CCMTL 158 (Rule Changes for Publicly Funded Child Care Ohio Benefits Implementation)
Child Care Manual Transmittal Letter No. 158
March 8, 2022
TO: All Child Care Manual Holders
FROM: Matt Damschroder, Director
SUBJECT: Rule Changes for Publicly Funded Child Care Ohio Benefits Implementation

Background:

In 2010, the Ohio Department of Job and Family Services (ODJFS) implemented the Child Care Information and Data Systems (CCIDS) eligibility and authorization system as the statewide automated eligibility system for the Publicly Funded Child Care (PFCC) program.

To simplify the process for Ohioans applying for public benefits, the Ohio Benefits statewide integrated web-based eligibility system was launched.  The Ohio Benefits system allows Ohioans to apply for multiple benefit programs at one time, including medical, cash and food assistance.

Child care will begin utilizing the Ohio Benefits system for eligibility processing in early 2022 using a phased-in approach that begins with pilot counties before going statewide. The counties participating in the pilot are Allen, Athens, Butler, Hamilton and Medina.

Additionally, rules have been amended to incorporate changes due to the passage of Amended Substitute House Bill 110 of the 134th General Assembly, and to remove revision dates from all form citations.

The following rules have been amended:

5101:2-16-01 "Definitions for eligibility for publicly funded child care benefits" has been amended with the following changes: 

  • Added a definition for "authorized representative"
  • Amended the definition for "Head Start" to match federal language and Ohio Revised Code (ORC)
  • Added a definition for "statewide automated eligibility system"

5101:2-16-03 "Income eligibility requirements for publicly funded child care benefits" has been amended with the following changes: 

  • Removed "severance pay" and "temporary workers compensation payments" from the earned income list and added them to the unearned income list to align with the SNAP program
  • Added that termination/severance payments received as a one-time lump sum are not counted as unearned income to align with the SNAP program
  • Added "income from a rental property minus the cost of doing business when an individual is actively engaged in management of the property for at least an average of twenty hours per week" as gross earned income for individuals who are self-employed to align with the SNAP program
  • Added "payments from a roomer or boarder, except a border for whom foster care, guardianship, or kinship support payments are received" as gross earned income for individuals who are self-employed to align with the SNAP program
  • Added more examples of countable unearned income, and changed from a paragraph to a list for clarification and readability
  • Added that kinship support payments will not be counted as gross unearned income
  • Clarified that documentary evidence of income includes the most recent tax forms for self-employed individuals 

5101:2-16-05 "Copayment for publicly funded child care benefits" have been amended to add the word "recertification" where the word "redetermination" occurs to reflect language used in Ohio Benefits

5101:2-16-06 "Authorizations for publicly funded child care services" have been amended with the following changes: 

  • Clarified that authorizations always begin on the first day of the eligibility period, even if the qualifying activity starts later to align with ORC
  • Removed the exemption for a second provider if a child is attending a part time Step Up To Quality program due to the passage of Amended Substitute House Bill 110 of the 134th General Assembly

5101:2-16-07 "Caretaker improper payments or misuse of publicly funded child care benefits" have been amended with the following changes: 

  • Clarified that the caretaker is responsible for overpayments that occur because of errors on the part of the caretaker's authorized representative
  • Clarified that the caretaker is responsible for overpayments that occur because of information withheld or falsified by the caretaker's authorized representative

5101:2-16-08 "County agency responsibilities for the administration and determination of eligibility for publicly funded child care" has been amended with the following changes: 

  • Clarified that the county responsibilities for utilization of the CCIDS system also apply to the Ohio Benefits system
  • Clarified that county agencies should terminate eligibility, after providing hearing notice rights, when the caretaker requests discontinuance of child care benefits
  • Clarified that payment after denial authorizations are always for full time hours of care
  • Clarified that the caretaker is not assigned a copayment for a payment after denial authorization
  • Clarified that counties utilizing Ohio Benefits for child care determinations will send the caretaker a summary of information provided on a telephonic application with instructions on how to correct errors or omissions
  • Clarified that counties utilizing CCIDS for child care determinations will assign each family a payment code according to the family's programmatic eligibility
  • Added the word "recertification" wherever the word "redetermination" occurs to reflect language used in Ohio Benefits
  • Clarified that counties utilizing CCIDS for child care determinations will accept the JFS 01124{{nolink}} for redetermination/recertification, and the 01124 will be sent when caretakers requests a copy of the redetermination/recertification application
  • Clarified that counties utilizing Ohio Benefits for child care determinations will accept the JFS 07204{{nolink}} or the electronic or telephonic equivalent for redetermination/recertification, and the 07204 will be sent when caretakers request a copy of the redetermination/recertification application
  • Clarified county agency responsibilities regarding authorized representatives
  • Clarified county agency responsibilities when a caretaker is applying for other benefits

5101:2-16-09 "Provider Responsibilities for Publicly Funded Child Care" has been amended with the following changes: 

  • Removed "Beginning September 1, 2020" from paragraph (A)(1) due to the passage of Amended Substitute House Bill 110 of the 134th General Assembly
  • Added "Except as described in paragraph (A)(3) of this rule" for clarification

5101:2-16-10 "Payment rates and procedures for providers of publicly funded child care services" has been amended with the following changes: 

  • Clarified that in-home aides are not eligible for payment enhancements or extra percentages

Appendix A to rule 5101:2-16-10 has been updated to reflect new provider categories and rates that went into effect on July 4, 2021.

Implementation:

As counties begin using the Ohio Benefits statewide automated eligibility system to process PFCC applications, they will follow the OB procedures in rule, including accepting the appropriate OB forms and all other procedures specific to the OB system.

The process will begin with the five pilot counties before statewide conversion to the OB system.  When the entire state is live in OB, another package of rule amendments will be submitted for public review. 

Forms

Forms contained in these rules will appear in a separate clearance. The manual procedure letter will contain more detailed implementation guidance.

The JFS 07200 "Application for Supplemental Nutrition Assistance Program (SNAP), Cash assistance, Medical assistance or Child Care assistance" will be used to apply for child care using the Ohio Benefits system

The JFS 07204 "Request to Reapply for Cash Assistance, SNAP and/or Child Care" will be used to redetermine eligibility using  the Ohio Benefits system.

The JFS 07105 "Application/Reapplication Verification Request Checklist" will be generated via Ohio Benefits when a county is utilizing Ohio Benefits to determine eligibility.

The most recent version of all ODJFS forms referenced in these rules can be accessed through Forms Central.

Please contact the Child Care Policy Helpdesk at childcarepolicy@jfs.ohio.gov or 1-877-302-2347, option 4, if you have any questions.