FAQ October 1 ERDC Policy Updates

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1 Table of Contents 12 Month ERDC Eligibility... 2 Verification of Work Schedule... 3 Priority Child Care Processing... 6 ERDC Notices... 9 Authorized Work Search (AWS) Authorized Medical Leave (AML) Authorized Military Transition (AMT) Copays and Child Care Billing Forms ERDC Exit Income Limit Student Child Care Hours (STU) Self employment P age

2 12 Month ERDC Eligibility Can the ERDC case be certified for less than 12 months in order to align with SNAP? No, all ERDC cases must be certified for 12 months. The only time ERDC will align with SNAP is when both programs are being certified at the same time. Are there any exceptions to the 12 month certification? No. How is the 12 month certification coded? ERDC must have a BAS N/R. The need resource date is the effective date. The effective date is the month the certification is starting. Example: A case is certified 10/20XX with an APR of 09/30/20XX. The BAS N/R is coded BAS 10/20XX. The system reads this as a 10/01 start date. What about clients with on call or commission based jobs and they do not have proof of income? Clients must supply proof of income in order to be determined eligible. ERDC can no longer allow a 3 month certification for the start up phase of a business. These cases will need to be pended for sufficient verification and denied if verification cannot be supplied. Will ERDC cases still be in SRS? Effective 10/01/15, all SRS coding is removed from existing ERDC cases. The APR date will not be changed. Central office is mailing a notice of change in reporting systems to all families whose cases were in SRS notifying them of their new reporting requirements. Can workers pend for a completed application? No, the 210 is used to pend an application for benefits, not a DOR. Once the new DOR is narrated and the application is sent to the client, it is the client s responsibility to follow through with their reapplication for benefits. What to do when a client lost their job while still in pend status at initial certification? The action taken depends on the scenario. First determine if there is a child care need. To do this you will need to determine how many hours the client worked from the 1 st day of the DOR month to the date of job loss. You will need verification of any pay received in the DOR month. Example: DOR is 12/5, worker pends the client for income verification on 12/6. On 12/10 the client calls to report they lost their job on 12/8. If the client worked a total of 25 hours at a $10.50 per hour, the total gross income is $262.50, with no other household income the copay would be $27. The client has a two year old child. The max 2 P age

3 DHS would pay if the child is at a standard family provider is $2.90 per hour x 25 hours = $ There is a child care need and we can issue a Child Care Billing form for 25 hours. To determine if AWS can be added to the case, we will need to determine good cause. If it was a good cause job loss, code AWS starting January 1 through March 31. If the parent is applying for TANF do not code AWS. If no good cause, open the case to issue the CCB for December, no AWS is allowed. If time for 10 day notice close effective the end of the DOR month sending close notice. If no time for 10 day close for the end of the following month. When can a client s copay be increased? Copay s will only increase in limited situations: adding a new filing group member with income, removing a filing group member with little or no income, removing AWS or AMT, adding income back onto a case after medical leave (AML), higher income is verified after priority processing, or a self employed individual asks to have deductions lowered in order to have higher child care hours authorized. What if higher income is verified upon receipt for another program? Verified upon receipt does not apply to ERDC. Actions to increase child care hours or decrease the copay should only be taken when requested by the client. Verification of Work Schedule Why are work schedules required? Along with 12 month eligibility came a requirement to ensure increased program accuracy. Work schedules are required when reviewing the provider attendance logs to see if the parent is using child care appropriately and if the provider is billing correctly. Are work schedules required for everyone? Yes, all cases, including those transitioning from TANF require verification of work schedule. Do single parent households need to supply verification of work schedule? Yes, even single parent households now need to provide verification of work schedule. 3 P age

