Chapter 11 - Early Intervention Family Participation Fees

11.1 Family Participation Fee Policy

  • 11.1.1 Family Participation Fees are assessed based on a family's ability to pay. To determine ability to pay, EI compares household size and taxable reported income to the Federal Poverty Level on a sliding scale and consider out-of-pocket medical/disaster expenses. A family meets the definition of "able to pay" if the family falls within the scale and does not have proven out-of-pocket medical/disaster expenses in excess of 15% of the reported income. A family who is "unable to pay" is defined as a family whose household size and taxable reported income does not fall within the sliding scale and/or has proven out-of-pocket medical/disaster expenses in excess of 15% of reported income. Only one calculation per family is done. A family will only have one Family Fee account regardless of the number of children enrolled in EI at the same time.
  • 11.1.2 Family Fees are calculated as an annualized amount per IFSP period and broken into monthly installments for easier budgeting purposes. Family Fees are invoiced monthly to those who qualify to participate.
  • 11.1.3 Any and all services subject to fees are accrued and compared to the maximum out-of-pocket calculated for the Family Participation Fee.
  • 11.1.4 A family is never charged more than the amount EI pays for services subject to fees.
  • 11.1.5 The family pays either the amount calculated for the annualized Family Participation Fee maximum out-of-pocket OR the amount EI pays for services subject to fees - whichever is less. Maximizing insurance plans helps offset the cost to the program which may also offset the amount a family owes in Family Fees; meaning, if insurance pays for the direct services subject to fees, the family may owe only part of the calculated annualized Family Participation Fee.

11.2 Services Subject To Fees

Services subject to fees means any service provided that the EI System pays for on behalf of the child(ren) and family. The services that will be considered when calculating the amount the family may owe EI:

  • AT (Durable Medical Equipment and Supplies);
  • Audiology;
  • Aural Rehabilitation and other related services;
  • Developmental Therapy;
  • Health Consultation;
  • Nursing Services;
  • Nutrition Services;
  • Occupational Therapy;
  • Physical Therapy;
  • Psychological and or other counseling services;
  • Social Work and counseling services;
  • Speech Language Therapy;
  • Transportation, and
  • Vision Services.

11.3 Services Not Subject To Fees

Services not subject to fees means services that are provided at no cost to the child(ren) or family. Per law, those services include the following:

  • Child find activities;
  • Evaluations and/or Assessments;
  • Service Coordination (including but not limited to Transition, IFSP meetings, etc.);
  • Development, review and evaluation of IFSPs and interim IFSPs;
  • Developmental Screenings;
  • Medical Diagnostic Services;
  • Interpretation and Translation Services;
  • Administrative and Coordination activities related to Procedural Safeguards,and
  • All EI services when the parent or family meets the State's definition of inability to pay.

