Management Bulletin 03-09, Attachment A
Excerpts from 2003/04 Child Development Attendance and Fiscal Reporting and Reimbursement Procedures, Child Development Fiscal Services, Fiscal & Administrative Services Division (http://www.cde.ca.gov/fg/aa/cd/index.asp), California Department of Education
Page 13: Enrollment vs. Operation vs. Attendance
Days of Operation
A "Day of Operation" is a day the contractor provides child care and development services for one or more certified children enrolled.
Page 16: Non-Operating Days
Staff Development Days
Staff development days benefit the program because staff is being trained, but because children are not receiving services those days cannot be reported as days of operation and should not be included on the service calendar submitted. (If the contractor brings in substitute staff and provides subsidized services then it is a day of operation.) IF service calendar days are used as staff development days (without providing services) there may be an adverse affect on contract reimbursement, either by lowering the Maximum Reimbursable Amount (MRA) due to failure to meet the contract Minimum Days of Operation (MDO) or by insufficient service earnings:
Effect on MRA: Service calendar days used as staff development days may affect the contract MRA because the contractor is operating less than 100% of the MDO. Contractors who fail to operate at least 98% of the contract MDO will have the contract MRA "reduced in proportion to the percentage of the contract minimum days of operation that the contractor was not in operation" (Title 5, Section 18055). This allows a two percent (2%) "flex for minimum days of operation" (2% of a 250-day calendar is five days; 2% of 175 days is three days), and this allowance is usually sufficient to account for a few non-operating staff development days. However, the 2% "flex for MDO" is for all days in the calendar when the contractor fails to operate, so contractors should take care to not exceed this 2% MDO allowance or the MRA will be reduced (see "Flex Factors").
Effect on Service Earnings: Staff development days with no services provided may mean the contractor will not have sufficient total certified enrollment to generate enough service-level earnings to cover certified program costs or earn the contract MRA (see "Limits of Reimbursement"). To substitute for enrollment lost due to staff development days, a contractor may need to increase enrollment by enrolling more children, or enrolling children for longer periods of time, on days the program is in operation (see "Self-Help: CDFS Worksheets").
Page 46: Flex Factors
Flex for Minimum Days of Operation (MDO)
This allows a 2% flex factor for agencies that do operate at least 98% of their contract MDO; contractors have that small degree of flexibility within the 98-100% in case they are short one or two days of operation.