IM-148 10/06/99 CHILD CARE POLICY REVISIONS
|CHILD CARE POLICY REVISIONS, PROCEDURAL CHANGES, AND POLICY CLARIFICATION|
|This Memorandum discusses revisions and
clarification of policy relating to Child Care. Child Care Policy
changes are being made to prepare for FAMIS implementation. Other
changes are due to staff requests and information gathered from around
the state. Clarifications and reminders are based on questions we receive
from staff regarding policy that is unclear or procedures that were not
previously defined in writing.
This memorandum covers provider and household eligibility issues and policy. Implement new and revised policy with receipt of this Memorandum.
Effective immediately, request and verify:
PROVIDER REGISTRATION AND HEALTH/SAFETY CERTIFICATION FORMS
All system provider registration and health/safety certification renewal forms generated by FAMIS have new form numbers that begin with "FA" instead of "IM". FAMIS system generated forms have no Departmental tracking number, such as "MO-886-2834". Forms Management does not print FAMIS forms nor are they available from the Warehouse.
FAMIS combined the Provider Registration forms, IM-91 and IM-91A into one system generated form numbered as FA-350.
The Provider Health and Safety Certification form, IM-92, is system generated in FAMIS as FA-351.
INCOME MAINTENANCE FORMS
The current hard copies of the Provider Registration form, IM-91 and IM-91A, Health and Safety Certification form, IM-92, and Child Care Provider Voucher Payment Agreement, IM-93, remain in supply. Continue to use these forms to:
DVN (Departmental Vendor Number) SCREENING AND ASSIGNMENT
Duplicate DVN assignments are increasing, in part, due to insufficient clearing of providers and business names. Often, this duplication results in registration, authorization, invoicing, and payment problems. In addition, there are serious implications if a facility has been assigned more than one DVN. They may have their license or registration revoked or suspended under one DVN, and a county may accidentally authorize children with this same facility under a different DVN.
The same DVN should follow a provider regardless of vendor type. EXAMPLE: A licensed foster parent becomes a registered child care provider, then later becomes a licensed Family Home child care provider. This person would be registered as a foster care provider, then later licensed as a child care provider, using the same vendor number that was assigned initially with his/her foster parent license.
In order to reduce duplication; first clear the provider by using the provider's social security number or tax ID via VTXI or VNMI. If no matches are found, continue the clearing process using provider name.
Provider names are to be cleared using as many name variations as possible prior to assigning a DVN. Clear names using VNME and VNMA. Clear provider numbers through VNMI, VALL, and VPAR. Be sure to match the provider's address, SSN, or Tax ID number with data already in the DVN system.
When assigning a DVN, the provider's name is entered into the system using the following sequence: Last name, First name, Middle name, or initial.
When assigning a DVN to a facility or business name, enter the provider's name using proper sentence sequence; Granny's Little Angels.
Common names or names that can be easily confused should be entered as complete as possible, such as Mary Ann, Mary Lynn, etc. The following two examples are variations of provider/facility names using proper names and business/facility names:
EXAMPLE #1: Mary Anne Thomas:
Thomas, Mary Anne/Thomas, Mary A/Thomas, M AAlternate spellings:
Thomas, Maryann/Thomas, Marianne/Thomas, Marian/Thomas, Mary Anne, etc.Try to be as thorough as possible.
Mary's Little Lambs/Lambs, Mary's Little/Mary's Lambs/Little Lambs, etc.
Invoice errors have increased the number of CS-65's entered for payment. The majority of invoice errors result in payment delays causing additional work for staff and dissatisfied providers and parents. The majority of invoice errors are due to:
Initiate the household redetermination process thirty (30) days before the end of the eligibility or authorization period as indicated in the Income Maintenance Manual, Chapter XIII, pages 44-45. Mail IM-1CC's to households whenever possible. An in-office interview is not required.
Mailings of system generated FA-350's occur thirty days prior to the registration end date. Mailings of system generated FA-351's occur with the FA-350's when the health and safety certification end date and the registration end date are identical. Mailings of system generated FA-351's occur when the Health and Safety Certification end dates precede the Registration end dates. Supply IM-91 and IM-92 forms to providers when requested.
This section contains processes and resolutions for invoice errors caused by changes in a provider's status.
CHANGES IN A PROVIDER'S LEGAL STATUS
When the provider's status changes from license-exempt to licensed and system changes have not yet been made, the invoice printing program cannot determine which status is correct. This results in invoices printed with rates as $0.00 or blank rate fields.
No reports are generated to notify DFS of this change in status. DFS becomes aware of this change at the time the county initiates the daycare contract or child care registration process with the provider. It is important for county office staff responsible for daycare contracts and provider registration to communicate this change to the supervisor or county director for appropriate staff notification.
Once a provider's contract has been entered by Central Office Contract Management Staff, enter the child authorizations into the ICAU/ICEA system.
