Corey Khan: Good morning, everyone. We're going to wait just a few minutes. I see the participant count creeping up every second so we're going to let more participants join before we get started today.
Okay, good morning, everyone. Again, my name is Corey Khan. I'm the manager over the Early Education and Nutrition Fiscal Services unit. Us, our unit, along with our education– Early Education Division and Audits Division is presenting this training and so this is day two of our California State Preschool Program Fiscal Training. So again, I don't know how many of you joined yesterday, but yesterday was day one, today is day two. This is a– you know we had done these in person, and this is our first time doing a webinar of this magnitude for– to get the you know, the training out to the rest of the field who couldn't make it to the in-person training. So, this is day two.
I'm going to like I did yesterday, I’m going to start by going over the agenda on what we plan to do and how we plan to handle today. So, the agenda today, again, planning to go from 9 to 12. We're going to first open up with some policy updates and so that is a lot of the change– some of the changes that have come through, whether it be last year or this year. We have a representative, Virginia Early, who will discuss some of the policy updates affecting the school year 2023-24 and then we'll go into contents and organization of a family file and that will be presented by Crystal Devlin again. Sort of laying again the foundation on what you have to have in your family file and how that– you won't see it now, but it's going to relate to how you do report to our unit. That is– those two presentations are expected to go until about 11. What we plan on doing just you know, lessons learned from yesterday, we know that we did go over about a half hour. What we are going to try to do today is not take live questions and answer after every presentation. We're going to hold the live questions until after Crystal's presentation so we will go over the policy updates and then family file contents first. We will then take live questions that you can ask live, and we are encouraging contractors to also use the Q&A function throughout either presentation to ensure that, you know, you are asking your questions and we're not just not answering them. So that– those two presentations and a Q&A, hoping that we will be done by 11. At that point in time, we have a third presentation that will close out today and it's an audit presentation. It's the audit requirements for CSPP contractors. That presentation is expected to begin at 11. Again, these are sort of estimated times, but this presentation is only specific to non-LEA contractors. So, all the private agencies, cbos, in the– in the webinar. So, anyone who is from a school district LEA, county office of ED, let's see, community college district, that presentation will not apply to you. We will remind you all that the next presentation when we get there, you can hop off if you are part of an LEA or community college district and then day three, we will start again at nine. Day three is very, very heavy on fiscal reporting. It sort of brings together everything that we've touched on over the last two days and then we'll get into the nitty gritty on how you report, how it– all that data feeds into your report, and how ultimately it feeds into your reimbursement. So, day three will be for everyone, whether you're an LEA, community college or private agency. So, that's sort of how today we'll go. Again, questions will be after Crystal's presentation, live questions and then encourage you all to use the Q&A again. So, I'm going to turn it over– just to start it all off and kick it off. I'm going to turn it over to Virginia to begin her policy updates.
Virginia Early: Perfect thanks so much, Corey and nice to be with you all today. Incredible how many people are on this line, especially as I know we've told many of you to sort of group together.
So today we'll be giving– I'll be giving some policy updates and just quickly a couple topics that that are in this deck. Of course, if there other updates– questions you have, we will be taking Q&A and you can ask that at the appropriate time, but just in terms of what this presentation covers, we will be covering the hold harmless, dual language learners, early child and mental health consultation services, family fees, and children with disabilities set-aside requirements. So, next slide.
All right, so hold harmless. So, hold harmless has been extended from July 1, 2023, to June 30, 2025, inclusive, if the program is open and operating in accordance with their approved program calendar and remains open and offering services throughout the program year. Now you may have originally heard that the hold homeless was only in effect until September 30, but I do want to point out that in September the Governor signed legislation that would extend it from that September 30 timeline all the way to June 30, 2025. What this means is that reimbursement shall be a hundred percent of the contract's maximum reimbursable amount or net reimbursable program costs, whatever is less. And later, in the later presentation, EENFS will be going over how this is different from normal years and how your contract earnings for your CSPP contracts are determined under the hold harmless policy. Next slide.
Alright, dual language learners. So many of you may already be familiar with this. I hope you are but just to just to sort of provide a quick overview, state preschool contractors are required to use what we call the Family Language Instrument, and the directives are in Management Bulletin 23-03. So, identify dual language learners that are in the California State Preschool Program and also required to report child and program data to the CDE and that's through the preschool language– Oh, my gosh! I'm forgetting what PLIS stands for. I can't– we came up with this acronym, but through the through the PLIS system. For children that are duly enrolled in the California State Preschool for Extended Learning and Care and for children that are enrolled in state preschool for the Extended Learning Care portion of their day and TK and kindergarten, contractors can do a couple of things. They can either conduct the Family Language Instrument to determine DLL status or they can use the child designation as an English learner through the state assessment for English language proficiency and that's what's used in the K-12 system. And the Management Bulletin 23-03 goes into more details on these two options, but essentially have to do one or the other. We have also noted that contractors then use it– once you identify a child as a DLL, then you– anyone that's identified as a DLL, contractors have to have a conversation with that family that we call the Family Language and Interest Interview and that's also included in the Management Bulletin 23-03 and it's the Preschool Language Information System. I'm so embarrassed that I forgot that I. So, our contractors have to collect and report data through that PLIS system and this includes dual language learner status for children, language characteristics of preschool programs and language composition of program staff. And so, this is what you're using to determine now whether the child is getting the DLL adjustment factor. So, it's this process that sets that adjustment factor. All right and I will also say there are a bunch of like intricacies about this and different situations that pop up and we have some FAQs about what to do if you think that the family has filled out the Family Language Instrument wrong. There's a process by which if you have a talk with a family and they say they filled it out right, but you hear the child speaking in another language, there's a process through which the teacher can say, yes I've observed and documented that this child is a dual language learner, so more on that in our Management Bulletins, FAQs. Next slide.
So early childhood mental health consultation services with an extremely long acronym, ECMHCS. So basically, what– what this is, is support for providers, parents, legal guardians, and caregivers to create trauma-informed, proactive inclusive environments that respond effectively to all children. And so, this can be done in a number of ways. It can be done through assistance through individual site consultations, provision of resources, formulations of training plans, referrals, it can look like aid to providers, parents or legal guardians and caregivers, encouragement and facilitation of collaboration and communication. It can include development of strategies for addressing prevalent child mental health concerns. If there's a child that's exhibiting persistent and serious behaviors, it can include support with the pursuit and documentation of reasonable steps to maintain the child’s safe participation in the program. It can include face-to-face interactions or video-based platforms or other modes of communication like the phone and then group or individual consultations of anything that– well it says on the slide described in this paragraph, really what this is, it's copied and pasted from statute. So really anything sort of on this bulletin list. So, that's what early childhood mental consultation includes. So next slide.
There is an adjustment factor for early child and mental health consultation services that applies to any child that's in a classroom that's benefiting from the services. So common misconception of this adjustment factor is that it's just for kids that have challenging behaviors whereas if that kid is in a classroom where there other children that don't have behaviors that challenge adults, but there's a couple of children that do have behaviors that challenge adults then and the consultant is working with the entire classroom, all of the children in that classroom would be eligible for that adjustment factor. So, there are five things that determine whether costs are reimbursable, and you can see them on the slide. First of all, services have to be provided on a schedule of sufficient and consistent frequency throughout the program year and I should also note that some of the things on this list are brand new requirements. The policy office is working on an updated Management Bulletin about early childhood mental health consultation services so until we get that out I urge you to consult Education Code 8243 because it's pretty specific about what the requirements are for early childhood mental health consultation in the meantime and in fact what our draft Management Bulletin is really going to do is look, sort of pull a lot of those pieces over statue into a Management Bulletin form and we're hoping to get that one out pretty soon, but in the meantime go look at Education Code Section 8243. So that code section specifies who can provide early childhood mental health consultation. There are a couple of differences– there are a couple of differences that started very recently that will be in this updated Management Bulletin and that are in 8243 now– where now there can be folks that are license eligible or have related master's degrees if they are supervised by someone that's sort of fully qualified and all the specifics of what meets that and what doesn't are in that Education Code Section 8243. There's also requirement that the early childhood mental health consultation service uses a relationship-based model emphasizing and strengthening relationships among early childhood education, providers, parents, children and representatives of community systems and resources, and that also integrates reflective practice into the onsite consultation model. And the model has to include three things so– but also can include things beyond that. So at least twice a year that has to conduct an early care and education setting based mental health assessments. And one example of this is the climate of healthy interactions for learning and development, or the child assessment or another appropriate instrument. There has to be record keeping that adequately documents all consultation activities and if you're trying to frantically grab notes on this, this is just all in Education Code 8243 so you can go to that statute and find everything that I'm telling you here. There has to be record keeping that adequately demonstrate– oh my gosh! Adequately documents all consultation activities and then also with consent of parents and guardians there has to be at least one screening of each enrolled child for adverse childhood experiences and screening for buffering factors such as resilience. So those are a couple of things there. As soon as you know, within the first 30 days upon hire or start of a consultation service, the agency that is sort of hiring them or starting the consultation has to ensure that a consultant has some specific required training. There are four specific training categories, one on California law and professional ethics for early childhood mental health consultation, child abuse and neglect, mandated reporting laws, best practices and foundations of early childhood mental health consultation and then all relevant laws and regulations regarding state and federal child care programs. Again, you're trying to frantically take notes on that, it's all in 8243. You can sort of print that out and take a deep look at it. And then finally, consultants and supervisors for early childhood and mental health consultation have to participate in continuing professional development and education for at least 18 hours per program year and topics can include, but aren't limited to things like infant family and early childhood mental health, implicit bias and equity, common form practice, early childhood development and consultation.
So, family fees. Family fees are waived from July 1, 2023, through September 30, 2023 and beginning October 1 of this year, family fee schedule for CSPP is changed. So family fees are now limited to 1 percent of a family's monthly income. Families with incomes below 75 percent of the state median income no longer have to pay a fee and there's a provision for giving state preschool family debt accrued but that are uncollected prior to October 1, 2023. So that's a little bit on that, and I'm going to hand it over to Joey to go a little bit deeper into reporting family fees and the family fee allocation.
Joey Boyd: Thank you, Virginia. As mentioned, my name is Joey Boyd. I'm also a fiscal analyst with the Early Education Nutrition Fiscal Services unit and just wanted this morning to give a brief overview on the upcoming family fee allocations and reporting this year. So, starting off AB 110 provides additional funding authority to ensure contractors have sufficient funds to cover the cost of family fee waivers between July 1, 2023, and September 30, 2023. CSPP contractors will receive an allocation to cover the cost of the family fee waivers. These allocations for the family fee waivers will be included as part– as the Budget Act amendment and that's expected to be released later this fall. The Early Education and Nutrition Fiscal Services unit will also be utilizing family fee waiver data submitted in the fiscal 2023-24 first quarter Enrollment, Attendance and Fiscal reports as the basis for this allocation. The CPARIS Enrollment Attendance and Fiscal reports have been updated to include lines to report family fee waivers waived July 1, 2023, through September 30, 2023, and family fees collected October 1, 2023, through the remainder of the fiscal year, June 30, 2024. Contractors will report the amount of family fees waived between July 1, 2023, and September 2023, and the amount of family fees collected between October 1, 2023, and June 30, 2024, on the applicable lines on the Enrollment, Attendance and Fiscal reports that you're submitting to us in CPARIS. And then lastly, AB 102 provides additional funds in fiscal year 2023-24 to support lost revenue due to the family fee changes effective October 1, 2023. More information about this allocation is going to be forthcoming and provided in the EENFS contract changes letter that we'll be sending out later. I'm going to throw back one more slide for Virginia to talk about policy changes on the set-aside.
Virginia Early: Perfect, thanks so much. So, now we're going to talk about the funded enrollment set aside for children with disabilities. So, the previous timeline for the set aside for serving children with disabilities was originally– that we're supposed to have seven and a half percent of funded enrollment reserve for children with disabilities this year. And as a reminder, we use the words children with disabilities and exceptional children with exceptional needs interchangeably. Children with exceptional needs is what's sort of in statute, but we know that most people when they talk, they talk about children with disabilities, so we sort of say that interchangeably. So that timeline has changed, and you can see the new dates on the slide. So, July 1, 2025, would be when the increase to seven and a half percent of funded enrollment reserve for children with disabilities or exceptional needs would take place. And then July 1, 2026, for increasing to at least 10 percent of funded enrollment reserved for children with exceptional needs or disabilities. And just note on this that we, even though there's more time to get to seven and a half now and there's more time for programs to build that capacity, we really want to encourage you to continue working toward the seven and a half percent requirement during the extension. And I will turn it back to Joey.
