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9.1.5 Authorizing Care-Employment Plans

ISSUE DATE: 03/2026

An MFIP client is eligible for CCAP if the client meets all CCAP eligibility requirements.

If a family meets CCAP eligibility requirements and the parent(s) 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 for the family.

For more information about authorizing care, see Chapter 9.1 (Authorizing Child Care) and Chapter 9.12 (Authorization Changes During the 12 Month Eligibility Period).

Communication

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 verbal communication, fax, and email).

Roles and responsibilities

Job counselors and CCAP workers have unique roles and responsibilities. Agencies are encouraged to develop guidance for whether job counselors are responsible for helping CCAP workers determine the child care needs for families with Employment Plans.

Job counselor roles and responsibilities

The job counselor is responsible for:

· Determining the activities included in the Employment Plan.

· 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 their Employment Plan.

· Providing the CCAP worker with the activities included in the Employment Plan, including activity type and activity begin dates.

The job counselor is encouraged to:

· Provide the CCAP worker with the activity schedules of the parent(s) and the school schedule of the children.

· 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:

· Notify the CCAP worker of sanctions, changes in Employment Plan activities, and changes in the parent’s activity schedule.

· Indicate how many hours of child care are needed to support the Employment Plan activities, including travel time. Travel time to support Employment Plan activities can exceed more than 2 hours per day as determined by the job counselor.

· If the job counselor indicates how many hours of child care are needed, they must consider:

· 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 not required to send the Employment Plan to the CCAP worker.

For agencies that allow job counselors to indicate child care needs, the job counselor can use the MFIP Employment Services Child Care Request DHS-7054 (PDF) or an agency created form to send information to the CCAP worker.

CCAP worker roles and responsibilities

The CCAP worker is responsible for:

· Determining how many hours of child care are needed if the job counselor has not provided this information.

· Authorizing care in MEC2.

· Acting on information received from the job counselor within 10 days.

· Ensuring that families and providers are given 15-day notice of adverse actions.

· Obtaining parental activity schedule verification and child school schedule information, if needed. This information is not needed if the job counselor provides it or if the job counselor indicates how many hours of child care are needed, taking into consideration the activity schedule, child school schedule, and provider availability.

· Obtaining income verification for employment. An Employment Plan cannot be used as verification of income for CCAP.

· Communicating with the job counselor. This may include clarifying whether the job counselor considered all factors when indicating how many hours of child care are needed. It may also include sharing information about activity participation.

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.

Employment Plan information

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.

Details about the status of Employment Plans:

· If an MFIP participant has an Employment Plan, consider that person to be participating in the activities in the Employment Plan until the job counselor communicates otherwise 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 dates of individual activities 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 4.3.3.9 (MFIP Sanctions).

Employment Plans and overpayments

The agency should implement safeguards to ensure that the appropriate amount of care is being provided to CCAP families. Safeguards might include Employment Plan/CCAP audits.

Families may be charged with CCAP overpayments if:

· The family 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.

· CCAP fraud is determined. See Chapter 13.6 (Disqualification for Wrongfully Obtaining Assistance – Families).

· MFIP fraud is determined, and that results in the family’s reduction or loss of CCAP eligibility or authorization. See Chapter 4.3.3.6 (MFIP Special Circumstances).

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. Do not assess a CCAP overpayment due to lack of or reduced participation in the Employment Plan activities, except in cases of MFIP and/or CCAP fraud. If a job counselor fails to notify the CCAP worker that an Employment Plan has changed or ended, this would not be an overpayment because the overpayment resulted solely from agency error. See Chapter 14 (Overpayments) to determine when to assess an overpayment.

Legal authority

Minnesota Statutes 142E.08
Minnesota Statutes 142E.14, subd. 2
Minnesota Rules 3400.0040
Minnesota Rules 3400.0080
Minnesota Rules 3400.0110, subp. 3

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Child Care Assistance Program (CCAP) Policy Manual