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1 Early Learning Coalition of Brevard County, Inc. Minutes: Board of Directors Meeting Date/Time: Tuesday, February 21, 2012 at 4:00 p.m. Location: Early Learning Coalition Rockledge Office, 1018 Florida Ave, Rockledge, FL 32955 Members Present: Priscilla DeNino, Lori Duester, Mike Durante, Mildred Coyne, Ian Golden, Nancy Grzesik, Tom Peer, Myrna Shimei, Tom Peer, Mona Potter, Shannon Smithwick, and Karen Street Excused Absent members: Marci Brilley and Althea Puzio Unexcused Absent Members: Natalie Jackson and Doug Workman Staff Present: Sky Beard, Jessica Beecham, Gwen Hertlein-Haber, LaShaundra McGhee, Cathie Odom Guest/Public: Susan Bragonje, Staci Faenza, Andrea Lawson, Connie Rivera Called to order: Shannon Smithwick, Board Chair called the meeting to order at 4:01 p.m. Self-introductions were conducted and quorum was established. Agenda Item Summary/Discussion Action/Follow-up Consent Items a. Minutes: January 24, 2011 b. Directors Report c. OEL Accountability Monitoring Report Tom Peer motioned for all consent items to be approved. Mildred Coyne seconded the motion. The motion passed unanimously by all Board members. Presentations: Child Care Fraud (Connie Rivera, Financial Crimes Investigator: Connie explained to the Board that client fraud is usually detected at the client’s re-authorization appointment when there is an inconsistency with information previously provided. When a fraud crime is suspected by a Coalition staff, the Coalition will put together a fraud packet the meets the criteria required and submit it to the Office of Early Learning for review and then sent to the Department of Financial Services for further investigation. In regards to the criteria, the case must meet is that there have been a loss of funds to the State in the amount of $2000 or more; due to the budget cuts the amount of funds lost went from $200 to $2,000. In addition, there must be a false application submitted by the client. Once investigated about 75-85% of the cases result with an admission to the crime. The State Attorney will then decide if there was intent to commit fraud is found. Sky Beard introduced to the Board, Connie Rivera. Connie is a Financial Crimes Investigator that is contracted with the Coalition to investigate fraud and was invited to speak to the Board and give an overview of fraud in Brevard County. In response to a Board member’s question Connie informs the Board that there are 4,500 fraud case submitted to the State from both Coalitions and Department of Children and Families (DCF). About 95% of all cases submitted are proven to be fraud cases. Ian Golden inquired if data was used to help train Coalition staff of the “signs” for fraud. Connie and Sky informed the Board that there has been several fraud training for Coalition staff that handles eligibility. Sky also informed the Board that the Coalition will be working No Action Required

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Page 1: Early Learning Coalition · budget cuts the amount of funds lost went from $200 to ... proposal is to collaborate with Brevard Public Schools early ... the Early Learning Coalition

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Early Learning Coalition of Brevard County, Inc.

Minutes: Board of Directors Meeting

Date/Time: Tuesday, February 21, 2012 at 4:00 p.m.

Location: Early Learning Coalition Rockledge Office, 1018 Florida Ave, Rockledge, FL 32955

Members Present: Priscilla DeNino, Lori Duester, Mike Durante, Mildred Coyne, Ian Golden, Nancy Grzesik, Tom Peer, Myrna Shimei, Tom Peer, Mona Potter, Shannon Smithwick, and Karen Street

Excused Absent members: Marci Brilley and Althea Puzio

Unexcused Absent Members: Natalie Jackson and Doug Workman

Staff Present: Sky Beard, Jessica Beecham, Gwen Hertlein-Haber, LaShaundra McGhee, Cathie Odom

Guest/Public: Susan Bragonje, Staci Faenza, Andrea Lawson, Connie Rivera

Called to order: Shannon Smithwick, Board Chair called the meeting to order at 4:01 p.m. Self-introductions were conducted and quorum was established.

Agenda Item Summary/Discussion Action/Follow-up Consent Items

a. Minutes: January 24, 2011 b. Directors Report c. OEL Accountability Monitoring Report

Tom Peer motioned for all consent items to be approved. Mildred Coyne seconded the motion. The motion passed unanimously by all Board members.

Presentations:

Child Care Fraud (Connie Rivera, Financial Crimes Investigator:

Connie explained to the Board that client fraud is usually detected at the client’s re-authorization appointment when there is an inconsistency with information previously provided. When a fraud crime is suspected by a Coalition staff, the Coalition will put together a fraud packet the meets the criteria required and submit it to the Office of Early Learning for review and then sent to the Department of Financial Services for further investigation. In regards to the criteria, the case must meet is that there have been a loss of funds to the State in the amount of $2000 or more; due to the budget cuts the amount of funds lost went from $200 to $2,000. In addition, there must be a false application submitted by the client. Once investigated about 75-85% of the cases result with an admission to the crime. The State Attorney will then decide if there was intent to commit fraud is found.

Sky Beard introduced to the Board, Connie Rivera. Connie is a Financial Crimes Investigator that is contracted with the Coalition to investigate fraud and was invited to speak to the Board and give an overview of fraud in Brevard County.

In response to a Board member’s question Connie informs the Board that there are 4,500 fraud case submitted to the State from both Coalitions and Department of Children and Families (DCF). About 95% of all cases submitted are proven to be fraud cases. Ian Golden inquired if data was used to help train Coalition staff of the “signs” for fraud. Connie and Sky informed the Board that there has been several fraud training for Coalition staff that handles eligibility. Sky also informed the Board that the Coalition will be working

No Action Required

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with Connie and the Department of Financial Services in regards to clients that may be receiving both Unemployment Compensation and School Readiness fund.

Committee Reports:

Executive/Finance Committee: Shannon Smithwick reported to the Board that the Executive/Finance Committee met on February 21, 2012 and the agenda included the following:

• January Minutes were approved • the Coalition’s tax return, Form 990, was reviewed and

approved. •

Establishment of Committee Membership: Shannon Smithwick and Sky Beard asked the Board members to please sign-up for their preferred committee. Sky reviewed the different committees. Shannon notified the members that those members that did not sign-up for a committee of their preference, they will be assigned to one. Those members not in attendance will be emailed the information and asked to sign up for a committee before the next Board meeting.

No Action Required

Old Business Legislative Update:

Sky reported to the Board that currently there are several pending House and Senate bills that concern early learning. One large concern the Coalitions have regarding the pending changes would be that there seems to be less focus on the quality of early learning.

Sky Beard informed to the Board that Mike Durante and she attended the meetings held in Tallahassee at the beginning of the month. Mike reported to the Board that he feels that “Dr. Mel” is really on top of things at the State level. While in Tallahassee Sky and Mike were able to meet with two of Brevard’s local representatives.

Waiting List/New Enrollment Update:

Sky informed the Board that with the legislation focus on the wait list the Coalition hopes that Brevard can be an example of how to maintain a current wait list.

Cathie Odom reported to the Board that there is still a projection of an increase to funds (see attached: Utilization Reports). However, there is an exception to see a change in the next month. Enrollment numbers are continuing to climb and stay up.

Quality Assessment Scores:

No Action Required

Sky Beard informed the Board that assessment scores will be discussed in New Business (see: New Business: Us of Environmental Rating Scale)

New Business Florida First Start Monitoring Report:

LaShaundra McGee reported to the Board that on December 16, 2011 there was an on-site review of the Florida First Start program. LaShaundra reviewed the monitoring report with the Board (see attached: Monitoring Report).

Use of Environmental Rating Scale:

No Action Required

Sky Beard informed the Board that the Office of Early Learning has new stance on the Environmental Rating Scales (ERS) and reviewed how the Coalitions are using it. When reviewing, it was found that only

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February 2012 Board of Directors Minutes Approved: Respectfully Submitted, Approved

__________________________________ _________________________________________

Signature Date Signature Date

Executive Coordinator Executive Director

nine (9) Coalitions are using the scale as Brevard does, which OEL has termed as High Stacks Accountability. OEL has informed the Coalitions that the ERS are no longer allowed to be used in contracts. With this change from OEL the Coalition will not be able to continue practicing the policy of terming providers that continue to score a 3.5 or below on the ERS. The Coalition will be holding a provider meeting on March 8, 2012 and will be informing providers then of the change. Sky also informed the Board that due to the new proposed School Readiness contract will not be available until December 2012 the Coalition’s will have the ability to continue with current contracts past June 30, 2012. However, the ERS wording must be removed. Ian Golden inquired about a letter being sent to the Governor from the Board of Commissioners in regards to the importance of Quality Early Learning.

Board Updates

Providers: Priscilla Denino informed the Board that after learning all the new information there may be more to report next month regarding all the changes. Lori Duester informed the Board that she had received the grant she had been working that submitted to Blue Cross Blue Shield. The grant will provide an opportunity to bring the CATCH early childhood program to Brevard County. It's an evidence-based physical activity and nutrition program for ages 3-5 (modified from the K-6 school aged program). The proposal is to collaborate with Brevard Public Schools early childhood programs, ELC and Head Start.

Licensing: Tom Peer informed the Board that three (3) new employees have been hired for the Brevard area.

No Action Required

Public Comment

N/A No Action Required

Adjournment The meeting was adjourned at 5:44 p.m.

Next Meeting March 20, 2012

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Board of Directors Meeting Tuesday, February 21, 2012 4:00 pm

AGENDA

I. Call to Order

II. Coalition Roll Call by Self Introduction

III. Consent Items a. Minutes: January 24, 2011 b. Director’s Report

c. OEL Accountability Monitoring Report

IV. Presentations a. Child Care Fraud (Connie Rivera, Financial Crimes

Investigator)

V. Committee Reports a. Executive / Finance Committee b. Establishment of Committee Membership

VI. Old Business

a. Legislative Update b. Finance Report and Waiting List/New Enrollment Update c. Quality Assessment Scores

VII. New Business

a. Florida First Start Monitoring Report b. Use of Environment Rating Scales

VIII. Board Updates

a. Providers (Priscilla DeNino, Lori Duester and Doug Workman)

b. Licensing (Tom Peer)

IX. Public Comment

X. Adjourn

Next Meeting: March 20, 2012

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Director’s Report February 2012

Office of Early Learning (OEL) Update:

• A series of statewide meetings was held the week of January 30, 2012 in Tallahassee. The Early Learning Coalition’s Executive Director attended the meetings along with Mike Durante, member of the Board of Directors.

Coalition Update:

• Coalition staff has been in communication with the Office of the State Attorney regarding the pending legal case with a child care provider. The case has been set for trial.

• The Early Learning Coalition participated in a variety of Literacy Week activities during the

week of January 23, 2012. Literacy Week was a joint venture with the Department of Education and Florida’s Office of Early Learning. Many Coalition staff visited contracted child care providers and read the identified book, “Chicka Chicka 1,2,3,” as well as provided reading opportunities to children in the lobbies of Coalition offices. During the reading activity at The Learning Tree, Florida Today took a series of photos highlighting the importance of early literacy and the role that the Early Learning Coalition plays in the community.

• On February 17 – 18, 2012, the Early Learning Coalition and the Children’s Forum will be hosting the annual child care provider conference, “Strengthen Your Core: Understanding Florida’s Core Competencies for Early Care and Education” in Melbourne. It is anticipated that approximately 300 child care directors, owners and teachers will be attending this high quality professional development event.

• Planning for the VPK round up process for the 2012 – 2013 school year is underway. The Coalition will be offering a variety of opportunities for parents to obtain a Certificate of Eligibility, including the addition of Saturday round ups. The process will begin March 20 with the first scheduled round up and will continue through the beginning of the school year.

• Coalition leadership has introduced a revised organizational chart that puts the previously discussed “Front Door to Services” concept into practice. A new team of staff consisting of a Family Resource Administrator and an expanded Child Care Resource and Referral department has been developed which will provide enhanced opportunities for exceptional service delivery.

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STATE OF FLORIDA GOVERNOR RICK SCOTT

FLORIDA’S OFFICE OF EARLY LEARNING

(850) 717-8550 DIRECTOR

MEL JURADO, PH.D.

PROGRAM INTEGRITY MANAGER TAMARA AKINS PRICE

REVIEW SUPERVISOR

REGINAL WILLIAMS

REVIEW TEAM LEAD ED HACHENBERGER

REVIEW TEAM ANDREA RAINES JAMES RUSSELL

LORA LEE-TURNER LATOYA SAMPSON

SUSAN SCHUMACHER

WRITER CELICIA BELL

QUALITY ASSURANCE

THOMAS IMHOLT BETTY WALLACE AMY MITCHELL

AU REPORT 11-12.21 JANUARY 2012

FLORIDA’S OFFICE OF

EARLY LEARNING

Accountability Monitoring Report for the Early Learning Coalition of Brevard County

Florida’s Office of Early Learning’s Program Integrity Unit conducted an early education and care accountability review for the Early Learning Coalition of Brevard (the Brevard coalition, the coalition). The coalition is incorporated as a not-for-profit organization, which is tax exempt under 26 U.S.C. s. 501(c)(3).

All early learning service providers that expend state and federal funds shall operate early education and care programs in a manner that complies with state and federal rules, regulations, and laws. The team conducted the review to ensure a coalition’s overall administration and implementation of the early learning programs (School Readiness (SR), Voluntary Prekindergarten (VPK), and Child Care Resource and Referral (CCR&R)) meets or exceeds the service delivery and operational requirements.

The desk and on-site combination review occurred September 12-14, 2011. The Accountability review team reviewed the coalition’s programmatic operations from July 1, 2010 through July 30, 2011, and the coalition’s monitoring reports and supporting documentation for SR services the coalition delivered for April through June 2011 and for VPK services during the 2010/11 program year.

In this report, a criterion that complies with the review requirements is indicated with a “YES”; a criterion that does not comply with requirements is indicated with a “NO ” unless otherwise noted.

For each “NO” response, the coalition needs to take corrective actions as required by the terms of the Early Learning Grant Agreement. The report notes corrective action examples that help ensure the coalition’s effective delivery of program services.

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Authority Federal and Florida laws, rules, and regulations mandate that Florida’s Office of Early Learning (FOEL) administer early learning programs in Florida, as well as monitor and evaluate each coalition’s performance in administering the early learning programs and implementing the coalition’s SR plan (Title 45, Code of Federal Regulations (CFR), s. 98.11(b)(6), s. 411.01(4)(l), and s. 1002.75(1), Florida Statutes (F.S.). The monitoring and performance evaluations must include, at a minimum, onsite monitoring of a coalition’s finances, management, operations, and programs. The Office may also identify best practices for a coalition to improve the outcomes of the early learning programs.

