04.02.01 - Copayments

Effective Date: 11/01/04
Revised:  5/1/10, 6/15/10, 4/1/11, 7/1/12, 7/1/13, 07/1/17, 7/1/22
Reference: 89 Ill. Adm. Code, Chapter IV, §50.310; 45 CFR Part II, Subpart E, §98.42;

Policy Statement:

All families approved for CCAP (other then those exempted below) must share in the cost of child care by paying a monthly Family Copayment based on their family size and non-exempt income as illustrated in Administrative Rule 50.320 at https://www.ilga.gov/commission/jcar/admincode/089/089000500C03200R.html. 

If all the children in care are school age* and are approved for only part-time days (less than 5 hours per day) during services months of September through May, the Family Copayment will be assessed at 50% of the amount shown in Administrative Rule 50.320.

* A school age child is a child whose age is 5 to 13 years and is enrolled in school.

The State is responsible for the costs in excess of the assessed copayment up to the state maximum rates. See example in section IV. (C) of this part. The parent is responsible for additional costs charged by the provider that are not reimbursed by CCAP.

Applicability:

All families must share in the cost of child care as illustrated in Section 50.320, except the following criteria:

  1. relatives (other than parents) who receive a child-only TANF benefit for children needing care due to the relatives' employment:
  2. families approved for CCAP Protective Child Care services due to experiencing homelessness;
  3. youth in care, as defined in Section 4d of the Children and Family Services Act, who are parents, and, for 12 months after the parenting youth in care's case with the Department of Children and Family Services is closed, any family that receives child care assistance;
  4. families receiving Extended Family Support Program services from the Department of Children and Family Services; and
  5. families with active CCAP cases in which a parent in the household is called into active military duty

Families that meet the following criteria will have their copayments assessed at $1.00 per month:

  1. CCAP-eligible families with a parent or guardian working in child care, as defined by the Department (See section VI below).
  2. Families with income at or below 100% of the Federal Poverty Level (FPL) .

If all of the children in care are of school age and are approved for part-time (less than 5 hours per day) day care for any month September through May, the parent share is 50% of the amount shown in Section 50.320. A school age child is a child whose age is 5 to 13 years and is enrolled in school.

Procedures:

Use IL444-3455B Table A for all families for the service months of June, July and August.

For the service months of September through May, use Table A for all families not covered by Table B.

Use IL444-3455B Table B during September through May only when all of the children in care are school age (age 5 or older as of the month of September of each school year) and are approved for less than 5 hours of care.  This also applies to families whose children are in year-round school.

General Guidelines for Assessing the Monthly Copayment

The parent's copayment is based on the family's combined non-exempt income and family size at the time eligibility is determined with a new application or at the time of a scheduled redetermination. 

Refer to Policy 04.03.01 for other potential costs to the parent.

  1. To determine the monthly copayment, include income from all sources unless the income is on the exempt income list.  (see section 01.02.03)
  2. In general, the copayment shall be allocated to the child having the highest reimbursement from the state to avoid the need to allocate a portion of the copayment to multiple children or multiple providers.
  3. When the family has only one provider, the copayment shall be allocated to the youngest child first. If the copayment exceeds the approved cost of care for the youngest child, the remaining amount shall be allocated to the next oldest child. This method shall be used until the full parent copayment has been allocated. For CCR&Rs or site providers entering cases, the child care tracking system will allocate the copayment automatically.
  4. Payment will not be made by the State if the monthly copayment exceeds the approved cost of care for all eligible children.  Add the following language to the approval notice until the form can be permanently changed:  "If the assessed copayment exceeds the actual cost of care, then the parent pays the actual cost of care and no payment is made by the state."
  5. Parents are responsible for paying the copayment directly to the provider. IDHS considers the collection of the monthly copayment to be between the parent and the provider.
  6. Use IL444-3455B Table B only if:
    1. All the children in care are school-age (age 5 or older as of the month of September of each school year), and
    2. All the children in care are approved for part-day/school age rate (less than 5 hours per day) unless full time days are needed to cover week days the school is not in session (holidays, in-service days, snow days...).  If any full time days are approved based on the client's activity schedule, chart A must be used,and
    3. The care is provided during the months of September through May.
  7. Use IL444-3455B Table A in all other instances.
    Example 1: Ms. A has one school age child, and one child who is age 3. Use Table A Copayment for family size of 3 for all months of care.
    Example 2: Mr. B has 3 school age children who receive care during the month of April. Use Table B Copayment for family size of 4 for April and May. Use the Table A copayment for care provided in June, July and August.
    Example 3: Ms. C has 2 school age children who attend a school with a year-round schedule. School is in session in June, but not in December. Use Table A copayment for family size of 3 for care provided in June, July, and August. Use the Table B copayment for care provided in September through May including December.