CHANGES IN FACILITY TYPE
Any time it is believed that a provider's facility type has changed, staff should check the Q135 licensing screen and/or the ZCVR contract screen. Compare the facility type on the previous registration or contract to the current facility type on Q135 and/or ZCVR. Examples of when it is appropriate to review a provider's facility type are:
For example a Family Home may increase capacity and become a Group Home. It is necessary to manually close the child's authorization for the previous facility type Family Home, and open a new authorization for the new facility type Group Home, anytime a change in facility type occurs. Failure to update the authorization in this manner results in invoice rate errors.
Immediately update authorizations to the appropriate service code as changes occur. Submit necessary payment corrections via CS-65.POLICY CLARIFICATIONS
PERSONS TO BE REGISTERED AS PROVIDERS
This is a reminder to staff to register the person that is actually providing the care. This applies to individuals as care providers, not facilities, organizations or businesses.
PARENTS AS PROVIDERS
A parent of a child(ren) cannot be a registered or licensed provider for his/her own children. This includes non-custodial parents, married parents living together, married parents not living together and unmarried parents of children needing care.
The next portion of the memorandum is specific to revisions and clarification of policies governing Child Care assistance such as household eligibility criteria, applications, budgeting, functional age of the child, waiting lists, hearing requests and interim changes.
HOUSEHOLD ELIGIBILITY CRITERIA
SOCIAL SECURITY NUMBERS
Federal regulations require verified Social Security numbers for all Child Care heads of households at the time of application.
Effective immediately, request the Social Security number for the Child Care head of household. Request payee social security numbers at redetermination for active cases and any pending applications upon receipt of this memorandum. Refer to any departmental computer screen that shows a SSN validation indicator of "V" verifying the number for the payee.
If the household cannot produce the social security number to the agency, allow the household the full fifteen (15) calendar days to apply for a number or replacement card. Request proof that the application for a number or replacement card has occurred. Do not deny Child Care assistance for failure to provide a social security number of the head of household until the end of fifteen working day processing time frame for Child Care applications.
Once the social security number or application for number/replacement card of the head of household is provided to the agency, the household has fulfilled this eligibility component.
When the social security number is received,
enter it into the common data area via the SUPD screen. The data
interface with the Social Security Administration verifies the number.
Reports are generated to the counties when the social security number or other personal data in the Departmental Common Area is in conflict with records of the Social Security Administration. If the social security number is not validated through the system interface, a report is generated to the county.
When the interface match is unsuccessful, request proof of the head of household's social security number using standard deadline procedures; IM-31A with a ten (10) day response time.
For households who do not provide the Social Security number or application for a number, deny Child Care services on the basis of the household's failure to cooperate.
Request social security numbers and assist applicants in obtaining social security numbers for other members of the household. Eligibility may not be denied due to failure to provide a social security number for anyone other than the head of household.
Residency is defined as living in the state on a voluntary and permanent basis. A family must reside in Missouri and intend to remain, at the time of initial application and reapplication in order to satisfy eligibility requirements for initial and continued Child Care benefits.
The applicant's statement verifies that the residency requirement is met. If residency is questionable, documentary evidence may be obtained.
Documentary evidence may include recent housing and utility receipts showing the applicant's name and current address.
JOINT CUSTODY HOUSEHOLDS
Current policy requires that the household composition income and medical insurance premiums of both parents be considered in determining Child Care eligibility for households practicing joint custody.
Effective immediately, consider the household composition, income, and medical insurance premiums of only the family unit claimed on the IM-1CC, Child Care Application form.
TEMPORARY ASSISTANCE HOUSEHOLDS
Effective immediately, households receiving a Temporary Assistance grant may receive Child Care Assistance without meeting the Temporary Assistance hourly work participation requirement.
For households who show a need for child care, but are engaged in an eligible component for a limited number of hours, the Child Care application will include a statement to show how Child Care Assistance supports the family's employability plan.
INTERIM CONTACTS AND BUDGET ADJUSTMENTS
Current policy states action on interim changes requires completion within fifteen days from notification of the change. Processing times for interim changes are revised in order to make Child Care consistent with other IM programs.
The revised policy requires caseworkers and case managers to take prompt action on all reported changes following the 10-10-10 rule. The customer has ten days to report changes in circumstances such as changes in employment or household composition. The second ten days, gives the caseworker or case manager ten days to obtain necessary verification, (e.g., sending an IM-12 to verify new employment) and to act on the reported change. The last ten days allows for the notice of adverse action, if appropriate. Changes to be reported by Child Care households includes, but is not limited to, the following:
EXAMPLE: A second parent moving into or out of the household may affect the household's eligibility for continued Child Care or the household's sliding fee amount. This may be due to a change in need for care or due to the change in considered income or household size.LOSS OF EMPLOYMENT/END OF JOB TRAINING
Any Child Care recipient,
CHILD CARE APPLICATIONS
A face-to-face interview is not required in order to determine the applicant's eligibility for Child Care assistance, (reference E-Mail Memorandum IM-20 dated April 15, 1993.)
