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: A completed invoice for services to CCPP are submitted though an electronic ledger. All providers submit their ledger by the 5th or the 15th of each month. Payments are received by the provider no more than 21 days of receipt of the completed claims form or ledger. 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 will pay a mandatory registration fee of $50.00 once per year to the provider which the child is enrolled with at the time of initial approval or at redetermination. [ ] 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 established payment processes which are outlined in the MDHS Child Care Payment Program Policy Manual. The Lead Agency also provides a written statement of agreement to child care providers that defines payment policies and includes a web link to market rates schedule and copay schedule for providers. The agreement includes and outlines the dispute-resolution process. Child care reimbursement rates are set by the Lead Agency using a Market Rate Survey. Rates are set by age group served and a different rate for children that have special needs is also set. Different rates are set based on different geographic areas of the state (e.g., counties identified as either metro or non-metro). Child Care providers are paid in a reimbursement cycle and are required to submit payment ledgers electronically through the MDHS Child Care Payment System (CCPS) once a month. Providers may submit ledgers during one (1) of two (2) payment cycles during the month; however, providers only receive one (1) payment per month for services rendered. Payment ledgers shall open to providers on the first day of the month and remain open until 11:59 p.m. CST on the fifth day of the month. Child care providers who submit ledgers by the fifth day of the month will be issued payment by the 15th day of the month. Child care providers who do not submit their ledger by the fifth day of the month have the option to submit the ledger by 11:59 p.m. CST on the 15th day of the month. Providers who submit their ledgers by the 15th day of the month will be issued payment by the last day of the month. DECCD cannot issue provider payments outside the scheduled payment cycle. Child care providers may be paid via direct deposit or with a paper check. Child care providers are not charged any fees by the Lead Agency as part of the payment process. The dispute-resolution process is as follows: Any unresolved dispute concerning a question of fact under the Application/Agreement between DECCD and Parent or Provider shall be subject to a hearing. The individual must make the request for a hearing in the form of a written and signed request to the attention of the Director of the Division of Early Childhood Care and Development (DECCD). An individual/claimant who requests a hearing as a result of a change in case or case closure has 30 days following the expiration of advance notice to request a hearing. The decision of the Hearing Officer and any supplemental information from the Director of DECCD shall be put in writing. A copy of the decision shall be mailed or furnished to the claimant and shall be final and conclusive, unless, within thirty (30) days from the date of the decision, the claimant mails or delivers to the Executive Director of the Mississippi Department of Human Services a written request for review. Pending final decision of the Executive Director of the Mississippi Department of Human Services or his/her designee, DECCD shall proceed in accordance with the decision of the Hearing Officer. 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: Providers are notified no later than the date that the Lead Agency becomes aware of a family's eligibility status change. The notification gives providers a two-week notice of the pending change. e. Describe the Lead Agency’s timely appeal and resolution process for payment inaccuracies and disputes: The Lead Agency conducts any of the following levels of appeal and resolution process: Agency Appeal Level One (AAL-I): The first level of agency appeal, which occurs up on the claimant's timely written request. The AAL-I is an informal telephonic meeting between the claimant and a supervisor other than the Director of the Division of Early Childhood Care and Development (DECCD) to attempt to resolve the issue(s). If the issue(s) is not resolved after the AAL-I to claimant's satisfaction, the claimant may request an Agency Appeal Level Two. An AAL-I must occur before an AAL-II can take place. Agency Appeal Level Two (AAL-II): A second level of review wherein the claimant, upon timely written request, meets either in person or telephonically with the Director of the Division of Early Childhood Care and Development (DECCD), to attempt to resolve the same issue(s) raised in the AAL-I. If the issue(s) is not resolved to claimant's satisfaction in the AAL-OO, the claimant may request an Administrative Hearing, which is the third and final level of agency review. Administrative Hearing (AH): The third and final level of review within MDHS, which occurs upon the claimant's timely written request. The AH will be held at the MDHS state office or telephonically upon written request and shall be conducted by the MDHS Executive Director or executive designated hearing officer. f. Other. Describe any other payment practices established by the Lead Agency: N/A 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 pays all child care providers through widely accepted payment practices across industries and employment settings. The Lead Agency pays providers through either a paper check or direct deposit and allows for two payment cycles per month to ensure that all providers have an opportunity to submit a claim for payment. The Lead Agency has established rates for each age group (infant, toddler, twos, preschool, school-age) and also sets a different rate for children that have special needs. The Lead Agency has established rates for non- residential, licensed child care and residential, licensed child care (i.e., family child care). The Lead Agency also allows for in-home care (i.e., a provider to care for a child in the child's home if the child has special needs for children up to 19 years of age). Payment practices apply to all types of care.