Individualized County Child Care Subsidy (Pilot) Program: Answers to Frequently Asked Questions (FAQ)
1) When can a participating Pilot county submit a plan or modification to the California Department of Education?
Effective January 1, 2019, the California Department of Education (CDE) established two annual opportunities for counties to submit plans or modifications: February 1–February 15 and June 15–June 30.
The intent of establishing these submission periods is to make the Pilot process more organized and efficient. If the submission deadline is on a weekend, then the deadline is extended to the next business day. Submissions that are not received on a timely basis will not be considered.
2) What are the elements of a Pilot county plan submission and/or modification?
Each Pilot plan submission must include the following:
- Cover Letter stating the policy changes being requested by the county and any changes to the ‘Participating Contractor’ list
- Pilot Template demonstrating a need for the policies, showing baseline data. The Pilot Template is where counties specifically identify or propose policies they would like to opt-in to.
- Needs Assessment report and other data as applicable detailing the child care needs in the county, among other criteria as specified in California Education Code (EC) Section 8332.2(a)(1). Data should support the need for the policy change.
- List of participating contractors and contract types for each contractor (along with signed memorandums of understanding for each contractor)
3) How should a county develop the Pilot Cover Letter?
The Pilot Cover Letter should be drafted on county letterhead and be no longer than one page in length. The purpose of the Pilot Cover Letter is to provide a summary of the submission/modification plan. The Pilot Cover Letter must include the following components:
- Policies that are being requested and/or opted out of
- Requests to add or remove contractors and contract types
- Date of submission
4) What is the Pilot Template?
The Pilot Template is a spreadsheet detailing the specific policies requested by the county. The CDE has developed this Template in accordance with EC Section 8332.25 to streamline the review process. The Pilot Template includes the following column headers:
- Proposed Local Policy
- What data collection in the Needs Assessment supports superseding state law for this local policy?
- What goal does this meet?
- Expected Measurable Outcomes
- Status
The CDE relies heavily on measurable data provided in the Template, with a deep focus on columns B and D, when determining whether to approve a policy request.
5) What are the CDE’s expectations for providing data?
As a county develops the data section of the Pilot Template, the county must be careful to provide data that illustrates the problem faced and how the proposed policy will address the issue presented. This data should be aligned with the stated goal.
After deciding what data to include, provide references to the relevant data from the county’s Needs Assessment report or other sources. A Pilot county may wish to cite multiple data points to support superseding state law on a certain policy. If so, include citations for each of the data elements you include. References should consist of the page and/or chart numbers from the Needs Assessment report that show the data element being used.
For example, if a county wishes to cite the number of eligible children by income ranking in the county, the county must include, in the Template, the page number where the data is located in your Needs Assessment. In the Template, the county may list “Number of children by income ranking in the county (page X of Needs Assessment)”.
6) What if a county cannot provide quantitative data in the Pilot Template?
If the county cannot produce quantitative data, the county must provide qualitative data and describe how and when the county will collect appropriate data for the CDE to use in evaluating the county’s progress.
7) What does the CDE mean by “Needs Assessment report and other data applicable”?
Counties must consider data when developing their plan and provide the data that supports their policy requests in the Pilot Template submitted to the CDE.
Specifically, EC Section 8332.2(a)(1)) states that the county must consider the following data elements when preparing the Pilot Template:
- Needs Assessment data collected pursuant to EC Section 8499.5(b)
- Data collected by resource and referral agencies
- The county's self-sufficiency income level
- The cost of providing child care
All counties must provide a copy of their county Needs Assessment report with their Pilot plan submission.
If a county has not included in their Needs Assessment report data collected by resource and referral agencies, data on the county’s self-sufficiency income level, or data on the cost of providing child care—and if a county plans on relying on those data elements or others in their Pilot Template to support a policy request—the county must provide the additional data elements cited to the CDE in addition to providing the Needs Assessment report.
8) What is a Participating Contractor List?
The Participating Contractor List is a document included in the Pilot plan or modification that lists all participating contractors and their contract type(s).
We have included an example of a participating contractors list. Please remember to always include the following:
- County name
- Date submitted
- List of participating contractors, including any you wish to add or remove during the current modification period
- Contract types
9) What are Memorandums of Understanding?
Memorandums of Understanding (MOUs) are signed by each participating contractor and Local Planning Council (LPC) Coordinator in their county. A MOU is an agreement that informs the CDE of the contractors participating in the Pilot plan.
It is the responsibility of the LPC Coordinator for each county to ensure the individual that signs the MOU on behalf of the contractor is authorized to do so. The authorized signer is typically the Executive Director, but can also be another individual as long as there is a resolution on file with the CDE Contracts Office specifying the signer is allowed to sign on behalf of the contractor. The CDE considers all contractors with a signed MOU to be Pilot participants and contracts will be executed accordingly.
