The Mississippi Low Income Child Care Initiative (MLICCI) released a report in September 2021 detailing the results of a statewide survey of child care center directors who participate in the Child Care Payment Program (CCPP). The survey revealed that CCPP providers and parents face many state-imposed procedural barriers applying for and retaining CCPP, particularly the requirement that single parents (mostly single moms) must comply with the child support requirement. The survey also revealed that CCPP providers have waiting lists of parents who are work and income-eligible for CCPP, but who cannot get through the procedural barriers. CCPP providers reported that parents who had CCPP lost it during recent redetermination – not because they were no longer eligible, but because they couldn’t get through the procedural barriers.
MLICCI held a press conference to release the findings, pushing for MDHS to remove preventable red tape that providers and parents commonly report, to simplify the application and reporting requirements, to remove the child support requirement and to increase the number of parents served by CCPP.
Read MLICCI’s REPORT.
Mississippi Today released an article interviewing MDHS officials, child care providers, a parent and MLICCI. The article references findings from MLICCI’s report, particularly the findings showing parents lost child care assistance during the Pandemic. Shortly following publication of this story, Mississippi Today received and published a lengthy statement from MDHS in what appears to be a response to the subject of the article and to MLICCI’s report.
Below, we provide responses to the MDHS statement and point to a number of misleading and contradictory statements.
MDHS Statement: “Parents and childcare providers were notified in February 2021, that redetermination would be put back in place beginning April 2021”.
MLICCI Response: Providers reported on the monthly MDHS DECCD Zoom Info Sharing Sessions that reinstating CCPP redetermination would be very problematic. The recordings of these meetings are not available on the MDHS website, though we are told monthly that they will be uploaded and available soon.
The Office of Child Care at the Administration for Children and Families allowed CCDF lead agencies to submit waivers for a variety of extensions in light of the pandemic. This is true of all emergency situations – OCC allows CCDF lead agencies to enact a number of measures upon approval of a submitted waiver request (not blanket approval immediately implemented for all programs, as the MDHS statement implies). Mississippi was one of 20 states that received approval for a waiver of the 12-month eligibility period. MDHS submitted waivers for several different measures, including for the redetermination period to be suspended. This waiver was approved for one year, with the retroactive start date being March 1, 2020. In September 2020, ACF-OCC released guidance regarding waivers and the CCDF State Plan that lead agencies compose every three years. Page six of this guidance includes a section relevant to the MDHS redetermination waiver, titled “Requesting Renewals for Current Waivers for Extraordinary Circumstances”. This section states “Currently, approved waivers for extraordinary circumstances for requirements impacted by COVID-19 for states, territories, and tribes have a one-year duration, expiring a year from the jurisdiction-requested effective date. Due to the ongoing uncertainties of COVID-19 and in an effort to align waiver durations, the OCC has determined that states, territories, and tribes will have the option to request renewals for their current waivers for extraordinary circumstances.” (pg. 6). To request a renewal, the lead agency had to email a request to their Regional Program Office “after September 30, 2020, but no later than January 28, 2021”. While the COVID-19 case numbers in Mississippi were relatively low in September 2020, they grew significantly throughout December and January, reaching a peak on January 9, 2021, of 3,203. MDHS had time to submit a request to renew this waiver, but they chose not to do so. MDHS did, however, submit renewal requests for other waivers, including an extension on the timeline of posting inspection reports, implementing background checks for provisional hires, and the completion of the Market Rate Survey. These waiver renewals were approved on November 28, 2020, with a retroactive start date of October 1, 2020. MDHS made the policy decision to reinstate CCPP redetermination when it had the option to continue the waiver. MDHS was aware of the process and deadlines to request extensions on existing waivers, they used the process for other waivers, but they chose—with heightened COVID-19 case numbers at a time where no vaccine was available—to allow this waiver to expire, re-instating the redetermination process which caused many families to lose childcare assistance. The original waiver of redetermination expired on February 28, 2021.
