01.03.10.a - PSCC: Families Experiencing Homelessness

Effective Date: 09/30/2016

Revisions: 07/01/2022

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.

• Families approved under this section will have their monthly family copayment waived (assessed at $0).
• Families being approved due to homelessness will initially be approved for a 12-month eligibility period.
• Families that report they are experiencing homelessness and indicate an eligible employment or education activity at the time of application or redetermination will be given 90-days from the date of CCAP approval to submit documentation of an eligible activity and homelessness to continue their 12-month CCAP eligibility period.
• Families that indicate Homelessness as the Reason for Care on the IL444-33455 must submit a Certification of Temporary Living Arrangement Questionnaire (CTLAQ)pdf at the time of the application or within 90 days of the application submitted stamp date. If the Homeless CTLAQ form is not received within 90 days case will be cancelled.
• Family non-exempt income and total assets must be within CCAP guidelines.

Procedure

1. Documentation of Homelessness

   1. A family's application or redetermination must be marked "Homelessness" as the Reason for Care and their circumstances must meet the McKinney-Vento Act definition of homelessness
   2. The Family must complete, sign, and return the Certification of Temporary Living Arrangement Questionnaire (CTLAQ) to document:
      1. that their living situation is included in the McKinney-Vento Act definition above and
      2. that they have registered with an approved local agency or program to support families experiencing homelessness
      3. Approved local agencies and programs can include, but are not limited to:
         1. Homeless Shelters
         2. Early Head Start and Head Start programs
         3. Transitional housing programs
         4. CCR&R's and Sites may contact dhs.ccap.policy@illinois.gov to inquire about specific programs
   3. If an application or redetermination is submitted with Homelessness selected as the Reason for Care process the application/redetermination in CCMS and approve the case for 12 months for all eligible children
   4. Issue a Request for Additional information and a blank CTLAQ to the applicant giving them 90 days from the approval date to submit and documentation of an eligible activity.
   5. If the CLTAQ is not retuned, cancel the case effective the last day of the month following the 90th day after the first date of eligibility.
   6. If the CLTAQ is completed returned within the 90 days, but there is no documented activity, the case will be canceled effective the last day of the 6th full month of the eligibility period. 
   7. If the CLTAQ is completed and returned within the 90 days, the case will continue through the end of the 12-month eligibility period if there is a documented eligible activity.
   8. Payments made during the time the family is completing the Certification of Temporary Living Arrangement Questionnaire (CTLAQ) shall not be considered an error or improper payment even if the form has not been submitted.

2. Activity Requirements

   1. If an application or redetermination is submitted with Homelessness selected as the Reason for Care and there is no eligible employment or training activity indicated process the application/redetermination in CCMS and approve the case for 12 months for all eligible children.
   2. Issue a Request for Additional information to the applicant giving them 90 days from the CCAP approval date to submit documentation of an eligible activity.
   3. If the documentation is not retuned, cancel the case effective the last day of the month following the 90th day after the first date of eligibility.
   4. If documentation of an eligible activity is returned, and non-exempt income is below 225% of Federal Poverty Level (FPL), the case will remain approved for the entirety of the eligibility period.
   5. Payments made during the time the family is completing the activity documentation process shall not be considered an error or improper payment even if the form has not been submitted.

3. Authorization of care

   1. For families eligible for CCAP due to homelessness, the child care arrangement schedule shall be approved as listed on the application. If the application does not include a schedule, the case should be approved for five full-time days per week: Monday through Friday.
   2. Eligible days can be increased during the eligibility period from the scheduled requested if an activity is reported that needs additional days of care.
   3. Families experiencing homelessness that are not engaged in an activity may be eligible for an Initial Activity Search (IAS) as described in CCAP Policy Section 01.03.12. The copayment will be waived for the entire eligibility period.
   4. The Family Co-payment shall be waived and assessed at $0.00 per month during the entire CCAP 12-month eligibility period.
   5. Families that document they are experiencing homelessness that are engaged in a CCAP eligible activity will be approved for 12 months. Under the Protective Services guidelines, the family monthly copayment will be waived for the entire eligibility period.
   6. At the time of redetermination, 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.

4. Authorization and Verification

   1. Families being approved due to homelessness will initially be approved for a 12-month eligibility period.
   2. The 90-day period is provided to children whose parents indicate they are currently experiencing homelessness and are engaged in a CCAP eligible activity.
   3. CCR&Rs 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.  The CTLAQ will document the family's eligibility under this provision and explain their responsibility to provide accurate information.
   4. The CTLAQ must be signed by the applicant/client and identify a certified homeless agency/program within 90 days of CCAP approval.
   5. 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.

5. Contact Information

   1. The parent/guardian should identify and maintain current mailing address and/or telephone information.
   2. If the parent/guardian 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.
   3. The parent/guardian 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.
   4. 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
   5. 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.

6. Reasons for Denial or Cancellation

   1. Families experiencing homelessness may be denied or cancelled for reasons including:
      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 to receive CCAP-PSCC for which no eligibility would otherwise exists.

7. Immunization Certification Grace Period

   1. Families may receive up to ninety (90) days to verify immunization requirements.
   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.

8. 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 YES 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. Copayment will be waived for the entire eligibility period.