4 Does work schedule verification need to come from the employer? Yes, verification must come from the place of employment. Can a work schedule that was already worked be used? Yes, the client can supply either a work schedule from the past week or two or one from an upcoming schedule. Either is acceptable as long as it is representative of their ongoing schedule. How can work schedules be verified? Clients can supply a copy of a posted work schedule, a printout or copy of a schedule from an employer s website, scanned copy of a schedule including a picture taken from a smart phone, a calendar completed by the client with their manager s name, signature and contact number, letter from the employer or workers can verify work schedule with a phone call to the employer. What if the employer will not provide a work schedule? When a client states their employer will not supply them with a work schedule the worker will make an attempt to contact the employer to verify this is correct. This is a generic call, do not give the clients name. If the employer is not reachable, leave a message, if no response in two business days, or the employer states they will not give verification of a work schedule the client can self verify their work schedule. The clients statement of their work schedule must be narrated. Important: It is important to remind clients to be as accurate as possible when selfverifying. If a case is pulled due to an investigation the investigator will be able to get copies of the clients work schedule and compare those hours to the provider billed hours. Self employed work schedule, how do I verify for self employed clients? Self employed persons will self verify their work schedule. If questionable additional verification can be requested. Questionable information could be a landscaper who states they work past daylight hours. Ask questions, if you aren t sure if a self employed work schedule makes sense please contact policy. Remember: determining allowable child care hours for self employed families is not based on the work schedule. Use countable income after cost deduction divide by current Oregon minimum wage. Should the work schedule be narrated? Yes, the work schedule should always be addressed in narration. If a copy of the schedule is scanned with the application, each day does not need to be narrated. However, a general description of parent works 4 P age

5 primarily days from 8 5, or parent works a rotating shift with days and evenings, copy of schedule on file. If the worker verifies by viewing the schedule on the computer/smart phone or by a phone call to the employer more detail will be needed with the narration. Can the work schedule be used to verify child care hours? No. We cannot use a work schedule to verify child care hours. A work schedule only gives us an idea of when the client can work, not what will be or was worked. Example: Client is scheduled to work from 10 AM to 8PM, Mon, Tues, Thurs, Sat. However, when reviewing what was actually worked, we see the client worked Mon. until 6PM, Tues. until 5PM and Sat. until 9PM. Their hours each day are dependent on business that day. If a client is transitioning from TANF, do they still need to supply the work schedule? Yes, the work schedule is required for the worker to convert the program 2 or 82 case to an M5. Work schedule is not required for an open TANF case whose child care is being paid with a CCB zero copay. How many weeks of work schedule is required? This is dependent on the clients variation in their work schedule. For non varying work schedules, (example: 8 5 five days a week or 1pm to 9pm four days a week and it does not change then one week of verification is enough or a statement from the employer. If their work schedule varies a longer period may be needed. How can a variable work schedule be verified? Clients with variable work schedules may need to supply 2 to 4 weeks of their past and/or future work schedules in order to give an accurate picture of their schedule. Remember: If you can get a good idea of work hours by requesting 2 weeks do not request more. More than 2 weeks should only be requested in situations where the schedule varies beyond what can be seen in a two week period or for persons who work on call jobs. We do not want to cause barriers for families who need subsidy child care. When is verification of work schedule needed? Work schedule is needed: at certification; recertification; or when a two parent household requests more child care hours. 5 P age

6 Priority Child Care Processing What does priority processing do? Priority processing allows ERDC benefits to be open immediately when the family is unable to supply sufficient verification of income and/or work schedule at the time of certification or recertification. Who qualifies for priority child care processing? Families who indicate on the application that they are homeless or applying for child care for a foster child should be considered for priority child care processing. What is the definition of homeless? Homeless in the ERDC program is defined as lacking a fixed regular and adequate nighttime residence. This includes living in an emergency shelter, shared housing with others due to loss of housing or economic hardship, staying in motels, cars, parks, public places, tents, trailers, or other similar settings. What if a family meets the definition of homeless, but does not consider themselves to be homeless? The definition of homeless is included on the DHS 415F, DHS 7470 and DHS It is up to the family to identify themselves as being homeless. Is everyone who shares housing considered homeless? Only those who share housing because of a job loss or a loss of their own housing are considered homeless. People who have a roommate to help share costs or parents who have an adult child move back in would typically not be considered homeless. An adult child who moved back in with their parents after a job loss, would be considered homeless. Is the HLL C/D only used on priority processing cases? No, HLL is specifically being used to identify and report the number of homeless families being served by the ERDC program. This is needed for Federal reporting. Can priority processing be used to prevent a child from being placed in foster care? The Child Welfare referral (DHS 861) to bypass the ERDC reservation list is not connected to priority processing. Foster children are included in priority processing based on federal recommendations. A parent is applying for ERDC anticipating their child to return home from foster care, are they eligible for priority processing? Yes, a child transitioning home from foster care is still considered a foster child for the purposes of priority processing. How often is priority processing allowed? At this time there is no limitation on how often someone can apply for ERDC and receive priority processing. Please contact child care policy to staff situations that seem questionable. 6 P age

