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The table below shows comments received at this web site about the following rule:

Working Connections
DCYF is implementing the federal requirement of 2nd tier eligibility and making amendments to improve the readability of the chapter as well as technical changes needed after the creation of DCYF.

DEL uses these comments, and other input during the rule making process, to help us write and adopt the permanent rules. For proposed rules only, DEL will prepare one response to all of the comments received, in what is called a “concise explanatory statement” required by RCW 34.05.325. The department sends the concise explanatory statement to everyone who commented or testified on the proposed rule, and to anyone who asks for it.

Agree/Disagree: Neutral

Comment: WAC 110-15-0020 Subsections (1)(a)(i) through (iv) don’t mention citizenship or residency. I bring this up because WAC 110-15-0024 on CWCCC doesn’t either. The reasoning we’re using for that is, because it doesn’t mention it, it’s not needed for CWCCC. Using that logic, aren’t we saying in-loco parentis/NNR children don’t need to meet citizenship/residency requirements? Suggest adding “other requirements under WAC 110-15-0005 (2).” Subsections (4), (5), and (6) are from the now-repealed WAC 110-15-0055. We want to confirm that this supports current practice of 12-month eligibility/authorization, and termination with 10-day notice if a consumer doesn’t begin their activity. WAC 110-15-0031 Do subsections (3) and (4) apply to all changes or only required reports? If the latter, we suggest adding that to these subsections in some way to make it clear. WAC 110-15-0065 CSD’s practice has been to not give 60 days to verify income in the middle of a certification period. If this is how we ought to continue, recommend removing “and change reporting” from subsection (1)(b)(ii). WAC 110-15-0095 Subsection (1)(c) was deleted, which said one of the conditions for benefits beginning was “The consumer needs child care for approved activities within at least thirty days of the date of application for WCCC benefits.” Why was this deleted? Also, WAC 110-15-0020 addresses approving child care 14 days before the start of an activity. Current practice is to approve a child care application if they need child care within 30 days of application. With this, it sounds like they can only approve if it’s within 14 days. But is that 14 days from the date of application, or the date of approval? If a consumer applies for child care and needs care to start within 30 days, are we able to approve them so long as we don’t authorize more than 14 days in advance? WAC 110-15-0095 addresses when WCCC benefits start. Does this mean the start date of an eligibility period, or when a consumer may be authorized for care? Should CWCCC or HGP be addressed in this section at all since they may not have an approved activity, and reference their individual WAC’s? WAC 110-15-0110 Subsection (2)(a) was previously going to be updated to say “sustained countable income” to conform with the CCDF plan. But it wasn’t updated. Why not? Again, should HGP or CWCCC be referenced as an exclusion for this WAC?

Date Submitted: 1/7/2019 8:27:50 AM

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