MDHS Statement: “Additionally, per our policy, parents receive a 60-day notification and 30-day follow-up notification that their case is up for redetermination with instructions for completing the process. Childcare providers receive a 30-day notice and have access to the Childcare Provider Portal, which allows them to review all certificate information, including redetermination deadlines, at any time. While providers did not receive a written notification, as parents do, that information appears in the provider portal when the family’s case enters the redetermination period 60 days prior to their certificate/voucher end date.” (Bold added for emphasis)
MLICCI Response: Providers have repeatedly stressed the importance of them receiving a formal written 60-day notice, as well as the parent. Providers help parents navigate the process of redetermination. If they have more time, they are able to help prevent terminations of eligible parents. Including this information in the portal in addition to giving providers 60-day written notice may prevent terminations, which is why providers have repeatedly requested to receive this notice by mail. Although providers have given input on this multiple times, MDHS refuses to acknowledge or reinstitute this procedure.
MDHS Statement: “MDHS does not have a waitlist for certificates/vouchers.”
MLICCI Response: MLICCI’s report, “State-Imposed Child Care Policies Prevent Parents from Working: Results from a Survey of Child Care Payment Program (CCPP) Child Care Providers,” acknowledges that MDHS currently reports no “waitlist” due to lack of funding. MLICCI’s report and the reference in the Mississippi Today article to “waitlists” refer to those waitlists that individual CCPP child care center’s currently have. These waitlists are often not due to lack of capacity at the center, but are due to parents desperately needing childcare who are waiting on CCPP approval for assistance. CCPP applicants are required to select a childcare provider before their application is approved. MDHS’s own commissioned research affirms this reality. Per the MDHS-commissioned 2021 Market Rate Survey, “Overall, 59% of respondents reported having any kind of waitlist. Of those who reported having a waitlist, 99% of respondents said they had a waitlist for full-time care, and 35% said they had a waitlist for part-time care.” (Source: 2021 MDHS Market Rate Survey, pg. 14)
MLICCI’s survey of childcare providers reflected their current experiences with waitlists. “Most providers in the sample reported having a waiting list of parents (56.4%). Those providers reporting a current waiting list provided data showing an average of 15 parents. If we assume that 56.4% of CCPP providers in the larger CCPP universe experience what the average survey respondent reports with regard to their current waiting list of parents, between 6,700 – 8,100 parents are potentially on CCPP provider waiting lists throughout the state of Mississippi. Extending this estimate beyond parents, MLICCI estimates 11,800 – 14,200 children are prevented from accessing child care due to parents being on the waiting list.” (Source: MLICCI Survey Report – 2021, pg. 12)
MDHS Statement: “We are processing applications, and any families that meet eligibility requirements receive a certificate/voucher for 12 months per ECCD policy.”
MLICCI Response: A minimum 12-month eligibility period is a federal policy that went into effect in 2016 with the passage of the CCDF Final Rule, following CCDBG Act Reauthorization in 2014. Providers have repeatedly cited issues with parent application approval due to MDHS not following its own policies and procedural timeline. Caseworkers are notably difficult to reach. The 60-day timeline often results in applicant documentation becoming “outdated,” for example pay stubs that were current at the time of submission but are “out of date” by the time they are reviewed. Providers and parents are frequently told that required documentation was never received when it was in fact uploaded appropriately. These are only a few recorded examples, MLICCI and providers hear these and related issues daily. (Source: MLICCI Survey Report – 2021)
MDHS Statement: “Federal eligibility criteria limit MDHS. For example, a household cannot exceed 85% of the state median income to be eligible for certificates/vouchers.”