Scope and Methodology Florida’s Office of Early Learning developed performance criteria to provide a framework for measuring a coalition’s effectiveness in implementing early learning programs. The performance criteria include indicators about compliance with federal and state laws, rules, and regulations to assist the coalition in maintaining high quality in the following areas: coalition governance, operations and program management, CCR&R, educational service delivery, SR and VPK eligibility, VPK provider eligibility, payment validation, and data security. During the fiscal year, not all coalitions are subject to review of each criteria.

Coalition Background Information History of Operations. The Early Learning Coalition of Brevard began operations in 2005 in response to amendments made to Chapter 411, F.S., by the Florida legislature.

Provider Type and Children Served. The following is a list of the number of provider types and the number of children served by program type. The number of children served includes eligible children birth through 12 years of age and children with special needs up through the age of 18.

Type of Providers Number of SR Providers

Number of VPK Providers

Number of School Readiness Children

Number of Voluntary Prekindergarten Children

Faith-Based Providers1 N/A 44 N/A 1,328

Family Child Care Homes 14 2 88 16

Private Centers/Schools 112 149 4,276 3,757

Public School Providers 33 32 97 885

Informal Caregivers 0 N/A 0 N/A

Total (unduplicated)* 159 183 4,393 4,644

Source: OEL Fact book, 2010-2011.

*The sum of coalition data does not equal the statewide total. Children may be served by more than one coalition.

1 Distinct count of providers. Faith-based providers are included in the provider type counts and are not considered a separate provider type. Florida’s Office of Early Learning does not require that a coalition identify faith-based providers in the SR program.

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Organization and Staffing. The coalition has an administrative staff of five employees who implement the programmatic aspects of the coalition’s board of director’s mission. The management staff includes the executive director, director of human resources, director of business operations, director of program initiatives, and director of resource development. There were no management position changes during this review period.

Board Governance. The coalition’s board of directors serves as the policy-making entity for the coalition, delegating authority to the coalition’s executive director. At the time of the review, the 15-member board consisted of 15 voting members and three vacancies representing one county that includes representatives from both the private and public sectors. The following standing committees established in accordance with the coalition’s bylaws, support the board: executive committee and nominating committee.

Scope of Services.

The Coalition provides the following early learning services: SR child eligibility determinations Coalition Contractor VPK child eligibility determinations Coalition Contractor VPK provider eligibility determinations Coalition Contractor SR provider reimbursements Coalition Contractor VPK provider reimbursements Coalition Contractor CCR&R Coalition Contractor Parent support Coalition Contractor Health and developmental screening Coalition Contractor SR provider recruitment Coalition Contractor VPK provider recruitment Coalition Contractor SR provider training Coalition Contractor VPK provider training Coalition Contractor EFS management Coalition Contractor Information Systems Security Coalition Contractor

The coalition’s allocations/expenditures2 for the SR and VPK programs in the fiscal year ending June 31, 2011 totaled approximately $6,909,081.

Early Learning Coalition of Brevard County Reported SR and VPK Allocations and Expenditures

Services Allocation FY 2010-2011 Expenditures (as of 9/30/11)

School Readiness (Base,R&R, Incl & Qty) $17,235,535 $4,430,427

CCEP $251,500 $20,008

Total SR $17,487,035 $4,450,435

Voluntary Prekindergarten Base $11,001,287 $2,390,686

Administration $440,051 $65,479

Total VPK $11,441,338 $2,456,165

Outreach, Awareness and Monitoring Initiative

Outreach and Awareness $12,076 $1,500

Monitoring $15,303 $981

Total OAM $27,379 $2,481

Total All Programs $28,955,752 $6,909,081

Source: Notice of Award and OEL Expenditure Worksheet

2 Expenditures in the table represent cost categories that support the scope of the accountability review and are not all-inclusive.

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Review Criteria Findings and Recommendations The following report of findings summarizes notable observations and compliance issues that the accountability review analysts observed during the monitoring. Under the terms of the Early Learning Grant Agreement between FOEL and the coalition, the coalition must submit a corrective action plan for all compliance issues within 30 days of receipt of the report. Each issue and the associated recommendation in this section of the report have a reference number. The numbered statements contain the review observations on criteria that did not comply with state and federal requirements. Some file(s) may contain more than one type of finding. The file numbers cited in each finding refer to the file(s) listed on the monitoring review spreadsheets or scorecards.

I. Coalition Governance

The recommendations address the steps that the coalition should take to correct the observed noncompliance. A corrective action plan should identify the cause of the initial finding and how to ensure continued compliance.

To ensure the success of the SR, VPK, and CCR&R programs, a coalition must have an effective executive leadership structure. The board should be the policymaking entity for the coalition, and the executive director should have the primary responsibility for implementing and managing the coalition’s policies. Each coalition establishes its own bylaws, including the selection of a method of parliamentary procedures to provide structure and organization for board business and operations. The Brevard Coalition’s bylaws set Modern Rules of Order as a standard for parliamentary procedure for voting members. A coalition’s approach to governance is important to avoid possible legal challenges to board actions.

Coalition Governance Performance Criteria (CG-A) - Board Governance 1. Does the coalition’s board membership adhere to statutory and program requirements? YES NO (Plan 0.1.1 and 0.2.1; s. 411.01(5)(a)4-13, F.S.; OEL File #206.04; and OEL File #206.05)

– The coalition has not submitted an updated board roster, since August 2010. OEL requires a coalition to submit each coalition’s board membership to the FOEL through the coalition SR plan approval process, within 60 days of board approval. According to the meeting minutes analyzed during the review, the coalition had new members join the board and members to resign which should have been reflected in a new board roster.

– According to the board roster submitted to FOEL, the coalition’s private sector membership is not more than one-third of the total membership as required by s. 411.01(5) (a) (7), F.S. The coalition has an 18 member board and only 6 of the 18 members represent the private sector. Only 33 % of the board members are from the private sector.

2. Do the board members follow a Code of Ethics as prescribed in Florida Statutes? YES NO (Plan 0.2.1 and s. 112.311(6), F.S.) 3. Do the coalition’s bylaws provide sufficient guidance to enable the board to operate effectively as a

corporate governing board? YES NO (Plan 0.2.1) 4. Does the board conduct regular, written evaluations of the executive director and are the evaluations

completed in compliance with Sunshine Law? YES NO

FOEL recommends corrective action for noncompliance with coalition governance criteria (CG-A). (1) For all findings, corrected and not corrected, identify the cause of the initial finding and how to ensure continued compliance. (2) For a finding the coalition has not corrected since the review

− Submit a current board roster to FOEL as part of the coalition SR Plan approval process to reflect new members that are added and/or members that have resigned from the board.

, the coalition should take the following corrective actions to comply with all applicable statutes, rules, and recommendations:

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− Ensure that the coalition’s private sector board membership is more than one-third of the total membership as stipulated in s. 411.01(5) (a) (7), F.S.

Coalition Governance Performance Criteria (CG-B) - Board Meeting Accessibility /Sunshine Law Are all board and committee meetings or workgroups noticed and conducted in accordance with the Florida Sunshine Law including documentation and notification requirements? YES NO (s. 286.011(1)(2), and (6), F.S. and Plan 0.1.1)

II. Operations and Program Management The team reviewed the coalition’s performance in Operations and Program Management (OPM) for the following criteria: a clearly defined organizational structure, including procedures to effectively manage coalition personnel; adherence to eligibility priorities and maintaining internal controls over federal programs consistent with laws, rules, and policies; policies and procedures to monitor both administrative, programmatic, and eligibility aspects of all contracts; processes that accurately and timely report misrepresentation and fraud; protections that ensure VPK provider profile(s) comply with law; and designated staff assigned responsibility for managing coalition’s contracts. A coalition must have policies and procedures to ensure the coalition complies with state and federal laws and regulations, and specifically with s. 287.057, F.S. A coalition must maintain all documentation related to the contract and/or grant award selection process, including the method of selection that the coalition used. Without the proper documentation, the coalition will have insufficient evidence that the coalition followed proper procedures. The coalition’s failure to adhere to the requirements could result in a conflict of interest, bid protests, and poor quality of work performed by contractors.

Operations and Program Management Performance Criteria (OPM-A) – Operations and Human Resources 1. Does the coalition’s procedures forbid discriminatory employment practices, as outlined in Florida’s

labor laws? (s. 760.10, F.S.) YES NO 2. Does the coalition have human resource policies that guide personnel decisions for hiring, firing,

employee evaluation and compensation, and reflect an effort to recruit and develop a stable, skilled staff? (Plan 1.10.1) YES NO

3. Does the coalition and contractor have grievance policies and procedures for coalition staff, providers,

and parents? (Plan 0.3.1 and 1.10.1) YES NO 4. Has the coalition and its contractor’s implemented drug free workplace policies in accordance with state

and federal law? (s. 112.0455, F.S. Drug Free Workplace Act of 1988; 29 CFR 98 Subpart F; Early Learning Grant Award Attachment B, section D) YES NO

Operations and Program Management Performance Criteria (OPM-B) – Elig ibility Policies, Priorities, and Disenrollment 1. Does the coalition’s policies ensure that the coalition does not limit the number of children enrolled with

VPK providers? (s. 10002.53(6) (a), F.S.) YES NO 2. Does the coalition have clearly defined eligibility priorities for serving children in its SR program, which

reflect the mandated eligibility priority categories? (Rule 60BB-4.201-4.207, F.A.C.) YES NO 3. Does the coalition have written policies and procedures for non-priority SR children that ensure that

non-priority SR children receive services according to coalition policy and only after all identified priority children have been served? (Rule 60BB-4.200(2), F.A.C.) YES NO

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4. Does the coalition have written policies and procedures for dis-enrolling SR children from SR services that are in accordance with the FOEL guidance referenced in the Grant Award? (OEL-FG-240.01 and Early Learning Grant Award-12(e)) YES

NO

The coalition has written SR Eligibility Priorities, revised effective July 1, 2011, which are largely in accordance with FOEL guidance). The coalition’s Policy ELCB-SR-0009-08, for Re-determination and Termination of Services stipulates that parents must receive a 30-day written notice that services will be ending if re-determination does not occur prior to or on the last day of the eligibility period. The analyst, however, did not find specific mentioning of written notices to the affected children’s parents at least 30 calendar days before a group of children are dis-enrolled per FOEL Policy 240.04. The coalition shall not disenroll any group of children prior to consulting with representatives of the Office.

5. Does the coalition ensure the coalition has not established eligibility policies, procedures, or priority

rules that discriminate against children or their families on the basis of race, national origin, ethnic background, sex, religious affiliation, disability, and has a process to resolve discrimination complaints? (45 CFR subpart C, 98.20(b)(1), and Plan 1.10.1) YES NO

6. Has the coalition established written eligibility policies and procedures that align with Rule 60BB-4 and

s. 411.01, F.S.? YES NO

FOEL recommends corrective action for noncompliance with operations and management criteria (OPM-B). (1) For all findings, corrected and not corrected, identify the cause of the initial finding and how to ensure continued compliance. (2) For a finding the coalition has not corrected since the review

Update and revise the coalition’s SR or disenrollment policies and procedures in accordance with the Early Learning Grant Award and the FOEL Guidance 240.04 to include providing written notice to parents or guardians of at least 30 calendar days prior to disenrolling a child. Specifically, the coalition shall include the following:

, the coalition should take the following corrective actions to comply with all applicable statutes, rules, and recommendations:

• providing written notification to FOEL at least forty-eight (48) hours prior to the initiation of formal consideration by the coalition board to disenroll a group of children from early learning programs;

• providing written notification to FOEL at least five (5) business days prior to taking action to notify providers or families of a determination to disenroll a child from early learning programs.

• providing written notice to any affected child’s parent or guardian at least thirty (30) calendar days before the child is disenrolled from the School Readiness program, which includes the effective date of the child’s disenrollment;

• providing written notice to any affected child’s School Readiness provider at least thirty (30) calendar days before the child is disenrolled from the School Readiness program, which includes the effective date of the child’s disenrollment;

• allowing the continued initial enrollment of a child in a priority eligibility group in accordance with Section 411.01(6), Florida Statutes;

Operation and Program Management Performance Criteria (OPM-C) – Misrepresentation and Fraud 1. Does the coalition have policies and procedures to support the reporting of overpayment?

(60BB-4.202(2)(b), 60BB-4.203(2)(b), 60BB-4.205(2)(b), 60BB-4.400(4)(c) and (d)(1) YES NO 2. Does the coalition act upon all cases where the coalition suspects fraud and does the coalition have

appropriate fraud case referral procedures? (Accountability Guidance 250.02) YES NO The coalition had the following number of fraud referrals within the past year: 123

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3. Does the coalition have an appropriate separation of duties ensuring the personnel performing duties

related to parent/child application intake, eligibility determination, and approval do not perform duties related to accounting and reimbursement, unless the coalition has implemented sufficient internal controls to ensure proper oversight of the reimbursement process/procedures? (OMB Circular A-133.105; Subpart C.300(b); and Early Learning Grant Award Attachment D) YES NO

Operations and Program Management Performance Criteria (OPM-D) – VPK Provider Profile(s) 1. Is the provider profile of all the VPK providers in the county or multi-county region available to all

parents enrolling or registering their child in VPK? (Rule 60BB-8.201(4) (a) (5-7) and s. 1002.53(5), F.S.) YES NO

2. Does the VPK profile comply with statutory requirements by containing the following required

elements? • Services YES NO • Curriculum YES NO • Instructor Credentials YES NO • Instructor/Student Ratio YES NO • Kindergarten Readiness Rates YES NO

FOEL REQUIRES NO FURTHER CORRECTIVE ACTION. The coalition has completed the following corrective actions:

The coalition has updated the VPK Provider Profile.

