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. The Lead Agency promotes continuity of care by allowing the parent to determine the child’s need for care and inquiring whether a child has an Individualized Education Plan (IEP) or Individual Family Services Plan (IFSP). The authorized child care hours do not need to follow the parent’s work, training, or educational schedule. A child cannot be authorized for more than 20 hours per day or 50 hours per week without approval from the Lead Agency. The goal is to use a reasonable approach that supports the child’s developmental and learning needs. 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? [ ] Yes. [x] No. If no, describe: Based on the Preliminary Notice of Possible Non-Compliance dated 01/30/2024 from the Office of Child Care, the Lead Agency does not provide a minimum of 12-months eligibility when a child is newly added to the case of a family already participating in the CCDF program; or provide services at least at the same level for a minimum of 12 months when a parent requests case closure or a reduction in benefits, or when a parent is late submitting required re-determination information. The Lead Agency needs additional time to meet the un-met requirements. Currently, when a new child added to a family already participating om the CCDF program, eligibility is only given to the current 12-month eligibility period, which does not allow a minimum of 12 months of eligibility for the new child. Currently, a family can request a case to be closed, which means a family does not receive the same level of services a minimum of 12 months. Currently, if a parent is late when submitting required re-determination information, the family may be given less than 12 months of eligibility because the previous eligibility period is considered and a lapse in eligibility can be given, using the old 12-month eligibility end date. The Lead Agency is receiving technical assistance from federal partners to plan and implement changes to scholarship policy and procedure to meet these non- compliance issues. See Appendix for additional information. 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. [ ] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at initial eligibility determination. If yes, describe: ii. [ ] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at redetermination. If yes, describe: iii. [x] 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: A parent is required to report a change in work, training, or educational status within ten calendar days from the date the change occurs. If the parent has a cessation of work, training, or education, the parent will be given a 90-calendar day grace period. The parent must meet activity requirements at the end of the grace period, and if not, the family's eligibility will be discontinued. Cessation refers to a permanent ending of activity, meaning the parent does not plan to return to the activity. ii. If no, describe what specific actions/changes trigger the job-search period after each such loss or cessation: When a parent reports the required change in work, training, or educational status, it is evaluated to see if it is a cessation or a temporary change. If it is a cessation of work, training, or education, a 90-calendar day grace period is given. iii. If no, how long is the job-search period where a family can continue assistance (must be at least 3 months)? 90-calendar days 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. [x] 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: Five or more consecutive unexplained absences reported by the child care facility when there is no indication that the child will be receiving care at that facility soon. 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: To receive Best Beginnings Child Care Scholarship, the parent and the child must be living together in Montana. If a family moves out of the state, the family is not eligible for the scholarship, and eligibility will be terminated. 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: A parent will be issued an intentional program violation and sanction for any of the following intentional program violations: (1) providing false employment information, including concealing employment; (2) providing false information regarding wages or other income; (3) misrepresenting or failing to disclose household membership; (4) claiming child care assistance for care provided by an ineligible provider; (5) misrepresenting the amount of child care needed or used; or (6) falsifying sign-in/sign- out records. If a parent or guardian receives a second intentional program violation, the department will require the repayment of all child care assistance payments related to the violation and the parent will be terminated from the Best Beginnings Scholarship Program. 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: $4,303, 64.36% of SMI ii. Describe how the second eligibility threshold takes into account the typical household budget of a low-income family: The copayment is a flat eight percent of the family’s income in the second eligibility level. Affordable child care is defined as seven percent of a family’s income. The eight percent copayment is close to affordable child care. 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: The entry level for a family of three into the second eligibility level is above 185% of the Federal Poverty Guideline (FPG), and the exit level is 200% FPG, an income of $3,982 at entry and $4,303 at exit. It allows for an increase in monthly income of $321 and $3,852 annually. iv. Describe how the second eligibility threshold reasonably allows a family to continue accessing child care services without unnecessary disruption: Graduated phase-out families have the same change reporting requirements as all other families utilizing the subsidy program. v. [ ] 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: 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.