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Frequently Asked QuestionsDHS Child Care and COVID-19 CoronavirusEffective March 16th, 2020Transmittal Number: SS-PT-20-004Subject: Temporary changes to DHS child care assistance programs; COVID-19 pandemic Copay reduction Employment Related Day Care (ERDC) copays are reduced to $0 for all families. Q1.Should branch staff adjust child care deductions already coded on SNAP cases to $0? A1.No, do not adjust child care deductions to $0 due to the temporary waiver of ERDC copays. This is a temporary change for an unknown length of time and cannot be anticipated to be ongoing. Many child care facilities are closing temporarily, and families may have additional out of pocket child care costs during this time. No changes to the child care deduction should be made without a conversation with the family.Note: For a new SNAP application, follow usual procedures to determine if the family is eligible for the SNAP deduction based on the cost of child care for the family. If the family has no additional child care costs above the copay amount, code $0.Q2.If initially coding SNAP as $0 copay, is it up to the customer to update the agency with the new copay?A2.No, as the change in copay wouldn’t be a required change to report. After the state of emergency, when the $0 copay reductions end and cases have copays reverted to the usual amounts, if customers let the agency know we could then act on the reported change. Policy will not automatically put the reverted copays back onto SNAP cases as child care deductions as that may not be the amount of out of pocket child care costs the families are paying.Q3. Do staff need to adjust the reduced $0 copay amount on cases after the state of emergency ends? A3.No. When the state of emergency period ends, OIS will remove the temporary copay adjustments. Central Office will receive a report of the ongoing copay amounts and will send a reduction notice to families; no branch action is anticipated at this time. Q4.Through the state of emergency while copays are reduced to $0, when families transition from TANF to ERDC during the time they would normally receive the 3 months reduced copay (RCP): After the copays are restored will the family then receive the 3 months of RCP or will it revert back to the regular copay amount?A4.Code the cases with RCP now, that way if the state of emergency is lifted before the families RCP period ends the family can still get the reduced copay for any remaining months. Increased income limit for initial eligibility The initial income limit for ERDC is being increased to the existing ongoing and exit limit amount (see DHS 5530 for income limits). Q1.Someone applies for ERDC today and they are under the exit limit income, so they are approved with a $0 copay. Based on their income, after the copay amounts revert to their usual copay, the copay would exceed the amount of child care need. How will this work going forward and will the system notify families at that time or is this something staff need to keep track of?A1.During the state of emergency, we are not looking at “copay over need”. We are not planning a tracking process for these cases. The copay over need should be reevaluated at their next recertification. Q2.Should branch staff search for March applications that were denied over income between 3-1 and 3-15 that may have become financially eligible under the increased income limit after 3-16-20? A2.Staff do not need to search for those applications. If you can recall any or if a family makes an inquiry about care you can approve them financially under the new increased limit (the exit limit) as of 3-16. Please have them resign the application attesting the information has not changed that was provided on it. Remember ERDC eligibility covers back to the 1st of the month the family is determined eligible. Q3.When a family applies for ERDC and they are working from home due to COVID-19 should I deny them as they would have no child care need?A3.No, the agency should be having a discussion with the parent and determining if there is a child care need necessary to maintain employment or participate in self-sufficiency activities. Child care related to employment means the nature of the parent’s work makes it necessary for someone else to provide care for the child during working hours. Ordinarily, there is no child care need if the caretaker works at home and can care for their own child without significantly affecting their work. This needs to be addressed with the applicant as many families are working from home due to COVID-19 and they may not be able to work and care for their children at the same time. Remember to narrate your conversations and determinations clearly.For families receiving ERDC this is not a required report and they could continue to use the child care benefit. Q4.Is a family eligible for ERDC when due to COVID-19 their employer is allowing them to not report to work for a period of time but they are continuing to pay them?A4.New families applying for ERDC must have paid employment as well as a child care need. You will need to ask if having child care will allow them to either return to their worksite or start performing