ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
Karen Mercadante – kmercadant@pa.gov
(717) 772
4848
Leslie Shaw – lshaw@pa.gov
(717) 346
4660
Jessica Sands – jsands@pa.gov
(717) 787
8082
Nancy Buczeskie – nbuczeskie@pa.gov
(717) 772
0655
June 2012 1
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
June 2012 2
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Background & Purpose of Act 22
• Passed 6/30/11 .
• Expires 6/30/12 .
• Gives the Secretary broad authority to promulgate expedited regulations.
• Must result in cost savings to the Commonwealth.
• Included the co-payment increases effective 10/1/11 .
June 2012 3
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Links to Revised Regulations
http://www.pabulletin.com/secure/data/vol42/42-15/643.html
http://www.pabulletin.com/secure/data/vol42/42-15/648.html
http://www.pacode.com/secure/data/055/chapter168/chap168toc.html
http://www.pacode.com/secure/data/055/chapter3041/chap3041toc.html
June 2012 4
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
Agenda
Office of Income Maintenance (OIM) Updates
Special Allowances
Referrals to the County Assistance Office (CAO)
OCDEL Regulatory Package #1:
Self-Employment (Verification & Income Inclusions)
Pre-Kindergarten
Half Co-payment for School-Age Children
June 2012 5
ACT 22 Expedited Regulation Changes www.education.state.pa.us|www.dpw.state.pa.us
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare
Agenda
(Cont’d)
• OCDEL Regulatory Package #2:
Absences ( 5 -Day Absence & Attendance Tracking)
Changes also made to Chapter 168 (relating to child care)
Subsidy Continuation – Breaks in Work/Education/Training
Head Start
Overpayment & Suspected Fraud (Parent & Provider)
Voluntary Disqualification (Parent)
• Provider Agreement Revisions
• R/N MCCA Changes
June 2012 6
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
June 2012 7
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
OIM Updates —
• Changes made to § 165.41
(f) (relating to special allowances for supportive services).
• The Department will NOT pay for education or training related expenses for a FS/SNAP only participant when these expenses are being met prior to participation in a FS/SNAP employment and training program.
• Also applies to TANF recipients.
• Code “ 74 ” in the “Indtrk/CompIRV/Appeal/GC” field on the CIS
CQPREN screen – COMING SOON.
• INELIGIBLE for subsidized child care.
June 2012 8
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
OIM Updates —
• The CCIS must be careful in its wording regarding child care referrals to the CAO.
• The CCIS may NOT discuss eligibility for child care with recipients of
TANF and/or FS/SNAP benefits.
• Acceptable language:
“You must talk to your CAO worker about your circumstances to see if you can get any help with your child care costs.”
“Only your CAO worker can determine whether you can receive help with your child care costs.”
June 2012 9
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
June 2012 10
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Definitions — §
• Self-employment – Operating one’s own business, trade or profession for profit equal to or greater than the hourly Pennsylvania minimum wage.
• Current PA minimum wage = $7.25.
June 2012 11
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
EXAMPLES – Hours/Week Subsidy is Provided
1. $5,320 for 52 weeks.
$5,320/52 = $102.31/$7.25 = 14 hours/week
INELIGIBLE (Not meeting work-hour requirement).
2. $5,320 for 36 weeks.
$5,320/36 = $147.78/$7.25 = 20
ELIGIBLE for up to 20 hrs/week.
3. $5,320 for 24 weeks.
$5,320/24 = $221.67/$7.25 = 31
ELIGIBLE for up to 31 hrs/week.
June 2012 12
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Verification of Self-Employment Income —
§§
• An annual Federal income tax return is required to verify income when the p/c :
Has been self-employed for more than one year in the same business.
Has been self-employed for less than one year, but has filed a Federal income tax return.
June 2012 13
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Verification of Self-Employment Income —
§§
• An annual Federal income tax return must include any schedule(s) related to self-employment that are appropriate for the type of business .
• An annual Federal income tax return is only valid until the next Federal income tax return is filed.
June 2012 14
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Federal Income Tax Return Criteria
• The Federal income tax return MUST include:
ALL pages of the Federal income tax return.
ALL pages of any attached forms that were submitted along with the Federal income tax return.
June 2012 15
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Verification of Self-Employment Income —
§§
• A notarized statement as described above is valid only until
the next Federal income tax return is filed.
• A notarized statement is acceptable when the following conditions are met:
It indicates gross earnings minus allowable costs of doing business which shows an hourly profit equal to or greater than the PA minimum wage for the preceding tax quarter.
The p/c has been employed in the same business for less than one year and has not yet filed a Federal income tax return.
June 2012 16
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Verification Hierarchy
• Once a self-employed p/c has submitted a Federal income tax return as income verification, only another
Federal income tax return is acceptable verification of income going forward.
• The CCIS will NOT accept another notarized statement as income verification unless the p/c has new self-employment and has not yet filed a
Federal income tax return that includes income from the new self-employment .
June 2012 17
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
EXAMPLE —
• Family applies 9/2/12.
The p/c may submit a notarized statement.
The initial redetermination is scheduled for on 3/2/13. The CCIS must notify the p/c that he/she is required to submit a Federal income tax return by 4/15/13.
June 2012 18
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
EXAMPLE —
• Family applies 7/2/12.
If p/c filed a Federal income tax return, the p/c must submit a copy.
If the p/c did not file a Federal income tax return, the p/c may submit a notarized statement.
The initial redetermination is scheduled for on 1/2/13. The CCIS must notify the p/c that he/she is required to submit a Federal income tax return by 4/15/13.
June 2012 19
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
EXAMPLE —
• Family applies 7/2/12.
If p/c filed a Federal income tax return, the p/c must submit a copy.
If the p/c did not file a Federal income tax return, the p/c may self-declare income for up to 30 calendar days and must file a
Federal income tax return.
On, or before, the 30 th day following self-declaration, the p/c must submit a copy of the Federal income tax return.
The initial redetermination is scheduled for on 1/2/13. The CCIS must notify the p/c that he/she is required to submit a Federal income tax return by 4/15/13.
June 2012 20
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
EXAMPLE —
• A family is scheduled for redetermination on 7/25/12.
If p/c filed a Federal income tax return, the p/c must submit a copy.
If the p/c did not file a Federal income tax return, the p/c may submit a notarized statement.
The p/c must be notified that he/she is required to submit a Federal income tax return by 4/15/13.
June 2012 21
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
EXAMPLE —
• A family is scheduled for redetermination on 7/25/12.
