COMMENT DUE DATE:
August 8, 2016
DATE:
July 28, 2016
Laura Brown, Adult and Family Services Policy Liaison (405) 521-4396
Dena Thayer, Legal Services Programs Administrator 405-521-4326
Nancy Kelly, Legal Services Policy Specialist 405-522-6703
RE:
APA WF 16-03
The proposed policy is Emergency . This proposal is subject to Administrative Procedures Act
It is important that you provide your comments regarding the draft copy of policy by the comment due date. Comments are directed to Legal Services - Policy, *STO.Legal Services.Policy.
Emergency revisions have a proposed effective date of October 1, 2016.
SUBJECT:CHAPTER 40. CHILD CARE SUBSIDY PROGRAM
Subchapter 1 General Provisions
OAC 340:40-1-2
Subchapter 3. Initial Application
OAC 340:40-03-1 [AMENDED]
Subchapter 7. Eligibility
OAC 340:40-7-3 [AMENDED]
OAC 340:40-7-5 [AMENDED]
OAC 340:40-7-6 [AMENDED}
OAC 340:40-7-7 [AMENDED]
OAC 340:40-7-8 [AMENDED]
OAC 340:40-7-9 [AMENDED]
OAC 340:40-7-11 [AMENDED
OAC 340:40-7-12 [AMENDED]
Subchapter 9. Procedures Related To Case Changes
OAC 340:40-9-1 [AMENDED]
OAC 340:40-9-2 [AMENDED]
Subchapter 13. Child Care Rates and Provider Issues
OAC 340:40-13-3 [AMENDED]
Subchapter 17. Enrollment Freeze [NEW]
OAC 340:40-17-1 [NEW]
(Reference WF 16-03)
SUMMARY:The proposed revisions to Chapter 40, Subchapter 1 amend the rules to:(1) add the Child Care and Development Block Grant Act (CCDBG) of 2014, Public Law (P.L.) 113-186to the legal authority for the Child Care Subsidy Program; and (2) update terminology.
The proposed revisions to Chapter 40, Subchapter 3 amend the rules to:(1) rename expedited eligibility processing to presumptive eligibility processing, expand the reasons for an initial 30-calendar day approval, and clarify eligibility requirements prior to approval and before further care is approved; (2) update terminology regarding request, application, and certification dates to match systems fields; (3) clarify that the child care interview may be completed over the phone and must be completed prior to determining the applicant eligible; (4) add required 12-month eligibility period; (5) clarify when a new application is needed following a denial; (6) add legal and policy cites; (7) update a form name; and (8) simplify and clarify terminology.
The proposed revisions to Chapter 40, Subchapter 7 amend the rules to:(1) allow a child to remain eligible for child care until renewal when the child's 13th or, for a child with disabilities or under court supervision, 19th birthday falls during an eligibility period; (2) add an eligibility requirement that household resources may not exceed $1,000,000 to qualify for subsidized child care; (3) add resource types; (4) add a definition for a person acting in the role of a spouse; (5) remove gender information when considering whether to count the income of an adult non-relative living in the child care household; (6) add definition for acting in the role of spouse; (7) simplify and clarify the eligibility process when parents share custody of the child; (8) add Supplemental Nutrition Assistance Program (SNAP) Education and Training (E&T) activities as an allowable need factor; (9) remove job search as an allowable need factor; (10) remove court-ordered community service hours as a non-allowable need factor for child care subsidy; (11) allow child care to remain open until renewal, when after initial approval, the client begins new employment with an employer who refuses to pay the client at least minimum wage; (12) allow child care to remain open until renewal when the client is not making at least minimum wage and has been self-employed or working for an employer paying wages based on commission or another performance measure for less than one year; (13) add qualifications to when child care is approved for a person working from home; (14) remove job search as meeting the employment need factor for child care subsidy for clients who lose employment or complete an education or training program; (15) change proof of progress and attendance requirements from when requested or as a class ends to at renewal for the training and education need factors; (16) remove the requirement to provide proof of initial education or literacy level testing results when child care is requested to participate in high school equivalency, literacy, or adult basic education (ABE) classes; (17) change the time frame for not approving further child care, to at renewal when the client is not making satisfactory progress or stops attending training or education during an eligibility period; (18) add approval requirements for the SNAP E&T need factor and time frame for discontinuing child care when the client stops participating; (19) update TANF related subsidized child care to: (a) remove limited approval period for TANF clients waiting to enter an approved TANF Work activity and TANF applicants in job search, (b) include child care for a child included in a child only TANF benefit, and (c) include