Operations and Program Management Performance Criteria (OPM-E) - Contract Management 1. Has the coalition designated an individual to function as the contract manager to enforce the contract

terms and conditions in compliance with state procurement procedures? (Plan 1.1.1, s. 287.057(15), F.S., and OMB Circular A-133.300(b)) YES NO

2. Does the contract manager or designated personnel have the authority to procure for commodities and

services in compliance with state statute? (Plan 1.1.1) [s.287.057 (15), F.S., OMB Circular A-122, Attachment A] YES NO

3. Does the coalition’s board establish limits for how much coalition staff can spend before seeking board

review and approval? (Plan 1.1.1) [s.287.057 (15), F.S., OMB Circular A-122, Attachment A] YES NO 4. Does the coalition have procurement policies and procedures that are in accordance with state statutes

and federal regulations? (287.057 F.S and OMB circular A-110, Subpart C.) (Plan 1.1.1) YES NO 5. Does the coalition ensure there are no potential conflicts of interest in awarding of contracts? (s. 287.057 (17) (a) 1. F.S.) YES NO 6. Does the coalition ensure contracts receive legal review and approval before the coalition executes the

contract? (s. 287.057 (18), F.S.) YES NO

Operations and Program Management Performance Criteria (OPM-F) – Monitoring of Sub-Recipients and Child Care Providers

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1. Does the coalition conduct subrecipient monitoring for all early learning programs that are contracted, including SR, VPK, and CCRR? [Early Learning Grant Agreement Section 8; 45 CFR 74.51; OMB Circular A-133 Compliance Supplement, Part 6-4, June 2010.] YES NO

2. If the school district has notified the coalition that it will monitor the compliance of the school district’s public schools or providers for the VPK program, has the coalition requested and received the monitoring reports from the school district? (AWI-VPK 20) YES NO

3. Does the coalition have a monitoring process and tool, for on-site monitoring of VPK childcare providers, based upon the requirements of the VPK Outreach, Awareness and Monitoring Initiative Grant? YES NO

III. Data Security Integrity Data Security Integrity Performance Criteria (DSI-A) - EFS Data and Reporting Systems Accuracy

The law requires each coalition to use the Enhanced Field System (EFS), the “single statewide information system” established by the Office under s. 411.01(5) (c) 1.e., F.S. The coalition must use the EFS database to establish eligibility for child care funding. EFS data must accurately reflect the most current household circumstances that the applicant presented to the coalition. EFS data is the basis for reimbursement and federal and state reporting.

The review team compared 33 SR and 32 VPK child eligibility file(s) against the EFS database records for accuracy of entry, timeliness of processing actions, case history note narrations, and data security. In addition, the team reviewed the file(s) for correct parent fees, eligibility dates, family income, household size, and correct demographic data. The team reviewed EFS data to ensure that the data matched the application.

1. Does the information in each SR child file match the information in EFS? YES NO

2. Does the information in each VPK child file match the information in EFS? YES NO

3. Does the information in each VPK provider file match the information in EFS? YES NO The following file(s) did not comply with all applicable statutes, rules, and recommendations: #40-41, and 76 #40 – The coalition provided a copy of the local law enforcement check for an instructor that has both of the instructor’s last names; however, the review analyst was unable to read the stamp from the law enforcement office and the instructor did not sign the local law enforcement document. #76 – The coalition provided a copy of the history note update to show changes made to the classroom. The review team did not receive a screen print to show that the coalition updated EFS. The review analyst checked EFS on 10.13.2011 and no update was shown; however, system delay may be the reason for the information not showing.

FOEL REQUIRES NO FURTHER CORRECTIVE ACTION. The coalition has completed the following corrective actions:

The coalition has corrected #40, 41, and 76.

Data Security Integrity Performance Criteria (DSI-B) - Information Systems Security

In accordance with the coalition’s Early Learning Grant Agreement, the coalition shall comply with the Computer-Related Crimes Act, Chapter 815, F.S., and demonstrate due diligence in safeguarding the coalition’s information resources by establishing policies and procedures for information systems security that contain criteria and standards according to the Office’s Policy 5.02, Information Systems Security Program. The coalition shall develop specific security protocols that include at a minimum the Office’s 5.02 protocols #4 - Security Training and Awareness, #10 – Contingency Planning, #11 - Access Control, #12 - Identification and Authentication, #16 - Personnel Security, #22

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- Mobile Computing, #25 - Remote Access, #30 - Database Security, #31 - Media Management, and #32 - Password Management, as well as Records Confidentiality Compliance and the Data Security Agreement from the Early Learning Grant Agreement. The coalition was evaluated for compliance using the EFS Data Security Review Checklist.

Does the coalition comply with the AWI Data Security Protocol Series 5.02.III.C? YES NO

IV. Child Care Resource and Referral CCR&R serves as the “front door” to all services offered through a coalition and the coalition’s contracted service provider. In accordance with Rule 60BB-9.300, F.A.C., a coalition must offer a parent assistance with locating child care and information, which will help the parent make an informed decision, as well as additional information and community resources as appropriate.

A coalition shall follow the minimum standards required to guide the coalition in delivering CCR&R services to a family. CCR&R requirements address issues, such as customer service criteria, staff training and certification, consumer services and information, and database maintenance. Each CCR&R specialist should be prepared to explain various types of legally operating early learning and school-age child care providers (including all licensed and license exempt centers; faith based providers; licensed, registered, and large family child care homes; school-age care providers; SR providers; VPK providers; Head Start providers; Early Head Start providers; nanny/au-pair agencies; and summer camp providers). A coalition must provide a family who is offered CCR&R services with options and resources in addition to wait list placement. A family enrolling a child in the VPK program may request a complete list of all VPK providers in the area or receive a customized list of VPK providers in the area that best matches the needs of the family.

The Brevard Coalition conducts all CCR&R services, such as providing child care consumer information, establishing a toll-free telephone system, and maintaining and managing a comprehensive database of all early child care and education caregivers and community resources in Brevard County, among other resource and referral services.

The following table shows the number of completed referrals generated by the coalition’s CCR&R services, based on the size of the birth to 5-year-old population and in comparison to similarly-sized coalitions. *Note: this table is for informational purposes only. The table does not reflect differences in the coalitions’ SR budgets and therefore should not be solely relied upon to determine the performance of a coalition.

2010 Coalition Comparison of Completed Referrals

Coalition Brevard Seminole Big Bend

Referrals 5,900 6,088 5,177

Percentage 18% 20% 18%

0–5 Population 31,985 30,341 28,798

Source: CCR&R County Comparison Report, 2010.

Child Care Resource and Referral Program Criteria (CCR&R-A) - Delivery of CCR&R Services

According to the CCDF Plan, the expected result of the CCR&R activities is to ensure that the coalition makes CCR&R services available and accessible to all Florida families. The CCR&R services support families in becoming self-sufficient and making informed decisions about child care.

Does the coalition adhere to requirements and the Office’s recommendations about CCR&R services? YES NO

CCR&R Program Criteria (CCR&R-B) - Informational Packet

Does the coalition provide an informational packet to each individual requesting service within six business days after the individual requested services and does the coalition ensure that each informational packet contains the minimum information? YES NO

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Calls #1, #2, and #3 resulted in informational packets being received within 6 days and the informational packets received from calls #2, #3, and #4 were complete.

However, the cover letter from call #1 did not include the required contact information for the State Child Care Resource and Referral Network, resulting in an incomplete packet. The same cover letter was also submitted by the coalition as part of the initial document submission. Cover letters emailed with other packets included all required information.

An informational packet from call #4 was not received within 6 days, but a follow-up call to the specialist found that the packet had been sent to an incorrect email address. The specialist then emailed another packet, which was received.

FOEL REQUIRES NO FURTHER CORRECTIVE ACTION. The coalition has completed the following corrective action:

Technical assistance was provided to the coalition on 10/5/11 by the State CCR&R Network. Additionally, the coalition revised the cover letter after call #1 to meet the requirements.

All cover letters that go out to families include all of the required information and links and informational packets are provided to each individual requesting services within six business days of the date which services was requested.

In the future, to comply with all applicable statutes, rules, and recommendations, the coalition should ensure the following:

CCR&R Program Criteria (CCR&R-C) - Consumer/Community Services

Does the coalition adhere to requirements and the Office’s recommendations about consumer/community activities? YES NO

CCR&R Program Criteria (CCR&R -D) - Provider Information

Does the coalition provide the minimum information about each organization? YES NO

Five of the six providers reviewed were found to have discrepancies between the update forms and the information in EFS, as follows:

• Program participation - provider update form indicates VPK school year program, but EFS has VPK summer program

Weekday Preschool - Our Father's House:

• Enhanced schedule - provider update form indicates vacation/holiday, but it is not in EFS

Transportation - provider update form does not have To Site from Home checked, but it is in EFS Shirley Crowder Family Daycare:

Demographics - Update form has address as 132 Hilton Avenue NW, and the NO box is checked re: does the provider want childcare referrals but the EFS address does not have NW and the Accepts Referrals box is checked. There is reference to the referrals issue in the history notes, but no explanation as to why the Accepts Referrals box is checked.

Patti's Playhouse:

• Schedule - Update form says ages served are birth to 12 years but EFS says birth to 1 year Learning Street Child Care Center:

• Staffing - Update form says 1 staff person has a Director Credential Foundational, but EFS says Director Credential Advanced

• Rates – Date on Rates Table (7/12/11) is not the same as the last update (8/12/11)

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• Transportation - history notes and note added to this section on the update form indicate provider asked to add Hope Private and Calvary schools to the list of schools that transportation is provided from and to. However, EFS does not have them listed.

Giggles Preschool and Day Care:

FOEL REQUIRES NO FURTHER CORRECTIVE ACTION. The coalition has completed the following corrective actions:

The coalition submitted the appropriate documentation.

V. Educational Services Delivery During the review, the team looked at the required components for the implementation of the coalition’s SR Plan, amendments and outcome measures, as stated in s. 411.01(5)(c) and (d), F.S. The components include ensuring the use of developmentally appropriate curricula by providers, implementing health and developmental screenings and assessments for children participating in the program, coordinating staff development and provider training, and fostering parental support and involvement.

Educational Services Delivery Program Criteria (ESD-A) - Developmentally Appropriate Curriculum 1. Does the coalition demonstrate compliance with its SR Plan for ensuring SR providers use

developmentally appropriate curricula? (Plan Sections 4.3.1 and 4.3.3) YES NO

The coalition has not demonstrated compliance with the following outcome measure for Plan Section 4.3.3. • (2) 98% of all SR funded providers not currently using an approved curriculum will attend trainings on

utilizing developmentally appropriate curricula as seen by training rosters

• The coalition did not provide evidence that the providers who were found to not be using approved curricula during 2009-10 attended training on the curricula that the provider chose to implement during 2010-11. The coalition did not provide evidence that it monitors the Florida Children's Forum for this outcome measure.

2. Does the coalition ensure that all SR providers are using the curricula as specified in agreement,

voucher, or contract? (Plan Sections 4.3.1 and 4.3.3) YES NO

FOEL recommends corrective action for noncompliance with educational service delivery criteria (ESD-A). (1) For all findings, corrected and not corrected, identify the cause of the initial finding and how to ensure continued compliance. (2) For a finding the coalition has not corrected since the review

The coalition should either include a monitoring section in the tool it uses to monitor the contract with the Florida Children's Forum, and track providers to ensure those not using an approved curriculum attend trainings or complete a SR plan amendment to revise or delete this outcome measure in Plan section 4.3.3.

, the coalition should take the following corrective actions to comply with all applicable statutes, rules, and recommendations:

Further action for 30-day corrective action plan

Educational Services Delivery Performance Criteria (ESD-B) – Improving the Quality and Availability of Child Care Services

: identify the cause of the initial finding and how to ensure continued compliance.

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1. Does the coalition demonstrate collaboration with local licensing agencies, community organizations and entities to support unique populations, children at-risk, children with disabilities and special health care needs? (Plan 2.5.1) YES NO

2. Does the coalition demonstrate compliance with the coalition’s plan for ensuring the establishment of

partnerships with existing local entities for offering special services or supplies for unique population, such as migrant workers and including children who are homeless? (Plan 3.6.1) YES NO The coalition has not demonstrated compliance with the following outcome measures (2) and (3) for Plan Section 3.6.1:

– (2) 100% of special needs children receiving school readiness services will be assessed for their involvement and/or eligibility for specialized services through the identified resources as evidenced through the monitoring.

– (3) 100% of all families in need of specialized services will receive referrals or services within 10 days.

The coalition submitted a listing of 2010-11 Inclusion Referrals and the 09-10 and 10-11 Special Needs Referral List, as documentation for these outcome measures. However, none of the documents provided evidence of the percentages of children that were assessed and referred within 10 days, or proof that these outcome measures were tracked or had been met.

FOEL recommends corrective action for noncompliance with educational service delivery criteria (ESD-B). (1) For all findings, corrected and not corrected, identify the cause of the initial finding and how to ensure continued compliance. (2) For a finding the coalition has not corrected since the review

The coalition should either implement a tracking system to ensure compliance with SR Plan section 3.6.1 outcome measures (2) and (3), or complete a SR plan amendment to revise or delete these outcome measures.

, the coalition should take the following corrective actions to comply with all applicable statutes, rules, and recommendations:

Further action for 30-day corrective action plan

Educational Services Delivery Performance Criteria (ESD-C) – Skill Building Opportunities and Economic Self Sufficiency for Families

: identify the cause of the initial finding and how to ensure continued compliance.

1. Does the coalition demonstrate compliance with the coalition’s plan for ensuring the provision of parent

involvement and skill-building/education opportunities? (Plan Sections 3.4.1) YES NO

The coalition has not demonstrated compliance with the following 3 outcome measures for Plan Section 3.4.1:

– (1) Florida First Start will offer at least 4 parent education classes annually. Monthly reports and coalition monitoring will indicate the level and type of involvement provided by the parent during home visits and the activities performed, including parent education classes.

Although the coalition's current contract with Florida First Start requires "monthly parent education sessions for parents with similarly aged children”, the coalition did not provide specific documentation that these sessions are taking place. FFS record review forms (monitoring form used by the coalition) include a section that asks the reviewer to note if there is documentation in the file that parent support and training has been provided. A review of the 7 sample record review forms submitted shows that most of the documentation is from activities with parents and children during home visits or field trips. The coalition also submitted FFS Monthly Reports for April, May and June of 2011 as documentation for this outcome, but the analyst review did not find any reference to parent education classes.

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– (2) At least 4 training/educational activities will be offered to parents annually, including, at the minimum, the following topics: FL Birth to 3 Standards; FL SR Standards for Three and Five Year Olds, and FL DOE VPK Standards. A minimum of 25 parents/caregivers will attend the above-referenced trainings as demonstrated by quarterly reports submitted to the coalition and attendance records reviewed during onsite coalition monitoring of the subcontracted training provider.

The coalition submitted a Family Training Opportunities Summary. The coalition also submitted sign –in sheets from various VPK Standards trainings and one Birth to 3 training, but it appears that only providers attended these trainings. A review of 2010 and 2011 coalition calendars available on the website shows that a large number of trainings took place. However, they all appear to be targeted toward providers. The parent resource page on the coalition's website does not give any information about training the coalition offers that would be helpful to parents. The coalition did not submit any other verification of training made available to parents or of ways the coalition notifies parents of training opportunities.

