This memorandum covers provider and household eligibility issues and policy.  Implement new and revised policy with receipt of this Memorandum.

PROVIDER ISSUES

NEW POLICY

Effective immediately, request and verify:

• Date of birth;
• Social Security numbers for persons; or,
• Federal or state tax identification numbers for businesses or organizations, who are registering as child care providers. This applies to new registrations and renewals.  Do not renew registrations without proof of the provider's Social Security number.

PROVIDER REGISTRATION AND HEALTH/SAFETY CERTIFICATION FORMS

FAMIS 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:

• Register new providers, and
• Re-register current providers who do not have a system generated renewal form.

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:

1. Clear provider name through VNME using name variations, beginning with the last name:

Thomas, Mary Anne/Thomas, Mary A/Thomas, M A

Alternate spellings:

Thomas, Maryann/Thomas, Marianne/Thomas, Marian/Thomas, Mary Anne, etc.

Mary Anne Thomas/ Mary A Thomas/M A Thomas, etc.

Try to be as thorough as possible.

2. When no match of name or Tax number is found, assign DVN typing the sequence of Last name, First name, Middle name.

1. Clear facility name with as many name variations as possible:

Mary's Little Lambs/Lambs, Mary's Little/Mary's Lambs/Little Lambs, etc.

2. When no match of the facility name or Tax number is found, assign a DVN using proper sentence sequence of:  Mary's Little Lambs.

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:

1. the household's eligibility and/or authorization expired, 

 
2. the provider's registration and/or health and safety expired, or, 

 
3. the provider's status changed.

1. REDETERMINATIONS OF ELIGIBILITY AND AUTHORIZATIONS 

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. 

2. RENEWALS FOR REGISTRATION AND HEALTH AND SAFETY 

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.

Reports sent to the county offices notify staff when to anticipate household or provider changes.  The Child Care Caseload Report (Report number FCRWA040-01) and Authorizing Worker Reminder Report (Report number FCRWA070-01) contain eligibility and authorization data that is crucial for successful caseload management.  In particular, the Authorizing Worker Reminder Report lists eligibility expiration dates three months in advance.  It lists contract expiration dates two months in advance.

With this available information, renewal data of the household and provider can be entered timely.

3. PROVIDER STATUS CHANGES

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 a Registered/License-exempt provider chooses to become licensed, and their approved license status appears in the Q135 system:

Close the provider's registration and health and safety certification;

Close the children's authorizations in ICCR; and,

Initiate the contract process with the provider.

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:

• At registration or re-registration;
• At initial, or renewing contracts; or,
• At any time a report is received that there are no rates or incorrect rates printed on the provider's invoice.

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.

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. 

• Under no circumstances is the parent of a teen care provider to be registered as the provider if that parent is not providing the care.

 
• Do not register two persons as one provider.  The provider must designate which of the two is the primary caretaker of the children.  The designated primary caretaker of the children may not be employed elsewhere during the hours the children are in their care.

 
• Individuals registered as child care providers may not "subcontract" with another party to provide the care paid by subsidy dollars.

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

NEW POLICY

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.  This
process takes approximately ninety (90) days.

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

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.

REVISED POLICY

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:

• changes in the type, source, amount, frequency, income of any member of the family unit,

 
• a change of child care provider,

 
• changes in the need or hours of care, or

 
• changes in household composition, and resulting changes to the households eligibility due to the addition or loss of a member of the family unit.

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.

Any Child Care recipient,

1. whose job training ends, or
2. who loses employment,

POLICY CLARIFICATIONS

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.) 

PROVIDER CONTACTS

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.

STUDENTS

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.
Disregard:

• Child care income that passes between household members; and
• Child care expenses incurred between household members,

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.)

WAITING LISTS

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)
08 - Special Needs/Very Low Income
11 - BG Eligibility Type

Codes 09 and 10 are now obsolete.

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.

• Review this Memorandum with appropriate staff and retain for reference.

 
• Effective immediately, implement policy revisions and clarifications with receipt of this memorandum.

 
• Continue to initiate steps necessary to ensure there is no lapse in services to children or providers due to system updates or budget adjustments not being completed in a timely manner.

 
• Continue to thoroughly screen provider names with the Departmental Vendor system prior to assigning new DVN's as indicated.

 
• Assign new DVN's as indicated.

 
• Make Child Care applications available at every opportunity.

 
• Continue to initiate and accept applications for Child Care assistance filed by mail, in person, or through the help of the provider.