time frame for discontinuing child care when the client stops meeting a need factor; (20) for protective or preventive child care: (a) reorder information, (b) remove the face-to-face interview requirement, (c) add reasons protective or preventive child care may be approved, (d) add definition of homeless and when a homeless family or a family that experienced a natural disaster may be approved for child care, and (e) clarify procedures to request approval for more than 30-calendar days of care; (21) remove the requirement that a minor parent must pursue child support for his or her own child; (22) update terminology regarding a non-relative adult considered a household member to remove gender information and use the term acting in the role of a spouse; (23) add information that a person in non-cooperation status with Child Support Services (CSS) at application must verify cooperation before approval; (24) change the requirement to close child care when a client fails to cooperate with CSS during an eligibility period from 10-calendar days to not approving further care at renewal; (25) change the requirement to pursue identified potential income from 90-calendar days to before the next child care renewal; (26) change the requirement to close child care when the client does not pursue potential identified income, accept a pay raise, or decreases work hours or pay rate to decrease or avoid a family share copayment during an eligibility period to not approving further care at renewal; (27) remove no longer applicable information regarding calculation of self-employment income from a new source; (28) remove gender information and update terminology regarding a non-relative adult; (29) change the time frame regarding when a client must take action to become the payee for a Social Security Administration (SSA) benefit when appropriate; (30) allow an eligible child adopted through the Oklahoma Department of Human Services (DHS) to remain eligible for child care with a household income exemption until renewal when the child turns 6 years of age during an eligibility period; (31) exclude all educational income; (32) update and simplify language and terminology; and (33) add, remove, and update policy and legal cites.
The proposed revisions to Chapter 40, Subchapter 9 amend the rules to:(1) change the child care renewal time frame from six months to no earlier than 12 months from the date of approval or last renewal unless the client applies for food benefits before the next renewal; (2) remove the requirement for a face-to-face interview at renewal for the protective or preventive need factor; (3) clarify information regarding income changes and advance notice procedures when child care benefits decrease; (4) add effective dates for different types of closure actions; (5) clarify that a new child care application based on the adoptive parent's income is not required until renewal when a child adopted through DHS turns 6 years of age during an eligibility period; (6) add a policy cite; and (7) update terminology and simplify language.
The proposed revisions to Chapter 40, Subchapter 13 amend the rules to: (1) remove information regarding when eligibility stops because of a child's age as it is duplicated in another section and is not rate related; and (2) update terminology and a form name; and (3) simplify language.
The proposed addition of Chapter 40, Subchapter 17 is created to include information regarding establishment of an enrollment freeze when funding is not available to provide child care benefits to all eligible families, explaining that an enrollment freeze affects new applicants and not existing child care clients, and allowing for new application approvals from designated priority groups.
LEGAL AUTHORITY:Director of Human Services;Section 162 of Title 56 of the Oklahoma Statutes; CCDBG Act of 2014, P.L. 113-186; and Title 45 of the Code of Federal Regulations Parts 98 and 99.
Rule Impact Statement
To:Programs Administrator
Legal Services - Policy
From:Jim Struby, Director
Adult and Family Services
Date:June 22, 2016
Re:CHAPTER 40. CHILD CARE SUBSIDY PROGRAM
Subchapter 1. General Provisions
OAC 340:40-1-2 [AMENDED]
Subchapter 3. Initial Application
OAC 340:40-3-1 [AMENDED]
Subchapter 7. Eligibility
OAC 340:40-7-3 [AMENDED]
OAC 340:40-7-5 through 340:40-7-9 [AMENDED]
OAC 340:40-7-11 through 340:40-7-12 [AMENDED]
Subchapter 9. Procedures Relating to Case Changes
OAC 340:40-9-1 through 340:40-9-2 [AMENDED]
Subchapter 13. Child Care Rates and Provider Issues
OAC 340:40-13-3 [AMENDED]
Subchapter 17. Enrollment Freeze [NEW]
OAC 340:40-17-1 [NEW]
Contact:Laura Brown 405-521-4396
A.Brief description of the purpose of the proposed rule:
Purpose.The proposed revisions to Chapter 40, Subchapter 1 amend the rules to:(1) add the Child Care and Development Block Grant Act (CCDBG) of 2014, Public Law (P.L.) 113-186to the legal authority for the Child Care Subsidy Program; and (2) update terminology.