Joey Boyd: Thank you. Okay, so lastly, we'll be covering a brief overview on the set-aside reporting in CPARIS. CSPP contractors will report certified children with Exceptional Needs or Severely Disabled in the appropriate time-based category on the Enrollment, Attendance and Fiscal reports submitted in CPARIS. The CDE is going to be using this reported data to determine if the set-aside is being met. The CDE has updated the CPARIS calculation worksheet to show the set-aside requirements. CSPP contractors will also be able to determine if they are projected to meet the set-aside after each submitted Enrollment, Attendance and Fiscal report. We'll kind of do– we will be doing more of a deep dive of this and more visuals in tomorrow's presentations. CDE is also providing CSPP contractors with a tool to assist in determining the number of children funded to serve by service county as well as the number of children required to meet the set-aside to serve children with exceptional needs in children with severe disabilities. The funded enrollment calculator can be found at https://www.cde.ca.gov/fg/aa/cd/. We will not– we will not be reviewing an example of the fund enrollment calculator during this training as each agency has its own specific criteria, but we're encouraging contractors to reach out to their fiscal analyst if they have any questions on how to calculate the number of children associated with the set-aside requirement. And then, lastly, funded enrollment is defined in ED Code 8205(ae) as the number of subsidized children funded to be enrolled, based on the maximum reimbursable amount, the contract rate, inclusive of any adjustment factors, an approved program calendar by a CSPP contractor. Contractors can calculate the funded enrollment by dividing the MRA by the service county full-day rate adjusted by the average adjustment factor and dividing by the minimum days of operation. And I will hand it back to Corey or the moderator.
Corey Khan: Is that me or Virginia? I think it's Virginia.
Joey Boyd: Oh sorry, Virginia.
Corey Khan: Oh, no questions. Sorry.
Virginia Early: I think it's not–
Corey Khan: Sorry, okay so as I said before, we're going to hold questions, keep coming in through the chat. There's some good ones or not chat the Q&A function. There's some good ones coming in. We will go over live questions at the end of this presentation, and it looks like we're like super ahead of schedule in terms of timing so we're going to have a lot of time, I think, to go through live questions. So, Crystal, I'm going to invite you up to go over the contents of a family file and then we'll go over our Q&A.
Crystal Devlin: Alright, thank you, Corey. Good morning, everybody. Thanks for joining us again and for those of you who were not here with us yesterday, my name is Crystal Devlin. I'm an Education Administrator in the Early Education Division Program Quality Implementation office and we're going to talk about the contents, the organization and reconciliation of the California State Preschool Program family data file.
So, let's first look at the contents of the family data file. What do you have to have in that family data file?
So first, you need to have that application for services. That application must be complete, and it needs to include the parent's signature and the date that the parent signed, as well as the authorized agency representative signature along with the date that it was signed, and also noting that if the parent self certifies as a single parent they need to– and so that means there's only one parent included on the application for services, they need to check that little box at the top of the first page of the application for services indicating that they’re a single parent and then on the back side of the application for services, I believe in section five, they need to initial certifying that they are a single parent. Exciting. Then we also need to see that Notice of Action, that Notice of Action needs to be thoroughly completed. It's either for approval or denial of CSPP services, any changes to services or termination of services, and keeping in mind with those changes to services the parent must request any changes to services within their 24-month eligibility period and that needs to be in writing. So, if we see a Notice of Action in the file where there's a change to services, we also want to see that written documentation from the parent requesting those changes, and then if you're– there's a termination of services, we need to make sure that you are also abiding by the new suspension and expulsion requirements. We want to see that the Notice of Action has been issued within 30 days of the parents signing the application for services and then we want to see the appropriate appeal information, including that appeal date and how to request a hearing. And so, noting that the appeal due date is either 14 days from the date you hand the delivery the Notice of Action to the parent, or 19 days if you mail it. So, you're giving them those five days for mailing time, and then how to request a hearing. In most instances you're going to include the hearing information at the local level, right? So, you're going to have your hearing officer listed on the back side of that Notice of Action, their contact information, etc. If it's a suspension or expulsion Notice of Action, you're going to include appeal information directly to the Department of Education rather than at the local level. And then also keeping in mind at the local level appeals, that the hearing officer needs to be somebody different than the person that issued the Notice of Action, and that person needs to be at least one level higher in authority than the person that issued the Notice of Action. Next slide, please.
So, this is a just a screenshot of the Notice of Action and you probably can't see my cursor, but just noting that everything is complete, right? You need to thoroughly complete the application first or the Notice of Action so if the services are being approved, when do they begin? If they're denied, when is the appeal due by and then that section one B for recipient of services, is it a change in service? Is it a termination of service? Is it a termination of service for delinquent fees? You want to note on in Section 2 that the notice was given to the parent caretaker. This is when you hand it to them directly, and so you want the parent to initial there and then if the notice is mailed, how was it mailed and the date it was given or mailed. And then you're going to complete all the parent caretaker information in section 3 and section 4, those approved services, the days, and hours of service for the child that the family is approved for. In section 5, what is the basis for the family eligibility for services and then for our full-day state preschool section 6, what is their basis for need? I will say that we are in the process of updating the Notice of Action and the application for services. So, if there's– these are fairly dated so if there's something missing here, and we have like new needs for services or no need requirements, you can just write that into that section until we have the updated versions available for you. Then in section 7 you're going to give specific reasons for any action that you're taking. The approval for services, if the services are denied, what's the change in service? What's the reason for the termination of services? And then oh, hold one second, I can't see my screen really well. bottom part of that, for some reason, is slightly too large. Bear with me, please. It's not going to work. Okay, so then, going to the second page of the Notice of Action that first section there is for the parent to write their appeal, right? Why are they appealing? Why do they disagree with any action that the contractor is taking? The section or step 2 area there is where you need to include the information, your agency name, your agency address, city, state and zip code and the name of the agency contact. So, you need a person listed here. Quite frequently we will just see the name of the– of the agency. Again, you need an actual person and a phone number that they can be contacted at and then the rest of that gives them more information about their appeal rights. Next slide, please.
Ok, next, we need to see in the family data file the documentation of family size. So, we want to see records of birth for all children included in the family size, which is typically a birth certificate. However, if the parent does not have a copy of the child's birth certificate, any documentation that shows the relationship of the child to the parent can be accepted. And you need to verify, right? Look at that and make sure that it clearly indicates the relationship of the child to that parent. And then also, as I spoke about a little bit ago, the self-certification as a single parent, if applicable, because of course the parents are included in the family size, if they are the actual parent or adoptive parent, but if it's a single parent, make sure that box for single parent caretaker in section 1 on the application for services has been checked, and then initial Item 1 in section 5 on the back side of the application for services, which is the certification and signature of parent caretaker of the application for– on the application for services. Next slide, please.
Okay, I really have to fix my screen here, so sorry. There we go, okay. So, we also need to see that documentation of California residency. So acceptable documentation for proof of residency may include any of the following with one or more of the parents’ names on the documentation. So, this only has to be one of the parents if that's what they have available. So, it could be a current utility bill, a current property tax bill, it could be that current rental or lease agreement with the landlord's information, current photo registration, a current letter from a governmental agency, a current employment pay stub, or any documentation that you, as the contractor, reasonably relies upon to prove a family's residency. Next slide.
All right, now we need that documentation of eligibility and so your documentation is based on the category of eligibility. So, families receiving benefits from a governmental program, this could be like their application– the initial application. And then, like a Notice of Action, or some sort of letter from that governmental program. Recipient of child protective services or at risk of neglect, abuse, or exploitation. So, for CPS, you want to have that referral from a social worker, and if they're at risk of neglect, abuse, or exploitation, you need that referral from a legally qualified professional. If they're income eligible, you want their income documentation, which could be pay stubs from the– from any of the four weeks of the two months preceding the certification or recertification. It could also be a self-certification of income, for instance so for part-day CSPP or no need for services requirements, you could have that self-certification of income. Definitely make sure that if the parent has no income, you're getting that self-certification that they have no income, and then self-certifications of income also for children with disabilities. And then another documentation of eligibility or category would be that the family is experiencing homelessness, the child has exceptional needs i.e. a child with disabilities so you want to see that that portion of the IEP that indicates that the IEP is current for the child. And then you have those CSPP neighborhood school eligibility and then, when the income is no more than 15 percent above 100 percent of the state median income, after all, otherwise eligible children have been enrolled. Next slide.
We also need to see that income calculation worksheet in every family data file and this income calculation worksheet is available on the CDE EED webpage. Next slide.
Okay, we also need to see if the family is– if the parent is employed in every family data file, you need to have that authorization to contact the parent's employer. So, you need that release authorization to contact the employer, which authorizes you the contractor, to call that employer up or mail something to that employer, to verify the parents’ income and days and hours of employment as needed. So, always have to have that release authorization and this is for employed and or self-employed parents. And then, when the parents’ income documentation doesn’t include the parents’ days or and hours of employment, then you need to contact the employer to verify the days and hours of employment in order to certify that families need for services. Next slide, please.
Okay, so a documentation of need for full-day state preschool programs and this does not apply if you only provide part-day state preschool program services. Again, this is type– the type of documentation is based on the category of need. So, the child may be a recipient of CPS, or maybe at risk of neglect, abuse, or exploitation, the documentation of the parent's employment or self-employment, documentation of seeking employment, which is a written declaration from the parent, that is, you know, gives you an idea of their plan for seeking employment, and when they will be seeking. You know the days and hours that they will be seeking employment. The family is experiencing homelessness, which could be a referral from a shelter, could also be a self-certification. Same with seeking permanent housing. And if they're seeking permanent housing, you want that documentation, a written declaration from the parents of what their plan is to seek permanent housing. There can be the parent enrollment in an educational program or vocational training. The parental incapacitation which you need written documentation from the parents’ physician. And then again, CSPP. neighborhood school eligibility, you need to verify that they're within the boundaries of that school, and you have been approved as an FRP site, or free and reduced-price meal site, and there is no need requirement in this category, after all otherwise eligible children have been enrolled. Next slide, please.
Okay, this one's a little newer for contents of the family data file, it's that identification of dual language learners which Virginia spoke about in her presentation. So, we always need to see in that family data file for every child, you need to have completed that Family Language Instrument and this is completed at the time of enrollment. And then, if that child has been identified as a dual language learner, we also want to see that Family Language and Interest interview has been completed and the documentation is in the family data file. So again, that's conducted for all children identified as dual language learners and this needs to be conducted by the child's teacher or other designated staff in collaboration with the child's family. So, we don't want to see that you have just you know, given this document to the parents and have them fill it out. This is really to be completed in collaboration, preferably by the child's teacher because they– the teacher is the one that has developed the relationship with the child in the family, but you may have another designated staff if that's not possible. And you can learn more about the identification of dual language learners in Management Bulletin 23-03, which is accessible at https://www.cde.ca.gov/sp/cd/ci/mb2303.asp. And then we need to see documentation for health and social services, so this is part of your program quality requirements, and you need to be identifying the child and family's health and social service needs. And this, quite frequently what we see, and it is useful for all three of these components, the identification, the referrals and follow up, we’ll see a form and the form has, like, you know, a variety of things where you're asking the family if they have health and social service needs and they need like referrals for you know, food or health, care, or housing, or you know, a variety of things, and then, you know, the parents can check him off, and you might also include other, right? Where the parent might identify something else that's not on that form. I want to kind of stress here the identification of the child and families’ health and social service needs, this is typically done at intake, right or enrollment, and families have not yet really established a relationship with you, and so they may not be comfortable telling you that they have health and social service needs and that those have not been met. And so, I recommend that you also have like a family resource center or something to that effect where you put this document, and parents as they start to establish those relationships with either your intake staff or your enrollment staff or their teacher. They might come to you later with some identification of their health and social service needs. So, just making that available on an ongoing basis so that they can do that when they feel ready to and then, if on that form you have identified that there is a health and social service need, we want to see that you've made a referral to any of the community resources based on those identified health and social service needs. Excuse me and it– oh, go back, please. Thank you. And so, after that referral, you know, give it a little bit of time, you know, a couple weeks, depending on what the referral is specifically for. It might be a little bit longer, but follow up with that family and document it, that you followed up with them to ensure that their health and social service needs have been met and if those needs have not been met possibly, you know, providing another referral. Next slide, please.
Thank you. And then we need to see the Title 22 Health and Safety documentation. So, that's from the Department of Social Services Community Care Licensing division. We need to see that health and safety documentation within the file. So, we want to see that emergency card that is completely filled out. We need to see that the child's immunization– current immunization records are within that file and then the physician’s report that includes the tuberculosis screening. Next slide.
Thank you and now we're going to talk about organization of the family data file, which looks really a lot like what we just went through. Next slide, please.
Okay so and we really want to see, like, when we're coming out for a monitoring review and for your own purposes, when you're, you know, auditing your own files, or you're conducting your program self-evaluation. It's really nice to have your documentation in this order and then make sure that it's like secured within the file. So, for instance, a file with the prongs, or there's pockets or something. There have been times I've gone out on a review, and I've opened up the file and everything just falls out. So, it's really nice to have it nice and organized and tidy. So, the first thing we want to see is that application for services, and that it's completed in its entirety. We want to see the Notice of Action following that application for services and then their documentation of eligibility, including the income calculation work sheet for eligibility based on income. And then that parental authorization to contact the employer for employed and self-employed parents. For our full-day state preschool programs, we then want to see the documentation of that family's need for services. And then we want to see that documentation of family size. So, we need to see those birth records for all children that are included in the family size. Next slide, please.