– (3) Quarterly family newsletters sent to providers for distribution to parents will contain appropriate skill building information and literacy resources as evidenced by coalition review of newsletters.

The coalition submitted newsletters published by the Florida Children's Forum for summer 2010 and spring 2011 as evidence that this outcome measure has been met. A review of the newsletters found that they appear to be targeted toward providers and those who work in the child advocacy field. There did not appear to be any skill-building information or literacy resources for parents.

2. Does the coalition demonstrate compliance with the coalition’s plan for providing information or referrals about family literacy programs? (Plan Sections 3.4.2) YES NO

The coalition has not demonstrated compliance with the following outcome measures (4) and (5) for Plan Section 3.4.2: – (4) Quarterly newsletters will be sent to all childcare providers for distribution to parents and families

The coalition was asked to provide a summary of yearly newsletter distribution, including the manner of distribution and the number distributed for 2009-10 and 2010-11. No information was submitted, other than samples of 2 Children's Forum newsletters, which appear to be targeted to providers rather than parents.

– (5) A minimum of 4 family training opportunities will be provided annually. The coalition was asked to provide evidence of 4 family training opportunities that had been offered during 09-10 and 10-11, but did not submit documentation specific to family literacy training for families not enrolled with the Florida First Start program. The coalition provided a Family Literacy Summary which included information about a distribution of books to families during eligibility appointments.

3. Does the coalition demonstrate compliance with the coalition’s plan to ensure the provision of

family support services to help achieve economic self-sufficiency? (Plan 3.5.1) YES NO

The coalition has not demonstrated compliance with outcome measures (2) and (3) of Plan Section 3.5.1:

• (2) 95% of families attending a scheduled appointment at a Brevard Workforce location will be offered child care resource and referral information as well as eligibility services necessary to enroll their children in appropriate early learning programs

For this outcome measure, the coalition uploaded a sample of EFS interview screens and history notes showing the CCR&R services that were provided.

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The coalition also submitted client survey results for 2010-11,} which showed response to the statement "I was given resources to help choose a child care provider", as follows: 67 surveys were returned. Of those, this question was answered by 44 customers. 7 indicated the statement was not applicable to them. Of the remaining 37 responses, 34 (92%) agreed or strongly agreed with the statement and 3 disagreed or strongly disagreed with the statement. Since this is such a small number of the families who come to the workforce locations for eligibility interviews, the results may not be a reliable indicator.

The coalition was asked to provide tracking evidence that CCRR information was given to families with appointments, but no further tracking information was provided. The coalition was also asked to provide a policy/procedure that mandates an offer of CCRR services for each family attending a scheduled appointment, but noted in an email that there is no formal policy in place.

• (3) 90% of families who have been identified through the needs assessment as requiring further assistance or who have requested assistance will have received a referral to the appropriate community agency; thus assisting parents to utilize all community resources available to them

The coalition provided a sample of a completed Family Resource Request Form and follow-up information provided to the family. Once a family has identified certain needs, the Family Resource Specialist accesses an information database that contains a variety of resources. Family needs are matched to services in the database, and each family is then given an individualized list of agencies and contact information.

The coalition submitted a blank Family Resources Tracking Log as evidence of tracking for this outcome measure. A request was made for samples of completed tracking logs, but the coalition’s response indicated that the form is not in use. No other tracking information was provided.

Previous Compliance Issue:

FOEL recommends corrective action for noncompliance with educational service delivery criteria (ESD-C). (1)

The previous Performance Review (CPR Report 09-05) also had a finding in this area. The finding indicated that the coalition did not have a process in place to track referrals.

For all findings, corrected and not corrected, identify the cause of the initial finding and how to ensure continued compliance. (2) For a finding the coalition has not corrected since the review

− The coalition should enhance its parent education programs and services for outcome measures (1), (2) and (3) of Plan Section 3.4.1, or complete a SR plan amendment to revise, delete, or add to these outcome measures and submit to the Office for approval.

, the coalition should take the following corrective actions to comply with all applicable statutes, rules, and recommendations:

− The coalition should follow and track measurable outcomes (4) and (5) for Plan Section 3.4.2; family literacy services, or completes a SR plan amendment to revise or delete these outcome measures and submit to the Office for approval. .

− The coalition should implement a tracking system to track outcome measures (2) and (3) of Plan Section 3.5.1; or complete a SR plan amendment to revise or delete the outcome measures and submit to the Office for approval. .

Further action for 30-day corrective action plan

VI. School Readiness Eligibility

: identify the cause of the initial finding and how to ensure continued compliance.

Review of the following SR eligibility criteria includes: eligibility applications, referrals, redeterminations, hours of care, rights and responsibilities/terms and conditions, parents rights, parental choice, immunization, child’s age, definition of a parent, residency, citizenship/immigration status, priority groups, family unit income, worksheets, and payment validation.

The review team examined 33 SR child file(s) for compliance with the SR program governed by Title 45 CFR, parts 98 and 99, Child Care Development Fund Plan (CCDF) Parts 3 and 4, s. 411.01, F.S., and Rule 60BB-4 (F.A.C.). Three of the reviewed file(s) contained one or more findings.

SR Elig ibility Criteria (SR-A) - Application Process

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An SR child file must include an application that the parent has signed and dated. A parent should sign an application at the initial eligibility determination and updated annually. A parent may submit an application via mail, facsimile, or electronic signature. (Rule 60BB-4.200-207, F.A.C.)

1. Does the coalition have a completed, signed, and dated application on file for each child file reviewed: (45 CFR 98.20(b); CCDF Plan 4.1, Rule 60BB-4.100, F.A.C.) YES NO

2. Does the coalition have a completed, signed, and dated payment certificate for each child file reviewed? (s. 411.01 (7) (c), CCDF Plan 3.1.1.) YES NO

SR Elig ibility Criteria (SR-B) - Referrals (if applicable)

Several child care eligibility categories for SR services require a documented referral. For all partner referral programs, the coalition should have a documented referral and ensure the coalition approves child care for the period authorized on the referral, if the authorized period is within program guidelines and the child meets SR program guidelines. (Rule 60BB-4.201, 4.202, 4.204, and 4.206, F.A.C.).

1. Is there a documented valid referral on file for each applicable child? (45 CFR 98.20(b); Rule 60BB-4.100, 4.201, 4.202, 4.204, and 4.206, F.A.C.) YES NO

2. Does the current referral form include the correct authorized eligibility period? (Rule 60BB-4.201 and 4.202, F.A.C.) YES NO

3. Does the authorized child care period match the referral period? (Rule 60BB-4.201 and 4.202, F.A.C.) YES NO

SR Elig ibility Criteria (SR-C) - Timely Delivery of Services for Priority Groups

A coalition’s eligibility determination should be timely, ten days from receipt of the referral for TANF and At-Risk programs (CCDF Plan 3.4, Early Learning Grant Agreement). For priority groups the coalition must offer services within ten calendar days from receipt of the referral.

1. Did the coalition authorize each case within ten calendar days from receipt of the referral? (Early Learning Grant Agreement #37) YES NO

2. If the coalition did not authorize services to a family, did the coalition submit written notification to the referring agency and the Office at [email protected], no later than close of business ten calendar days from receipt of referral? YES NO

SR Elig ibility Criteria (SR-D) - Authorized Hours of Care

Authorized hours of care for all child care services shall meet the definition of unit of care. The amount of care is related to purpose for care plus reasonable travel time.

Do the hours of care authorized reflect the amount of care needed? (Rule 60BB-4.100(12) and (19), F.A.C.) YES NO

SR Elig ibility Criteria (SR-E) - Elig ibility Period and Redetermination

A coalition must provide services to a family within the eligibility period. Eligibility begins only after the coalition has established all factors of eligibility. A coalition should re-determine eligibility annually, at a minimum, with an additional fifty percent of child file(s) re-determined during the same fiscal year through a statistically valid random sample (Rule 60BB-4.209, F.A.C.). A coalition must stop all funding at the re-determination due date if the coalition has not yet fully reestablished eligibility in accordance with the coalition’s re-determination policy.

1. Does the coalition re-determine/reauthorize each case before the end of the authorization period? (Rule 60BB-4.209, F.A.C.) YES NO

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2. Is the coalition current on redeterminations? YES NO One overdue redetermination - the coalition states when the parent re-determined on January 7, 2011 they were given until June 9, 2011 to redetermine the next time. The parent did not follow through on June 9, 2011; the case was terminated on June 10, 2011. EFS was not updated to reflect the termination.

FOEL REQUIRES NO FURTHER CORRECTIVE ACTION. The coalition has completed the following corrective actions:

The coalition has corrected the finding.

SR Elig ibility Criteria (SR-F) - Parental Rights and Responsibilities/Terms and Conditions

An SR file should have a signed and dated Rights and Responsibilities/Terms and Conditions notification that includes the required minimum information as noted in the SR Standard Eligibility Review Program. The document should also be re-signed annually at a minimum or when the content of the form changes.

1. Is there evidence that the coalition notified the parents of their rights and responsibilities? (45 CFR 98.30-34, 46, and 60; CCDF Plan 4.1; Rule 60BB-4.202-4 (2) (b) and 4.401, F.A.C.) YES NO

2. Did the Rights and Responsibilities notification contain, at a minimum, the following information?

• A statement that the coalition explained and offered parental choice of child care settings. The law requires that the coalition serve protective services children in licensed care. This may limit the choice of provider. (45 CFR 98.30, CCDF Plan 4.1) YES NO

• A parent’s right to notification of decisions and the right to appeal any decision, including reductions in or termination of services. (45 CFR -98.32) YES NO

• A loss of funding notice. (Rule 60BB-4.209(2), F.A.C., 45 CFR 98.60) YES NO

• An authorization for release of information to the Florida Department of Law Enforcement if false information is provided or there is other reason to suspect fraud. (s. 411.011(3) (g) F.S.) YES NO

• A statement that the family is responsible for reporting all changes within 10 calendar days (this does not apply to protective services clients) and the consequences of not reporting these changes. (Rule 60BB-4.202(2) (b), 203(2) (b), and 205(2) (b), F.A.C.) YES NO

• Notification of a family’s right not to be discriminated against for race, national origin, ethnic background, sex, religious affiliation, and disability. (45 CFR 98.20, and 98.46) YES NO

• A parent’s obligation to pay parent fees and consequences of non-payment. (CCDF Plan 3.5, Rule 60BB-4.401, F.A.C.) YES NO

• A parent’s right to be allowed unlimited access to their child during normal hours of provider operation and whenever the child is in the care of a provider. (CCDF Plan 4.3, 45 CFR 98.31) YES NO

SR Elig ibility Criteria (SR-G) - Parental Choice

Federal regulations of child care funds require that a coalition allow parents to choose a child care arrangement from a variety of providers, including licensed and non licensed providers. The coalition should retain documentation showing that the family was provided information on parental choice. If the coalition did not include parental choice as a sign-off on the Rights and Responsibilities/Terms and Conditions notification, then the file must contain documentation that the coalition explained and offered parental choice to the parent.

Is there documentation in the file that the parent received information about parental choice? (45 CFR 98.16(k), 98.30 (a) through (e); 98.41(a)(i); s. 411.01(7), F.S., CCDF Plan 4.1) YES NO

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SR Elig ibility Criteria (SR-H) - Immunization and Health Requirements

A coalition shall ensure that a child receiving services under CCDF is age-appropriately immunized or exempt from immunization. In accordance with s. 411.01(4)(j), F.S., the coalition must ensure that the program provider obtains information about the child’s immunizations, physical development, and other health requirements as necessary, including appropriate vision and hearing screening and examinations within 30 days after enrollment. For program provider’s licensed by the Department of Children and Family Services, the provider’s compliance with s. 402.305(9_), F.S., as verified pursuant to s. 402.311, F.S., shall satisfy this requirement. A coalition should have a procedure to review a Department of Children and Families (DCF) Licensing Department’s monitoring report of an SR provider (s. 411.01(4)(j), F.S.). The Office has only exempted children whose parents object to immunization on religious grounds and children with a medical condition that contraindicates immunization (s. 6.7, CCDF Plan, and 45 CFR 98.41(a) (i)).

1. Does the coalition’s immunization practices adhere to s. 411.01(4) (j), F.S.? YES NO

2. Has the coalition ensured that each child receiving services under CCDF is age-appropriately immunized or does the child fall under an allowable exemption? YES NO

SR Elig ibility Criteria (SR-I) - Child’s Age Requirements

In accordance with state and federal regulations, a child must be under the age of 13, or up to age 19 if physically or mentally unable to care for himself or herself or under court supervision to be eligible for the SR program 45 CFR 98.20, CCDF Plan 3.3, s. 411.01(6), F.S., and Rule 60BB-4.200, F.A.C.).

Is each child younger than 13 years of age or is each child younger than 19 years of age and physically or mentally incapable of caring for himself or herself or under court supervision? (45 CFR 98.20(a) (1); Rule 60BB-4.200, F.A.C.) YES NO

SR Elig ibility Criteria (SR-J) - Definition of a Parent

Federal regulation provides the definition of a parent for the purpose of establishing a child’s eligibility for services (45 CFR 98.2). A parent means a parent by blood, marriage, or adoption, and also means a legal guardian or a person standing in loco parentis (45 CFR 98.2 and Rule 60BB-4.100, F.A.C.). Florida law states that a parent is a parent of a student, a guardian of a student, a person in a parental relationship to a student, or a person that exercises supervisory authority over a student in place of the parent (s. 1000.21(5), F.S.). In loco parentis is defined as a person acting as the temporary guardian of a child (Rule 60BB-4.100, F.A.C.), which may include any blood relative or any person who has received temporary custody through a court order. A coalition should ensure that a client meets the definition of a parent.

Does each parent meet the definition of a parent? (45 CFR 98.2; Rule 60BB-4.100, F.A.C.) YES NO

SR Elig ibility Criteria (SR-K) - Residency Requirements

A coalition should ensure that a family’s file includes information that the family currently resides in the state. The coalition may verify residency information with documentation that includes an in-state physical address. There is no minimum length of time a person must reside in Florida to obtain benefits. The family members may also be a temporary resident in a domestic or homeless shelter in Florida or authorized emergency management location. A TANF client must be a Florida resident and the referring agency verifies residence during the TANF application process (s. 414.095(2) (a), F.S.).

