executive committee meeting november 17, 2015...november 17, 2015 4:00 p.m. until business is...

EXECUTIVE COMMITTEE MEETING November 17, 2015

4:00 P.M. until business is concluded 5735 Rio Vista Drive Clearwater, FL 33760

PROPOSED AGENDA

I. CALL TO ORDER A. Approval of November 17, 2015 Agenda page 1 B. Approval of September 17, 2015 Executive Committee Minutes page 2

II. ACTION ITEMS

A. Budget Amendment 15.11.01E page 7 B. Fraud Plan 15.11.02E page 10 C. Florida First Start 15.11.03E page 23

III. Discussion

A. School Readiness Provider Enforcement Policy page 59 B. Giving Tuesday C. Legislative Update D. VPK Readiness Rates

IV. PUBLIC COMMENT In accordance with the Florida Government in the Sunshine, all meetings of the Early Learning Coalition of Pinellas County, Inc. and its committees are open to the public. Those in attendance who wish to address the Coalition must submit a public comment card to the recorder prior to addressing the Coalition.

V. ADJOURNMENT

Next Executive Committee Meeting is currently scheduled for Tuesday, January 19, 2016 at 4:00 p.m.: 5735 Rio Vista Drive, Clearwater, FL 33760 Next Board of Director’s Meeting is scheduled for Thursday, December 3, 2015 at 4:00 p.m.: 5735 Rio Vista Drive, Clearwater, FL 33760

Unapproved Minutes—September 17, 2015

EXECUTIVE COMITTEE MEETING September 17, 2015

Unapproved Minutes 4:00 P.M. until business is concluded

5735 Rio Vista Drive Clearwater, FL 33760

Attendance: Committee Members: Craig Phillip –Chair, Cindy Seletos, Yvonne Malague Conference Call: Jack Geller Coalition Staff: Lindsay Carson, Merita Kafexhiu, Matthew Bonner Official Recorder: Rachel Meadors

I. Call to Order

Chair Craig Phillips called the meeting to order at 4:10 p.m.

A. Chair Phillips called for the approval of the September 17, 2015 agenda.

A motion was made by Cindy Seletos and seconded by Yvonne Malague to:

Approve the September 17, 2015 agenda.

The motion passed unanimously.

B. Chair Phillips called for the approval of the July 21, 2015 minutes.


Approve the July 21, 2015 minutes.


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II. ACTION ITEMS

A. Continuity of Operations Plan (C.O.O.P.) 15.09.01E Lindsay Carson presented the C.O.O.P. The Coalition is required to maintain a current Continuity of Operations Plan in case of a disaster. The COOP has been updated for this year and will be submitted to the Florida Office of Early Learning for approval. The COOP addresses how the Coalition will manage business in the instance the offices are destroyed or damaged.


Approve the Coalition’s Continuity of Operations Plan The motion passed unanimously.

B. School Readiness Eligibility Priorities 15.09.02E

Lindsay Carson presented the School Readiness Eligibility Priorities. Independent Living- Eckerd’s Community Alternatives Independent Living Program is responsible for the coordination and implementation of services to older teens in the foster care system as they prepare to turn 18 years old as well as providing assistance to young adults who previously aged out of the foster care system. The goal of Independent Living Program (ILP) is to prepare teens in foster care for adulthood and self-sufficiency. The Camelot ILP formally administers the continued services for these young adults; as well as the Ready for Life program which provides additional supports. The Coalition adjusted their terminology from Independent Living Program to the Ready for Life Program. The title Independent Living is the appropriate program title that should be used for clarification. An impact will not be felt by making this adjustment, this is only a correction. Family Services Initiative (FSI), funded by the Juvenile Welfare Board, provides “front end” short- term emergency care to stabilize families in order to prevent or address homelessness, child abuse or neglect. Participating families are referred through 2-1-1 Tampa Bay Cares. Access to childcare before circumstances reach critical could mitigate the challenges these families are facing thus making self-sufficiency and stabilization more attainable.