Note - CCMS will calculate copayment amounts based on family size and income.? A copayment override will be needed for some cases to ensure the correct copayment has been assessed according to this policy.?


II.  How to Assess the Copayment when the Parent has More Than One Provider

If a family has more than one child care provider, only one provider is assessed and collects the copayment.

  1. If all the providers are paid through the CCR&R, the CCR&R shall assign the copayment to the provider receiving the highest reimbursement from IDHS, considering the amount of the copayment and the amount of the child care charges. The provider(s) not collecting a copayment will be reimbursed the full amount of the child care charges up to the maximum state rate.
  2. If the family has both a Site Administered Provider and a provider paid through the CCR&R, the copayment shall be assigned to the Site Administered Provider. The Site Provider must give the CCR&R a copy of the Approval Notice for the case record.
  3. If the family uses two Site Administered Providers, the copayment shall be assigned to the Site receiving the highest reimbursement from IDHS, considering the amount of the copayment and the amount of the child care charges. The Site not collecting a copayment will be reimbursed the full amount of the child care charges up to the maximum state rate.
  4. If the copay exceeds the amount charged to the first provider, the second provider shall be assessed the remainder.  This situation doesn't happen very often.

Changes in the Copayment Assessment

The copayment shall be calculated at the time of application and when a redetermination is conducted at the end of an eligibility period.

  1. If you receive new earned income information due to a change in a family income prior to redetermination:
    1. recalculate the income to ensure the case remains eligible by being below 85% SMI.  
    2. Case note the date that you received the new information along with the new total monthly income amount.
    3. If the copayment has decreased due to a loss of income or increase in family size, the lower copayment goes into effect the month following the reassessment. 
    4. Do not increase  the copayment amount in the CCMS Families continue to be subject to the Combined Gross Monthly Base Income limit of 85% of SMI and shall report all increases in income within 10 calendar days even if the change does not immediately affect the copayment.  If the family is determined to have income over 85% of SMI , cancel the case giving 10 calendar days' notice in accordance with Policy 02.07.01.
  2. A decrease in the monthly copayment shall be implemented on the first of the month following the month in which the change is reported and documented. Parents who report a decrease in income must provide written documentation to support the reduction in copayment.  This documentation must be maintained in CCMS.
  3. Do not adjust the copayment for any month due to vacation, illness, center closure, or when care begins or ends mid-month, even at the time eligibility is established. 
  4. The State is responsible for the costs in excess of the assessed copayment up to the state maximum rates. See example in section IV. (C) of this part. The parent is responsible for additional costs charged by the provider that are not reimbursed by CCAP.
  5. The only times a copayment amount can increase during an eligibility period is when it had been decreased during the eligibility period and is being re-assessed due to a change reported by the client.  Copayments can only be re-assessed up to the amount originally assessed during eligibility determination. This could occur when:
    1. A client reported a temporary loss of employment and their copayment was lowered due to decreased family income. 
      1. If the client returns to work, the copayment is to be reassessed based on the new income documentation. 
        1. If the new income exceeds 85% SMI, cancel the case with a 10-day notice. 
      2. If the new copayment is higher than the original amount assessed at the time of eligibility determination, increase the copayment to the same amount as established at the beginning of the eligibility period.
      3. If the copayment is higher than it was during the loss of employment, but lower than the original amount, change the copayment based on the new income amount.
    2. A family that qualifies for use of Co-payment Chart B per Procedure I. F. above can have their copayment increased to the Chart A level starting in September since the change was determined at the time eligibility was established.


Collecting the Copayment

  1. All providers in the IDHS Child Care program are required to collect the monthly copayment and keep records of this collection. IDHS may ask for copies of records of parent copayment collection.
  2. Providers are encouraged to collect the fees before the service is given or use fee collection policies developed for private pay parents.
  3. IDHS automatically deducts the assessed monthly copayment for each family from the total charges billed on the Child Care Certificate or Monthly Enrollment Report during the payment process.
    A provider should still submit the Certificate or MER for billing purposes even if the copayment exceeds the payment amount so the provider can be paid for any additional add-on fees for which the provider is eligible.