1. Is each applicant a resident of Florida? (45 CFR 98.20 (2) and (3) (i)) YES NO

2. Did the coalition authorize child care by county of residence? YES NO

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SR Elig ibility Criteria (SR-L) – U.S. Citizenship/Immigration Status

A child must be a U.S. citizen or a qualified alien, to qualify for SR services (CCDF-ACF-PI-2008-01). If a child was born outside of the U.S., the coalition must ensure that documentation exists in the child’s file to support the child’s legal status.

Is each child a U.S. citizen or a qualified eligible alien? (Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA); (62 FR 61344) YES NO

SR Elig ibility Criteria (SR-M) - Family Unit Income

An SR child file must include a completed SR Income Worksheet (SR-100) to determine a child’s eligibility and establish the applicable parent fee, based on the sliding fee scale included in the coalition’s approved SR plan. If the family counts the individual as a family member, the eligibility specialist should include any income the individual may receive as part of the total family income. If the family lives with an aunt, uncle, or grandparent or other adult who the family does not support, the specialist should not count the individual or the individual’s income in the family size or income. If a parent/guardian lives with a friend who is not a biological or legal parent/guardian of a minor child that is eligible for care, and the friend does not contribute money or consider himself or herself part of the household, then the eligibility specialist should not include the friend in the household. The Office’s rules provide guidelines for verification of employment and income (Rule 60BB-4.208, F.A.C.).

For each child file, does the coalition have the following information on file:

1. A completed SR Income Worksheet for Eligibility and Parent Copayment (SR-100)? (45 CFR 98.20(2); Rule 60BB-4.100 and 4.208, F.A.C.) YES NO

2. Earned and unearned family income fully supported by the appropriate documentation? (45 CFR 98.20(2); Rule 60BB-4.100 and 4.208, F.A.C.) YES NO

3. Earned and unearned family income correctly calculated on the SR Income Worksheet for Elig ibility and Parent Copayment (SR-100)? (45 CFR 98.20(2); Rule 60BB-4.100 and 4.208, F.A.C.) YES NO

SR Elig ibility Criteria (SR-N) - Family Unit Size

Family unit size must meet the state income threshold in Section 3.3.2 of Florida’s CCDF State Plan and the coalition’s SR Plan. A family may consist of a parent or parents living together, a parent’s minor child, and any other minor child for whom the parent is legally responsible. A family may also include any other adult that the parent considers part of the family, such as an aged grandparent that the family supports. (Rule 60BB-4.100(9), F.A.C.)

Has the coalition clearly defined each family unit size and relationship to establish compliance with income threshold requirements? (Rule 60BB-4.100, F.A.C.) YES NO

SR Elig ibility Criteria (SR-O) - Maximum Family Unit Income Threshold

The family applying for services must meet income eligibility requirements to be approved for service unless the service is available without regard to income. The Office’s rules provide guidelines for verification of employment and income (Rule 60BB-4.208, F.A.C.). An applicant must fully declare household circumstances and income on the application.

Does the family unit size and income meet the federal and state income threshold (if applicable)? (45 CFR 98.20(a) (2), Rule 60BB-4.208, F.A.C.) YES NO

The following file(s) did not comply with all applicable statutes, rules, and recommendations: #22 and 23

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FOEL REQUIRES NO FURTHER CORRECTIVE ACTION. The coalition has completed the following corrective actions:

The coalition has corrected #22 and 23.

SR Elig ibility Criteria (SR-P) - Parent Copayment

Each family that receives SR services shall be assessed a copayment based on family size and the family’s income, according to the sliding fee scale included in the coalition’s approved SR plan. (CCDF Plan 3.5.1, Rule 60BB-4.400, F.A.C.).

Was the parent copayment correctly determined based on the approved sliding fee scale? (45 CFR 98.42(a) and (b); Rule 60BB- 4.400, F.A.C., s. 411.01 (5) (d) 4.a, F.S.) YES NO

The following file(s) did not comply with all applicable statutes, rules, and recommendations: #22 and 23

FOEL REQUIRES NO FURTHER CORRECTIVE ACTION. The coalition has completed the following corrective actions:

The coalition has corrected #22 and 23.

SR Elig ibility Criteria (SR-Q) – Parent Copayment Reduction or Waiver

A copayment may be temporarily reduced to the minimum fee (Rule 60BB-4.400(1)(a)2, F.A.C.) or temporarily waived for a foster parent and a family participating in an At-Risk program (Rule 60BB-4.400(1)(c), F.A.C.) on a case-by-case basis during an event that limits a parent’s ability to pay. Under the standard process for reducing or waiving a copayment, the referring case manager checks a box on the referral or provides other written documentation requesting the fee reduction.

1. If applicable, is there a documented request for a temporary fee waiver or reduction in the child’s file? (45 CFR 98.42(c), 98.20 (A); Rule 60BB-400(1) and (2) F.A.C.) YES NO N/A

2. Does the request identify the reason for the fee waiver? YES NO N/A

SR Elig ibility Criteria (SR-R) – Elig ibility and Billing Groups

Each family unit shall meet the state requirements for the approved eligibility and billing group. Each OCA standard code provides definitions for each billing group’s purpose for care. The same codes also give guidance when the coalition should use the income of the “child only” to calculate eligibility. The Office has established standard codes (Office of Early Learning Standard Codes) to categorize specific eligibility groups that are critical to the ability of the Office and the Office’s stakeholders to properly report on federal programs. Additionally, law requires a parent to have a purpose for care to receive the funding. The Office’s standardization of codes ensures uniform and accurate data reporting on local, state and federal reports. The coalition’s incorrect use of codes affects the accuracy of reporting, payments, and reimbursements.

Does the billing group match the program requirement for purpose for care? (45 CFR 98.20. Rule 60BB-4.100, 4. 201 and4.207; F.A.C., OEL Standard Codes) YES NO

SR Elig ibility Criteria (SR-S) - Purpose for Care

A child’s eligibility for child care services depends on an established purpose for care (45 CFR 98.20 and Rule 60BB-4.200, F.A.C.). Without a purpose for care, a family may not be eligible for SR services. The Office has established standard codes (Office of Early Learning Standard Codes) to categorize specific eligibility groups that are critical to the ability of the Office and the Office’s stakeholders to properly report on federal programs. Additionally, law requires a parent to have a purpose for care, to receive the funding. The Office’s standardization of codes ensures uniform and accurate data reporting on local, state and federal reports. The coalition’s incorrect use of codes affects the accuracy of reporting, payments, and reimbursements. The coalition must ensure that each parent or guardian living in the same household of any child that requests funding has a purpose for care.

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Does each parent meet the purpose for care requirement? (45 CFR 98.20(3)(i) and (ii); Rule 60BB-4.201-207, F.A.C. and Office of Early Learning Standard Codes) YES NO

SR Elig ibility Criteria (SR-T) – Qualifying Care and Provider Arrangement

In order to receive SR funds for providing child care services, a provider must be eligible to legally provide child care services and must have a fully executed SR Provider Agreement with the coalition in order to receive payment. A parent may choose from a variety of eligible child care types, including the following: center-based, group home, family, in-home, or other child care provider type that is licensed, regulated, or registered under state or local law and satisfies state and local requirements (45 CFR 98.41 and 98.2). For children who are at-risk of abuse or neglect, informal child care may only be authorized by exception when no licensed child care homes or facilities are available within close proximity to work or home (CCDF Plan 3.1.4).In addition, an individual 18 years old or older who provides child care services only to an eligible child who is related by marriage, blood, or court decree as the grandchild, great grandchild, or sibling who does not live with the provider, niece, or nephew, can also be an eligible child care provider as long as the individual complies with certain requirements (45 CFR 98.2).

1. Did the coalition determine that only legally operating providers that met the regulatory requirements are providing services for the children in the review sample? YES NO

2. Did the coalition determine that the provider had a fully executed SR Provider Agreement in place prior to receiving SR funds from the coalition? YES NO

3. Were the reviewed protective services families’ enrolled in a licensed child care facility or an unlicensed provider approved by the referring counselor and supervisor, as applicable? YES NO

SR Elig ibility Criteria (SR-U) – Previous Corrective Actions

Did the coalition implement SR eligibility corrective actions as indicated in the previous Accountability Unit review? YES NO

VII. Voluntary Prekindergarten Child Eligibility The VPK law requires the Office to adopt procedures that govern the enrollment and eligibility determination of a child in the VPK program by a coalition or school district (s. 1002.75(2) (a), F.S.). A coalition determines the eligibility of a child in accordance with Rule 60BB-8.200 and 8.202, F.A.C.

The review team examined 32 VPK eligibility file(s) for compliance. None of the reviewed file(s) contained one or more findings.

VPK Child Elig ibility Criteria (VPKC-A) - Age and Residential Elig ibility Requirement

A child who resides in Florida and will be four years old on or before September 1 is eligible for the VPK program during that program year (s. 1002.53(2), F.S., and Rule 60BB-8.200 (1) and (2), F.A.C.). A parent who enrolls a child in VPK must complete and submit an application to the coalition, as established under s. 1002.53(4) (a), F.S. and Rule 60BB-8.201(1), F.A.C.

1. Has the coalition determined and documented each child’s age? Is each child four years of age on or before September 1 of the program year and is the appropriate documentation in the file? (Rule 60BB-8.200(1), F.A.C; s. 1002.53(2), F.S.) YES NO

2. Does each applicant reside in the State of Florida and is the appropriate documentation in the file? (Rule 60BB-8.200(2), F.A.C.; s. 1002.53(2), F.S.) YES NO

VPK Child Elig ibility Criteria (VPKC-B) - Child Registration

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A parent that registers a child for the VPK program must complete and sign a Form AWI-VPK 01 (Child Application); or alternatively a parent may register online through the Internet website, submit the registration, and print confirmation of the online registration.

A coalition determines a child’s eligibility face-to-face with the child’s parent unless the coalition is not required, under Rule 60BB-8.201(4) (b), F.A.C., to conduct a parent-orientation session or exhibit a parent-orientation video for the child’s parent. Once the coalition determines that a child is eligible for the VPK program, the coalition issues the child’s parent a Form AWI-VPK 02 , (Child Eligibility and Enrollment Certificate (COE)) either completed by the coalition as a paper form or as an electronically generated and printed form using the Enhanced Field System (EFS) (Rule 60BB-8.202(1)(c), F.A.C.). The form must be signed by the provider and the parent. To enroll an eligible child, the VPK provider admitting the child must submit the child’s COE to the coalition.

If necessary, a parent must re-register his or her child for the VPK program with the coalition of the county where the VPK provider site is located if the parent initially registered the child with the coalition of another county. Re-registration is the responsibility of a child’s parent. To assist a parent with re-registration, a coalition may enter into one or more agreements with another coalition to provide for the transfer of a child application and supporting documents between the coalitions (Rule 60 BB-8.201 (2), F.A.C.).

A coalition shall conduct a face-to-face parent-orientation session or exhibit a parent orientation video for a parent or group of parents registering their children for the VPK program in accordance with Rule 60BB-8.201 (4), F.A.C. During the parent-orientation session or video exhibition, the coalition shall provide the parent with a copy of the VPK Parent Handbook (Rule 60BB-8.201(4) (a) (2), F.A.C.

1. Is there a signed and dated application Form AWI-VPK 01 (Child Application) or an online confirmation of the registration form on file for the child? (Rule 60BB-8.201 (1), F.A.C.) YES NO

2. Has the coalition determined each child eligible and was Form AWI-VPK 02 (Child Eligibility and Enrollment Certificate (COE)) completed, signed, and issued? (Rule 60BB-8.202(1) (c), F.A.C.) YES NO

3. Is there a completed Form AWI-VPK 02 (Child Eligibility and Enrollment Certificate) indicating the child’s assignment to a VPK Class in the file and has the information been included in the statewide information system? (Rule 60BB-8.202(2) (a), F.A.C.) YES NO

4. Does the coalition have processes in place to ensure each parent receives a VPK program orientation either face-to-face or by a video? (Rule 60BB-8.201(4), F.A.C.) YES NO

5. Do the file(s) reflect that each parent received a copy of the VPK Parent Handbook? (Rule 60BB-8.201((4) (a) (2), F.A.C.) YES NO

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VPK Child Elig ibility Criteria (VPKC-C) - Delayed Enrollment, Reenrollment and Transfers

A parent may enroll a child in a 540-hour school-year or a 300-hour summer VPK program. The Office issued guidance that indicates that after instruction has begun for a VPK class an eligible child may still enroll in the VPK program and begin instruction in a VPK class, if at least 10 percent of the class’ instructional hours remain (54 hours for a school-year program or 30 hours for a summer program) (s. 1002.53(3), F.S., OEL-PI 510.027). The coalition should maintain documentation indicating that a parent who chooses delayed enrollment was fully informed of enrollment options and may do so by requesting that a parent who chooses delayed enrollment sign Form AWI-VPK 04 (Informed Parental Consent for Delayed Enrollment). VPK law prohibits a child from enrolling in more than one program type (s. 1002.53(3), F.S.) or from being reported for funding purposes as more than one full-time equivalent (FTE) student. (s. 1002.71(2), F.S.)

The law allows a one-time opportunity for re-enrollment in another VPK program for good cause for continuation of funding not to exceed a full-time equivalent or if due to an extreme hardship, the child may re-enroll in one of the summer programs for full funding (s. 1002.71(4), F.S.). In order to maintain appropriate documentation regarding reenrollments, a coalition may request that a parent complete Form AWI-VPK 05(Reenrollment Application) and attach documentation of an extreme hardship, if applicable. If the child is reenrolled with a coalition other than the coalition of the previous enrollment, the coalition may also request that a parent complete and resubmit Form AWI-VPK 01 (Child Application). The coalition should follow the procedures for registration, eligibility determination, and enrollment of the child in the VPK program (Rule 60BB-8.202, F.A.C.). The coalition does not have to repeat the face-to-face parent consultation performed by the coalition of the previous enrollment.

