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 continuity of care for all children, the Lead Agency sends reminder notices to families in advance of the renewal period. These notices are sent to families at both the 60- and 30-day mark. This allows families ample time to gather necessary information to submit the application to continue their child care assistance, if eligible. These notices are sent to families via the online child care data system (CCDS) portal, as well as email. In addition, to simplify the renewal process for all participants, the online renewal application is prefilled with all previously reported data from the last eligibility period and only requires new information as it relates to income/household size and need for child care. 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: The Lead Agency recognizes job search as a valid need for care. The participant will remain eligible for the entire 12-month period; however, the participant receives an initial 90-day authorization for part time care during this time. ii. [x] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at redetermination. If yes, describe: The Lead Agency recognizes job search as a valid need for care. However, the participant may not use job search as the primary need in two consecutive eligibility periods. If the participant submitted a new need for care during their initial eligibility period, then they can select ￿my job, school, or training has ended, and I am looking for work￿ in their renewal application. This will allow the participant to have a 90-day authorization for full time care during this time. 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? [ ] Yes. The Lead Agency continues assistance. [x] 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: Circumstances for discontinuing assistance due to a parent’s non-temporary change include: (1) gross monthly income exceeding 85% of the SMI for the household size; (2) child care need has ended for more than 90 days without another need; (3) no eligible child remains in the home. ii. If no, describe what specific actions/changes trigger the job-search period after each such loss or cessation: Actions/changes that trigger the job search period after each such loss or cessation include when a parent eligible for Child Care Subsidy reports (or it is discovered) the loss of employment or the discontinuation of an educational program. iii. If no, how long is the job-search period where a family can continue assistance (must be at least 3 months)? The job search period begins at application or on the date of loss of need and continues until the last day of the third full month of services. 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. [ ] 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: 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: Once the participant notifies the Lead Agency of a change in residency outside of the state of Missouri, the Lead Agency will review the change in information. If this is found to be an accurate request, the Lead Agency will close the participant’s benefit case. 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: ￿Intentional Violation￿ means the receipt of any benefit through the wrongful acquisition or issuance of Child Care Subsidy payment for child care services by the Lead Agency through false representation or concealment of material facts by the participant, eligibility unit, child care provider, or any other representatives. These actions may include, but are not limited to: (A) Submission of inaccurate information for the purpose of obtaining compensation for which the child care provider is not legally entitled; (B) Charging the Lead Agency an amount higher than what is charged for private pay participants for the same child care services; (C) Failure to maintain the Child Attendance Record by the eligibility unit as specified by the Lead Agency; (D) Improper billing practices that do not comply with the child care provider’s agreement or that do not comply with state or federal laws and regulations governing child care services; (E) False or misleading statements, oral or written, regarding the participant’s income or other circumstances that affect eligibility or the amount of subsidy received; or (F) Failure to timely report changes in income or other circumstances that affect eligibility or the amount of subsidy received. 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. [ ] 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. [x] 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: $3,332-$4,109 and 50% SMI. ii. Describe how the second eligibility threshold takes into account the typical household budget of a low-income family: The gradual phase out process begins at the Transitional child care level of 151% of the federal poverty level (FPL) and ends at 185% FPL. Transitional Child Care Level 2 begins at the 186% FPL and ends at 215% FPL. The Lead Agency offers a third level of Transitional child care that begins at 216% FPL and ends at 85% SMI or approximately 242% FPL. This allows households who entered the subsidy program at a low-income to gradually earn more income and still be eligible for child care assistance. 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: Transitional child care levels are the gradual phase out process for families experiencing an increase in income. An Eligibility Unit may be allowed a gradual phase out of child care assistance if the family first entered at the Traditional level of at or below 150% FPL, and their income has increased but remains less than the upper income limit (i.e., 85% SMI or approximately 242% FPL) for the third Transitional child care level. This allows households who entered the subsidy program at the first level to gradually earn more income and still be eligible for child care assistance while they are holding a stable job or going to school. iv. Describe how the second eligibility threshold reasonably allows a family to continue accessing child care services without unnecessary disruption: Families are notified 60 and 30 days prior to the expiration date, to ensure adequate time to renew their child care. Income increases under 85% of the SMI for the household size do not adversely affect a family’s eligibility, meaning the family continues to receive the same benefit if determined eligible under the Transitional child care. If an income change will negatively impact the family, then the income change is not acted upon until the next eligibility redetermination period. The range of sliding fees in the first tier of eligibility is from $1.00 a year to $5.00 a day for full time care. The range of sliding fees in the second tier of eligibility is from $7.50 to $10.00 a day for full time care. There are sliding fees for half day and part day that have a similar structure based on the household size and income. v. [x] 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: The Lead Agency has three levels of Transitional child care assistance. Each level has a set sliding fee amount that is based on the household size and income. 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.