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COMMENT DUE DATE:  

February 14, 2020

DATE: 

January 15, 2020

Laura Brown, Adult and Family Services 405-521-4396

Dena Thayer, Programs Administrator, Legal Services - Policy 405-521-4326

Nancy Kelly, Policy Specialist, Legal Services - Policy 405-522-6703

RE:  

APA WF 20-40

It is very important that you provide your comments regarding the DRAFT COPY of policy by the comment due date. Comments are directed to *STO.LegalServices.Policy@okdhs.org

The proposed policy is  Permanent .  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 *STO.LegalServices.Policy@okdhs.org.The proposed amendments are permanent.

A public hearing is scheduled for 10:00 a.m. on February 24, 2020, at DHS, Sequoyah Memorial Office Building, 2400 N. Lincoln Boulevard, Oklahoma City, Oklahoma 73105, Room C-48.Anyone who wants to speak must sign in at the door by 10:05 a.m.

SUBJECT:CHAPTER 40. CHILD CARE SUBSIDY PROGRAM

Subchapter 1. General Provisions

340:40-1-6 [AMENDED]

Subchapter 3. Initial Application

340:40-3-1 [AMENDED]

Subchapter 5. Child Care Plan

340:40-5-1 [AMENDED]

Subchapter 7. Eligibility

340:40-7-1 [AMENDED]

340:40-7-2 [REVOKED]

340:40-7-6 [AMENDED]

340:40-7-7 [AMENDED]

340:40-7-9 [AMENDED]

340:40-7-10 [AMENDED]

340:40-7-11 [AMENDED]

340:40-7-12 and 340:40-7-13 [AMENDED]

Subchapter 9. Procedures Relating To Case Changes

340:40-9-1 [AMENDED]

340:40-9-2 [AMENDED]

Subchapter 10. Electronic Benefit Transfer (EBT) System for Child Care

340:40-10-1 through 340:40-10-4 [AMENDED]

Subchapter 13. Child Care Rates and Provider Issues

340:40-13-3 [AMENDED]

340:40-13-5 [AMENDED]

Subchapter 16. Improper Payments Error Rate Review Process

340:40-16-1 [AMENDED]

(Reference APA WF 18-17 and 20-40)

SUMMARY:

The proposed amendments to Chapter 40, Subchapter 1 amend the rules to: (1) update and add clarifying language and terminology; (2) add child development as a goal of the child care subsidy program; and (3) remove a child care partnership that no longer exists.

The proposed revisions to Chapter 40, Subchapter 3 amend the rules to: (1) remove reference to an exit income threshold; and (2) update a rule citation.

The proposed revisions to Chapter 40 Subchapter 5 amend the rules to: (1) exempt Oklahoma Early Childhood Program (OECP) facilities from the requirement to charge all parents for the hours child care subsidy payment is requested to promote higher quality child care; and (2) remove reference to an entry and exit income threshold and that the number of children in child care affects the family share copayment amount.

The proposed revisions to Chapter 40 Subchapter 7 amend the rules to (1) remove a no longer applicable example regarding when a child is not predetermined income eligible for a zero copayment; (2) clarify when one parent or caretaker is not participating in Supplemental Nutrition Assistance Program (SNAP) Education and Training (E&T) activities, that parent must meet another need factor for child care during the same hours; and (3) approve children attending an OECP for a weekly unit type as long as the parent or caretaker meets a need for child care during some of the OECP care hours to promote higher quality: care; (4) exempt household income when at least one child attends an OECP and the household meets income guidelines; (5) remove reference to an entry and exit income threshold (6) update legal citations regarding excluded income from programs under the Older Americans Act as reauthorized and remove specific organizations receiving these funds; (7) exclude military combat pay from income consideration; (8) update rule and legal citations; (9) remove rule citations; (10) revoke a section which is no longer needed; (11) remove the definition for adult non-relatives; (12) remove adult non-relatives acting in the role of a spouse and their children from household composition and income consideration; (13) remove reference to an adult non-relative’s child from the child support pursuit rule; (14) update and clarify language regarding requesting good cause to not pursue child support; (15) add information regarding when income received from an S corporation is considered as earned or unearned income; (16) update how profit sharing income from S corporations, general or limited partnerships, or limited liability companies (LLC) is considered; and (17) remove reference to income from a roomer or boarder who is acting in the roll of spouse.

The proposed revisions to Chapter 40 Subchapter 9 amend the rules to: (1) remove reference to an exit income threshold.

