CCS is implementing changes in the way ACCS enrolments are handled. These changes will come into effect on 1st July 2021.
Here’s the text supplied by the department in March 2021 advising the intended changes
System Changes – Context Document Upcoming legislative changes associated with Additional Child Care Subsidy (ACCS)
Overview A system change is required to give effect to Legislative / Minister Rule changes in relation to the current enrolment type “ACCS Child wellbeing”. The changes are amending the name of the enrolment type from “ACCS Child Wellbeing’ to “Provider Eligible Arrangement”. This amended enrolment name will apply retrospectively to enrolment types that were previously name “ACCS Child Wellbeing’.
Changes Legislation and Ministers rules will expand the eligibility criteria for the ACCS Provider Eligible Arrangement. The changes allow a maximum period of Child Wellbeing (any combination of Certificates and Determinations) for a total maximum period of 13 weeks per child per service.
The changes will: Introduce a new ‘Provider Eligible Arrangement’ type from 01/07/2021 for any eligible enrolments with a start date on or after 01/07/2021. Collect all required information as part of the enrolment creation process for Provider Eligible Arrangements. The user must be able to indicate the circumstances meet the approved sub-class of child in accordance with the Legislation and Minister’s Rules or that they have been unable to identify a CCS Eligible individual.
Acceptable criteria for Provider Eligible Arrangement creation are: 1. Service not able to identify a CCS eligible carer – This allows the service to receive ACCS CWB directly for children who are considered to be ‘at risk’ and who are under the care of an individual who does not meet the eligibility criteria for CCS (e.g. the individual is not residentially qualified). 2. Child is in formal foster / kinship care (newly eligible child group) – this allows a Provider Eligible Arrangement to be created for children who are in formal foster or kinship care.
The maximum period of child wellbeing that a service can access under a Provider Eligible Arrangement for a child in formal foster / kinship care (in any combination of Certificates and Determinations) is a maximum period of 13 weeks per service per child CRN. Provider Eligible Arrangement created where no eligible individual can be identified will not be time limited.
Existing Child wellbeing enrolment treatment Services who have Children enrolled under a Child Wellbeing enrolment type will be required to create new Provider Eligible Arrangement type from 01/07/2021 and will be subject to the information requirements relating to a Provider Eligible Arrangement.
All active Child Wellbeing enrolment types will be end dated from Wednesday 30/06/2021. The CWB legacy enrolment type will be renamed Provider Eligible Arrangement on 01/07/2021.
Use Case Scenario
Billy is a four year old child under a state court order. He has been placed with a new foster family who approaches Yellow Early Learning Centre to enrol Billy in child care as it will enable him to socialise with other children in a positive learning environment. Attendance at child care will also enable Billy’s foster parents to maintain their existing employment.
As Billy is a foster child subject to a protection order, Yellow Early Learning Centre enrols Billy under a Provider Eligible Arrangement type for ACCS (child wellbeing). This enrolment type is limited to 13 weeks and in that time the provider is expected to work with the family to ensure that the new foster parent makes an application to Centrelink in order to confirm their CCS eligibility.
During the 13 weeks the provider issued a six week ACCS (child wellbeing) certificate followed by a determination application for another 7 weeks. When the foster family’s CCS eligibility was confirmed, the provider submitted a new Complying Written Arrangement (CWA) with the eligible individual (foster parent/s). The remaining 7 weeks of the determination continued to be in effect under the new CWA with the foster parent/s.
Overview A system change is required to give effect to legislative changes which allow ACCS (child wellbeing) certificates and determinations to have a backdated start date to up to 13 weeks, prior to the date of submission in exceptional circumstances (i.e. Circumstances beyond the provider’s control).
Change Context A range of changes are required to give effect to legislative amendments which, at a high level, will allow a service to indicate that they experienced exceptional circumstances (beyond their control) which prevented them from accessing CWB at an earlier point in time. This will then allow the service to select a start date (Monday) of a Certificate or Determination up to 13 weeks prior to the date of submission. The Department of Education, Skills and Employment (DESE) will be the authorized decision maker for these determinations / certificates.
The system will determine based on the circumstances of the service (ACCS Cap %) and the child (Certificates totalling 6 weeks in the last 12 months) to determine the combination of backdated certificates / determinations required.
The changes will allow services to backdate determinations / certificates up to 13 weeks (where they have indicated exceptional circumstances) across multiple financial years. In the event that reconciliation already completed on an impacted individual re-reconciliation of the relevant financial year will be required. Noting that in this circumstance any arrears for the previous financial year will be directed to the customer.
