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.” Children with Special needs are defined as: A child with a disability, as defined in section602 of the Individuals with Disabilities Education Act (20 U.S.C. 1401); A child who is eligible for early intervention services under part C of the Individuals with Disabilities Education Act (20 U.S.C. 1431 et seq.); Child who is less than 13 years of age and who is eligible for services under section 504 of the Rehabilitation Act of 1973 (29 U.S.C 794); and A child with a disability, as defined by the State. e. “Families with very low incomes.” Families with very low incomes are defined below and may qualify for subsidy assistance in the order presented: Guaranteed subsidy eligible if receiving TANF and Gross income is tested against a Gross Income Standard which is 185% of the Consolidated Need Standard for the appropriate Assistance Unit size, as listed on the Family Assistance Standards Desk Guide. Families transitioning from TANF benefits may be eligible for an eighteen (18) month Transitional Child Care eligibility period and who meet the work requirement and have income that does not exceed 60% of the State Median Income (SMI) guidelines. (Tenn. Code Ann. § 71-3-104). Child-only guardians who have care and control of a relative child receiving TANF benefits may qualify for child care payment assistance and who meet the work requirement as defined by the state and income that does not exceed 60% of the SMI guidelines. (Tenn. Comp. R. & Regs. 1240-01- 54-.01). Teen parents who are enrolled in and attending middle or high school and have income for mandatory household members that does not exceed 85% of the SMI guidelines. (Tenn. Comp. R. & Regs. 1240-01-54-.01). Smart Steps Child Care Payment Assistance provides child care support to working families and those pursuing post- secondary education goals and income does not exceed 85% of the SMI guidelines. The Lead Agency waives co-pays for families that fall below 150% of the Federal Poverty Level (FPL). 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: 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] [ ] [ ] Describe: Children experiencing homelessness, as defined by CCDF [x] [ ] [ ] [x] [ ] [ ] Describe: (Optional) Families receiving TANF, those attempting to transition off TANF, and those at risk of becoming dependent on TANF [x] [ ] [x] [x] [ ] [ ] Describe: 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: The following groups are given consideration by the Lead Agency in priority order: Children in Foster Care, Homeless Children, Children with Diagnosed Disability, and Military Status of the Adult Parent, currently active due, i.e., serving full-time, in the U.S. Military or a member of either a National Guard or Military Reserve unit. 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: Families who meet homelessness criteria may be given an additional 60 calendar days, if needed, to provide any missing verifications for eligibility to the Lead Agency. 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: Families may receive care for up to 60 days without documentation of immunization requirements as defined at Tenn. Comp. R. & Regs. 1240-04-01. Children who are in foster care: Families may receive care for up to 60 days without documentation of immunization requirements as defined at Tenn. Comp. R. & Regs. 1240-04-01. 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 Lead Agency is the licensing authority. Exceptions are defined in licensure rules at Tenn. Comp. R. & Regs. 1240-04-01. The Lead Agency contracts with TDH and six (6) regional public health departments with responsibility for immunizations to conduct immunization record audits for child care providers licensed or subject to licensure by the Lead Agency as defined at Tenn. Comp. R. & Regs. 1240-04-01 consistent with statutory and/or regulatory requirements and recommendations by the Centers for Disease Control and Prevention and applicable Tennessee laws.