The proposed amendments to Chapter 40, Subchapter 10 amend rules to:(1) update and clarify language and terminology; and (2) remove a form that is no longer valid.

The proposed amendments to Chapter 40, Subchapter 13 amend rules to:(1) remove the county in which the provider provides care as a determining factor in the rate paid to that provider; (2) add proof of ownership verification as a requirement to obtain a contract; (3) add to the changes that a provider must report timely:(a) a change in the legal name of the business; (b) a change in the responsible person or legal name change of the person who is the authorized contract signor; (c) the provider's disqualification, suspension, or disbarment from any federal program; (d) when a person with ownership interest or a relationship with the provider is convicted of a criminal offense or fraud-related crime; and (e) a provider address change; (4) add that the provider must advise Child Care Subsidy staff of the expected date of return to the contracted facility when requesting a temporary change of location; and (5) update and clarify language and terminology.

The proposed amendment to Chapter 40, Subchapter 16 amends the rules to clarify the definition and purpose of the Improper Payments Error Rate Review process.

 

PERMANENT APPROVAL:Permanent rulemaking is requested.

LEGAL AUTHORITY:Director of Human Services; Section 162 of Title 56 of the Oklahoma Statutes; Section 658A of the Child Care Development Block Grant Act of 2014 [Public .Law 113-186]; and Sections 98.11, 98.16, and 98.20 through 98.21 of Title 45 of the Code of Federal Regulations.

Rule Impact Statement

To:Programs Administrator

Office of Intergovernmental Relations and Policy

From:Patrick Klein, Director

                Adult and Family Services

Date:December 13, 2019

Re:CHAPTER 40. CHILD CARE SUBSIDY PROGRAM

Subchapter 3. Initial Application

OAC 340:40-3-1 [AMENDED]

Subchapter 5. Child Care Plan

OAC 340:40-5-1 [AMENDED]

Subchapter 7. Eligibility

OAC 340:40-7-1 [AMENDED]

OAC 340:40-7-7 [AMENDED]

OAC 340:40-7-10 [AMENDED]

OAC 340:40-7-12 and OAC 340:40-7-13 [AMENDED]

Subchapter 9. Procedures Relating To Case Changes

OAC 340:40-9-1 [AMENDED]

OAC 340:40-9-2 [AMENDED]

(Reference APA WF 18-17)

Contact:Laura Brown 405-521-4396

A.Brief description of the purpose of the proposed rule:

Purpose.The proposed revisions to Chapter 40, Subchapter 3 amend the rules to: (1) remove reference to an exit income threshold; and (2) update a rule citation.

The proposed revisions to Chapter 40 Subchapter 5 amend the rules to: (1) exempt Oklahoma Early Childhood Program (OECP) facilities from the requirement to charge all parents for the hours child care subsidy payment is requested to promote higher quality child care; and (2) remove reference to an entry and exit income threshold and that the number of children in child care affects the family share copayment amount.

The proposed revisions to Chapter 40 Subchapter 7 amend the rules to (1) remove a no longer applicable example regarding when a child is not predetermined income eligible for a zero copayment; (2) clarify when one parent or caretaker is not participating in Supplemental Nutrition Assistance Program (SNAP) Education and Training (E&T) activities, that parent must meet another need factor for child care during the same hours; and (3) approve children attending an OECP for a weekly unit type as long as the parent or caretaker meets a need for child care during some of the OECP care hours to promote higher quality: care; (4) exempt household income when at least one child attends an OECP and the household meets income guidelines; (5) remove reference to an entry and exit income threshold (6) update legal citations regarding excluded income from programs under the Older Americans Act as reauthorized and remove specific organizations receiving these funds; (7) exclude military combat pay from income consideration; (8) update rule and legal citations; and (9) remove rule citations.

The proposed revisions to Chapter 40 Subchapter 9 amend the rules to: (1) remove reference to an exit income threshold.

Strategic Plan impact. The proposed rules achieve the Oklahoma Department of Human Services (DHS) goal of continuously improving systems and processes.

Substantive changes.

Subchapter 3. Initial Application

OAC 340:40-3-1 is amended to: (1) remove reference to an exit income threshold; and (2) update a rule citation.

Subchapter 5. Child Care Plan

OAC 340:40-5-1 is amended to: (1)exempt OECP facilities from the requirement to charge all parents for the hours child care subsidy payment is requested to promote higher quality child care; and (2) remove reference to an entry and exit income threshold and the provision that the number of children in child care affects the family share copayment amount.

Subchapter 7. Eligibility

OAC 340:40-7-1 is amended to remove a no longer applicable example regarding when a child is not predetermined income eligible for a zero copayment.