The proposed revisions to Chapter 40, Subchapter 3 amend the rules to: (1) rename expedited eligibility processing to presumptive eligibility processing, expand the reasons for an initial 30-calendar day approval, and clarify eligibility requirements prior to approval and before further care is approved; (2) update terminology regarding request, application, and certification dates to match systems fields; (3) clarify that the child care interview may be completed over the phone and must be completed prior to determining the applicant eligible; (4) add required 12-month eligibility period; (5) clarify when a new application is needed following a denial; (6) add legal and policy cites; (7) update a form name; and (8) simplify and clarify terminology.
The proposed revisions to Chapter 40, Subchapter 7 amend the rules to:(1) allow a child to remain eligible for child care until renewal when the child's 13th or, for a child with disabilities or under court supervision, 19th birthday falls during an eligibility period; (2) add an eligibility requirement that household resources may not exceed $1,000,000 to qualify for subsidized child care; (3) add resource types; (4) add a definition for a person acting in the role of a spouse; (5) remove gender information when considering whether to count the income of an adult non-relative living in the child care household; (6) add definition for acting in the role of spouse; (7) simplify and clarify the eligibility process when parents share custody of the child; (8) add Supplemental Nutrition Assistance Program (SNAP) Education and Training (E&T) activities as an allowable need factor; (9) remove job search as an allowable need factor; (10) remove court-ordered community service hours as a non-allowable need factor for child care subsidy; (11) allow child care to remain open until renewal, when after initial approval, the client begins new employment with an employer who refuses to pay the client at least minimum wage; (12) allow child care to remain open until renewal when the client is not making at least minimum wage and has been self-employed or working for an employer paying wages based on commission or another performance measure for less than one year; (13) add qualifications to when child care is approved for a person working from home; (14) remove job search as meeting the employment need factor for child care subsidy for clients who lose employment or complete an education or training program; (15) change proof of progress and attendance requirements from when requested or as a class ends to at renewal for the training and education need factors; (16) remove the requirement to provide proof of initial education or literacy level testing results when child care is requested to participate in high school equivalency, literacy, or adult basic education (ABE) classes; (17) change the time frame for not approving further child care, to at renewal when the client is not making satisfactory progress or stops attending training or education during an eligibility period; (18) add approval requirements for the SNAP E&T need factor and time frame for discontinuing child care when the client stops participating; (19) update TANF related subsidized child care to: (a) remove limited approval period for TANF clients waiting to enter an approved TANF Work activity and TANF applicants in job search, (b) include child care for a child included in a child only TANF benefit, and (c) include time frame for discontinuing child care when the client stops meeting a need factor; (20) for protective or preventive child care: (a) reorder information, (b) remove the face-to-face interview requirement, (c) add reasons protective or preventive child care may be approved, (d) add definition of homeless and when a homeless family or a family that experienced a natural disaster may be approved for child care, and (e) clarify procedures to request approval for more than 30-calendar days of care; (21) remove the requirement that a minor parent must pursue child support for his or her own child; (22) update terminology regarding a non-relative adult considered a household member to remove gender information and use the term acting in the role of a spouse; (23) add information that a person in non-cooperation status with Child Support Services (CSS) at application must verify cooperation before approval; (24) change the requirement to close child care when a client fails to cooperate with CSS during an eligibility period from 10-calendar days to not approving further care at renewal; (25) change the requirement to pursue identified potential income from 90-calendar days to before the next child care renewal; (26) change the requirement to close child care when the client does not pursue potential identified income, accept a pay raise, or decreases work hours or pay rate to decrease or avoid a family share copayment during an eligibility period to not approving further care at renewal; (27) remove no longer applicable information regarding calculation of self-employment income from a new source; (28) remove gender information and update terminology regarding a non-relative adult; (29) change the time frame regarding when a client must take action to become the payee for a Social Security Administration (SSA) benefit when appropriate; (30) allow an eligible child adopted through the Oklahoma Department of Human Services (DHS) to remain eligible for child care with a household income exemption until renewal when the child turns 6 years of age during an eligibility period; (31) exclude all educational income; (32) update and simplify language and terminology; and (33) add, remove, and update policy and legal cites.
