Transcript EEC REGULATION REFORM – Subsidy Revisions Policy and Fiscal Committee March 7, 2011

EEC REGULATION REFORM –
Subsidy Revisions
Policy and Fiscal Committee
March 7, 2011
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EEC Subsidy Regulations
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What Are the Subsidy Regulations?
EEC is the Lead Agency responsible for compliance with early
education and care services under the Personal Responsibility and
Work Opportunity Reconciliation Act of 1996 (Pub. L. 104-193). As
such, EEC is responsible for administering and providing early
education and care programs and services to children, through
grants, contracts and vouchers. The current regulations (606 CMR
10.00) identify the general provisions and eligibility requirements for
families with children seeking subsidized child care in the
Commonwealth.
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EEC Child Care Subsidy Program Governance
EEC’s Financial Assistance Program is governed by both federal and
state laws and policies:
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Federal Statutes -- The Child Care and Development Block Grant
Act and the Social Security Act
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Federal Regulations -- The Child Care Development Fund
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Federal Policies, Program Instructions and Other Guidance
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State Regulations -- Subsidized Child Care
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State Policies -- EEC Financial Assistance Policy Guide
FY11 EEC Budget Breakdown
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Financial Assistance – Table of Contents for both
EEC Regulations and Policy Guide
Table of Contents: EEC Regulation
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10.01: Introduction
10.02: Definitions
10.03: General Provisions
10.04: Income Eligible Child Care
Subsidy
10.05: Employment Services Program
10.06: Supportive Child Care
10.07: Teen Parent Child Care Services
10.08: Trial Court Child Care
10.09: Child Care for Special
Populations
10.10: Caregivers
10.11: Reimbursement
10.12: Termination and Reduction of
Services
10.13: Review Process
10.14: Applicability
Table of Contents: EEC Policy Guide
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Chapter 1: Eligibility
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Chapter 2: The EEC Centralized Waiting
List for Financial Assistance
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Chapter 3: Documentation of Eligibility
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Chapter 4: Service Need
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Chapter 5: Parent Co-Payments
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Chapter 6: Reassessment
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Chapter 7: Terminations and
Reductions
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Chapter 8: EEC Financial Assistance
Complaint and Investigation Process
Why Amend the EEC Subsidy Regulations?
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Factors contributing to the need to review and amend the
Regulations include:
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Identifying and Implementing Best Practices
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Review regulations every 5 years (Subsidy Regulations last
updated in 2006)
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Analyze other State child care subsidy laws and policies
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Address unique challenges/ weaknesses identified due to
recent fiscal constraints/ system restructuring (e.g.,
closure/ limited access to EEC financial assistance, CPC
transition, Voucher Pilot)
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Targeting/ maximizing limited resources
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Addressing user feedback/ achieving efficiencies
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Addressing Federal & State Oversight concerns
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Reduce opportunities for Fraud, Waste and Abuse
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Ensure Program Integrity
Addressing Federal & State Oversight concerns
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Program Integrity and Fraud, Waste and Abuse Prevention
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GAO and OIG findings related to CCDF, TANF and Head Start
subsidized child care identify several issues and best practices on
a national scale, not MA specific, related to eligibility verifications
and lack of resources:
● Unreliable internal controls to oversee/manage applications
and billing processes – vulnerable to fraud:
● Excessive billing;
● Documentation falsification;
● Fictitious children; and
● Collusion between parents and providers
● Insufficient data sharing agreements to verify eligibility
● Insufficient resources – staff and technology
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Improper Authorizations for Payment (IAP) exercise results
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Response from ACF regarding our State Plan
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ANF established a Task Force on Fraud Waste and Abuse to
review public assistance programs
Addressing User Feedback/ Achieving Efficiencies
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As EEC providers, CCR&Rs and internal staff have used the
Guide, issues have been identified, including:
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Ability to update and communicate changed or new
policies
Structure of and clarity of policy information
Documentation of eligibility requirements
Outdated, confusing policies
Missing policies
Ease of finding needed information
CCR&R and Provider Feedback
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Confirms need to improve Financial Assistance Polices
and regulations, including the Request for Review
process, Recoupment procedure, and Documentation
requirements
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Raises other concerns regarding improving
Communication (w/ EEC, DTA and DCF staff)
Subsidy Regulation Changes - Required
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While many of the issues identified to date have been
addressed by revising the Policy Manual, and improving the
process for updating policies, some regulation revisions are
necessary, including:
Redefine Special needs of parent/ child
