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Management Bulletin 13-01

Early Education and Support Division

Subject: Implementation of TrustLine Regulations

Number: 13-01

Date: January 15, 2013

Expires: Until Rescinded

Authority: California Education Code, Section 8261; California Health and Safety Code, Section 1596.66; California Code of Regulations, Title 5, sections 18078 18224.6, 18227, 18227.1, 18409, 18411, 18424 and 18426

Attention: Executive Officers and Program Directors of all Alternative Payment, CalWORKs Stage 2 and Stage 3, and Resource and Referral Contractors


The purpose of this Management Bulletin (MB) is to inform Alternative Payment, CalWORKs Stage 2 and 3, and Resource and Referral (R&R) contractors of the implementation of new TrustLine regulations and to provide instructions for providing parents and providers with information on the new requirements.


California Health and Safety Code (HSC), Section 1596.66 requires child care providers who are exempt from licensure and not the child’s grandparent, aunt, or uncle by marriage, blood, or court decree, to be TrustLine registered in order to be eligible to receive a child care subsidy payment.

On December 24, 2012, the Office of Administrative Law approved TrustLine regulations submitted by the California Department of Education. These regulations become effective January 23, 2013.

Regulatory Requirements

The new regulations require that in order to receive a subsidy from an Early Education and Support Division (EESD) contractor, a license-exempt child care provider who is not the grandparent, aunt, or uncle of the child must be TrustLine registered. Providers who are required to be TrustLine registered and who are not, cannot be reimbursed for services.

In situations where there is an “immediate need,” the regulations allow the parent to select a “provisional child care provider.” However, the provisional child care provider must first complete a TrustLine application and submit fingerprints and then be TrustLine registered within 30 days in order to be eligible for reimbursement.

The regulations clarify when a license exempt provider is ineligible for reimbursement as well as when a contractor should discontinue payment to a previously eligible provider.  Additionally, these regulations require contractors to notify parents and providers when payment has been denied or terminated, as applicable, and also to refer parents to the R&R for assistance in finding a new provider; to document the action taken; and to retain the documentation.

Please see Attachment A: TrustLine Regulatory Sections at for specific regulations.


Effective immediately, contractors must:

  • Inform license exempt providers of the new regulatory requirements. In accordance with the California Code of Regulations, Title 5, Section 18227 (c), to be eligible for reimbursement, an individual exempt from licensure must be:

    • An aunt, uncle, or grandparent of the child receiving services;

    • A registered TrustLine provider; or

    • A provisional child care provider who becomes TrustLine registered within 30 days.

  • Inform license exempt providers who are providing care prior to January 23, 2013, that unless they are a grandparent, aunt, or uncle, they will have 30 days from that day (January 23) to be TrustLine registered in order to receive payment. Contractors should refer providers to the R&R for information on how to become TrustLine registered.
  • Inform parents who are using license exempt providers of the new TrustLine requirements and limitations. Contractors should refer parents to the local R&R Network to find an eligible provider.

  • Update parent and provider handbooks to reflect the new regulatory requirements.

Sample Letter to Providers

Sample Notice of Action to Parents

MB 13-01 Frequently Asked Questions

Questions regarding the information in this MB should be addressed to your EESD Field Services Consultant at or by phone at 916-322-6233.

This Management Bulletin is mandatory only to the extent that it cites a specific statutory and/or regulatory requirement. Any portion of this Management Bulletin that is not supported by a specific statutory and/or regulatory requirement is not prescriptive pursuant to California Education Code Section 33308.5.

Questions:   Early Education and Support Division | 916-322-6233
Last Reviewed: Thursday, July 27, 2023
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