A motion was made by Yvonne Malague and seconded by Cindy Seletos to:

Approve the revised ELCPC-60.1.1 School Readiness Eligibility Priorities The motion passed unanimously.

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C. CEO Authority in Personnel Matters 15.09.03E

Lindsay Carson presented the CEO Authority in Personnel Matters. The powers, management, and control of the Coalition, and all of its affairs, shall be vested in the Board as outlined in Florida Statutes Chapter 1002. The Board, upon appropriate resolution, may delegate certain responsibilities to its Chief Executive Officer (CEO). The CEO is responsible for daily activities of the Coalition, compliance with local, federal and state policies and laws. Management of operations rests solely with the CEO.


Grant CEO full authority and responsibility to: -Establish and implement personnel policies in accordance with grant requirements and the Fair Labor Standards Act. -Establish or eliminate Full Time Employee positions necessary to ensure effective operations within budgetary parameters established by the board of directors.


D. Nominations for Executive Officers 15.09.04E

Chair Craig Phillips presented the Nominations for Executive Officers. Vice Chair Jack Geller Treasurer Jim Madden Secretary Patsy Buker The Early Learning Coalition of Pinellas County, Inc. bylaws state the Executive Officers will change during the annual meeting of the Coalition to be held during the first quarter of the fiscal year.


Approve the nominations of Executive Officers Discussion Chair Craig Phillips asked Cindy Seletos if she was going to continue being part of the ELC Board of Directors. Cindy Seletos replied that she had termed out of Treasurer for the Board; but, until the Governor appoints another to the Board she will continue to be an active member of the Board. Cindy Seletos asked when the nominations go into effect.

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Lindsay Carson replied at the end of the next Board of Director’s Meeting, September 24, 2015.


E. Committee Chair Appointments 15.09.05E

Chair Craig Phillips presented the Committee Chair Appointments. Finance Committee Jim Madden Board Development Committee Elliott Stern Program Development Committee Yvonne Malague Review Hearing Committee Joshua Dreschel Audit Committee Ellen Lasher Coalition bylaws require committee chairs to be appointed by the Board Chair and approved by the full Board to serve for one year.

A motion was made by Jack Geller and seconded by Cindy Seletos to:

Approve the nominations of Committee Chair The motion passed unanimously.

F. CEO Contract 15.09.06E

Chair Craig Phillips presented the CEO Contract. The Executive Committee is responsible for evaluating the job performance of the CEO of the Early Learning Coalition and conducting salary negotiations. Lindsay Carson has served as CEO since May 2014. The Executive Committee completed an annual performance review in September 2015.


Approve a one-year employment contract for the CEO, Lindsay Carson at the compensation of $3% salary increase and $5,000 bonus. Plus, revisit the contract annually, with a start date of October 1.


III. Public Comment

No public comments were made.

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IV. Adjournment: The meeting adjourned at 4:55 p.m.

Next meeting: Scheduled for November 17, 2015 at 4:00 p.m. until the conclusion of business. Early Learning Coalition Training Room, 5735 Rio Vista Drive, Clearwater FL 33760.

____________________________ _______________ Craig Phillips, Committee Chair Date

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15.11.01E

Early Learning Coalition of Pinellas County, Inc. November 17, 2015

Subject: Amendments # 1 to the FY 2015-16 budgets

BACKGROUND

The Coalition has received two grants and as the result, the total budgeted revenue has increased from $47,275,586 to $47,915,946 equaling an overall increase of $640,360 as follows:

1. The Early Learning Coalition of Pinellas County, Inc. has received the Performance Funding Pilot grant for year 2. This is an early learning professional development initiative funded by the Florida Legislature to provide incentives to child care providers and instructors for improvement in School Readiness Program outcomes and provides data for an independent evaluation. Early learning training focused on teacher-child interactions will be offered to a pilot group of SR providers within the ELC’s service area.

