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 and information for the following October 1, 2003 KEESM changes:

• Child Care Family Share Payment Enforcement - 1212.11, 7541, 7640, 10034.

• Special Purpose Rates for Child Care - 7600, 10021.1, 10260

• Direct Deposit for Child Care Providers - 10200

• Work Programs Community Service Component - 3310.3

• Verification requirements for purposes of the Food Stamp Program - 1322

• Legal immigrants under the age of 18 eligible for food stamps regardless of date of entry into the country - 2143.2

• Definition of a complete interim report form - 9122.6

I. CHILD CARE

SRS Enforcement of Family Share Payment

[See Summary of Changes, item IV, A. (1).] Effective with this revision, providers will have full responsibility to collect any family share, as with other fees owed by SRS clients. SRS will no longer have a policy of terminating/denying child care assistance if there is a family share amount owed by the client to the provider. This policy change does not relieve the client of their obligation to pay the family share. Providers will need to apply private pay collection practices to SRS clients as needed. Providers should be referred to their local Child Care Resource and Referral Agency for guidance in establishing/enforcing such business practices. Workers will no longer be required to screen new applications for outstanding family share debt prior to determining eligibility. Workers will not be required to act on information of family share non-payment obtained from the time sheet.

The SRS Mission is to protect children and promote adult self-sufficiency. Workers should feel free to discuss non-payment implications with the client if there appears to be a problem. Non-payment for services provided may effect the client’s ability to stay employed (self-sufficient). Child care providers are a business, and need to be paid in order to stay in operation. As with any other non-payment situation people encounter in life, if payment for service is not made then the provider may choose to end services. Families may be reminded of the consequences of losing services from a child care provider. These may include inability to maintain employment and negative effects on the child if pulled from the familiar caregiver. Families should be referred to the local Child Care Resource and Referral Agency, if needed, for further information on the importance of stable, quality care on their child’s development (protect children). Child Care Resource and Referral Agencies will be copied on this memo, and will be ready to assist any family or provider as needed.

System Issues - Due to limited IT staff availability and competing priorities within IT, no system changes will be made due to this policy change. There will be no mass system notice informing clients/providers of this change. Since there will not be a mass notice informing providers of this policy change, a sample letter is being provided to areas and is attached to this memo. The sample letter may be used by areas and contains information on all policy changes included with this revision. In addition, providers have been notified of policy changes included in this revision via R&R newsletters. These newsletters go out at differing times from R&R’s, however, by October 1, 2003, all newsletters containing this information will have gone out.

The system generated time sheets will still contain a space for providers to report whether or not the family share has been paid. This space will be removed from the local time sheet however, as that would not require programming. Providers may choose to report or not. The agency will not act to close a case based on this information. The time sheet shall be processed by the payment clerk. The clerk is required to make an entry on REPC reflecting whether or not the family fee has been paid. Effective 10-1-03, the clerk should always enter a "Y" in the Paid Family Fee field on REPC. Entering "Y" or "N" does not impact the amount of payment made to the provider. It was there only to support the policy which is now being eliminated. Entering "Y" rather than "N" will avoid system generated alerts. Staff are reminded that this procedure will not impact current policy related to the Food Stamp Program dependent care deduction. For Food Stamps, only the obligation to pay dependent care must be verified and documented in the case file. The fact that the consumer has a family share is adequate documentation to allow the dependent care expense.

The C501 Family Fee notice on KsCares will be end dated 9/30/03. The Child Care Plan will be revised by removing the statement "Client failure to pay the family fee may cause the client to lose eligibility for child care services." This statement will be replaced with "Client is responsible for family fee payment. Provider is responsible for family fee collection." KsCares case closure code CC FF - Family Failed to Pay Family Fee is being removed.

Special Purpose Enhanced Payment Rates

[See Summary of Changes, item IV, A. (3).] Special Purpose enhanced payment rates for children with disabilities will now be available for providers other than child care centers. Historically, Special Purpose child care was available only through service provided by a licensed Special Purpose child care center and the enhanced payment rate was provided. In 1999, centers other than licensed Special Purpose centers could request the enhanced Special Purpose payment rate based on the child’s needs and the provider’s ability to give proper care. Effective with this revision, any family/provider may request the enhanced Special Purpose payment rate for a child with a disability. See June 23, 2003 CC Special Purpose Rate memo posted on the EES Intranet at http://www.srsnet.srs.ks.gov:5003/ees/PolicyProc/memo_index.htm. The Special Purpose enhanced payment rate continues to be available under any child care subtype. (Staff are reminded that Special Purpose payments are not necessarily associated with the SS child care subtype.) Making this enhanced rate available to any provider allows the parent to choose where the child will be cared for and also makes it possible financially for the provider to give the level of care the child needs. If staff are aware of a situation with a child eligible for subsidy where an enhanced rate may be needed, they are encouraged to put in a request. These will be reviewed on a case-by-case basis. The ES-1627a Request for Special Purpose/Special Needs Provider Child Care is being revised to support this policy change. The original memo implementing this change is attached. Jean Morgan is the Central Office contact person on this issue. Due to the current age groupings on the Maximum Hourly Child Care Provider Rate chart and KsCares programming, there will be special implementation instructions for this expansion.

