CCMTL 142 (Rule Changes for the Implementation of a New Automated Child Care Attendance Tracking and Payment System for Publicly Funded Child Care)
Child Care Manual Transmittal Letter No. 142
December 10, 2018
TO: All Child Care Manual Holders
FROM: Cynthia C. Dungey, Director
SUBJECT: Rule Changes for the Implementation of a New Automated Child Care Attendance Tracking and Payment System for Publicly Funded Child Care

Background

In 2011, the Ohio Department of Job and Family Services (ODJFS) implemented an electronic child care system to track attendance and calculate payment to providers for the delivery of publicly funded child care (PFCC) services.

ODJFS has identified the need to enhance and improve how Ohio tracks publicly funded child care attendance and calculates payment to approved child care providers. These rules implement the new automated child care system.

New Policy

The new system no longer utilizes the Ohio Electronic Child Care (ECC) cards nor the point of service (POS) devices. Instead, a mobile application is available for use on tablets and smart phones for parents to enter attendance at the child care program.

The following rules and forms will be effective December 16, 2018.

Amended Rules:

5101:2-16-01 "Definitions for Eligibility for Publicly Funded Child Care Benefits" has been amended with the following changes:

  • "Automated child care system" has been defined
  • "Back Swipe Period" has been removed
  • "Designee/Sponsor" has been defined
  • Added border state provider to "eligible provider"
  • "POS device" has been removed
  • "Professional development day" has been defined
  • "School child" has been amended to "School-age child"
  • "School not in session" has been defined

5101:2-16-07 "County Agency Responsibilities for the Administration of Publicly Funded Child Care" has been amended with the following changes:

  • The manual claim, payment after denial and payment adjustment procedures for county agencies have been removed because the county agency no longer processes them
  • County agencies are required to follow procedures determined by ODJFS during the transition to the new automated child care system

5101:2-16-30 "Eligibility Requirements for Receipt of Publicly Funded Child Care Benefits" has been amended with the following changes:

  • The revision dates of the PFCC applications have been updated to December 2018
  • Federal work study assignment has been added to the definition of post-secondary education activities
  • Post-secondary activities have been clarified
  • Job skills training activities have been clarified and updated to include workforce inventory of education training (WIET) provider(s) as possible approved activity when the training provider has been approved by ODJFS
  • Transitional child care has been clarified
  • Protective child care has been amended to clarify that there is no income or qualifying activity requirement
  • Homeless child care has been defined in a new paragraph

5101:2-16-35 "County Agency Responsibilities for Determining Eligibility for Publicly Funded Child Care Benefits" has been amended with the following changes:

  • The requirement for county agencies to approve PFCC payment after denial has been removed
  • References to ECC were replaced with "automated child care system"

5101:2-16-35.1 "Caretaker Eligibility Requirements to qualify for publicly funded child care benefits" has been amended with the following changes:

  • References to ECC were replaced with "automated child care system"
  • The requirements for lost or stolen swipe cards were removed
  • The term "designee" was changed to "designee/sponsor"
  • Language pertaining to the responsibilities of the designee/sponsor for the new automated child care system was clarified
  • The reference to Type B assistant was removed

5101:2-16-36 "County Agency Responsibility for Annual Re-determination of Eligibility for Publicly Funded Child Care" has been amended with the following change:

  • The JFS 01124 "Redetermination application for child care benefits" revision date was updated to December 2018

5101:2-16-37 "Caretaker Requirements for Annual Re-determination of Eligibility for Publicly Funded Child Care" has been amended with the following change:

  • The JFS 01124 "Redetermination application for child care benefits" revision date was updated to December 2018

5101:2-16-39 "Copayment for Publicly Funded Child Care" has been amended with the following change:

  • The requirement for homeless child care was clarified to waive the copayment for the family
  • Cost of care for a week does not include payment to the provider when there is no tracked attendance for the week even if absent days or professional development days have been reported

5101:2-16-41 "Payment Rates and Procedures for Providers of Publicly Funded Child Care" has been amended with the following changes:

  • "Provider" refers to a program licensed by the Ohio Department of Education only when the program is complying with rule 5101:2-16-43 of the Administrative Code
  • The determination of the base rate for a provider was clarified
  • Expired exemptions for Head Start and Early Head Start programs were removed
  • Language was added to require tracked attendance in the previous twelve months prior to the payment of an absent day
  • Language was added to allow programs to be reimbursed for two professional development days per fiscal year
  • The requirement that the provider must notify the county agency when there has been loss of contact with the caretaker was removed from this rule
  • References to substitute and emergency caregivers for Type B and IHA providers were removed
  • The payment categories in appendix A were adjusted for thirty-eight counties to codify the changes implemented by Child Care Manual Procedure Letter No. 123

5101:2-16-44 "Provider Agreement for Payment of Publicly Funded Child Care" has been amended with the following changes:

  • Providers must utilize the automated child care system to track attendance, including while eligibility is determined
  • The requirements for submitting attendance data were added, including when caretaker approval is required and when attendance will be automatically swept for payment
  • The provider may not use a caretaker's or designee/sponsor's personal identification information to track attendance
  • The process for payment after denial, manual claims, adjustments for services provided prior to the effective date of this rule were updated.
  • References to swipe card were removed
  • References to ECC were replaced with "automated child care system"
  • The process for programs to request payment for services provided prior to the effective date of the rule was clarified

5101:2-16-70 "Caretaker Improper Payments or Misuse of Publicly Funded Child Care" has been amended with the following changes:

  • References to ECC were replaced with "automated child care system"
  • References to the ECC swipe card were replaced with "personal identification information" of a caretaker

5101:2-16-71 "Provider Improper Payments or Misuse of Publicly Funded Child Care" has been amended with the following changes:

  • References to ECC were replaced with "automated child care system"
  • References to misuse of ECC swipe card were replaced with misuse of "personal identification information" of a caretaker

5101:2-16-72 "Publicly Funded Child Care Program Integrity Review" has been amended with the following changes:

  • References to ECC were replaced with "automated child care system"

Revised Forms:

JFS 01121 "Early Childhood Education Eligibility Screening Tool" has been revised to clarify language on the cover sheet regarding verifications, proof of citizenship and directions for using the ODJFS child care directory.