The project duration is October 1, 2015- July 31, 2016. Total project cost is $556,210.

2. The Early Learning Coalition of Pinellas County, Inc. has received the Early Learning Florida grant from the UF Lastinger Center for learning. The grant supports a comprehensive professional development system that helps early childhood professionals gain the knowledge and skills they need to transform the care and education they provide to young children. The Coalition will lead the development of a local implementation plan for Early Learning Florida courses (e.g., online only, online with Community of Practice (CoP) Facilitation, and online with Technical Assistance (TA) Coaching) that aligns with the Contractor quality improvement goals/initiatives.

The project duration is October 15, 2015- June 30, 2016. Total project cost is $84,150. This increase in funds and proposed utilization of these funds is as follows:

Changes in Revenue Budget:

Revenue: Increase: $640,360 Adjustments to the Coalition’s Expenditure Budget: The Coalition’s expenditure budget will be modified as follows:

PFP Provider Payments: Increase: $520,860

ELF Provider Payments: Increase: $38,250

Personnel Services Increase: $81,250

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PROPOSED COALITION ACTION To approve amendments to the Coalition’s Budget as proposed by the Coalition staff. Supporting Documents: Budget Amendment # 1

Approval ______________________________ Chair Signature ______________________________ Date

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15.11.02E


Subject: Anti-Fraud Plan

BACKGROUND

The criteria for the anti-fraud plans is described in Rule 6M-9.400, FAC. The rule requires ELCs to create procedures for detecting and investigation possible acts of fraud, abuse or overpayment and procedures to ensure due process for recipients. It also requires training on the detection and prevention of fraud, abuse and overpayment including an annual self-assessment of the ELC’s internal controls, policies and procedures. The ELC Anti-Fraud Plan was approved by the board May 26, 2015 and approved by the Office of Early Learning in July 2015. This plan includes provisions for benefit recovery (in cases not associated with fraud) related to unreported changes that affect subsidy rates.

PROPOSED COALITION ACTION To approve the revised 2015-2016 Anti-Fraud Plan and ELCPC-60.1.16 School Readiness Client Compliance Policy. Supporting Documentation Attached: 2015-2016 Anti-Fraud Plan ELCPC-60.1.16 School Readiness Client Compliance Policy

Approval _________________________________________ Chair Signature _______________________ Date

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Revised December 3, 2015

Anti-Fraud Plan

2015-2016

Coalition Board Approval Date: May 26, 2015December 3, 2015

OEL Approval Date:

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Table of Contents

I. Plan Statement

II. Plan Definitions

III. Description of Organization Structure with Plan Responsibilities

IV. Plan Procedures A. ELC Procedures Review

B. ELC Staff Education/Awareness/Training

C. SR and VPK Parent Education and Awareness

D. SR and VPK Provider Education and Awareness

E. Providers, Parents, Employees, and Public Access to Reporting of Potential Fraud

F. ELC Detection and Investigation of Suspected Acts of Fraud, Abuse, or Improper

Payment

G. Benefit Recovery

H. Monthly Reporting Process to OEL

I. Plan Contact

V. Attachments A. ELCPC-10.1A Provider Grievance and Due Process Policy

B. ELCPC-10.1B Client/Recipient Grievance and Complaint Resolution Policy

C. ELCPC-10.6 Suspected Employee Fraud Policy

D. ELCPC-50.1 Suspected Provider and Client Fraud and Misrepresentation Policy

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I. Plan Statement

The Anti- Fraud Plan addresses the detection and prevention of overpayments, abuse, and fraud relating to the provision of and payment for the School Readiness (SR) program and Voluntary Prekindergarten (VPK) program services. The Plan addresses parents or legal guardians of children enrolled in the SR or VPK programs. Note: provider fraud is a violation of the terms of the contract and is addressed in the statewide contract rules.