Reduce Allowable Absences
Redefine Self Employment
Allow for eligibility verifications through inter-agency
data matches
 Streamline Review Process and recoupment process
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Status of policy updates requested
Quick Fixes – Policies Updated
Long Term Fixes – Regulation
Changes or Data Exchanges Needed
Break in service need of parent
Self Employment Verification
Eligibility self reporting “significant
changes” in income (20% rule)
Special Need Access Regulations
Travel time for calculation of service
need
Streamline Review Process
Child Support Requirement
Waitlist management enhancements
Second parent in Household
Redraft Provider voucher manual and
agreement (Jan roll out)
Clarify Recoupment Process
Identity/ legal immigration status
documentation
Codified Variance Process
Special Need Forms (Child/Parent)
Redraft Financial Assistance agreement/
termination notices
Excessive Absences of Children
Schedule of Care
Interfaces with other agencies: RMV,
DOR (wage matches) or other agency
systems
Key
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 = Policy issue reviewed and updated
 = Policy issue reviewed and requires regulation change to update
Summary of Proposed
Changes to Subsidy
Regulations
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Technical Amendments to Subsidy Definitions,
606 CMR 10.02
The addition of new or revised definitions are
necessary to ensure compliance with current
laws/policies and to aid in the interpretation and
enforcement of the regulations:
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Child Care Educator/Provider
Contracted Child Care Educator/Provider
Excessive Absence
Explained Absence
Full Time Care
Protective Services
Amendments to the General Eligibility Provisions,
606 CMR 10.03
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Family Size and Household Composition (codifies existing practice)
o
Clarifies verification of household members necessary for
purposes of determining eligibility and establishing parent
fees.
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Identity, Residency & Citizenship Status (codifies existing practice)
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Requires verification of applicant’s identity and residency, as
well as the citizenship or immigration status of each child
seeking child care financial assistance.
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Child Support Enforcement Requirement (new)
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Requires single parent applicants to submit evidence of child
support and/or cooperation with the Commonwealth’s Child
Support Enforcement agency, as a condition of eligibility.
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Child Attendance/Reimbursement Requirements
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(amends current
requirements)
Requires children to regularly attend early education and care
programs subsidized by the Commonwealth or risk
termination.
Data Sharing/Interfaces Authorization (new)
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Authorizes EEC to request and/or provide information to/from
other government agencies, contracted providers, other
states and banks or other financial institutions for purposes of
verifying eligibility.
Identity, Residency & Citizenship Status – Issue
and Proposed Remedy
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EEC seeks to formally codify the Citizenship and
Immigration Status policy issued in April 2010,
in order to:
o
Address the deficiency in EEC’s regulations and
policies identified by ACF the 2008-2009 Federal
Improper Authorization for Payment review
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Massachusetts, along with all other Year 2
States, were given a one time exemption to
implement this requirement
Achieve consistency between regulations
and policies and to ensure efficient and
uniform outcomes for families
Comments from Advisory Council and Providers
Questions regarding the impact of citizenship
requirement on Head Start programs and Public
School districts
 Recognition that this is a federal requirement and is
not optional for federal reimbursement
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Child Support Enforcement Requirement – Issue
and Proposed Remedy
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Due to concerns about the accuracy of household size reported by
families and in support of the mission of the MA Child Support
Enforcement Agency (CSE), EEC proposes a requirement to mandate
“cooperation” with CSE agency OR other proof of child support as a
condition for child care assistance for single parent families
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At least 20 States currently impose a CSE requirement
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Benefits of instituting a Child Support Enforcement policy:
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Key issues to consider during implementation of policy:
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Keep families out of poverty
Provide adequate food, shelter and clothing
Increased access to medical services & sense of security
Add to the overall stability, security and well-being of families
and children
Intended to lessen the existing burdens of second parent in the
household documentation
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How many families seeking assistance are currently enrolled –
avoid duplication
Identify exceptions (i.e., domestic violence or child protection)
Required documentation
Monitoring and evaluation of effectiveness
Comments from Advisory Council and Providers
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Recognize that particular circumstances lend
themselves to waiver (e.g. domestic violence)
Just because other states are utilizing this approach
does not mean that it makes sense for Massachusetts
May cause programs to lose clients because the
regulations will become too intimidating
May incentivize parents to “disappear” from their
children’s lives
Current regulation enables parents not to take
responsibility for their own children
Request to solicit feedback from parents and other
stakeholders through public comment process
Implementation questions regarding how requirement
be enforced and how parents will be able to file with
DOR
Strengthen Child Attendance Requirement - Issue
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Review of annual billing and current EEC regulations related to
absences identified potential abuse/waste.