Evidence requirements Services will be required to substantiate that they have experienced exceptional circumstance by uploading evidence of the exceptional circumstance and how this impacted their ability to access Child Wellbeing as part of the certificate or determination application. A manual assessment of the evidence is required for all certificates and determinations where they have indicated exceptional circumstances exist. Existing evidence requirements for determinations / certificates will continue to apply regarding evidence of at risk (i.e. Mandatory evidence for initial determination application etc.)
Extended Backdating - Enrolment type The extended backdating will apply to certificates/ determinations lodged against both Complying Written Arrangements (CWA) and Provider Eligible Arrangement (PEA) enrolment types.
Date of Notice (referral to an appropriate support Agency) The circumstances around when a service must refer a family / child to an appropriate support agency remain unchanged. Date of notification is mandatory if submitting a backdated certificate/ determination beyond 28 days. I.e. date of notice cannot be in the future & date of Notice cannot be older than 6 weeks prior to the commencement date of the backdated certificate / determination. Note: the date of notice must be on or prior to the date of submission of the application for both certificate /determination. Current rules regarding date of notice for determinations/ certificates that are backdated up to 28 days will continue to apply.
Commencement date The commencement date of the measure is 1 July 2021. This means earliest possible backdated start date is 5 April 2021.
Use Case Scenario On 3 Jan 2022, a provider issues a certificate for 6 week to an ‘at risk’ child. The child continues to be ‘at risk’ so an initial determination is submitted and approved for 13 weeks until 15 May 2022. The child continues to be ‘at risk’. As the evidence is outdated, the provider seeks updated evidence from the third party to support a subsequent determination. Despite the provider’s effort, evidence is not received by the provider until 3 July 2022. On 4 July 2022, the provider submits a subsequent determination application and requests backdate 7 weeks prior, i.e. 16 May 2022 indicating as part of the application they have experienced exceptional circumstances and have uploaded supporting evidence
Overview A System change is required to give effect to legislative changes which allow providers to apply for ACCS (child wellbeing) determinations, in certain circumstances for a period up to 52 weeks. The changes are limited to children who meet the at risk eligibility criteria, the extended determination criteria and who are enrolled at the child care service under a Complying Written Arrangement (CWA) enrolment.
Change Context A range of changes are required to give effect to legislative amendments (subject to the passage of legislation), which at a high level will allow the period of time a provider can apply for an ACCS determination to be extended from 13 weeks to up to 52 weeks for children under long-term child protection orders such as children in formal foster care as per legislation.
The change will allow a provider to assess and record, on an ACCS determination application, whether or not the child fits the criteria for a determination of up to 52 weeks (longer term protection order or in formal foster care).
The system then will allow the provider to: If the provider indicated that the child is either on a longer term protection order or in formal foster care – Allow provider to apply for up to 52 weeks of ACCS (child wellbeing) in line with the timeframe of the order, or If the provider indicated (no) that the child is not on a longer term protection order or in formal foster care – Allow provider to apply for up to 13 weeks of ACCS (child wellbeing) The change must allow providers to apply to cancel/change an existing ACCS determination that has been made for over 13 weeks. This is consistent with current system behaviour. Note this also requires services to be able to view and upload additional evidence to a provisional determination application. A validation must be added to ensure that ACCS (child wellbeing) determinations are not submitted with a ‘date of commencement’ greater than 13 weeks from the ‘date of submission’. Under this measure instead of making an application four times a year for a child on a long term protection order, only one application would be required for this sub-cohort.
Evidence requirements Mandatory evidence is required for ACCS Determinations that are over 13 weeks in length. As part of the application process – where a service indicates that the child meets the extended determination criteria and subsequently seeks to lodge an application for a period that exceeds 13 weeks the service will be required to lodge required evidence (for example a letter from the state child protection agency indicating the court order details and / or the court order).
Use Case Scenario
Billy is in the care of his foster parents on a long term protection order for a period of two years.
Billy is enrolled with Yellow Early Learning Centre under a Complying Written Arrangement.
Under this change, as Billy’s protection order places him in the care of his foster family, the provider applies for an ACCS (child wellbeing) determination for 52 weeks.
Centrelink approves the application, using the order as evidence and the provider does not need to apply for another determination for 52 weeks unless Billy’s care situation changes.