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: Current payment practices are to pay providers following services to ensure accurate payment to providers. This is appropriate because: 1. Some children attend multiple providers requiring the Lead Agency to verify attendance for both providers to make proper payment to the correct one for each day of care. 2. This ensures there is not an overpayment to a provider when parents transfer providers during the reimbursement period. 3. This allows the Lead Agency to receive a timesheet signed by the parent and provider verifying care was used during the reimbursement period. b. Does the Lead Agency pay based on authorized enrollment for all provider types? [ ] 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. [x] 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: No provider types are paid by authorized enrollment at this time. All provider types are paid based on actual monthly attendance to conserve limited subsidy funds (i.e., providers are currently only reimbursed for days care is actually provided). When children do not attend multiple providers, the provider is paid the daily rate based on monthly attendance records and is not paid the daily rate for days the child did not attend unless the parent uses a "discretionary day." Parents are permitted to use 21 "discretionary days" per calendar year (e.g., sick, vacation, school holiday, etc.). In cases where the child is enrolled with multiple providers, the care is paid based on actual attendance at each provider so as not to exceed the daily state max rate (only one provider may be paid per day). [ ] 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: DWSS/CCDP will pay up to $40 in registration or annual fees 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: Each participating provider is required to sign a Provider Service Agreement (PSA) at registration and to update their Agreement as changes occur. Providers also receive a preservice/orientation training and ongoing technical assistance on billing practices to ensure accurate and timely payment. The PSA outlines the responsibilities of the state, the Child Care Resource & Referral (CCR&R) agencies, and child care providers/facilities in meeting the needs of participating families in accordance with the Child Care Policy Manual. Subsidy reimbursement payments to providers are facilitated by and through the CCR&R agencies. The PSA specifies that payments are subject to funding availability and are based on the approved schedule as indicated on the child care certificate. The PSA notifies providers that all child care subsidy reimbursements processed by the state are subject to audit and that failure to meet the obligations set forth in the agreement may result in withholding of payment, referral to the DWSS Investigations and Recovery (I&R) Unit (including the dispute resolution process), or termination of the provider's enrollment in the subsidy program. Nevada's current PSA includes a "Child Attendance and Provider Reimbursement Timesheet" section and a "Payment (Reimbursement) Practices" section outlining the issuance of child care certificates, payment schedules, and reimbursable/non- reimbursable fees (e.g., Nevada allows subsidy funds to cover certain annual registration fees for enrolled households but not field trips/meals). Providers are not charged any fees to participate in the subsidy program. 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 receive an amended certificate or certificate termination from their respective CCR&R agency via email the same day whenever eligibility changes occur for an enrolled child. Additionally, staff may call the provider that day to inform them of changes that will impact payments. Policy updates are shared with providers via an email listserv and/or through webinars hosted by either/both the lead agency and the CCR&R agencies to help them be aware of upcoming changes and provide an opportunity to ask questions. e. Describe the Lead Agency’s timely appeal and resolution process for payment inaccuracies and disputes: Providers have 60 calendar days from the payment date to request an adjustment if they disagree with the amount of their payment. All payment adjustment requests must be resolved and responded to in writing by DWSS/CCDP within 30 calendar days of the requests. f. Other. Describe any other payment practices established by the Lead Agency: Provider overpayments are validated within 60 calendar days of the date the overpayment is discovered. Collection of the overpayment is accomplished through retention of future provider payments until the debt is retired in whole. For closed providers, a debtor file is submitted to the DWSS Investigation & Recovery (I&R) unit for collection. Provider underpayments are resolved in the next available reimbursement period from the date the underpayment is validated. 4.4.3 Payment practices and parent choice How do the Lead Agency’s payment practices facilitate provider participation in all categories of care? DWSS/CCDP currently sets payment rates comparable to market standards to ensure equitable access for all families to a variety of quality care. DWSS/CCDP work with the CCR&Rs to ensure timely reimbursement to participating child care providers. DWSS/CCDP recently completed a cost model study and will begin using an alternative methodology based on paying a portion of the cost of care to set rates as of October 1, 2024.