Sixth, we want to see that documentation of California residency. And then we want to see that Family Language Instrument and then, if applicable, we would want to see that Family Language and Interest interview. We want to see that Title 22 Health and Safety information. And then we want to see that health and social services documentation, the identification referral and follow up as applicable for health and social services. Okay.
All right, reconciliation of the family data file.
So periodically, it's really recommended that you review a random sampling of family data files to ensure that all the required documentation is present, all forms, such as the application for services and Notice of Action have been fully and accurately completed. Now, this is not a you know, a regulation or a requirement, but it's really good to get in the habit of periodically doing that random sampling, just to make sure that you– your staff that are responsible for certification of eligibility and need is applicable– are doing things correctly. And so, it's really a good idea to do this by– to have a staff person complete this that isn't the staff that is responsibility for certification of eligibility and need. And this would usually be the program director, you can have somebody else do that, and we don't want to see it be used as punitive, right? For the staff that are certifying eligibility and need, we'd really like to see the results from the– the review of your family data files, use it to determine training and technical assistance needs. And if you're seeing you're identifying through this process that your eligibility staff need training and technical assistance, I strongly encourage you to reach out to your assigned Program Quality Implementation office regional consultant for some training and technical assistance on you know, completing the certification and making sure all that documentation is present in the file. Okay and we're done. I'll turn it back over to Corey.
Corey Khan: So, I think we're going to take– I know yesterday people wanted a break so we're going to take just a fivemin break and then we'll take a live Q&A at 9:56. So we'll be back, 9:56.
Cate Washington: Welcome back from break everyone. So, we have a few raised hands and by the way since I haven't talked yet today, good morning, everybody. My name is Cate Washington, so I'll be moderating the Q&A portion before our next session. So, I wanted to before I start calling on people just take a look here at the Q&A because we do have a couple of questions that I've seen a few times repeated. So, one of the questions was whether or not the Notice of Action can be emailed. Crystal, is that something that you can answer? I’m going to call on you to hop on and answer that if you would.
Crystal Devlin: Sure. Yes, the Notice of Action can be emailed, but it's strongly recommended that you when you email that you include a– that you want a receipt of delivery and then you also want to do a read receipt, right? So, the parent when they read it, they indicate that they have read the Notice of Action or read that email.
Cate Washington: Perfect and thank you for that. In the same kind of vein of a question for you, Crystal, there's a question here, do you need to mail the Notice of Action with a tracking number, is that required?
Crystal Devlin: Would strongly encourage it. You want to make sure that the family receives it so yes, you should do that.
Cate Washington: Perfect. Alright, I'm just going to– and Crystal you might just want to stay on, cause I'm just going to go down the list of all the questions that we had as you were speaking. So, we had a question about the Notice of Action. Let's see here, it says issued with 30 days of parent sign– of parent signing for application, if the parent asks about the services, do we need to issue Notice of Action and also what should it say on Notice of Action? I'm not sure I understand that question, sorry as I was reading it, do you?
Crystal Devlin: Yes, I do. I read it and I was actually going to ask to speak to this a little bit, anyway. So, Notice of Action is only completed and given to the parent once they have completed an application for services and you're either certifying or denying services, or when there's been a change in services and they're already enrolled, right? So, when a parent comes in to inquire about services, you're not completing that application for services right on the spot because you need to like provide information to the families, let them know what documentation they need to bring to you, you know, kind of do like an intake with them and then once they say, okay, I'm ready to enroll my child in state preschool then you complete the application for services, preferably with the parents. If the parent takes the application for services and completes it on their own, you're going to want to make sure that they've completed everything accurately on that application for services. Then, once the parent has signed that application for services, you, the contractor, or your authorized representative has 30 days to either approve or disapprove the services or the change in services and then you issue that Notice of Action. It doesn't have to be 30 days. It could be a couple of days but within 30 days, so do not issue a Notice of Action if that family has not completed an application for services. Hope that answers your question.
Cate Washington: Thank you. We also had a question here about asking to repeat the mailing versus handing them the Notice of Action that you were talking about. What is the days– the time frames for that?
Crystal Devlin: So, when you, you provide the appeal rights and you're handing that Notice of Action for services to the parent directly giving it to them, you give them 14 days from the date you gave them that Notice of Action to appeal. So, you want to make sure that you include that appeal date is 14 days from the date you gave them. If you mail the Notice of Action to the families, you're giving them five additional days because of the time it takes to mail that you know the mail to be delivered to the parent. So, then you give them 19 days from the date that you mailed the Notice of Action.
Cate Washington: There's the question about when documents are sent electronically, let's say, through like a parent portal. Is there a way to? Or how should they document that on the Notice of Action that that was sent electronically?
Crystal Devlin: That is a really good question. We're seeing, you know, more and more things like this happening. I'll have to take that question back. I don't have a for sure answer for you. So, I would say if you're doing that already make sure you're case noting it. Maybe you know in the comments section on the Notice of the Action that you're documenting that it was delivered electronically.
Cate Washington: Okay, so we have a question here about updated forms, such as self-employment verification, seeking employment plan, employment verification, etc. Are there plans to update those forms?
Crystal Devlin: Yes, we are working on it. The forms approval process is pretty in depth, and we have to make sure anything that we post on our webpage is accessible to folks with disabilities. So, they're being updated. We'll get them up there as soon as we can and thank you all so much for your patience.
Cate Washington: There's a question here as well about how current proof of address needs to be?
Crystal Devlin: So, I would say within that month or two months preceding the certification or recertification and it doesn't have to be you know the specific address, that what we're looking for is that the family resides in the state of California, but it should be, you know, fairly current. I would say, within a month or two of certification or recert.
Cate Washington: Okay, so we had a couple of questions here about aid that families are receiving. So, there's a question if a family is receiving SSI, are they considered a current aid recipient? And also, a separate question, does WIC or Medi-Cal account for families receiving government benefits?
Crystal Devlin: I know that WIC and Medi-cal do. I'm going to ask Virginia or Eddie to speak to SSI because I'm not sure off the top of my head.
Virginia Early: Is the question whether SSI counts as a means tested government program for purposes of– I don't think that's typically called out in the Management Bulletin.
Crystal Devlin: Oh, and I'm actually– I'm rereading this question. I just found it and it says, does that mean they're considered a current aid recipient? So that would be no because that's like CalWORKs. Correct, Virginia?
Virginia Early: Yeah, so there are a couple of ways to– yeah, I mean I think there, yeah, there's the– there's the current aid recipient and there's the means tested government programs and if you're in CalWORKs, you come in under either one. I'm just waiting for the Management Bulletin to load. Maybe we can take another question, come back to this one, does that work? So, no one has to wait.
Cate Washington: Yes, that works. I was going to hop over to the people who have their hands raised and we'll come back to the Q&A. I know we have quite a few questions in there. I'm going to start with Kristen Burkett. I'm going to go ahead and unmute you if you want to ask your question.
Kristin Burkett: Sorry, I didn't realize my hand was raised.
Cate Washington: Oh, okay.
Kristin Burkett: Sorry about that.
Cate Washington: Thank you, no problem. Alright, so I'm going to move on to Jenny Duren, who also has her hands up. I'm going to go ahead and ask you to unmute. You can ask your question.
Jenny Duren: I don't have a question. I pushed that by mistake.
Cate Washington: Okay, well these are easy. Alright, moving on to Susan. Apologize, Talebian? I'm not sure how to say your last name. I'm going to unmute you. Alright–
Susan Talebian: Hi! You gave me the answer. Good morning. You gave me the answer. and you pronounce my last name so correctly, properly. Thank you.
Cate Washington: Thank you. Alright, I'm going to move on to Nelly Duong. I’m going to go ahead and let you unmute.
Nelly Duong: Hi! Good morning.
Cate Washington: Good morning.
Nelly Duong: My question is right now; our agency is using the online for all the documentation. So, our family data file will be online. So, when the– when the audit's going to come, so are we going to printing everything out? And it would not consider a original like 9600, NOA and all the documentation we have to print it from the file– online file. Would that be acceptable? That's the first question. Second question, I just heard that the NOA, if we have it issue online we have to– we have to case note for every Notice of Action that we issue?
Crystal Devlin: I would strongly, yeah, I would strongly encourage that you case note anything that is not, you know, like usual. You should– you should case note it. There is, however, no requirement around that. It just makes it more difficult for us to verify. In terms of electronic family data files, that's acceptable and we can, when we come out for a contract monitoring, review them electronically. Paper is sometimes easier, but we are getting much better about reviewing family data files electronically. We do have our team who does that for our full-day state preschool programs when they're up for contract monitoring review, so you don't have to print them. I think maybe when it gets to the point that you're scheduled for a contract monitoring review, possibly speak to your reviewer or your signed consultant about their preference.
Nelly Duong: Okay, as long we save them in the order of the file order and in the PDF format will be fine, right? Hello?
Crystal Devlin: I'm sorry. I said yes.
Nelly Duong: Okay, thank you. Appreciate it.
Crystal Devlin: You're welcome.
Cate Washington: Okay so I'm going to move on to Girls Club of Los Angeles. You can go ahead and unmute yourself and ask your question.
Girls Club of Los Angeles: Good morning. Can you hear me?
Cate Washington: Yes, we can.
Girls Club of Los Angeles: Okay, thank you. My name is (unintelligible audio) I'm at the Girls Club of Los Angeles. I just have a question regarding the Notice of Action the number one or section 1A. When we do– when we approve services, we usually put the day the services begin, begin, I'm sorry and we also put the 14 days under the appeals due by under deny. Do we need to do that? Or do– or does this apply to services denied?
Crystal Devlin: Parents always have appeal rights. So, for instance, say, it's a family who is enrolling in full-day state preschool program and they disagree with it the approved days and hours of service, or they disagree with the family fee. They always have appeal rights, always have due process rights.
Girls Club of Los Angeles: Okay, so we should continue to write the date in there?
Crystal Devlin: Please.
Girls Club of Los Angeles: Okay, thank you so much.
Crystal Devlin: You’re welcome.
Cate Washington: Alright, I'm going to move on to Lisa Martinez. You can go ahead and unmute yourself and ask your question.
Lisa Martinez: Good morning. I have questions regarding full-day CSPP and documentation in family file. So, when we do go ahead and approve families based on a family indicating that they've just found a job and are income eligible, they've already received that Notice of Action indicating that they have been approved for services and we go to follow up and request additional documentation from the family requesting that they verify their eligibility. However, the family no longer responds to that. What recourse do we have, or do we have any recourses? Or do we just document that we've asked parents for that and they don't return it since there is that 2024 month eligibility?
Crystal Devlin: So, to be clear is you're making sure you do not issue that Notice of Action approving the family's eligibility for services until you have all of that required documentation, okay?
Lisa Martinez: That means we can't start the family even though–
Crystal Devlin: Not until you have all of the required documentation. So, if a family– so, what I hear you saying is that the family, you know, they just started the job and correct me if I'm wrong, they just started the job. They came in, they only had one pay stub.
Lisa Martinez: They have no pay stubs.
Crystal Devlin: They have no pay stubs, and they just started the job. So, this is where it matters that you have that released authorization right, to contact the parents’ employer. And then you're going to contact that employer to verify that parent’s eligibility– you know, their employment, their days and hours of employment, their pay, etc. Okay, so you never want to approve a family for services until you have all of that documentation from them. So that's why you have that 30-day window, right? That 30 days, those from the date the parents signed the application for services within those 30 days they need to provide you all that documentation and if they have not then you issue a Notice of Action denying their eligibility for services, okay?
Lisa Martinez: Meanwhile the child is already enrolled. I guess that's the gray part that I am having a hard time reconciling.
Crystal Devlin: So yeah, so once you've already enrolled the family, they do have that 24-month eligibility and you cannot disenroll them. So, this is like, you know, there was an error on the contractor’s part. I would strongly suggest if that's happened, that you reach out to your assigned PQI office consultant and ask for some technical assistance around that but yes, that you cannot disenroll the child. And I would continue following up with the parent If you have that release authorization which you should, then I recommend going ahead and contacting the parents’ employer just to verify.
Lisa Martinez: Okay, so we do have release authorization. Parents’ employers are now saying that they are no longer employed. So, we just need to contact our consultant to figure next steps?
Crystal Devlin: No, so if the if the employer is saying they're no longer employed, that parent is still within their 24-month eligibility period and there could be no change to their services unless they voluntarily request a change.
Lisa Martinez: Okay.
Crystal Devlin: So yeah, and that would be somewhere like– right? If they're no longer employed, they might want to come to you and say, I want a reduction of my family fee. If there's a fee assessed.
Lisa Martinez: Okay, so I do have a second part of this is along the same lines for full-day CSPP. On the parents’ seeking employment, so they've given us a letter indicating, you know, under penalty of perjury, you know I am currently seeking employment. Their eligibility– their 24 months of eligibility are now up and we contact the family to recertify. And they're now indicating again that they're still seeking. How do we proceed with that? Do we send them a Notice of Action, letting them know that they're no longer eligible? Because if exhausted seeking because in the past that was in the regs that seeking did– could not exceed a certain amount of time. Or do we take that under penalty of perjury letter and recertify them under seeking again?