The proposed revisions to Chapter 40, Subchapter 9 amend the rules to:(1) change the child care renewal time frame from six months to no earlier than 12 months from the date of approval or last renewal unless the client applies for food benefits before the next renewal; (2) remove the requirement for a face-to-face interview at renewal for the protective or preventive need factor; (3) clarify information regarding income changes and advance notice procedures when child care benefits decrease; (4) add effective dates for different types of closure actions; (5) clarify that a new child care application based on the adoptive parent's income is not required until renewal when a child adopted through DHS turns 6 years of age during an eligibility period; (6) add a policy cite; and (7) update terminology and simplify language.
The proposed revisions to Chapter 40, Subchapter 13 amend the rules to: (1) remove information regarding when eligibility stops because of a child's age as it is duplicated in another section and is not rate related; and (2) update terminology and a form name; and (3) simplify language.
The proposed addition of Chapter 40, Subchapter 17 is created to include information regarding establishment of an enrollment freeze when funding is not available to provide child care benefits to all eligible families, explaining that an enrollment freeze affects new applicants and not existing child care clients, and allowing for new application approvals from designated priority groups.
Strategic Plan impact. The proposed rules achieve the DHS goal of complying with the CCDBG of 2014, P.L. 113-186, while continuously improving systems and processes.
Substantive changes.
Subchapter 1. General Provisions
Oklahoma Administrative Code (OAC) 340:40-1-2 is amended to:(1) add the CCDBG of 2014 to the legal authority for the Child Care Subsidy Program; and (2) update terminology
Subchapter 3. Initial Application
OAC 340:40-3-1 is amended to: (1) rename expedited eligibility processing to presumptive eligibility processing, expand the reasons for an initial 30-calendar day approval, and clarify eligibility requirements prior to approval and before further care is approved; (2) update terminology regarding request, application, and certification dates to match systems fields; (3) clarify that the child care interview may be completed over the phone and must be completed prior to determining the applicant eligible; (4) add required 12-month eligibility period; (5) clarify when a new application is needed following a denial; (6) add legal and policy cites; (7) update a form name; and (8) simplify and clarify terminology.
Subchapter 7. Eligibility
OAC 340:40-7-3 is amended to:(1) allow a child to remain eligible for child care until renewal when the child's 13th or, for a child with disabilities or under court supervision, 19th birthday falls during an eligibility period; and (2) update terminology.
OAC 340:40-7-5 is amended to: (1) add an eligibility requirement that household resources may not exceed $1,000,000 to qualify for subsidized child care; (2) add resource types; (3) add legal cite; (4) update terminology; and (5) simplify language.
OAC 340:40-7-6 is amended to: (1) remove gender information when considering whether to count the income of an adult non-relative living with the child care household; (2) add a definition for a person acting in the role of a spouse; (3) remove no longer valid policy cite; and (4) simplify and clarify eligibility process when parents share custody of the child.
OAC 340:40-7-7 is amended to:(1) add SNAP E&T activities as an allowable need factor; (2) remove job search as an allowable need factor and a no longer applicable policy cite; (3) remove court-ordered community service hours as a non-allowable need factor for child care subsidy; and (4) simplify and update terminology.
OAC 340:40-7-8 is amended to: (1) allow child care to remain open until renewal when, after initial approval, the client begins new employment with an employer who refuses to pay the client at least minimum wage; (2) allow child care to remain open until renewal when the client is not making at least minimum wage and has been self-employed or working for an employer paying wages based on commission or another performance measure for less than one year; (3) add qualifications to when child care is approved for a person working from home; (4) remove job search as meeting the employment need factor for child care subsidy for clients who lose employment or complete an education or training program; (5) change proof of progress and attendance requirements from when requested or as a class ends to at renewal for the training and education need factors; (6) remove the requirement to provide proof of initial education or literacy level testing results when child care is requested to participate in high school equivalency, literacy, or ABE classes; (7) change the time frame for not approving further child care to at renewal when the client is not making satisfactory progress or stops attending training or education during an eligibility period; (8) add approval requirements for the SNAP E&T need factor and time frame for discontinuing child care when the client stops participating; (9) update Temporary Assistance for Needy Families (TANF) related subsidized child care to: (a) remove limited approval period for TANF clients waiting to enter an approved TANF Work activity and TANF applicants in job search, (b) include child care for a child included in a child only TANF benefit, and (c) include time frame for discontinuing child care when the client stops meeting a need factor; (10) for protective or preventive child care: (a) reorder information, (b) remove the face-to-face interview requirement, (c) add reasons protective or preventive child care may be approved, (d) add definition of homeless and when a homeless family or a family that experienced a natural disaster may be approved for child care, and (e) clarify procedures to request approval for more than 30-calendar days of care; (11) remove no longer applicable policy cite; and (12) simplify and update language and terminology.