For child care centers needing to access the enhanced Special Purpose rates, current policy/system work will apply.

• There needs to be a "Y" in the Special Purpose Indicator field on PRRA. The appropriate Special Purpose rates ($7.05, $7.37) need to be entered on PRRA.
  
  
• CAMA must indicate an IP plan type as entered on CHCI. And the Spec Purp Rate field on CHCP must have a "Y".
  
  
• This Special Purpose rate can be paid for a maximum of 4 hours per day. If care is needed for more than 4 hours per day, a second plan is to be set up using the regular/special needs rate. Special Purpose rates available to centers are $7.37/hr for children under 2.5 years and $7.05/hr for children over 2.5 years.

For home providers needing to access the enhanced Special Purpose rates, the following system work will apply.

• There needs to be a "Y" in the Emergency CC Ind field on PRRA. (Areas do not need to input special purpose rates as the appropriate rates will be entered onto a table by Central Office staff).
  
  
• A new field has been added to CHCP. This field is the Enhanced Rate field (previously know as Emergency CC field). There needs to be a "Y" in this field in order to trigger the enhanced Special Purpose rate for home providers.
  
  
• This Special Purpose rate can be paid for a maximum of 4 hours per day. If care is needed for more than 4 hours per day, a second plan is to be set up using the regular/special needs rate. Special Purpose rates available to homes are $7.37/hr for children under 18 mos and $7.05/hr for children 18 mos and over.

It is intended that the rates be flat rates paid to providers. The provision that the state not pay more than the private sector charge would not apply to these rates. The Americans with Disabilities Act (ADA) prohibits providers from charging a higher rate to serve a child with a disability. Child Care and Development Fund (CCDF) regulations recognize that providers do incur a greater expense in caring for a child with a disability, so do allow higher payment to be made through the subsidy program.

The Maximum Hourly Child Care Provider Rate chart has been revised indicating the enhanced rates now available. These rates are available for clients/families under any subtype.

Direct Deposit Requirement

[See Summary of Changes, item IV, A. (2).] Direct Deposit has been optional for child care providers for several years. Many providers already take advantage of this service. Effective with this revision, providers will be required to receive payment via direct deposit. There are two reasons for this policy change. The state, in general, is trying to take advantage of available technology and move away from paper issuances (such as checks). With Direct Deposit, providers will continue to get the remittance advice that they currently receive with each check. Rather than getting an actual check however, they will get a stub listing how much money was deposited into which bank account. Also, the state has made the official decision to put child care benefits on EBT. EBT CC is targeted for June 2005. Once this is implemented, providers will only be able to receive payment electronically. Making the direct deposit requirement now will allow providers to become accustomed to this technology and will also allow the state to identify and work through any barriers related to direct deposit. If a provider has difficulty meeting this requirement (cannot get a bank account), they should not be denied payment. The ability for the state to issue checks will still be available and should be used while investigating the issues. A form has been developed and should be used by field staff to notify Central Office about specific situations where providers are unable to meet this requirement. The form should be sent as an attachment to earlylearning@srskansas.org. Once the specific barriers are known, the state will be able to begin pursuing solutions.

Implementation of this requirement for existing providers will begin 10/1/03. It is not expected that field staff convert all providers at once. Field staff are allowed discretion in notifying and converting providers as soon as possible given workloads. Existing providers not enrolled for Direct Deposit will continue to receive payment by check until Direct Deposit enrollment is complete. A report will be made available listing providers who are and are not signed up for direct deposit. These reports will be available monthly. They can be used by field staff to identify which providers need to be signed up. Areas may also request mailing labels. Request for mailing labels should be directed to Steve Ferrier. Whether a provider already has direct deposit can be determined by doing a vendor inquiry through FARMS, which is currently available to Administrative staff in the areas.

A sample letter is being provided to the field and may be used to explain the various October 2003 policy changes including direct deposit. Providers have also been informed of these policy changes through R&R newsletters. The DA-130 should also be sent to providers needed to sign up. Providers should be instructed to return the DA-130 to the field office. Field staff should then review the document for completeness in a similar way Provider Enrollment requests are reviewed (i.e. - making sure names match, all fields are completed). Names and information on the DA-130 should correspond with the name on the Agreement, W-9, etc. Providers should be encouraged to attach a voided check rather than a deposit slip, if at all possible. However, one of these documents must be attached to the request in order for it to be processed. The original documents should then be forwarded to Topeka at the address indicated on the attached cover letter for processing. The provider enrollment packets are being updated with this revision. The enrollment documents state that direct deposit is required. The DA-130 is now included in the actual enrollment packet. The DA-130 will be returned to the field office as part of the application. Upon provider approval, the original DA-130 should be forwarded to Topeka. Additional confidentiality procedures would not be required due to this change, however, staff do need to ensure that banking information is accessible only to staff who have a need to know.

