4.4 Payment Practices to Providers

Lead Agencies must use subsidy payment practices that reflect practices that are generally accepted in the private pay child care market. The Lead Agency must ensure timeliness of payment to child care providers by paying in advance or at the beginning of delivery of child care services. Lead Agencies must also support the fixed cost of child care services based on paying by the child’s authorized enrollment, or if impracticable, an alternative approach that will not undermine the stability of child care programs as justified and approved through this Plan. Lead Agencies must also (1) pay providers based on established part-time or full-time rates rather than paying for hours of service or smaller increments of time, and (2) pay for reasonable, mandatory registration fees that the provider charges to private-paying parents. These policies apply to all provider types unless the Lead Agency can demonstrate that in limited circumstances the policies would not be considered generally-accepted payment practices. In addition, Lead Agencies must ensure that child care providers receive payment for any services in accordance with a payment agreement or an authorization for services, ensure that child care providers receive prompt notice of changes to a family’s eligibility status that could impact payment, and have timely appeal and resolution processes for any payment inaccuracies and disputes. 4.4.1 Prospective and enrollment-based payment practices Lead Agencies must use payment practices for all CCDF child care providers that reflect generally- accepted payment practices of providers serving private-pay families, including paying providers in advance or at the beginning of the delivery of child care services and paying based on a child’s authorized enrollment or an alternative approach for which the Lead Agency must demonstrate paying for a child’s authorized enrollment is not practicable and it will not undermine the stability of child care programs. Lead Agencies may only use alternate approaches for subsets of provider types if they can demonstrate that prospective payments and authorized enrollment-based payment are not generally-accepted for a type of child care setting. Describe the Lead Agency payment practices for all CCDF child care providers: a. Does the Lead Agency pay all provider types prospectively (i.e., in advance of or at the beginning of the delivery of child care services)? [x] Yes. If yes, describe: The Lead Agency ensures a full month's subsidy benefit amount is made available through the parent's EBT card at the beginning of each month. A provider will enter into a written payment agreement with each parent that receives a child care subsidy. Parents are responsible for determining when the payment is transferred to the child care provider's account. [ ] No, it is not a generally-accepted payment practice for each provider type. If no, describe the provider type not paid prospectively and the data demonstrating it is not a generally-accepted payment practice for that provider type, and describe the Lead Agency’s payment practice that ensures timely payment for that provider type: b. Does the Lead Agency pay based on authorized enrollment for all provider types? [x] Yes. The Lead Agency pays all providers by authorized enrollment and payment is not altered based on a child’s attendance or the number of absences a child has. [ ] No, it is not a generally-accepted practice for each provider type. If no, describe the provider types not paid by authorized enrollment, including the data showing it is not a generally-accepted payment practice for that provider type, and describe how the payment policy accounts for fixed costs: [ ] It is impracticable. Describe provider type(s) for which it is impracticable, why it is impracticable, and the alternative approach the Lead Agency uses to delink provider payments from occasional absences, including evidence that the alternative approach will not undermine the stability of child care programs, and thereby accounts for fixed costs: 4.4.2 Other payment practices Lead Agencies must (1) pay providers based on established part-time or full-time rates rather than paying for hours of service or smaller increments of time, and (2) pay for reasonable, mandatory registration fees that the provider charges to private-paying parents, unless the Lead Agency provides evidence that such practices are not generally-accepted for providers caring for children not participating in CCDF in its State or Territory. a. Does the Lead Agency pay all providers on a part-time or full-time basis (rather than paying for hours of service or smaller increments of time)? [x] Yes. [ ] No. If no, describe the policies or procedures that are different than paying on a part- time or full-time basis and the Lead Agency’s rationale for not paying on a part-time or full-time basis: b. Does the Lead Agency pay for reasonable mandatory registration fees that the provider charges to private-paying parents? [x] Yes. If yes, identify the fees the Lead Agency pays for: Parents may receive registration fees up to $125, two times per rolling calendar year. [ ] No. If no, identify the data and how data were collected to show that paying for fees is not a generally-accepted payment practice: c. Describe how the Lead Agency ensures that providers are paid in accordance with a written payment agreement or an authorization for services that includes, at a minimum, information regarding provider payment policies, including rates, schedules, any fees charged to providers, and the dispute-resolution process: Providers are required to have a written payment agreement with parents receiving Wisconsin Shares. The written agreement must include the child care price, payment schedule, provider’s address where the care takes place, child’s name, fees, agreed upon start date, providers days and hours of operation, closure dates and payment policies during closures, provider’s payment expectations for expected child absences, provider’s payment dispute policy, and that payments are deposited directly into the provider’s bank account through ACH. The provider must maintain a copy of expired written payment agreements for three years. The expired agreement may be kept at a location where it can be made available to DCF within 24 hours. d. Describe how the Lead Agency provides prompt notice to providers regarding any changes to the family’s eligibility status that could impact payments, and such a notice is sent no later than the day that the Lead Agency becomes aware that such a change will occur: A Wisconsin Shares Child Care Provider letter is mailed to providers on the last business day of each month. The authorization information letter includes the child’s name, date of birth, and the start and end dates of all current and future authorizations, any backdated authorizations added since the last notice was sent, any authorizations that were deleted or ended by the agency worker, or the system, and that were previously listed in an earlier notice. The letter also specifies when authorization dates have been changed The Wisconsin Shares Child Care Provider Letter does not include payment or authorized hours information due to confidentiality. The provider also has access to the information online using the Provider Portal e. Describe the Lead Agency’s timely appeal and resolution process for payment inaccuracies and disputes: Parents have the right to appeal decisions made regarding their case including subsidy payments. An Administrative Law Judge decides if the local agency’s findings and calculations were correct. If the local agency’s determination is upheld, the local agency and parent will receive a decision dismissing the appeal. If the parent’s appeal is upheld, the ruling remands the matter to the local agency to rescind or recalculate the amount. The local agency must carry out the remand order within 10 calendar days. f. Other. Describe any other payment practices established by the Lead Agency: 4.4.3 Payment practices and parent choice How do the Lead Agency’s payment practices facilitate provider participation in all categories of care? The Lead Agency prospectively loads funds onto the parent’s electronic benefit transfer (EBT) card where the funds may be used as soon as they are loaded to the card, ensuring the provider receives timely payment and immediate access to funds.