2.5 Promoting Continuity of Care

Lead Agencies must consider children’s development and promote continuity of care when authorizing child care services and must establish a minimum 12-month period for each child, both at the initial eligibility determination and redetermination. 2.5.1 Children’s development Describe how the Lead Agency’s eligibility, enrollment, reporting, and redetermination policies promote continuity of care in order to support children’s development. CDD’s specialized services child care policies promote continuity of care in order to support children’s development. The application inquires about whether the child has an IEP or IFSP and explores how services included in a child’s IEP or an Individualized Family Support Plan ("IFSP") can be supported and/or provided onsite and in collaboration with child care services. There is a high level of coordination between eligibility staff and their local CIS team for families who are accessing other child support services. Families with multiple risk factors also receive more intensive case management. 2.5.2 Minimum 12-month eligibility Lead Agencies must establish a minimum 12-month eligibility period for each child, both at the initial eligibility determination and at redetermination to support continuity in child care assistance and reduce barriers to families retaining eligibility. This requirement is: • Regardless of changes in income, Lead Agencies may not terminate CCDF assistance during the minimum 12-month period if a family has an increase in income that exceeds the Lead Agency’s income eligibility threshold but not the federal threshold of 85 percent of SMI; and • Regardless of temporary changes in participation in work, training, or educational activities. a. Does the Lead Agency certify that their policies or procedures provide a minimum 12- month eligibility period for each child at initial eligibility determination? [x] Yes. [ ] No. If no, describe: b. Does the Lead Agency certify that its definition of “temporary change” includes each of the minimum required elements? 1. Any time-limited absence from work for an employed parent due to such reasons as the need to care for a family member or an illness. 2. Any interruption in work for a seasonal worker who is not working between regular industry work seasons. 3. Any student holiday or break for a parent participating in a training or educational program. 4. Any reduction in work, training, or education hours, as long as the parent is still working or attending a training or educational program. 5. Any cessation of work or attendance at a training or educational program not listed above. In these cases only, Lead Agencies may establish a period of 3 months or longer. 6. Any change in age, including a child turning 13 years old during the minimum 12-month eligibility period. 7. Any changes in residency within the State or Territory. [x] Yes. [ ] No. If no, describe: c. Are the policies different for redetermination? [x] No. [ ] Yes. If yes, provide the additional/varying policies for redetermination: 2.5.3 Job search and continued assistance a. Does the Lead Agency consider seeking employment (engaging in a job search) as an eligible activity at initial eligibility determination and/or at the minimum 12-month eligibility redetermination? (Note: If yes, Lead Agencies must provide a minimum of 3 months of job search.) Check all that apply: i. [x] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at initial eligibility determination. If yes, describe: Seeking Employment may be authorized for up to twelve (12) weeks, or three (3) months, for an income eligible parent/caretaker. At initial application, a client applying under Seeking Employment will be required to have a service need at the end of three (3) months or the case will be closed. If the client reports at any time during the three (3) months that they have obtained a new service need of employment, education, training, or special health need, the file is redetermined to place the family under the appropriate service need. The family continues with the remainder of the 12 month eligibility period. The eligibility percentage remains the same for the remainder of the 12 month eligibility period unless the family reports income that will reduce the family share. At initial application, eligibility will be denied if both primary caretakers are requesting the service need of Seeking Employment. However, if twelve (12) month eligibility is in place and both parents lose their jobs simultaneously, seeking employment may be authorized for both. ii. [x] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at redetermination. If yes, describe: If a client requests to use the service need of Seeking Employment more than once during their twelve (12) month eligibility period or at redetermination, the request will be granted. If a parent/caretaker loses their job at the end of their twelve (12) month eligibility and is unable to use all three (3) months of seeking employment, the remainder of their seeking employment eligibility period will carryover once their redetermination application is received to allow for the full three months of seeking employment to be exhausted. iii. [ ] No. The Lead Agency does not consider seeking employment (engaging in a job search) as an eligible activity at initial eligibility determination or redetermination. b. Does the Lead Agency continue assistance during the minimum 12-month eligibility period when