The Anti- Fraud Plan serves to support organizational processes and staff in prevention of fraud, build on employee knowledge and awareness of fraud prevention and describe the Coalition’s procedures for detecting and investigating possible acts of fraud, abuse of services and related overpayment. Due process procedures for suspending or terminating a recipient’s eligibility for SR or VPK programs and the recipient’s right to appeal the decision are included in the Plan.

II. Plan Definitions

Recipient- The parent or legal guardian whose child was determined eligible for SR or VPK Education Program benefits.

Fraud- An intentional deception, omission, or misrepresentation made by a person with knowledge that the deception, omission, or misrepresentation may result in unauthorized benefit to that person or another person, or any aiding and abetting of the commission of such an act. The term includes any act that constitutes fraud under applicable federal or state law.

Suspension- When services are temporarily no longer provided, however, parents do not have to go to the waiting list when their suspension is finished.

Termination- When services are ended and the recipient would have to return to the waiting list when their termination is expired.

III. Description of Organization Structure with Plan Responsibilities

The Fraud/Benefit Recovery Specialist is responsible for implementing the Coalition’s anti-fraud activities.

The Director of Program Operations is responsible for reviewing an initial appeal request by recipient for decision to uphold or modify the suspension or termination.

The following are responsible for the daily activities related to prevention, detection, investigation, and reporting of possible overpayment resulting from potential fraud or abuse:

Internal Means of Notification

External Means of Notification

Family Services Specialist Reimbursement Specialist Contract & Compliance Specialist Program Integrity Specialist Suspected Fraud Tip Line

Child Care Providers Centers & Homes DFS/DPAF DFS/DIF Pinellas County License Board CareerSource Pinellas Office of Early Learning Early Learning Coalitions USDA Food Programs LSF – Head Start/Early Head Start R’Club Child Care – Food Program

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Juvenile Welfare Board Local/ State Law Enforcement DCF Pinellas County School Board Early Steps/ FDLRS Suspected Fraud Tip Line

IV. Plan Procedures

A. ELC Procedures Review 1. Director of Program Operations, Human Resources Generalist, Chief Financial Officer, and Chief

Executive Officer will annually review job descriptions and internal processes to confirm appropriate separation of duties is in place, and review internal controls to reduce risk.

B. ELC Staff Education/Awareness/Training 1. Fraud/Benefit Recovery Department holds an annual meeting for Family Services Eligibility Staff

on Fraud/Benefit Recovery, given by Department of Financial Services, Division of Public Assistance Fraud Unit.

2. Fraud/Benefit Recovery Specialist is a member of the Association of Certified Fraud Examiners and completes at a minimum of five (5) Continuing Professional Education hours annually.

3. Family Services Department holds a staff meeting twice a month to review any changes or issues that may arise.

4. All Departments under Program Services meet twice a month, which consist of the following departments; Contracts and Compliance, Family Services, Fraud/Benefit Recovery and Reimbursement.

5. Program Integrity continually monitors throughout the year and holds department meeting on their findings.

C. SR and VPK Parent Education and Awareness 1. Display fraud awareness posters in interview rooms at ELC 2. A fraud awareness statement is included in SR parent packets with ELC phone number to report

any suspected fraud 3. Family Services will review responsibilities of parent in detail at interview, including importance of

reporting changes in their circumstances with in ten (10) days, which will include recipient signing an SR Scholarship Participant Agreement and receiving a VPK Parent Guide, if applicable.

4. Information about the ELC Fraud Tip Line is included on the ELC phone system hold menu.

D. SR and VPK Provider Education and Awareness 1. Encourage child care providers to report potential fraud to ELC staff through provider

communication venues including email or portal communications, and appropriate provider group meetings

2. Periodic reminders to providers about having procedures in place to prevent fraud 3. Regular practices of monitoring that occur with providers that also keep providers aware of ELC’s

intention to prevent and/or detect fraudulent practices 4. Use of SR and VPK monitoring tools

E. Providers, Parents, Employees, and Public Access to Reporting of Potential Fraud

1. The Suspected Fraud Reporting form and phone number is on the ELC website; for the purpose of reporting potential fraud for parents, providers, employees, and general public.

