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. Wis. Statutes, s.49.155(6g)(a)5 allows the child's learning and development to be considered and continuity of care to be promoted when authorizing hours of child care. The Lead Agency is not required to limit authorized hours based on the parent's schedule of activities or the number of hours the parent spends in those activities. Wis. Admin. Code DCF s. 201.039(2g)(b) states that during a parent's 12- month eligibility period, parents may continue the most recent authorization, extend the most recent authorization, or receive an authorization for up to the same number of hours as the parent's previous authorization when any of the following changes begin: 1. The parent is continuing to participate in an approved activity, but the number of hours that the assistance group needs child care is decreasing. 2. The parent is beginning a temporary break. 3. The parent is beginning an approved activity search period. 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? [ ] Yes. [x] No. If no, describe: A parent’s renewal is due by the end of the 12th month from the application month or previous renewal month. A renewal can be completed in the 13th month without requiring the parent to apply. The first month of application may be a partial month, making the eligibility period 11 full months and potentially one partial month. The renewal is also due for the entire Assistance Group, so children added during the eligibility period receive only the amount remaining in the original eligibility period. The Lead Agency has submitted a corrective action plan to ACF-OCC identifying policy and system changes needed to ensure full-compliance with the full 12-month eligibility period. 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? [ ] No. [x] Yes. If yes, provide the additional/varying policies for redetermination: A 3- month break period begins the calendar month following the first day of the break. Parents who experience a temporary break in approved activity during the last month of the 12-month eligibility period are not eligible for a new 12-month eligibility period until they resume participation in their approved activity or start a new approved activity. 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. [ ] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at initial eligibility determination. If yes, describe: ii. [ ] Yes. The Lead Agency does consider seeking employment (engaging in a job search) as an eligible activity at redetermination. If yes, describe: iii. [x] 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? [x] Yes. The Lead Agency continues assistance. [ ] 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: ii. If no, describe what specific actions/changes trigger the job-search period after each such loss or cessation: iii. If no, how long is the job-search period where a family can continue assistance (must be at least 3 months)? 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. [x] 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: Excessive unexplained absence is defined as no attendance by the child for the 30 previous days when the provision of child care services was expected by the child care provider, based on the agreement between the provider and the parent, and the parent has not contacted the provider to explain the child's absence. The parent's eligibility for Wisconsin Shares will continue but the parent's subsidy will be ended if the agency cannot reach the parent after multiple attempts. 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: Wisconsin residency is a condition of eligibility per Wis. Statutes, s.49.145(2)(d). Eligibility is terminated if a family moves out of Wisconsin. All changes that may affect eligibility must be reported to the local agency within 10 days after the change per Wis. Statutes, s.49.145(2)(m). 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: The following are Client Intentional Program Violations (IPVs): misrepresentation of income, misrepresentation of household composition, misrepresentation of child care needs, misrepresentation of residency, misrepresentation of participation in an approved activity, selling access to a subsidy account (trafficking), providing false or fraudulent documentation, misrepresentation of hardship need, using child care subsidy (as a client) to pay themselves as a provider, providing false identification or Social Security Number (SSN). Assistance can also be discontinued for a client's collusion with a child care provider to defraud the Wisconsin Shares program. The Lead Agency denies subsidy funds for the following durations: six months for a first violation, 12 months for a second violation, and permanent suspension from the Wisconsin Shares program for a third violation. The information on client IPVs is located in Wis. Statutes, s. 49.151(2) and the Wisconsin Shares Handbook Section 4.5.4.3 and 4.5.4.3.2. The violations that lead to discontinued assistance are listed in 4.5.4.3.5. 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. [ ] 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. [x] The Lead Agency sets the second tier of eligibility at 85 percent of SMI. If checked, describe the policies and procedures: Families at or below 200% FPL must report if their gross monthly household income exceeds 85% SMI, while a family with income above 200% must report if their household’s gross monthly income increases by $250 or more i. [x] 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: Families at or below 200% are eligible at initial application. At redetermination, a family will remain eligible if the income remains below 85% SMI. Families at or below 200% FPL must report if their gross monthly household income exceeds 85% SMI, while a family with income above 200% must report if their household’s gross monthly income increases by $250 or more. ii. [ ] Lead Agency requires additional reporting requirements during the graduated phase-out period. If checked, describe: c. [ ] The Lead Agency sets the second tier of eligibility at an amount lower than 85 percent of SMI for a family of the same size but above the Lead Agency’s initial eligibility threshold. If checked, provide the following information: i. Provide the income level ($/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.