If p/c filed a Federal income tax return, the p/c must submit a copy.
If the p/c did not file a Federal income tax return, the p/c may self-declare income for up to 30 calendar days and must file a
Federal income tax return.
On, or before, the 30 th day following self-declaration, the p/c must submit a copy of the Federal income tax return.
The CCIS must notify the p/c that he/she is required to submit a
Federal income tax return by 4/15/13.
June 2012 22
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Decreasing Co-payment
• Self-employment income may not always be received on a consistent basis (such as monthly or weekly), but is meant to cover a specific time period, usually 52 weeks.
• The co-payment will not be decreased because a p/c indicates that his/her income is less than expected for a particular month or week, as the income may increase in subsequent months or weeks and average out to the amount reported on the Federal income tax return.
June 2012 23
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Redetermination Requirement —
§§
• The CCIS must complete a redetermination of eligibility at the time the Federal income tax return is filed.
OCDEL will provide the CCIS agencies with a query indicating which cases include a p/c that is currently self-employed so the CCIS can begin to plan its workload.
Redeterminations will be brought into April and October cycles, if these cycles are not already established.
The CCIS will complete redeterminations as each redetermination comes due.
June 2012 24
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Redetermination Requirement —
• Upon completion of the family’s scheduled redetermination, the
CCIS must:
Set a tracking date alert for 4/15 as a reminder to obtain a copy of the
Federal income tax return filed for the previous tax year.
Send the p/c a Missing Information Letter requesting the Federal income tax return no later than 4/15.
Complete a redetermination in April following receipt of the Federal income tax return by placing the case in Full Redetermination mode.
Generate an AA if the p/c does not submit the Federal income tax return by 4/15.
• A.
June 2012 25
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Income Inclusions & Deductions —
• Removed deductions:
Professional licensing fees
Union dues
Depreciation
Other deductions allowed by the IRS
• Remaining deductions:
Costs of maintaining a business
Interest on purchases
Employee labor costs
Cost of goods sold, supplies and materials
Advertising costs
Accounting and legal fees
Transportation costs
June 2012 26
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Income Inclusions & Deductions — Procedures
• Those deductions that are no longer permitted must be included in the income calculation only when the CCIS can easily determine the amount of income associated with those deductions.
• If the CCIS is unable to easily determine the amount of income associated with those deductions that are no longer permitted, the CCIS will use the total adjusted gross income as indicated on the Federal income tax return, which includes all allowable IRS deductions.
June 2012 27
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
EX: Schedule C –
Able to
Determine
Depletion &
Depreciation
Amounts
The CCIS will NOT deduct the income reported on Lines 12 or
13 of the Schedule C.
June 2012 28
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
June 2012 29
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Prekindergarten program — §
• This section has been removed from regulation.
Redetermination will be done every six months.
Must meet all eligibility requirements.
June 2012 30
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Implementation
• OCDEL will provide the CCIS agencies with query indicating which cases, by CCIS office, currently contains children enrolled in PreK.
• For cases including a PreK child ONLY, the CCIS will complete an immediate redetermination after 7/1/12.
• For cases including a PreK child and other children in the family, the revised regulation will take affect at the next scheduled redetermination.
• The CCIS must assess/confirm eligibility under the Low-Income or
Former TANF child care program to establish a Redetermination Date and generate the redetermination packet.
June 2012 31
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Obsolete Announcements
• S-09 #18 Linking Pennsylvania Pre-K Counts and Child Care
Works Subsidized Child Care
– PKC & CCW FAQ
– PKC-CCW Policy and Procedures
– 08-09 PKC Grantees Enrollment Contacts as of 8-21-07
• S-07 #08 PA Pre-K Counts and Child Care Works: Enrollment and
Release of Information Procedures
– Enrollment Verification Form
– CCIS Directory
– 07-08 PKC Grantees Enrollment Contacts as of 8-31-07
June 2012 32
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Obsolete Policy Communiqués
• #08-15 2008-09 Pennsylvania Pre-K Counts Grantees and
Updated Outreach Materials
– PA PKC Grantees 08-09
– PA PKC Parent Flyer
– PA PKC Parent Flyer - Spanish Version
• #09-09 Verification of Income for Families Participating in Child
Care Works (CCW) and Pennsylvania (PA) Pre-K Counts
June 2012 33
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Valid Policy Communiqués
• #08-12 Redeterminations for Children in Head Start and PA
Pre-K Counts
June 2012 34
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Valid Information – Payment Rate Guidelines
Communiqué to Follow
• The CCIS will continue to use the PA PreK Counts Enrollment
Verification form so the CCIS can ensure the provider is paid at the proper unit of care.
• A PA Pre-K Counts grantee that has a full-day program may only receive a part-time subsidized child care payment rate, no matter how many hours of care the child needs beyond the PA Pre-K
Counts school day.
June 2012 35
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Valid Information
– Communiqué to Follow (Cont’d)
• If a child needs more than five hours of care a day beyond the
PA Pre-K Counts day, the CCIS should create a part-time schedule and note the following in case comments:
– The child is enrolled in the PA Pre-K Counts and Child Care
Works program; and
– The full number of hours the child needs care and is in attendance at the facility.
June 2012 36
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Valid Information
– Communiqué to Follow (Cont’d)
• A PA Pre-K Counts grantee that has a half-day program may receive either a full-time or part-time subsidized payment rate based on the number of hours the child needs care beyond the PA Pre-K Counts school day.
• The CCIS may pay a blended rate for children throughout the school year who will need a mixture of full-time care for days
PA Pre-K Counts is not in session and part-time care for days
PA Pre-K Counts is operating.
June 2012 37
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
June 2012 38
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Co-payment — §
• Half co-payment has been removed from regulation.
• If the co-payments for 1 month are equal to or exceed the monthly payment for care, the family is not eligible for subsidized child care with the provider.
June 2012 39
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Summer Only Set-Aside for FY 2012-13
• NOT like the “Summer Only” from years ago.
• Does NOT include families with multiple children and school-age children who do NOT necessarily need care during the school year (i.e., my kids this year at 10 and 12).
June 2012 40
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Summer Only Set-Aside for FY 2012-13
(Cont’d)
• Available ONLY for families that:
Would have qualified for the half co-payment.
–1 school-age child requesting care.
–Receiving part-time care during the school year and full-time care during the summer.
Have a cost of care that exceeds the co-payment now that the family must pay the full co-payment amount.
June 2012 41
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Implementation –
• No co-payment flip in August 2012.