OAC 340:40-7-7 is amended to (1) clarify when one parent or caretaker is not participating in SNAP E&T activities, that parent must meet another need factor for child care during the same hours; (2) allow children attending an OECP to receive a weekly unit type as long as the parent or caretaker meets a need for child care during some of the OECP care hours to promote higher quality: care; and (3) update rule citations.

OAC 340:40-7-10 is amended to:(1) remove reference to a federal exit income threshold; and (2) remove a rule citation.

OAC 340:40-7-12 is amended to:(1) exempt household income when at least one child attends an OECP and the household meets income guidelines; (2) update legal citations regarding excluded income from programs under the Older Americans Act as reauthorized and the organizations that may receive these funds; and (3) exclude military combat pay from income consideration.

OAC 340:40-7-13 is amended to:(1) remove reference to two income thresholds; (2) remove a rule citation; and (3) update a legal citation.

Subchapter 9. Procedures Relating To Case Changes

OAC 340:40-9-1 is amended to remove the graduated phase out of care provision.

OAC 340:40-9-2 is amended to remove reference to an exit income threshold.

Reasons. The proposed amendment to remove the graduated phase out of care provision, reference to an entry and exit income threshold and the provision that when the number of children in care increases, the family share copayment increases are made as the income threshold on Appendix C-4, Child Care Eligibility/Copayment Chart is being updated to raise the income threshold for all families to the federal income threshold and to no longer increase the family share copayment when the number of children in child care increases.These changes will increase the number of families eligible for high quality, subsidized child care and is made possible because of the increased discretionary Child Care and Development Fund (CCDF) funding received as a result of passage of the Bipartisan Budget Act of 2018.

The proposed revisions to approve children attending an OECP facility for a weekly unit type and exempting household income when a child attends an OECP facility are made to benefit low-income families by increasing access to child care and providing high-quality early learning opportunities for young children. Decades of research show that the experiences infants and toddlers have in their earliest years shape the architecture of the brain and have long-term impacts on human development such as success in school and the ability to earn higher wages as adults.At the same time, the proposed changes increase the employability and stability of parents and reduce the impact of poverty on children.Studies have shown that access to reliable child care contributes to increased employment and earnings for parents.

The proposed amendment to exclude military combat pay from income consideration and update the legal citations for Title III and Title V funds excluded under the Older Americans Act and the organizations that receive the funds are made to align Child Care Subsidy rules with SNAP rules.

Repercussions.If the proposed revisions are not implemented by September 2019, the Oklahoma Department of Human Services may lose the increased Child Care and Development Funding that allows DHS to serve more low-income families by raising the income threshold and reducing the family share copayment amounts and allows children to attend OECP providers and reap the benefits of the enriched environment.

Legal authority. Director of Human Services; Section 162 of Title 56 of the Oklahoma Statutes; Section 658A of the Child Care Development Block Grant Act of 2014 [Public .Law 113-186]; and Sections 98.11, 98.16, and 98.20 through 98.21 of Title 45 of the Code of Federal Regulations.

Permanent rulemaking approval is requested. The rules listed in this Rule Impact Statement were approved by the Governor as emergency rules on February 8, 2019 and were effective March 1, 2019.

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 class 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 proposed rules have a positive economic impact on the clients receiving child care subsidy benefits and their children to attend child care in a high quality environment with no financial burden to the child care household.The proposed rules will also provide payment stability for OECP facilities.

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 proposed rules will result in enhanced delivery of services to positively impact children and families.The probable DHS cost of printing and distributing the rules is estimated to be less than $20.The revised rule to allow child care providers to be reimbursed for the full week of care for children attending OECP is estimated to cost $1,583,578 annually.The data is based on the number of children currently authorized to receive wrap around care at child care facilities with OECP programs.The costs associated with these revisions are 100 percent federally funded; there are no costs to the State.The revised rules which support revisions to the Appendix C-4, Child Care Eligibility/Copayment Chart, is estimated to cost $6,176,160 annually.  The data is based on current utilization of the Child Care Subsidy Program.The costs associated with these revisions are 100 percent federally funded; there are no costs to the State.

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, nonregulatory, or intrusive methods for achieving the purpose of the proposed rules.

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:(1) raising the income threshold for all parents to the federal income threshold which increases the number of children eligible for quality child care; and (2) incentivizing parents to place their children in a high quality OECP facility by approving five days of care each week with a zero copayment.This will serve to protect the health and safety of children by enriching their environment and providing high quality early learning opportunities.In addition, the proposed changes increase the employability and earning potential of parents and thus, reduce the impact of poverty on children.