MLICCI Response: This MDHS statement implies that federal eligibility rules limit MDHS in approving CCPP applications. MLICCI’s 2021 MLICCI Survey Report found that state-imposed eligibility criteria, specifically the child support requirement and minor procedural issues are cited more frequently by CCPP child care providers as reasons parents they serve do not get approved for CCPP. Federal eligibility criteria, such as the work/education requirement and the federal income cap, were cited far less frequently in survey responses by CCCP providers as reasons parents’ CCPP applications don’t get approved.
MDHS Statement: “Parents were notified via email which is how the Childcare Division handles beneficiary communication. Childcare providers were also notified in monthly Zoom information sharing sessions. Childcare providers have access to the Childcare Provider Portal regarding any of the children they care for in real time. The provider portal allows for a more secure transmission of children’s information in real-time to childcare providers. When certificates are up for redetermination, the notification shares the next steps to complete the redetermination. ECCD provides an average of 20-22,000 children access to childcare each month. ECCD issued temporary, 90-day emergency certificates to additional families who had never qualified for childcare vouchers during the pandemic. Each of these emergency voucher families were given the opportunity to see if they would qualify for the program moving forward. Families in the pandemic related emergency certificates were eligible to apply for the 12-month childcare certificate. Emergency certificates reached their monthly peak in September 2020 with over 4,600. This is in addition to the 20-22,000 children enrolled in the traditional certificate program. Due to new Federal guidelines regarding the second round of stimulus funding (ARP) state that monies from ARP cannot be for the same purpose as CARES.” (Bold added for emphasis)
MLICCI Response: According to federal guidance, stimulus funds “Past CCDF Participation and other Federal Funding: Stabilization funds are available to qualified child care providers regardless of a provider’s previous receipt of federal assistance, including CCDF and other COVID-19 funding.”
Link to OCC Infographic: Common Requirements/Allowable Use of Funds in CARES, CRRSA, and ARP. Link to OCC Chart: Provider Eligibility for American Rescue Plan Act of 2021 Child Care Stabilization Subgrants
MDHS Statement: “Due to staffing levels, we want to ensure accountability of Cares Act funds; we are trying to ensure reports are received before the 2nd round of funding so it will not be problematic to the childcare providers from an accountability standpoint.” (Bold added)
MLICCI Response: Staffing Levels: Administering Child Care Stabilization Subgrants, Lead agencies may use this set-aside to assist with administering the stabilization subgrants. They are strongly encouraged to use a portion of their set-aside to cover the cost of staffing and systems necessary to administer and process the subgrants in a timely, transparent, and effective manner to help stabilize the child care sector.
MDHS Statement: “To date, ECCD is still awaiting reports from over 300 childcare providers. Providers cannot receive ARP Stabilization Grants until their CARES funding reports have been filed. We believe that this policy is in the best interest of the providers and the state of Mississippi as the trustee of the stimulus funds. The Federal government requires childcare providers to be in good financial standing. Childcare centers must provide supporting documentation to show they are in good standing to receive additional funding from the ARP Stabilization Grants.” (Bold added)
MLICCI Response: The ARP funds referred to in the MDHS statement are “stabilization” funds and are intended to also help providers who may not be considered in “good financial standing” at time of application. Additionally, MDHS has flexibility in determining eligibility and federal guidance contemplates these funds being used to assist centers experiencing “financial hardship”. The MDHS claim that the federal government requires child care providers to be in good financial standing before they are eligible to receive ARP Stabilization funds is inconsistent with federal guidance. Per the ACF-OCC “Stabilizing Child Care and COVID-19 FAQ page, Section: ARP Stabilization Grants: Eligible Providers: Question 4:
“In order to be a qualified child care provider and eligible to receive a subgrant, a child care provider must either be open to provide child care services or temporarily closed due to public health, financial hardship, or other reasons relating to the COVID-19 public health emergency at the time of application. The terms included in the Act are broad, and lead agencies have the flexibility to define them. Therefore, a lead agency could define a lack of qualified staff or demand as an accepted reason related to the COVID-19 public health emergency for why a child care provider may be temporarily closed.” [Bold added for emphasis]