In circumstances where a VPK student does not qualify for a good cause or extreme hardship reenrollment or in cases where a good cause or extreme hardship reenrollment is not desired for the student by his or her parent or guardian, a student may undergo a class transfer or a provider transfer in accordance with the intent of section 1(b), Article IX, of the Florida Constitution. A student who undergoes a class transfer or provider transfer uses only his/her remaining FTE funding. Provider and class transfers may be documented with Form AWI-VPK 06 (Informed Parental Consent for Provider Transfers and Class Transfer). 1. If applicable, did the coalition document that the parent was fully informed of the potential loss of

program hours for delayed enrollment, as evidenced by Form AWI-VPK 04 (Informed Parental Consent for Delayed Enrollment Form) or other documentation? (Rule 60BB-8.202(1) (c), F.A.C.) YES NO

2. If applicable, in accordance with reenrollment law, did a parent request to reenroll in another VPK

program due to an extreme hardship that was beyond the child’s or parent’s control as evidenced by Form AWI-VPK 05 (Reenrollment Application)? (s. 1002.71(4) (b), F.S.) YES NO

3. If applicable, did a parent and the coalition complete documentation Form AWI-VPK 06 (Informed

Parental Consent for Provider Transfers and Class Transfers) or provide other evidence indicating compliance with re-registration law? (Rule 60BB-8.201(2) (a), F.A.C.) YES NO

VPK Child Elig ibility Criteria (VPKC-D) - Previous Corrective Actions

Did the coalition implement VPK child eligibility corrective actions as indicated in the previous Accountability Unit review? YES NO

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VIII. Voluntary Prekindergarten Providers A coalition administers the VPK program through the service delivery of a VPK provider. Even after a coalition has determined that a provider is eligible to deliver the program, a coalition has an ongoing duty to verify the provider’s compliance with the Florida Statutes, state rules, and procedures of the coalition.

The review team examined 62 VPK classroom instructor’s credentials and qualifications within 20 child care provider sites to establish whether all instructors were qualified before the coalition authorized the instructors to enter the classroom. Three of the 62 instructor file(s) reviewed contained one or more findings.

VPK Provider Criteria (VPKP-A) - Provider and Class Registration

Before delivering instruction or receiving payment for the VPK program, a VPK provider must submit a completed and signed Form AWI-VPK 10 (Statewide Provider Application) and AWI-VPK 11 (Class Registration Application. A provider must submit Form AWI-VPK 10 (Statewide Provider Application) to the coalition in the county of the VPK provider’s site. If a VPK provider has more than one VPK site, the provider must submit a separate Form AWI-VPK 10 (Statewide Provider Application) for each site. Once a coalition determines a VPK provider eligible, the provider does not have to resubmit the form unless the provider needs to update information on the form, which should be done within 14 calendar days after the change.

A coalition must follow procedures for classroom registration (Rule 60BB-8.300, F.A.C.).A provider must submit Form AWI-VPK 11 (Class Registration Application) to the coalition annually. If the VPK provider has more than one VPK class, the provider must submit a separate Form AWI-VPK 11 (Class Registration Application) with supporting documents for each class. If any change that would affect the information the provider supplied on the Form AWI-VPK 11 (Class Registration Application) occurs, the provider must submit an updated form to the coalition within 14 calendar days after the change.

1. Has the coalition placed a completed, signed, and dated Form AWI-VPK 10 (Statewide Provider Registration Application) in the file for each provider? (Rule 60BB-8.300(1) (a), F.A.C.) YES NO

2. Has the coalition placed a completed, signed, and dated Form AWI-VPK 11 (Class Registration Application) in the file for each class? (Rule 60BB-8.300(2) (a), F.A.C.) YES NO

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VPK Provider Criteria (VPKP-B) - Statewide Provider Agreement

Before delivering instruction or receiving payment for the VPK program, a VPK provider must have submitted a completed and signed Form AWI-VPK 20 (Statewide Provider Agreement). A VPK provider must have, for each VPK class, at least one VPK instructor who is qualified to act as a VPK instructor in accordance with section 1002.55, 1002.61 and 1002.63, F.S. A VPK instructor must be of good moral character, must complete a level 2 background screening before entering the classroom and re-screening every five years, and must not be ineligible to teach in a public school because the instructor’s educator certificate is suspended or revoked (s. 1002.55(3) (d), F.S.). Rule requires an instructor to update an Attestation of Good Moral Character annually1 (Rule 65C-22.006(4) (d) 1.c., F.A.C.). A level 2 background screening is defined by statute as including, but not be limited to fingerprinting, a Florida Department of Law Enforcement (FDLE) statewide criminal and juvenile records check, a Federal Bureau of Investigation (FBI) federal criminal records check, and a local criminal records check through local law enforcement agencies (s. 1002.55(3) (d), F.S., and s. 435.04, F.S., and Form AWI-VPK 20 (Statewide Provider Agreement).

Statute defines time limits on validity for VPK coursework and/or credential requirements. All instructors must have valid credentials before entering a VPK classroom and maintain valid credentials while acting as a VPK instructor.

The coalition must ensure that both the coalition and the VPK provider sign a Form AWI-VPK 20 (Statewide Provider Agreement) before the coalition pays the provider (Rule 60BB 8.301, F.A.C.). The coalition is not obligated to pay for costs the provider incurs before the agreement’s beginning date or after the agreement’s ending date.

A private VPK provider must have a VPK director who has a VPK director credential that meets or exceeds the minimum standards adopted under s. 1002.57, F.S. A VPK director who earned a director credential on or before December 31, 2006 is exempt from completing additional requirements to obtain a VPK endorsement. A director who received a director credential on or after January 1, 2007 must complete a series of requirements to receive a VPK endorsement.

1 As of August 2010, the Attestation of Good Moral Character was replaced by the Affidavit of Good Moral Character and is required upon initial employment with a child care provider or upon change of employment. This change has a transition period for implementation.

1. Is there a completed, signed, and dated Form AWI-VPK 20 (Statewide Provider Agreement)? (Rule 60BB-8.301F.A.C.) YES NO

2. Has each provider met the requirements for a legally operating provider eligible to deliver the VPK program? (1) Licensed or licensed exempt and/or (2) accredited by an Office-approved accrediting body and/or hold a Gold Seal Quality Care designation? (s. 1002.55, 61, and 63, F.S.) YES NO

3. Does each private VPK provider have a director with a valid director credential for the full classroom period and is onsite for the majority of the time of the program’s hours of operation, and, if applicable, the VPK Director Endorsement? (s. 1002.57, F.S.) YES NO

4. Does each lead instructor meet the qualifications of a VPK instructor in accordance with s? 1002 .55, 61 and 63, F.S.? YES NO

The following file(s) did not comply with requirements for: Emergent Literacy or equivalent: #76 - Instructor does not have emergent literacy, as early literacy birth to three is not equivalent.

5. Does each VPK lead, secondary, and substitute instructor for each class offered by a private provider have evidence of completing all current level 2 screening laws before entering the classroom? (s. 1002.55, 61 and 63, F.S.) YES NO

6. Does each lead, secondary, and substitute instructor have evidence of an annually updated Attestation of Good Moral Character (GMC) for each class that a private provider offers? (s. 1002.55, 61 and 63, F.S.) YES NO

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FOEL recommends corrective action for noncompliance with VPK provider elig ibility criteria (VPKP-B). (1) For all findings, corrected and not corrected, identify the cause of the initial finding and how to ensure continued compliance. (2) For a finding the coalition has not corrected since the review

#76 – the coalition shall obtain documentation that the instructor has obtained the required emergent literacy and submit as a corrective action or provide a statement as to why the file cannot be corrected.

, the coalition should take the following corrective actions to comply with all applicable statutes, rules, and recommendations:

Further action for 30-day corrective action plan

VPK Provider Criteria (VPKP-C) - Program Classroom Sizes

: identify the cause of the initial finding and how to ensure continued compliance.

According to Rule 60BB-8.451(1) (a), F.A.C., “a school-year program may not begin instruction more than 14 days before Labor Day.” A VPK class must be composed of at least four children enrolled in the VPK program and cannot exceed 18 children for a school-year program or 12 children for a summer program (s. 1002.61(7), F.S and Rule 60BB-8.400(3), F.A.C.). A coalition may not issue the initial advance payment for a VPK class unless the class meets the minimum class size. If a mixed group of VPK and non-VPK children are in a class, both groups count toward the 18-child or 12-child maximum class size. A VPK class may not exceed the maximum class size in enrollment or attendance on a particular day (Rule 60BB-8.400, F.A.C.).

1. Did the coalition ensure that the provider had a minimum of four VPK children enrolled to begin the class? Public School providers are exempt from this requirement during the summer program. (s. 1002.53(6) (b), F.S.) Rule 60BB-8.400, F.A.C.) YES NO

2. Did the VPK class not exceed a maximum of 18 children per class for the school year program or 12 per class for the summer program? For school year classrooms in excess of 10, two instructors should be present. (Rule 60BB-8-400, F.A.C; s. 1002.55, (3) (f), 1002.61(7), and 1002.63(7), F.S.)) YES NO

VPK Provider Criteria (VPKP-D) - VPK Statewide Kindergarten Screening

The VPK legislation (s. 1002.69(5), F.S.) requires the Department of Education (DOE) to calculate kindergarten readiness rates annually for each VPK provider. The State Board of Education, responsible for setting the minimum readiness rate, set the minimum readiness rate at 140 for program year 2009-2010 during their meeting on March 15, 2011. A VPK provider has 21 calendar days from the State Board’s adoption of the minimum readiness rate to acknowledge status as a low performing provider by utilizing the www.ImproveVPK.org

The VPK legislation (s. 1002.67(3) (c), 1002.69(5), F.S.) establishes that the Department of Education (DOE) shall annually calculate each private and public provider’s VPK readiness rate. If the readiness rate falls below the established level the provider or school shall submit an improvement plan for approval by the coalition or school district.

website. The review team requests documentation and improvement plans for low performing providers as part of the annual eligibility review.

1. How many low performing VPK providers did the coalition report to DOE? (1002.67, F.S.)

The coalition reported: 7

2. Has the coalition approved an improvement plan for each low performing provider (LPP) and has the

coalition required the provider to implement the plan? (s. 1002.67 and 1002.69, F.S.) YES NO

3. Did each LPP submit a signed AWI-VPK 20 (VPK Provider Agreement)? YES NO For Endeavor Elementary VPK (2 year), the 09-10 AWI-VPK 20 (provider agreement) was not in the file because the coalition was unable to obtain the original signed agreement.

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4. For each VPK provider that the team reviewed and was designated as an LPP for two consecutive years or more, did the coalition place the provider on probation and take certain corrective actions, including the use of a curriculum approved by DOE, and does the provider submit periodic progress reports? (s. 1002.67 and 1002.69, F.S.) YES NO

FOEL REQUIRES NO FURTHER CORRECTIVE ACTION. The coalition has completed the following corrective actions:

The coalition obtained a signed attestation from the school district.

− The coalition should continue to look for the original provider agreement and add it to the provider file.

In the future, to comply with all applicable statutes, rules, and recommendations, the coalition should ensure the following:

− The coalition should ensure that all files have internal monitoring to ensure documents are in place.

VPK Provider Elig ibility Criteria (VPKP-E) - Previous Corrective Actions

Did the coalition implement VPK provider eligibility corrective actions as indicated in the previous Accountability Unit review? YES NO N/A

IX. Payment Validation The Office team reviewed 33 SR child file(s) and 32 VPK child file(s) for payment validation for the months of April, May and June 2011. The team also evaluated the records for absences according to the Office’s attendance rules. The team compared attendance records and noted any discrepancies. See the attached payment validation spreadsheet for specific record detail.

Payment Validation Criteria (PV-A) - Attendance Monitoring and Payment Validation

The coalition and the coalition’s contractors should have well-defined procedures for attendance monitoring and provider payments. An SR provider must maintain daily attendance documentation, which at a minimum shall include a sign-in/sign-out process, as approved by the coalition to validate the attendance data (Rule 60BB-4.502(1), F.A.C.). A VPK provider must keep a daily record of a child’s attendance in the program. The Form AWI-VPK 03S (Child Attendance and Parental Choice Certificate Short Form) shall be supported by a sign-in/sign-out log or an electronic attendance-tracking system. The Form AWI-VPK 03L (Child Attendance and Parental Choice Certification Long Form) shall be used by the VPK provider if the provider records the child’s daily attendance using a method other than the sign-in/sign-out log or an electronic attendance-tracking. (Rule 60BB-8.305(1) and (2), F.A.C.) A coalition must implement a records retention policy ensuring that all documentation is maintained in accordance with sub-grant award provisions. The coalition must conduct monitoring activities to ensure the accuracy of payments of the monthly reimbursement requests.

A coalition pays an SR provider based on payment for attendance and absences (Rule 60BB-4.500-501, F.A.C.). A VPK provider is paid in accordance with the provisions of the Office’s Uniform Attendance Policy for Funding the VPK Program and Advance Payment and Reconciliation for the VPK Program rules (Rule 60BB-4.500-502, 8.204 and 205, F.A.C., Early Learning Grant Agreement).

An SR/VPK provider must keep a daily record of a child’s attendance in the program and require the parent to verify monthly the child’s attendance for the prior month as follows (Rule 60BB-4.500 and 60BB-8.305(2), F.A.C.). See forms used for VPK attendance listed below:

• Form AWI-VPK 03S (Child Attendance and Parental Choice Certificate Short Form). The parent may use the short form if the VPK provider records daily attendance using a paper sign-in/sign-out log that records the date, child’s name, and signature of the parent or other person dropping off or picking up the child to, or from, the VPK site or an electronic attendance-tracking system that records the date, time, child’s name, and electronic

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signature, card swipe, entry of a personal identification number, or similar daily action taken by the parent or other person dropping off or picking up the child from the VPK site.

• Form AWI-VPK 03L (Child Attendance and Parental Choice Certificate Long Form). If the provider does not maintain daily sign-in/sign-out logs, the parent must complete Form AWI-VPK 03L that indicates which days the child was in attendance for that month.

A coalition shall give an SR/VPK provider a monthly roster (Enrollment/Attendance Certification), prepared by using the Office’s statewide information system, which lists each child enrolled in the provider’s program and includes blank spaces for a provider to add and certify a child’s attendance for the calendar month. A provider must certify and submit the monthly enrollment/attendance certification of a child enrolled in the provider’s program to ensure payment from the coalition. For SR a recognized holiday as approved by a local coalition shall not be counted as an absence for the purpose of reimbursement. The Office shall include a reimbursement to a provider of full-time and part-time care for up to twelve (12) recognized holidays per year. A coalition/contractor shall authorize reimbursement for no more than three absences per calendar month per child, except in the event of extraordinary circumstances in which case the coalition or the coalition’s designee shall provide written approval for payment based on written documentation provided by the parent justifying the excessive absence for up to an additional seven days (Rule 60BB-4.500(2), F.A.C.).

The coalition may not pay the final payment for the VPK program year until the provider submits a final verification of the annual cumulative attendance of each child enrolled in the program, which certifies the paid hours of attendance of each child enrolled for the program year (Rule 60BB-8.305(3), F.A.C.).