7 What if a homeless family is pending for other verification? Priority processing only waives the requirement to supply verification of income and work schedule. If other verification is required, the case is not open while the verification is pending. Should workers try to get verification from the employer by phone before a case is opened under priority processing? Yes, workers should always try to obtain the verification by phone first. If the client does not want the worker to call the employer or if the employer is not able to provide information over the phone right away, priority processing would apply. How long does a case stay open with priority processing? All ERDC cases are certified for 12 months including priority process. However, the priority processing time frame is 2 to 3 months. It starts the first of the DOR month and ends the last day of the month in which the 45 th day falls. Do workers have to manually close the case at the end of the priority processing period if the client does not respond? Yes. All cases must be certified for 12 months, no exceptions. Workers will need to manually close the case. The 210 serves as a close notice only if the client does not respond to the 210. A 10 day close notice is not required in this situation. Important: The priority processing ERDC case must be closed to comply with the date shown on the 210 the worker gave to the client. This close action should be done prior to CMS cutoff/compute deadline, because the child care billing forms are mailed out the first day of CMS cutoff. If the case is not closed the day before CMS cutoff a CCB will be issued and the ERDC case will need to remain open an additional month. A new 10 day notice will need to be sent by the worker, because we kept the case open a month beyond the date given on the 210. What happens if the 45 th day falls on or after CMS cutoff? The child care billing forms are issued out at CMS cutoff. Because of this, the worker will need to complete the close action the day before CMS cutoff if the client has not responded. This will keep the child care billing form from going out. If the client responds after the date the worker closed it and before the 45 th day the case can be restored. Example: the 45 th day falls on 12/28. The 210 will state the case is open from 11/01 through 12/31/15. The 210 was completed with a 12/31 end date. The worker takes action on the case to close 12/24. This will keep the child care billing form from issuing and the close notice is valid. 7 P age

8 If the client turns in the needed information after the case was closed, example; on 12/29, the worker can restore the case, send 10 day notice if any changes caused the copay to increase and contact DPU to issue the child care billing form. If the worker is unable to close the case prior to CMS cutoff the priority processing period should be extended to the end of the following month. Close the case for the end of the following month and send a close notices for 01/31. What happens if the client supplies the pending information after the 45 th day, but before the close date? Keep benefits at the same level; send 10 day notice if the verification results in an increased copay. Remember, child care hours are not the benefit; no 10 day notice is required to reduce child care hours. What happens if the client supplies the pending information after the case has closed? If it is in the month following the closure, review the case for eligibility. A new application is not needed. The case can be restored back to the first of the month. If the case has been closed for one full calendar month or more, treat the contact as a new DOR for ERDC. Mail the client an application with the DOR and narrate. Can priority processing be extended? Yes, staff can extend priority processing and the 45 day application period if the client requests more time to provide verification due to circumstances beyond their control. Staff will need to send a new 210 with corrected dates if extending the priority processing time frame. Does priority processing have a processing time frame like expedited SNAP? No. Priority processing does not have a specified processing time frame based on the DOR. The benefits should be processed immediately following intake if all other eligibility factors are met. How should the income be calculated? The worker will determine the income based on the best estimate the client can supply. Best practice is to ask the client how many hours a week they typically work and ask for their rate of pay. Workers should not accept a statement of how much the client receives on their checks, this is likely the net pay. Workers should convert income appropriately. Example, client reports earning $1600 a month when they are actually paid $10 an hour 40 hours a week. The worker will need to convert the income to $10 x 40 x 4.3 = $1720. Salaried pay Clients who state they are salaried will not be able to give an hourly rate of pay. Assist the client in your explanation of what the gross pay means. You will still 8 P age

9 need to take their statement on the amount but our goal is to be as close to actual income as possible. Can workers adjust income up if the verification shows that the earnings were higher than estimated? Yes, under priority processing the copay can be increased with 10 day notice when the income verification is higher. Can child care hours be decreased if the highest verified hours are lower than estimated? Yes, under priority processing the hours can be decreased. 10 day notice is not required to reduce child care hours. Can an overpayment be processed if the verified income or hours are different? No overpayments will be processed for child care covered during the priority processing time frame. ERDC Notices Does the DHS 862 go out automatically? No, the worker will need to mail the DHS 862 to the client. Will workers need to send an 862 and 853 when certifying ERDC and SNAP at the same time? Yes. Both forms will need to be provided to the client if certifying both types of benefits at the same time. Do workers need to complete the DHS 7294 when a case is approved? No, the ERDC case will automatically send out an approval notice when the APR date is updated on UCMS. Is the DHS 7294 obsolete for ERDC? No. Workers can still use a DHS 7294 when recalculating income to lower a family s copay, adding income for a new filing group member, removing AWS or AMT coding or adding income back on when a caretaker has returned to work after medical leave (AML). What is included on the automatic approval notice? The approval notice includes the ERDC start and end dates, copay amount, authorized hours, number of people in the filing group, countable income and the ERDC exit income limit. The notice informs clients that a list of changes required to be reported can be found on the DHS 862. It gives information about the Parent Guide, Child Care Resource and Referral, as well as links to the CCR&R website and the DHS form server. 9 P age

10 Authorized Work Search (AWS) What does AWS do? AWS waives the full copay when the client has a good cause temporary or permanent job loss. This allows children to continue to attend their child care program and parents time to find new employment. An AWS approval notice is sent when the coding is added to the case explaining the benefit. A 10 day closure notice is sent in the final AWS month prior to the case automatically closing. What is a permanent job loss? A permanent job loss means the employee was either fired, voluntarily left employment, a short term job that has ended, or the employee was permanently laid off. The employer has not given a return to work date and the employee does not anticipate returning to that employer. What is a temporary job loss? A temporary job loss is when an employee has a break in work and their employer expects them to return. This includes short term layoffs with a return date, seasonal breaks, and school district employees who are not working during the summer. Can the copay be reduced in the month the job loss occurred? Yes, if the client does not have enough income to cover the copay it can be reduced in the month the job loss occurred; only if the job loss was reported timely and the client provides verification of their income in the job loss month. This would require all income including the final pay check. The worker can use the copay calculator to determine the adjusted copay amount. An must be sent to DPU to have the CCB cancelled and reissued. Include a description of why you are requesting the change. Do not make any changes to the income on the ERDC case (UCMS). Should EML be removed from the case when AWS is added? No. Income on the case should remain the same. The AWS code will bypass all income on the case allowing for a waived copay. When does AWS start? When a job loss is reported timely the AWS code is added the month following the job loss. This includes job losses that occur late in a month and are reported timely even though the report is made the first of the following month. Example: Irma lost her job December 28 th, she reported it to DHS on January 2 nd. The AWS will be added to Irma s case effective January 1 st. The CCB sent to the provider for January will be canceled and reissued to a zero copay. The worker will need to contact DPU and request the change to the CCB. 10 P age

11 When the job loss is not reported timely the AWS code is added for the month following the month reported if there is any time remaining for work search. CCB s cannot be canceled and reissued when a job loss is reported late. Example: Martha lost her job on December 15 th. She reported the job loss to DHS February 1 st. The worker determined it was a good cause job loss and codes the AWS on Martha March Because Martha did not report timely there is only one month left in her AWS period. ERDC AWS and TANF If an ERDC client experiences a job loss and applies for TANF the ERDC case is closed. Do not code ERDC AWS and open a TANF case. TANF to ERDC AWS A TANF client cannot transition to ERDC AWS if they lost their job while on TANF, this includes the transition month. Example: Zane and his two children are receiving TANF. Zane became employed on January 5 th. His worker is transitioning the case to ERDC for February 1 st. On January 28 th Zane reported he was laid off his job. Because the job loss occurred before ERDC was opened he is not eligible for ERDC or AWS. How will a client know when they are receiving authorized work search (AWS)? The system will automatically send a notice informing the client of the AWS start date, and the waived copay at $0.00, the number of authorized hours and when their case will close if they do not report employment. Why is the copay waived when a second unemployed parent moves into the home? Waiving the copay allows the second parent to have time to look for work, giving the family a better chance of gaining self sufficiency. It also reduces the chance that the family will opt to remove the child from child care in order to save money on the copay. Can a teacher receive AWS even if they are paid 12 months out of the year? Yes, teachers can qualify for the summer months even if they have chosen to receive their pay over 12 months. Remember, income is anticipated over the full 12 month certification period. A teacher s income should be anticipated and coded the same regardless of if they choose to receive it over 10 months or 12 months. What if someone works a short term job, but it is with the same employer each year? (Examples: Harry and David or the Oregon State Fair) When an employee is required to 11 P age

12 reapply each year, this is considered a short term job or a permanent job loss; the 3 month AWS period would apply. How long can someone be on AWS? Clients who have had a permanent job loss can qualify for up to three months. Clients with a return to work date are allowed AWS through the end of the month in which they are scheduled to return to work. Contact policy if the return to work date is questionable. Can AWS be extended? The 3 month AWS for a permanent job loss can only be extended if the client reports new employment after the 10 day NOTM deadline of the 3 rd AWS month. AWS based on a return to work date can be extended if the expected return date is postponed by the employer to a later date. Contact policy if the return to work date is questionable. How many times can a person have AWS during a certification? There is no limit on the number of AWS periods someone can have during their certification. Please contact policy if workers see a situation that is questionable. Should workers pend for verification if the AWS date is being changed? Only if the later return to work date is questionable. A date can become questionable if the client has requested to have the date extended more than one time or if the worker is aware that the client s layoff is not typical of their employer. Does good cause align with TANF s definition of good cause? Yes. See OAR (2). ERDC policy first started looking at good cause in July The October 1 st new policies did not change the good cause criteria the ERDC program implemented previously. Do workers need to determine if it was a productive job? No. ERDC has no minimum number of work hours required in order to qualify. Any job quit without good cause could make the family ineligible. What action should be taken if there is no good cause for the job loss? Close the case with 10 day notice. A client is transitioning from TANF and their unemployed spouse just moved into the home, do we add AWS to the spouse? No. AWS is not allowed when the TANF case is still open. A family must be eligible for ERDC first before they can qualify for AWS. A client reported a job loss, but we have been unable to contact them to determine good cause. What action should be taken? Send a 210a asking for the reason of the job 12 P age

13 loss. Close with 10 day notice if there is no response or good cause cannot be determined. Are we monitoring work search? No. When a new job or return to work is reported during AWS, does the worker pend for new income verification? The worker would remove the AWS and send 10 day notice to return the copay back to the amount prior to the job loss. The worker would not change any of the EML coding on the case. Verification of the new job is not required unless the client reports the new income is lower and they want a lower copay or the new job is more hours and they want an increase in hours. Do not request verification of both hours and income, only what is needed to make the appropriate adjustment. Remember: During the ERDC 12 month certification we can lower income for a lower copay or increase hours. Verification is required to make the change. We do not raise the copay or decrease the hours during the 12 month period. If a job is reported after the 10 day notice deadline of the final AWS month, will the case still close? The auto close notice becomes invalid when the client reports employment prior to the close date. The worker will need to bump out the AWS date for one additional month in order to allow 10 day notice to increase the copay. What happens if the client does not report a new job? The case will auto close with a system generated 10 day notice. Can the AWS period go beyond the APR? Yes, the AWS needs resource code can extend up to three months beyond the end of the certification. AWS will hold the case open to allow for job search. What happens when a client reports a job after their APR and AWS is on the case? The system generated recertification notice and DHS 7476 are mailed to the client 45 days before the APR date. An additional close notice is sent in the APR month. If an AWS is coded on the case with a MM/YY past the APR date the recertification will still need to be completed when employment is reported. The client can use the DHS 7476 already sent to them if they retained that copy. The date the client reports the new employment or return to work, after the APR date is their new DOR. The worker will narrate the DOR and send a date stamped application to the client. If the client has submitted the DHS 7476 re application that was sent to them with their 45 day notice of recertification the worker can use this application. 13 P age

14 However, verification of the new job and any changes that have occurred since the application was received will need to be reviewed. Remember: An interview must be done at certification and recertification. Do additional notices need to be sent if the AWS date is past the APR date and the client does not report a new job? No, the system will send an AWS close notice due to no job being reported and another close notice will be sent stating the recertification was not complete. What if a client reapplies during AWS, but they are not currently employed? The application would be denied and a denial notice sent. If the client later becomes employed during the AWS period, the application can be reused without obtaining a new signature. The worker would verify that the information is correct and recertify the case if all other eligibility factors are met. Do workers need to add AWS when a self employed client states that they are no longer working? The only time a self employed client would qualify for AWS is if they are reporting the failure of their business and that they intend to look for new employment. Someone who owns a landscaping business may not have work during the winter months, but they are still available to take on work during that time. Their income has been annualized to account for the highs and lows of the year. Can AWS be used when a client goes on maternity leave? No, maternity leave is covered under Authorized Medical Leave. Do not code AWS for clients on maternity leave. A client reported that they lost their job in September, can they qualify for AWS? No, AWS and all other October 1 policies cannot be applied to changes that occurred prior to October 1. Authorized Medical Leave (AML) What does AML do? Authorized Medical Leave allows the ERDC case to remain open during a break in employment due to medical leave. When does AML start? AML starts the month following the medical leave start date. 14 P age

15 Remember: The client has 10 days to report changes. If medical leave starts on January 28 th and the client does not report until February 5 th they are still within their 10 day reporting requirement. However, the medical leave started January 28, this means AML is coded and effective for February 1 st. The CCB for February will need to be canceled and reissued if there is a change in pay for February due to the medical leave. Does AML waive the copay? No, AML does not waive the copay. However, the copay can be adjusted if the family income changes due to the medical leave. Verification of the change in income is required before an adjustment is made. What happens if the client won t have enough income to cover their copay? If income is going to be lower during the medical leave period, workers can verify the lower income (like short term disability, workers compensation) and update the case to lower the copay. What can I do when the client reports medical leave for the rest of the current month only? Request verification of the client s income for the current month. Use the copay calculator to determine the copay amount. If the copay will change by $25 or more you can ask DPU to cancel and reissue that month copay. Does medical leave need to be verified? Yes, medical documentation is needed in order to approve AML except maternity leave. Medical documentation must include a diagnosis and prognosis as outlined in OAR including the expected return to work date. Maternity leave is allowed for up to 3 months without requiring medical documentation (maternity leave is a full three months). Example: Mom calls 11/5 and reports she is going on maternity leave starting 11/7. The worker will use a compute action and add the AML code with a date of 02/20YY. The three month maternity leave is December, January and February. The worker will adjust the income on the case if it is different during the leave. If needed, due to less income in November the worker can a request DPU cancel and reissue the CCB for November based actual income in that month. The income must be verified. 15 P age

16 When does the three month maternity leave start? Maternity leave starts the month after the mother stops working, when reported timely. If not reported timely any remaining maternity leave can be used starting the month after it is reported. Can maternity leave be extended either for pre delivery bed rest or postdelivery complications? Maternity leave can only be approved for 3 months without verification. Any extensions of the 3 month leave, either pre delivery or post delivery will fall under general medical leave and requires medical documentation. The client did not respond to the 210a sent requesting verification of diagnosis and prognosis. Should the case be closed? Yes. The client reported they are no longer working due to medical leave and verification is required. If they do not respond, close the case with 10 day notice. The client turned in their 210a pended items late. Can I reopen the ERDC case? If the pending items are returned late, the verification is still valid and the ERDC case has been closed less than 30 days the case can be reopened. Will the client s copay increase when they return to work? Yes, when the client reports returning to work the previous income is added back onto the case when the AML code is removed. The worker will need to send a 10 day reduction notice. How will workers know what the previous income was prior to the medical leave income? When the income is removed from the case the original income amount or a TRACS narration number should be noted in the explanation field of the AML or EML N/R. Example: AML 05/ EML Or EML C This will allow the case to be updated to the prior income efficiently. 16 P age

17 Does adoption leave or another parent staying with a newborn count as maternity leave? Not at this time. Workers are encouraged to share situations regarding adoption or paternity leave requests with child care policy if they arise. A client reported they went on maternity leave in September 2015, can they qualify for AML? No, AML and all other October 1 policies cannot be applied to changes that occurred prior to October 1. Authorized Military Transition (AMT) What does AMT do? Authorized Military Transition waives the ERDC copay for up to 6 months while allowing U.S. military members a transition period once they have been discharged after serving in a war zone. When does AMT start? The 6 month period starts the month following the discharge. Do clients still get the full 6 months even if they report late? No, the AMT period is for the 6 months following the caretaker s discharge date. If this information is reported late, it will shorten the amount of time the family will receive the waived copay. Do we need to verify that the caretaker was serving active duty in a war zone? Verification of serving active duty is a military war zone is not needed. Workers should be asking and narrating where they were stationed, when they returned, and their discharge date. As with other changes, workers can pend for verification if questionable. What if they did not come directly back from the war zone due to debriefing or medical treatment? Caretakers qualify for AMT if their last active duty assignment was in a military war zone. Debriefing or medical treatment following deployment to a war zone are included as part of that assignment. If the caretaker was stationed in a war zone previously, but their most recent assignment was not in a war zone can they qualify for AMT? No, the caretaker s most recent assignment must be within a military war zone including the transition back home after deployment. If someone is stationed overseas, but not in a war zone, do they qualify for AMT? The assignment must be to a U.S. military war zone. 17 P age

18 How do workers know what is considered a U.S. military war zone? Currently policy considers a military war zone to be similar to a U.S. combat zone which is declared by Executive Order. What if they are still serving in active duty or continuing to go to weekend trainings in the Reserves or National Guard? AMT can only be applied once the military members has been discharged. Do military members have to be honorably discharged in order to qualify for AMT? The policy does not require the type of discharge to be reviewed. Does the caretaker have to use the child care for work search? Authorized Military Transition periods allow the caretaker to use child care for work search, medical treatment and appointments, to maintain their child s spot in a child care facility or for other transition activities. What if the caretaker finds a job before the 6 month period is over? If the caretaker is on the case and the new income is less than previous or if the caretaker is being added to the case, the worker will need to verify income and add it to the case. The worker will flag the case to remove AMT in the final month and send a 10 day reduction notice when removing AMT. Copays and Child Care Billing Forms Can the child care billing form be canceled and reissued in a month a change is reported? In some cases, yes. When a client reports a job change, job loss or medical leave the CCB can be canceled and reissued for the current month. The change in the copay must be at least $25 or more to request the adjustment. Use the client s verified income for the current month and the copay calculator to determine what the copay would be. Send the request to cancel and reissue to your DPU representative. Does actual income need to be verified in order to lower the copay on a CCB? Yes, verification of reduced income or a final pay stub is required in order to lower the copay. Do workers update income on the case when asking to replace a CCB? Income is only updated on the case when ongoing income has gone down, either due to less income from employment or AML income (like short term disability). In the case of a job loss, the income remains on the case and is waived by the AWS or AMT coding. 18 P age

19 ERDC Exit Income Limit Does the computer have an edit in place just in case a new applicant s income is above 185%? No. Unless you are using a new incoming code the system cannot differentiate between new and exit income limits. Workers must use the combined standards chart when determining eligibility for a new applicant and at recertification. A new applicant includes someone whose ERDC case was closed for 30 days or more. When does the exit income limit go into effect on a case? As soon as a new case is certified and found eligible for ERDC the higher exit limit applies. Eligible means all pended information has been received and the client was eligible in the DOR month. What if a family s income increases over 185% in the first month that the new case is certified? As long as the case was found eligible based on true, accurate and complete information, meaning the client/employer did not withhold information in order for the case to be determined eligible, the higher exit limit applies as soon as the case is certified. Does the Exit Limit apply to TANF transitioners? No, those transitioning off TANF must be under the initial ERDC income limit (185% FPL). Student Child Care Hours (STU) What is the limit on student hours? The client must have a child care need related to their employment before being determined eligible for any student hours. Student hours cannot exceed the authorized work hours and EXH cannot be approved for student hours. Who qualifies for student hours? Any caretaker eligible for ERDC and working less than 40 hours a week may qualify for additional student hours. They must be attending an institution of higher education that is approved to receive federal student aid. How can workers verify that the school qualifies to receive federal student aid? Workers can search for the institution by name on the FAFSA website at: What if the worker cannot find the school on the FAFSA website? It is the client s responsibility to provide verification that their schooling meets this requirement. The case can be pended for the information or workers can verify by looking at the school s website or contacting the school directly. 19 P age

20 What kind of schooling can be approved? The schooling must be oriented toward improving employment opportunities including completion of a degree, certificate or comparable credential. Online coursework for an approved institution is allowable. Are G.E.D. or E.S.L. allowable for student hours? Yes, if the client is attending an institution of higher education eligible for federal student aid. Should workers request the financial aid award letter? Yes, first workers should review the letter to see if any assistance is provided to cover the client s child care need. Any client who receives a child care grant from the Oregon Student Assistance Commission is ineligible for all ERDC benefits, including for their work hours (OAR (5)). Child care assistance received from other sources should be considered to determine if there is an unmet child care need for student hours that can be covered by ERDC. If there is no unmet need, the client would not qualify for additional student hours. Can teen parents qualify for ERDC while attending high school and working? Teen parents can qualify for ERDC, but student hours would only be covered if they are attending an institution of higher education approved for federal student aid. How will authorized student hours be determined? Child care hours can be authorized for class hours. This can be verified with the class schedule or class synopsis (for online classes). If class hours are not available on a class schedule or synopsis the worker can use the credit hours. What if the credit hours are not sufficient to cover all of the class hours, like a lab that is 4 hours a week, but only one credit hour? The class schedule or synopsis should provide verification of the total hours required to complete the class. If they do not, it is the client s responsibility to provide verification from the school on the number of hours required to complete the class. If it is a two parent family with one or both parents attending school can I authorized student hours? Yes, if there is an overlap in the parents work schedules. The family must be determined eligible for ERDC with overlapping work schedules before student hours can be authorized. Once the overlapping work hours are determined, review for overlapping school hours. School hours cannot be more than overlapping work hours and no more than 172 hours can be coded when combining work hours and school hours. Example: Dad works Monday Friday from 8 5. Mom works Tuesday, Wednesday and Saturday from 1 5. The parent s work schedules overlap on Tuesday and Wednesday 20 P age

