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California Department of Education
Official Letter
California Department of Education
Official Letter

July 25, 2019

Dear Executive Directors, Child Care and Development Programs:

2019–20 Implementation of Staff Training Days for Center-Based Programs

The purpose of this letter is to provide information regarding new reporting requirements and reimbursement procedures for Fiscal Year (FY) 2019–20 related to two allowable professional development days. These changes are a result of Assembly Bill (AB) 2626 and became effective July 1, 2019. Please share this letter with your agency staff.


Title 5 of the California Code of Regulations (5 CCR) Section 18274 requires each contractor to develop and implement a staff development program that includes staff development opportunities on topics related to functions specified in each employee’s job description and identification of training needs of staff or service providers. Per Education Code (EC) Section 8208(ae), staff training and development activities are included as a supportive services, making these costs reimbursable to the child development program.

AB 2626 added EC Section 8272.1, which allows center-based child care contractors to utilize state funding to schedule up to two professional development days, per contract period, on topics including procedures for emergencies in child development programs, licensing regulations relating to child development programs, recognition and reporting of suspected abuse of children in child development programs, managing challenging behaviors and preventing expulsion of children, and addressing items on the program’s Quality Rating and Improvement System plan. While staff training days have always been a reimbursable expense per EC 8208(ae), AB 2626 allows the California Department of Education (CDE) to reimburse expenses associated with professional development without requiring contractors to meet the service requirement for their contract.

Additional funding was not appropriated for this purpose and contract Maximum Reimbursable Amounts (MRAs) will not be increased. Contractors should determine the cost of providing staff training days and assess whether or not the costs will be reimbursable under the existing MRA. Contractors may also consider revenue received outside the child development contract and child development reserve account funds that may be used for this purpose when reimbursement is limited by the MRA.

Determining Staff Costs 

The determination of reported staff costs associated with trainings can be calculated in various ways. Contractors must first determine which staff will be affected, and how best to calculate salaries and benefits based on their salary structure. In the example below, a daily salary and benefit cost of each employee participating in the training is being calculated by multiplying the daily salary and benefits cost by the number of training days each employee attended.

Determination of Staff Cost Example

Title Number of Staff Attending Weekly Salary + Benefits Daily Salary + Benefits (Weekly Total) Number of Days of Training Total

Program Director

Assistant Director
Administrative Secretary
Chief Financial Officer
Teacher's Aid

Total Salary + Benefits Cost = $3,720

Reimbursable costs related to the two staff training days may include travel and per diem expenses, consultant fees, and training materials. 5 CCR Section 18033 states that contractors will be reimbursed for actual costs that are reasonable and necessary to the performance of the contract. “Reasonable and necessary costs,” is defined by 5 CCR Section 18013(s) as expenditures that, in nature and amount, do not exceed what an ordinarily prudent person would incur in the conduct of a competitive business. Contractors may refer to the Funding Terms and Conditions of their contract for further detail on reimbursable and non-reimbursable costs.

Further information regarding the reimbursable expenses related to staff training can be found in Management Bulletin 19-05.

Reporting Staff Training Days Service Level Exemption

Contractors taking advantage of these optional staff training days will report all reimbursable costs, including those associated with up to two staff training days, in expense categories 1000 through 5000 on the CDNFS 8501 or CDNFS 9500 report form. There is no change to how reimbursable costs are to be reported in these categories. However, the FY 2019–20 CDNFS attendance and fiscal reports will be revised and contractors will be instructed to identify the amount to which the total expenses reported within categories 1000 through 5000 are associated with staff training expenses approved per EC 8272.1. A separate line will be included in the FY 2019–20 CDNFS report forms specifically for this purpose. The revised FY 2019–20 CDNFS report forms will allow the CDE to collect the necessary data to reimburse these expenditures and adjust the contract earnings accordingly.

Contractors will continue to exclude staff training days from their program calendar if no services to certified children are provided on staff training days. If contractors choose to provide services to certified children on staff training days by hiring substitute teachers, those days would be considered days of operation and should be included on the program calendar submitted to CDE. A contract’s Minimum Days of Operation (MDO) is used to project contractor earnings throughout the fiscal year. Reducing a contract’s MDO will not impact the child days of enrollment required to fully earn the contract.

As with all program expenses, contractors are required to have supporting documentation for all expenses reported on CDNFS 8501 and CDNFS 9500 report forms readily available for CDE review. This may include:

  • Invoices for training and travel
  • Determination of staff costs for attending training (wages, benefits, and travel expenses)

Reimbursement for Staff Training Days

Beginning July 1, 2019, expenses incurred for up to two staff training days will be reimbursed as a service-level exemption. Service-level exemptions exempt the identified expenses from the service requirement (i.e. certified child days of enrollment). Per 5 CCR Section 18054, a contractor’s reimbursement is limited to the lesser of the following:

  1. The contract’s MRA;
  2. The net reimbursable program costs for subsidized children; or
  3. The child days of enrollment earnings adjusted for attendance (known as service earnings)

Service-level exemptions increase contract earnings by adjusting two of the three limits of reimbursement: net reimbursable costs and service earnings. This adjusted limit allows the contractor to be reimbursed for expenses that may not have otherwise been reimbursed due to the limits of reimbursement rules.

Example: A contractor has the following limits of reimbursement.

  1. The contract MRA of $500,000.
  2. Net Reimbursable Costs of $500,000
  3. Actual Service Earnings of $475,000

Additionally, the contractor has identified $25,000 in expenses related to staff training.

In this example, without the approved staff training expenses of $25,000, the contract would be reimbursed $475,000 (the lesser of Net Reimbursable Costs, Adjusted Service Earnings, and the contract MRA). By reporting $25,000 in staff training expenses, the total reimbursement will be $500,000.

A service-level exemption provides flexibility for agencies to determine when to provide staff training to best suit their schedules and families’ needs. For some agencies, closing their program for two full days is most beneficial. For other agencies, keeping the program open by hiring teacher aides is most beneficial, while for others incrementing the two staff training days throughout the year is most beneficial for their program and families. 

If you have any questions regarding this letter, please contact your assigned fiscal analyst. The CDE Fiscal Apportionment Analyst Directory web page can be found at



Andrea Johnson, Staff Services Manager III

Child Development and Nutrition Fiscal Services

Fiscal and Administrative Services Division

ACJ: lm

Last Reviewed: Friday, July 26, 2019

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