11.4 Determining Family Fees Participation

  • 11.4.1 Financial: All families are subject to a Family Participation Fee calculation. A family's household size and taxable, reported income are factors used to determine the amount based on a sliding scale and considering medical/disaster expenses. The family also must meet the state's definition of "ability to pay". The ability to pay is defined as a family that falls within the sliding scale and does not have out-of-pocket extraordinary medical/disaster expenses that exceed 15% of the reported income. The family may have income proven to be less than 185% Federal Poverty Level with All Kids or WIC eligibility documentation. Families proving income under 185% FPL meet the State's definition of inability to pay on the sliding scale. The Service Coordinator should determine if the family qualifies for the Family Fee Exemption outlined in Chapter 11.8.
  • 11.4.2 Multiple Siblings: A family is only assessed one Family Fee account per household, regardless of the number of siblings in the EI system at any one time. A Family Fee account is specific to a matching IFSP period. Families who have multiple IFSPs will have multiple Family Fee Accounts. Each account is associated with a separate IFSP, calculated separately and invoiced separately. A family who qualifies to participate in Family Fees will receive a monthly invoice in addition to the Parent Explanation of Benefits showing any and all services provided to their child(ren).
  • 11.4.3 Declining Verification of Income: A family may decline to provide proof of household income. If the family declines to provide proof of household income, they must sign the CFC Family Participation Fees Payment Agreement acknowledging that the family will be subject to the highest annualized Family Fee calculation/monthly installment. The agreement also explains the services subject to fees and insurance usage options to help minimize the out-of-pocket costs to the family.
  • 11.4.4 Exemption Requests: A family who does not meet the state's definition of ability to pay as outlined above, must be provided all EI IFSP-approved and consented services at no cost. The family should receive information and assistance to request an exemption to Family Fee participation. The CFC Family Fee Exemption Request must be requested through the CFC to the Bureau of EI and follow proper procedures. Exemptions are only for the current IFSP and are not retrospective. All out-of-pocket medical and/or disaster expenses for the household are considered, not just the child in EI. All expenses must be within the previous 12 months of submitting the request. Expenses can include actual payment amounts on qualifying expenses as well as outstanding "due" current amounts for qualifying expenses. Any medical expense approved by the Internal
  • Revenue Service (IRS) as an acceptable medical cost for deductions on taxes can be used in the calculation of the Family Fee Exemption.
  • 11.4.5 Changes to household size or income: The Family Fee can be adjusted in the system prospectively, at the request of the family and with proof of the needed adjustment. If household size or income changes occur, the CFC should obtain necessary documentation and immediately make adjustments in the system.
  • 11.4.6 Acknowledgement of Understanding and Agreeing to Family Participation Fees: Every family is provided with written documentation and support to understand Family Fees and is required to sign an agreement that they understand the Family Participation Fee process.
  • 11.4.7 Family Fee Record period: The Family Fee record begins with the entry of the first direct service authorization subject to fees and ends only when the IFSP ends or is closed. The monthly level payment installments accrue beginning the first calendar month direct services subject to fees are authorized to begin before the 16th of the month and will continue through the last calendar month the file is active after the 15th of the month. This means if the first direct service authorization for services subject to fees is entered on the 18th of the month, that calendar month will not accrue the monthly installment. And if the case is closed or IFSP ends before the 16th of the month, the monthly installment will not accrue for that final calendar month. The Family Fee is not based on how many or what type of services but rather it is calculated based on household size and income and broken into monthly installments. All services subject to fees are accumulated towards the maximum out-of-pocket but the family cannot be charged more than what EI pays for direct services subject to fees.
  • 11.4.8 The Family Fee is a monthly installment of the annualized maximum out-of-pocket. This means that if the monthly installment is $100 and the Family Fee period is 11 months, the maximum out-of-pocket is $1,100 broken into 11 level monthly payments of $100. If the CBO pays $3,000 for direct services subject to fees, the family only owes $1,100. If the CBO pays $500, the family only owes $500. Remember that the EI charges the maximum out-of-pocket or the amount EI pays for services subject to fees - whichever is less.

11.5 Family Fee Procedures

Explain to the family the policies and procedures of Family Fees including sliding scale calculations, exemptions and choice to decline providing income verification.