MLICCI’s contention with this MDHS statement is that child centers facing financial hardship due to COVID-19 may not meet MDHS’s definition of “good financial standing”. For instance, providers that received funds from the CARES Act may still be facing hardship, such as a lack of staff and sporadic COVID-related closures, which may prevent them from complying with MDHS reporting requirements. Stabilization grants are intended to continue supporting providers as they continue to operate in this unprecedented environment. In addition, per CCDF-ACF-IM-2021-02:
“To help ensure that subgrant funds are being appropriately spent to stabilize the child care sector…Qualifying providers…includes existing child care providers who, on the date they apply for a subgrant, are temporarily closed due to public health, financial hardship, or other reasons relating to the COVID-19 public health emergency. There are many reasons why a child care provider may be temporarily closed due to the COVID-19 public health emergency but for which a stabilization grant will be very beneficial to the community and the sector.” (pgs. 7-8) [Bold added for emphasis]
“Prior to the passage of the ARP Act, child care providers incurred substantial financial losses in order to keep providing these essential services to their communities throughout the pandemic, and there were not sufficient resources available over the past year to support the child care sector. Prolonged and short-term closures, reduced hours, tuition adjustments, low enrollment, extra expenses related to sanitation and safety, and accommodations for new safety and staffing protocols have placed many child providers on very precarious financial footing for which prospective stabilization grants will not compensate. Assisting child care providers with these past financial losses will help ensure their future viability and are an essential component to stabilizing the availability of child care for our families and our communities as we recover from this pandemic. Even with stabilization grants to help prospectively, the financial harm of the past year is likely to continue to reverberate without this targeted financial assistance. Therefore, under the authority granted in section 2202(e)(2) of the ARP Act, lead agencies are strongly encouraged to make subgrant funds available to qualified child care providers…[Bold added for emphasis]
If MDHS insists on moving forward with this burdensome policy, the agency should not prevent providers who have completed the close out process for previous grants from applying for ARP Stabilization Grant funds. Doing so restricts providers from accessing funds to stabilize their centers – the exact purpose of the ARP Stabilization Grants. MDHS should utilize a portion of the R&R network outreach to ensure the close out processes are completed as soon as possible and that those providers are allowed to proceed with their application immediately upon completion.
MDHS Statement: “ECCD distribution of ARP Stabilization Grants directly to Childcare providers will be exponentially more significant than the CARES Act Booster Shots. Due to staffing levels, we want to ensure accountability of all Cares Act funds. ECCD is attempting to close out all open grants related to the CARES funding before opening the 2nd round of funding. To date, ECCD is still awaiting reports from over 300 childcare providers.” (Bold added)
MLICCI Response: Per the ACF-OCC Stabilizing Child Care and COVID-19 FAQ page, MDHS is not required to spend down previous funds before disbursing Stabilization funds. Federal guidance encourages the opposite:
Section: ARP Stabilization Grants – Lead Agency Spending: Question 2: “Are Lead Agencies required to spend down previous supplemental relief funding “(i.e., CARES Act and the CRRSA Act) before spending the ARP Act Stabilization funds? Answer: No, lead agencies are not required to spend down previous supplemental relief funding before spending the ARP Act stabilization funds. While lead agencies should be aware of obligation and liquidation requirements for the other COVID-19 related funding (i.e., under the CARES Act and CRRSA Act), lead agencies are strongly encouraged to obligate their ARP Act stabilization grant funds quickly to ensure they reach providers in need and protect the existing child care market. OCC also recommends that lead agencies be aware of allowable uses of funds and funding requirements with the multiple COVID-19 supplemental funds. Lead agencies may also consider how they can pair more flexible funding provided by the CARES Act and CRRSA Act with the more prescriptive ARP Act stabilization funds. Lead agencies should contact their OCC Regional Offices for support and technical assistance related to spending the various funding streams so they can reach child care providers and families quickly.”