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Current Regulatory Definitions, 606 CMR 10.02:
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Excessive absence = more than 3 consecutive unexplained
absences or 11 or more explained absences w/in a 30 day period.
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Explained absences = any absence due to illness, emergency, or
max. of 10 days vacation/ year.
Current utilization and annualized billing
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(EEC’s annual billing for FY08-10 shows):
Average annual billing by the CCR&Rs - $18.5M
Average annual billing by contract providers - $18.5M
Over each of past 3 years, providers have billed EEC for over
$37M related to absent days
Absence rates for some children approach 50%
Providers acknowledge billing for “regularly scheduled” absences,
such as families that only need 4 days/week
Strengthening Child Attendance Requirement –
Best Practices
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In preparing its recommendations, EEC reviewed research which
shows that chronic absenteeism in the early years, such as
kindergarten, predicted continuing absences in later
grades.
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In addition, we looked at other states to identify best practice:
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Ohio – limits absences to 10 in 6 months
Maryland – limits absences to 60 in 12 months
Delaware – limits absences to 5 per month
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MA public schools limit absences to 7 in 6 months
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These examples have ramifications on both families (termination)
and providers (billing) giving incentive for proper use of funds
and encouraging attendance/ good outcomes for children
Strengthening Child Attendance Requirement –
Proposed Remedy
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Options for implementation – excused absences:
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Limit absences to
Limit absences to
Limit absences to
Limit absences to
Limit absences to
with ESE policies
5 per month
15 per 3 months
30 per 6 months*
60 per 12 months
7 in 6 months, in accordance
*The Recommendation above reflects an average of 5
absences per month enforced over a 6 month period.
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EEC does not propose any changes related to the
definition of “excessive” absence.
Comments from Advisory Council and Providers
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Good change; very supportive of 30 absences/6 mos.
Support for reducing the number of absences
Be clear on medical documentation needed to
substantiate approved absences
Need to counsel families on why attendance is
important; may want to look at Head Start policies
Questions regarding exceptions (i.e. children who are
hospitalized for an extensive period of time, children
with chronic conditions, children with contagious
diseases, etc.) and how these situations would be
handled
Amendments to Financial & Service Need Eligibility
Criteria, 606 CMR 10.04(1)
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Limitations on Self-Employment (amends current requirements)
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Imposes restrictions on certain work-related service need
activities, in particular “at home” self-employment
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Changes methodology for calculating service need – total
earnings divided by minimum wage to establish amount of
care needed.
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Special Needs (Protective Services) (amends current requirements)
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New definition of protective services to include
parents and children with documented disability
and/or special need.
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Eliminates child with special need as a single
service need.
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Additional Documentation (codifies existing practice)
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Authorizes providers and/or CCR&Rs to request
additional documentation, if file indicates
application inaccuracies/ contradictions.
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Travel Time (codifies existing practice)
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Requires applicants to present a minimum of 20
hours of service need before allowing travel time to
be factored in.
Self-Employment – Issue and Proposed Remedy
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Feedback from stakeholders identified inconsistent and inefficient policies
for assessing eligibility for self-employed parents AND increased
terminations, reductions and recoupment due to false, misleading or
inaccurate documentation submitted.
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To improve program integrity and efficiency, EEC proposes to limit the
types of work-related activities that satisfy the service need requirement:
1.
No home-based self-employment, unless the work performed:
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Propose a launch/grace period for new self-employment business – 3
month start up
3.
Implement new mechanism for confirming minimum wage
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creates a clear and present danger to children
requires regular face-to-face meetings or appointments with
clients, which prevents direct supervision of children
Current practice – divide gross income by estimated hours to
determine hourly rate
Proposed practice – divide gross income by MA minimum wage
rate to determine hours
Comments from Advisory Council and Providers
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Generally supportive of change
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Question whether income taxes would still be required
for self-employed
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Concerns regarding whether people who work at home
can provide an educationally rich environment for
children
Special Needs: Federal Regulatory Compliance –
General Issues
Federal regulations establish two foundational requirements for
all children seeking CCDF-funded child care services:
1.