  • 11.5.1 Ensure the family has been provided at Intake and at each annual IFSP the Illinois Family Participation Fees Program Fact Sheet to discuss and answer questions.
  • 11.5.2 Record the household size into the system: Record the number of people in the EI household that the head of household is financially responsible for based on who is counted on Internal Revenue Tax forms. If filing status has changed since the last tax return was filed, enter the amount claimed and case note the situation. This is useful for recent separations, divorces, etc. Document any differences from the number claimed to any documents received for audit purposes.
  • 11.5.3 If more than one child from a family is enrolled, group the children in Cornerstone.
  • NOTE: Not all CFC offices are able to group children due to shared server issues. This issue is scheduled to be resolved in a future Cornerstone version. The grouping issue impacts CFCs on shared server with other Cornerstone programs AND there are multiple children active in EI at the same time AND the family participates in Family Fees. If children cannot be grouped, please ensure proper CFC Family Fee Credit Requests are applied for (see 11.9 for details).
    • Group siblings in EI on PA06 of Cornerstone. All children being grouped must have active IFSPs prior to grouping.
    • If all children in the family have the same date of birth and are being enrolled at the same time, randomly select the group head.
    • If the children have different dates of birth and are being enrolled at the same time, select the youngest child as the group head.
    • If the children being enrolled have different dates of birth and/or are being enrolled at different points in time, always select the youngest child as the group head.
    • When one child exits but one remains in EI, remove the grouping on the PA06 screen in Cornerstone.
  • 11.5.4 For DCFS Wards in foster care OR children residing in private residential facilities where the facility has guardianship established only: Enter Household Size of 1 in the system.
  • 11.5.5 If the family does not provide proof of household income, ensure the family is informed of the provision to decline and accept the Family Participation Fees maximum annualized calculation. The parent must sign the CFC Family Participation Fees Payment Agreement indicating their understanding and acceptance.
  • 11.5.6 If the family chose to decline income proof, indicate Max Fee (parent declined to provide proof) on the PA25 screen in Cornerstone.
  • 11.5.7 For all other households, confirm the household size and income reported on the most recent DSCC Screening Device are still accurate.
  • 11.5.8 Record the household Proof of Income into the system: There is a hierarchy of income proof. EI recognizes certain other state entities eligibility as proof of income (All Kids, DCFS Wards and WIC). EI will not require tax returns or pay stubs for these families because they have already verified their income with the other state agencies. Other households, agreeing to share income, must use the
  • hierarchy of income proof (Federal Tax Return, Current Pay Stubs or Statement of Income affidavit) listed in order below. Copies must be obtained for the record and audit purposes.
  • NOTE: Even families of DCFS Wards, All Kids and WIC must still provide an amount of income to be recorded. The Proof of Income will be the respective state agency's proof in the list - no additional proof of income is required other than their All Kids card or print out of PA42 screen from Cornerstone.
    • For DCFS Wards in foster care OR children residing in private residential facilities where the facility has guardianship established only: Enter $0 for Income amount with the Household Size of 1 in the system. Proof of Income should be All Kids < 200% FPL.
    • Use All Kids < 200% FPL for households on All Kids who can provide a copy of their current All Kids card (or you can obtain the proof from the system and print a copy of the PA42 screen from Cornerstone) for the record.
    • Use WIC ID Card for households with current proof of WIC participation. Obtain copy for the record.
    • Use Federal Income Tax Form-1040 for households not covered under All Kids or WIC. Record the amount from line 22 of the most recent Federal Income Tax Form 1040 if it accurately reflects the household income sufficiently. Obtain copy for the record. W-2 documents are not acceptable. If the most current tax return does not accurately reflect the household income, choose the next appropriate option;
    • Use Two Check Stubs for households not covered by options above provided it currently reflects the current income of the household. Obtain current copies of 2 consecutive pay stubs from all employed parents in the EI household for the record. Calculate the annual gross income amount based on frequency of pay dates (2 times per month, bi-weekly, monthly, etc.).
    • Use Statement of Income Affidavit for households not covered under the other Proof of Income options. This is useful for households who may be self-employed and do not receive pay stubs or the status of employment has changed since the last tax filing or the tax return does not adequately reflect the current income situation. Have the family provide and sign a written statement of anticipated annual gross income. The affidavit does not have to be notarized or obtained from an accountant. Keep the original in the record.

11.6 Families Participating in Family Fees

After explaining the Family Fee policy and reviewing the Illinois Family Participation Fees Fact Sheet with the family, if the family is subject to Family Participation Fees, provide the family with the CFC Family Participation Fees Payment Agreement form to review. After all questions have been answered, ensure the form is completed and signed.

NOTE: Best practice is to have all families sign, but it is required of all families calculated to participate in Family Fees.

  • Maintain the original in the case record
  • Provide the family with a copy of the signed CFC Family Participation Fees Payment Agreement
  • 11.6.1 Family Fee Report (Cornerstone HSPR0778)
    • Calculate and print out the system generated - Family Fee Report as soon as all verified information is in the system.
    • Maintain a copy in the record.
    • Provide a copy to the family as soon as possible but before any direct services subject to fees begin.
    • Remind the family to report changes timely per the CFC Family Participation Fees Payment Agreement form they signed.
    • Confirm the report indicates the correct household size, annual gross income and Proof of Income.
  • 11.6.2 Changes to household size or income:
    • If anything changes that affects the Family Fee calculations, update the system and reprint the Family Fee Report as quickly as possible.
    • Maintain a copy in the record
    • Provide a copy to the family as soon as possible.