Opening grant applications to providers who have successfully closed out the previous CARES Act-funded “Booster Shots”, as well as those who didn’t receive CARES funds, would provide incentive for the remaining providers to close out these grants. MDHS’s stated justification for delaying the disbursement of ARP Stabilization funds is inconsistent with federal guidance.
MDHS Statement: “Providers cannot receive ARP Stabilization Grants until their CARES funding reports have been filed with ECCD. We believe that this policy is in the best interest of the providers and the state of Mississippi as the trustee of the stimulus funds.”
MLICCI Response: Federal guidance strongly urges states to make the disbursement of Stabilization funds quick, efficient and targeted. Federal guidance does NOT link eligibility for Stabilization funds to previous CARES Act funding received. Imposing this requirement is an example of MDHS creating unnecessary bureaucracy, contrary to what federal guidance urges states to do. Additionally, this MDHS policy will make it more difficult for the state to meet deadlines for obligating federal funds. Per CCDF-ACF IM 2021-02:
“Every effort should be made to process applications on a timely basis in order to create stability, trust, and transparency in the subgrant process. OCC recommends lead agencies process subgrant applications and distribute approved funds within 30 days of receipt.” (pg. 14) “To stabilize the child care sector during and after the COVID-19 public health emergency, lead agencies should limit the burden and bureaucracy on child care providers and ensure subgrants are sufficient in size and duration to support continuous operation.” (pg. 14) [Bold added for emphasis]
Obligating 50 Percent of Funds “Lead agencies are strongly encouraged to obligate their stabilization grant funds quickly to ensure they reach providers in need and protect the existing child care market. The ARP Act requires lead agencies to notify HHS if they will not be able to obligate at least 50 percent of the funds used for subgrants to providers by December 11, 2021, 9 months after the date of the enactment of the ARP Act. The Act does not require lead agencies to return funds unobligated at that point, but strongly encourages lead agencies to plan to obligate at least half of funds by this date. OCC will initiate regular communication to check in with and provide technical assistance to lead agencies to facilitate obligating and spending the stabilization grants in keeping with the Congressional intent that these resources provide immediate fiscal relief to the child care sector. Lead agencies that anticipate challenges in obligating half of their stabilization grant funds by December 11, 2021, are encouraged to notify their OCC Regional Office as soon as possible. OCC will issue guidance on how lead agencies can report this information at a later date.” (pg. 24)
MDHS Statement: “To date, all CARES Act money has been dispensed. None of the funds have come back from providers. New policies put in place over the past year include: 1) Covering parent Copays for families at or below the poverty line amounting to between $800,000 – $1,000,000 in additional payments per month going to providers. 2) ECCD is also paying an enhanced rate of an additional 25% from April 2020 to December 2022. 3) Payments are based on enrollment, not attendance. If the child stays home, the providers will still get the funds for that child. This is a permanent policy change. 4) Removed child support as countable income when calculating eligibility for childcare vouchers. This goes into effect 10/1. This change will lower the income requirements. [Bold added for emphasis.]
MLICCI Response: This is a red herring and is impossible to verify. Although it has been requested in the past, there is no data on how many eligible parents receive consistent monthly child support payments, the average amount of those payments, or how much of an effect this income would have on putting a family close to or over the eligibility limit. What would have an incredible effect on expanding access to the CCPP for eligible parents is removing the state-mandated child support enforcement requirement. Child care providers even reported this as a barrier in MDHS’s own commissioned 2021 Market Rate Survey, during the open-ended questions portion: “Directors stated that more families need to qualify for the program and that the application and renewal processes can be difficult for families. Difficulties that were listed by multiple directors included families being required to apply for the program online when technology can be difficult for them to access and use, single mothers being required to submit child support documentation, and needing to be employed to qualify (when families are typically not able to work without child care)” (pg. 20, 2021 Market Rate Survey).
