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: NH will be requesting a waiver in order to implement prospective payments. Providers are required to bill DHHS weekly and payments are issued two times each week. For invoices submitted by Wednesday, payment is issued by that Friday, and for invoices submitted by Friday, payment is issued by the following Tuesday. Direct deposit is also available to providers. Direct deposit is not required but suggested. 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: NH pays a $50 registration fee per year per child. [ ] 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: As part of the provider enrollment process, a Form 1860 "Provider Agreement" must be reviewed and signed by the provider. This agreement identifies federal and state laws and regulations, rules, policies, and procedures required for participation in the NH Child Care Scholarship Program. The agreement includes a statement that the provider will comply with all billing directives, including securing a non-transferable PIN for submitting invoices through the web billing system and a directive to bill weekly for services provided the previous week. In addition, NH rules are referenced in the Provider Agreement for easy identification and location of the dispute-resolution process, which is located in rule He-C 6918.07, Child Care Provider Billing and Payment Requirements under Appeals. Child care rules and policy, the Child Care Provider Web Billing Training Manual (Form 2531), the Provider Enrollment Handbook (Form 2648), the Provider Billing and Payment Handbook. (Form 2515), Maximum Weekly Standard Rates Employment-Related (Form 2533), Maximum Weekly Standard Rates - Preventive and Protective (Form 2534), and a Web Billing Training Request (Form 2682) are available on the DHHS website. BCDHSC also has a designated Child Care Provider Relations telephone line to answer any billing and/or payment inquiries. 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: When the child care cases are open for eligibility, reviewed or changed a notice of decision is sent out that night to the family and the child care provider. The family will receive the notice in their NH Easy account and the child care provider receives the notice by mail. e. Describe the Lead Agency’s timely appeal and resolution process for payment inaccuracies and disputes: Providers are trained to reach out the provider relations specialist and report any billing errors, inaccuracies, etc. This needs to be done within 60 days in order to utilize the electronic billing system. Otherwise, a paper request and manual bill must be submitted. Internally, BCDHSC notifies providers via the electronic system, email and calls as appropriate in the event of billing inaccuracies. The funds are automatically recouped as the agency identifies issues and providers then can dispute the deduction or other issue. f. Other. Describe any other payment practices established by the Lead Agency: DHHS employs a full-time staff member who works with child care providers, District Office staff, and sometimes the family to resolve payment inaccuracies and disputes. Calls or emails are typically returned the same day, but not later than the next business day. Families may file an appeal in writing within 30 days of a notice of ineligibility to the DHHS Appeals Unit. Families may choose within 15 days of the notice to continue to receive their child care scholarship at the established payment rate. If the decision on the appeal upholds the DHHS proposed action, then the child care scholarship will be denied, decreased, or terminated effective the date indicated on the original notification of the denial, decrease, or termination. If the denial was due to failure to complete the redetermination process, the effective date will be the closure date identified on the notification of redetermination. If the family opted to continue to receive a child care scholarship, any overpayment will need to be repaid. If the decision on the appeal does not uphold the DHHS proposed action, eligibility will be established as provided for in the appeal decision. 4.4.3 Payment practices and parent choice How do the Lead Agency’s payment practices facilitate provider participation in all categories of care? NH pays providers based on the child’s service level and cost share at initial eligibility. The cost share can’t increase above the family cap amount at initial application. The provider is now able to budget the child’s enrollment for their 12 months. The weekly rates are sent and posted for providers to be able to see our weekly rates for the provider type, age of child, and service level.