• School year begin date is 9/3/12.
• The CCIS must:
1. Run the Co-payment Exception Report (RE328).
2. Generate and print locally an AA to be sent with a letter explaining the set-aside process and that families can reapply after 4/15/13 .
3. Send the letter throughout the year to families who apply for subsidy for a school-age child requesting part-time care and are ineligible because cost of care exceeds co-payment.
June 2012 42
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
June 2012 43
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Consecutive Absences — §§
• Requirement has been reduced from 10 to 5 consecutive days.
Provider closures (Paid or Nonpaid) do NOT count as days of absence.
Policy Communiqué #11-06 Determining Ten Consecutive Days of
Absence is OBSOLETE
• The provider must now report consecutive absences on the 6 th day.
• The CCIS must generate the AA on the 6 th day, if the child has not returned to care.
June 2012 44
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Suspension — §
The CCIS will now evaluate whether suspension is appropriate following the 5 th consecutive day of absence.
June 2012 45
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Implementation
• The CCIS will process consecutives absences following the
5 th consecutive day of absence.
• Pennsylvania’s Enterprise to Link Information for Children
Across Networks (PELICAN) Child Care Works (CCW) has been revised to include “5-day absence” as a drop-down selection for eligibility and enrollment purposes.
• Notices have been revised.
June 2012 46
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Implementation
(Cont’d)
• If a child is absent for 10 consecutive days in June, the CCIS will generate an AA on the 11 th day if the child has not returned to care.
• If a child is absent at the end of June and continues to be
absent following 7/1/12, the 5-day regulation is in effect so the CCIS will take action on the 6 th day by zeroing-out days on the schedule or generating an AA terminating subsidized child care if the child has not returned to care.
June 2012 47
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
EXAMPLES
— June only absences
• A child is scheduled to attend child care 5 days/week, but is absent from 6/18/12, 6/19/12, 6/20/12, 6/21/12, 6/22/12,
6/25/12, 6/26/12, 6/27/12, 6/28/12, 6/29/12 and 7/2/12
(i.e., 11 consecutive days). The provider reports the absence on 7/2/12.
The CCIS must generate an AA on 7/2/12 by deselecting “CC request” on the Care Request page, selecting the “Reason” as
“10 day absence,” clicking “Save” and assessing/confirming eligibility.
June 2012 48
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
EXAMPLES
— Provider Closure
• A child is scheduled to attend child care 5 days/week, but is absent 6/29/12, 7/2/12, 7/3/12 and 7/5/12. The provider was closed on 7/4/12.
The CCIS will generate an AA on 7/9/12 if the child fails to return to care on 7/6/12.
Provider closures do NOT count as an absence.
June 2012 49
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
EXAMPLES
—
End of June/Beginning of July absences
• A child is scheduled to attend child care 5 days/week, but is absent 6/22/12, 6/25/12, 6/26/12, 6/27/12, 6/28/12,
6/29/12 and 7/2/12. The provider reports the absence on
7/3/12 (i.e., 7 consecutive days).
The CCIS must generate an AA on 7/3/12 by deselecting “CC request” on the Care Request page, selecting the “Reason” as
“5 day absence,” clicking “Save” and assessing/confirming eligibility.
June 2012 50
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
PELICAN CCW Drop-Down Logic
Existing child care requests ended with the old “10-Day Absence” reason code will continue to be displayed, but this reason code will not be available for use after
08/31/2012
.
June 2012 51
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
PELICAN CCW Drop-Down Logic
(Cont’d)
An additional validation was added so the new reason code,
“5-day Absence,” is only used on or after
07/01/2012
, which is the date the regulations go into effect.
June 2012 52
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
June 2012 53
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Absence Cap — §§
• The CCIS will only pay for a maximum of 25 absences in a State fiscal year.
• Eligibility will continue, but the p/c
pay the
daily rate for each absence beginning with the 26 th absence.
• The absence count resets at the beginning of each
State fiscal year.
June 2012 54
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
Absences captured per child for the FY and stored based on the child’s individual number.
The Enrollment Summary was modified to show Total FY Absences as of the last day of latest invoice with attendance saved. The invoice does not need to be in a paid status. If there are no prior invoices it will show 7/1/xx.
PELICAN CCW will count every absence entered in the system.
Policy Note: Only 1 absence may be counted for a child with 2 enrollments/day.
June 2012 55
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
CCIS agencies will no longer have access to the Group Attendance
Detail page.
The reason for the change is because the Group Attendance
Detail page is not frequently used.
(Only 3,552 out of 288,000+ invoices process through this page in FY 2010-11.)
CCIS users can still utilize the existing group functionality for:
- Invoice Received
- Calculate
- Authorized
- Paid statuses
June 2012 56
ACT 22 Expedited Regulation Changes
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The Invoice Attendance
Detail page will help the
CCIS track absences for the year.
It is read only when invoice is in “New Invoice
Not Printed” or “Need
Invoice” statuses.
The “Current” and “Paid”
Absences columns are editable when the invoice is in “Have Invoice” or greater status.
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The Absences become read only again when books close at the end of the fiscal year.
The CCIS will continue to record end of month absences in “Current
Absences” column & data will move to “Prior
Absences” on the next invoice.
The CCIS will record any absences from the invoice in the “Paid Absences” column.
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Paid absences can go up to the number of units of care in the month to a maximum of 25 days in a fiscal year.
The entries in the
“Current Absences” &
“Paid Absences” fields do not change when the schedule is adjusted.
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EX: Enrollment suspended retroactively
- Enter 5 paid absences.
- Click “Save”.
- Suspend at later date.
- Go back to the invoice and change paid absences to 2.
- Click “Refresh” and “Save”.
Total attended days is no longer an editable field.
Total Attended Days =
Units of Care – Paid Absences.
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Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare
The “FY Cap Absences” column displays cumulative paid absences for the year.
NOTE: The following do
not count as absences per policy:
- Suspended Days
- Zeroed Out Days
- Non Scheduled Days
- Closures (Paid or
Nonpaid) www.education.state.pa.us|www.dpw.state.pa.us
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The CCIS will suspend a child’s enrollment PRIOR TO DAY 6 if the following conditions are met:
- The circumstances meet one of the conditions set forth in §
3041.21(a)(1) – (8) (relating to subsidy suspension).
- May be planned or unplanned (i.e., emergency).
- The p/c submits verification, in advance (except for emergencies), that the child will be unable to attend child care for more than 5 consecutive days.