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F. ELC Detection and Investigation of Suspected Acts of Fraud, Abuse or Improper Payment 1. Monthly unscheduled reviews of work products and follow up on questionable circumstances are

conducted by Family Services Training Coordinator, Monitoring and Compliance Specialist, and Fraud/Benefit Recovery Specialist

2. Monthly review, research, and follow up of data quality reports generated from Office of Early Learning are completed by Family Services Specialist and Monitoring and Compliance Specialist

3. Documented verification of child care referrals from other organizations through manager signature, if required, and periodic cross reference review of children in service

4. Daily alertness of Family Services Specialist to inconsistencies through regular operational processes with recipient(s). At initial placement and eligibility redetermination, the Coalition’s Family Services Specialist reviews the recipient’s information for “red flags”. If the Specialist believes “red flags” exist, but cannot be confirmed, then the case is forwarded to the Director of Program Operations and the Fraud/Benefit Recovery Department for further review with an explanation on the ELC Investigation form. This will include consultation with the Department of Financial Services (DFS), the Division of Public Assistance Fraud (DPAF) and/or the Division of Insurance Fraud (DIF).

5. Once inconsistencies are identified through any of the above means, the ELC Fraud/Benefit Recovery Department will conduct a phone interview with recipient(s) (recipient will be told that the interview is being recorded) and obtain verification from parent or legal guardian within five (5) business days to resolve inconsistencies, which could include but not limited to income, residential documentation, or household composition, and determine if situation is resolved or warrants next steps of due process provisions for termination or suspension of SR or VPK benefits. – Family Services and Fraud/Benefit Recovery Department

6. The ELC Fraud/Benefit Recovery Specialist will save the recording of the phone call. 7. For those cases in which there is reasonable suspicion that a recipient has committed fraud in

the receipt of SR or VPK services, calculate associated overpaid benefits amount and follow the due process provisions for termination or suspension of SR or VPK benefits – Fraud/Benefit Recovery, Family Services, Reimbursement and Finance Departments

8. After phone interview by ELC Fraud/Benefit Recovery Specialist, a follow up letter with delivery confirmation will be sent by ELC Fraud/Benefit Recovery Specialist requesting all documents to be sent within five (5) business days that will clarify or correct Coalition records.

9. If there is no response by recipient(s), case will be referred to DFS.

G. Benefit Recovery

Cases Below Minimum Threshold

In situations where DFS determines that there is reasonable suspicion fraud has occurred, but is unable to refer the case to the States Attorney’s Office due to low restitution amount, the case will be processed through the repayment agreement process.

1. DFS determines that there is reasonable suspicion fraud has occurred, but refuses case due to restitution is below $5,000.00

2. DFS shares findings and supporting documentation with ELC Fraud/Benefit Recovery Specialist. 3. ELC Fraud/Benefit Recovery Specialist Contacts recipient(s) and schedules an in person

interview. 4. During the interview with the recipient(s), the ELC Fraud/Benefit Recovery Specialist and another

ELC staff person, the ELC/DFS findings are shared and recipient(s) is given the opportunity to sign a repayment agreement or request a Review Hearing.

5. If the recipient(s) is still qualified for services and signs a repayment agreement, services will continue as long as the terms of the repayment agreement are being met.

6. Payments must be made by money order or cashier’s check and payable to the Early Learning Coalition of Pinellas County.

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7. ELC Fraud/Benefit Recovery Specialist or assigned ELC Staff person will write a receipt for each payment received and document payments in recipient(s) file.

