Child Care and Development Individualized County Child Care Subsidy Program

Individualized County Child Care Subsidy (Pilot) Program

Legislative Report:  Assembly Bill 1294 (Chapter 497, Statutes of 2021)

Legislative Report - Recommendations from the Individualized County Child Care Subsidy Pilot Program Flexibilities


Frequently Asked Questions (FAQ)

1) When can a participating Pilot county submit a plan or modification to the California Department of Social Services?

Effective January 1, 2019, per Education Code (EC) section 8332.25, the California Department of Education (CDE) established two annual opportunities for counties to submit plans or modifications: February 1–February 15 and June 15–June 30. The California Department of Social Services (CDSS) recognizes these timelines as established process that shall continue to be adhered to.

The intent of establishing these submission periods is to make the Pilot process more organized and efficient. If the submission deadline is on a weekend, then the deadline is extended to the next business day. Submissions that are not received on a timely basis will not be considered.

2) What are the elements of a Pilot county plan submission and/or modification?

Each Pilot plan submission must include the following:

  • Cover Letter stating the policy changes being requested by the county and any changes to the ‘Participating Contractor’ list.
  • Pilot Template demonstrating a need for the policies, showing baseline data. The Pilot Template is where counties specifically identify or propose policies they would like to opt-in to.
  • Needs Assessment report and other data as applicable detailing the child care needs in the county, among other criteria as specified in Welfare and Institutions Code (WIC) section 10342(a)(1). Data should support the need for the proposed policy change.
  • List of participating contractors and contract types for each contractor (along with signed memorandums of understanding for each contractor).

3) How should a county develop the Pilot Cover Letter?

The Pilot Cover Letter should be drafted on county letterhead and be no longer than one page in length. The purpose of the Pilot Cover Letter is to provide a summary of the submission/modification plan. The Pilot Cover Letter must include the following components:

  • Policies that are being requested and/or opted out of.
  • Requests to add or remove contractors and contract types.
  • Date of submission.

4) What is the Pilot Template?

The Pilot Template is a spreadsheet detailing the specific policies requested by the county. The CDE originally developed this Template in accordance with EC Section 8332.25 to streamline the review process. The CDSS recognizes this as an established process that shall continue to be adhered to. The Pilot Template includes the following column headers:

  • Proposed Local Policy.
  • What data collection in the Needs Assessment supports superseding state law for this local policy?
  • >What goal does this meet?
  • Expected Measurable Outcomes.
  • Status.

The CDSS relies heavily on measurable data provided in the Template, with a deep focus on columns B and D, when determining whether to approve a policy request.

Beginning July 1, 2021, the CDSS implemented new procedures for requesting pilot plan modifications during the modification periods. Participating counties must include all approved policies to date and all new policies being requested on the Pilot Template. The new policies being requested on the Pilot Template must be bold to distinguish them from the approved policies to date.

5) What are the CDSS’ expectations for providing data?

As a county develops the data section of the Pilot Template, the county must be careful to provide data that illustrates the problem faced and how the proposed policy will address the needs of the county. This data should be aligned with the stated goal.

After deciding what data to include, provide references to the relevant data from the county’s Needs Assessment report or other sources. A Pilot county may wish to cite multiple data points to support superseding state law on a certain policy. If so, include citations for each of the data elements you include. References should consist of the page and/or chart numbers from the Needs Assessment report that show the data element being used.

For example, if a county wishes to cite the number of eligible children by income rank within the county, the county must include in the Template the page number and where the data is located in the county’s Needs Assessment. In the Template, the county may list “Number of children by income ranking in the county (page X of Needs Assessment)”.

6) What if a county cannot provide quantitative data in the Pilot Template?

If the county cannot produce quantitative data, the county must provide qualitative data and describe how and when the county will collect appropriate data for the CDSS to use in evaluating the county’s progress.

7) What does the CDSS mean by “Needs Assessment report and other data applicable”?

Counties must consider data when developing their plan and provide the data that supports their policy requests in the Pilot Template submitted to the CDSS.

Specifically, WIC section 10342(a)(1) states that the county must consider the following data elements when preparing the Pilot Template:

  • Needs Assessment data collected pursuant to WIC section 10486(b).
  • Data collected by resource and referral agencies.
  • The county's self-sufficiency income level.
  • The cost of providing child care.

All counties must provide a copy of its Needs Assessment report with the Pilot plan submission.

If a county has not included in its Needs Assessment report data collected by resource and referral agencies, data on the county’s self-sufficiency income level, or data on the cost of providing child care—and if a county intends to rely on those data elements or others in their Pilot Template to support a policy request—the county must provide the additional data elements cited to the CDSS in addition to providing the Needs Assessment report.

8) What is a Participating Contractor List?

The Participating Contractor List is a document included in the Pilot plan or modification that lists all participating contractors and their contract type(s).

The CDSS provided an example of a participating contractors list. Please remember to always include the following:

  • County name.
  • Date submitted.
  • List of participating contractors, including any you wish to add or remove during the current modification period.
  • Contract types.

9) What are Memorandums of Understanding?

Memorandums of Understanding (MOUs) are signed by each participating contractor and Local Planning Council (LPC) Coordinator in their county. A MOU is an agreement that informs the CDSS of the contractors that are participating in the Pilot plan.

It is the responsibility of the LPC Coordinator for each county to ensure the individual that signs the MOU on behalf of the contractor is authorized to do so. The authorized signer is typically the Executive Director but may also be another individual if there is a resolution on file with the CDSS Contracts and Purchasing Bureau specifying that the signer is allowed to sign on behalf of the contractor. The CDSS considers all contractors with a signed MOU to be Pilot participants and contracts will be executed accordingly.

