelines, application procedures, spending guidelines and grant eligibility criteria, may be identified. These are compiled by our subrecipients, and thoroughly analyzed for their impact on child care providers and programs. This includes considering the risks of how any changes may impact any data systems used in implementing pass-through grant programs, the impact of accessibility to underrepresented and underserved communities, and the impact on staff capacity to implement the changes. Any agreed-upon changes are included in annual revisions to policy and implementation manuals for the respective programs. These manuals guide the work of subrecipients to ensure that the programs are implemented with fidelity and consistency across the state. The department supports the integrity of county and tribe administration by providing training, technical assistance, policy manuals, statewide administrative systems, case management review guidelines and county and tribe plan review. The department monitors spending of the Basic Sliding Fee annual allocations, case overrides and waiting list data at the local agency level. Follow up occurs when data is inconsistent or shows patterns that indicate technical assistance is required. Minnesota participates once every three years in the federal Improper Payment (IP) error report process and conducts an in-depth review of a sample of individual cases throughout the state. Cases handled by subcontractors are included in the full population used to select the sample for the IP process and, if selected, are subject to the same in-depth review as other cases handled by a county or tribe. Minnesota also reviews a sample of cases from counties and tribes on an ongoing monthly basis, using the standards established in the Federal Error Report Data Collection Instructions to conduct the reviews. Based on the ongoing reviews, performance is measured tied to the error rate at the local agency level. Minnesota provides follow up to the local agency whenever a payment error is determined as part of our performance management plan. Each local agency is audited by the department. The department’s Licensing Division is responsible for monitoring licensed child care centers and certified license-exempt centers, including processing license and certification applications, conducting inspections, investigating complaints, issuing correction orders, and issuing licensing sanctions when appropriate. Counties have delegated authority for monitoring family child care programs, including processing license applications, making licensing recommendations to the department, conducting licensing inspections, investigating complaints, issuing correction orders, and recommending licensing sanctions to the department when appropriate. The department staffs a family child unit that oversees the work delegated to counties. Counties and tribes that administer the Child Care Assistance Program (CCAP) also have delegated authority for monitoring legal non-licensed providers. The department’s Child Care Assistance Program (CCAP) provides oversight and monitoring of this responsibility by requiring policies and procedures related to legal non-licensed provider monitoring be documented in a biennial Child Care Assistance Program County and Tribal Child Care Plan and through reporting requirements. 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: