01.03.10 - CCAP Protective Services Child Care for Children Experiencing Homelessness

Helping Families. Supporting Communities. Empowering Individuals.

Effective Date: 09/30/2016

Revisions: 11/01/18, 12/1/18

Reference: CCAP Protective Services Child Care (CCAP-PSCC) 45 CFR § 98.2 Definitions; 45 CFR § 98.46 Priority for Child Care Services; 45 CFR § 98.51 Subpart F, Services for Children Experiencing Homelessness.

Cross Reference: 01.03.01 - Two-Parent Household; 02.02.03 - Notification Eligibility Determination; and  01.01.01 - Residence

Policy Statement:

The Illinois Child Care Assistance Program uses the McKinney-Vento Act definition of families experiencing homelessness. (Section 725 of Subtitle VII-B of the McKinney-Vento Act (42 U.S.C. 11434a). According to this act, the term homeless means an individual who lacks a fixed, regular and adequate nighttime residence; and includes individuals who;

  • Share the housing of other persons due to loss of housing, economic hardship, or a similar reason; are living in motels, hotels, trailer parks or camping grounds due to the lack of alternative accommodations; are living in emergency or transitional shelters; are abandoned in hospitals or awaiting foster care placement;
  • Have a primary nighttime residence that is a public or private place not designed for or ordinarily used as regular sleeping accommodations for human beings;
  • Live in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings; and
  • Are migratory and live in any of the circumstances as described above.

The list of examples included in the definition is not exclusive; rather, it is meant to address some of the more common situations of homelessness in determining the extent to which the family fits the definition.

The Department will provide CCAP Protective Service Child Care Assistance to eligible families who indicate they are experiencing homelessness on an Application, Redetermination, or Change of Information Form to obtain or maintain a child care arrangement, respectively.  Families that indicate and provide documentation that they are experiencing homelessness will be allowed 2 periods immediately following notification of experiencing homelessness within a 12-month period to establish a CCAP eligible activity (employment, education...) and to submit required eligibility documentation including pay stubs, and school schedules.

