4.3 Adequate Payment Rates

The Lead Agency must set CCDF subsidy payment rates in accordance with the results of the current MRS or ACF pre-approved alternative methodology and at a level to ensure equal access for eligible families to child care services comparable with those provided to families not receiving CCDF assistance. Lead Agencies are also required to provide a summary of data and facts to demonstrate how payment rates ensure equal access, which means the Lead Agency must also consider the costs of base level care and higher quality care as part of its rate setting. Finally, the Lead Agency must re-evaluate its payment rates at least every 3 years. The ages and types of care listed in the base payment rate tables are meant to provide a snapshot of the categories of rates and are not intended to be comprehensive of all categories that might exist or to reflect the terms used by the Lead Agency for particular ages. If rates are not statewide, please provide all variations of payment rates when reporting base payment rates below. Base rates are the lowest, foundational rates before any differentials are added (e.g., for higher quality or other purposes) and must be sufficient to ensure that minimum health, safety, quality, and staffing requirements are covered. These are the rates that will be used to determine compliance with equal access requirements. 4.3.1 Payment rates a. Are the payment rates that the Lead Agency is reporting in 4.3.2 set statewide by the Lead Agency? [x] Yes. i. If yes, check if the Lead Agency: [x] Sets the same payment rates for the entire State or Territory. [ ] Sets different payment rates for different regions in the State or Territory. [ ] No. ii. If no, identify how many jurisdictions set their own payment rates: b. Provide the date the current payment rates became effective (i.e., date of last payment rate update based on most recent MRS or ACF pre-approved alternative methodology as reported in 4.2.1). 6/30/2024 c. If the Lead Agency does not publish weekly rates, then how were the rates reported in 4.3.2 or 4.3.3 calculated (e.g., were daily rates multiplied by 5 or monthly rates divided by 4.3)? N/A 4.3.2 Base payment rates a. Provide the base payment rates in the tables below. If the Lead Agency completed a market rate survey (MRS), provide the percentiles based on the most recent MRS for the identified categories. If the Lead Agency sets different payment rates for different regions in the State or Territory (and checked 4.3.1aii), provide the rates for the most populous region as well as the region with payment rates set at the lowest percentile. Percentiles are not required if the Lead Agency also conducted an ACF pre-approved alternative methodology but must be reported if the Lead Agency conducted an MRS only. The preamble to the 2016 final rule states that a benchmark for adequate payment rates is the 75th percentile of the most recent MRS. The 75th percentile benchmark applies to the base rates. The 75th percentile is the number separating the lowest 75 percent of rates from the highest 25 percent. Setting rates at the 75th percentile, while not a requirement, would ensure that eligible families can afford three out of four child care providers. In addition to reporting the 75th percentile in the tables below, the Lead Agency must also report the 50th percentile and 60th percentile for each identified category. If the Lead Agency conducted an ACF pre-approved alternative methodology, provide the estimated cost of care for the identified categories, as well as the percentage of the cost of care covered by the established payment rate. If the Lead Agency indicated it sets different payment rates for different regions in the State or Territory in 4.3.1.a, provide the estimated cost of care and the percentage of the cost of care covered by the established payment rate for the most populous region as well as the region with rates established at the lowest percent of the cost of care. For each identified category below, provide the percentage of providers who are receiving the base rate without any add-ons or differential payments. Provide the full-time weekly base payment rates in the table below. If weekly payment rates are not published, then the Lead Agency will need to calculate its equivalent. i. Table 1: Complete if rates are set statewide. If rates are not set statewide, provide rates for most populous region. Percentiles are not required if the Lead Agency also conducted an ACF pre-approved alternative methodology but must be reported if the Lead Agency conducted an MRS only. Care Type Base payment rate (specify unit, e.g., per day, per week, per month) % of providers receiving Base rate Full-Time Weekly Base Payment Rate What is the percentile of