MDHS Statement: MDHS has not had a waitlist in 4 years. (Editor’s note: Mississippi Department of Human Services reportedly cleared the Child Care Payment Program wait list in 2018, less than three years ago). We are serving every family that is eligible and applies for assistance.
MLICCI Response: MLICCI’s report and the Mississippi Today article asserts that CCPP child care providers have waiting lists, not MDHS. MLICCI acknowledges that MDHS reports no current waiting list. Child care provider waitlists are often not due to lack of capacity at the center but are due to parents desperately needing childcare who are waiting on CCPP approval for assistance. Per MDHS’s own 2021 Market Rate Survey, “Overall, 59% of respondents reported having any kind of waitlist. Of those who reported having a waitlist, 99% of respondents said they had a waitlist for full-time care, and 35% said they had a waitlist for part-time care.” (Source: 2021 MDHS Market Rate Survey, pg. 14) MLICCI’s 2021 report, “State-Imposed Child Care Policies Prevent Parents from Working: Results from a Survey of Child Care Payment Program (CCPP) Child Care Providers,” found similar trends – specifically, that 56.4% of CCPP providers reported a waiting list and an average of 15 parents on the waiting list. Of these providers reporting a waiting list, 65.2% said parents on their waiting list are CCPP-eligible. While MDHS may not currently report a formal “waiting list,” MLICCI’s research and MDHS’s own commissioned report reveal that child care centers do have waiting lists and such waiting lists include parents who need CCPP to afford the costs and enroll their children.
MDHS Statement: “MDHS monitors all relief funding to (1) ensure we comply with all funding requirements;(2) ensure that the funding to sustain childcare providers stretches as far as it can reach. To date, fourteen (14) states have activated the ARP funding. Most recently, Louisiana opened but ended up closing their distribution for unknown reasons.” (Bold added)
MLICCI Response: (35 states have open grant applications in place, with many states on the second round of ARP funds for centers. Mississippi began “Phase One of Child Care Strong” and unofficially announced on November 11, 2021 in an Info Sharing Session that the new anticipated opening date of the application process is now December 1st. This opening date is not on the Child Care Strong page, there is still no state-specific timeline of the application process available, and there is no guarantee that all applications will be open and available on December 1st, regardless of any pending unfinished CARES close outs.
MDHS Statement: “In reference to the additional public hearing and policy changes. Public hearings are required by law to gather comments on policy changes. Policy manual update proposals were shared at the public hearing and posted online with an email address for written comments…ECCD recently undertook a market survey from childcare providers…92% approval on how ECCD handled the pandemic CARES Funds.”
MLICCI Response: The use of the word “approval” in this statement is misleading. Per the 2021 Market Rate Survey being referenced by MDHS: “Participants were asked to evaluate rate subsidy increases by MDHS in response to COVID-19 in the following question: ‘The Child Care Payment Program has increased subsidy rates for providers in response to the COVID-19 pandemic. To what extent has this increase been adequate to meet your center’s needs?’” Figure 5 shows responses to this question: 32.6% responded “somewhat adequate”, 59.7% responded “very adequate” – for a total of 92.3%.” (pg. 18) While this question asked about “adequacy” of increased subsidy rates in response to COVID-19, it did not ask respondents whether they approved of MDHS’s handling of CARES Act funds. The MDHS statement implies that participants in the Market Rate Survey were aware that the increased subsidy rate was funded through the CARES Act and that providers approved of ALL uses of CARES funds, which would include the Booster Shot payment and procedures related, as well as the subsidy increase. The survey question did not cover all of these dimensions. There is no direct mention of the CARES Act or CRRSA funds in the Market Rate Survey.
MDHS Statement: “Last year, ECCD spent 85% of discretionary funds on vouchers, 10 % higher than the federally mandated 75% of discretionary funds.”