a parent has a non-temporary loss or cessation of eligible activity? [ ] Yes. The Lead Agency continues assistance. [x] No, the Lead Agency discontinues assistance. i. If no, describe the Lead Agency’s policies for discontinuing assistance due to a parent’s non-temporary change: A parent that permanently loses their job during their twelve (12) month eligibility period may utilize the service need of Seeking Employment for a period of three (3) months. Eligibility will be redetermined, the service need will be changed to Seeking Employment, and the income from the job will be removed. If the parent reports at any time during the three (3) months that they have obtained a new service need of employment, education, training, or special health need, the file is redetermined to place the client under the appropriate service need. The eligibility percentage remains the same unless the family reports income that would reduce the family share. ii. If no, describe what specific actions/changes trigger the job-search period after each such loss or cessation: If a parent reports they had a non-temporary loss or cessation of an eligible activity within ten (10) days of the change occurring, the Eligibility Specialist sends the parent a Seeking Employment form to complete and return within ten (10) days. When the form is returned, the Eligibility Specialist processes the change in the information system to reflect the change in income and service need. iii. If no, how long is the job-search period where a family can continue assistance (must be at least 3 months)? A family can access three (3) months of Seeking Employment if they have a non-temporary loss or cessation of eligible activity. c. The Lead Agency may discontinue assistance prior to the next minimum 12-month redetermination in the limited circumstances listed below. Check and provide the policy for all circumstances in which the Lead Agency chooses to discontinue assistance prior to the next minimum 12-month redetermination: i. [ ] Not applicable. ii. [ ] Excessive unexplained absences despite multiple attempts by the Lead Agency or designated entity to contact the family and provider, including the prior notification of a possible discontinuation of assistance. Provide the Lead Agency’s policy defining the number of unexplained absences identified as excessive: iii. [x] A change in residency outside of the State or Territory. Provide the Lead Agency’s policy for a change in residency outside the State or Territory: The Lead Agency's policy for a change in residency outside the State includes verification of when the child stopped attending and if notice was given to the provider to determine the effective date of the assistance ending. If a family is no longer eligible due to moving out of state, the Eligibility Specialist will verify with the primary caretaker if notice was given to the provider. a. If notice was given, all certificates will end the Saturday at the end of the week of last attendance. b. If two weeks’ notice was not given, the Eligibility Specialist will request two weeks’ of no notice payment if no notice was given or one week of no notice payment if one week of notice was given. The Eligibility Specialist will end certificates the Saturday at the end of week of the applicable no notice payment period. In any scenario, assistance is discontinued when a family moves out of Vermont. iv. [x] Substantiated fraud or intentional program violations that invalidate prior determinations of eligibility. Provide the Lead Agency’s definition of fraud/intentional program violations that lead to discontinued assistance: CCFAP regulations allow for CDD to withhold future payments, in whole or in part, until an overpayment or payment received by a family in violation of regulations or law has been satisfied. The eligibility case may be closed in the middle of the authorization period if there was substantiated fraud. 2.5.4 Reporting changes during the minimum 12-month eligibility period Lead Agencies may only require families to report changes that impact a family’s eligibility, including only if the family’s income exceeds 85 percent of the SMI, taking into account irregular fluctuations in income, or there is a non-temporary change in the parent’s work, training, or education status, during the 12-month eligibility period. Lead Agencies may also require families to report that enable the lead agency to contact the family or pay providers, such as a new telephone number or address. Note: The response below should exclude reporting requirements for a graduated phase-out, which are described in question 2.5.5. Does the Lead Agency limit what families must report during the 12-month eligibility period to the changes described above? [x] Yes. [ ] No. If no, describe: 2.5.5 Policies and procedures for graduated phase-out of assistance at redetermination Lead Agencies that establish initial family income eligibility below 85 percent of SMI must provide a graduated phase-out of assistance for families whose income has increased above the Lead Agency’s initial income threshold at the time of redetermination but remains below the federal threshold of 85 percent of SMI. Lead Agencies that provide a graduated phase-out must implement a two-tiered eligibility threshold, with the second tier of eligibility (used at the time of eligibility redetermination) to be set at: (i) 85 percent of SMI for a family of the same size; or, (ii) An amount lower than 85 percent