State of Kansas Department of Social and Rehabilitation Services
Gary Daniels, Acting Secretary

Integrated Service Delivery - Candy Shively, Deputy Secretary (785) 296-3271
Economic and Employment Support - Bobbi Mariani, Director (785) 296-3349

MEMORANDUM

This memo provides implementation instructions for the September 2005 revision to the Kansas Economic and Employment Support Manual (KEESM). Staff are encouraged to ask questions after implementation as this revision contains information for child care benefits on EBT which is a major program change. Information on the following aspects is contained in this memo:

1. Effective date of statewide EBT CC implementation and implications;
2. Impact on clients;
3. Impact on providers; and
4. Overpayments/Canceling CC benefits on EBT

Staff may also refer to previous information released on this project, including EBT CC Centra materials, EES intranet, KsCares training material and user manuals and internet information, and parent and provider training videos.

1. Effective dates of EBT CC - Statewide implementation will begin September 1, 2005. Pilot areas began June 1, 2005. Staff in the statewide areas are encouraged to collaborate with pilot area staff and Central Office during the initial months of the change. On September 1, 2005, client benefits for child care will be available for the client to purchase September care. August care (and any unpaid months prior to August) will be paid by SRS directly to providers via time sheets.

   Beginning September 1, 2005, EBT will be the state standard for delivery of child care benefits. Any child care subsidy payments made outside of the EBT system will require Central Office approval.

   In-Home Care - All child care plans using In-Home care and being paid to the client shall end no later than August 31, 2005. New plans for the case shall begin September 1, 2005 using the actual provider of care as the provider on the plan. Under EBT CC, providers hired by clients to give care in the child’s home will be treated like other providers. This means the actual provider (not the client) will need to be put on KsCares and enroll with eFunds Corp. Child care plans authorized on CHCP will use the actual provider, and this provider will need to be able to accept payment for services electronically.
   
   Reports on SAR - Three reports will be available to staff for case management.

   • Provider Not Paid Report - This report will contain case level information. The report will indicate if a provider who was expected to be paid for a month (had a plan authorized) was not paid at all.
     
     
   • New Provider Paid Report - This report will contain case level information. It will indicate if a new provider was paid that month (no plan was authorized with that provider).
     
     
   • Large Balance Report - This report will contain case level information. It will indicate if a case has a large balance left over from a previous month.

   KsCares notices will be available to assist staff in addressing possible issues that may be presented on these various reports. Staff are encouraged to provide feedback on the usefulness of the reports and any desired modifications. The first report may indicate that the client’s needs have changed and they no longer need child care subsidy. The second report may indicate that a provider change has occurred that was not reported. The third report may indicate that the client or provider is struggling with paying through the new system, benefits need to be adjusted or child care subsidy is no longer needed. When staff see cases on these reports, they should decide if further investigation is needed. Staff should contact the client to obtain any information needed.

2. Client Impact - With the change to EBT CC, child care subsidy will be a monthly benefit similar to cash and food stamps. Clients will need to discuss payment schedules and fees with their provider(s). SRS will not tell clients when to pay their provider or how much to pay. If the client exhausts benefits for one month, they will not receive benefits again until the next month. Parents will pay the provider through either a provider’s POS machine or through the toll-free telephone option (ARU). An ARU Worksheet (ES-1605) is available to parents/providers to document payments that are made over the phone.

   Clients and providers will continue to receive Child Care Service Plans. In addition, clients will receive a Family Plan each month. This Family Plan itemizes the lump sum monthly benefit they see on the card. This Family Plan will be sent at the beginning of the month prior to the benefit month. This will allow the client time to report any changes in hours/benefits needed for the next month. Clients will be responsible for insuring that hours of need are communicated to the worker. A Child Care Plan Hours Worksheet will be available in the KEESM Appendix. It will help staff document child care hours needed for the benefit. School-age children may be especially difficult to calculate appropriate hours. Clients should be responsible for supplying the necessary information (i.e., - school schedules). Staff are allowed discretion when calculating benefits for school-age child needs. Some staff may choose to average hours needed over the school year to supply a continual subsidy to be used toward the purchase of care. Staff should discuss this option with the client and document in the case file. Staff are reminded that child care plans may be as long as 12 months, but may be shorter. Staff discretion is allowed as long as shorter plans do not create a hardship for the client.