The CCIS will NOT suspend a child’s enrollment or zero-out enrollment days related to family vacations or any other reason not set forth in § 3041.21(a)(1) – (8).
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Paid Absences are stored in history on the Case
Summary Detail page once the fiscal worker clicks the following on the
Invoice Attendance Detail page.:
- “Save”
- “Save-Go To
Calculate”
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As set forth in the regulations, absences for the FS/SNAP funding program will not be included in FY Cap
Absences.
If any day of the enrollment is funded through FS/SNAP, absences for the month will not count towards the
CAP Absences.
June 2012 64
ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare
The “Enrollment Info” column displays:
VWS – Varied Work
Schedule indicator is displayed for averaged or
“Wal-Mart Schedules.” This is to assist the worker when reviewing attendance invoice & recording absences accurately.
2 Enrlmts – if a child has more than 1 enrollment regardless of if the enrollment is in the same case or different cases. www.education.state.pa.us|www.dpw.state.pa.us
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Business Process: An alert generates to the
Eligibility Specialist when child reaches 20 paid absences. If child has dual enrollments only 1 absence counts/day. The CCIS must decide whether to reconcile dual enrollments each month or when alert generated.
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The hyperlink on FY Cap
Absences allows absences to be removed from the
FY Cap Absences.
This field is only editable by Help Desk or staff with the Payment
Authorization Roles.
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The main reason to adjust
CAP Absences is when a child is enrolled at multiple providers and more than 1 absence is recorded in PELICAN
CCW for a day.
The fiscal worker can adjust one of the invoices so the child is not charged with 2 absences during a given day.
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If a user makes a mistake when editing the FY Cap
Absence field, it can be corrected.
For example, change 2 to
1 and click save. The FY
Cap Absences will be updated accordingly.
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Policy Note: If a child is absent on the first day of scheduled care, payment begins the first day the child attends. Zero out the day(s) on the schedule since this is not considered an absence.
The p/c should pay the copayment for the week.
DO NOT record this as an absence on the
Invoice.
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When a child on the Invoice
Attendance Detail page reaches the 26 absence in a fiscal year, the child’s row will highlight and an error message displays when
“Save-Go To Calculate” is selected.
The worker will need to click “Save”, then click the Individual Number hyperlink to go to the schedule to mark an absence as unpaid or adjust the “Paid Absences” to proceed.
June 2012 www.education.state.pa.us|www.dpw.state.pa.us
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ACT 22 Expedited Regulation Changes
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Note: When the worker returns to the
Invoice Attendance
Detail page after adjusting the schedule, the worker must click “Refresh”.
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Any unpaid absences will reduce Units of
Care and Total Attended
Days.
Unpaid days entered on the schedule will adjust the Paid Absences column.
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EX: You realize 7 absences makes child go over 25
FY Cap Absences.
- Enter 7 paid absences.
- Click “Save”.
- Go to the schedule.
- Enter 2 unpaid absences.
- Click “Save”.
- Click “Refresh” and
“Save” on Invoice
Attendance Detail page.
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Units of Care & Total
Attended Days will update. Paid & FY Cap
Absences will decrease by 2 due to unpaid days on schedule.
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To record an unpaid absence:
- Select the checkbox next to the child’s enrollment on the Case Enrollment
Summary page.
- Click “Schedule”.
- Click “Edit” for the week that needs to display an unpaid absence.
- Select the checkbox for any unpaid absence.
- Click “Save”.
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Note: Non-standard schedule changes must be done as a separate transaction.
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The unpaid absence will display on the Enrollment
Schedule.
Note: If the absence is recorded on a day that only has a Standard Schedule, the schedule will show as non-standard because the absence changes the schedule type.
All paid and unpaid absences are recorded realtime on all pages in
PELICAN CCW.
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The Standard schedule is where the worker can indicate if the p/c has a varying work schedule.
- Click Schedule.
- Click
“Parent/Caretaker has varying work schedule”.
- Click “Save”.
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Note: The effective date for the varying work schedule indicator is tied to the effective date on the standard schedule. If the indicator is on for any date in the month, it will display on the Invoice
Attendance Detail page.
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Only the following roles have access to change the funding program for an enrollment , within a fund: “Super User”,
“Supervisor”, “Director”,
“Help Desk”, “Eligibility
Specialist”, “Enrollment
Authorization”, and “Intake
Specialist”.
The roles listed above can change the funding program for an enrollment , within a fund, without entering an override reason. (i.e. TANF
Working to MOE.)
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Roles who have access to override the enrollment funding program which requires entering an override reason (i.e. Food
Stamps/Supplemental
Nutrition Assistance
Program to Low
Income) are: “Super
User”, “Director”, and
“Help Desk”.
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The Case Summary page now includes a link to the total number of paid absences for a child.
Click the History Icon on the end of a Case
Members row to view his/her paid absences.
Note: Absences are stored by Individual number and will continue to accumulate through out the fiscal year.
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Business Process: If a
CCIS user discovers an
MCI mismatch for a child, add absences for the year on the invoices that are generated for the correct MCI number.
Enter an invoice comment indicating that number of absences added is due to the incorrect MCI number.
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The Individual Absences
Detail page displays the number of paid absences for each service period within the fiscal year for the selected child.
“Invoice ID”, “Provider ID”,
“Office” and “County” fields are included to assist with researching any absences that might need to be adjusted in the case of a dual enrollment.
The worker must click
“Refresh Absences” to ensure the number is accurate as of the latest invoicing.
www.education.state.pa.us|www.dpw.state.pa.us
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An alert goes to the
Eligibility Specialist when a child reaches 20 absences.
The worker must click
“Generate
Correspondence” to generate the Absence
Warning Letter.
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The Absence Warning Letter generates for the p/c and the provider(s) associated with the child . It is generated per child and will generate for any enrollment in enrolled or suspended status.
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Note: If a child is in more than one case (joint custody), you would need to generate the letter from within each case.
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The second alert displays for a child who has 25 day of paid absences accumulated for the fiscal year.
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The Eligibility Specialist will need to manually create a Confirmation
Notice for a p/c who has a child who reaches his/her
25 days of absence.
A separate Confirmation
Notice must be generated for each individual child.
The short description of the variable text field to select is:
25 Days of Absence.
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The worker must enter the:
- Begin & end dates of the fiscal year.
- Child’s Individual number.
- Date of the 25th day of absence
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There are several validations in place to ensure the variable text fields are populated correctly, which include:
Populating each field.
Entering valid FY dates.
- Entering the child’s
Individual Number rather than the child’s name.
