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Commingled versus Co-Located Programs FAQs

Answers frequently asked questions (FAQs) from the Commingled versus Co-Located Programs webinar training presented on January 15, 2025.

General

  1. What is a commingled program?

    A commingled program is defined as the provision of services to both California State Preschool Program (CSPP) and non-CSPP children in the same classroom at the same time (California Code of Regulations, Title 5 (5 CCR) Section 17700(r)).

  2. What is a co-located program?

    Co-located programs are those that share the same facility but not the same classroom. Co-located programs can be:

    • Program types that cannot be commingled because they are different types of programs with different program requirements, or
    • Program types that can be commingled, but the contractor chooses not to do so.

    Contractors with co-located contracts must ensure subsidized children are not enrolled in more than one program at the same time.
  3. Can I have a commingled and co-located program?

    Yes, it is possible for a contractor to operate a commingled and co-located program at the same site. For example, a contractor that has two preschool classrooms at a site, may have one classroom with only non-certified children (co-located), and another classroom that has both certified and non-certified children (commingled).

Reporting

  1. How does a contractor's reported data differ when operating a commingled versus co-located programs?

    When contractors have commingled or co-located programs, oftentimes, a cost allocation plan will be necessary to be able to accurately report the appropriate costs for each program. A cost allocation plan identifies the appropriate amount of expenses to be ascribed to a program. With both commingled and co-located programs, the enrollment of a child may not be charged to more than one program.

    Contractors should refer to the Early Education and Nutrition Fiscal Services (EENFS) Fiscal Handbook (DOCX) for detailed examples on how to report commingled versus co-located program data on the Enrollment, Attendance, and Fiscal Report.

    Commingled Program Reporting:

    For instances where a contractor has a commingled classroom and the amount received for non-certified children does not differ greatly from the California State Preschool Program (CSPP) reimbursement rate, the contractor can report the non-certified enrollment in the Non-Certified Enrollment section of the Enrollment, Attendance, and Fiscal Report. Contractors would report all child days of enrollment (cdes) for all CSPP children, and any non-certified children that are in the same classroom at the same time of CSPP certified children.

    When contractors report certified and non-certified days of enrollment, they must report fiscal data for the entire classroom. The contract earnings calculations will prorate costs based on the percentage of certified and non-certified enrollment reported. For instances where a contractor has a commingled classroom, but the amount received for non-certified children greatly differs from the CSPP reimbursement rate, contractors should not consider these children as “non-certified” for reporting purposes. In this instance, contractors will not report the non-certified enrollment on the Enrollment, Attendance, and Fiscal Report and must only report the expenses allocated for the CSPP program.

    Co-located Program Reporting:

    For instances where a contractor has a co-located program, contractors would report the child days of enrollment (cdes) associated with children enrolled in California State Preschool Program (CSPP) only. No non-certified cdes would be reported for children enrolled in other programs.

    For co-located programs, contractors must report each program separately.  In these instances, there are likely shared costs such as rent and utilities and therefore, contractors with co-located programs must have a cost allocation plan to accurately identify the appropriate costs for each program.

    With both commingled and co-located programs, costs of a child and enrollment of a child may not be charged to more than one program.

Questions:   Jenny Tran | jtran@cde.ca.gov | 916-322-8326
Last Reviewed: Thursday, April 17, 2025
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