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.” A child under age 18 at the beginning of the certification period who requires a level of care above the norm for their age, due to disabilities, emotional or behavioral disorders, behavioral needs, or health needs. Child care services are prioritized with higher reimbursement rates, called the Special Needs Rate. Children may also qualify for additional payments on top of the Special Needs Rate based on individualized assessment in their child care setting through the Inclusive Partners Program, called the High Needs Rate. e. “Families with very low incomes.” Children in families with incomes under 200% of the Federal Poverty Level who are receiving or transitioning off TANF cash benefits are considered families with very low income. 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] Describe: A child under age 18 at the beginning of the certification period who requires a level of care above the norm for their age, due to disabilities, emotional or behavioral disorders, behavioral needs, or health needs. 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] [x] [x] [ ] [ ] [x] Describe: Copayments are waived for families with one individual receiving TANF benefits, families with income under 100% FPL, families with at least one caretaker who has lost employment (either temporarily or permanently), or with one caretaker on medical leave from employment. Families receiving services through the TANF program may bypass the ERDC waitlist when it is in effect. 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] Describe: An individual who is experiencing a lack of a fixed, regular, and adequate nighttime residence. This includes, but is not limited to, individuals who are living in an emergency or transitionary shelter, sharing housing with others due to loss of housing or economic hardship, or staying in a motel, campground, hotel, car, park, public place, tent, trailer, or other similar settings. 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] [x] [x] [ ] [ ] [x] Describe: Families receiving TANF are exempt from the ERDC waitlist, their copay is waived, they are also exempt from the employment or education participation requirements. Families receiving services through the TANF program may bypass the ERDC waitlist when it is in effect. 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: New applicants will be placed on the Child Care Waitlist for ERDC unless any member of the ERDC filing group meets at least one exemption listed in the following paragraphs: Received a partial or full month of cash benefits from the Refugee (REF), State and Family Pre-SSI (SFPSS), or Temporary Assistance to Needy Families (TANF) programs in the state of Oregon in at least one of the preceding three months; Determined eligible for, and being placed in, a current opening in a Head Start program contracted slot, an Early Head Start Child Care Partnership contracted slot, or a Baby Promise program contracted slot; The caretaker is currently working with Child Welfare as part of a Child Protective Services (CPS) assessment or open case and Child Welfare has determined the use of child care will prevent removal of the child from their home, allow a child to be returned home, or allow for placement of the child with a relative or with an adult whom the child or the family of the child has an established relationship; Determined eligible for Temporary Assistance to Domestic Violence Survivors (TA- DVS) program benefits from the state of Oregon in the current month or at least one of the preceding three months; Was part of an ERDC filing group with a break in ERDC benefits of no more than two consecutive calendar months. Families enrolled in Oregon Prenatal to Kindergarten and Head Start programs with contracted slots are able to access extended hours of care. The Teen Parent program contracted slots are used to prioritize access for high school students with young children. Young parents (age 20 or younger) are allowed qualify for ERDC when participating in any High School or GED completion program without needing to attend an institution eligible to receive federal financial aid. Baby Promise contracted slots are used to prioritize care for infants and toddlers. Baby Promise enrollment processes prioritize historically underserved or underrepresented populations defined as: African American, Asian and Pacific Islander, emergent bilingual children, geographically isolated, immigrants and refugees, migrant families and/or families working in agricultural sector, Latinx, Tribal nations and communities, children with developmental delays and disabilities, children of incarcerated parents/parental figures, and/or children experiencing homelessness and engagement with the foster care system. 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: Oregon has implemented enrollment during a grace period through ￿priority processing.’ This is also treated as presumptive eligibility. This means families experiencing homelessness can receive up to three months of benefits based upon their statement while waiting for formal verification. These families are not required to complete an interview with an eligibility worker, speeding up the eligibility process. If eventual verification does not meet subsidy requirements, these months are not collected as overpayments, but benefits do not extend for a full twelve months. Child care assistance is opened immediately for children in families experiencing homelessness who have not yet documented immunization. After the case is open, the family is given 45 days to supply any needed verification. This results in a case being open for 2 to 3 months depending on the date benefits are requested. The time period can be extended. Families who mark "no" to immunization are given up to 3 months to comply with immunization requirements or supply verification of a medical or non-medical exemption. In order to comply with immunization requirements, families just need to show they are moving forward in the process. This could mean applying for medical insurance, scheduling an appointment, or taking the courses required for the non-medical exemption form. The Lead Agency worked in consultation with the Oregon Health Authority to establish the immunization grace period. 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: Per Oregon Administrative Rule 414- 175-0005, '(8) A filing group that is experiencing homelessness or requires child care for a current foster child may receive ￿priority processing.￿ For purposes of this rule, ￿priority processing￿ means the benefits may be open for up to three months while pending for verification of income, work schedule, verification of immunization records, or a copy of the medical or non-medical exemption form during the application period.' Children who are in foster care: Per Oregon Administrative Rule 414-175- 0005, '(8) A filing group that is experiencing homelessness or requires child care for a current foster child may receive ￿priority processing.￿ For purposes of this rule, ￿priority processing￿ means the benefits may be open for up to three months while pending for verification of income, work schedule, verification of immunization records, or a copy of the medical or non-medical exemption form during the application period.' 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? [x] Yes. [ ] No. If no, describe: 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: The period for immunization is based upon the Oregon Health Authority’s (OHA) administrative rules. ODHS provides information for the local public health departments to develop a plan. ODHS workers provide information and assistance applying for medical program benefits, if needed. The Lead Agency works closely with the Oregon Health Authority (OHA) to support licensed child care compliance with immunization laws. OHA contacts the Lead Agency if a child care program has not submitted required immunization verifications. The Lead Agency will contact the licensed child care and provide technical assistance and a referral to OHA for additional support. If compliance is still not achieved, OHA will mail a formal letter to the child care program and provide a copy to the Lead Agency. The Lead Agency will then follow up again to support compliance. At the point of the program receiving a letter from OHA, The Lead Agency will cite the program for being out of compliance with licensing immunization rules. This is a very rare occurrence as the prior attempts at support are typically successful.