8. All payments will be delivered to the Fiscal Department for further processing. 9. If the recipient fails to meet the terms of the repayment agreement, the ELC may choose to have

the case resubmitted to DFS or file a civil action through Pinellas County Clerk of Court. 10. If recipient(s) requests a Review Hearing, the Coalition will follow the procedures outlined in the

Client/Recipient Grievance and Complaint Resolution Policy. Services will continue until the Review Hearing is conducted and a final decision is made by the committee.

11. Fraud/Benefit Recovery Specialist or assigned ELC Staff person will document outcomes of the Review Hearing.

12. If the Review Hearing Committee determines that the evidence supports DFS’s determination that fraud was committed, the recipient will be given the opportunity to sign a repayment agreement.

Improper Payments

In situations where recipient(s) has received SR/VPK where there is NOT reasonable suspicion of fraud, but an improper payment exists which exceeds $250, the case will be processed through the repayment agreement process.

1. At time of eligibility redetermination, the Coalition’s Family Services Specialist will review the recipient’s information for any unreported changes that would change the parent/recipient co-pay or eligibility status.

2. The ELC Family Services Specialist will verify the new information to make sure the recipient(s) is still eligible for School Readiness funding.

3. If recipient no longer qualifies for SR funding they will be terminated with fourteen (14) calendar days’ notice.

4. If recipient still qualifies for services they will continue to receive SR funding. 5. The ELC Family Services Specialist will fill out an Investigation Form, have it reviewed and

signed by the Director of Program Operations, and placed in Fraud/Benefit Recovery mailbox. This applies to items 3 and 4 above.

6. ELC Benefit Recovery Specialist will confirm that there is no reasonable suspicion of fraud. 7. Fraud/Benefit Recovery will follow the steps 5-8 in the section above.

H. Monthly Reporting Process to OEL

The Fraud/Benefit Recovery Specialist will submit an electronic report monthly reporting the parents and providers terminated from services as a result of fraud, per Rule 6M.9.400 subsection (b).

Process for Mandatory Reporting Fraud and Abuse through the OEL Fraud Referral System

The Fraud/Benefit Recovery Specialist is the designated administrator for the Office of Early Learning’s Fraud Referral System. Contact information:

Margaret “Peggy” Comerford Early Learning Coalition of Pinellas County

[email protected] (727) 400-4458

At the point when potential fraud has been communicated to the recipient, the Fraud/Benefit Recovery Specialist makes a mandatory referral for potential fraud or abuse investigation using Office of Early Learning Fraud Referral System. The referral includes the recipient information, amount of overpayment; discover date and a brief summary of the allegations, and notifications of any evidencing documents available that substantiate the allegations.

Note the Coalition’s fraud investigation and appeals procedures outlined in this plan will complement the OEL referral process to Department of Financial Services through the Fraud Referral System.

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mailto:[email protected]


I. Plan Contact: Margaret “Peggy” Comerford, Fraud/Benefit Recovery Specialist, ELC of Pinellas County, [email protected]

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mailto:[email protected]


Attachment A

ELCPC-10.1A Provider Grievance and Due Process Policy

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Attachment B

ELCPC-10.1B Client/Recipient Grievance and Complaint Resolution Policy

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Attachment C

ELCPC-10.6 Suspected Employee Fraud Policy

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Attachment D

ELCPC-50.1 Suspected Provider and Client Fraud and Misrepresentation Policy

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T:\Board\Meetings\Executive Committee\2015-2016\November 2015\60.1.16. SR Client Compliance Policy.doc

Policy: ELCPC-60.1.16

Title: School Readiness Client Compliance Policy

Review Date: November 16, 2015

Next Review Date: November 16, 2016

References: Chapter 1002.87(4)

School Readiness Participant Agreement Purpose: To establish enforcement procedures for client compliance with the

parent rights and responsibilities. Background: Florida Statute 1002.87, School Readiness Program; Eligibility and

Enrollment indicates “The parent of a child enrolled in the school readiness program must notify the coalition or its designee within ten (10) days after any change in employment, income, or family size. Upon notification by the parent, the child’s eligibility must be reevaluated.”