Children must reside with a family whose income does not
exceed 85% of SMI; and
2.
Reside with parent(s) who are working, or participating in
job training or an education program, or are receiving or
need to receive protective services.
In 2009-2010, ACF identified two instances where EEC policies
and regulations and policy may not align with these mandatory
requirements:
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1.
Children with Special Needs – 1) allowing children to
remain in care up to 100% SMI; 2) allowing a categorical
waiver of the work, education and training requirement, and
3) not clearly defining such families “in need of protective
services.”
2.
Parents with Special Needs – 1) allowing children to
remain in care up to 100% of SMI, and 2) not clearly
defining such families “in need of protective services.”
Special Needs: Federal Regulatory Compliance –
General Issues
CCDF regulations provide some flexibility to States for
purposes of defining and implementing laws and policies
related to protective services. Specifically, families
within the State definition of protective services, may be
exempt from some eligibility requirements:
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1.
Children residing in a family that is receiving or
needs to receive protective intervention
services may be eligible for CCDF-funded child care,
if they remain in the home, even if the parent(s) is
not working or in an education or training program.
See 45 CFR 98.20(a)(3)(ii).
2.
Additionally, states have the discretion to waive the
85% SMI limitation if a child is residing in a family
that is receiving or needs to receive protective
intervention services if determined necessary on a
case by case basis. See 45 CFR 98.20(a)(3)(ii)(A).
Special Needs: Federal Regulatory Compliance –
Proposed Remedy
States are required to define “protective services” in the CCDF State
Plan, if they choose to fund services to this population. See 45 CFR
98.16(e)(7)
Currently, Massachusetts defines “protective services” as:
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Families are eligible for supportive child care services when they
have active protective needs documented in a supported report of
abuse or neglect within the previous 12 months or when there is a
determination of need to begin or continue supportive child care at
a Department of Children and Families Progress Supervisory
Review.”
Proposed definition:
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“Families, who have active protective needs documented in a
supported report of abuse or neglect within the previous 12 months
or when there is a determination of need to begin or continue
supportive child care at a Department of Children and Families
Progress Supervisory Review, will be deemed to be in need of
protective services. Additionally, children may be deemed at risk of
needing protective services in special circumstances, wherein
families are unable to provide child care for any portion of a 24 hour
day due to a crisis situation of domestic violence or homelessness, a
physical, mental, emotional or medical condition, or participation in
a drug treatment or drug rehabilitation program, or court-ordered
community service.”
Special Needs Children – Unique Issues
Current MA practice:
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Parents are not required to engage in work, education and/or
training activities
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Families may enter care at 85% SMI and exit at 100%
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Children are eligible for full-time care regardless of need
Utilization and Estimated Annual Cost (based on 10/2010 data):
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Parents with special need – 1,845 children/$12.17M
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Children with special need – 902 children/$5.95M
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Total annual cost – over $18M
Issues:
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Exemption was originally based on assumption special needs
children are “educationally at risk”
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Misaligned with federal exemption definition of “in need
of protective services”
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Research based risk factors show that ALL low-income
children are “educationally at risk”
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Streamlining and coordinating resources:
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Other agencies are charged with providing services to
special needs children -- ESE (IEP) or DPH (IFSP)
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EEC should support ESE and/or DPH with wrap-around
services, for otherwise eligible children
Special Needs Children – Proposed Remedy
Proposed change:
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Align EEC regulations with Federal
regulations and require parents of children
with special needs to participate in work,
education or training
No Change:
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Families will continue to remain eligible at
the 85%/100% income levels
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Eligible children may continue to qualify for
full-time care, regardless of their parents’
service need
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EEC will continue to work with other state
agencies to provide the necessary wraparound support for eligible children
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Comments from Advisory Council and Providers
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Providers and CCR&Rs Very supportive of proposed
change
Request not to accept any and all children who
present with an IEP; there are services out there that
are a better match
However, may create a gap when children leave IEP
but are unable to get picked up by public schools
Current regulation has pushed out working families
and changed the balance of classrooms; unable to
meet the needs of all working Income Eligible families
Question regarding who will connect parents to other
services and whether case workers will be trained
regarding special needs
Question whether new requirement should include
reviewing multiple risk factors for children, including
environmental risk factors or using an assessment tool
to verify eligibility
Special Needs Parents – Unique Issues
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The Department has identified the following concerns when
reviewing its child care subsidy regulations and policies and
makes the following findings/observations – for Parents:
• In practice, “special need of parent” definition
misaligned with federal “in need of protective
services” intention.