the rate? (MRS) What is the 50th percentile of the rate? (MRS) What is the 60th percentile of the rate? (MRS) What is the 75th percentile of the rate? (MRS) What is the estimated cost of care? (Alternative Methodology) What percent of the estimated cost of care is the rate? Center Care for Infants (6 months) 471.00 Per Week 100.00 471.00 93.00 349.00 350.00 390.00 Family Child Care for Infants (6 months) 387.00 Per Week 100.00 387.00 98.00 225.00 240.00 250.00 Center Care for Toddlers (18 months) 443.00 Per Week 100.00 471.00 92.00 330.00 345.00 375.00 Family Child Care for Toddlers (18 months) 364.00 Per Week 100.00 364.00 98.00 225.00 246.00 250.00 Center Care for Preschool ers (4 years) 439.00 Per Week 100.00 439.00 95.00 305.00 325.00 356.00 Family Child Care for Preschool ers (4 years) 361.00 Per Week 100.00 361.00 99.00 225.00 225.00 250.00 Center Care for School- Age (6 years) 371.00 Per Week 100.00 371.00 88.00 272.00 297.00 325.00 Family Child Care for School- Age (6 years) 321.00 Per Week 100.00 321.00 99.00 225.00 225.00 250.00 ii. Table 2: Do not complete if rates are set statewide. If rates are not set statewide, provide rates for region with payment rates set at the lowest percentile. Percentiles are not required if the Lead Agency also conducted an ACF pre-approved alternative methodology but must be reported if the Lead Agency conducted an MRS only. Care Type Base payment rate (specify unit, e.g., per day, per week, per month) % of providers receiving Base rate Full-Time Weekly Base Payment Rate What is the percentile of the rate? (MRS) What is the 50th percentile of the rate? (MRS) What is the 60th percentile of the rate? (MRS) What is the 75th percentile of the rate? (MRS) What is the estimated cost of care? (Alternative Methodology) What percent of the estimated cost of care is the rate? Center Care for Infants (6 months) Family Child Care for Infants (6 months) Center Care for Toddlers (18 months) Family Child Care for Toddlers (18 months) Center Care for Preschool ers (4 years) Family Child Care for Preschool ers (4 years) Center Care for School- Age (6 years) Family Child Care for School- Age (6 years) b. Does the Lead Agency certify that the percentiles reported in the table above are calculated based on their most recent MRS or ACF pre-approved Alternative Methodology? [x] Yes. [ ] No. If no, what is the year of the MRS or ACF pre-approved alternative methodology that the Lead Agency used? What was the reason for not using the most recent MRS or ACF pre-approved alternative methodology? Describe: 4.3.3 Tiered rates, differential rates, and add-ons Lead Agencies may establish tiered rates, differential rates, or add-ons on top of their base rates as a way to increase payment rates for targeted needs (e.g., a higher rate for serving children with special needs). a. Does the Lead Agency provide any rate add-ons above the base rate? [x] Yes. If yes, describe the add-ons, including what they are, who is eligible to receive the add-ons, and how often are they paid: Specialized child care providers are eligible to receive an additional 10% of the established CCFAP payment for children with a protective services, child with special health needs, or family support child care service need. Additionally, children with special health needs are also eligible for the rate add-on when documentation to support the special health needs status is on file. [ ] No. b. Has the Lead Agency chosen to implement tiered reimbursement or differential rates? [x] Yes. [ ] No. Tiered or differential rates are not implemented. If yes, identify below any tiered or differential rates, and, at a minimum, indicate the process and basis used for determining the tiered rates, including if the rates were based on the MRS or an ACF pre-approved alternative methodology. Check and describe all that apply: i. [x] Differential rate for non-traditional hours. Describe: Extended care which is defined as fifty-one (51) hours or more is paid a differential rate that is 36% higher than the full-time rate for that age child and type of program. ii. [x] Differential rate for children with special needs, as defined by the Lead Agency. Describe: Providers who care for children with special needs and have been approved as a specialized child care provider receive an additional amount based on the age of the child above the provider rate . iii. [ ] Differential rate for infants and toddlers. Note: Do not check if the Lead Agency has a different base rate for infants/toddlers with no separate bonus or add-on. Describe: iv. [ ] Differential rate for school-age programs. Note: Do not check if the Lead Agency has a different base rate for school-age children with no separate bonus or add-on. Describe: v. [ ] Differential rate for higher