An MFIP/DWP client is eligible for CCAP if the client meets all CCAP eligibility requirements. If a client meets CCAP eligibility requirements and has an Employment Plan, the amount of child care authorized must be based on the parents’ schedule of participation in the activities identified in the Employment Plan, the child’s school schedule, the provider’s availability, and any other factors that would affect the amount of care that the child needs.
The amount of child care authorized should reflect the child care needs of the family and minimize the out-of-pocket child care costs to the family.
The agency should develop a method of communication between the job counselor and the CCAP worker that supports sharing information as efficiently and as timely as possible so care can be authorized. The job counselor and CCAP worker can communicate through a variety of methods (including, but not limited to fax and email).
Because families that are Schedule Reporters must have Service Authorizations changed based on their activity participation, job counselors should report changes in activity to CCAP workers at least for families who are Schedule Reporters. Agencies should determine communication guidance for CCAP workers and job counselors in their agency. If agencies develop different guidelines for communication between CCAP workers and job counselors based on a family’s reporting type, workers must coordinate to understand which reporting type the family is considered and what must be reported. See Chapter 8.3 (Reporting requirements) and Chapter 8.3.6 (Reporting types).
Your agency may determine whether the job counselor or CCAP worker is responsible for determining how many hours of child care are needed, provided that the worker is considering:
· The activity schedule (days and times) of the parent(s).
· The school schedule (days and times) of the children.
· The provider’s availability.
The job counselor is responsible for:
· Determining the activities included in the Employment Plan.
· Providing the CCAP worker with the activities included in the Employment Plan, including activity type and activity begin dates.
· Monitoring participation in Employment Plan activities on an ongoing basis.
· Adjusting the Employment Plan as needed.
· Determining if a client is out of compliance with his/her Employment Plan.
· Notifying the CCAP worker within 10 days of changes in Employment Plan activities, changes in the parent’s schedule if known, and sanctions.
The job counselor is encouraged to:
· Provide the CCAP worker with either the activity schedules of the parent(s) and children OR the days and times that child care is needed.
· Cluster or group Employment Plan activities to create periods of time that work with child care provider schedules and practices, when possible.
The job counselor may indicate the number of hours of child care needed for activities other than employment and education.
The job counselor is not required to send the Employment Plan to the CCAP worker.
The job counselor can use the MFIP/DWP Employment Services Child Care Request DHS-7054 (PDF) or an agency created form to send information to the CCAP worker.
The CCAP worker is responsible for:
· Determining how many hours of care are needed.
· Authorizing the care the family is eligible for.
· Acting on information received from the job counselor within 10 days.
· Ensuring that families and providers are given 15 day notice of adverse actions.
· Communicating concerns about actual participation in the activities in the Employment Plan to the job counselor. The CCAP worker should not take action to reduce or end the authorization for non-participation in Employment Plan activities unless the job counselor changes the Employment Plan.
· Obtaining schedule verification of the activities in the Employment Plan only if the job counselor has not provided the activity schedule (days and times) or the days and times that child care is needed.
· Obtaining income verification for employment. An Employment Plan cannot be used as verification of income for CCAP.
CCAP workers should not re-verify activity information that is monitored by the job counselor.
CCAP workers are not responsible for monitoring participation in the activities in the Employment Plan.
The job counselor regularly determines if the participant is participating in the activities in the Employment Plan. They must take appropriate action when and if changes occur or an Employment Plan ends.
Specific details about the status of employment plans and their active dates:
· If an MFIP/DWP participant has an Employment Plan, consider that person to be participating in the activities in the Employment Plan until the job counselor ends or changes the Employment Plan.
· All signed Employment Plans are considered to be “approved.”
· The job counselor does not need to indicate a date that the Employment Plan or the Employment Plan activities will end if the job counselor believes that the family will continue to participate in the activities.
· The review dates listed on the Employment Plan should not be interpreted as “end dates.” Child care assistance should not automatically end if an Employment Plan review date has passed and a new Employment Plan has not been completed.
· Workforce One (WF1) assigns a “Plan Start Date” on the front page of the Employment Plan and does not allow that date to be adjusted. Individual activities within the Employment Plan can have earlier dates than the “Plan Start Date.” CCAP can be authorized and paid back to the earlier individual activities dates as long as the family was MFIP eligible and meets all CCAP eligibility requirements.
· For information about when a participant is out of compliance with their Employment Plan, see Chapter 184.108.40.206 (MFIP sanctions) and Chapter 220.127.116.11 (DWP non-compliance).
Participants may be charged with CCAP overpayments if:
· The job counselor fails to notify the CCAP worker within 10 days that an Employment Plan has changed or ended or that the participant is sanctioned.
· The participant does not provide timely reports of changes in income over 85% of SMI, family composition or other factors related to the family’s eligibility for child care assistance.
A job counselor may determine that a participant has not been in compliance for a prior period of time with some or all of the activities identified in the Employment Plan. There should not be a CCAP overpayment due to lack of or reduced participation in the Employment Plan activities, except in cases of MFIP and/or CCAP fraud.
The agency should implement safeguards to ensure that the appropriate amount of care is being provided to CCAP clients. Safeguards might include Employment Plan/CCAP audits.
Minnesota Statutes 119B.05
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Minnesota Statutes 119B.07
Minnesota Rules 3400.0080