Establishing Rates

In the decision making process many other considerations are involved: dual eligibility of the children, the amount of the grant award to the Tribe, the State's payment rates, the economic conditions on the reservation, and the supply and demand for child care. While reimbursement rates are normally based on the amount charged in the marketplace, the Tribe must decide what is the maximum amount it is able to pay for child care. Under ideal conditions, all providers would be paid whatever they charged they charged their non-subsidized families. However, the Tribe's CCDF funds rarely meet their needs. Therefore, the Tribe must decide how many children need CCDF support and how to set the rate ceilings in each category of care so families can access the highest quality of care possible with the funds available.

In summarizing the data collected, the Tribal Market Rate Survey will likely report:

• the average charge per day for child care centers, family child care homes and in-home care (as possible.)
• the average daily charges broken down into the different age groups
  • infants
  • 2 to five year olds
  • kindergarten and school age children
  • children with special needs

This initial summary of the data collected will provide the Tribe with a base from which to make decisions.

Differential Payment Rates

Tribes may choose to establish different rates for different categories of care. Center-based care, group home care, family child care, and in-home care can have different rate ceilings. Within a category of care, Tribes can establish a different rate for regulated or unregulated care. For example, family child care homes that meet the state or Tribe's regulations above the basic health and safety regulations can be paid more than homes that do not. There can be no differential rates between relative care and non-relative in-home care based simply on the relationship to the child. Also, the Fair Labor Standards Act and minimum wage laws apply to caregivers; in the child's home. Different rates are also based on the ages of the children in care. For example, rates paid for infants and toddlers will likely be higher than for school-age children.

Over one-fourth of the states have established differential. payment rates to encourage providers that serve low-income children to provide high quality services. In states where this occurs, the differential payments include providers who meet higher standards such as accreditation, providers who offer additional services such as serving children with special needs, or providers located in very low-income areas where none of the families can afford to pay the actual cost of care. In the latter case, the price of care in these areas is below the market rate.

Special Fees

Special fees can present serious problems to low income families if they are not included in the Tribe's rate payments. Low-income families may be unable to use care when activity or registration fees are charged; or, their children may be unable to participate in special programs that require additional costs. The Tribe needs to consider market practices when establishing policies regarding the payment of special fees. The Tribe could pay these fees or add them to the base rate when establishing rate ceilings and reimbursing providers.

Some providers charge the families less for second or succeeding children in the same family. However, the cost of care per child does not change even though there are multiple children from the same family in child care. Therefore, the Tribe needs to reimburse the provider on a per child basis regardless of the number of children from one family who are in care.

Absences, Vacations and Breaks in Employment

The CCDF regulations do not establish attendance requirements for children receiving child care services. Therefore, the Tribe has flexibility in determining policies to cover payment for absences, vacations or breaks in service. These policy decisions can be stated in the CCDF Tribal Plan.

After looking at all the data and making decisions and policies as described throughout the document, the Tribal decision makers can then set payment rates for families and providers. Based on a well-developed Market Rate Survey, tribal families will have valid options in the CCDF supported child care they select. The Tribe may wish to develop and make available a Tribal Market Rate Survey Report summarizing the data collected and providing the decisions made as a result of the survey.

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