11.7 Families Not Participating in Family Fees

For families not eligible for Family Participation Fees, calculate and print out the Family Fee Report showing family is not eligible to participate in Family Fees.

NOTE: Best practice is to have all families sign the CFC Family Participation Fees Payment Agreement, but it is only required of families calculated to participate in Family Fees.

11.7.1 Family Fee Report

  • Maintain a copy in the record.
  • Provide a copy to the family as soon as possible but before any direct services subject to fees begin.
  • Remind the family to report changes timely.

11.7.2 Changes to household size or income

  • If anything changes that affects the Family Fee calculations, update the system and reprint the Family Fee Report as quickly as possible.
  • Maintain a copy in the record
  • Provide a copy to the family as soon as possible.

11.8 Family Fee Exemptions

If the family is potentially eligible for an exemption from participating in Family Fees, assist the family in the process of applying for the exemption immediately. Explain to the family the exemption policies and procedures.

  • 11.8.1 Family Fee exemptions are for families who have, or are incurring, excessive out-of-pocket expenses due to high medical costs or disasters such as fire or flood that are in excess of 15% of the gross annual income.
  • 11.8.2 Verify the current gross income and household size to determine if any unreported changes have occurred that could adjust the Family Participation Fee amount.
  • 11.8.3 If necessary, submit a Family Fee credit request for instances approvable that could adjust an accruing balance owed by the family. This includes situations
  • such as change of income or new household member not corrected in the system timely.
  • 11.8.4 Consider expenses for any household member - not just the child participating in EI when determining documentation for the request.
  • 11.8.5 Expenses allowed by the Internal Revenue Service for medical deduction itemization are allowed by EI to be counted towards out-of-pocket medical expenses. (Example: Dental, medical, optical.)
  • NOTE: Health Insurance premiums paid using pre-tax dollars are not acceptable.
  • 11.8.6 Families should contact their tax consultant if they have specific questions about qualifying medical expenses.
  • 11.8.7 Family Fee exemptions are not retroactive and begin the day the Family Participation Fee Exemption Request form is completed and submitted to DHS.
  • 11.8.8 Family Fee exemptions are for the current IFSP period and must be reapplied for when the current IFSP period ends and the child will continue in EI in a new IFSP period.
  • 11.8.9 Expenses include payments for qualifying expenses made within the last 12- month period from the month of request. Expenses also include current amounts due on current (within 12 months) outstanding bills for qualifying expenses. Example: Surgery performed that has outstanding balance due now, even if actual date of surgery occurred prior to the 12-month period prior to the request.
  • 11.8.10 Collect and review the required documentation with the family listed on the CFC Family Participation Fee Exemption Request. The request packet must include:
    • Completed and signed form
    • Copy of Family Fee Report showing current gross income and household size.
    • Itemized list of all medical or disaster allowable expenses during previous 12 months and/or bills currently owed that will not be covered by insurance. Best to look for larger items first to meet required 15% to make calculations easier. Stop accepting expenses once 15% is exceeded.
    • This list should be created by the family showing details of the amount and where/who accrued the expense. (Example: John Doe, $140, ABC Hospital).
    • Copies of receipts and/or unpaid invoices showing portion still due that is not covered by insurance matching itemized list described above. The family may use printouts from an agency showing history of the previous 12 months of payments such as pharmacy or insurance printout.
    • Optional documentation that family feels is necessary to prove consideration if not matching the required items above.
    • Confirm the packet is complete and submit to the Family Fee Coordinator at the Bureau of EI.
    • Adjust the Proof of Income in the Cornerstone system once the packet has been sent. The day the packet is submitted to the Bureau of EI, adjust the Proof of Income to Pending Exempt.
    • Reprint the Family Fee Report. Send copy to family and file copy in record.
    • The family will not accrue a monthly installment for any month while Pending Exempt is the Proof of Income.
    • The Bureau of EI will review and make a decision within 10 working days of receipt. The Bureau of EI will inform the CFC of the decision with a Memorandum which is to be shared with the family within four (4) working days of receipt of the Memorandum by the CFC.
  • 11.8.11 If the request is approved, the CFC should adjust the Proof of Income to either Medical Exempt or Disaster Exempt, as appropriate.
    • Reprint the Family Fee Report.
    • Send copy to family
    • File copy in record
  • 11.8.12 If the request is denied, the CFC should adjust the Proof of Income to the correct proof on file (Federal Tax Return 1040, Two Check Stubs, Statement of Income Affidavit, etc.).
    • Reprint the Family Fee Report.
    • Send copy to the family
    • File copy in record