Crystal Devlin: Yes, you do. They are able to come back and re-certify as seeking eligibility– or seeking employment and it, you know, it quite possibly is true, right? They may very well be seeking employment. They may have gotten employment during that 24-month eligibility, and it could have been temporary employment. It– they could have been laid off. Anything could have happened. So yes, they can re-certify as seeking employment.
Lisa Martinez: Okay, so that could be their sole need is to continue to seek employment?
Crystal Devlin: Correct.
Lisa Martinez: Okay, thank you.
Cate Washington: Alright, I'm going to move on to the next person who has their hand raised. It looks like that is Angelica Alvarez. You can go ahead and unmute yourself and ask your question. Angelica, you're unmuted. Did you have a question? Alright, looks like she might be having technical difficulties. Move on to Sabriya Pedretti. You can go ahead and unmute yourself.
Sabriya Bayati Pedretti, Bellflower USD: Hi, thank you. My question relates back to the mental health consultant piece. Under section the 8243, if you go down below into subsection, lowercase b, item 4 and then it's– there's a comment that says after 30 days of the consultant starting, that they have to meet these requirements of training with California law and professional ethics, contemporary professional ethics, therapeutical clinical practices. Where are those trainings listed like, how do we know what complies with that to make sure that the consultant we hire meets those?
Crystal Devlin: Virginia? Thank you.
Virginia Early: You're talking– you're sort of saying, looking at the Education Code there are certain things about that. I think, what I would say– so we're still working on the Management Bulletin like I said so I think that's helpful, helpful question for us to hear as we work on finalizing that. I think really, really like sitting with Education Code 8243 and I'll paste in the chat specific things that are required as part of that. So, you know, really like kind of looking at this list yourself and seeing you know, does the training and it maybe the consultant is already trained in these things, and they don't need to have additional training.
Sabriya Bayati Pedretti, Bellflower USD: Yeah, that’s what I was wondering. Yeah, because first 30 days upon hire, provider ensures that the consultant is trained so they would be the ones to tell us which training might apply to each of these subsections.
Virginia Early: Yeah, I mean, I and I think obviously you'll want to take a look at it yourself. I mean, if they're trying to say something that seems like really tangential applies, you'll want to sort of say, does that pass the sniff test from my perspective?
Sabriya Bayati Pedretti, Bellflower USD: Okay.
Virginia Early: But yeah, I mean I think you know we haven't issued develop regulations on this and depending on how you know the monitoring goes like there may be additional things in the future, but for now, I think follow, follow what's here in the statute as best as you can.
Sabriya Bayati Pedretti, Bellflower USD: Yeah.
Virgina Early: Knowing that you know it is a requirement to follow this in order to claim the adjustment factor. So yeah, so if the consultant already has training in California law and professional ethics for early childhood mental health and that training covers, you know, the contemporary professional ethics and statutory regulatory and decisional laws that delineate the scope of the practice of early child and mental consultation like, I'm just sort of reading it, but I put it in the chat for everyone to see if they if they have that confidentiality as it pertains to minors. I would assume that anyone setting up shop as an early child mental health consultant I would hope that have that. So, it's really a matter of like you talking to them. I'm saying, okay, do they, have it? How are they documenting that they have it? Does this– does this seem like when you read the plain language in the Education Code and what they're telling you, does that seem like it would pass to you? And of course, if you have specific questions, you could email your PQI consultant since they're going to monitor.
Sabriya Bayati Pedretti, Bellflower USD: I had– I had one more question related to that. I'm sorry. So, if the consultant goes into the classroom, I understand that you know the reimbursement rate applies to all children, but do we have to get permission slips from the parents of those children in that classroom to work with that because we have a mental health consultant coming in?
Virginia Early: I don't think so. I mean, I think when you look at– when you I mean, I think probably anyone that's even remotely interested in the– providing this, I recommend you sit with 8243. It's honestly like a very specific section of statue and sort of really read with it. One of the things that early childhood mental health consultation includes, and we covered this on the slide is support for providers, parents, legal guardians, and caregivers. So that's one of the changes I think like prior to the recent law change. I think it used to just say support for providers, and they, I think they've added the parent piece in. So that's a new aspect and so if your early childhood mental health consultation is sort of doing this whole child approach to consultation, I think you're going to need to let the parents know kind of what you're doing so that it can be effective in meeting you know those things that it's required to include because it's not just aid to providers and caregivers. It's aid also to parents and legal guardians.
Sabriya Bayati Pedretti, Bellflower USD: So, it’s not aid to children?
Virginia Early: So, I think, I think that the definition is pretty broad. And I'll just hopefully I won't get cut off if I tried to copy and paste all of this in. Yeah, there's always like a word cap, but if you look at 8243a(1) or sorry a(2). They're like A through G list of things that is included in early childhood mental consultations. So, you kind of have to– it includes all of those things, right? So, there's the specific things that you do if the child is exhibiting persistent, if specific children are exhibiting persistent and serious behavior. That– in that situation the consultant will support with pursuing and documenting reasonable steps to maintain that child safe participation in the program Like as we have, you know, included in our suspension expulsion Management Bulletin. That's specific– that's like related to strategies to support a specific child, right? And that could be strategy support that child and that could be strategies to support other children when that child is having an issue. That's challenging to adults, but it can also be more general support for the classroom as a whole. So, I think I think there's some flexibility in the model to think about what the needs of your program are and sort of figure out what makes sense and what your needs are. So, I think, I think what I would recommend doing is sitting down with this Education Code section saying, okay, what's required? What's allowable? What are the needs of my program? And how can this, you know, sort of support the needs both of individual children and of like a classroom, and the teaching workforce as a whole?
Sabriya Bayati Pedretti, Bellflower USD: And our consultant can help us work through that as we sit through, because I printed everything out so I've got it all. So it– the consultant can be support for like sounding board to make sure that I'm on the right target?
Virginia Early: I mean that's my personal interpretation. I mean 2(a) 8243 says support for providers, parents, legal guardians, and caregivers to create trauma informed proactive inclusive environments and to respond effectively to all children.
Sabriya Bayati Pedretti, Bellflower USD: Okay
Virginia Early: So getting support to create trauma informed proactive inclusive environments that respond effectively to all children, you're probably going to need to strategize with them a bit.
Sabriya Bayati Pedretti, Bellflower USD: Okay, perfect.
Virginia Early: And are benefiting like from that support, you would claim the adjustment factor for, but also noting right that, you know there's specific things that have to be done if you're claiming that adjustment factor beyond just getting them as a sounding board. You know, there's specific goals that are listed in statute around improving interpersonal relationships and child outcomes, increasing the confidence, competence, and wellbeing of those that are asking for the consultation and eliminating suspension expulsions, as well as the specific things that are requirements for the model. And we, I answered a lot of questions in the chat about the setting based mental health assessments so that's required if you're using this. You're required to do a setting based mental health assessment two times a year.
Sabriya Bayati Pedretti, Bellflower USD: Okay, perfect. I'm sorry and then I think I was– I added a little confusion there. I didn't mean the mental health consultant uses a sounding board. I'm talking about our consultant from CDE.
Virginia Early: Oh, oh, sorry it's confusing when there are two words, and they mean two different things.
Sabriya Bayati Pedretti, Bellflower USD: Yeah, I’m so sorry.
Virginia Early: I think, I think, yeah, you know, I think it's helpful for your CDE consultant to hear about things that are sort of popping into your mind as well that way, you know, if there’s something that you’re doing that’s really working well then they can be sharing that with other contractors in their area that are calling them so yeah. So yeah, definitely use your CDE consultant as a sounding board and I'm sorry I misunderstood your question.
Sabriya Bayati Pedretti, Bellflower USD: No, no, that was my mistake. Thank you so much for your time.
Virginia Early: Of course.
Cate Washington: Alright, I'm going to go ahead and move on to the next person who has their hand raised. It looks like that is Tereadel Sosa-Borges. Want to go ahead and unmute yourself and ask your question?
Tereadel Sosa-Borges: I just wanted to know if there's any form that has been updated, or that you can provide when we are verifying for proof of income. For example, if we could get, you know, CalWORKs or anything just like a form because we have one, but it's not, I don't think it's updated. If there's anyone– well, we could use and what's accountable and what it's not accountable, like, what income is accountable and what is not accountable? And yeah, to see if you guys have that.
Crystal Devlin: We do have a document that indicates countable income and non-countable income. I'm thinking we probably need to take a look at that and just to make sure that it's, you know, 100 percent accurate, but you can reach out to your assigned Program Quality Implementation office consultant and they can provide you with that form, but I will say we– I’m glad you brought that up because we need to take a look at it just to make sure it's a hundred percent accurate, but do reach out to your consultant if you need guidance on things like that, or if you– one forms that's something that's always nice to hear from all of our contractors like, if there's something that is useful for you that we don't yet have available. If it's something that we can do, you know, fairly efficiently, without, you know, too many staff hours and that type of thing. We're happy to accommodate where we're able to. So please do feel free to reach out to us.
Tereadel Sosa-Borges: Okay, great and one more question. When we have a family that comes in and says that they're not working, that the other, the other parent is working, but receiving cash, and they do the letter stating, you know this is true and then we do two different letters, one stating there's no income, I don't have a job and the other one stating yes I do have a job but I’m receiving cash. Is that– are those the only forms that we need to provide for proof of verification? Or do we need to request other stuff?
Crystal Devlin: So, so the parent, yeah so the parent is employed and saying they're receiving cash, again you need that release authorization from the parent, but the parent can also not you know, authorize you to contact their employer if there might be, you know, if it– there might be a negative effect on the parent, right? They don't want you to contact the employer because of– they're afraid they'll lose their employment or what have you? But you need that doc, you know, that statement from the parent saying that and then you could do a self-certification of income.
Tereadel Sosa-Borges: Okay, great, thank you. And what if we have students– I'm sorry we have parents that are students and they say that they do not have any income whatsoever, but they have money that when they were in their country, they may be from China or other places and they say we have a fund in our bank that when we came, that's the money that we're pulling from. Is that statement from their bank is okay? Or how do we certify that?
Crystal Devlin: I'm going to ask you to contact your assigned consultant. I'm not really sure off the top of my head, but if you reach out to your assigned consultant and ask them, if either they know the answer or if they can, you know, work with our team to come up with the answer for that.
Tereadel Sosa-Borges: Okay, okay, thank you. I'm fairly new to this position, but our site secretary, she's been here for 17 years. So, what she does is she does request like proof of that and then she does the math like, divided by 12 months, and then, based on that, I just wanted to know if there's another answer to that.
Crystal Devlin: Yeah, and that's another thing too as I as I think about it a little bit more like they say they have a fund, you can accept like the prior year’s tax return and then divide their adjusted income by 12 to get a monthly income.
Tereadel Sosa-Borges: Okay, perfect. Thank you.
Crystal Devlin: You’re welcome.
Cate Washington: Alright, I'm going to go ahead and move on to the next person on the list. Let's go to Christina Marquez. Want to go ahead and unmute yourself and ask your question?
Christina Marquez: Hi! Good morning. I just had a– Can you hear me?
Cate Washington: Yes, we can hear you now.
Christina Marquez: So, I just had a quick question about the family data file related to the documentation of eligibility. So, when you're going over the slide, you mentioned that parental authorization to contact the employer was needed. Is that true for all eligibility categories? Specifically, I'm thinking of the government means tested if that would be applicable?
Crystal Devlin: No, it's only based on employment. So, if the parent is employed, you need that release authorization. They're coming in under income eligibility as employed. Then that's when you need that release authorization.
Christina Marquez: Okay and is that the same for the income calculation worksheet? Or is that still needed for all eligibility categories?
Crystal Devlin: Yes, income calculation worksheet is required for all categories.
Christina Marquez: Okay, awesome. Thank you.
Crystal Devlin: You’re welcome.
Cate Washington: On that same topic, Crystal, before I move on to the next person who has their hand raised. We did have a question in the Q&A about whether or not they can use the family fee rate calculator instead of the income worksheet. Can you address that?
Crystal Devlin: So, we do see this, right? And sometimes it's for part-day CSPP so there is a way in there to toggle in between the family fee and the income. And so, when you go in and do the income documentation, you can print out– it looks just almost exactly like our income calculation worksheet. So, you don't have to use the income calculation worksheet that is on our webpage. You just need to make sure you have some sort of income calculation worksheet that shows us how you determine the family’s monthly income, okay? So yes, you can use that, but you should print that out and have a copy of it in the family data file.
Cate Washington: Thank you. Alright, so let's move on to Lori Miller. Go ahead and unmute yourself and ask your question. Lori Miller, you had your hand raised. Did you have a question? If so, you can unmute yourself and ask. Okay, move on to the next person. Lynda Ledo, go ahead and unmute yourself and ask your question.
Lynda Ledo: Hi! Good morning. I have two questions. One of the questions was regarding about a written request, if there's any changes that a family likes to make to their service. If a family is requesting to change their schedule and if they're sending us an updated employment verification, well, the back story is that they'll call us and say, I would like to request to increase my hours and we would do our screening and then provide them the updated employment verification form. And then is that like enough documentation when they submit us– submit the updated employment verification form instead of actually writing us an email or sending us a letter to say I would like to increase my hours, or do we need both of the documentation?