job duties.For families receiving ERDC this is not a required report and they could continue to use the child care benefit. Q5.Is a family eligible for ERDC when due to COVID-19 they are laid-off and are requesting child care to hold their child care slot with their provider?A5.No, ERDC is not intended to pay for child care slots to be held. Expanded absent day policy & emergency billing for temporarily closed facilities (TANF & ERDC) Q1.Is a parent required to sign their child care billing form when a provider is billing for absent days as a child or children were scheduled to attend, but are not actually be taken to care due to the COVID-19 virus?A1.No, during the state of emergency parents are not required to sign the billing form if there is concern due to COVID-19. It is suggested that providers write COVID-19 on the billing form. Q2.During the state of emergency when there is a secondary provider for a family (ex: secondary has 25% of the child care hours and a primary has the other 75%) and the primary site is closed however, the secondary provider remains open and has the child for extra hours can the secondary bill for the additional hours? A2.For March and April caretakers can contact the Direct Pay Unit (DPU) to let them know their child can no longer attend the primary care site, DPU will replace the billing form for the secondary provider and allow them to bill more hours. The primary provider will still be able to bill for the absent and closure days under the current policy through the end of April.Starting May, all provider types may bill during a temporary closure if they are closed for no more than 14 consecutive calendar days and the provider bills for the number of days the child was scheduled to be in care, the provider is a license exempt family provider or a licensed provider or recorded program listed with the Office of Child Care as an Emergency Child Care provider. Q3.How do staff know if providers are Emergency Child Care providers with the Office of Child Care? A3.Staff should continue to send connections to DPU. DPU will notify staff if a connection could NOT be made. Other common questions Q1. During the state of emergency, do branch staff still need to gather medical documentation that is currently required for AML? A1. Yes, branch staff will still need to follow current policy guidance on AML medical documentation requirements. There were no temporary child care changes regarding AML. Q2. When branch staff are processing redeterminations and families report being told to not come to work for 2 weeks, 3 weeks etc. due to COVID-19 what should we do? A2. Determine if they are reporting temporary layoff that will last more than a calendar month and expect to return to work and then review these cases for AWS eligibility. Changes less than a calendar month would not need to be acted on as they are not anticipated to continue. Reminders: Allow 3 full months for permanent loss or lay off with no return to work date. For instances with a return to work date, do not code more than 3 months past the certification end date even when the return to work date is father out. Q3.A customer was working at the time of application and we pended for income verification. They later bring in pended items, but now report they were laid off due to COVID-19 closures. Should they be denied as they are no longer employed? Or should we approve based on old income information and add AWS?A3.The case would be denied as they no longer meet ERDC eligibility. The customer can apply when there is a verified start date.Q4.Should we code AWS for employees who are not working, and they do not know any information regarding their pay or when they will return to the job?A4.Review the case for AWS as usual if they have been or are expecting to be off over a month. This situation would be considered a valid good cause reason for the layoff.Q5.Staff are hearing two parent households saying that likely one of the parents will be quitting their employment based on child care needs due to school or child care closures based on COVID-19. How do we handle these cases? A5.Policy for two parent HH’s and job loss has not changed. Job loss due to COVID-19 is considered good cause. Q6.Are stimulus checks counted for ERDC?A6.Stimulus checks are not counted for ERDC: The stimulus checks (including the stimulus amounts of $500 per dependent child) are excluded as income as they are given as a one-time tax credit. This income is excluded for one year after receipt and is counted as a resource after one year.Q7.How is the extra weekly $600 in unemployment compensation (UC) income counted for ERDC?A7.The emergency UC income being paid under the CARES act is counted as unearned income for the ERDC program. Q8.How can a provider submit their billing form during the state of emergency to maintain social distancing? A8.DPU created email addresses to answer questions and to accept electronic billing forms and provider listing forms: Billing forms and listing forms: dpu.childcarebilling@dhsoha.state.or.us*billing forms must be submitted as a pdf attachment Questions: customerservice.dpu@dhsoha.state.or.us ................
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