11.9 Family Fee Credit Requests

If the family was billed in error, the CFC must document and verify the cause of the error and request a fee credit. For instance, authorizations are entered but services do not start timely that would result in a monthly installment being charged for a month that the child did not start yet. Also, when the child is discharged but the case is not terminated timely and the monthly installment accrues for one or more months while the child does not receive any services. If a change in household size or income that was not adjusted in the system timely results in an incorrect monthly installment charged, submit a request for the partial amount that was incorrectly accrued.

  • Complete the CFC Family Participation Fee Credit Request form
  • Submit completed form and current Family Fee Report to the Bureau of EI
  • Adjust the system as necessary
  • Issue new Family Fee Report if changes occur in the Family Fee calculation
  • Send copy to the family
  • File copy in record

11.10 Family Fee Delinquency

DHS sends a written notice to the family if they fall behind in minimum payments. Service Coordinators should be prepared to update financial data and recalculate fees if income, family size, All Kids or WIC status changes or if the family no longer meets the state's definition of "ability to pay". The Service Coordinator must use the monthly Delinquency Report to make contact with families above and beyond the DHS written notices.

  • When DHS sends a notice to the family regarding minimum due payments that are one month (30 days) past due, follow up with family.
  • When DHS sends a notice to the family regarding minimum due payments that are two months (60 days) past due, follow up with family.
  • When DHS sends a notice to the family regarding minimum due payments that are three months (90 days) past due;
  • Notify the provider(s) that services subject to fees will be discontinued and the date that they will be discontinued.
  • Notify the family that services subject to fees will be discontinued and the date that they will be discontinued, but that the child is still eligible for services not subject to fees AND that, as long as the case remains open, the monthly installment will continue to accrue.
  • Adjust the end dates of authorizations for services subject to fees to end on a date at least two weeks after the notices have been sent to the family and providers.

NOTE: The exception is AT devices. Do not discontinue AT service authorizations that have previously been entered into Cornerstone.

  • After adjusting authorizations, print the revised IFSP and send a copy to the family and other team members with a letter indicating the discontinuation, send Sample Letter 12: Discontinuation of One or More Services - Non-Payment of Family Fees (Cover Letter to Revised IFSP).
  • File a copy of the IFSP and the letter in the CFC permanent record.
  • DO NOT enter any new authorizations for newly approved AT devices or any other services subject to fees until the family is no longer delinquent. Notify the DHS AT Coordinator to suspend processing AT requests not yet approved for authorization.
  • Upon contact from family indicating payment and wanting services to start again, contact the CBO Call Center at 1-800-634-8540 to verify receipt of payment. Check back as necessary as the processing of a payment could take 5-7 working days to show in the system.
  • Once verification of payment making parents less than 90-days delinquent is received, initiate the IFSP review/update process to identify services that are subject to fees that should be re-authorized.

11.11 Bankruptcy

If a family states they have filed for bankruptcy but continue to receive invoices from the CBO, contact the CBO Call Center at 1-800-634-8540 to work with the Family Fee Accountant to help the CBO obtain necessary documents from the family.

  • Modify the Family Fee information in Cornerstone ONLY IF the family indicates other changes to household size, income, excessive out-of-pocket medical/disaster expenses. Follow procedures outlined above to review Family Participation Fees eligibility.
  • EI will not pursue pre-discharge debt for bankruptcy but will pursue post-discharge debt. Therefore the families retain responsibility for the portion of their fee not recorded in the bankruptcy period but are responsible for the portion after the disposition/discharge.

Rev. 11/01/2015