Providers wishing to make a change to an existing direct deposit arrangement may contact either the field office or Central Office Payables to initiate the needed change.

Providers who are able, but unwilling to receive payment via Direct Deposit should be informed of the reasoning behind the requirement (more efficient for the state than issuing checks, EBT CC in 2005). If, after this conversation, the provider continues to display an unwillingness to comply with the requirement, the area can move toward termination of the Agreement.

II. WORK PROGRAMS

Community Service

[See Summary of Changes, item VIII, A. (2).] Community Service is a primary component under current policy and it is anticipated that it will be a core activity under TANF Reauthorization legislation. Current policy includes AmeriCorps, VISTA and court ordered community service as part of sentencing through the Department of Corrections as activities that may be counted as Community Service work participation. Effective October 2003, the definition of activities that can be considered work participation under Community Service is being expanded to allow more flexibility. TAF parents may be active in church, children’s schools, volunteer work required by public housing, Heartland Shares and other community involvement. This policy modification will allow these types of volunteer activity to count toward meeting the work participation requirement. Volunteer hours countable under the Community Service component should be related to the clients progress in achieving the individual’s maximum level of independence.

EES Management Areas will establish Community Service progress reviews and verification requirements. A reporting form is being developed for use by areas which wish to utilize it.

Interest has been expressed by some areas in the development of a contracted employment service description so that the activity of developing volunteer activities and monitoring clients participation and progress in this activity would be performed by a contracted employment service provider. This is being developed.

Volunteer hours countable toward meeting the work requirement are limited to 25 hours per week. In-home activities (i.e., home schooling) cannot be considered volunteer hours countable as work participation.

III. Food Assistance

Verification Provisions for Food Stamps

[See Summary of Changes, item V, A. (1).] Section 1322 has been modified to provide more extensive verification requirements for purposes of the Food Stamp Program. Additional requirements are included for earned income, shelter expenses and the claim of separate household status. It is important to note that the draft statewide Earned Income Worksheet and revised Purchase and Prepare Statement that were in the Phase I draft manual material have been removed from the final manual material. It was felt more user input was needed before the forms could be mandated for statewide use. A workgroup of staff from the Implementation Planning Team and local field staff will be working on a statewide Earned Income Worksheet and a revised version of the Purchase and Prepare Statement. Until such time as a statewide Earned Income Worksheet is available, please continue to use any locally developed forms. The FP-1013, Purchase and Prepare Statement shall also continue to be used until a revised form is developed. Once forms are drafted, they will be routed to the field for comment.

Qualified Non-Citizen Status for Food Stamps

[See Summary of Changes, item V, A. (3).] Effective October 1, lawful permanent residents under the age 18 are eligible for food stamp benefits regardless of the date of entry into the U.S. This change primarily affects legal immigrant children who have not been in the country for five years. As long as the child is a lawful permanent resident, they become eligible for food stamps effective October 1. See the Non-Citizen Qualification Chart (item 1) in the Appendix for details regarding documents that verify this status. Refer specifically to items 7 and 17.

The new policy shall be applied to all applications received or processed on or after October 1, 2003. For ongoing cases, children determined to be eligible under the new rules must be added to FS cases by the November benefit month. A printout will be issued on 9/24/03 to the Chiefs which lists all persons under the age of 18 (as of 9/30/03) who are coded DI (and apparently a few coded DF) on SEPA and who have a citizenship code of anything but "US". There are 325 open cases with 476 potentially eligible children. The vast majority are coded IA. The report is sorted by Area/Worker/Case name with each Area starting on a new page. Staff must review the cases on this printout, and if the children are now eligible for food stamps, add them to the FS case by the November benefit month. Staff should also be reminded that the correct coding for an ineligible non-citizen is DI, not DF.

It is also important to note that eligibility ends once the child turns 18, unless they qualify under another non-citizen eligibility criteria. Loss of eligibility, if appropriate, shall be effective for the month following the month the child turns 18 allowing for timely notice. (Processing this change is required since the fact that the child is now 18 is information known to the agency.)

Interim Report

[See Summary of Changes, item V, A. (4).] Section 9122.6 has been modified to include a definition of what is a complete interim report. These provisions are based on the former provisions used for monthly reporting. See the above section of the manual for a description of a complete interim report. Since implementation of simplified reporting, questions have arisen about when to register the interim reports on RERE. Should they be registered when received, but not complete? Or only registered when they have been received and complete? Because the registration of interim reports is not as sophisticated as the registering of monthly reports, it is recommended that interim reports be registered only when they are complete. This will insure that cases are closed timely when the interim report is received incomplete, is subsequently returned to the consumer for completion, and is not returned by the IR close deadline.

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Attachments:

ES-1627a
Maximum Hourly Child Care Provider Rate Chart
Sample Informational Letter for Providers
Request for Special Purpose/Special Needs Provider Child Care
DA-130 and cover letter

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