MLICCI Response: While CCDF has specific spending requirements and 70% of discretionary funds after quality and admin set-asides must be spent on direct services, CARES Act funds were largely exempt from the requirements. It is unclear if this statement is in regard to spending requirements for general CCDF and/or CARES Discretionary funds, or some combination of the two funding streams. Per CCDF-ACF-IM-2020-01:
“Funds from the CARES Act are exempt from certain spending requirements required by the CCDBG Act. The CCDBG Act requires a significant portion of Lead Agency spending to be used for assistance for certain families (section 658E(c)(3)(D)), 70 percent of the remaining funds (after quality and administration) to be used for direct services (section 658E(c)(3)(E)), and certain percentages (9 percent for States and Territories, 8 percent for Tribes, and an additional 3 percent targeting infants and toddlers) to be used on quality improvement activities (section 658G). These requirements do not apply to the CARES Act funds.” (pg. 7)
MDHS Statement: “Once a child is qualified and the voucher is approved, it is good for 12 months. The parent is given a 60-day notice before the voucher eligibility expires. They will need to be verified. During COVID, the Feds temporarily waived the CCDF redetermination. As of April 2021, redetermination is back in place unless the feds waive the requirement again.” (Bold added)
MLICCI Response: The Office of Child Care at the Administration for Children and Families allowed CCDF lead agencies to submit waivers for a variety of extensions in light of the pandemic. This is true of all emergency situations – OCC allows CCDF lead agencies to enact a number of measures upon approval of a submitted waiver request (not blanket approval immediately implemented for all programs, as the MDHS statement implies). Mississippi was one of 20 states that received approval for a waiver of the 12-month eligibility period. MDHS submitted waivers for several different measures, including for the redetermination period to be suspended. This waiver was approved for one year, with the retroactive start date being March 1, 2020. In September 2020, ACF-OCC released guidance regarding waivers and the CCDF State Plan that lead agencies compose every three years. Page six of this guidance includes a section relevant to the MDHS redetermination waiver, titled “Requesting Renewals for Current Waivers for Extraordinary Circumstances”. This section states “Currently, approved waivers for extraordinary circumstances for requirements impacted by COVID-19 for states, territories, and tribes have a one-year duration, expiring a year from the jurisdiction-requested effective date. Due to the ongoing uncertainties of COVID-19 and in an effort to align waiver durations, the OCC has determined that states, territories, and tribes will have the option to request renewals for their current waivers for extraordinary circumstances.” (pg. 6). To request a renewal, the lead agency had to email a request to their Regional Program Office “after September 30, 2020, but no later than January 28, 2021”. While the COVID-19 case numbers in Mississippi were relatively low in September 2020, they grew significantly throughout December and January, reaching a peak on January 9, 2021, of 3,203. MDHS had time to submit a request to renew this waiver, but they chose not to do so. MDHS did, however, submit renewal requests for other waivers, including an extension on the timeline of posting inspection reports, implementing background checks for provisional hires, and the completion of the Market Rate Survey. These waiver renewals were approved on November 28, 2020, with a retroactive start date of October 1, 2020. MDHS made the policy decision to reinstate CCPP redetermination when it had the option to continue the waiver. MDHS was aware of the process and deadlines to request extensions on existing waivers, they used the process for other waivers, but they chose—with heightened COVID-19 case numbers at a time where no vaccine was available—to allow this waiver to expire, re-instating the redetermination process which caused many families to instantly lose childcare assistance. The original waiver of redetermination expired on February 28, 2021.
MDHS Statement: “The parent is given a 60- day notice before the voucher eligibility. They will need to be verified. During Covid, the Feds temporarily waived the CCDF redetermination, but now the CCDF determination is required unless we request a waiver from the Feds.” (Bold added for emphasis).
MLICCI Response: In this statement, MDHS contradicts a previous statement and recognizes it was, in fact, responsible for requesting a waiver for the redetermination process to be extended.