JFS 01122 "Publicly Funded Child Care Supplemental Application" has been revised to update Section 7, Rights and Responsibilities pertaining to the use of the automated system and the personal identification of the caretaker.

JFS 01124 "Re-determination Application for Child Care Benefits" has been revised to clarify language on the cover sheet regarding verifications, proof of citizenship and directions for using the ODJFS child care directory, and to update Section 7, Rights and Responsibilities pertaining to the use of the automated system and the personal identification of the caretaker.

JFS 01138 "Application for Child Care Benefits" has been revised to clarify the language on the cover sheet regarding verifications, proof of citizenship and directions for using the ODJFS child care directory, and to update Section 7, Rights and Responsibilities pertaining to the use of the automated system and the personal identification of the caretaker.

JFS 01172 "County Agency Notice of Child Care Improper Payment Repayment Requirements for Child Care Providers" has been revised to update Section II, Your Responsibility, pertaining to the use of the automated child care system to schedule repayment for the amount owed.

Implementation:

Forms

The new versions of the forms listed above shall be completed by caretakers who apply for child care on or after the effective date of this letter. Prior versions of these forms shall be accepted until March 15, 2019.

General Attendance for Non-Early Adopter Providers:

Services provided prior to December 16, 2018

All PFCC services provided prior to December 16, 2018 should be recorded in the ECC system using the swipe card for families currently authorized to that program. Manual claims may be submitted following the requirements and process outlined in rule 5101:2-16-44 (J). ECC will be available through December 28, 2018 to back swipe attendance for services provided prior to December 16, 2018.

Services provided on or after December 16, 2018

All PFCC services provided on or after December 16, 2018 must be tracked using the new automated system and new payment processes as required in these rules. This includes services provided while an initial application for eligibility is being processed by the county agency, even if the application is ultimately denied.

Payment adjustments for services provided before December 16, 2018

Providers will follow the process outlined in rule 5101:2-16-44 (J) for payment adjustments for services provided before December 16, 2018. The request for adjustments must be sent to ODJFS within seven weeks of the provided services.

Payment adjustments for services provided after December 16, 2018

Providers will follow the process outlined in rule 5101:2-16-44 (H) for payment adjustments to submit adjustments in the automated child care system.

Changes in Authorization between December 13 and December 16, 2018

Providers will follow the process outlined in rule 5101:2-16-44 (J) for payment adjustments for services provided before December 16, 2018.

New applicants

Applications submitted before December 14, 2018 with eligibility approved after December 14, 2018

Caretakers will utilize the new automated system and new payment processes as required in these rules for all services provided on or after December 16, 2018. Providers will submit manual claims using the process outlined in rule 5101:2-16-44 (J) for all services provided prior to December 16, 2018.

Applications submitted before December 16, 2018 with eligibility denied after December 16, 2018

Caretakers will utilize the new automated system and new payment processes as required in these rules for all services provided on or after December 16, 2018. Providers will submit the JFS 01211 "Request for Payment of Publicly Funded Child Care Services Provided for a Denial of Application" to request payment for services provided prior to December 16, 2018.

Swipe Cards

Mailing of swipe cards

Caretakers whose initial eligibility is determined after December 2, 2018 will not be mailed swipe cards. Providers will be able to submit manual claims for services provided before December 16, 2018 using the process outlined in rule 5101:2-16-44 (J).

Lost swipe cards:

Cards reported lost after December 2, 2018 will not be replaced. Providers will be able to submit manual claims for services provided before December 16, 2018 using the process outlined in rule 5101:2-16-44 (J).

New Providers

Providers that signed a provider agreement on or after November 4, 2018 and providers that have their first child authorized to them on or after November 4, 2018 will not receive POS devices. These providers will be sent a tablet for the new child care automated system. All parents authorized to those providers will use the new child care automated system and these new rules to record all attendance.

County Processing of Manual Claims and Adjustments

Manual claims:

County agencies will be able to process manual claims for services prior to December 16, 2018 until December 28, 2018. After December 28, 2018, county agencies will no longer have access to that functionality in ECC. All manual claims not entered into ECC by close of business on December 28, 2018 must be sent to the ODJFS at child_care_adjustment@jfs.ohio.gov for processing in TAP.

Adjustments for providers with current provider agreements:

If the county agency identifies a needed adjustment for a provider because of county error pursuant to rule 5101:2-16-71 and the provider has a current provider agreement, the county will calculate the overpayment, send the JFS 01172 to the child care provider and then notify ODJFS at child_care_adjustment@jfs.ohio.gov for processing in TAP.

Adjustments for providers without current provider agreements:

If the county agency identifies a needed adjustment for a provider because of county error pursuant to rule 5101:2-16-71 and the provider does not have a current provider agreement, the county agency will calculate the overpayment and then notify ODJFS at child_care_adjustment@jfs.ohio.gov.

The following website will be updated regularly with information about TAP: www.ohiocctap.info

If you have questions, please contact the Child Care Policy Help Desk at 1-877-302-2347, option 4 or CHILDCAREPOLICY@jfs.ohio.gov.