Crystal Devlin: You always have to have that written request from the parent requesting a change to their services. That's what's in in regulations. So yes, you have to have that.
Lynda Ledo: So, they'll need to write written request or email let us know that. What if they text us? Can we screenshot that and put it in our file?
Crystal Devlin: I would say that's acceptable. What do you think, Virginia? It's a written request via text for a change in services?
Virginia Early: Yeah, I mean, I think as long as you have some way of like documenting it in your files. Can't imagine, you know, I like that you want to be flexible and responsive to how your families are communicating with you, but you would want to have some way of capturing that outside of a person’s cellphone.
Lynda Ledo: Thank you and if it was like a verbal request can we case note that? Would that be like a written request, or it has to be a written request directly from the parent?
Crystal Devlin: Correct, it has to be a written request from the parent.
Lynda Ledo: Okay, thank you. And then my second question is just to ensure that you guys remember to follow up on the– just to clarify if a family is receiving SSI are they considered a current aid recipient? Not to say that SSI is part of the government tested program, but it's not, but I was wondering if a family who's a recipient of SSI can we qualify them? Are they eligible through current aid recipient?
Crystal Devlin: No, they're not. That's related to CalWORKs or cash aid.
Lynda Ledo: Perfect, thank you so much.
Crystal Devlin: You're welcome.
Cate Washington: Alright, Crystal, we had a couple of questions related to part-day. So, we have a question here in the chat. For part-day, do you need to do income verification forms for the working parents?
Crystal Devlin: If you– I think this is referring it back again to that release authorization. So yes, you do always, whether it's part-day or full-day. If the parent is employed, you have to have that release authorizing you to contact the parents’ employer. However, for in the case with or instance with part-day CSPP, you have that release authorization, you typically are not contacting that employer to verify things. The parents are able to provide you paystubs, that type of stuff. That's usually really reserved more for verifying the family's need for services, but if there's an instance where the parent is like, I'm just not sure my income, what it's going to be, I just started last month so they're not able to provide you with a self-certification of income then you would contact that employer to determine what the parent earns– is going to be earning.
Cate Washington: Thank you. Alright, so I'm going to go ahead and move on to the people who have their hands raised again. We have, let’s see, M. Carmen Serrano, do you want to go ahead and unmute yourself and ask your question?
M. Carmen Serrano: Hi, I'm fairly new to the program as a fiscal officer and I just started reading a lot about the family fees that started in September. Do we have to go and charge these family fees, or can we decide to waive them to the end of the year for the parents that are already enrolled?
Crystal Devlin: So, the Management Bulletin around family fees specifically says and this is the rare instance where you're within that 24 month eligibility and that you, you make a change. It does say that you have to go back and assess family fees based on the current fee schedule and assess those fees and bill the families for those fees. Sometimes we see programs like LEAs or other programs that might receive some external funding where they go ahead and cover the family fee, but yes, the Management Bulletin and I can't remember the name or the number of it off the top of my head, but it does very specifically say that you have to assess family fees effective October 1 and use that fee schedule to notify the families of the fee and that it will start being due and payable.
M. Carmen Serrano: You said that it can be waived with other programs. Could that be part Head Start, could we use that to cover it?
Crystal Devlin: I'm not really sure about Head Start and I'm and I'm just from what I know is a practice is like sometimes the LEA will use their own funding to cover the family fee, or you might receive a grant from an external you know, community partner, or something like that that ends up covering the family fees. I don't think you can use Head Start funds. I think that's for Head Start children only. I would, I would speak to your Head Start folks about that.
M. Carmen Serrano: Okay, thank you.
Crystal Devlin: You're welcome.
Cate Washington: Alright, I'm going to go ahead and move on to the next person who has their hand raised. Michelle Boswell, do you want to unmute yourself and ask your question?
Michelle Boswell: Sorry, can you hear me?
Cate Washington: You're cutting out just a little bit.
Michelle Boswell: Hello?
Cate Washington: Yes, I hear you now.
Michelle Boswell: Okay, okay. I'm sort of new to this. I just have a couple of questions. If that's okay, not just one. The first one being if a parent self certifies their income, do we still need the calculation worksheet and we just enter that– the number that they put in there?
Crystal Devlin: So, the calculation worksheet is just a requirement. And for any– when a family is certified based on income, it has to be used. So, you do need to have that income calculation worksheet in there, even if the parents self-certifying their income.
Michelle Boswell: Okay and then I put the question in the chat, but since I'm– put my hand up, the social services referral is that for full-day and part-day CSPP?
Crystal Devlin: Yes.
Michelle Boswell: Okay and then this is kind of the piggyback on a question that was actually asked a while ago, as far as like required document. So, the physician’s reports, that licensing form, they're not due at the time of enrollment, but they are due within 30 days, but from what I heard once we send out the NOA, we can't disenroll them. So if they have the 30 days from enrollment, does enrollment count when they start? Or does enrollment start when they've signed the 9600? I'm a little confused on that.
Crystal Devlin: So, their start date occurs the start date for receiving services. So, they okay, they fill out the application for services, they sign it. You have 30 days to either approve or deny their services, right? Within that 30 days they should be trying to get that, you know, that physician’s report but you would not if they're certified and they begin receiving services and within 30 days they have not provided you that physician’s report. I just recommend that you're continually following up with them because this is not just a CDE thing. This is also a DSS licensing thing and if you don't have that on file, then that's going to be a finding from licensing as well.
Michelle Boswell: Okay
Crystal Devlin: Yeah, so it's really important that you're following up with families and telling them that you have to have that documentation.
Michelle Boswell: I do, I follow up about once a month and it's been an ongoing battle to get these physicians reports. A lot of parents, once their kids starts, they don't really bother with any other paperwork. So, would it be okay if like, we did all the paperwork and then waited to do the NOA approving their services after the physician's report was turned in, or are we not allowed to do that? Do we have to enroll them without it? Or can we wait to get them to start until they have it?
Crystal Devlin: That's a tough one. Virginia, do you know? You're on mute.
Virginia Early: Can you repeat the question?
Michelle Boswell: Okay, so for the physician’s report, I was wondering, will enroll them, we'll send out the NOA. We remind the parents they have 30 days for the physician’s report. A lot of times I never get it within 30 days. I follow up once a month. I'm still not getting it and I know that the regulation states without it they can no longer attend, but her answer was, once we send out that NOA we cannot disenroll anybody. So, I'm just confused on what the regulations are. And then, if we can enroll them without the physician's report then we can't disenroll them if they don't have it. So, I'm just kind of confused on the physician's report. I guess.
Crystal Devlin: Yeah, you know what, can I ask you to email me this question and let me take it back to our PQI team, our consultants and our administrators and have a conversation with them and get you a accurate answer.
Michelle Boswell: Yes, please, I would appreciate it. Yeah, it's been an ongoing thing for me trying to get this physician's report.
Crystal Devlin: I get it.
Michelle Boswell: And then I know we can't really disenroll them, but the regulation says they can't attend without it after 30 days, so I'm not sure what– how to go about that.
Crystal Devlin: Right, so what I would do for right now because you're dealing with this in real time is making sure that you're taking really detailed case notes and including those in the family data file. And then get this question over to me. I'm putting my email in the chat for you right now and we can follow up with you, okay?
Michelle Boswell: Okay, thank you so much.
Crystal Devlin: You're welcome.
Cate Washington: Alright, thank you Michelle. So, I'm going to move on to Shannan Watkins. If you want to go ahead and unmute yourself, you can ask your question.
Shannan Watkins: Hello! Hi! Can you hear me?
Cate Washington: Hello, yes we can hear you.
Shannan Watkins: So, my question is this, I know that we can't reduce the parents’ hours, but we run into the situation now twice where we have a child enrolled in our CSPP program, then we work through the process to get them an IEP. The district says they have to come to their CSPP program in order to get their services and then the other half of the day they're being dropped back off by their buses at our sites, but now we're both billing CSPP for the same child.
Crystal Devlin: So, they're duly enrolled in two different state school programs?
Shannan Watkins: Yeah, so they're originally enrolled with us and then we go through the process, they end up getting an IEP. Then the district says, oh well now you have to come to our CSPP program for your services and then the little– the bus will bring you back and drop you off at your providers for the afternoon or morning depending on what they're in. And so, I can't reduce the parents’ hours with us because they've been certified for 24 months, but now the district is billing them for a CSPP also.
Crystal Devlin: They cannot be duly enrolled in two CSPP programs at the same time.
Shannan Watkins: So how do I notify the– I mean, the district doesn't care. Quite honestly like they're– we were first person that had them enrolled. I mean, it's happened twice now, so it's not– it's becoming a practice at this point.
Crystal Devlin: The LEA is required to provide free and appropriate– I can't. It's fape and that doesn't have to be in their CSPP so they need to be providing those accommodations and supports that are included in that IEP, either where the child already is, or they need to be doing it through their LEA. They should not be doing it through state preschool if that child is already enrolled in another state preschool and also attending there. I think we– I think we probably need to take this back and discuss with policy that this is happening and develop a FAQ around that because that's yeah– that's not acceptable. So let us take it back to our leadership team and our policy office and work on an FAQ,
Shannan Watkins: Okay, that would be fantastic because we're seeing it more often now and it's not only is it affecting, obviously, our billing. We don't want to be doing anything incorrect, but it affects the parent, but it also is affecting even our ability to meet our set aside because soon as they get an IEP the districts like nope, you have to come over here. Come over here because then it meets their set aside and we're back to the drawing board finding children again. So, any important answers on that would be fantastic.
Crystal Devlin: Sure. Thank you, Shannon.
Shannan Watkins: Thank you.
Cate Washington: Thank you. Okay, so I want to hop over to a question from the Q&A from Amy Martinez and I'm going to call on Virginia for this one. So, are you aware of the CDE requiring CSPP programs to use CLASS?
Virginia Early: Yes, we are aware. In fact, we're working on a Management Bulletin about it that I feel like it's taking all my time right now because it's very complicated. So yes, there will be a move to CLASS. CDE is required to release guidance, that we're hoping to release in the form of a Management Bulletin by December 31 of this year. So, happy New Year to everyone. I know that's at– what everyone wants to be doing is looking at a Management Bulletin on New Year's so that Management Bulletin will show the timeline for CLASS implementation and this– the law that directs us to implement CLASS also direct us to take another look at ours, because, of course CDE using ECERS are which– is not even supported anymore because it it's sort of older. So, more to come from the upcoming Management Bulletin. We also received some funding in the budget to support implementation of CLASS so we're working on getting those funds out and we will have more information in the coming months, but what I will say is that this will not be a sort of– there will be a phase into the new requirements and a lot of support and we'll be releasing more information in the coming weeks and months about that. I thought I saw seven people all raise their hands. I don't know if everyone has questions about CLASS, but we will just say a lot of those questions will be answered by the Management Bulletin and there's, you know, there's a limited amount that we can share before we finalize that and it goes through all of our internal approvals.
Cate Washington: Thank you, Virginia. Most of those people, I think, had their hands raised already.
Virginia Early: Okay, I was like, whoa, I guess everyone is really excited.
Cate Washington: It’s a hot topic. Alright, I'm going to go ahead and call on Janet Buckmore. If you want to go ahead and unmute yourself, you can ask your question, Janet. Janet, are you able to unmute yourself and ask your question? Alright, I’m going to move on to the next person here, Cynthia, from S-Kids 1st, you want to go ahead and unmute yourself? You can ask your question.
Cynthia S-Kids 1st: Hi, there! Thank you for your patience. I have a couple of questions regarding the 24-month eligibility when we enroll parents that have– they're student parents or training parents. We know what the 24-month eligibility and we provide them service for semester units, but 24 months later they probably have moved on and they probably come in a couple of times to change the schedule because of these classes they received. What documentation are we going to ask for the proof of passing? Would that be the units that, or the classes that they first enrolled with, or all the classes within that period?
Crystal Devlin: The– would be any of the oh, yeah, okay, I'm sorry. So, you need to see, you know, verification of passing grade would be for any of the classes that they were enrolled in within that 24-month period. And you're talking about recertification, correct?
Cynthia S-Kids 1st: Correct.
Crystal Devlin: Yeah, so you're going to want to see that they're passing– typically a transcript. You want to see their transcript, or you know, some other evidence of documentation with the name of the educational institution on it that shows the parents.
Cynthia S-Kids 1st: Correct, we use your provided form.
Crystal Devlin: Okay, great.
Cynthia S-Kids 1st: The next one is regarding the– you had talked about this. Somebody talked about the savings account being the form of income to– I think it's more like incline how you're supporting yourself, but we were informed that a savings bank account, or any bank statement would only show that they can provide incline for themselves and their family, but their income would be zero. So, in the case of the student that came from China that was used. What if she doesn't have tax returns to do that? Would we put zero as her income and then in incline put living off savings, or whatever have you? That's what we were told by a consultant, so I want to make sure we get that right.
Crystal Devlin: And I want to make sure we get that right. Does policy have any feedback on that? The parent has no job, but they are living off their savings are– I'm not sure how we would calculate income for that and they don't have a tax return because there's, you know, foreign exchange.