- End Fiscal Year must be greater or 1 greater than
Begin Fiscal Year.
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The first page of the
Confirmation Notice will be sent to the provider to notify them that the child has 25 absences for the year.
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The Provider Payment
Summary is sent to a provider or another payee
(such as the parent) to document the detail of the payment calculations.
The Provider Payment
Summary will now display the Number of Paid Days and the Number of Unpaid
Absences for each Unit of
Care.
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This will indicate to the provider the number of absences not paid by the
CCIS and which they should collect payment from the parent/caretaker.
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The online attendance process will work the same as the paper process for provider attendance invoicing except for a few differences.
One difference is that
Current Absences and
Paid Absences will automatically populate from the Online Provider
Invoice. The CCIS will need to validate absences and update accordingly.
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Note: On-line invoices will no longer count closures as absences.
The other difference with online attendance is that the provider can view
Total FY Absences for each
Child on the Attendance
Update pop-up page.
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Subsidy continuation during breaks in work, education or training — §
• The CCIS will now pay through Day 30 only.
• Eligibility will continue, but care will be suspended beginning on Day 31 and ending on Day
60 or the date the p/c resumes work.
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Notification
• Revised language for the
Confirmation
Notices.
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• New version of the Child Care
Stop Letter.
Notification
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Notification
• Includes, as other reasons, automatic copies for p/c and provider.
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Implementation
• The CCIS will manually generate and send the Confirmation
Notice that is appropriate to the circumstances upon discovery
that the p/c has graduated or has lost a job involuntarily.
• On Day 31, the CCIS will suspend the enrollment(s) for each child in the case using the reason “Involuntary Job Loss/Graduation greater than 30 days.”
• When the CCIS suspends the enrollment(s), the Child Care Stop
Letters will be automatically generated.
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EXAMPLES
— Reported before 7/1/12
• When a p/c reports an involuntary job loss or graduation from education or training PRIOR TO 7/1/12, the CCIS must continue payment through Day 60.
The CCIS must generate the appropriate Confirmation Notice at the time the p/c reports an involuntary job loss or graduation from education or training.
The CCIS must honor the notice that was sent to the p/c.
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EXAMPLES
— Reported on or after 7/1/12
• When a p/c reports an involuntary job loss or graduation from education or training ON OR AFTER
7/1/12, the CCIS must continue payment through Day
30 only and suspend the enrollment(s) effective Day
31 unless the p/c resumes/begins work.
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§
• The p/c must meet eligibility requirements, each time a child
in the family applies for the Head Start expansion program.
• The CCIS will verify with the Head Start program that the program meets Federal and State Head Start requirements.
Contact Lists for those CCIS agencies that have Head Start programs in their counties/geographical areas.
Establish relationships with the Head Start programs in the county/geographical area.
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• If extended hours or days of care are provided beyond the Head
Start program hours or days, the extended hours and days of care must be provided by a facility that has a certificate of compliance or registration by the Department as a child day care facility.
• There is NO requirement regarding the existence of a collaborative agreement.
• The PreK Counts Payment Rate Requirements do NOT apply to
Head Start providers.
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Hours of Care
• The family may receive subsidized child care for the hours the p/c needs care while the p/c is working and/or working and participating in training ONLY.
• If a child is enrolled in a Head Start program 5 days/week, but the p/c is working only 3 days/week, the child may receive subsidized child care for 3 days/week ONLY.
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Redetermination — §
• The CCIS is NOT permitted to complete a partial redetermination or a redetermination on a child enrolled in the Head Start Expansion program until the child is no longer enrolled in Head Start.
Previously, the p/c could request a partial redetermination or redetermination in order to lower the co-payment if the p/c loses work hours.
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Redetermination
(Cont’d)
— §
• A redetermination will be completed if the family has additional children receiving subsidy, but not enrolled in the
Head Start expansion program.
• Eligibility for the child enrolled in Head Start expansion program is unrelated to the eligibility of the other children in the family.
Head Start child will remain eligible even if other children in the family are no longer eligible.
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Redetermination —
• Family consists of the mother, father and three children, one of whom is enrolled in Head Start and is receiving subsidy under the
Head Start Expansion program. The additional children receiving subsidy are not enrolled in Head Start.
• CCIS discovers, during the scheduled redetermination, that the father is working only 15 hours/week. An AA is sent terminating subsidy for the two children who are not enrolled in Head Start.
• The Head Start child will remain eligible even though the other children in the family are no longer eligible.
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Implementation
• OCDEL will provide a query for the CCIS agencies indicating which cases include HS children with siblings who are not enrolled in HS.
• The CCIS will use the results of the query to identify the cases which must be transferred to the Low-Income or Former
TANF child care program and must have a redetermination of eligibility completed.
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Failure Reason Codes
• The language associated with
Failure Reason Code
“928” was revised.
• The following Failure
Reason Codes were added:
945
946
947
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Generating Redetermination Packet:
1.
Select “Determine Eligibility” from the drop-down and click “Go” to navigate to the Child Care Program page to assess eligibility.
2.
Select “Low Income” or “Former TANF” as the child care program and click “Assess Eligibility.” Click “Assess” again through the validation that at least one child is in Head Start.
3. Enter a 8/31/2012 as the Redetermination Date so the packet will generate during the nightly batch, select an “Override Reason” and enter an “Override Comment” of “Department Mandate.” This will ensure redetermination packets are generated timely and mailed no later than 7/13/12.
4. Click “Confirm.”
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Processing Redetermination Packet:
1. Answer the question “Has Redetermination packet been returned?,” enter the “Date Redetermination packet was returned” and click
“Save” on the Full Redetermination page. Click “Save” again.
3. Update the case information in Open/Redetermination mode.
4. Select “Determine Eligibility” from the drop-down and click “Go” to navigate to the Child Care Program page to assess eligibility.
5. Select the appropriate child care program and click “Assess
Eligibility.” Click “Assess” again through the validation that at least one child is in Head Start.
6. Click “Confirm” if the case continues to be eligible.
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Generating Confirmation Notice – Co-payment or :
1. Enter the Co/Record for the case, select “Confirmation Notice –
P cc” from the “Correspondence” drop-down and click “Go” in the “Case Correspondence” section.
2. Select “§ 3041.104(c) OR (d) – Co-pay Increase OR Decrease,” as appropriate, and click “Save” on the Create New
Correspondence page.
3. Click ‘Display Selections” so the long description displays, enter the co-payment effective date in the variable text field and click
“Save.”
