SUSPENDING ENROLLMENTS FOR AT-RISK CHILD CARE

DISCUSSION PAPER

Background

The Child Care and Development Block Grant Act of 2014 (CCDBG Act) made significant changes to the Child Care and Development Fund (CCDF). These changes are anticipated to impact the level of child care enrollments beginning in Board Contract Year 2017 (BCY’17).

Under current rules, if a parent experiences a temporary job loss or reduction in work hours below the required 25 hours per week, child care would be discontinued during the child’s eligibility period. Currently, Local Workforce Development Boards (Boards) expect a fairly regular and predictable attrition rate as parents are no longer eligible due to job loss or reduction in work hours below the 25-hour requirement. Additionally, Boards with six- or nine-month eligibility periods expect a certain attrition rate of familiesthat are no longer determined eligible once the eligibility period has ended. Boards manage the level of children who can be enrolled within the Board’s child care allocation using their expected attrition rates, and open and close enrollments accordingly.

The CCDBG Act requires a 12-month eligibility period for child care services. Care cannot be discontinued during the 12 months unless a parent experiences a permanent end of work, job training, or education activitiesduring the 12-month period. If a parent experiences a permanent end of job, training, or education, care must continue for three months in order for the parent to look for work or begin a job training or education activity. If a parent resumes work, job training, or education activities within the three months, then care would continue through the 12-month period.

Additionally, the CCDBG Act requirement for a 12-month eligibility period applies to children receiving Child Protective Services (CPS) child care through the Department of Family and Protective Services (DFPS). DFPS typically authorizes fewer than six months of CPS child care services for open CPS cases. In some cases, and if recommended by DFPS, child care would continue for up to six months using TWC funds after the CPS case is closed. However, in most cases, care is discontinued by DFPS immediately upon closure of the CPS case. In these instances, under the CCDBG Act requirements, care must continue through the end of the 12-month eligibility period.

Issue

It is anticipated that these changesrequired by the CCDBG Act will have a significant impact on both the attrition rate and the anticipated level of CCDF enrollments, thus affecting Boards’ ability to project manageableenrollment levels.

Recommendations

Staff recommends that Boardssuspend enrollments for new at-risk child care cases effective August 1, 2016, unless the Board can demonstrate—and TWC concurs—that enrollments at the end of BCY’16:

  • are sustainablethroughout BCY’17;
  • allow for the continued enrollment of TWCpriority groups (Choices, Transitional, TANF Applicant, and SNAP E&T), as well as former CPS children, as authorized by DFPS;
  • will not exceed a Board’s BCY’17CCDF funding; and
  • will not require thateligible children be removed from care.

Additionally, staff recommendsthat a Board’s BCY’16 child care funds not expended by the BCY’16 service period end date of October 31, 2016,will be extended through December 31, 2016.

DP – Suspending Child Care Enrollments(07 27 16)Notebook