3.1 Family Co-payments

Lead Agencies must establish and periodically revise a sliding-fee scale for families receiving CCDF services that varies based on income and the size of the family to determine each family’s contribution (i.e., co-payment) and does not create a barrier to receiving CCDF assistance. In addition to income and the size of the family, the Lead Agency may use other factors as appropriate when determining family contributions/co-payments. Lead Agencies may not use price of care or amount of subsidy payment in determining co-payments. 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. 3.1.1 Family co-payment Lead Agencies may not charge any family more than 7% of a family’s gross income, regardless of the number of children participating in CCDF. a. What is the maximum percent of a family’s gross income any family could be charged as a co-payment? The maximum percent is 12.4%. b. Does the Lead Agency certify that their sliding fee scales are always based on income and family size (regardless of how many different scales they may use)? [x] Yes. [ ] No. If no, describe: 3.1.2 Sliding fee scale Provide the CCDF co-payments for eligible families in the table(s) below according to family size for one child in care. a. Is the sliding fee scale set statewide? [x] Yes. [ ] No. If no, describe how the sliding fee scale is set: b. Complete the table below. If the sliding fee scale is not set statewide, complete the table for the most populous locality: -- A B C D E F Family Size Lowest monthly income at initial eligibility where the family is first charged a co-pay (greater than $0). What is the monthly co-payment for a family of this size based on the income level in (A)? What percentage of income is the co- payment in (B)? Highest monthly income at initial eligibility where a family is charged a co-pay before a family is no longer eligible. What is the monthly co- payment for a family of this size based on the income level in (D)? What percentage of income is this co- payment in (E)? 1 4303.00 215.00 5.00 8607.00 1075.00 12.50 2 4303.00 215.00 5.00 8607.00 1075.00 12.50 3 4303.00 215.00 5.00 8607.00 1075.00 12.50 4 5200.00 215.00 4.10 10400.00 1075.00 10.30 5 6097.00 215.00 3.50 12193.00 1075.00 8.80 c. What is the effective date of the sliding-fee scale(s)? April 7, 2024 d. Provide the link(s) to the sliding-fee scale(s): https://outside.vermont.gov/dept/DCF/Shared%20Documents/Benefits/CCFAP-Income- Guidelines-Effective-April-2024.pdf e. Does the Lead Agency allow providers to charge families additional amounts above the required co-payment in instances where the provider’s price exceeds the subsidy payment? [ ] No. [x] Yes. If yes: i. Provide the rationale for the Lead Agency’s policy to allow providers to charge families additional amounts above the required co-payment, including a demonstration of how the policy does not provide a barrier and promotes affordability and access for families: The rationale for this policy is to encourage the broadest array of regulated provider participation in CCFAP so that families eligible for subsidizes have access to the same provider pool as non-subsidized families. It is part of a set of program policies intended to position the state subsidy system as a responsible participant in the child care market on behalf of assisted families. This policy recognizes evidence that indicates that most families in the United States cobble together multiple arrangements to meet their child care needs. The policy enables subsidized families to utilize assistance to negotiate arrangements with child care providers in the marketplace with a level of flexibility that the alternative - requiring all participating providers to accept the state rate as full payment - would not provide. Adopting a policy that does not allow providers to charge any additional amounts above the state rate would reduce the number of providers willing to accept assisted families and reduce access. ii. Provide data (including data on the size and frequency of such amounts) on the extent to which CCDF providers charge additional amounts to families: Vermont's 2023 Child Trends Survey provided data regarding provider tuition rates and establishing if rates are higher than the current maximum state capped reimbursement rate. The survey also provides information regarding providers who may have raised tuition following the reimbursement rate increase. Of the 217 programs who participated in the survey and participate in CCFAP, just over half of center-based programs (53%) reported that their tuition rate is higher than the current maximum state capped reimbursement rate, as did 57% of Family Child Care Programs ("FCCP"). These rates were similar across urbanized and rural programs as well. Additionally, following the change to the reimbursement rate, 49% of center-based programs and 68% of FCCPs did not raise tuition rates for families who do not participate in CCFAP. Using current administrative data from the CDDIS system we were able to determine that the average increase on all instances of a provider charging more than the State capped rate was $59 per week.