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Reason(s) for non-compliance: • The Lead Agency does not pay all provider types prospectively or alternatively does not demonstrate that it is not a generally-accepted practice for all provider types, as required by 98.45(m)(1). (Plan Question 4.4.1a). Please note the Lead Agency has an approved waiver for this requirement through August 1, 2026. • The Lead Agency does not pay based on enrollment or alternatively does not provide justification that this is impracticable or is not a generally-accepted practice, as required by 98.45(m)(2). (Plan Question 4.4.1b). Please note the Lead Agency has an approved waiver for this requirement through August 1, 2026. Overall Target Completion Date: 08/01/2026 Action Step Number Action Step Description Target Completion Date 1 Prospective Payment: OCFS to collaborate with local departments of social services commissioners, and other relevant stakeholders in order to discuss the potential impacts of this provision. OCFS to collaborate with NYC to identify and address any barriers to this provision specific to NYC. NYC may need to make changes to the City Charter to accommodate paying prospectively. This change will need to take place over multiple budget cycles, which requires legislative and executive approvals. 03/31/2025 2 Prospective Payment: OCFS to draft, approve and propose changes to statute to require that child care providers are paid prospectively. Statutory changes must be passed by the NYS Legislature and signed by the Governor. OCFS to draft, approve and file regulatory amendments to require prospective payments. OCFS to draft, approve and issue policy updates related to prospective payments. 04/30/2026 3 Prospective Payment: OCFS to ensure that there is adequate funding to address the shift of costs to LDSSs. 01/30/2026 4 Prospective Payment: OCFS to update computer systems to process payments prospectively. OCFS to update and develop training materials related to prospective payments. 07/31/2026 5 Prospective Payment: OCFS to pay all provider types prospectively or alternatively demonstrate that it is not a generally-accepted practice for all provider types, as required by 98.45(m)(1). 07/30/2026 6 Payments Based on Enrollment: OCFS to collaborate with local departments of social 03/31/2025 services commissioners, and other relevant stakeholders in order to discuss the potential impacts of this provision. 7 Payments Based on Enrollment: OCFS to draft, approve and propose changes to statute to allow the CCAP to pay providers based on enrollment. Statutory changes must be passed by the NYS Legislature and signed by the Governor. 06/30/2025 8 Payments Based on Enrollment: OCFS to draft, approve and file regulatory amendments to require payments based on enrollment. OCFS to draft, approve and issue policy updates related to requiring payments based on enrollment. 04/30/2026 9 Payments Based on Enrollment: OCFS to update computer systems to process payments based on enrollment. OCFS to update and develop training materials related to payments based on enrollment. 08/31/2026 10 Payments Based on Enrollment: OCFS to pay based on enrollment or alternatively provide justification that this is impracticable or is not a generally-accepted practice, as required by 98.45(m)(2). 08/31/2026