Policy: School Readiness clients must notify ELC within 10 days of any changes

affecting income, employment status, school enrollment status, or household size.

Procedures:

I. Loss of eligibility In the event a client fails to report a change that makes the client ineligible for school readiness services, the scholarship will be terminated at the end of the authorization period or in 14 calendar days, whichever is shorter and the client will be ineligible to apply for the wait list for 3 months.

II. Change in Parent Copayment A. First occurrence: In the event a client fails to report a change that does not

impact their eligibility, but does result in an increase in their parent copayment the client will receive a written warning that failure to report changes within 10 days can result in a loss of scholarship. Second Occurrence: In the event a client fails to report a change that does not impact their eligibility, but does result in an increase in their parent copayment after receiving the first warning the scholarship will be terminated at the end of the authorization period or in 14 calendar days, whichever is shorter and the client will be ineligible to apply for the wait list for 3 months.

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15.11.03E


Subject: Florida First Contract

BACKGROUND

The Coalition has a contract with the Pinellas County School Board for the Florida First Program. Florida First Start (FFS) is a home visitation program designed to give young children school readiness skills and to give parents strategies to be their child’s first and lifelong teacher. Certain members of the Board of Directors of the Coalition are mandated by the “School Readiness Act”. The mandated members consist of executive directors of child care providing agencies or government agencies. As a result, in order to achieve its objectives, the Coalition enters into related-party transactions with the organizations in which the Coalition’s Board Members are actively involved. The related-party members include Assistant Superintendent for Elementary & Special Education of Pinellas County. Section 1002.84(20), Florida Statutes (F.S.) provides instructions each entity must comply with before contracting with governing board members, employees, or relatives of either group. “Such contracts may not be executed without the prior approval of the office.” The Florida First Start contract is considered related party contract and is required to be presented to the coalition’s entire governing board for a vote. In addition, the Coalitions are prohibited from entering into contracts equal to or greater than $25,000 without prior approval from the Office of Early Learning (OEL) when the contract is with employees, governing board members or relatives of either group. In addition, the minutes must discuss the vote on this contract too and the conflicts of interest must be disclosed. The member must be abstaining from the vote. Also, the details of how each member voted must be provided to the OEL.

PROPOSED COALITION ACTION To approve the contract with PCSB for the Florida First Start program. The contract term is July 1, 2015 - June 30, 2016. Supporting Documents: Contract SR15-01; Amendment #1, and Related party transaction form.

Approval ______________________________ Chair Signature ______________________________ Date

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RELATED PARTY CONTRACTS

CHECKLIST

Related Party Board Member

Contract Amount over $25,000 Yes

Amount of Contract $239,220

Was the contract presented to the Board for approval?

Yes, at July 28, 2015 meeting - as part of the budget approval process for year 2015-2016

The program is also part of the Coalition Plan approved by the OEL (Item III.B) on 9/2015.

Total number of board members present or on attendance by conference call

14 +4 = 18; 3 members were absent

Number of percentage of board members stated in the bylaws to establish a quorum

18 out of 21 or 85%

Quorum Established Yes

Conflict disclosed prior to vote Yes; when applicable However, the PCSB board member, Ms. Sandra Downs was absent on July 28, 2015; therefore, could not abstain

All benefiting members abstain from the vote (Yes or No and number abstained)

The PCSB board member, Ms. Sandra Downs was absent on July 28, 2015; therefore, could not abstain.

Approved by two –thirds vote of entire board (not just those in attendance)

Yes

Proper conflict disclosure forms completed for all individuals and submitted with board minutes to OEL(Form88)

The PCSB board member. Ms. Sandra Downs was absent on July 28, 2015; therefore, form 8B could not be completed.

Board minutes detail the breakdown of how each board member voted in order to ensure that two-thirds of the members voted in favor of approving the related party contract and submitted to OEL

Yes

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Board approval Yes

Reported to OEL within 30 days of board approval No for reasons stated below

Prior approval obtained form OEL Part of the Plan approval process

Note/Justification This is not a new contract. The contract with PCSB/Florida First Start was in place before 7/01/13*.

