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.” For subsidized child care purposes, the state defines a child with special needs as one who qualifies under one or more of the criteria listed in this Paragraph: (1) a child who is determined by the Division of Public Health, Children's Developmental Service Agency, to be developmentally delayed or have an established condition pursuant to 10A NCAC 43G.0110; including subsequent amendments; or (2) a child who is determined by the local educational agency (LEA) to have a disability as defined in G.S. 115C-106.3. The agency determining eligibility for the services shall have on file an Individualized Education Program (IEP) as defined in G.S. 115C-106.3, an Individualized Family Service Plan (IFSP) as defined in 10A NCAC 27G .0903, a Section 504 Plan as defined in 29 USC794 or a Person-Centered Plan (PCP) as defined in 10A NCAC 70G .0402 to document the "special need" or "disability". https://schs.dph.ncdhhs.gov/data/champ/cshcn.htm DSS/LPAs will use the 4% set aside to serve vulnerable populations which includes children identified as having special needs. Counties must establish a separate waiting list for children identified as having special needs. Payment for these services is made with the vulnerable population set-aside. In addition, a local purchasing agency may supplement the provider's approved rate for additional costs incurred for a child with special needs who is enrolled in an inclusive setting. The supplement is paid from the set aside for vulnerable populations. The NC Early Intervention Branch of the Division of Child & Family Well-Being’s Infant- Toddler Program (IDEA Part C) provides early intervention services for children with special needs based on evidence of developmental delays or established conditions. A developmental delay is defined as a significant difference (at least 30% in one area or 25% in two areas) between the skills a child actually shows at the time of assessment and skill levels generally shown by other children the same age. A child is considered to have an established condition if the child has a diagnosed physical or mental condition which has a high probability of resulting in developmental delay. The Department of Public Instruction’s Exceptional Children’s Program provides IDEA Part B services through their Preschool Program. Services are provided for children 3, 4 and PreK 5-year-olds identified need determined by the Individual Education Program (IEP) Team resulting from parental report, observation and evaluation results conducted by qualified professional in accordance with the North Carolina Policies Governing Services for Children with Disabilities. The identified delay or disability must have been determined to have an adverse effect on educational performance in the general curriculum and require specialized instruction so that the child may progress in the regular early childhood program. Citation: "Who qualifies for early intervention services?: Special Needs Criteria". Division of Child Development and Early Education. (March 2024). Accessed June 19, 2024. https://ncchildcare.ncdhhs.gov/Parent/Special-Needs/Special-Needs-Criteria e. “Families with very low incomes.” Families whose income is less than the State's income eligibility (200% FPL for children ages 0-5 and 133% FPL for children ages 6 and older) are considered families with very low incomes. Local purchasing agencies may establish priorities for serving children from the waiting list. In addition, fees are not assessed to families whose only source of income is "not countable"(as defined in child care subsidy policy); and fees are not charged for children with no income who live with someone other than a biological or adoptive parent, or with someone who does not have court-ordered financial responsibility. 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] [x] [ ] [ ] [ ] [x] Describe: Lead Agency is legislatively mandated to set aside four percent (4%) of child care subsidy allocations for vulnerable populations, which includes a child identified as having special needs. A child identified by this subdivision shall be given priority for receiving services until such time as set-aside allocations for vulnerable populations are exhausted. After the set aside funds are exhausted, children identified by this subdivision may be placed on the county’s waiting list until funding is available. 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 Families with very low incomes [ ] [ ] [ ] [ ] [ ] [x] Describe: North Carolina's definition of families with very low incomes is 'Families whose income is less than the State's income eligibility (200% FPL for children ages 0-5 and 133% FPL for children ages 6 and older). These are the program's initial income limits, so we consider all families who are income eligible to be 'families with very low incomes'. Because of this we don't prioritize another income limit as very low. The idea has been that all families who are below the initial income limits meet the program's definition of very low income and the program does not classify families separately as long as their income is below the initial 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 eligibility threshold. 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 experiencing homelessness, as defined by CCDF [x] [x] [ ] [ ] [ ] [x] Describe: Lead Agency is legislatively mandated to set aside four percent (4%) of child care subsidy allocations for vulnerable populations, which includes a child whose application for assistance indicates that the child and the child’s family is experiencing homelessness or is in a temporary living situation. A child identified by this subdivision shall be given priority for receiving services until such time as set-aside allocations for vulnerable populations are exhausted. After the set aside funds are exhausted, children identified by this subdivision may be placed on the county’s waiting list until funding is available. 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 (Optional) Families receiving TANF, those attempting to transition off TANF, and those at risk of becoming dependent on TANF [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: Prioritization of additional populations is determined at the local county level and approved by the Lead Agency. Some examples of additional populations that are prioritized are foster care, teen parents, and Work First recipients. 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: Families experiencing homelessness are made eligible at the time of application based on information reported by the recipient. If the recipient does not have all required documentation on the day of application, the recipient's reported need for care and reported income are used to complete an application. If the reported information meets all eligibility criteria, the application is approved, and child care services can begin immediately. The recipient then has 30 days to provide all needed documentation to support their eligibility for child care services. If it is determined that the recipient is not eligible for child care services once all required documentation has been submitted, the child care case is terminated with a 10- day notice provided to the recipient and the child care provider. If this occurs, the child care provider shall be paid for services provided based on the start date on the voucher through the last day of the 10-day notice. Any payment made to the child care provider prior to the final eligibility decision shall not be considered in error or an improper payment and shall not be recouped from the provider. 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: All families have 30 days to submit immunization records and a medical report. Children who are in foster care: All families have 30 days to submit immunization records and a medical report. 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? [ ] Yes. [x] No. If no, describe: The length of the grace period for reporting the results of the child health assessment was established by the NC Legislature and is included in child care law. GS 110-91(1) states, ￿The Commission shall adopt rules for child care facilities to establish minimum requirements for child and staff health assessments and medical care procedures. These rules should be developed in consultation with the Department. Each child shall have a health assessment before being admitted or within 30 days following admission to a child care facility.￿ It is assumed the legislative committee which developed this law consulted with public health and DCDEE; as this is general practice. DCDEE does not have documentation of this consultation, so did not certify. The immunization law (GS 130A155); however, allowing 30 days to submit the required documentation of immunizations upon child care enrollment is in Public Health law; therefore, DCDEE can certify that the state public health agency was directly involved and consulted with in the development of the immunization reporting requirement. 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: NC DCDEE encourages child care programs to help families meet the immunization and health requirements by including immunizations and health records on the annual monitoring visits. NC DCDEE supports Child Care Health Consultants who provide training, technical assistance and referral to support child care facilities in meeting health and safety requirements and best practices by funding a contract with the NC Child Care Health and Safety Resource Center (RC). The RC provides health and safety training courses for all qualified Child Care Health Consultants and directly funds some of these positions. Child Care Health Consultants provide referrals and support to help families with children receiving services during a grace period comply with immunization and other health and safety requirements. Child Care Resource and Referral, Family Referral Specialists, also make referrals on behalf of families through the NC CARE 360 system. https://nccare360.org/about/