Virginia Early: Yeah, I think that might be another one we need to take back Crystal and discuss because I don't know that we have a specific regulation that deals with that.
Crystal Devlin: Right? At least that I don't think so. Yeah, I don't think we do either.
Cynthia S-Kids 1st: Okay, and then, yeah. And then I have one more question I'm sorry, but I've been writing them down as people asking for further explanation. The oh– you know right now our agency is dealing with a lot of overtime issues like we have to collect 12 months of overtime. Very burdensome for the parents and the employers and is– when can they just attest their overtime according to the year to date? If that's something that they can readily have because it will show on the current check stubs and also can we put it on the fa– on the request for the employer to verify? And would that be sufficient if we were to say in the last 12 months with how much overtime do they make then the parent can declare that as well. What we're– what we're seeing is parents roll their eyes when we ask them for 12 months of checks because they might have $13 of overtime for 2minutes that they worked, you know.
Crystal Devlin: Right.
Cynthia S-Kids 1st: Slight exaggeration.
Crystal Devlin: Yeah, so if you're seeing like really consistent overtime, right like from month to month to month, there, you know, or there, there are four weeks of income documentation that is really consistent, right? That it pretty much stays the same. Then you're going to just use like their gross pay for each month. Okay, for the month and you don't need to do that 12 month income documentation. If they're unable to obtain the 12 month income documentation, it might be their tax return that you use and you divide it by 12. You can do the employer verification where the employer is saying that you know they're verifying that the parent works, you know, approximately 5 hours overtime each month, but around the holidays they might work 20 hours overtime, right? And so, they and then you can, you know, kind of project and calculate the income that way.
Cynthia S-Kids 1st: Okay, thank you. Yeah, I think it's something that's going to need to come back because I spoke to the p– the– we just were audited last year and that's not how they explained it. There were– it wasn't as friendly. I like your– the way we are doing it with you. It's more friendly to the parent and less labor intensive to the employer and to ourselves, but I do want to make sure that when we look at it like we just had a parent that only had overtime on one check, and we took that overtime out of the gross for that check because we can't double count it. Is that a correct way to calculate that?
Crystal Devlin: But they got– is that where it's like not consistent overtime, they don't, you know, it’s a one off. You know they're saying, we– this just happened once. It doesn't usually happen.
Cynthia S-Kids 1st: Well, I'll tell you what we looked at is the year to date was $351 for 10 months and the checks that they brought in were weekly and they only had it on one and it was $51. So that gross check we took the $51 out of it because we were able to calculate the 12 months based on their year to date and their certification. So that's how we were told to do it. I just want to make sure that the next audit we have that we're doing it on regulation.
Crystal Devlin: Okay, I don't want to get too deep in the weeds on this one. I just want to–I'm going to give you my email address as well. If you can email me all of the specific scenarios and I'm putting my email in the chat for you.
Cynthia S-Kids 1st: Thank you so much.
Crystal Devlin: You’re welcome.
Cynthia S-Kids 1st: And then the last one and I'm sorry for taking up the time, we had a parent that advised us that her child was leaving to Ellen Fisch School District and at the same time she wanted her other child to start. She was not potty trained, so we issued a Notice of Action approving the child to come in within a specific time, which was two weeks away, as the parent had requested, but the parent– the child left that is still considered– the child left the next day. She didn't give us any notice, that's still considered a change, is that correct? We can change– we could add a sibling, even though the child was going to be gone by the time the child started if it went on the NOA.
Crystal Devlin: So, you have a child leaving for school. You have the sibling coming in.
Cynthia S-Kids 1st: Correct.
Crystal Devlin: Okay so, the– you can't enroll the– just automatically bring the sibling in. You still have to do the priority order, right? So, you have this one child that has left that doesn't make the sibling automatically eligible if you have a wait list. If you don't have a wait list then you can go ahead and enroll that child, but you still you always have to enroll in priority order. So, if there's somebody on the wait list ahead of that family, that's you know their income is lower, or there a child with disabilities and you haven't met your set aside yet that type of thing, you need to make sure you're enrolling in priority order.
Cynthia S-Kids 1st: No, I guess that would be true if the child had gone, but we enrolled the child prior to the child leaving. Would that make– We don’t have a waiting list.
Crystal Devlin: So then, so then, that's okay. Yes, that's okay, but yeah, for future reference, just even if the other child is still there that doesn't automatically, you know, bring the sibling in unless you don't have that wait list, right?
Cynthia S-Kids 1st: But before it was the point where siblings can be added if a family was already enrolled in the same services. That is not the case now.
Crystal Devlin: That is not the case.
Cynthia S-Kids 1st: Okay, thank you.
Crystal Devlin: Thank you.
Cynthia S-Kids 1st: That's it. Thank you so much.
Cate Washington: Thank you, Cynthia. Alright, so I'm going to go ahead and turn it over to Corey to close this up before the last presentation of the day. Corey?
Corey Khan: Okay, so we will be moving on to the next presentation. It's 11. So, the next presentation is a presentation again, that only applies to those private agencies. So, anyone who is a Local Educational School District, I think agency is what we call them. So, school district, let's see, County Office of Ed or a Community College District, you guys do not have to stay to watch this presentation. This presentation is only for those who submit an audit to the CDE Audits Division. Tomorrow we will have– we will start again at 9 AM for everyone and that, like, I said, will be super involved with like how to report to the Early Education, no, Early Education and Nutrition Fiscal Services Division. So, my division or my unit and it's anything how to report within CPARIS and then how that then calculates your reimbursement. So, thank you to the school districts and community colleges, County Office of Ed that joined this morning and then we'll see you all tomorrow. So, I will turn it over to Laura to go over our next presentation or Verdette I think, sorry.
Verdette Parker: Yeah, I'll go ahead and start. Alright, so thank you everyone for joining us today. I hope you guys have been all enjoying the webinar so far. Today I will be going over the audit requirements for California State Preschool Program contractors and you can, yeah, there we go, perfect.
And again, my name is Verdette Parker. I am an audit manager in the CDE Audits and Investigations Division, and I oversee the audit report reviews section. We also have our assistant director, Laura Langston, with us today and she'll be going over the second half of this presentation. Again, as a reminder as they go through my presentation. You may have questions to the Q&A chat, but we will also have a live Q&A after this session, as far as I've been told. Next slide.
So, our presentation today is on the annual audit requirements for California State Preschool Program contractors. We will provide an overview of the program requirements. We'll speak specifically to your audit requirements, and we'll also go over how to submit a quality audit report.
And I'll start off with an overview of your program requirements.
So, laws and regulations. So, these links here, they're the various laws and regulations that govern the California State Preschool program. We have the Code of Federal Regulations. There's California Education Code as well as California Code of Regulations and so they include a wide range of program requirements. Not just for contractors, but you know also, CDE administration of the CSPP so just kind of just wanted to point out that just to be aware of which regulations are pertain to you. Next slide.
So, in addition to those links, CDE took all of that information and summarized the requirements that apply to contractors in the Contract Terms and Conditions. You're probably familiar with. Also, this is called the CT&C which makes them one of the most important documents that you should know inside and out. These CT&C are updated annually and posted online at this website here on the slide. As an auditor, these are very useful for us when researching to determine whether cost is allowable. We go to the CT&C first. This would be a good place for your annual auditor, your independent CPA or your auditors to start. Sometimes, also, though, some specific situations won't perfectly fit within the CT&C language, and in those cases, I'll go to the source requirements which are also referenced throughout the CT&C. The language in the CT&C is based off of those laws and regulations on the previous slide, however, sometimes it can be phrased differently and so seeing the same requirement in different ways can help provide some clarity and assist you in interpreting whether something's allowable or how to administer your program. And the CT&C provide for program operation requirements, reporting requirements and audit requirements all of which are overseen by a different part of CDE which can be a little confusing. So, if you have questions regarding your program operation requirements, your child development consultant would be the best person to contact for operation requirements. Next slide.
Then, if you have questions regarding reporting requirements or funding related questions, you can look that information up in the EENFS Fiscal Handbook or contact your fiscal analysts. This is another area of CDE. For example, you may have questions regarding how your reserve balance is calculated. That information is in the fiscal handbook which you can find at the link on this slide here. And again, you can also contact your fiscal analyst, who is also the person who performs that calculation. Another document that comes from your fiscal analyst that we find useful is the final earnings calculation and we find we use that in our reviews. And you can take your audited Attendance and Fiscal reports which we call the AUD form, and you can follow that– how that information fits into the final earnings calculation form and then the notes on that form has various steps that will allow you to follow the calculation and understand how the final earnings are determined. Next slide.
Okay, and then if you have questions regarding the annual audit, that's where my unit comes in and we developed the CDE Audit Guide which provides guidance on those requirements. We recently updated this guide in July of 2023 and that updated version is available at this link as well. Most of the updates were just links or references within the document, but there were some more important changes that we will discuss throughout the presentation.
And so, for this next part, I will go over the basic audit requirements.
So, the source of the audit requirement is a California Education Code Section 8335 which requires an annual financial and compliance audit of the entire organization for each agency with a CSPP contract. And please note that the requirement is for an audit of the whole organization. So not just an audit of the contract by itself, or just the program, has to be the whole agency.
And then, following that, the California Code of Regulations piggybacks the Education Code and specifies that the audit must be considered acceptable and in the CDE Audit Guide I mentioned earlier, defines the requirements of an acceptable audit and includes an example– also includes an example of an audit report that meets our submission requirements as well. Next.
So, the Audit Guide also goes over two types of audit reports that your agency could be required to submit. That would be a Single Audit, or a Contractor Audit and I'll go over how to determine which one is required of your agency, but with either option the audit must be conducted in accordance with generally accepted auditing standards and government auditing standards.
Single Audits, so Single Audits have a specific requirement. And a Single Audit that meets the requirements of Title 2, CFR Part 200, which is also known as the Uniform Grant Guidance is required if your agency expends $750,000 or more of federal funds in total. So, this means that it's important to know the source of the funding that your agency receives and just because funding came from CDE, it does not mean that it is only state funding and this means so in total, also, that also means, if you're receiving federal funds for other programs within– for your organization that's also included. So, for example, if you received only $50,000 from CDE and federal funds that you got 800,000 from other programs in federal funds, you would be required to have a Single Audit. So again, CSPP contracts are primarily for state funding, however, there are times when agencies will receive federal funding as part of that contract, and you can determine what part of your contract is federally funded by reviewing your contracts’ face sheet. Additionally, the CPARIS, or like California Preschool Accounting Reporting Information System will designate federal funding with the project cost account number, starting with one.
And the Contractor Audit. Your agency spends less than $750,000 of federal funds and you are required to submit an organization-wide audit report which we've termed a Contractor Audit. Essentially, Contractor Audit is an organization-wide audit that is not a Single Audit and the again, the biggest difference between these types of audit reports is just there's different steps that the CPA has to perform.
Okay and due dates most important regardless of the type of audit you are required to submit. Your audit report is due on the 15th day of the 5th month following your agency's fiscal year end. If that date falls on a weekend or holiday, the due date would then move to the next business day.
And for this slide we've included a list of comments. Fiscal year end– and their corresponding audit report due dates. This particular list is specifically for agencies with a fiscal year 2022-23 contract, and we've already adjusted them for the weekend and holidays. So, if you have a fiscal year end that falls on any of these dates that is your audit report due date on this slide. And of course, the first fiscal year end is June 30, which is pretty much most common fiscal year end for agencies. And the 15th day of the 5th month following June 30, would be November 15, so coming up here shortly.
Extension requests, we're getting a lot of these in now. So, A&I has the authority to grant a one-time-only, 30-calendar-day extension to the audit report due date, provided that the reason for the extension is beyond the fault and control of the agency. In other words, each fiscal year we can extend your due date by one month, and no further. There is no consequence for requesting an extension. So, we do recommend that everyone take advantage of it. The only potential drawback from doing so is that when is– when you submit your audit, we review them on a first come first serve basis and we get hundreds of audit reports around the extended December 15 due date. If you are owed money, or you just want to get your review done, submitting your audit by the end of November puts you ahead of all of the other agencies that will be submitting theirs by the 15 of December. And then, if there were handouts as part of the webinar, there's– there would be one in there. I know we handed them out in the in-person trainings. I just wanted to note that.
Okay, there's also an example of the extension request in the– in chapter 200 of our Audit Guide, and there are very few reasons why we would deny a request and all of those are listed on the form itself. We– there are a few situations where we won't be able to grant extensions. This would be for any agencies that are on conditional contract status, either currently or for a period under audit. For agencies that have already received an extension because we can only grant one per year, or for agencies whose audit report is already considered delinquent from prior years. If you remember from the previous slide, the caveat to the extension is that the reason for the request must be beyond default and control of the contractor. To verify this, your request has to include your reasons and we won't deny a request that doesn't include that information. We just won't be able to approve it either. Typical acceptable responses would include that the CPA has requested more time to complete the audit, or that there was a staff turnover.
And once you've completed your audit report, it can be submitted either electronically or by mail.