It has been disclosed on the Coalition financial statements as a related party contract each year.

According to OEL paper: “Questions and Answers about Requirements for OEL Prior Approval of Related Party Contracts in HB 7165 – Early Learning Legislation”, Item 3: If the contract was in place before 7/01/13 when the early learning legislation was put into effect, the previous federal and state laws, rules, regulations and instructions for procurement actions, contracting processes and conflict of interest disclosures apply. If all of the existing provisions were followed, the contract may continue.

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T:\Board\Meetings\Executive Committee\2015-2016\November 2015\ELCPC-61.2 School Readiness Provider Enforcement Policy April 2015.docx

Policy: ELCPC-61.2

Title: School Readiness Provider Enforcement Policy

Review Date: July 2015

Next Review Date: July 2016

References: Statewide School Readiness Provider Contract

OEL-SR20, OEL SR20LE, OEL-SR 20L, OEL-SR20FFN

School Readiness Provider Monitoring Tool, Chapter 1002 F.S., Florida Administrative Code Chapter 6M

Purpose: To outline enforcement actions with School Readiness providers who

are fail to comply with the terms of the School Readiness Provider Contract.

Background:

This Coalition policy and procedure is inclusive to all caregiver settings: child care center, licensed family child care home or informal provider receiving School Readiness (SR) funding. Policy: Corrective Action If the Coalition determines a provider has failed to comply with the School Readiness Provider Contract and concludes that corrective action will resolve the noncompliance, the provider will be notified in writing. The notice will identify the specific requirement the provider has failed to meet and a detailed description of required corrective action and timeline for completion. Coalition staff will verify satisfactory completion of corrective action and provide confirmation in writing to the provider. Probation If the provider fails to complete corrective action in the designated timeframe or has multiple corrective action plans within the same contract year, the provider will be placed on probation for up to 6 months. Terms of probation will be determined by

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T:\Board\Meetings\Executive Committee\2015-2016\November 2015\ELCPC-61.2 School Readiness Provider Enforcement Policy April 2015.docx

Coalition staff and will specifically relate to the areas of noncompliance. Probation may include one or more of the following conditions: training or staff development, monitoring or technical assistance, submission of documentation related to the violation. The Coalition will notify the provider in writing of the terms and duration of the probation. Financial Consequences Noncompliance related to insurance, background screenings, reporting suspected abuse or neglect, child attendance documentation or child ratios will result in nonpayment for school readiness funded children for the affected days. Terminations Notices of termination will include basis for the termination and state that a provider may request a review of the determination in accordance with the School Readiness/VPK Provider Grievance and Dispute Resolution Policy ELCPC-10.1. A provider whose School Readiness Provider Contract has been terminated due to noncompliance will be ineligible to execute a new School Readiness Contract for five (5) years from termination of the Agreement. Termination for Cause In the event of a termination for cause, providers will be notified 10 days prior to the effective date. Parents of School Readiness funded children will be notified at least 5 days prior to the termination date that the funding for this Provider’s program will cease. CCR&R staff will assist parents in finding alternate care. Parents choosing to keep their child enrolled with the terminated Provider will forfeit their School Readiness scholarship. Immediate Termination The Coalition must immediately terminate a provider’s School Readiness Contract upon notification from Child Care Licensing that actions or inactions of a provider pose an immediate and serious danger to the health, safety or welfare of children. Any lapse in coverage, non-renewal or cancellation of general liability insurance will result in immediate termination. In the event of an immediate termination, the Coalition will notify the provider by sending the provider written notice of emergency termination at least 24 hours prior to termination. CCR&R staff will assist parents in finding alternate care. Parents choosing to keep their child enrolled with the terminated Provider will forfeit their School Readiness scholarship.

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