EEC Financial Assistance Regulation and Policy Reform November 2010 1.
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Transcript of EEC Financial Assistance Regulation and Policy Reform November 2010 1.
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EEC Financial Assistance Regulation and Policy Reform
November 2010
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EEC Financial Assistance Regulation and Policy Reform
EEC Subsidy Regulations last updated in November 2006
Policy Guide developed and released in July 2007
“Question and Answer” document added to the Guide in 2008.
Several updates issued through EEC Management Bulletins (EMBs) and email messages from the Commissioner reflecting new or edited policies.
Beginning in December 2009, updated policies issued through EMBs were directly incorporated into the Guide, including an Amendment Log that identifies effective date, a summary and the prior policy that it amended or replaced.
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EEC Financial Assistance Policy Guide – Table of Contents
Chapter 1: Eligibility
Chapter 2: The EEC Centralized Waiting List for Financial Assistance
Chapter 3: Documentation of Eligiblility
Chapter 4: Service Need
Chapter 5: Parent Co-Payments
Chapter 6: Reassessment
Chapter 7: Terminations and Reductions
Chapter 8: EEC Financial Assistance Complaint and Investigation Process
Note: EEC Subsidy Regulations at located at 606 CMR 10.00 et seq.
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EEC Financial Assistance: Challenges and Issues
As EEC providers, CCR&Rs and internal staff have used the Guide, issues were identified, including:
Documentation of eligibility requirements Outdated and confusing policies Existing policies outside of the Guide (recently
added as “appendices”) Misalignment with subsidy regulatory requirements Capability to verify programs’ determination of
financial assistance eligibility (fraud/waste/abuse)
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Proposal: Update and Amend EEC Regulations and Policies
Many factors contribute to the necessity of updating the Guide including: Improper Authorizations for Payment (IAP) exercise
results Response from ACF regarding our State Plan Unique challenges/ weaknesses identified due to recent
fiscal constraints/ system restructuring• (e.g., ongoing closure of, or limited access to, EEC
financial assistance)
CCR&R Feedback Confirms need to improve Financial Assistance Polices,
including the Request for Review process, Recoupment procedure, and Documentation requirements
Raises other concerns regarding improving Communication (w/ EEC, DTA and DCF staff)
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Changes Required as a Result of the Improper Authorization for Payment (IAP) Project
Citizenship: EEC must verify the US citizenship or immigration status of children who receive CCDF-funded services* All entities performing CCDF-funded child care subsidy
assessments must obtain and maintain documentation of U.S. Citizenship of the child, before authorizing payment
Fees: EEC cannot categorically waive the fees. (e.g., per CCDF regulation if a teen parent earns enough must be assessed a co-payment).
Recoupments: IAP project highlighted some existing challenges in our regulations and policies in recouping funding improperly authorized
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Changes Required as a Result of ACF Commentary on the Massachusetts 2010-2011 CCDF State Plan
In order to be eligible for CCDF-funded child care services, children must:
Reside with a family whose income does not exceed 85% of SMI; and
Reside with a parent or parents who are working, or participating in job training or an education program , or are receiving or need to receive protective services .
In reviewing the MA CCDF State Plan, ACF identified two instances where EEC regulations and policy may not align with these mandatory requirements:
Children with Special Needs – 1) allowing children to remain in care up to 100% SMI and 2) allowing a categorical waiver of the work, education and training requirement for families w/ children with special needs.
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.”
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Changes Required as a Result of ACF Commentary on the Massachusetts 2010-2011 CCDF State Plan
CCDF regulations do allow states some flexibility:
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).
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)
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Other Financial Assistance Policies Needing Clarification or Presenting Unique Challenges
In addition to the issues identified through the IAP process and the ACF comments received on EEC’s state plan, EEC has been:
tracking questions/ issues as they arise, spotting recurring issues through the
Review/ Appeal process,conducting a wholesale review of the
manual and updating it by creating a red line version; and
reaching out to stakeholders (e.g., providers, R&Rs) to identify other problem areas that need to be addressed.
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Overall approach: Prioritize what we can do now, and what can wait
Identified issues have been categorized into three groups:
“quick fixes”– pressing issues that need immediate attention and can be fixed through EEC policy clarifications
“long term fixes”- issues that will be addressed either through regulations changes and/or the development of data exchanges
Interagency work– enhance communication between/ among EEC, DTA, DCF and R&Rs.
The following slides detail the policies that have been updated, as well as those that require regulation changes, data exchanges or interagency work
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Examples of other policy updates requested & status
Quick Fixes – Policies Updated Long Term Fixes – Regulation Changes or Data Exchanges Needed
Break in service need of parent
Eligibility self reporting “significant changes” in income (20% rule)
Travel time for calculation of service need
Waitlist management enhancements
Redraft Provider voucher manual and agreement (Jan roll out)
Identity/ legal immigration status documentation
Codified Variance Process
Special Need Forms (Child/Parent)
Self Employment Verification
Special Need Access Regulations
Streamline Review Process
Child Support Requirement
Second parent in Household
Clarify Recoupment Process
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
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Key
= Policy issue reviewed and updated = Policy issue reviewed and requires regulation change to update
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Examples of Interagency Work to Enhance Communication/ Business Practices (DTA)
A review of DTA and EEC business processes is underway to review and adjust practices including:
Ensuring DTA authorizations comply with EEC requirements Example: DTA staff authorize part time or full time
child care for families that don’t meet the EEC minimum work/ education requirements
Ensuring better communication between DTA staff and R&Rs Example: “1D” clients need to start paying fees
when their cases close• if DTA staff would “cc” R&Rs on parent 1D
letters should not only help reduce the number of requests for EEC reviews, but will also help minimize parent debt accrual/ EEC recoupments for parent fees
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Examples of Interagency Work to Enhance Communication/ Business Practices (DCF)
EEC/ DCF MOU developed to address a range of issues including:
To ensure smooth transitions from Supportive Child Care to Income Eligible
• Parents don’t understand EEC service need requirements, which creates stress for parents and increased R&R time to help parents produce supporting documentation
To ensure DCF Foster Parents have appropriate expectations regarding access to EEC financial assistance including service need
• Enhanced communication for variance process• May need to create a DCF foster care voucher at IE
rate vs. supportive rate• 6 month case continuity for DCF supportive families
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Financial Assistance Policies RequiringRegulation Changes
Many identified changes can be made by revising the Policy Manual, however, some changes are necessary to EEC’s Subsidy regulations:
“Special Needs” of parent and/or child definitions to ensure compliance with federal child care laws
Updates to EEC Review Process regulations• Dismissals for failure to prosecute and failure to
exhaust administrative remedies• Clarify appropriate grounds for appeal• Clarify documentation requirements
Clarify recoupment appeal process
Excessive absences
Require data checks to verify eligibility (e.g., DOR, RMV or other agency systems)
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Proposed Regulation Promulgation Timeline
Tasks Date
Vet Regulation Changes with Providers/ CCR&Rs; continue to make policy changes/ clarifications that do not require regulation changes
Ongoing
Board reviews first draft of proposed regulation changes; Committee discussions
December 2010
Board vote to put regulations out for public comment
January 2011
Public comment period; meetings with providers/ advocates
January- February 2011
Board vote to promulgate regulations;Roll out implementation/ trainings
March 2011
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