21 from 1 5. This allows for 8 hours of work overlap each week. Mom also attends school on Monday, Thursday and Friday from 8:30 12:00 there is an overlap here of 3.5 hours 3 days per week. Mom s total school hours are 10.5 hours per week. The most that can be added for school hours is 8 hours per week, because school hours cannot be more than the authorized work hours. Total authorized hours are 8 work plus 8 school hours = 16 hours per week x 4.3=68.8 (round to 69) Can homework time be approved? Additional hours will not be approved for homework time, though homework time is an allowable use of the additional 25% added for travel time and meal breaks. Are student hours removed once the schooling is complete? No, authorized student hours will remain on the case through the end of the certification. Can clients continue using child care for class hours while they are on AWS, AML or AMT? Yes, clients can continue attending school and using the student child care hours even if they are not currently working due to authorized work search, medical leave or military transition. Self employment Are self employed child care providers eligible for ERDC? No, to be eligible for ERDC there must be a child care need. When someone runs a child care business DHS cannot authorize ERDC for another provider to care for their children. Are self employed individuals eligible for child care even if they are able to watch their children and conduct their business? No, if the individual is able to watch their children without significantly impacting their ability to perform their job duties, there is no child care need. This applies to self employment as well as standard employment. Are self employed individuals eligible for AWS? Yes, in limited situations only. A client who is self employed can qualify for AWS if they report a complete failure of their business. AWS cannot be granted for seasonal periods of low or no work during selfemployment. 21 P age

22 Are self employed individuals eligible for AML? Yes, medical documentation is still required stating that the client is unable to perform their job duties. The AML would only go through the end of the month listed in the medical documentation. Are self employed individuals eligible for AMT? Yes, AMT is allowed when the individual is self employed. How is income verified for self employment? Self employment income is primarily selfverified. Tax documents should be used whenever the previous year s income is representative of ongoing. Self employment income should be annualized to capture the full year s ups and downs. How is work schedule verified for self employment? Work schedule is self verified. Is the client s income compared to the income limit before or after the deductions? The income is compared to the income limits before deductions are allowed. How are income deductions determined? Clients have the choice of choosing zero cost deductions, a 50% cost deduction if they have at least $1 in costs, or their actual costs if higher than 50%. Actual costs must be verified, but verification should be provided in a manner that is easily processed by the worker (boxes of receipts are not acceptable). How are the highest verified work hours determined for self employment? If the client makes at least minimum wage or more (after costs) the worker would use the client s statement of the highest possible work hours, not to exceed 40 hours a week. If the client earns less than minimum wage, the countable income after costs is divided by the Oregon minimum wage to determine the highest number of child care hours allowed. Example: A parent is self employed and states that they earn $300 a week with no costs. Their typical work week is hours a week. They are earning more than minimum wage so the child care hours would be 15 x 4.3 = 64.5 (65) Example: A parent is self employed and states they earn $300 a week with no costs. Their typical work week is 40 hours a week. They are not earning more than minimum wage. The maximum monthly hours that can be approved is $300 x 4.3 = $1290 / $9.25 = (140). Example: A parent is self employed and states they earn $300 a week with costs. They do not want to verify costs so they opt to use the 50% deduction. Their typical work week is 40 hours a week. They are not earning more than minimum wage. The maximum monthly hours that can be approved is $300 / 2 = $150 x 4.3 = $645 / 9.25 = 69.7 (70). 22 P age

23 Example: A parent is self employed and states they earn $300 a week with 75% of their income going to costs. They provide verification of the actual costs. Their typical work week is 32 hours a week. Due to their high cost deduction, they are earning less than minimum wage. The maximum monthly hours that can be approved is $300 / 4 = $75 x 4.3 = $ / $9.25 = 34.8 (35). Can workers increase a copay if a self employed client asks for their child care hours to be increased by lowering their cost deduction? Yes, if a customer was earning less than minimum wage after using actual costs or the standard 50% deduction, they can have their authorized child care hours recalculated using a lower cost deduction. The worker would increase the hours and increase the copay in the same month and send a 10 day reduction notice for the increase in copay. The change in hours and copay must take place at the same time. 23 P age