OAC 340:40-7-9 is amended to: (1) remove the requirement that a minor parentmust pursue child support for his or her own child; (2) update terminology regarding a non-relative adult considered a household member to remove gender information and use the term acting in the role of a spouse; (3) add information that a person in non-cooperation status with CSS at application must verify cooperation before approval; (4) change the requirement to close child care when a client fails to cooperate with CSS during an eligibility period from 10-calendar days to not approving further care at renewal; (5) change the requirement to pursue identified potential income from 90-calendar days to before the next child care renewal; and (6) change the requirement to close child care when the client does not pursue potential identified income, accept a pay raise, or decreases work hours or pay rate to decrease or avoid a family share copayment during an eligibility period to not approving further care at renewal.
OAC 340:40-7-11 is amended to:(1) remove no longer applicable information regarding calculation of self-employment income from a new source; (2) remove gender information and update terminology regarding a non-relative adult; (3) remove duplicative on-the-job training information; (4) change the time frame regarding when a client must take action to become the payee for a SSA benefit when appropriate; and (5) update a legal cite.
OAC 340:40-7-12 is amended to:(1) allow an eligible child adopted through DHS to remain eligible for child care with a household income exemption until renewal when the child turns 6 years of age during an eligibility period; (2) exclude all educational income; and (3) update a legal cite.
Subchapter 9. Procedures Relating to Case Changes
OAC 340:40-9-1 is amended to: (1) change the child care renewal time frame from six months to no earlier than 12 months from the date of approval or last renewal unless the client applies for food benefits before the next renewal; (2) remove the requirement for a face-to-face interview at renewal for the protective or preventive need factor; (3) add a policy cite; and (4) simplify language and update terminology.
OAC 340:40-9-2 is amended to: (1) clarify information regarding income changes and advance notice procedures when child care benefits decrease; (2) add effective dates for different types of closure actions; and (3) clarify that a new child care application based on the adoptive parent's income is not required until renewal when a child adopted through DHS turns 6 years of age during an eligibility period.
Subchapter 13. Child Care Rates and Provider Issues
OAC 340:40-13-3 is amended to: (1) remove information regarding when eligibility stops because of a child's age as it is duplicated in another section and is not rate related; (2) update terminology and a form name; and (3) simplify language.
Subchapter 17. Enrollment Freeze Subchapter 17.
OAC 340:40-17-1 is created to include information regarding establishment of an enrollment freeze when funding is not available to provide child care benefits to all eligible families, explaining that an enrollment freeze affects new applicants and not existing child care clients, and allowing for new application approvals from designated, priority groups.
Reasons. The proposed revisions are necessary to comply with provisions in the CCDBG Act of 2014, as stated in this section, and due to budget constraints, information regarding establishment of an enrollment freeze is added.
To comply with the 12-month minimum eligibility period provision in the CCDBG Act of 2014, the following revisions are being made:
•a 30-calendar day presumptive eligibility period is established for uncertain situations in which a complete eligibility determination was not made;
•all child care renewals are set at 12- month intervals;
•children turning the maximum eligibility age during an eligibility period continue to receive assistance until the child care renewal is due;
•clients that stop meeting a need factor during the 12-month eligibility period are allowed to continue using child care until the renewal is due unless the need factor is based on SNAP E&T activities or TANF related activities;
•the 90-calendar day job search period when employment is lost or education or training is completed is removed because clients remain eligible until renewal;
•after certification, a client's cooperation with CSS or in pursuing potential income is not reviewed until the renewal is due to determine cooperation status;
•a child adopted through DHS who turns 6 years of age during an eligibility period is allowed to remain eligible without consideration of the adoptive parent's income until the renewal is due; and
•effective dates for different types of closure actions are added.
To comply with the resource eligibility provision per the CCDBG Act of 2014, the $1,000,000 maximum resource limit is added to rules.
