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: The Lead Agency is updating payment practices to reflect prospective payment during the waiver period provided by ACF to come into compliance with this requirement. 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: The Lead Agency is updating payment practices to reflect enrollment based payment during the waiver period provided by ACF to come into compliance with this requirement. [ ] 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: For Family Child Care Providers the Lead Agency pays registration fees where providers illustrate their policy requires all private-pay families to do the same. For Center Based Providers, the previous Market Rate Survey showed registration fees were not a generally-accepted practice across the majority of center-based providers. We are conducting a new market rate to confirm this is still accurate and will propose new rates accordingly. [ ] 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: CCAP Approved providers execute an agreement with the Lead Agency where they agree to accept the published rates as full payment for providing care to CCAP participating children they enroll in their program. The agreement, signed by both the Provider and the DHS covers payment policies, rates, schedules of payment, enrollment and attendance reporting requirements, dispute resolution guidance and appeal information. 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 a child’s eligibility change has potential impact to provider payment, a system generated notice (through the RI Bridges eligibility system) is mailed as a paper notice to the Provider and loaded to the communication tab in the Provider’s portal informing them of the change in eligibility including time authorization changes, eligibility changes and/or family co-payment amount. This notice is sent 10 days prior to any changes taking effect. e. Describe the Lead Agency’s timely appeal and resolution process for payment inaccuracies and disputes: In situations where agreement is not reached between the Provider and CCAP Program administration on payment disputes or inaccuracies, the Provider submits a written Request for Hearing form to the Lead Agency (DHS) within 30 days of the notice of action being appealed. A discussion of the disputed issue(s) is usually arranged between and the appropriate agency representative in appeals and the program administration to clarify the issue and seek resolution. If the Provider is still unsatisfied, a date is then set for an Appeal Hearing. At the hearing, the appeals officer reviews the facts of the case against program policy. A decision letter is prepared by the hearing officer and a copy sent to the provider. If unsatisfied with the outcome, an individual has the right to appeal the decision of the hearing officer to the RI Superior Court. f. Other. Describe any other payment practices established by the Lead Agency: N/A 4.4.3 Payment practices and parent choice How do the Lead Agency’s payment practices facilitate provider participation in all categories of care? Lead Agency payment practices are the same across all categories of care. Rates are applicable based on the type of provider, the quality rating and the age of the child enrolled. Payment schedules, attendance reporting schedules and enrollment requirements are the same across all categories of care. Families can choose any CCAP approved provider and any licensed provider can apply to become a CCAP approved provider at any time.