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Generating Enrollment Summary for Co-pay Change:
1. Select the enrollment(s) associated with child(ren) to whom the co-pay is assigned.
2. Enter a Monday date.
3. Enter “Co-pay Change” as the “Reason.”
4. Click “Generate Enrollment Summary.”
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Processing case failure(s) & maintaining eligibility for the HS child(ren):
1.
Select “Determine Eligibility” from the drop-down and click “Go” to navigate to the Child Care Program page to assess eligibility.
2. Click “Assess.”
3. Click “Update” under the “Failure Reasons” section on the
Individual Eligibility Results page and add the following failure reason codes:
• 928; AND
• 945, 946 and/or 947, as appropriate.
4. Click “Confirm.” An AA will be generated.
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Generating Child Care Stop Letter for Non-HS Child(ren):
1. Select “Enrollments” from the drop-down and click “Go” to navigate to the Case Enrollment Summary page.
2. Select the enrollment(s) associated with the non-HS child(ren) and click “Change/End Enrollment”.
3. Click “Update” under the “Enrollment Status Information” section on the Enrollment Detail page.
4. Enter the date the AA expires as the “Effective Date”, select
“Discontinue/Close” as the “Status”, select “Ineligible” as the
“Reason” and click “Save and Continue.”
5. Repeat for each non-HS child in the case for whom the enrollment(s) must be discontinued.
6. .
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Generating Enrollment Summary for the HS child(ren):
1. Select the enrollment(s) associated with the HS child(ren).
2. Enter a Monday date.
3. Enter “Child remains eligible under Head Start Expansion” as the “Reason.”
4. Click “Generate Enrollment Summary.”
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Removing Child Care Request for Non-HS Child(ren):
1. Select “Child Care Request” from the drop-down and click “Go” to navigate to the Care Request page.
2. Deselect “CC Request” for each non-HS child in the case, select
“No Need for Care” as the “Reason Ending Care” and click
“Save.”
3. Click “Assess Eligibility” in the “Case Eligibility” section on the
Case Summary page.
4. Select “Head Start” as the child care program and click “Assess
Eligibility” on the Child Care Program page.
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Removing CC Request for Non-HS Child(ren) – ( Cont’d)
5. Click “Assess Eligibility” again through the validation that this action will end eligibility in LI and assess eligibility for
HS.
6. Click “Confirm” on the Family Composition Eligibility
Results page.
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Entering a Tracking Date Alert
1. Set a tracking date alert by selecting “Tracking Dates” from the drop-down and clicking “Go.”
2. Click “New” on the Tracking Date Summary page.
3. Enter a “Tracking Date” equal to tomorrow’s date.
4. Enter a priority of “Medium.”
5. Enter “Alert Text” as “Generate Confirmation Notice –
Transfer to HS.”
6. Click “Save.”
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Generating Confirmation Notice – Transfer to HS:
1. Enter the Co/Record for the case, select “Confirmation
Notice – P cc” from the “Correspondence” drop-down and click “Go” in the “Case Correspondence” section.
2. Select “55 Pa.Code, Chapter 3041, § 3041.51 Transfer to
HeadStart” and click “Save” on the Create New
Correspondence page.
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Parent Notification
The p/c will receive the following:
Redetermination Packet.
AA – notifying the family of the ineligibility of the non-HS child(ren).
Stop Letter – notifying the family that payment will end effective the date the AA expires.
Enrollment Summary – notifying the family the HS child remains eligible.
Confirmation Notice – notifying the family of the transfer to the Head
Start Expansion child care program AND change in co-payment (if appropriate).
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Provider Notification
The provider will receive the following:
Stop Letter – notifying the provider that payment will end effective the date the AA expires.
Enrollment Summary – notifying the provider the HS child remains eligible AND change in co-payment (if appropriate).
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Provider Fraud —
• The intentional act of a provider that results in obtaining, continuing or increasing payment for subsidized child care for which the family was not eligible.
• Involves the following:
A false or misleading statement.
The failure to disclose information.
The failure to comply with the conditions of the Provider
Agreement.
Falsifying documentation related to attendance or published daily rates.
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Provider Fraud —
• Using the “NC” indicator/failing to mark absences.
• Charging the Department more than the provider’s published daily rate.
• Providing care at a location NOT approved by the CCIS or registered/certified by the Bureau of Certification.
• Failing to report debarred status.
• Charging the Department for care that was not provided, such as:
Children are not attending any longer/moved.
Dropping children off at free after-school or summer programs.
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Provider Fraud —
• The OIG will review and prosecute (if possible) provider only fraud overpayments.
• The CCIS will send provider only referrals to the OIG for review
UNLESS:
Payment has not yet been made.
The issue involves failure to comply with the Provider Agreement versus blatant provider fraud.
• There is NO minimum amount required for a referral to be made to the OIG.
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– No Payment
EXAMPLE: OIG confirmed fraud effective 5/7/12 through
6/15/12.
The CCIS will NOT make a referral to the OIG for collection .
The CCIS must:
• Withhold payment.
• Discuss future ramifications – OIG referral and/or termination of the Provider Agreement.
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Provider Fraud – Retroactive Overpayment
EXAMPLE: OIG confirmed fraud effective 2/6/12 through
5/31/12.
The CCIS must:
• Complete a fraud referral for the amount paid from
2/6/12 through 5/31/12.
• Discuss future ramifications – OIG referral and/or termination of the Provider Agreement.
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Provider Fraud
– Retroactive Overpayment & Partial Payment
EXAMPLE: OIG confirmed fraud effective 2/6/12 ongoing.
The CCIS must:
• Complete a fraud referral for the amount paid from
2/6/12 through 5/31/12.
• Withhold payment for June 2012.
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Provider Fraud –
Referral Criteria
Willful provider fraud is suspected.
The overpayment was not caused by administrative error.
EXAMPLE: A duplicate payment where the provider cashed the check.
The collection process was not initiated by the CCIS.
A signed provider agreement is available.
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Provider Fraud — §
• The CCIS must now refer suspected provider fraud to the OIG.
• Recoupment will be delayed for any case referred to the
OIG for suspected fraud until the investigation is complete.
• The method of recoupment will be determined in conjunction with the OIG.
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Procedures for Referring Provider Fraud
• The CCIS must complete the OIG 1009 – Subsidized Child
Care Services Application Investigation Referral form.
• See handouts:
OIG 1009 – Subsidized Child Care Services Application Investigation
Referral form.