Reasons for protective or preventive child care are expanded to include situations in which families are homeless or experience a natural disaster to comply with provisions in the CCDBG Act of 2014.
The proposed revision to add information regarding establishment of an enrollment freeze is added to inform clients, staff, and the public that this may occur when funding is not available to provide child care benefits to all eligible families and is in response to the enrollment freeze that occurred in June and July of 2016.
The proposed rules throughout the subchapters are amended to make policy easier to understand for clients, staff, child care providers, and the public, less error prone for staff, to ensure benefits are issued properly and renewed appropriately.
Repercussions.If the proposed revisions are not implemented by the federal deadline of September 30, 2016, Oklahoma will not meet CCDBG Act of 2014 requirements and may result in financial penalties to DHS.
Legal authority. Director of Human Services;Section 162 of Title 56 of the Oklahoma Statutes; CCDBG Act of 2014, P.L. 113-186; and Title 45 of the Code of Federal Regulations Parts 98 and 99.
Emergency rulemaking approval is requested effective October 1, 2016 to meet the federal deadline for implementation of the CCDBG Act of 2014, P.L. 113-186 and to have rules in place in the event of a future enrollment freeze.
B.A description of the classes of persons who most likely will be affected by the proposed rule, including classes that will bear the costs of the proposed rule, and any information on cost impacts received by the Agency from any private or public entities:The classes of persons most likely to be affected by the proposed rules are DHS staff, clients applying for or receiving subsidized child care benefits, and child care providers.
C.A description of the classes of persons who will benefit from the proposed rule:The classes of persons who will benefit are DHS staff, clients applying for or receiving subsidized child care benefits, and child care providers.
D.A description of the probable economic impact of the proposed rule upon the affected classes of persons or political subdivisions, including a listing of all fee changes and, whenever possible, a separate justification for each fee change: The revised rules have a positive economic impact on the clients receiving child care subsidy benefits and their children by allowing them to receive 12 months of continued eligibility and care from the same child care provider.Providers will continue to receive subsidy for children who previously became ineligible due to loss of the parent’s need factor.Allowing children to remain on subsidy for 12 months allows payment stability for providers.
E.The probable costs and benefits to the Agency and to any other agency of the implementation and enforcement of the proposed rule, the source of revenue to be used for implementation and enforcement of the proposed rule and any anticipated effect on state revenues, including a projected net loss or gain in such revenues if it can be projected by the Agency:The revised rules will result in enhanced delivery of services to positively impact children and families.The estimated cost for implementation of the proposed rules is $2,750,000, which is covered by federal funds and mandated by the CCDBG Act of 2014, P.L. 113-186.The probable DHS cost of printing and distributing the rules is estimated to be less than $20.
F.A determination whether implementation of the proposed rule will have an impact on any political subdivisions or require their cooperation in implementing or enforcing the rule:The proposed rules do not have an economic impact on any political subdivision, nor will the cooperation of any political subdivisions be required in implementation or enforcement of the rules.
G.A determination whether implementation of the proposed rule will have an adverse economic effect on small business as provided by the Oklahoma Small Business Regulatory Flexibility Act: There are no anticipated adverse effects on small business as provided by the Oklahoma Small Business Regulatory Flexibility Act.
H.An explanation of the measures the Agency has taken to minimize compliance costs and a determination whether there are less costly or nonregulatory methods or less intrusive methods for achieving the purpose of the proposed rule: There are no less costly or nonregulatory methods or less intrusive methods for achieving the purpose of the proposed rules as the revisions are required by the CCDBG Act of 2014.
I.A determination of the effect of the proposed rule on the public health, safety, and environment and, if the proposed rule is designed to reduce significant risks to the public health, safety, and environment, an explanation of the nature of the risk and to what extent the proposed rule will reduce the risk:The proposed rules protect the health and safety of children by allowing children to remain eligible for subsidized child care for 12 months when the parent or caretaker loses a need factor during the eligibility period.
J.A determination of any detrimental effect on the public health, safety, and environment if the proposed rule is not implemented:If the proposed rule revisions are not implemented, DHS will be non-compliant with federal requirements that may result in penalties further exacerbating limited child care funding and increasing safety risks to children who lose stable and licensed child care.
K.The date the rule impact statement was prepared and, if modified, the date modified: Prepared June 22, 2016; modified July 22, 2016.
