Management Bulletin 14-04 FAQs

Answers to Questions relating to Management Bulletin (MB) 14-04 on Monthly Attendance Record or Invoice Requirements for Reimbursing Child Care Providers Authorized to Provide Subsidized Services through an AP or a California Work Opportunity and Responsibility for Kids (CalWORKs) Program

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1. Are Alternative Payment contractors required to have the parent sign the child in and out on a daily basis for reimbursement purposes?
   
   No, only the times of arrival and departure must be documented on a daily basis. The signatures of both the parent/guardian and provider are required at the end of each month, attesting under penalty of perjury, that the information provided on the attendance record or invoice is accurate. However, Community Care Licensing may have additional requirements for licensed centers.
   
   
2. Does the department have a definition for "broadly consistent" or an example of what it means?
   
   Legislation did not define the term “broadly consistent”; contractors should define and set their own policies on what broadly consistent means to them.
   
   
3. Do we compare the provider’s bill/invoice to the Regional Market Rate ceiling and pay the lesser of the two?
   
   Yes, the process of determining reimbursement remains the same. The contractors must reimburse the provider based on the reimbursement ceiling selected (as noted on the Child Care Certificate or Notice of Action) or the provider’s bill/invoice amount, whichever is less.
   
   
4. Can a contractor adjust the reimbursement to a provider when the provider exceeds the 10 non-operational days?
   
   Yes. The California Code of Regulations, Title 5, Section 18076.2(b)(2) limits reimbursements to providers to 10 non-operational days per child per fiscal year. Contractors should set policies on how providers will report non-operational days and how they will track these days. (For example, the agency could set a policy to denote non-operational days on the attendance record. The agency can track non-operational days when the provider exceeds 10 non-operational days; the agency will prorate to account for the additional non-operational days.)
   
   
5. If the invoice does not have all required elements can contractors withhold reimbursement?
   
   Monthly Attendance Record/Invoice must contain the following:
   
   
   • The name of the child receiving services;
   • The specific date services were provided;
   • The actual times the child entered and the time the child departed care for each day services were provided; and
   • Signatures of both the provider and the parent at the end of each month, attesting under penalty of perjury, that the information provided on the attendance record or invoice is accurate.
     
     
   Contractors must set and implement policies outlining the consequences for parents and/or providers who submit incomplete attendance records or invoices. Consequences may include, but are not limited to withholding payment; terminating the business relationship with the provider, or terminating services to the family for continual violation of written policies.
   
   
6. The Management Bulletin states contractors should immediately contact the parent when there are inconsistencies with the services specified in the certificate. Does this mean this is a requirement or does it mean the contractor is to follow its written policies?
   
   Each contractor must set and implement policies that detail the consequences for not providing all required elements on the Monthly Attendance Records/Invoice or when the child’s attendance does not meet the contractor’s definition of broadly consistent. The contractor should follow their own agency policy.
   
   
7. Who is responsible for recording the daily time of arrival and departure of each child receiving services?
   
   The law does not specify that a particular person must record the daily time of arrival and departure of a child receiving services, but does require that the recording be done on a daily basis and that the parent and provider testify under penalty of perjury when they sign the attendance record as to the accuracy of the information in the record. Thus, both the parent and provider should have personal knowledge of the daily arrival and departure times of the child when they sign the attendance record.
     
8. Will contractors be responsible for “tracking” absences/attendance to ensure alignment with statutes and regulations? (Days in the best interest of the child, absence due to illness, quarantine, family emergency and unexcused absences).
   
   No. However, contractors are responsible for ensuring that usage is consistent with the certified need as documented on the Child Care Certificate or Notice of Action to include days and/or hours of care.
   
   
9. Is there a CDE approved monthly attendance record form that must be used and submitted to the contractors for reimbursement?
   
   The CDE does not have a standard form. The Monthly Attendance Record/Invoice must have a place in which the following information can be documented:
   
   
   • The name of the child receiving services;
   • The specific date services were provided;
   • The actual times the child entered and the time the child departed care for each day services were provided; and
   • Signatures of both the provider and the parent/guardian at the end of each month, attesting under penalty of perjury, that the information provided on the attendance record or invoice is accurate.
     
     
10. Are we required to create new monthly attendance records?
    
    No. So long as the above information is included in the attendance records.
    
    
11. Are agencies required to have updated policies to reflect these changes?
    
    AB 274 was effective July 1, 2014. Agencies must immediately update their policies to conform to these new requirements if they have not done so already.
    
    
12. Does AB 274 apply to Family Child Care Home Education Networks that operate through a Curriculum Framework and Evaluation Criteria Committee (CFCC) contract type?
    
    No, AB 274 does not apply to CFCC or General Child Care and Development (CCTR) contract types.
    
    
13. Will AB 274 also apply to Stage 1 CalWORKs or only Stage 2 and Stage 3 CalWORKs?
    
    It only applies to CalWORKs Stage 2 and 3 as these are the two programs administered by the CDE.
    
    
14. Under section "Review of Attendance Record or Invoice" of MB 14-04 it states that "ELCD, strongly recommends contractors communicate to the provider, in writing; any changes to the parent's approved level of services which may affect reimbursement to the provider," would it be possible for the CDE to require contractors to communicate to the provider, in writing (in a timely manner), rather than recommend? We think this can prevent future payment issues.
    
    AB 274 did not include such a requirement; therefore, it is a recommendation as well as a prudent business practice.
    
    
15. Does the CDE require Alternative Payment agencies to submit a copy of their Provider Handbooks for revision?
    
    The Field Services Office Consultants and Alternative Payment Monitoring Unit review handbooks during scheduled reviews. Contractors are required to update and provide written information and materials to parents and providers. It is their responsibility to ensure that written information reflects current requirements as well as reasonable agency policies. There is no requirement for contractors to submit revised information and materials to the CDE for approval.

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