   An interview is strongly recommended. Ideally, this should be done at application. An interview allows the worker to educate the client on responsibilities, use of the subsidy, and how to pay the provider. It is understood that face to face interviews are often difficult with a working population. A face to face interview may be waived in lieu of a telephone interview. If neither are feasible, the interview may be waived. Documentation should be included in the case file.

   EBT card issuance procedures in place for cash/food stamps shall be applicable for child care as well. Viewing the training video and allowing the client to ask questions is optimal, however, mailing cards with remote PIN selection instructions is acceptable. A KsCares notice, C120, is available for use with mailing cards and remote PIN selection. A KsCares notice, C107, is also available for use with clients who already have a card, but are adding child care benefits. Whenever a card is issued, either through the mail or in person, the client should be given the How to Use Your Vision Card for Child Care Benefits brochure. They should also be informed of how to contact the agency if they have questions.

   Under EBT CC, the family share takes on a new meaning. The agency will no longer restrict providers to only charging clients what SRS pays. Per federal regulations, the agency must assign a sliding fee (family share). This family share is deducted from the estimated cost of care before the benefit is issued to the client. The client then uses this benefit toward the cost of care each month. The benefit plus the family share deducted may still not cover the full cost of care depending on the client’s provider choice.

3. Impact on Providers - Providers will need to have business practices in place and be able to communicate payment rules to clients. SRS will no longer pay providers directly. Providers will need to keep their own records for tracking payments from parents and for taxes. Providers will no longer get a form 1099 from SRS every year. Providers will get a 1099 from SRS in February 2006, but it will only contain state payments made in 2005 prior to EBT CC implementation. Along with being enrolled by SRS, authorized providers will also need to enroll with eFunds Corp. in order to receive electronic payments from parents. Checks/direct deposit from the state can only be authorized with Central Office approval. Providers unable/unwilling to get a traditional checking/savings bank account should request information on a cash pay/pay card option. Many banks and credit unions have options available for people who need to receive a payment electronically. In-Home providers are included. The actual In-Home provider will need to be able to receive payment electronically. Providers are encouraged to seek assistance from the local Child Care Resource and Referral agency if they need help setting up business practices.
   
   
4. Overpayments/Canceling EBT Benefits - Initially, KsCares will not have a benefit reduction option for recovering client overpayments. If there is an overpayment to a case, it should be processed and put on KsCares. The methods of recovery are as follows: direct payment by the client to the agency, client authorization to repay using existing benefits, state Debt Set-off (i.e., - tax refunds). A child care benefit reduction option is currently in the design phase.

   In some cases, unused benefits can be cancelled on the EBT system. This would remove the inappropriate benefit from the case, hence not allowing it to be used and preventing the need for establishment of a client overpayment. Procedures for canceling EBT benefits can be found in KEESM 1513.5. The following lists situations where this option could be utilized:

   • Incorrect payment due to system error. Example - There were a few situations during pilot when KsCares issued benefits inappropriately. They were issued as a result of the way that worker input information, but still should not have issued by the system. Helpdesk was notified and those problems were fixed. Since the client was not expected any of the extra benefits (system error), those benefits were cancelled on the EBT system.
     
     
   • Duplicate payments. There were times during pilot when workers would inadvertently set up duplicate child care plans on the system. This is sometimes done when vacant caseloads are being covered and staff do not realize plans have already been done or if staff do not pay attention to CHCM to see that plans have been authorized. This also creates extra benefits that the client was not expecting. The duplicate benefits could be cancelled on the EBT system.
     
     
   • Client request to prevent an overpayment. In the case of a pure overpayment (i.e. - client did not report timely, worker calculated income incorrectly, etc.), if the client has not used the benefits so they remain on the card, the client can request in writing that the overpaid benefits be cancelled in order to prevent an official overpayment.
     
     
   • Extenuating circumstances. Since EBT CC is new, there may be more situations that come up that may require benefit cancellation. If a worker feels that benefit cancellation would be the best way to remedy a situation, the worker can request supervisory and Child Care Policy Manager approval for cancellation.
     

   All other incorrect payment situations are considered overpayments unless benefits are not used and age off of the EBT system.

Staff are encouraged to pursue any needed clarifications through the appropriate channels. As staff become accustomed to the new EBT CC system, they are encouraged to develop program improvement options to be considered by Central Office management and other Regions.

BM:MSW:jmm

ATTACHMENTS: Child Care Changes Side by Side