10) Can Pilot counties with 24-month eligibility policies, certify or recertify twelve-year-old children for 24-months of eligibility?
No. The CDE modified its 24-month eligibility policy to include an exception that children who are 12 years old at the time of initial certification or recertification shall only be certified for 12-month eligibility, regardless of a county’s previously approved plan. This policy is effective as of the date of the letter alerting counties to this change: January 8, 2020.
11) What happens when a contractor operates in two Pilot counties?
When a contractor operates in two different counties, the contractor will receive separate contracts for each of the Pilot programs indicating the amount of funding for each county and the provisions for each. In other words, Pilot participants will be required to split the participating/applicable contract type(s) if providing services in more than one county.
12) What is needed for a Pilot county to implement a Pilot Reimbursement Rate?
Specific information and criteria are needed in order to implement a Pilot Reimbursement Rate (PRR). The process is as follows:
- The LPC coordinator submits a data request to the CDE. Data will include fiscal contract terms and earnings information from baseline year and all subsequent years.
- Pilot contractors identify projected contract unearned child days of enrollment (cdes).
- The LPC coordinator submits a formal request to the CDE for a PRR during the February or June modification periods.
- The CDE reviews the proposed rate and contractor information.
- Letters of intent are submitted by each participating contractor.
- The formal approval of the PRR is sent to each contractor.
- Contracts are sent to each contractor to be signed and returned to the CDE.
13) Do all Pilot contractors need to contribute cdes to receive the PRR?
No. Not all contractors will have unearned cdes to contribute. When contractors are considering the amount of cdes to potentially contribute, they should consider earnings data from prior years and other factors such as legislative changes or plans for expansion that may impact their future earnings.
14) How often can a Pilot county request a PRR?
A Pilot county may only have one PRR for each contract type per fiscal year. A PRR request submitted in the February modification period can be retroactive to July 1 of the current fiscal year or go into effect the next fiscal year. A PRR request submitted in June will be for the new, upcoming fiscal year.
15) Do policy changes during the modification period still require signatures of all participating CDE Contractors, similar to the letter of intent needed during the Pilot Rate Reimbursement process?
After the CDE approves the Pilot submission or modification, participating Pilot contractors will be required to sign and submit an amended contract agreeing to the revised provisions. The CDE expects that any Pilot policy changes requested during the February or June submission periods have been communicated to all Pilot participating contractors by the county LPC Coordinator prior to the Pilot plan submittal to the CDE.
16) Can Pilot counties that have collaborated on aligning policies similarly across counties submit a joint Pilot plan?
No. Counties may collaborate to determine shared goals and policies, but each county must submit their plans individually using the CDE Pilot Template during the biannual submission period opportunities in February and June.
17) Can pilot counties submit plans at any point during the fiscal year?
No. Assembly Bill 108, which focused on individualized county child care subsidy plans, was passed in 2018, and required that the CDE “establish instructions and timelines for submittal or modifications of the plans” (EC Section 8332.25). In response to this statutory requirement, the CDE established a pilot plan template and modification period timelines of February 1–15 and June 15–30 each year. Any requested changes must be provided in the template developed by the CDE and be submitted within one of the modification periods. These rules help the CDE keep the administrative process consistent across counties and streamline the review process.
18) When is the effective date of the 24-month policy change letter that was emailed to all pilot counties on January 8, 2020? The letter is dated 12/17/20.
The effective date of the policy change is the same date of the email, January 8, 2020, as this was the first date the counties were made aware of the policy change.
19) How should pilot contractors implement the revised 24-month policy that is effective January 8, 2020?
All certifications/recertifications that occur after January 8, 2020, should take into account this policy revision. Contractors that, for example, certified 12-year old children for 24 months prior to January 8, 2020, will be held harmless as that was the allowable pilot policy in effect prior to the email stating the change.
In terms of 13-year old children, no new certifications should occur once a child turns 13 years of age. Pilot contractors can certify children that are 12 years of age, but only for 12 months. Once that 12 months is up, they would not be eligible for recertification. For children under 12 years of age served by pilot contractors, those children can be certified for 24 months, since they will not be receiving services under that certification when they are 14 years old. Services should not be occurring for children 14 years of age.
20) We are receiving CDD-801A error messages when reporting 14-year old children, even though they are currently eligible for services, as they were certified for 24-month eligibility when they were 12 years old. This certification occurred prior to the 24-month policy change effective January 8, 2020. What should we do?
The CDMIS team has made the necessary changes to allow for eligible 14-year old children who were certified prior to January 8, 2020, to be successfully saved on a monthly CDD-801A report. Please note that pilot agencies are required to retroactively report any eligible 14-year old children who were previously omitted on all CDD-801A reports. For additional guidance, feel free to contact CDMIS staff at, CDMIS@cde.ca.gov.
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