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 to raise the income threshold to the federal income threshold for all families and to exempt household income and approve children attending an OECP program for a weekly unit type is not implemented, fewer low income families will be able to afford high quality early learning opportunities.In addition, fewer programs will be able to provide high quality care, thus limiting access to low income families.Research suggests that children with access to high quality learning environments are more likely to succeed in school and later in life.

K.The date the rule impact statement was prepared and, if modified, the date modified:Prepared October 17, 2018; modified January 7, 2019; modified December 13, 2019.


Rule Impact Statement

To:Programs Administrator

Office of Intergovernmental Relations and Policy

From:Patrick Klein, Director

                Adult and Family Services

Date:December 13, 2019

Re:CHAPTER 40. CHILD CARE SUBSIDY PROGRAM

Subchapter 1. General Provisions

340:40-1-6 [AMENDED]

Subchapter 7. Eligibility

340:40-7-2 [REVOKED]

340:40-7-6 [AMENDED]

340:40-7-9 [AMENDED]

340:40-7-11 [AMENDED]

Subchapter 10. Electronic Benefit Transfer (EBT) System for Child Care

340:40-10-1 through 340:40-10-4 [AMENDED]

Subchapter 13. Child Care Rates and Provider Issues

340:40-13-3 [AMENDED]

340:40-13-5 [AMENDED]

Subchapter 16. Improper Payments Error Rate Review Process

340:40-16-1 [AMENDED]

(Reference WF 20-40)

Contact:Laura Brown 405-521-4396

A.Brief description of the purpose of the proposed rule:

Purpose.The proposed amendments to Chapter 40, Subchapter 1 amend the rules to: (1) update and add clarifying language and terminology; (2) add child development as a goal of the child care subsidy program; and (3) remove a child care partnership that no longer exists.

The proposed amendments to Chapter 40, Subchapter 7 amend the rules to:(1) revoke a section which is no longer needed; (2) remove the definition for adult non-relatives; (3) remove adult non-relatives acting in the role of a spouse and their children from household composition and income consideration; (4) remove reference to an adult non-relative’s child from the child support pursuit rule; (5) update and clarify language regarding requesting good cause to not pursue child support; (6) add information regarding when income received from an S corporation is considered as earned or unearned income; (7) update how profit sharing income from S corporations, general or limited partnerships, or limited liability companies (LLC) is considered; and (8) remove reference to income from a roomer or boarder who is acting in the roll of spouse.

The proposed amendments to Chapter 40, Subchapter 10 amend rules to:(1) update and clarify language and terminology; and (2) remove a form that is no longer valid.

The proposed amendments to Chapter 40, Subchapter 13 amend rules to:(1) remove the county in which the provider provides care as a determining factor in the rate paid to that provider; (2) add proof of ownership verification as a requirement to obtain a contract; (3) add to the changes that a provider must report timely: (a) a change in the legal name of the business; (b) a change in the responsible person or legal name change of the person who is the authorized contract signor; (c) the provider's disqualification, suspension, or disbarment from any federal program; (d) when a person with ownership interest or a relationship with the provider is convicted of a criminal offense or fraud-related crime; and (e) a provider address change; (4) add that the provider must advise Child Care Subsidy staff of the expected date of return to the contracted facility when requesting a temporary change of location; and (5) update and clarify language and terminology.

The proposed amendment to Chapter 40, Subchapter 16 amends the rules to clarify the definition and purpose of the Improper Payments Error Rate Review process.

Strategic Plan impact. The proposed rules achieve the Oklahoma Department of Human Services (DHS) goal of continuously improving systems and processes.

Substantive changes.

Subchapter 1.General Provisions

Oklahoma Administrative Code (OAC) 340:40-1-6 is amended to:(1) update and add clarifying language and terminology; (2) add child development as a goal of the child care subsidy program; and (3) remove a child care partnership that no longer exists.

Subchapter 7. Eligibility

OAC 340:40-7-2 is revoked because it is no longer needed.

OAC 340:40-7-6 is amended to remove:(1) the definition for adult non-relatives; and (2) adult non-relatives acting in the role of a spouse and their children from household composition and income consideration.

OAC 340:40-7-9 is amended to: (1) remove reference to an adult-non relative’s child from the child support pursuit rule; and (2) update and clarify language regarding requesting good cause to not pursue child support.