OIG 1009 – Subsidized Child Care Services Application Investigation
Referral form SAMPLE.
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Provider Only Fraud
Complete Section 1.
Enter the Provider’s information in Number 6(a) – 17.
Complete Section 2.
List all of the questions you want the OIG to answer about the circumstances…who, what, when, where, how and why.
Be specific and detailed.
Call your OIG field representative for help in completing the form, if needed.
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Parent/Caretaker & Provider Collusion Fraud
Complete Section 1.
Enter the Parent’s/Caretaker’s information in Numbers 1 - 5 .
Enter the Provider’s information in Number 6(a) – 17.
Complete Section 2.
List all of the questions you want the OIG to answer about the circumstances…who, what, when, where, how and why.
Be specific and detailed.
Call your OIG field representative for help in completing the form, if needed.
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Delaying Recoupment — §
• Recoupment will be delayed for case referred to the OIG for suspected fraud until the investigation is complete.
• The method of recoupment will be determined in conjunction with the OIG.
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Overpayment Notification —
§§
• The CCIS will NOT collect/recoup on any overpayment in which fraud is suspected and a fraud referral was made to the OIG.
• The CCIS must send the Confirmation Notice notifying the p/c of the overpayment and include the detailed calculation of the overpayment amount.
• The CCIS will NOT send the Repayment Letters unless the suspected fraud investigation has been completed and the OIG instructs the CCIS to pursue collection.
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Overpayment Collection
• The OIG will continue to collect overpayment for cases that are no longer active.
• The CCIS may make a referral to the OIG to pursue collection.
• If the OIG is unable to collect from the p/c and the p/c begins receiving subsidized child care again at a later date, the CCIS will instruct the p/c that the overpayment will be collected through an increased co-payment.
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Methods of Disqualification — §
• Reinstated a method of disqualification used under 3040.
• The p/c may agree to be disqualified by signing an administrative disqualification hearing waiver with the OIG.
There is no change to the procedures regarding processing an individual disqualification.
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Regulated Agreement —
• Bullets added:
I understand that if I am an owner, operator or director of a child care facility, I am not eligible for the subsidized child care program if there is space available to enroll my children in the facility.
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Regulated Agreement —
• Care in lieu of parental care for part of a 24-hour day.
• The following do NOT meet the definition of child care:
The p/c may not care for his/her own child(ren).
When a p/c works in a child care center, the p/c may not be a teacher in his/her child’s classroom.
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Regulated Agreement —
• Bullets added:
If I employ a subsidy parent, I must ensure that the parent/employee is not paid to care for his/her own subsidized child(ren). This means the parent/employee may not be assigned to his/her child’s classroom and he/she may not be assigned to supervise his/her child during evening and/or nighttime hours.
If this occurs, the daily rate paid for the employee’s child while the employee watches his/her child will be considered an overpayment. This may result in a referral to the OIG for fraud investigation.
If I am the owner, operator or director of a family or group child care facility, I agree that the subsidized child cannot live at the same address where s/he is enrolled.
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Regulated Agreement —
• Added paragraph:
The CCIS and/or OCDEL will investigate complaints and assess compliance with the requirements of this
Agreement. The CCIS will refer all cases of suspected parent/caretaker and/or provider fraud to the OIG.
OCDEL may instruct the CCIS to delay or withhold provider payment, in part or in full, pending the outcome of an OIG investigation for suspected fraud.
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Regulated Agreement —
• (b)(1) – Federal Debarment
• Sentence added:
A provider who fails to report his/her suspended/debarred status to the CCIS will be referred to the OIG.
June 2012 154
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Regulated Agreement —
• (2)(i) - added:
This agreement shall end if:
A provider fails to:
(i) Comply with the conditions specified in this Agreement and its Appendices.
• (3)(b)(4) - added:
The CCIS may end this Agreement without advance notice and concurrence from OCDEL for the following reasons:
(4) If, after investigation, the provider is determined to have committed or colluded to commit fraud.
June 2012 155
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Regulated Agreement —
• (B)(1) – sentence change:
Payment is made effective on the first day the child attends following the date authorized by the CCIS on a form prescribed by OCDEL.
• (C)(3)(a) – Co-payment – sentence added:
Parents are also required to pay an equivalent advance co-payment to the provider, which is refunded to the parent upon termination .
June 2012 156
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Regulated Agreement —
(Cont’d)
• (C)(4) – Absences – sentence change:
The CCIS will pay the provider for five consecutive days of absence. On the sixth consecutive day of absence, the provider must report the absences to the CCIS.
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Regulated Agreement —
(Cont’d)
• Paragraph added:
The CCIS will pay for a maximum of 25 days of absence during the
State’s fiscal year (July 1 – June 30) for each child. Children funded through the Food Stamp/Supplemental Nutrition Assistance Program are not subject to the 25 days absence limit. This is a cumulative number per child, regardless of provider transfers during the fiscal year. If a child’s absences exceed 25 days, the parent/caretaker is responsible to pay the provider for all additional absences. The parent/caretaker is responsible to pay the provider’s verified published daily rate for each day of absence starting with the 26th absence in addition to the weekly co-payment. Suspended days and provider closed days are not considered days of absence.
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Regulated Agreement —
(Cont’d)
• (7)(c) – Closed Days – sentence change:
Since the provider cannot change closed days once submitted, the provider may want to limit the number of closed days declared at the beginning of the year. This will allow a couple of days that could be added in case of an emergency or unplanned closures later in the year.
• (7)(e) – Closed Days – sentence added:
In no case will the subsidy program pay for more than 15 closed days per year beginning July 1 through June 30.
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Regulated Agreement —
• (D) – Paragraph Added:
The provider must accurately complete attendance invoices each month and document all absences for children who are not in care. The invoice must be submitted to the CCIS monthly either online or on a form provided by OCDEL. The invoice must include the days of attendance and absences for each child. For a newly enrolled child, payment will begin on the first day the child attends. If the child is absent on the initial day of scheduled care, payment will not start until the child attends.
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Regulated Agreement —
(Cont’d)
• (D) – Paragraph Added:
The CCIS may audit providers who utilize the “No
Change” code on a regular basis when completing
Attendance Invoices. Non-compliance with accurate completion of Attendance Invoices may lead to termination of the Agreement and referral to the OIG for fraud investigation.
June 2012 161
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Regulated Agreement —
• Track provider with 7 or more enrollments who submit an invoice with “No Change.”