Procedure

  1. Eligibility Criteria
    1. A family's circumstances must meet the Department's definition of homelessness under this section.
    2. If, after the initial 90-day eligibility period, full documentation of an eligible activity is not provided, a family experiencing homelessness will be determined ineligible unless the family indicates they are still experiencing homelessness, in which case a 2nd 90-day PSCC eligibility period can be approved.
    3. Payments made shall not be considered an error or improper payment.
    4. For new applicants documenting homelessness, the child care arrangement schedule shall be approved as listed on the application.
    5. Once approved for an eligible activity, the child care schedule will be determined according to the time in that activity per CCAP policy.
    6. The Family Co-payment shall be assessed at $1.00 per month during the 90-day approval period.
    7. Families that document they are experiencing homeless that are engaged in a CCAP eligible activity will be approved for 90-days under the Protective Services guidelines, including the $1.00 monthly family copayment amount.  (see section X below) 
    8. At the time of redetermination at the end of the 90-day eligibility period, if the family is still eligible with an activity, approve the case for 12 months and assess the copayment according to the countable family income.
  2. Authorization and Verification
    The 90-day period is provided to children whose parents indicate they are currently experiencing homelessness, regardless of participation in any employment or educational activities. 
    1. The provisions under the Child Care Assistance Program Protective Services Child Care (CCAP-PSCC) are intended to:
      1. Allow a reasonable time frame for families experiencing homelessness to address their basic needs (housing employment, medical care...) and to obtain and submit eligibility verification documentation at a time when the families' unique circumstances and the disruptions common to homeless families temporarily presents additional barriers;
      2. Implement program policies and procedures that encourage families experiencing homelessness to engage in and remain in self-sufficiency activities;
      3. Support children's learning and development in safe, stable and nurturing environments;
    2. If an applicant or current CCAP client indicates that they are homeless, the Application, Redetermination, or Change of Information must be processed by CCR&R's and Sites according to the policies and procedures listed in this section and;
    3. Contact the family to obtain missing information or clarification that is needed to enter case information into CCMS. If the Application, Redetermination or Change of Information Form is incomplete, contact the family using the most current information provided on the Application, Redetermination or Change of Information.
    4. The Family must also complete, sign, and return the Certification of Temporary Living Arrangement Questionnaire (CTLAQ) to describe their living situation to document that the family meets the definition of homeless. CCAPCertificationofTemporaryLivingArrangementHomelessnessQuestionnairerevision113018 (pdf)
      1. The CCR&R's and Sites must issue a CTLAQ to all applicants and clients that indicate they are experiencing homelessness verbally, on the Application, Redetermination, or Change of Information Form.
      2. The CTLAQ must be included in the family's eligibility documentation scanned into CCMS as a miscellaneous client document;
      3. The CTLAQ will serve as the initial information to determine the family's eligibility under this provision and explain their responsibility to provide accurate information. Allow the family 30 days from the Application, Redetermination or Change of Information receive date at the CCR&R or Site to sign and return the CTLAQ. If the CTLAQ has not been received within 30 days, follow cancellation procedures for canceling the case for CCAP.
    5.  Homeless families approved under the provision of CCAP-PSCC must certify they have registered with an approved local agency or program to support families experiencing homelessness within 30 days by submitting the CTLAQ. If the family has not, they must indicate a plan to do so within the next 30 days.
    6. Eligibility Staff must utilize current State databases and should use the same policies and procedures currently in place for electronically verifying information for entry into the CCMS.  NOTE:  Service eligible activities are NOT required for these families during the first 90 days of approval.
  3. CCAP Protective Services Child Care Eligibility Period
    The eligibility for homeless families approved under this provision is determined for a period not to exceed 90 days. Families determined eligible under this provision shall remain eligible through their eligibility period despite a parent's reported loss of work or cessation of attendance at a job training or educational program. A total of 2 90-day eligibility periods can be approved under these provisions within a 12-month period.  These period can be consecutive.
  4. Contact Information
    The Applicant or parent should identify and maintain current mailing address and/or telephone information. If the applicant's street address is recorded as "homeless", or is left blank and the "Homelessness" box is marked, the identified city and zip code will determine the managing CCR&R Agency. An Applicant or parent who does not have an address or telephone number must maintain as much current contact information as possible with the Child Care Resource and Referral Agency or Site Administered Child Care Provider.
    1. All notices will be deemed adequately served if they are mailed to parent(s) at their last known address, or if they are otherwise mailed or delivered to parent(s) based on the contact information that they maintain with their child care provider, CCR&R or Site Provider Agency
    2. A Family must have an active TANF Cash, SNAP, or Medical Assistance case and have an approved plan and arrangements for the recipient to receive all correspondence at the Family Community Resource Center address as a client with no permanent address. CCAP Specialist will need to enter the Family Community Resource Center address.
      PLEASE NOTE: If an Applicant is homeless, determine if a current email address is available for receiving Department notification.
  5. Notification
    All families approved under CCAP Protective Services Child Care identified as homeless will automatically receive 30-day written notification prior to end of eligibility that the case is to be canceled. CCAP Protective Services Child Care for families identified as homeless may be cancelled at any time it is determined that the family no longer meets the Department's definition of homeless, when the family requests to discontinue services under the provision of Protective Child Care Services, or at any time after a final determination is made the family is found ineligible for CCAP. Payment made prior to the final eligibility determination shall not be considered an error or improper payment. 
  6. Redetermination
    Homeless families approved under CCAP-PSCC seeking to continue eligibility after the initial 90-day period must be redetermined to continue receiving services, provided all applicable eligibility requirements are met including, (e.g., residency, education, employment and training) in order to be approved for a new 12-month eligibility period. If eligible the case shall be approved for a 12-month eligibility period in accordance with CCAP Policy.
    The family may be approved for a 2nd 3-month eligibility period under Protective Services Child Care if they are still experiencing homelessness at the time of redetermination as long as they have not been approved twice under these provisions within a 12-month period. If the 2nd PSCC period is immediately following the first 90 day approval, a new CTLAQ is not required.
  7. Denial, Cancellation
    CCAP Protective Services Child Care for eligible homeless families will end when the applicant family no longer meets the Department's definition of homeless, at the end of the 90 day period, or when it is determined that child services are no longer appropriate, whichever occurs first in accordance with the reasons for denial, cancellation.
  8. Reasons for Denial or Cancellation
    In accordance with CCAP-PSCC families may be denied or cancelled for reasons including, but not limited to the following:
    1. income exceeds maximum for family size,
    2. failure to submit Homeless Certification Questionnaire,
    3. family's circumstances do not meet the Department's definition of homelessness,
    4. submission of false statements, documentation, or misleading information in order to receive CCAP-PSCC for which no eligibility would otherwise exists.
  9. Care authorized with a Qualified License-exempt child care center (Applicable Only to Applications, Redeterminations, or Change of Information forms received on or after October 1, 2018). 
    1. A Certificate of Immunization is required to be kept in the family case record for all non-school-aged children who are receiving care through a License-Exempt Center
    2. Care approved using an approved License-Exempt Child Care Centers must have a written policy for it establishing grace periods that allow children experiencing homelessness enrollment in their program
    3. Under this provision, the center must allow families a reasonable time to take any necessary action to comply with requests for copies of birth certificates, prevention or immunization documentation and other health and safety requirements.
      1. Families may receive up to ninety (90) days to verify immunization requirements.
        1. The ninety (90) days grace period will not postpone the eligibility determination. However, if immunization is not verified by the end of the ninety (90) day period, the child for whom immunization cannot be verified will be determined ineligible for on-going child care assistance
  10. Families Experiencing Homelessness and Engaged in Activity
    1. If a family indicates they are experiencing homelessness, is involved in a CCAP eligible employment or education/training activity per CCAP policy and provides all required documentation:
      1. Select NO for the HOMELESS indicator in CCMS;
      2. Enter all required information;
      3. Run eligibility in CCMS;
      4. If eligible, approve the case for a 12-month eligibility period;
      5. Process a system override to give a $1 copay for the first three months of the 12 month eligibility period.
      6. Once approved and notices generated, update the case to change the HOMLESS indicator to YES.  This will allow proper reporting of the number of CCAP families experiencing homelessness.