After the coalition approves the enrollment/attendance certification, the coalition will generate a provider reimbursement report for the net reimbursement amount to be paid to the provider. The coalition will pay the provider by electronic funds transfer (EFT) or by warrant (check). The coalition should check to see if the provider received payment by EFT or check.

1. Does the coalition have enrollment/attendance certifications for each child enrolled in the SR/VPK programs? YES NO

2. Does the coalition verify each provider for child’s attendance in accordance with SR rule? YES NO

The following file(s) did not comply with all applicable statutes, rules, and recommendations: #25, 27, and 29

3. Does the coalition verify each provider for a child’s attendance in accordance with VPK rule? YES NO

The following file(s) did not comply with all applicable statutes, rules, and recommendations: #2, 12, 14, 22, 28, 30, and 32

4. Does documentation support the final provider reimbursement report? YES NO

The following file(s) did not comply with all applicable statutes, rules, and recommendations: VPK #12, and 32

5. Does the final 5045 detail report by billing group and provider match the payment transmittal? YES NO

6. Has the coalition documented that the payment cleared or provided documentation of a reconciling item? YES NO

The coalition has completed the following SR-PV corrective actions:

The coalition has corrected SR #25 and 27.

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FOEL recommends corrective action for noncompliance with SR payment validation criteria (SR-PV). (1) For all findings, corrected and not corrected, identify the cause of the initial finding and how to ensure continued compliance. (2) For a finding the coalition has not corrected since the review

− SR #29 – Please submit evidence that technical assistance has been provided (or is scheduled to be provided) to the child care program on how to properly verify child attendance in accordance with SR rule).

, the coalition should take the following corrective actions to comply with all applicable statutes, rules, and recommendations:

− Ensure the provider maintains daily attendance documentation, including a sign-in/sign-out process as approved by the coalition.

− Make every effort to encourage a provider to have a parent complete and include sign-in/sign-out times on the daily sign-in/sign-out sheets upon request.

− Do not pay for days the provider submits incomplete attendance logs. − Improve provider education on approved attendance practices (including the impropriety of pre-signed daily

attendance sheets) to ensure proper payments and fraud prevention.

Further action for 30-day corrective action plan

The coalition has completed the following VPK-PV corrective actions:

: identify the cause of the initial finding and how to ensure continued compliance.

The coalition has corrected #12, 14, and 28.

FOEL recommends corrective action for noncompliance with VPK payment validation criteria (VPK-PV). (1) For all findings, corrected and not corrected, identify the cause of the initial finding and how to ensure continued compliance. (2) For a finding the coalition has not corrected since the review

– Ensure a VPK classroom completes a short form attestation of attendance (Form AWI-VPK 03S) if the child was signed-in/signed-out daily or the provider must complete the VPK attendance long form (Form AWI-VPK 03L).

, the coalition should take the following corrective actions to comply with all applicable statutes, rules, and recommendations:

– Adjust payment for the reviewed period and provide proof of adjustment if the provider did not maintain the daily sign-in/sign-out sheets in accordance with rule or if payment was not correct.

– Ensure that all reimbursable payments are in accordance with Rule 60BB-8.204, F.A.C. – VPK #2 - The VPK-03S submitted for the month of April is incomplete because it does not include the day for

each month. The form submitted only included the month and the year. Please ensure that providers complete the VPK-03S according to 60BB-8.305.

– VPK #2, 22, 30, 32 – Submit evidence that technical assistance has been provided (or is scheduled to be provided) to the child care programs on how to accurately complete sign-in/out sheets, enrollment/attendance certifications, and VPK attendance documents (VPK-03S and VPK-03L) in accordance with 60BB-8, F.A.C.

Further action for 30-day corrective action plan

X. Data Accuracy

: identify the cause of the initial finding and how to ensure continued compliance.

The team reviewed selected edit and exception reports from the list below. The purpose of the reports is to identify anomalies in EFS data that may indicate data entry error or non compliance in SR or VPK eligibility. Not all file(s) identified on the reports are in error. The review analysts identified instances during the review of these reports that required follow-up by the coalition and validation by the team. Reports indicated by “*” are standard reports run by OEL DQI unit and provided to the coalitions on a quarterly or monthly basis. The coalition was expected to follow-up and correct items identified. Review team members confirmed if the coalition took corrective action on the reports.

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Data Accuracy Program

The coalition shall comply with data correction requests or data cleansing activities as communicated by the Office (Grant Award Section 11(c)).

Did the coalition resolve all items identified in the Data Accuracy Edit Reports? YES NO Partial

• Active SR files with SSA/SSI income (19) - Assists with identifying if children’s income is excluded properly and/or if parents’ income is included properly. The report also assists in determining if the case was placed in the correct billing group.

The team reviewed the following reports for Brevard Coalition:

• *Gold Seal Edit Report (1)-identifies providers with a Gold Seal payment which have a missing certificate or error with the certificate end date. DQ 07-06

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Summary Review of Recommended Corrective Actions The Office requires the coalition to submit a corrective action plan for all compliance issues within 30 days from the receipt of this accountability review report. The response should demonstrate the coalition’s steps to address each compliance issue and the numbered findings on the monitoring spreadsheets. For all findings

Coalition Governance

, corrected and not corrected, a corrective action plan should identify the cause of the initial finding and how to ensure continued compliance. See the suggestions below for how to (1) correct findings and (2) ensure compliance in the future for findings the coalition has already corrected since the review.

• CG-A: Submit a current board roster to OEL as part of the coalition SR Plan approval process to reflect new members that are added or that has resigned from the board.

• CG-A: Ensure that the coalition’s private sector board membership is more than one-third of the total membership as stipulated in s. 411.01(5) (a) (7), F.S.

Operations and Program Management

• OPM-B: Update and revise the coalition’s SR or disenrollment policies and procedures in accordance with the Early Learning Grant Award and the OEL Guidance 240.04 to include providing written notice to parents or guardians of at least 30 calendar days prior to disenrolling a child. Specifically, the coalition shall include the following: • providing written notification to the Agency at least forty-eight (48) hours prior to the initiation of formal

consideration by the coalition board to disenroll a group of children from early learning programs; • providing written notification to the Agency at least five (5) business days prior to taking action to notify

providers or families of a determination to disenroll a child from early learning programs. • providing written notice to any affected child’s parent or guardian at least thirty (30) calendar days before the

child is disenrolled from the School Readiness program, which includes the effective date of the child’s disenrollment;

• providing written notice to any affected child’s School Readiness provider at least thirty (30) calendar days before the child is disenrolled from the School Readiness program, which includes the effective date of the child’s disenrollment;

• allowing the continued initial enrollment of a child in a priority eligibility group in accordance with Section 411.01(6), Florida Statutes;

Educational Services Delivery

• ESD-A: The coalition should either include a monitoring section in the tool it uses to monitor the contract with the Florida Children's Forum, and track providers to ensure those not using an approved curriculum attend trainings or complete a SR plan amendment to revise or delete this outcome measure in Plan section 4.3.3.

• ESD-G: The coalition should either implement a tracking system to ensure compliance with SR Plan section 3.6.1 outcome measures (2) and (3), or complete a SR plan amendment to revise or delete these outcome measures.

• ESD-H: The coalition should enhance its parent education programs and services for outcome measures (1), (2) and (3) of Plan Section 3.4.1, or complete a SR plan amendment to revise, delete, or add to these outcome measures and submit to the Office for approval.

• ESD-H: The coalition should follow and track measurable outcomes (4) and (5) for Plan Section 3.4.2; family literacy services, or completes a SR plan amendment to revise or delete these outcome measures and submit to the Office for approval.

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• ESD-H: The coalition should implement a tracking system to track outcome measures (2) and (3) of Plan Section 3.5.1; or complete a SR plan amendment to revise or delete the outcome measures and submit to the Office for approval. .

VPK Provider Elig ibility VPKP-B: #76 - coalition shall obtain documentation that the instructor has obtained the required emergent literacy and submit as a corrective action or provide a statement as to why the file cannot be corrected.

SR Payment Validation − SR #29 – Please submit evidence that technical assistance has been provided (or is scheduled to be provided) to

the child care program on how to properly verify child attendance in accordance with SR rule). − Ensure the provider maintains daily attendance documentation, including a sign-in/sign-out process as approved

by the coalition. − Make every effort to encourage a provider to have a parent complete and include sign-in/sign-out times on the

daily sign-in/sign-out sheets upon request. − Do not pay for days the provider submits incomplete attendance logs. − Improve provider education on approved attendance practices (including the impropriety of pre-signed daily

attendance sheets) to ensure proper payments and fraud prevention.

VPK Payment Validation – Ensure a VPK classroom completes a short form attestation of attendance (Form AWI-VPK 03S) if the child was

signed-in/signed-out daily or the provider must complete the VPK attendance long form (Form AWI-VPK 03L). – If using the short form attestation, establish whether the daily sign-in/sign-out sheets exist for each child. – Adjust payment for the reviewed period and provide proof of adjustment if the provider did not maintain the

daily sign-in/sign-out sheets in accordance with rule or if payment was not correct. – Ensure that all reimbursable payments are in accordance with Rule 60BB-8.204, F.A.C. – Continue to research any uncleared provider payments. – Ensure a VPK classroom completes a short form attestation of attendance (Form AWI-VPK 03S) if the child was

signed-in/signed-out daily or the provider must complete the VPK attendance long form (Form AWI-VPK 03L). – Adjust payment for the reviewed period and provide proof of adjustment if the provider did not maintain the

daily sign-in/sign-out sheets in accordance with rule or if payment was not correct. – Ensure that all reimbursable payments are in accordance with Rule 60BB-8.204, F.A.C. – VPK #2 - The VPK-03S submitted for the month of April is incomplete because it does not include the day for

each month. The form submitted only included the month and the year. Please ensure that providers complete the VPK-03S according to 60BB-8.305.

– VPK #2, 22, 30, 32 – Submit evidence that technical assistance has been provided (or is scheduled to be provided) to the child care programs on how to accurately complete sign-in/out sheets, enrollment/attendance certifications, and VPK attendance documents (VPK-03S and VPK-03L) in accordance with 60BB-8, F.A.C.

Suggested Business Practices Please see the attached management addendum. The Office does not require corrective action for suggested business practices; however, the Office highly recommends corrective action to improve the coalition’s delivery of services.

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Florida’s Office of Early Learning Rick Scott Governor Mel Jurado Director

Florida’s Office of Early Learning 250 Marriott Drive•Tallahassee, Florida•32399

Telephone (850) 717-8550•Toll free line 1-866-fl-ready (357-3239) www.floridaearlylearning.com

An equal opportunity employer/program. Auxiliary aids and services are available upon request to individuals with disabilities. All voice telephone numbers on this document may be reached by persons using TTY/TDD equipment via the Florida Relay Service at 711.

MEMORANDUM DATE: January 26, 2012

TO: Sky Beard, Executive Director, Early Learning Coalition of Brevard County

FROM: Tamara Akins Price, Program Integrity Manager, Florida’s Office of Early Learning

SUBJECT: Management Assistance Addendum to Report AU11-12.21

As part of the accountability review of the Early Learning Coalition of Brevard County, we have provided business practice observations for your consideration. The observations are attached to this memo as the Management Assistance Addendum to Report AU 11-12.21. These observations are not a part of the main compliance report.

Please note that the Florida’s Office of Early Learning (FOEL) does not require a response to any business practice observations or the associated suggested actions. If your coalition decides to address these observations, please do so in a separate response within 30 days of the report’s publication.

If you have any questions, please contact Reginal Williams, Accountability Review Supervisor, at 850-717-8606.

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BREVARD COUNTY Addendum 11-12.21

MANAGEMENT AS SISTANCE ADDENDUM TO REPORT AU11-12.21

Observations FOEL’s Program Integrity Unit, Accountability Section is tasked with ensuring compliance and accountability for the implementation and operations of the early learning programs through sound standards and best practices. Although the Accountability Section has addressed issues of compliance within the report AU11-12.21 that require a 30-day corrective action plan, the issues noted below are observations that are sound business practices and the coalition should correct them to ensure the coalition continues to provide high quality services to children and their families.

Child Care Res ource and Referra l

The informational packet from call #4 was sent to an incorrect email address and was not received by the caller.

Suggested Action Ensure that CCR&R Specialists double check both the email addresses given to them by callers, as well as the email addresses that they type in when sending informational packets to families.

Educa tiona l Services Delivery

Outcome (5) is not measurable, and was not reviewed.

Suggested Action The coalition should review its School Readiness Plan and ensure that all outcomes relate back to the objectives and activities, and that the outcome is measurable.

VPK Provider Eligib ility

• #22, 26, 34, and 65 - Coalition provided documentation that they have monitored the provider which included validating the information obtained in the files

• #23-25, 27, 28, 35, 36-38, 66-68 - Will be compliance for next monitoring visit. No documentation in file to support teacher credentialing and level II besides letter from school district which does not meet criteria for having name and dates

• #39 – The coalition has made changes to the VPK 11 with no initials or effective dates.

Suggested Action − #22, 26, 34, and 65 - The Office is suggesting that the coalition consistently implement the internal

monitoring seen in most files to ensure files are complete and contain all needed documentation − #23-25, 27, 28, 35, 36-38, 66-68 - Email from Accountability Manager at OEL in file from October 22,

2010 stating that names of instructors and screening dates must be on the letter from the school district. Additionally, proof of meeting VPK educational requirements should be in file and not just stated on the letter from the school district.

− #39 - Ensure all changes made by providers to the VPK classroom is clearly indicated with name of person or initials next to change and date change is effective.

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BREVARD COUNTY Addendum 11-12.21

Pa yment Valida tion

SR #19, 21, and 30 – Parents failed to sign in/out.

Suggested Action SR #19, 21, and 30 – The coalition should provide technical assistance to providers.

Opera tions and Program Management

– The coalition does not ensure that all coalition contracts and subcontracts in excess of the threshold amount provided in s. 287.017 for CATEGORY TWO include and/or reference the federal contract provisions and assurances and contain the requirements in the Florida Statutes. [s.287.058 (1) (a)-(f), F.S.] (This item will be a compliance finding for fiscal year 12-13 reviews and will be placed in the main compliance report if the contracts do not meet the requirements.) The coalition’s contract with the Children’s Forum references most federal contract provisions and assurances and contains requirements found in the Florida Statutes. The coalition’s contracts with the Brevard County School District for Florida First Start and the Florida Children’s Forum do not contain references to Uniform Administrative Requirements and Equal Treatment of Faith-Based Organizations in its two contracts 287.058 of the Florida Statutes and to federal contract provisions.

