EEC Management Bulletin
EMB FY 2010 - 02

Subject: Eligibility Self-Reporting and Impact on Parent Co-Payment Fees

Date Issued: December 23, 2009

Effective Date: Immediately

For Use By: Contracted Providers, Family Child Care Systems, and Child Care Resource and Referral Agencies (CCR&Rs)

Synopsis: Clarifies and revises the self-reporting requirements for families receiving child care assistance in the Commonwealth

Further Info: Questions or clarifications related to this EEC Management Bulletin shall be emailed to: bulletinquestions@massmail.state.ma.us

Supersedes: This EMB supersedes the self-reporting requirements in the EEC Financial Assistance Policy Guide, Section 3.6: Eligibility Self-Reporting; the EEC Child Care Subsidy Application and Fee Agreement; the Regular Child Care Voucher; the EEC Financial Assistance Agreement; and to the extent that the policies contained in the document conflict with any other EEC Financial Assistance policies or forms, the policies contained herein govern.

Introduction

Currently, EEC requires families to self-report all changes in income, service need, family size or composition, or any other circumstance that may impact their eligibility for EEC financial assistance or parent fee within ten (10) business days to their contracted provider/System or CCR&R. See generally EEC Financial Assistance Policy Guide, at Section 3.6: Self-Reporting; and EEC Financial Assistance Agreement. Typically, self-reporting changes to contracted providers/Systems or CCR&Rs results in a family's reassessment and often results in a modification to the family's parent co-payment fee. The existing EEC "Parent Co-Payment" Table assigns 28 unique fee levels for family copayment fees based on routine/minor adjustments to income. See EEC Financial Assistance Policy Guide, at Appendix A: Parent Co-Payment Table (effective July 1, 2008).

EEC is issuing this EMB in an effort to stream-line the reassessment process, to reduce the administrative burden on entities managing child care subsidies and to assist families seeking to achieve self-sufficiency in the Commonwealth. To achieve these goals, this EMB revises the rules for families regarding when they must self-report a change in income.

3.6 Eligibility Self-Reporting

New/Updated Policy Statement:

All families are responsible for self-reporting substantial changes that might affect their eligibility to receive financial assistance for early education and care. Substantial changes must be reported immediately, but no later than 10 business days after the change takes place.

Substantial changes triggering self-reporting by a family receiving child care financial assistance may include:

  1. "significant changes" in income,
  2. employment change (e.g., loss of job, new employer, changes to schedule, etc.),
  3. school and/or training schedule change,
  4. family size change (e.g., changes to family composition and/or the number of children receiving care),
  5. change in address, or
  6. any other factor that may affect eligibility.

For purposes of this policy, a "significant change" in income is defined as a 20% increase or decrease in total household income. Unless there is a "significant change" in the total household income, the family is not required to report the change, nor is the CCR&R or contracted provider required to re-determine the families' copayment fee prior to the 12 month reassessment appointment. If a significant change in the total household income occurs, which impacts the family's copayment fee, the effective date of the new copayment will be the first day of the month after the information is received by the CCR&R or contracted provider/system.

Although routine and/or minor changes in income (e.g., less than 20%) may not trigger self-reporting requirements, in some circumstances minor income changes may impact a family's eligibility. For this reason, it is in the best interests of all families receiving subsidized child care in the Commonwealth to report any change in income to their voucher manager. If contacted by a family to self-report changes that may impact the family's income, household composition or service need prior to the expiration of a voucher or authorization, the CCR&R or contracted provider/system shall determine whether the reported change amounts to a substantial change requiring a reassessment of eligibility or redetermination of co-payment fee. All reported changes must be documented, in writing, in the case file, regardless of the need to conduct a reassessment or to re-determine the parent co-payment fee.

Additionally, families should be made aware of the fact that routine or minor income increases will impact eligibility for child care assistance at each assessment. For example, if a family's total household income is at or near 85% of the SMI, the CCR&R and/or contracted provider/system should notify the family that a routine or minor change to a parent(s)' income may actually result in the family being ineligible for child care assistance; therefore, any increase in total household income must be reported to ensure continued eligibility.

When families report a change in their eligibility, within the annual assessment period, the CCR&R and/or contracted provider/system, may allow the family to mail or fax the required documentation to demonstrate their continued eligibility for EEC financial assistance. CCR&Rs and/or contracted provider/systems shall not be required to schedule a face-to-face reassessment.

A family's failure to report a substantial change in family status, as described above, to the CCR&R and/or the contracted provider/system within 10 business days may result in the termination of financial assistance and/or an improper payment of child care assistance that may subject the family to recoupment of any improper payments.