CCMPL 107 (Head Start/Early Head Start Policy Amplification - Update)
Child Care Manual Procedure Letter No. 107
September 14, 2016
TO: All Child Care Manual Holders
FROM: Cynthia C. Dungey, Director
SUBJECT: Head Start/Early Head Start Policy Amplification - Update

This procedure letter (Child Care Manual Procedure Letter No. 107) obsoletes Child Care Manual Procedure Letter No. 106.

Background: On February 19, 2016, the Ohio Department of Job and Family Services (ODJFS) posted Ohio Administrative Code rule 5101:2-16-41 to Clearance for public comment. The rule was amended to clarify policy regarding when a publicly funded child care payment can be issued for a child covered under another funded program. This clarification in paragraph (E) ensures consistent statewide application of the state's policy that if a state or federal program (i.e. Head Start or Early Childhood Education) is providing payment for a specific child, the publicly funded child care program will not pay for the same time period. This rule was original filed on April 11, 2016, had a public hearing on May 16, 2016 and was on the June 6, 2016 Joint Committee on Agency Rule Review agenda. No testimony was submitted or provided at either hearing. The rule became effective June 26, 2016.

In Child Care Manual Procedure Letter (CCMPL) No. 101 (June 22, 2016) it was stated this policy clarification will not be enforced by the ODJFS until September 3, 2016. This delay in enforcement was to provide participating providers and their partners' time to evaluate their budgets, revise where necessary and to implement any changes in accordance with the rule clarification.

In Child Care Manual Procedure Letter No. 103 (August 30, 2016) it was announced that base rates and enhanced payment rates would be increased for Step Up To Quality rated providers, effective September 4, 2016 to maintain budget neutrality for the publicly funded child care program by investing any money realized as a result of the Ohio Administrative Code policy clarification outlined above into the Step Up To Quality program.

Update: Below please find updates to the policy clarification affecting Head Start/Early Head Start and the payment increase to the Step Up To Quality base rates and the enhanced rates for highly rated programs.

Head Start/Early Head Start: As a result of further discussion, the ODJFS will approve an additional extension of the delayed enforcement of Ohio Administrative Code rule 5101:2-16-41 paragraph (E) as clarified in CCMPL No. 101. The extension only applies to the Head Start/Early Head Start slots identified for layering with publicly funded child care in the approved 2016/2017 Head Start/Early Head Start federal program year budget. Slots not previously budgeted for layering as of September 3, 2016 must adhere to Ohio Administrative Code rule 5101:2-16-41 paragraph (E).

In order for the grantee to take advantage of this delay each Head Start/Early Head Start grantee must:

1.Register with the ODJFS by October 14, 2016 by filling out the attached "Head Start Provider Registration - Layering" spreadsheet to provide the following information:

Tab 1: Grantee Information:

  • Head Start grantee name
  • Grantee contact information
  • Total dollar amount awarded to the grantee for Head Start/Early Head Start
  • Total slots awarded to the grantee for Head Start/Early Head Start
  • Total number of licensed child care partner programs

Tab 2: Partner/Provider Information:

  • Names of all licensed child care providers partnering with the grantee for the current program year
  • Identify partners whose agreements are in conflict with Ohio Administrative Code 5101:2-16-41 paragraph (E)
  • Number of Head Start/Early Head Start slots for each partner
  • Number of slots budgeted for layering (the number of children being layered should not exceed the slots budgeted and approved in the 2016/2017 Head Start/Early Head Start program year budget.)
  • Total Hours of Care for non-PFCC children. * See Important Note Below.
  • Non-PFCC Schedule (ex. 9am to 3pm). * See Important Note Below.
  • Months of Service (ex. Full-Year, September to May, etc.). * See Important Note Below.

* Important Note: The above information is being gathered to inform future system enhancements for administration of the extended day policy.

Tab 3: Partner/Child Information:

  • Identify all children enrolled in both publicly funded child care and Head Start/Early Head Start as of the date of submission of the Head Start Provider Registration -Layering form to be served by the grantee and child care partner. * See Important Note Below.
  • Identify the children occupying slots for which the provider will receive layered funding.
  • If after the date of submission of the form, a child enters a slot previously identified for layering, the child's information must be provided to ODJFS.

* Important Note: Prior to submitting this form to ODJFS, children included on this document must have a signed release by a parent or guardian allowing the Head Start grantee permission to provide this information to ODJFS. If a parent or guardian elect not to provide the child's information the slot the child holds will not be eligible for layering. An example release form is attached. The grantee must maintain the release.

2.The grantee must also provide the following additional documents:

  • The approved federal budget for the 2016/2017 Head Start/Early Head Start program year that clearly identifies the use of layering.
  • A budget supplement that clearly explains the number of children to be served by the grantee and child care partner provider, planned category of utilization for PFCC (i.e. Full-time, Part-Time, hourly), other partnership funding and projected expenses by category (Administration, Staffing, Services by type, child care).

The Head Start/Early Head Start grantee must provide the above documents and any changes to the children enrolled and approved in a layering slot to the ODJFS by email at HeadStart-PFCC@jfs.ohio.gov no later than 5pm EST on Friday, October 14, 2016.

3.The grantee must submit the following information to ODJFS by December 31, 2016:

a.Transition Plan: the plan must explain how the grantee and all partners will become compliant with Ohio Administrative Code 5101:2-16-41 paragraph (E) with the start of the next school year/grant program cycle beginning in 2017. Details of the plan will be forthcoming.

b.Proposed Budget: The proposed budget for the 2017/2018 program year that supports the transition plan. The proposed budget should include total number of children to be served by grantee's program type by partner, source of partnership funding and projected expenses by category.

Step Up To Quality - Base Rates and Highly Rated Enhanced Rates: Pursuant to CCMPL 103, effective Sunday, September 4, 2016, the base rates for all Step Up To Quality rated providers were increased by four percent.

In addition to the four percent base increase for all Step Up To Quality rated programs, highly rated providers (3-, 4- or 5-star rated) will receive the following payment enhancement increases:

  • Three-star rated programs will increase from 18% to 21%
  • Four-star rated programs will increase from 25% to 29%
  • Five-star rated programs will increase from 31% to 35%

If you have any questions regarding these updates please contact the Child Care Policy Help Desk at childcarepolicy@jfs.ohio.gov

Attachment:Head Start Center Authorization for Release of Information

Attachment:Head Start Provider Registration - Layering