quality, as defined by the Lead Agency. Describe: vi. [ ] Other differential rates or tiered rates. For example, differential rates for geographic area or for type of provider. Describe: vii. If applicable, describe any additional add-on rates that you have besides those identified above. N/A Does the Lead Agency reduce provider payments if the price the provider charges to private-pay families not participating in CCDF is below the Lead Agency’s established payment rate? [ ] Yes. If yes, describe: [x] No. 4.3.4 Establishing payment rates Describe how the Lead Agency established payment rates: a. What was the Lead Agency’s methodology or process for setting the rates or how did the Lead Agency use their data to set rates? The 2022 ECE Financing Study helped to guide the rate setting that occurred in 2023. The Vermont Legislature used the analysis to inform legislation which increased the payment to providers at three different intervals. The information from the analysis gave them what they needed to determine affordability and implementation. On July 2, 2023, Vermont decoupled the STARS rating from the provider payment and set the rate for all providers at the rate for five (5) STARS. On December 17, 2023, the State increased the provider rates again by 35%. On June 30, 2024 the family child care providers rates increased by 50% of the difference of licensed centers and family child care homes. In both Licensed and Registered settings, with very few exceptions, State rates more than covered the 75th percentile of provider rates for full time care for all age groups. Conversely, in both Licensed and Registered settings, the State rates more often than not failed to cover the 75th percentile of provider rates for part time care for all age groups. Vermont also has universal entitlement to ten (10) hours of publicly funded prekindergarten for all three (3) and four (4) year-old children and for five (5) year-olds not yet eligible for kindergarten in Vermont. Services are provided through a mixed delivery system that includes private as well as public school programs. An annual tuition of $3884 (for the 24/25 school year) is provided to support these services to qualified private providers that parents choose for their children. This tuition is layered with CCFAP subsidies at the program level to further reduce costs for families participating in CCFAP for preschool age children enrolled in high quality early care and learning programs. b. How did the Lead Agency determine that the rates are adequate to meet health, safety, quality, and staffing requirements under CCDF? The cost model includes costs of maintaining basic health, safety, quality, and staffing requirements which guided the establishment of rates equating to 88th - 95th percentile. c. How did the Lead Agency use the cost of care, either from the narrow cost analysis or the ACF pre-approved alternative methodology to inform rate setting, including how using the cost of care promotes the stabilization of child care providers? Rates are set by the legislative process and include many factors such as current data, budget and need. The State works with the Joint Fiscal Office and the Legislature to set the rates. At the end of 2022 there was an ECE Financing Study done by a hired contractor that looked at child care settings from many different avenues, including cost of care, health, safety, quality, and staffing requirement, which was presented to the State and the Legislature. The Legislature then used that information to set the rates paid to providers in three intervals. By paying providers the true cost of care helps to to stabilize child care providers by paying them a livable wage, allowing for continuous care of children and allows for grown and sustainability. Looking at the current MRS, all providers are paid between the 88th - 98th percentile of the MRS. d. How did the Lead Agency account for the cost of higher quality while setting payment rates? Vermont no longer has a tiered rating system related to payment amount. The State rates are set to a higher amount to support all programs in achieving a higher quality of care for all children. The Vermont ECE Financing Study ("RAND") Study calculated the average cost per child of high-quality care at centers would be about $33,000 annually. When coupling the subsidy amount and the family share amount Vermont is paying approximately 74% of the cost of quality care: closer than it been in the past to paying providers the true cost of care. Currently rates are set at the 88th - 95th percentile of the current MRS. e. Identify and describe any additional facts (not covered in responses to 4.3.1 – 4.3.3) that the Lead Agency considered in determining its payment rates to ensure equal access. N/A