Next, we have a system called Xfiles to receive large files from outside parties. There is a specific link, project code and password that are needed to submit an audit for each contract year. We send those out to all agencies around mid-August, along with the Annual Audit Status Certification request or AASD and we provide the instructions. We did provide the instructions part of the handout previously so, hopefully, you've got that. Included in the instructions is a file naming convention and this is really important here. We do request that you provide a contact name and email or phone number as a description. We ask you to do these things to ensure that your audit gets logged appropriately. We have had instances where an audit was uploaded by someone who did not follow the naming convention and instructions and then the file ended up being corrupted and we couldn't open it. So, because, you know, the agency didn't follow the instructions, we had no idea which agency, or who to contact to figure it out. So, at that point the agency would think that they had submitted their audit, but we would not be able to log it in or confirm it. So, luckily there were two audits that were uploaded back-to-back. We were able to open the second one. We contacted the CPA and hoping that the same CPA was submitting for multiple agencies and sure enough, that turned out to be the case. So, that agency was very fortunate, but you know, without following the instructions and without that being the case, that again an agency would be listed as delinquent and without even possibly knowing. So again, although we were able to resolve the issue, you know, we do ask for specific naming convention and instructions to be followed.
Okay, so we, while we do prefer electronic submission. Especially, you know, with everyone teleworking. You do have the option to mail in your audit reports. Preferably an unbound copy since we can scan them and upload them into our system. And if you choose this option, it is important to specify that the package is for Audit and Investigations Division so that second line there so that it can be routed to the appropriate office within our– within our building.
Okay and delinquent audit reports. So hopefully this doesn't apply to anyone here, but just so you are aware, if you do not submit your audit report on time, you will end up on our delinquent audit list which then gets sent to our fiscal analyst twice a month on the 1st and the 15th. If you are on that list, your fiscal analyst is required by California Code of Regulation to place your apportionment payments on withhold so don't be delinquent.
Okay, and unsubmitted audits. So, Section 17825(c) of the CCR goes on to state that if a contractor fails to submit an acceptable audit report within one year of the due date, then CDE can build a contractor for 100 percent of the funding that they received from that contract year. And, while we do work with the contractors to make sure that a quality audit report is submitted, an acceptable audit report is submitted. So, just try to be responsive when we do reach out because we do like to work with you and avoid those situations as much as much as possible.
Okay, and so the last part of our presentation will be about submitting a quality audit report and so right now I will hand the screen or the video over to Laura Langston, our assistant director who will go over the next session– section. Laura?
Laura Langston: I'm here. I'm not sure I can– you can hear me and see me?
Verdette Parker: We can hear you. You sound a little echoey.
Laura Langston: Okay, we can move on to the next slide.
Corey Khan: Laura, do you have two different devices on?
Laura Langston: I do not.
Corey Khan: Oh, interesting.
Laura Langston: I don't know if everyone else is muted. Okay, so tips for success. Hopefully, my echo if it's still going, isn't too obnoxious. I'm not really sure how to fix it. The first thing is to start early. We– your CPAS, we, we typically get a lot of audit reports done by the same CPAS. And then so if you're, you know trying to contact those CPAS late, or if you have someone go out sick for a period of time, or whatever it is, those things can delay the audit process and like Verdette just mentioned, you don't want to have a delinquent audit that results in withheld apportionments so the earlier you start the process the better. You can start before your fiscal year ends. You want to make sure you have a CPA in line ready to perform your audit maybe by like February or March before your fiscal year end because if there's even an opportunity that they can perform some of their audit procedures before your contract even closes for that year. And the next tip is to select a reliable CPA. Verdette mentioned that one of the requirements of the audit report is that you, your audit must be conducted in accordance with government auditing standards. Not every CPA can do that. I'm not sure– I’m getting a lot of emojis, does that mean that my audio is not clear?
Corey Khan: Yeah, it’s still echoing for some reason, and it doesn't look like anyone is off mute.
Laura Langston: Okay maybe I can try to leave and come back?
Corey Khan: Okay, I think she's working on it. So, we'll take a short pause. You're on mute.
Laura Langston: Did that help at all?
Corey Khan: Yes.
Laura Langston: Oh, awesome.
Corey Khan: Does that work for everyone? If people can like use the emoji thumbs up, or I see celebrations too.
Laura Langston: Okay, thank you. Okay, so where was I? Oh, yes, government auditing standards. So, a CPA in order to say that they've conducted your audit in accordance with government auditing standards, they have to meet certain requirements. One of those requirements is that they have another CPA, or another CPA firm come out and do a peer review of them, which is kind of like an audit of their process to ensure that they're submitting quality reports. So, when you're selecting a CPA make sure you ask for that report and read it, review it, make sure whatever's in there is something that either the CPA can say that they've corrected, or that it says that they have the processes in place to perform a quality audit. The next thing is to make sure to complete the quality review checklist before you submit your audit. The quality review checklist is like a mini version of the review that your audit report goes through when it comes to us. So, if you performed that review ahead of time, then it's more likely that when it gets to us, everything's going to be in order. Verdette mentioned that we find the final earnings calculation very useful in audits and before you turn in your audit, you guys will get a copy of a draft audit from your CPA to kind of okay. That is a great time to kind of perform your own final earnings calculation based on the audited figures so you can see what your reimbursement will be. If it's out of line for what you think it is then try to look at that ahead of time to get it resolved. We'll have agencies that you know, it's gone all the way through the review process. Their fiscal analyst has calculated their audit, and it results in a billing to their contract and then they go through their audit and realize they forgot to include like half the salaries that they should have. So, just making sure you review it upfront is a– is a great idea to circumvent that. Okay, next slide.
Okay, so when we're reviewing your audit report, we're looking for three things. Does it meet the submission requirements? Does it appear reliable? And do the basic financial statements and the supplemental information that's required to be included in your audit, does it support what's reported in your Audited Attendance and Fiscal reports? Which I'm going to call AP forms from now on.
So, we typically have issues when we're working through our reviews where we have to reach out to someone. We work directly with the CPA so just because we find an issue doesn't mean we just reject the audit report. We do really try to work with CPAs to try to get the audit report up to meet our standards. So, these are common review issues that we come across that we will start by just contacting your CPA and seeing if we can get revisions or the missing documentation. So, the first one is, it's missing required schedules. There is a whole list of required schedules that are required to be included in your audit report, but they're also identified in that quality review checklist. So, if you've done your free check with the quality review checklist, this shouldn't be an issue for you. The next one is that Audited Attendance and Fiscal report forms, or AUD forms are incorrect or missing. So, we– one we have to have them in the audit report that's the– one of the main factors of our review are those forms, but also, they are specific to each year's contract. And so, you need to make sure that you're pulling the most recent form off of the– off of online where they're posted because things like adjustment factors will change every year. Lately, we've been adding new revenue lines. There's going to be new expense lines coming so you just want to make sure you have the most up to date forms. Another one is a management letter was provided to the agency, but not submitted with your audit report. You're not always going to get a management letter. What a management letter is, is there's different level of finance. So, a CPA might have found an issue, but they don't think it's egregious enough to include it in your audit report as a finding, but they may still let you know in a separate letter. If that audit report is going to tell us that they've submitted a separate letter to you, and we'll want a copy of that. And then another one that's pretty common is that the AUD forms does– they don't agree to the supporting supplemental schedules that were included in the audit report, which is the whole point of those schedules is for us to compare the two. So, if they don't agree, we're going to have to follow up to the C– with the CPA to figure out why.
Okay, so another common review issue that we come across is reporting capitalized versus non capitalized equipment. These two categories, the 6400 and the 6500, they are specifically for capitalized equipment, which I've included the definition for you on the screen. Now, what gets a little confusing is when people choose to apply different thresholds to grant purchased items. So, some agencies, let's say your capitalization threshold as an agency is $5,000. So, if you treat grant purchased equipment that same way then it's going to be capitalized for both purposes, and you're going to report it when you're expensing it to the program in these line items, 6400, 6500. Now, there's items that maybe like, maybe you're an agency that chooses not to capitalize grant equipment, even though you have a capitalization of $5,000. We're going to expect you to follow that threshold when you're reporting here and even if you didn't specifically capitalize it for accounting purposes because the point here is that your threshold is $5,000, and so by not capitalizing it for financial statement purposes, your kind of not intentionally, but it ends up circumventing our reporting process. And so, the threshold here is limited to $5,000, but another one is that some people like– there's the pre-approval threshold is either the capitalized threshold like what is reported on this screen, or if you're purchasing multiple items at a time, it can also result in you needing pre-approval. That doesn't make it capitalized equipment, though, right? Like, if you purchased, I believe, when you're purchasing multiple items together, if it exceeds $10,000, that becomes the pre-approval threshold. So, say you're purchasing a bunch of tables, and your purchase ends up exceeding $10,000 that– just because you obtained pre-approval doesn't mean that you report them in these lines. It's only for capitalized equipment.
Another one that we come across pretty frequently is administrative costs. And we perform certain analytical tests on your audit report, and we can tell that the administrative costs may not be reported correctly in your AUD form. Your agency is required to have a documented and approved rationale for determining direct and administrative costs and that rationale needs to be based on an allocation of benefits received. So, for example, let's say, I'm sorry this is two different things. So, you have to be able to separate your costs between direct, meaning they provide a direct benefit to the family versus administrative, meaning It's more of like a supportive function, something like management, having your audit done, accounting, HR, those types of things are typically administrative type costs. And then once you determine that you have to have a basis for allocating those costs based on the benefits received to the program and what that means is that there is some statistic that you're using. Unless, unless it's really easy like, say, you're, you're only have a CSPP program and you have, you know, one manager and that's all they do is manage. So, they're like 100 percent administrative and it's 100 percent to CSPP. That's pretty straightforward, but typically what we come into is, maybe they have, like one executive director of a facility and then they have both CSPP and CCTR in that is overseen by that executive director. You need to come up with a way to allocate that cost based on benefits received so things that we see that are not correct or like allocating it 50 percent to each contract, which doesn't necessarily reflect the benefits received because for example, if you know, CCTR has 5 children and CSPP has 20 children. Well, that CSPP program is going to require a lot more administrative support from that executive director than the CCTR program. Another thing that we come across is that you're not reporting all reimbursable costs. It's really to your benefit to report all reimbursable costs to the program. So, we have people who will cap their reporting at like, say, their CSPP contract will only pay $200,000. Well, if you cap that– what if there is something to reimbursement that you weren't clear about. And so, you're actually going to get paid less than you thought if you would put all of the reimbursable costs in there. It's going to result in you earning more of your contract. It's also if you get audited or reviewed and we end up disallowing some costs. You have other costs to replace those costs because you had other reimbursable costs reported.
So, when we have this line, the total administrative cost line in the AUD form, what we're looking for you to report is the amount of administrative costs that are included in the total reimbursable expenses which is every line above that total reimbursable expense line. We're– some people get confused because the maximum that they can get reimbursed for administrative costs is 15 percent. That does not mean that you stop reporting in that total administrative cost line at 15 percent, you report the actual amount of administrative costs there included in the reimbursable expenses section, and then the reimbursement calculation will limit your reimbursement to that 15 percent.
Some things that we're coming across now specifically related to Covid is ARPA funding. So, this can get kind of confusing because there are two types of ARPA funding that you were given. That you were given some ARPA funds within your contract and then you were given some outside of your contract. So, ARPA funding included with your contract, meaning like, when you go to CPARIS and you look at payments for your contract and you're seeing that you receive federal funding. That's a part of your contract. You don't report that separately as revenue in your AUD form. Now, if you got it as like stipend funding outside of your contract, but the expenses related to ARPA funding are included in that reimbursable expense section, you need to report it and there is a specific line in the form to report other unrestricted or I'm sorry, other restricted income and that's the line that you would put– report that ARPA funding in. Another one that we're coming across is the Employee Retention Tax Credit. So, agencies that applied for the Employee Retention Tax Credit based on salaries and related expenses that were paid for by the CSPP program, the related credit that was earned off that belongs to the program, and it needs to be reported as restricted income in your AUD form that it's not all of the credit that you received. It is just the portion that relates to the salaries and related expenses that were paid for by CSPP.
Now, the previous slides were all things that we could work with your CPA to try to have resolved. Now, we're moving into things that are going to end up in disallowed costs. So, the first one is indirect costs exceed 10 percent and its actually indirect costs that exceed either the lesser of 10 percent or your agency's approved indirect cost rate if you have one of those. So, this 10 percent is the maximum. You can't go over that, so we won't try to get anything revised, we'll just disallow what goes over 10 percent. The other thing that frequently results in disallowed costs is that if your agency rents from a related party. You have to have a fair market value appraisal to support that rent expense, or it can't be claimed. We see a lot where people will have an appraisal to support, or, you know, at one point they obtain an appraisal and that's great because they needed to, but when they increase the rent like, say it goes up like five percent a year, or whatever the terms of the rent agreement are, but they won't remember to go back and get another appraisal to support that the rent is still in line with fair market. So, just keep that in mind that your– you need a new one if you want to charge more than what was in your previous appraisal, you have to get a new appraisal.