of SMI for a family of the same size but above the Lead Agency’s initial eligibility threshold that: (A) Takes into account the typical household budget of a family with a low income (B) Provides justification that the second eligibility threshold is: (1) Sufficient to accommodate increases in family income over time that are typical for workers with low incomes and that promote and support family economic stability (2) Reasonably allows a family to continue accessing child care services without unnecessary disruption At redetermination, a child must be considered eligible if their parents are participating in an eligible activity even if their income exceeds the Lead Agency’s initial eligibility income limit as long as their income does not exceed the second tier of eligibility. Note that once determined eligible, the child must be considered eligible for a full minimum 12-month eligibility period, even if the parents’ income exceeds the second tier of eligibility during the eligibility period, as long as it does not exceed 85 percent of SMI. A child eligible for services via the graduated phase-out of assistance is considered eligible under the same conditions as other eligible children with the exception of the co-payment restrictions, which do not apply to a graduated phase-out. To help families transition from child care assistance, Lead Agencies may gradually adjust co-payment amounts in proportion to a family’s income growth for families whose children are determined eligible under a graduated phase-out. Lead Agencies may require additional reporting on changes in family income but must still ensure that any additional reporting requirements do not constitute an undue burden on families. Check and describe the option that best identifies the Lead Agency’s policies and procedures regarding the graduated phase-out of assistance. a. [x] Not applicable. The Lead Agency sets its initial eligibility threshold at 85 percent of SMI and therefore is not required to provide a graduated phase-out period. (If checked, skip to question 3.1.1.) b. [ ] The Lead Agency sets the second tier of eligibility at 85 percent of SMI. If checked, describe the policies and procedures: i. [ ] Lead Agency adjusts the family’s co-pay during the graduated phase-out period. If checked, describe how the Lead Agency gradually adjusts co-payment for families under a graduated phase-out period in proportion to a family’s income growth. Include information on the percentage or amount of change made in the co-payment during graduated phase-out: ii. [ ] Lead Agency requires additional reporting requirements during the graduated phase-out period. If checked, describe: c. [ ] The Lead Agency sets the second tier of eligibility at an amount lower than 85 percent of SMI for a family of the same size but above the Lead Agency’s initial eligibility threshold. If checked, provide the following information: i. Provide the income level ($/month) and the percent of SMI for the second tier of eligibility for a family of three: ii. Describe how the second eligibility threshold takes into account the typical household budget of a low-income family: iii. Describe how the second eligibility threshold is sufficient to accommodate increases in family income over time that are typical for low-income workers and that promote and support family economic stability: iv. Describe how the second eligibility threshold reasonably allows a family to continue accessing child care services without unnecessary disruption: v. [ ] Lead Agency adjusts the family’s co-pay during the graduated phase-out period. If checked, describe how the Lead Agency gradually adjusts co-payment for families under a graduated phase-out period in proportion to a family’s income growth. Include information on the percentage or amount of change made in the co-payment during graduated phase-out: vi. [ ] Lead Agency requires additional reporting requirements during the graduated phase-out period. If checked, describe: 3 Child Care Affordability CCDF subsidies make child care more affordable for eligible families, providing access to a greater range of child care options that allow parents to work, go to school, or enroll in training and they allow parents to access higher quality care options that better support children’s development. CCDF requires some families participating in CCDF to pay an affordable co-payment set by the Lead Agency to cover a part of their care. But co-payments can be a significant and destabilizing financial strain on family budgets and a barrier to parent employment, and the CCDBG Act requires that the co-payment amount not be a barrier to families participating in CCDF. Lead Agencies may not set parent co-payments above 7% of family income regardless of gradual phase- out policies and regardless of the number of children receiving assistance. Lead Agencies are encouraged to set co-payments much lower than 7% to make child care more affordable for more families and have broad flexibility to waive co-payments for to many participants. Lead Agencies must ensure that the total payment to a child care provider is not reduced because of family’s lowered or waived co-payment. In this section, Lead Agencies will identify how they determine an eligible family’s co-payment, the policies in place to waive or ensure co-payments are affordable for families, and how the Lead Agency improves access for children and families in economically and/or socially marginalized communities.