equal-access-payment-practices

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: 07/31/2026 Action Step Number Action Step Description Target Completion Date 1 Establish and document business and policy requirements to comply with paying providers based on enrollment and prospectively. A business planning estimate (BPE) must be provided by the technical solutions vendor to ascertain the anticipated time and cost to make the necessary system changes. The Health and Human Services Delivery Center (HHSDC) for IT, in coordination with OCDEL, will complete and obtain executive level approvals before proceeding further. 01/31/2025 2 OCDEL would identify requirements in a series of up to three phases: systems requirements, general systems design, and detailed systems design. When all requirements are documented, reviewed, and approved, the technical solutions vendor will develop and test the system modifications. During this phase, OCDEL will work with the business planning vendor to define system test cases. Finalized test cases are required to proceed with user acceptance testing to be conducted by OCDEL staff and business partners. Go-live validations will conclude the process. Also, during this period, OCDEL’s Bureau of Policy/Professional Development and Bureau of Early Learning Resource Center Operations will develop policy announcements and policy communications to notify providers/ELRCs of the respective changes, develop training materials, and generate other needed documents to facilitate the changes to PELICAN-CCW. The duration of each phase of the systems development lifecycle is dependent upon the extent and complexity of the changes. OCDEL expects these changes will be extensive and will require up to 25 months from start to finish. In addition, the intricacies of the current payment structure and system design around state fiscal year will necessitate the go-live implementation be timed to occur immediately prior to the start of the new state fiscal year. The state fiscal year is July 1 through June 30 with the anticipated go-live 07/31/2026 target for these modifications projected to be in July 2026. DHS/OCDEL may also need to review the subsidized child care regulations to determine the extent to which revisions are required to comply with CCDF Final Rule. If required, regulatory changes occur in two phases. An agency first develops a proposed regulation package and submits to the Office of Attorney General for approval from a form and legality perspective. Once approved, the proposed regulation is published for public comment and review. The Independent Regulatory Review Commission (IRRC) and the standing committees in the State House and Senate may also provide comment. DHS/OCDEL will then review submitted comments and revise the regulation package as necessary. The time required to review and address comments depends on the complexity of the issue and can range anywhere from several weeks up to two years. The second phase begins when the final-form regulation is delivered to the standing committees of the House and Senate and IRRC. The final-form regulation will detail responses to all comments received to the proposed regulation as well as any changes that were made. IRRC will schedule a meeting to either approve or disapprove the regulation based on the information detailed in the final-form regulation package. If approved, and after a final review by the Attorney General for form and legality, the final-form regulation is published with the full force and effect of law. 3 In concurrence with paying providers prospectively, reimbursements based on enrollment will require significant modifications to PELICAN-CCW. OCDEL will need to reexamine areas such as (but not limited to) ELRC payment reconciliation processes, system updates to the provider invoicing functionality, and logic within the system dedicated to attendance tracking by providers. It is imperative that when providers are paid prospectively, the amounts issued by ELRCs are accurate and in accordance with child 07/31/2026 enrollment schedules recorded in PELICAN-CCW. OCDEL requires sufficient time to work with the IT vendor to develop business requirements, design system changes and build schedules, conduct rigorous test cases, and train ELRCs. The required PELICAN-CCW updates will occur in conjunction with the updates for prospective payment under § 98.45(m)(1) and follow the same projected timeline. DHS/OCDEL requires time to adjust PELICAN- CCW and ensure payments for child care services are accurate, timely, and consistent with best practices in the open market.