10) Can Pilot counties with 24-month eligibility policies, certify or recertify twelve-year-old children for 24-months of eligibility?

No. The CDE modified its 24-month eligibility policy to include an exception that children who are 12 years old at the time of initial certification or recertification shall only be certified for 12-month eligibility, regardless of a county’s previously approved plan. This policy is effective as of the date of the letter that alerted counties to this change: January 8, 2020. The CDSS recognizes this as an established pilot policy.

11) What happens when a contractor operates in two Pilot counties?

When a contractor operates in two different counties, the contractor will receive separate contracts for each of the Pilot programs involved. Each respective contract will indicate the amount of funding for the specific county involved and will include the provisions applicable to that county-specific Pilot program. In other words, Pilot participants will be required to split the participating/applicable contract type(s) if providing services in more than one county.

12) What is needed for a Pilot county to implement a Pilot Reimbursement Rate?

Specific information and criteria are needed to implement a Pilot Reimbursement Rate (PRR). The process is as follows:

  • The LPC coordinator submits a data request to the CDSS. Data will include fiscal contract terms and earnings information from baseline year and all subsequent years.
  • Pilot contractors identify projected contract unearned child days of enrollment (cde).
  • The LPC coordinator submits a formal request to the CDSS for a PRR during the February or June modification periods.
  • The CDSS reviews the proposed rate and contractor information.
  • Letters of intent are submitted by each participating contractor.
  • The formal approval of the PRR is sent to each contractor.
  • Contracts are sent to each contractor to be signed and returned to the CDSS.

13) Do all Pilot contractors need to contribute cdes to receive the PRR?

No. Not all contractors will have unearned cdes to contribute. When contractors are considering the amount of cdes to potentially contribute, they should consider earnings data from prior years and other factors such as legislative changes or plans for expansion that may impact their future earnings.

14) How often can a Pilot county request a PRR?

A Pilot county may only have one PRR for each contract type per fiscal year. A PRR request submitted in the February modification period can be retroactive to July 1 of the current fiscal year or go into effect the next fiscal year. A PRR request submitted in June will be for the new, upcoming fiscal year.

15) Do policy changes during the modification period still require signatures of all participating CDSS Contractors, similar to the letter of intent required during the Pilot Rate Reimbursement process?

After the CDSS approves the Pilot submission or modification, participating Pilot contractors will be required to sign and submit an amended contract agreeing to the revised provisions. The CDSS expects that any Pilot policy changes requested during the February or June submission periods have been communicated to all Pilot participating contractors by the county LPC Coordinator prior to the Pilot plan’s submission to the CDSS.

16) Can Pilot counties that have collaborated on aligning policies similarly across counties submit a joint Pilot plan?

No. Counties may collaborate to determine shared goals and policies, but each county must submit their plans individually using the CDSS Pilot Template during the biannual submission period opportunities in February and June.

17) Can pilot counties submit plans at any point during the fiscal year?

No. Assembly Bill 108, which focused on individualized county child care subsidy plans, was passed in 2018 and required that the CDE “establish instructions and timelines for submittal or modifications of the plans” (EC section 8332.25). In response to this statutory requirement, the CDE established a pilot plan template and modification period timelines of February 1–15 and June 15–30 each year. The CDSS recognizes these timelines as established process that shall continue to be adhered to. Therefore, any requested changes must be provided in the Pilot Template and submitted within one of the modification periods. These rules help the CDSS keep the administrative process consistent across counties and streamline the review process.

18) When is the effective date of the 24-month policy change letter that was emailed to all pilot counties on January 8, 2020? The letter is dated 12/17/20.

The effective date of the policy change is the same date of the email, January 8, 2020, as this was the first date the counties were made aware of the policy change.

19) How should pilot contractors implement the revised 24-month policy that is effective January 8, 2020?

All certifications/recertifications that occur after January 8, 2020, should consider this policy revision. Contractors that, for example, certified 12-year old children for 24 months prior to January 8, 2020, will be held harmless as that was the allowable pilot policy in effect prior to the email stating the change.

In terms of 13-year old children, no new certifications should occur once a child turns 13 years of age. Pilot contractors can certify children that are 12 years of age, but only for 12 months. Once that 12 months has expired, they would not be eligible for recertification. For children under 12 years of age served by pilot contractors, those children can be certified for 24 months, since they will not be receiving services under that certification when they are 14 years old. Services should not be occurring for children 14 years of age.

20) We are receiving CDD-801A error messages when reporting 14-year old children, even though they are currently eligible for services, as they were certified for 24-month eligibility when they were 12-years old. This certification occurred prior to the 24-month policy change effective January 8, 2020. What should we do?

The CDMIS team has made the necessary changes to allow for eligible 14-year old children who were certified prior to January 8, 2020, to be successfully saved on a monthly CDD-801A report. Please note that pilot agencies are required to retroactively report any eligible 14-year old children who were previously omitted on all CDD-801A reports. For additional guidance, please contact CDMIS staff at: CCDDdata@dss.ca.gov.

21) Now that many of the programs have transferred to CDSS, what email address should LPC Coordinators use to contact the CDSS Pilot Team? And should Pilot contractors contact the state directly or go through their LPC Pilot Coordinator?

The CDSS Pilot Team may be reached by emailing: CCDDPilots@dss.ca.gov. Pilot contractors with questions for the state should send them directly to their county LPC Pilot Coordinator, who will act as the liaison with the state to resolve any issues.

 

Questions: Child Care and Development Division | CCDDPilots@dss.ca.gov

Last Reviewed: December 2021