    Example:  Eligibility begins on 6-29-22.  The monthly copayment is calculated to be $213.  The provider bills the state for 2 days of care at $35.30/per day.  The total charge for the month of April is $70.60.  Since the copayment of $213 exceeds $70.60, the provider should only collect $70.60, from the parent for the first month of care.  The state will pay the provider for the other fees such as Quality Add-ons (if applicable), etc. for which they are eligible.

Changing Providers

  1. Managing the copay
    Families shall pay their monthly co-payment to the provider that is approved on the first day of the month. Consequently, if a family changes provider any time after the first day of the month, the first provider shall collect the whole monthly copayment.  If charges for care are less than the monthly copayment, the provider shall collect the smaller of the two amounts.  The new provider will not collect a copayment until the first of the following month.

    Example A:      A family's monthly co-payment is $100.00. Provider A is the current provider and charges $25.00 a day.  If the last day of care at Provider A is June 2, the parent will pay Provider A $50.00 ($25.00 x 2 days of care).  The charges for care used are less than the monthly co-payment. The new provider will not collect a co-payment during the month of the change but will begin collecting $100 on July 1.

    Example B:      A family's monthly co-payment is $100.00. Provider A is the current provider and charges $25.00 a day.  If the last day of care with Provider A falls on July 10, the family will pay their full monthly co-pay to Provider A and will pay nothing to the new provider for July (the month of the change). On August 1 the new provider should collect $100.

Effective Date of Change
Parents are responsible for reporting all changes within 10 calendar days (whether via phone, walk in, fax, mail, etc.).  The CCR&R shall issue the COP form to the parent (if initial report of change was not in writing via a COP form), and the parent has 10 business days to complete and return the form.  If the provider change is not reported within 10 calendar days and documented in writing with the COP form within 10 business days, the change will take effect the month the documentation is received.

Example C:  Client calls the CCR&R to report a COP on June 1.  The new provider started on May 29.  CCR&R sends client the COP form and client returns the COP form within 10 business days.  The effective date of the change will be May 29.

Example D:  Client calls the CCR&R to report a COP on June 1.  The new provider started on May 29.  CCR&R sends the client the COP form, but the CCR&R doesn't receive the COP form until September 15.  The original provider should be closed out effective May 28 and the "No Qualified Provider" ID entered onto the case until the COP is received. The case should not be canceled due to the lack of a qualified provider.  When the provider change is received, care with the new provider can be backdated to May 29th if no other provider has been paid for the time requested.  

Co-pay Reductions for Child Care Worker

  1. For the purposes of determining CCAP co-pay amount for parents or guardians determined eligible for CCAP, a child care worker is any employee at a licensed child care center, licensed child care home, licensed group child care home, license-exempt child care center, or license-exempt child care home who spends 75% or more of their regular daily scope of work in service of early childhood education and care, including, but not limited to:
    1. Directors and Assistant Directors;
    2. Regular teaching staff, including teachers, teacher aides, and assistants;
    3. Floating or substitute teachers;
    4. Family engagement and support staff;
    5. Office staff;
    6. Support staff, including custodial, kitchen, transportation, and other staff.
  2. Employment in child care can be confirmed based on the employer information on the CCAP application, Redetermination or Change of Information forms.
  3. Employers listed on pay/employment verification documentation that are known to be child care providers by CCAP eligibility staff need no further verification.
  4. If unsure whether the employer is one of the child care provider types listed in VI.A, CCAP staff are to contact the employer to verify.
  5. CCAP staff are to contact the employer with questions about the amount of time the parent/guardian is assigned to child care duties. For example:
    1. The CCAP Application list the client's job title as "custodian."
    2. The employer is a child care facility located in a business that provides services in addition to child care.
    3. The employer should be contacted to confirm the client spends at least 75% of their regular daily scope of work in service of early childhood education and care.
      1. If confirmed, a $1.00 copayment should be assessed.
      2. If not confirmed, the copayment will be based on family's size and income according to the IL444-3455B.
    4. The Gateways to Opportunities Registry can also be used to verify that a parent/guardian is employed by a child care provider.