– The coalition has not submitted documentation illustrating that the Florida First Start and Children’s Forum contracts received legal review and approval before the coalition executed the contracts.

Suggested Action – The coalition should insert language reflecting federal rules regarding Uniform Administrative

Requirements and Equal Treatment of Faith-Based Organizations in its two contracts exceeding $100,000.

– The coalition shall ensure all contracts excess the threshold amount for Category Two in the Florida Statutes and Grant Award contain the required federal contract provisions and assurances.

– The coalition should ensure all contracts in excess of the threshold amount for Category Two in the Florida Statutes and Grant Award receive a legal review and approval before execution.

School Readines s Elig ib ility

Based upon change in statute, coalitions are not to collect immunization forms at initial eligibility to determine a client eligible or to determine whether the immunization requirement has been met. The statute allows providers to be given 30 days from the date of enrollment to collect this information. The coalition must monitor the providers to ensure compliance. The coalition is duplicating efforts by collecting immunization records at eligibility determination and must discontinue this practice. The FOEL Accountability Section will be reviewing immunization policies for compliance with this requirement during the 12-13 FY. It is only allowable for coalitions to use immunizations as proof of date of birth.

Suggested Action – The coalition shall update its policy to reflect the current change in statute in allowing the providers 30

days to collect immunization records from parents. – The coalition shall ensure that it monitors its informal providers to assure they are meeting the

immunization requirement.

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ELCB FY 11.12Direct Service Utilization Report

BillingPeriod

Children SERVED (unduplicated)

Per child Cost 97PP0 97R00 97G00 97GSD 97P00 97GNW

Total Direct Service Expenditures*

Monthly Direct Service

AllocationMatch

required**Match obtained

July-11 3,919 310.73$ 9,083$ 232,135$ 63,527$ 110,387$ 665,446$ 146,274$ 1,217,769$ 1,298,415$ 39,926.75$ 21,795.67$ August-11 3,793 276.24$ 10,926$ 231,131$ 62,006$ 98,241$ 521,704$ 134,685$ 1,047,768$ 1,176,454$ 31,302.24$ 21,843.67$ September-11 3,247 275.56$ 11,347$ 222,627$ 56,299$ 89,229$ 410,114$ 116,470$ 894,738$ 1,081,763$ 24,606.82$ 37,601.93$ October-11 3,098 266.39$ 9,238$ 211,177$ 53,569$ 86,817$ 369,170$ 104,532$ 825,264$ 1,051,863$ 22,150.19$ 35,973.99$ November-11 3,112 285.90$ 9,777$ 231,580$ 59,544$ 93,309$ 402,980$ 102,316$ 889,729$ 1,066,471$ 24,178.80$ 33,160.08$ December-11 3,075 296.27$ 9,176$ 226,400$ 59,416$ 95,808$ 423,563$ 105,828$ 911,015$ 1,172,227$ 25,413.79$ 30,287.90$ January-12 3,193 287.25$ 8,888$ 214,297$ 56,644$ 100,016$ 437,902$ 108,327$ 917,186$ 1,025,763$ 26,274.13$ 21,188.89$ February-12 -$ -$ March-12 -$ -$ April-12 -$ -$ May-12 -$ -$ June-12 -$ -$ Final Invoice -$ -$

TOTALS 3,348 285.48$ 68,435$ 1,569,346$ 411,005$ 673,807$ 3,230,879$ 818,433$ 6,703,470$ 7,872,956$ 193,852.72$ 201,852.13$ (7,999.41)$

* For internal utilization purposes - includes Gold Seal and Project Safety Net expenses, DOES NOT include CCEP direct services

OCA above97PPO 49.10% 57.67%97ROO $1,169,485.9797GOO97GSD 27.21% 58.33%97POO $99,231.18 20958.3333397GNW

Remaining Match Required

Expected YTD Spending RateYTD Spending Rate (overall)YTD Surplus / Deficit (overall)

Expected YTD Spending Rate

** Match required does not have to be obtained monthly, overall total must be obtained by end of fiscal year and may include in-kind.

Billing GroupCCEP (Child Care Executive Partnership)

CCEP YTD Spending Rate (overall)

BG-1 (Protective Services / DCF referrals)

BG-3, BG-3R (TANF referrals)

BG3W, BG-5 (TANF / TCC {transitional child care} referrals)GOLD SEAL DIFFERENTIAL BG-8 (working poor / income eligible) YTD Surplus / Deficit (overall)

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ELCB FY 11.12Direct Service Utilization Report

MonthTarget

Enrollment

# of Children Served

Avg Daily Rate / Child

# of Days

School Age Notes

Overall Expected Child

CareOverall Actual Child

CareSpending

Rate Surplus / Deficit YTD Expected YTD ActualJuly 4083 3919 $14.80 21 FT (21 days) $1,298,415.25 $1,217,769.32 93.79% $80,645.93 $1,298,415.25 $1,217,769.32August 4083 3793 $12.56 22 FT (6 days) $1,176,453.81 $1,047,767.71 89.06% $128,686.10 $2,474,869.06 $2,265,537.03September 3600 3247 $12.53 22 FT (2 day) $1,081,762.51 $894,738.16 82.71% $187,024.35 $3,556,631.57 $3,160,275.19October 3600 3098 $12.69 21 FT (1 day) $1,051,863.44 $825,264.46 78.46% $226,598.98 $4,608,495.01 $3,985,539.65November 3600 3112 $13.00 22 FT (4 days) $1,066,470.67 $889,729.43 83.43% $176,741.24 $5,674,965.68 $4,875,269.08December 3600 3075 $12.88 23 FT (8 days) $1,172,227.34 $911,015.33 77.72% $261,212.01 $6,847,193.02 $5,786,284.41January 3600 3193 $13.68 21 FT (6 days) $1,025,763.38 $917,186.02 89.41% $108,577.36 $7,872,956.40 $6,703,470.43February 3600 20 FT (1 day) $1,004,411.45 $0.00 $8,877,367.85March 3600 23 FT (5 days) $1,196,851.01 $0.00 $10,074,218.86April 3600 21 FT (1 days) $1,115,870.83 $0.00 $11,190,089.69May 3600 23 FT (5 days) $1,207,636.08 $0.00 $12,397,725.77June 3600 22 FT (22 days) $1,253,776.71 $0.00 $13,651,502.48Final InvoiceYTD Totals 3349 $13.16 261 $13,651,502.48 $6,703,470.43 84.94% $1,169,485.97

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  Early Learning Coalition of Brevard County Inc. Year to Date Comparison – January 2012 

   Slot Utilization FY 11.12 to FY 10.11  

 

FY 11.12 – FY 10.11 Comparison – Surplus/Deficit 

 

   

Budgeted Year to Date (YTD) Actual YTD Percent Actual

vs. Budget YTD

FY 11.12 $7,872,956 $6,703,470 85%FY 10.11 $9,238,320 $9,246,375 100%

$-$1,000,000 $2,000,000 $3,000,000 $4,000,000 $5,000,000 $6,000,000 $7,000,000 $8,000,000 $9,000,000

$10,000,000

FY 11.12 FY 10.11

July $80,645.93 $(89,578.69)August $128,686.10 $40,394.32 September $187,024.35 $16,976.24 October $226,598.98 $1,981.86 November $176,741.24 $(4,287.53)December $261,212.01 $2,289.98 January $108,577.36 $24,168.54 February

March

April

May

June

($150,000.00)

($100,000.00)($50,000.00)

$0.00

$50,000.00 $100,000.00

$150,000.00

$200,000.00 $250,000.00

$300,000.00 Surplus

Page 47: Early Learning Coalition · budget cuts the amount of funds lost went from $200 to ... proposal is to collaborate with Brevard Public Schools early ... the Early Learning Coalition

  Early Learning Coalition of Brevard County Inc. Year to Date Comparison – January 2012 

   

School Readiness Match – Actual to Forecast & Comparison to FY 10.11 

 

Enrollment FY 11.12 Compared to FY 10.11 (Month of January) 

 

Comparison: Prior to Current Month Enrollment  

 

$0$50,000

$100,000$150,000$200,000$250,000$300,000$350,000$400,000$450,000

FrcstThs Yr Actual 11.12 Actual 10.11

4,267

3,193

0500

10001500200025003000350040004500

FY 11.12 FY 10.11

Enrollment FY 11.12 to FY 10.11

3,0753,193

January December

Page 48: Early Learning Coalition · budget cuts the amount of funds lost went from $200 to ... proposal is to collaborate with Brevard Public Schools early ... the Early Learning Coalition
Page 49: Early Learning Coalition · budget cuts the amount of funds lost went from $200 to ... proposal is to collaborate with Brevard Public Schools early ... the Early Learning Coalition

FY 11.12 Status of Quality Assessments

(Information provided is cumulative)

November Meeting:

• To date, 95 individual classrooms have been assessed (35 ITERS, 51 ECERS and 9 FCCRS). The 95 classrooms represent 60 providers having been assessed.

• Of the 35 classrooms assessed using the ITERS, 10 received scores below 3.5:

o Lowest score = 1.72 o Highest of the lowest score = 3.37 o Highest score = 5.63 o Number of classrooms scoring in the 2’s: 6 o Number of classrooms scoring between 3 and 3.5: 3

• Of the 51 classrooms assessed using the ECERS, 4 received scores below 3.5: o Lowest score = 3.06 o Highest of the lowest score = 3.33 o Highest score = 6.64 o Number of classrooms scoring in the 2’s: 0 o Number of classrooms scoring between 3 and 3.5: 4

January meeting:

• To date, 161 individual classrooms have been assessed (68 ITERS, 84 ECERS and 9 FCCRS). The 161 classrooms represent 92 providers having been assessed.

• Of the 68 classrooms assessed using the ITERS, 21 received scores below 3.5:

o Lowest score = 1.72 o Highest score = 5.85 o Number of classrooms scoring in the 2’s: 11 o Number of classrooms scoring between 3 and 3.5: 8

• Of the 84 classrooms assessed using the ECERS, 4 received scores below 3.5: o Lowest score = 3.06 o Highest score = 6.64 o Number of classrooms scoring in the 2’s: 0 o Number of classrooms scoring between 3 and 3.5: 4

Page 50: Early Learning Coalition · budget cuts the amount of funds lost went from $200 to ... proposal is to collaborate with Brevard Public Schools early ... the Early Learning Coalition

February meeting:

• To date, 191 individual classrooms have been assessed (83 ITERS, 99 ECERS and 9 FCCRS). The 191 classrooms represent 106 providers having been assessed.

• Of the 83 classrooms assessed using the ITERS, 26 received scores below 3.5: o Lowest score = 1.72 o Highest score = 5.85 o Number of classrooms scoring in the 1’s: 2 o Number of classrooms scoring in the 2’s: 15 o Number of classrooms scoring between 3 and 3.5: 9

• Of the 99 classrooms assessed using the ECERS, 4 received scores below 3.5: o Lowest score = 3.06 o Highest score = 6.64 o Number of classrooms scoring in the 1’s: 0 o Number of classrooms scoring in the 2’s: 0 o Number of classrooms scoring between 3 and 3.5: 4

0

5

10

15

20

25

30

35

40

45

50

Initial Assessment Classroom Scores

Classrooms

Page 51: Early Learning Coalition · budget cuts the amount of funds lost went from $200 to ... proposal is to collaborate with Brevard Public Schools early ... the Early Learning Coalition
Page 52: Early Learning Coalition · budget cuts the amount of funds lost went from $200 to ... proposal is to collaborate with Brevard Public Schools early ... the Early Learning Coalition
Page 53: Early Learning Coalition · budget cuts the amount of funds lost went from $200 to ... proposal is to collaborate with Brevard Public Schools early ... the Early Learning Coalition
Page 54: Early Learning Coalition · budget cuts the amount of funds lost went from $200 to ... proposal is to collaborate with Brevard Public Schools early ... the Early Learning Coalition

FY 11.12 Status of Quality Assessments

(Information provided is cumulative)

November Meeting:

• To date, 95 individual classrooms have been assessed (35 ITERS, 51 ECERS and 9 FCCRS). The 95 classrooms represent 60 providers having been assessed.

• Of the 35 classrooms assessed using the ITERS, 10 received scores below 3.5:

o Lowest score = 1.72 o Highest of the lowest score = 3.37 o Highest score = 5.63 o Number of classrooms scoring in the 2’s: 6 o Number of classrooms scoring between 3 and 3.5: 3

• Of the 51 classrooms assessed using the ECERS, 4 received scores below 3.5: o Lowest score = 3.06 o Highest of the lowest score = 3.33 o Highest score = 6.64 o Number of classrooms scoring in the 2’s: 0 o Number of classrooms scoring between 3 and 3.5: 4

January meeting:

• To date, 161 individual classrooms have been assessed (68 ITERS, 84 ECERS and 9 FCCRS). The 161 classrooms represent 92 providers having been assessed.

• Of the 68 classrooms assessed using the ITERS, 21 received scores below 3.5:

o Lowest score = 1.72 o Highest score = 5.85 o Number of classrooms scoring in the 2’s: 11 o Number of classrooms scoring between 3 and 3.5: 8

• Of the 84 classrooms assessed using the ECERS, 4 received scores below 3.5: o Lowest score = 3.06 o Highest score = 6.64 o Number of classrooms scoring in the 2’s: 0 o Number of classrooms scoring between 3 and 3.5: 4

Page 55: Early Learning Coalition · budget cuts the amount of funds lost went from $200 to ... proposal is to collaborate with Brevard Public Schools early ... the Early Learning Coalition

February meeting:

• To date, 191 individual classrooms have been assessed (83 ITERS, 99 ECERS and 9 FCCRS). The 191 classrooms represent 106 providers having been assessed.

• Of the 83 classrooms assessed using the ITERS, 26 received scores below 3.5: o Lowest score = 1.72 o Highest score = 5.85 o Number of classrooms scoring in the 1’s: 2 o Number of classrooms scoring in the 2’s: 15 o Number of classrooms scoring between 3 and 3.5: 9

• Of the 99 classrooms assessed using the ECERS, 4 received scores below 3.5: o Lowest score = 3.06 o Highest score = 6.64 o Number of classrooms scoring in the 1’s: 0 o Number of classrooms scoring in the 2’s: 0 o Number of classrooms scoring between 3 and 3.5: 4

0

5

10

15

20

25

30

35

40

45

50

Initial Assessment Classroom Scores

Classrooms