• Examples identified through central office review:
headaches, backaches, carpal tunnel syndrome.
• Data shows inordinate number of special need of
parent service need approvals in contract slots
• Special need of parent service need currently
approved for indefinite time period irrespective of the
stated need
• Federal laws prohibit use of CCDF funding for respite
care
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Special Needs of Parents – Research/Best Practices
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In response to a nationwide survey of CCDF Program
administrators in January 2011, 8 states described policies
and procedures for assessing the eligibility of special need or
disability of parents.
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Highlights from the responses:
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Most states limit eligibility for special need or disabled
parents to 2-parent households
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Some states impose further restrictions based on the age
of the children in the household (i.e., not a valid service
need unless the child is under 8)
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Some states limit eligibility for a shorter duration (i.e., no
more than 6 months for medical illnesses, etc.)
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At least one state limits the eligibility for this population
to “continuity of care” only for limited time (i.e.,
previously employed, upon reassessment disabled –
allowable service need not to exceed 30 days)
Special Needs – Length of Authorization Consistency
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Subsidy Type
Initial Duration
I/E Continuity
TANF/DTA
Up to 12 months, in
accordance with DTA
authorization
Upon closure of DTA
case, must comply
with I/E regulations
and policies for
continuity
Supportive/DCF
Up to 6 months
One 6 month
extension allowed,
after which must
comply with I/E
regulations and
policies for continuity
Special Need Parents
or Children
Up to 12 months,
renewable at the end
of each authorization
for as long as
condition exists
Indefinite. Exempt
from I/E regulations
and policies and
continuity allowed for
as long as special need
exists
Income Eligible
Up to 12 months
must comply with I/E
regulations and
policies for continuity
Special Needs Parents – Proposed Remedy
EEC will seek to amend current policies related to
Child Care Financial Assistance eligibility requirements
for families with special needs parents to:
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Only allow for new access through vouchers
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Heighten the bar on what is deemed “at risk of needing
protective service”
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Only allow these to be short term vouchers -- 12 months,
renewable once –- with the intended purpose of helping
to serve as a bridge while parents seek other resources
to address the “protective service” issue and/or become
employable.
Comments from Advisory Council and Providers
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Observation that many of these children are in care
under this service need because DCF cases have
closed and parents are marginal (i.e. mental health
issues, substance abuse issues)
Some voiced support for focusing on helping parents
achieve self sufficiency as existing regulation creates a
conflict between enabling parent versus protecting
the child
Must allow exceptions for parents with permanent,
documented disabilities
Concern as to who is going to help these families get
additional resources after 12 months and care ends
Concern that other resources may not be available
upon the expiration of the 12 month vouchers
12 months may not be long enough– will there be an
exception/ waiver process
OVERVIEW OF REVIEW PROCESS
Parent submits a Request for Review
after Termination, Reduction or Denial
of Subsidy
EEC Financial Assistance Specialist
reviews Request and makes
Determination to Uphold or Overturn
If upheld, Parent submits Request for
Hearing and EEC Hearing Officer
conducts informal hearing and issues
a Written Decision
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Review Process: Issues
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Caseload volume (by calendar year)
• 2008 = 756 Requests for Review
• 2009 = 1,438 Requests for Review
• 2010 = 847 Requests for Review
Incomplete documentation
Significant lag times within caseload processing
Appellants have several “bites of the same apple”
Child care may continue for several additional
weeks or months pending the outcome of the
review and/or the informal hearing
Review Process: Proposal
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Proposed updates to EEC Review Process
regulations include:
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Dismissals for failure to prosecute
Clarify appropriate grounds for appeal
Clarify documentation timelines
Grant opportunity for appeal related
to recoupment amounts
GOALS FOR THE REVIEW PROCESS
EEC seeks to revise the Termination and Reduction of
Services and the Review Process sections to:
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Streamline and Manage Efficiencies
 Address Federal and State Mandates to Recoup
Fees
 Parent recoupments (by calendar year)
• 2008: 4 repayment agreements; 7 referrals to BSI/
AGO referrals.