Another thing is pre-approvals. So, if you, if you want to expense equipment to a contract or renovation impairs to a contract, you have to get pre-approval for that. So, if you have purchases that go over that threshold, and you did not get pre-approval, we will have to disallow the expense. The other option is– we do kind of try to go back to the CPA and say, okay, you can't expense it because you didn't get pre-approval for it, but you can claim depreciation or use allowance for the amount used by the program. So, we do work with you that way, but it's much better if you just go and get the pre-approval from your consultant beforehand. Another one, and it's a pretty big deal is to not get prior approval for a subcontract if you are, say, a CSPP center, and you subcontract out to another center to provide services to your children. That's what we're talking about here as a subcontract, and you need to get pre-approval from your consultant to do that. That can be a pretty big expense to your agency and so disallowing it can be a pretty big deal. So, you want to make sure that if you're going to subcontract that you talk to your consultant ahead of time. And another one is interest on consumer credit. So, what consumer credit is, is anything that's like credit for cash. So, like a line of credit or a credit card. It's not a specific expense. It's just cash to then go spend on something. You– your, the CSPP program is designed to pay in advance. So, interest on money is not allowable unless it's due to a delay in apportionment payments, which doesn't frequently happen. If it does, then your fiscal analyst can approve interest on a line of credit, but it's only for the amount of time that the apportionment was delayed. So, it's a very short period of time. If we see that you've claimed interest, we'll have to disallow it.
And then moving into issues that will result in your audit report being rejected. So, these are things that are going to take so long to resolve that it– that us just working with your CPA we won't get a revised audit in a reasonable amount of time. Verdette mentioned that the requirement for the audit is of the contractor, so of the agency, not just the contract, and similarly, that you have to if you subcontract out to another agency to provide childcare services. The requirement that you have to submit an audit, it flows through to that subcontractor, and they also have to have an audit performed and you're responsible for making sure that the audit gets submitted to us. So, either one of those two issues is going to result in, you know, you having to go out and getting a new audit performed, which is going to take quite some time, so we'll have to reject the audit. And the other one we'll try to work with your CPA. We provide extensions. We have a lot of leeway when we have issues that we're working with your CPA to resolve, but eventually it just takes so much time that we cannot wait anymore. So, what happens is then we'll start CCing you the agency to kind of give you a heads up, hey, we're not getting these issues resolved and we're going to end up having to reject the audit report if we don't get them resolved. So, if you start seeing a CC from us it's a good indication that we're getting to that point, and you may want to coordinate with your CPA to make sure those issues get resolved. And then again, if we, and we end up rejecting your audit, it's as if your audit was never received and it becomes delinquent and will end up in our delinquent audit list which results in your fiscal analysts placing your apportionment payments on withhold.
Once we're done with the review, we take our– the final version of the AUD form and we send it to your fiscal analyst. And they are going to be the ones that actually calculate your contract’s final earnings. And then, if we notice anything during our review that may indicate that you need technical assistance with operating your program, we'll also send a memo to your fiscal analyst and your child development consultant to let them know.
If your final earnings calculation results in a billing that is either more than 4 percent of your MRA, or more than $25,000, whichever is less, your fiscal analyst is going to let you know that you have appeal rights. Next slide.
They're going to notify you in writing that you have appeal rights and in that letter that they send you it's going to provide you with the instructions to appeal, and it gives you a timeline for appealing, which when agencies receive that I think they kind of panic and they think, oh, my gosh! We got to submit our appeal right now. I really suggest that before you submit your appeal request that you talk to your fiscal analyst, or you contact us in audits to see if you need to appeal. Like I mentioned, we have agencies that after they get their bill, they notice, wait, we didn't, we didn't report that correctly. We're missing expenses, or maybe you misreported enrollment or attendance, and it's resulting in your billing. Correcting something doesn't need to be appealed. An appeal is more like we're saying you need to report some way, you disagree with that and so we go to an independent third party in our Office of Administrative Appeals to kind of decide that for us. So, just contact us ahead of time because what happens when you appeal is that we're required within a certain amount of days to schedule that hearing and then, as soon as we schedule it, it incurs fees. There's a fee to schedule. There's a fee for attorney time and so if you guys are not– if the appeal does not result in like your agency being successful in your appeal, and a settlement does not count as being successful in that appeal, then you can be charged for those fees that are incurred for having gone through the appeal. And so, you just want to make sure that it– that you're only appealing for something that you need to appeal for. Next slide. Okay, and that's it for us.
Corey Khan: Oh, thank you. I do have one question that I saw in the chat because I think a few people asked it, but it was about whether we have as a department a list of CPAs that contractors can contact because some– it sounds like some agencies are having trouble finding CPAs within their area. So...
Laura Langston: Yeah, so we can sort of help with that. We cannot recommend a CPA, but what we can run is a report of CPAs that have performed audits for other agencies, and we can do it by county. That list is kind of outdated. So, I'm not sure that they're still in business. It's also not like our stamp of approval so we don't– we can't necessarily guarantee that they would be the best CPA to do it. So, we can help if you need that. I would say the actual best way to do it though, is to get in contact with other agencies in your area because CSPP, it's a very– because we require all those additional supplemental schedules and it's a specific program that the CPA is looking into and should be familiar with. It's good to find someone that has experience doing it and the best way to do that would be to find a CPA or find a CSPP program in your area and see, you know, do they like their CPA and if they can give you that contact information?
Corey Khan: Okay, thanks. So, we only have about 10minutes and I know that many of the representatives from the Early Education Division has hopped off for other commitments, but I see four hands raised. I'm going to call on them, but please keep it to like audits questions, or anything that maybe I can help with. I can't help with program questions. So, I'm going to call on you and hopefully we could keep it there and then get it within– be done by noon. So, the first person is Rasheedah. You can unmute yourself.
Rasheedah Shakoor: Hello, hi, my question was answered in the Q&A. Thank you.
Corey Khan: Okay, thank you. Okay, next person is Hope. Hope you can unmute yourself. Hope? No? Okay, I’m going to move on. What about Denise Gonsalves?
Denise Gonsalves: Yes, thank you. Two questions. One is– there was a review of the reconciling the family data files. What do we do if we find an error? Do we just make a note, or do we try to collect the documents?
Crystal Devlin: I just actually responded to that question in the Q&A. But yes, take case notes, document that you found these errors and then provide any type of training that the staff who conducts the enrollment process that they may need. And also, this is a good area for you to identify as part of your annual program self-evaluation, right? You have to look at items 1 through 20 in the program instrument and you could say, okay, this is what we found for items, say, it's eligibility item 2 and this is what we're going to do or have done to ensure that we meet the requirements.
Denise Gonsalves: Okay, great. Yeah, it's the person who's in charge of the center changed and the person who used to do the enrollment left. So, I'm auditing everything to just check it all. So, I'm just trying to figure out if I tried to make corrections, but it sounds like I just make notes.
Crystal Devlin: Yeah, you don't want to– you can't change anything for the family, anyway. So just yeah, make notes and use that as part of your program’s self-evaluation and continuous improvement.
Denise Gonsalves: Okay, and then my second question is for the ERTC funds. Do we report those when they're used or when they're received?
Laura Langston: Oh, I'm sorry that was me. Hi, so you report ERTC–
Crystal Devlin: (Unintelligible audio)
Laura Langston: Crystal, you're still on mute or unmuted. ERTC should be reported when you recognize the revenue for gap purposes.
Denise Gonsalves: What does recognize the revenue mean?
Laura Langston: In your financial statements when it qualifies to be recognized as revenue.
Denise Gonsalves: So when we receive it?
Laura Langston: No, not typically.
Denise Gonsalves: We're still using it.
Laura Langston: No, so that's probably a question for your CPA. So, it's when it shows up on your statement of activities as a revenue for the year, which is typically when you’ve earned it and it's more than likely that you're going to receive it.
Denise Gonsalves: Okay, we've already received it so I was just wondering if we reported for last– this last fiscal year when we received it? Or do we wait until we're using the funds? But it sounds like if we've received it, then we are supposed to be reporting it in our Attendance and Fiscal reporting, or you just mean in the audit?
Laura Langston: In your AUD form as restricted income, but it'll also it'll show up at the same time as it will in your audit because it's when you recognize it for audit purposes.
Denise Gonsalves: Okay, so it’s not something we're reporting in our Attendance and Fiscal reports. It’s something we’re including in our audit report.
Corey Khan: You, you should report it if it's going to end up being on the AUD as well.
Denise Gonsalves: Okay, so when should we report it in the Fiscal and Attendance reports for CDE?
Corey Khan: I would fall back to what Laura said and when you recognize it as revenue. Typically, you don't want to report it until you've had the expense for us, just because it'll lower your contract reimbursement, but effectively, like if you don't report the ERTC until the end until the audit report is submitted, we would have over reimbursed you throughout the year. So that's why I chimed in, just to say you'll want to report it throughout the year. I just don't know when. Usually, it's when your expenses are recorded, the associated expenses.
Denise Gonsalves: Okay, because the funds that we got were from a large organization and so not all the funds we received are actually for CSPP.
Corey Khan: You are only reporting the portion related to CSPP.
Denise Gonsalves: Okay, thank you.
Corey Khan: Yeah, okay, thank you. I'm going to move on. We have one more question or hand raised. Shannan Watkins, you can unmute yourself.
Shannan Watkins: Hi, can you hear me now?
Corey Khan: Yeah.
Shannan Watkins: Okay, so my question is around the unrestricted or the restricted–
Corey Khan: Shannan, you're cutting out a lot. I don't– I can't hear you so hopefully, if you can. I don't know if you're driving.
Shannan Watkins: Can you hear me?
Corey Khan: We can try, barely.
Shannan Watkins: Okay, let me try again. So, to preface this with, we are a co-mingled program. So, we have private pay, but we also– our private pay is subsidized children through like our ATP and CalWORKs so it's not just parent check. Now, my questions around the ERTC and the like, the food program which are recorded as restricted income. So, when I put that in as restricted income, you guys automatically deduct it off of our expenses and then you come down to this net expense, which then you break out by percentage on how many certified and how many non-certified children we are. So, in a way, it's taking away the benefit that we got for those like– so for children that we got reimbursable full program meal for, so to speak. It got reported under restricted income, but where's their portion?
Laura Langston: So, it does get allocated through that calculation, so say–
Shannan Watkins: No, I know it gets allocated to the calculation, but you're already taking it off the top of that before you do the calculations is the problem. So there– we're getting no benefit for those children, or like ERTC credit. It's all being claimed that it belongs to CSPP when in technicality a certain percentage belongs to the other part.
Laura Langston: Right, so if you're reporting CSPP and non CSPP children, the calculation reduces it from your total and then allocates it so it doesn't like allocate it to CSPP first, and then take it out. It does it first so they're both getting that allocation. They're both getting their piece of it.
Shannan Watkins: No, they don't though because I report my total net expenses, let's say $100,000. And then I report $10,000 in food program. Then that comes down to $90,000 in net expenses. Then you guys do the percentages on that.
Laura Langston: So, your AUD form has– you're reporting certified children and non-certified children in your AUD form, correct?
Shannan Watkins: Correct.
Laura Langston: And when you're reporting your total expenses in the reimbursable expense section, you're reporting expenses for all of those children, correct?
Shannan Watkins: Correct.
Laura Langston: Okay, so that's what you should be doing. The calculation it does result in both non-certified and certified children receiving an allocation of that restricted income because that reduction happens first before those net expenses get allocated. It doesn't– your expenses don't get allocated to CSPP first and then reduce by the full amount of the restricted income.
Shannan Watkins: Okay, okay thank you.
Corey Khan: Okay, we have two minutes but I'm going to go to Ernesto.
Ernesto An: Hi, thank you so much, Corey and Laura. Laura, my question is on the result of the audit after your audit investigation findings. Would you send us the report if there is a billing that will be sent to us? Normally when we receive the result, the amount that is in our GL is sometimes different from your billing. So, would you explain that on your findings?
Corey Khan: So, you're talking about the calculation worksheet that you receive after your audit has populated. So, I would say that if there's any discrepancy you want to review it, you'd want to, if you have any additional questions, you can reach out to your fiscal analyst. Like Laura said, if it turns out that like, I don't know, something was off or missing from your AUD like that might be something that we might say, oh, contact Laura's unit, the Audit and Investigation unit, request the revision. But it might just be just how the calculation worked given what the CPA might have made the adjustment for.
Laura Langston: That may be it too, maybe a communication thing with your CPA because we do work with your CPA and some AUD forms go through like multiple versions before we finally get the one that we're accepting. So maybe the CPA isn't providing you with the final copy.
Ernesto An: Yeah, actually, my question is on the bill. When we receive the billing that we owe the state. We need an explanation on that. For example, when we receive the final billing that says you– that we owe the state this much, but in our books after the audit we only have a certain amount for our due to funder or due to the state. So, how can we reconsider that if there's no explanation?
Corey Khan: That's where I said Ernesto, you should contact your fiscal analyst if you ever have questions on what the billing– how the billing was generated.
Ernesto An: Okay, okay, thank you.
Corey Khan: Yup, so we're at time. So, tomorrow we will pick up again at nine o’clock. And hopefully, you guys will all join us tomorrow. So again, any questions that we haven't been able to answer, we are downloading and hoping that we get back to them in some form. So, thank you for joining today and then we'll see you tomorrow.