Many interested and willing providers can facilitate the application process by helping parents complete the application forms and gather necessary verification. Supply the IM-1CC, Child Care Application to any provider, Resource and Referral agency representative, or other interested party requesting it.
Providers, Child Care Resource and Referral agencies, and Educare staff are viable resources available to facilitate the Child Care application process including the gathering of necessary proofs.
Release necessary case information to assist a provider in determining when to accept or continue care of a particular child. An example of this is a child's current or potential service authorization. Staff should use reasonable judgment in determining what is necessary information to assist a provider in their efforts and what is confidential household information.
EXAMPLE: Informing a provider that a child's benefits ended as no eligible need exists is acceptable. Informing a provider that a child is not eligible as the parent was fired from his/her job last Friday, is not acceptable.
MINOR PARENTS APPLYING FOR CHILD CARE ASSISTANCE
Under current policy, a minor parent is a parent under age eighteen (18). Minor parents claimed as dependent children on their parent's Temporary Assistance case, may not claim separate household status for Child Care purposes as the parent is claiming financial responsibility for that minor parent.
All other minor parents may claim separate household status from their parents. Minor parents living independently of their parents are not required to live in an adult supervised supportive living arrangement in order to qualify for Child Care benefits.
Post Graduate Study--For college students, a two or four year program resulting in an Associate's or Bachelor's Degree (in order to reach a stated employment goal,) is an eligible need for Child Care. College attendance for post-graduate study, such as to obtain either a Masters or Doctorate degree, is NOT an eligible need for Child Care assistance.
Parents in graduate study may qualify for Child Care based on another need for care such as employment. For these situations, applicants may be eligible for subsidy for the hours of employment, but not for the hours of school attendance.
PART TIME EMPLOYMENT
Eligible Child Care families engaged in part time employment meet the need criteria for Child Care assistance. There is no requirement that a parent be working full time in order to qualify for Child Care assistance. Appropriately authorize the child for services based on the parent's work schedule and income.
BUDGETING PROCEDURES FOR UNUSUAL HOUSEHOLD SCENARIOS
The parent may select a child care provider
who lives with them when the provider, and parent, of the child in care,
are in the same household composition for other assistance.
In situations where the Child Care household and the provider are considered separate households for other assistance, the Child Care subsidy and any parental co-payment is counted as income to the provider only. The Child Care household may claim, as an expense, any Child Care co-payment they pay out-of-pocket.
EXAMPLE #2: John and his child, Gary, live with John's mother, Jeanne, who provides child care as a registered provider. John and Gary are one Food Stamp household. Jeanne is a separate Food Stamp household. Budget child care income when determining Food Stamp eligibility for Jeanne. Allow John a child care expense for any out-of-pocket co-payments.
FUNCTIONAL AGE OF THE CHILD
Special Needs children may function at an age other than their actual age. They are eligible for care at the functional age as designated by their physician. If a child is designated as special needs, explore whether the child is eligible for payment at a different functional age level.
If medical documentation does not specify a functional age for a child, assume the child functions at their chronological age until further evidence is provided.
EXAMPLE: A physician certifies that a Special Needs child, aged ten, functions at the level of a child, aged one. At authorization, an entry in the functional age field of "IN" allows the worker to authorize the child for infant services, for example "CINF." This allows payment to the provider at the higher rate.
The special needs service code must match the functional age code, or an on-line error message appears "Functional age in conflict with SN child". The correct functional age must be reflected in the four character service code. (Refer to E-mail IM-67 dated April 30, 1999.)
Implementation of PRWORA offered additional funding that exhausted the "lack of funds" waiting lists, Memorandum #107, dated December 3, 1996. Families should not be placed on the "lack of funds" waiting list, at this time.
The "lack of provider" waiting list is not restricted. When using the lack of provider waiting list, determine the household's eligibility for Child Care assistance. Assign the appropriate code to the household based on type of case as follows:
07 - Determined Eligible (thirty (30) day time limit)NOTE: Place eligible Work First participants on the "lack of provider" waiting list when their four week job search cannot begin due to not having a provider. When a provider is located, authorize four weeks of Child Care services.
CONTINUATION OF CHILD CARE BENEFITS PENDING HEARING DECISION
As with other programs, households may receive Child Care benefits pending an appeal. Offer this option when a request for a hearing occurs. Record the household's selection on form IM-87, Application for State Hearing. Inform households that benefits received pending a hearing decision must be repaid if the Agency is affirmed. Offer this option, recording the household's decision on all appropriate forms until forms are revised.