• 2009: 196 repayment agreements; 5 BSI/ AGO
referrals.
• 2010: 359 repayment agreements; 1 BSI/AGO referral
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Provide clarification for Parents, CCR&Rs and
Contracted Providers
10.12 Termination and Reduction of Services
(1)
Reasons for Denial or Termination: Currently, there are 6
reasons for issuing a denial or termination of subsidized child
care:
• Lack of continuing service need
• Lack of financial eligibility
• Non-payment or late payment of fees
• Unexplained or excessive absence
• Failure to submit the required documentation at
reassessment
• Failure to comply with EEC’s, CCR&R’s or contracted
provider’s policies
 EEC seeks to add two additional reasons:
• Submission of False or Misleading Information and/or
Documentation to the contracted provider, CCR&R or EEC
• Outstanding child care debt owed to the Commonwealth
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10.12
Termination and Reduction of Services
(cont’d)
(2) Reasons for Reduction: EEC seeks to modify
the existing reason for reduction:
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Parent(s)’ service need changes from full time to
part time
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and add a new reason for reduction:
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If a change in the total household income results in
an increase to the parent(s)’co-payment fee, in
accordance with EEC’s fee schedule
10.13 Review Process
Reasons for Review: EEC seeks to add an additional
reason for review:
 assesses a fee or an outstanding child care debt that the
parent believes is not in accordance with EEC policy
(1)
(2) Scope of Review: EEC seeks to clarify scope of review by
adding a new scope to reflect recoupment:
 Requests for Review that are solely related to the existence
and/or the amount of a debt owed are outside the scope of the
review process, if:
(a) the parent(s) has already entered into an agreement
to repay the outstanding debt; or
(b) the parent(s)’ claim is limited to financial hardship
imposed by the agreement to repay
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10.13 Review Process (cont’d)
(6) Termination of Continued Subsidized Child Care: Currently there are
3 bases as to when subsidized child care can be terminated during the
review process or subsequent appeal:
•
a determination is made that the sole issue is a challenge to the
validity of a particular law or regulation
• a change affecting the parent’s subsidy occurs subsequent to the filing
of the request for review that makes the previously filed request moot
• the parent fails to comply with the requirements for continuing
subsidized child care.

EEC seeks to add the following as an additional basis:
• a determination is made that there is no genuine issue of material
fact as presented by the parent in his/her request for review
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10.13 Review Process (cont’d)
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(7) Preliminary Review:
(d) Decisions:
1. How Made. Currently the EEC Review Officer reviews
all information submitted by the parent and the provider or
CCR&R and seeks clarification from the parties, if necessary.
The Review Officer may take administrative notice of general,
technical or scientific facts within his/her specialized knowledge
and may use his or her experience and specialized knowledge
in the evaluation of the evidence presented.

EEC seeks to add the following provisions:
The Review Officer may take administrative notice of public
records or any information provided by other state agencies,
the State Auditor’s Office and/or its Bureau of Special
Investigations. If during the evaluation of the evidence
presented, the EEC Review Officer determines that additional
reasons for termination/reduction as enumerated in 606 CMR
10.12 (1) and (2) are supported by the evidence, the Review
Officer will identify these in the written decision.
10.13
Review Process (cont’d)
(8) Informal Hearing:
(e) Reasons for Dismissal: Currently there are 2 reasons as
to when a request for informal hearing may be dismissed.
EEC seeks to modify this provision and add two more
reasons for dismissal as follows:
1. fails to appear at the informal hearing;
 2. fails to prosecute his/her claim;
 3. has already agreed in writing to repay the debt at
issue; or
4. withdraws the request for Informal Hearing in
writing or on the record at the hearing.
44
Proposed Regulation Promulgation Timeline
45
Tasks
Date
Vet Regulation Changes with Providers/ CCR&Rs;
continue to make policy changes/ clarifications
that do not require regulation changes
Fall 2010
Board reviews draft of proposed regulation
changes; Committee discussions
Feb/March
2011
Board vote to put regulations out for public
comment
March/April
2011
Public comment period; meetings with
stakeholders/providers/ advocates
May/June
2011
Board vote to promulgate regulations;
Roll out implementation/ trainings
June/Sept.
2011