OAC 340:40-7-11 is amended to: (1) add information regarding when income received from an S corporation is considered as earned or unearned income; (2) update how profit sharing income from S corporations, general or limited partnerships, or LLC is considered; and (3) remove reference to income from a roomer or boarder who is acting in the roll of spouse.

Subchapter 10.Electronic Benefit Transfer (EBT) System for Child Care

OAC 340:40-10-1, OAC 340:40-10-2, and OAC 340:40-10-4 are amended to update and clarify language and terminology.

OAC 340:40-10-3 is amended to:(1) remove a form that is no longer valid; and (2) update and clarify language and terminology.

Subchapter 13.Child Care Rates and Provider Issues

OAC 340:40-13-3 is amended to:(1) remove the county in which the provider provides care as a determining factor in the rate paid to that provider; and (2) update language and terminology.

OAC 340:40-13-5 is amended to: (1) add proof of ownership verification as a requirement to obtain a contract; (2) add to the changes a provider must report timely: (a) a change in the legal name of the business; (b) a change in the responsible person or legal name change of the person who is the authorized contract signor; (c) the provider's disqualification, suspension, or disbarment from any federal program; (d) when a person with ownership interest or a relationship with the provider is convicted of a criminal offense or fraud-related crime; and (e) a provider address change; (3) add that the provider must advise Child Care Subsidy staff of the expected date of return to the contracted facility when requesting a temporary change of location; and (4) update and clarify language and terminology.

Subchapter 16.Improper Payments Error Rate Review Process

OAC 340:40-16-1 is amended to clarify the definition and purpose of the Improper Payments Error Rate Review process.

Reasons.

The proposed amendments throughout the Subchapters are amended to clarify and simplify rules and update terminology.

The proposed amendment to remove adult non-relative individuals from household composition and income consideration increases access to child care subsidy as their income will no longer artificially inflate child care clients' household income.The adult non-relative is not legally obligated to provide support to the family by state statutes or Child Care Federal Regulations and may not provide any help to pay for child care.

The proposed amendment to add and update information regarding S corporations and profit sharing is made to align Child Care Subsidy rules with Supplemental Nutrition Assistance Program (SNAP) rules.

The proposed amendment to remove the county in which the provider provides care as a determining factor in the rate paid to that provider is made because a single, statewide rate was established that increased all providers to the enhanced rate.

The proposed amendments to child care contracts policy give guidance on the requirements of the contracting process, what needs to be provided when requesting a temporary change of location, and what changes must be reported.

The proposed amendment to the Improper Payments Error Rate Review process is made to better define and clarify the process.

Repercussions.

If the proposed amendment to no longer require non-relative adults acting in the role of a spouse and their children to be included in household composition and income consideration is not implemented, the client may lack the resources to pay a higher copayment or the entire cost of child care.Higher child care costs may lead to greater family instability and children being placed in unsafe and/or low quality child care environments that hinder the child's development.

If the proposed amendments regarding S corporations and profit sharing are not implemented, SNAP and Child Care Subsidy income rules will not agree causing client and staff confusion and may lead to errors.

If the proposed amendments regarding contracting processes are not implemented, processes may not be followed as intended resulting in an inadequate understanding of how to obtain a contract to receive child care subsidy payments, what needs to be provided when requesting a temporary change of location, and what changes must be reported.

Legal authority. Director of Human Services; Section 162 of Title 56 of the Oklahoma Statutes; Child Care Development Block Grant Act of 2014 [Public Law 113-186]; and Sections 98.11, 98.16, and 98.20 of Title 45 of the Code of Federal Regulations.

Permanent rulemaking approval is requested.

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 class of persons most likely to be affected by the proposed amendments 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 proposed amendment, to no longer consider the income of adult non-relatives, will have a positive economic impact on certain clients receiving child care subsidy benefits and their children as their income will no longer artificially inflate child care clients' household income that may allow the children to attend child care in a high quality environment.

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 proposed amendments will result in enhanced delivery of services to positively impact children and families.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 amendments 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 amendments.

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 amendment, to no longer consider the income of an adult non-relative may increase access to child care subsidy benefits for certain clients to help pay for quality child care and reduce safety risks that may occur if they leave their children home along or in lower quality care because they cannot afford the increased copayment or because counting the income makes them ineligible for child care help.

J.A determination of any detrimental effect on the public health, safety, and environment if the proposed rule is not implemented:If the proposed amendments are not implemented no detrimental effect on public health, safety, and environment is expected.

K.The date the rule impact statement was prepared and, if modified, the date modified:Prepared April 30, 2019; modified December 13, 2019.

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