• When a provider has 3 invoices submitted with “NC” box checked for all children within the fiscal year:
Contact the provider and ask for verification (i.e., in-house attendance sheets, daily sign-in sheets or the meal count sheet from the food program).
Require back-up information for any invoice with “NC” checked for all children for the rest of the fiscal year.
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Regulated Agreement —
(Cont’d)
• If there is a discrepancy with the back-up information:
Adjust the paid and unpaid absences in PELICAN CCW.
Counsel the provider, stressing the importance of the integrity of the signed invoice and the requirement to report absences per the Provider Agreement.
Explain if this happens again it could result in a referral to the OIG and/or termination of the Provider
Agreement.
June 2012 163
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In-Home Agreement —
• Bullets added:
The provider supplies Social Security Number verification.
The provider does not live in the home of child(ren) receiving care.
The provider continues to meet the terms and conditions of this agreement.
OCDEL and the CCIS agree to continue this agreement.
June 2012 165
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In-Home Agreement —
• Bullet added:
The child’s health condition changes in a manner that no longer requires in-home care and/or the p/c no longer needs care between the hours of 9 p.m. and 6 a.m.
• Correction:
Additionally, the participation of the provider in the subsidized child care program may be terminated as a result of a complaint investigation by OCDEL which alleges that the parent/caretaker or the provider violates the provisions of this Agreement.
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In-Home Agreement —
• Sentence added:
The CCIS will refer all cases of suspected p/c and/or provider fraud to the OIG. OCDEL may instruct the
CCIS to delay or withhold provider payment, in part or in full, pending the outcome of an OIG investigation for suspected fraud.
June 2012 167
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In-Home Agreement —
• Moved the Indemnification paragraph to this section.
June 2012 168
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In-Home Agreement —
• Provider Standards – added sections:
(J) – The provider must notify the CCIS on day six if a child does not require care for five consecutive days.
(K) – The provider must provide photo-identification or two other forms of identification.
(L) – The provider must provide proof of address.
• Parent/Caretaker Guidelines – sentence added:
A parent/caretaker who fails to report his/her suspended/debarred status to the CCIS will be referred to the
OIG.
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In-Home Agreement —
• (C) – Submitting an Invoice for Payment –
Paragraph added:
The provider must accurately complete attendance invoices each month and document all absences for children who are not in care. The provider must confirm the days the child received care and note any days the child was not in the home. Payment will begin on the first day the provider cares for the child.
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In-Home Agreement —
(Cont’d)
• (C) – Submitting an Invoice for Payment –
Paragraph added:
Both the provider and the parent/caretaker must sign the Attendance Invoice. The CCIS may audit a provider who utilizes the “No Change” code on a regular basis when completing Attendance Invoices. Noncompliance with accurate completion of Attendance
Invoices may lead to termination of the Agreement and referral to the OIG for fraud investigation.
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In-Home Agreement —
(Cont’d)
• (D) – Fraud – Subsection and paragraph added:
All cases of suspected fraud will be referred to the OIG.
OCDEL may instruct the CCIS to delay or withhold provider payment, in part or in full, pending the outcome of an OIG investigation for suspected fraud.
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R/N Agreement —
• Bullet added:
I agree to provide care at the physical address indicated in this agreement and at no other location.
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R/N Agreement —
• Paragraph added:
The CCIS and/or OCDEL will investigate complaints and assess compliance with the requirements of this
Agreement. The CCIS will refer all cases of suspected fraud to the OIG. OCDEL may instruct the CCIS to delay or withhold provider payment, in part or in full, pending the outcome of an OIG investigation.
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R/N Agreement —
• (b)(1) – Federal Debarment
• Sentence added:
A provider who fails to report his/her suspended/debarred status to the CCIS will be referred to the OIG.
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R/N Agreement —
• Added:
The CCIS may end this Agreement without advance notice for the following reasons:
(4) Failure to report child absences as required.
(5) Provider fraud.
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R/N Agreement —
• (3)(a) – Co-payment – sentence added:
Parents are also required to pay an equivalent advance co-payment to the provider, which is refunded to the p/c upon termination .
• (3)(f) – Co-payment – sentence added:
Any payment that the p/c makes to the provider must be first applied to cover all delinquent and current co-payments.
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R/N Agreement —
(Cont’d)
• (4)(a) – Absences – sentence change:
The CCIS will pay the provider for five consecutive days of absence. On the sixth consecutive day of absence, the provider must report the absences to the CCIS.
• (4)(b) & (c) – Absences – added:
Same as the Regulated Provider Agreement.
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ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
R/N Agreement —
• (1) – Sentence Added:
For a newly enrolled child, payment will begin on the first day the child attends. If the child is absent on the initial day of scheduled care, payment will not start until the child attends.
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ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
R/N Agreement —
(Cont’d)
• (2) – Paragraph Added:
The CCIS may audit providers who utilize the “No
Change” code on a regular basis when completing
Attendance Invoices. Non-compliance with accurate completion of Attendance Invoices may lead to termination of the Agreement and referral to the OIG for fraud investigation.
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ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
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ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
— FT rates above $11.00/day reduced by 15% or to $11.00, whichever is higher.
— PT rates above $7.75/day reduced by 15% or to $7.75, whichever is higher.
Bradford
Counties NOT affected:
Franklin Northumberland
Cambria Greene
Cameron Huntingdon
Clearfield Jefferson
Columbia
Crawford
Juniata
McKean
Schuylkill
Somerset
Sullivan
Susquehanna
Tioga
All counties will send out NEW Appendix Bs with agreements.
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ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Secretary of Education | Gary Alexander, Secretary of Public Welfare www.education.state.pa.us|www.dpw.state.pa.us
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ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Distribution of Provider Agreements &
Payment Rates
• Send R/N Provider Agreements out the last week of June
(i.e., 6/25/12).
R/N Appendix Bs will be generated by HQ and available through the shared drive.
Locally create Out-of-State R/N Provider & all In-Home
Provider Appendix Bs.
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ACT 22 Expedited Regulation Changes
Tom Corbett, Governor | Ronald Tomalis, Acting Secretary of Education | Gary Alexander, Acting Secretary of Department of Education www.education.state.pa.us|www.dpw.state.pa.us
Distribution of Provider Agreements &
Payment Rates
(Cont’d)
• Send Regulated Provider Agreements out once the budget is passed.
Regulated Appendix C2 s will be generated by HQ and available through the shared drive.
Locally create Out-of-State Regulated Provider Appendix C2 s.
• Signature pages are due 7/30/12.
• Suspend enrollments effective 8/20/12 if not submitted by
8/17/12.
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