FAQ's for services

The enrolments in my service have not dropped. In fact they have increased and some of my educators are providing more care out of standard hours. Can we receive more than the formula used to calculate the ECEC Relief Package payments?

FDCA raised this issue with the Department as soon as the details about the Relief Package were released.

The Government has acknowledged that not all aspects of the package align with the family day care service model and they are working through these issues.

In recognition that not all ECEC services have suffered severely decreasing enrolments and attendance, especially in the family day care sector, the Department has made a commitment to make payments at a higher rate available in some circumstances such as where greater funding is required due to an increase in enrolments to meet demand to address the needs of essential workers or vulnerable children; or where a provider or a service were not in operation during the reference fortnight.

The Government has developed a new online “Supplementary Payment Form” for use by services in these situations. To access the form, click here (scroll to the bottom of the page). We recommend reading our email bulletin sent to services on Friday, 10 April before completing the form.

 

What do Family Day Care services have to do to receive payments under the Early Childhood Education and Care Package?

To receive the ECEC Relief Package payments “services are required to:

  • stay open unless closed on public health advice or for other health and safety reasons;
  • ensure families are not charged a fee, including an out of pocket or gap* fee;
  • continue and prioritise care to essential workers, vulnerable and disadvantaged children and previously enrolled children;
  • continue to record attendance of children;
  • where children enrol at a service who otherwise would be considered ‘at risk’ for the purposes of Additional Child Care Subsidy (ACCS) (child wellbeing) services are required to make a referral to an appropriate support agency as per the existing ACCS (child wellbeing) referral requirements;
  • comply with all other provider obligations including National Quality Framework and other relevant conditions of approval under Family Assistance Law.”

* The gap fee is the difference between the fee charged and any CCS paid

Services do not need to apply for the ECEC Relief Package payments. Payments will be made on a weekly basis until 21 June 2020 unless notified by the Department. To assist services with cash flow while they apply for the JobKeeper Payment scheme and/or apply for a higher rate of payment through the Supplementary Relief Payment (if required), the department is combining the second and third ECEC Relief Package payments to services (to be paid at the time of the second payment). This advance payment means there will be one less weekly payment at the end of the twelve week payment period, meaning payments will conclude 21 June 2020, instead of 28 June as previously stated.

 

Is there any guidance on how to distribute the ECEC Relief Package payments equitably to my educators?

The Government has not issued any specific rules for services regarding the distribution of the ECEC Relief Package payments to educators.

While FDCA has raised this issue with the Department we have recently commissioned Deloitte Australia to develop independent Practice Guidance for the distribution of funds under the ECEC Relief Package. This Practice Guidance has been distributed to members.

In the meantime, FDCA strongly encourages all services to be mindful that while the lump sum payments are distributed to services, these payments are designed to provide financial assistance to both services and their educators.

 

What tips are there for completing an application for the Supplementary Relief Payment?

In addition to reading the information we provided in our email bulletin dated 10 April 2020, you may wish to consider the following tips provided in the DESE FAQs:

Within the first four weeks of operation of the Relief Package, services can only be assessed as eligible for supplementary payments once. After the first four weeks, arrangements will be reviewed and any changes will be communicated to providers. Where a services’ application is rejected due to inaccurate or incomplete information the service can reapply within the four weeks. Services are encouraged to read the supporting information and the examples provided at relevant questions when completing an application.

Invalid applications

Where there are errors in critical identification or registration details the department is unable to process the application. Invalid applications will be rejected and services will need to reapply to be considered for a supplementary payment.

Common errors include:

  • Provider Customer Reference Number (CRN) and Service CRN used are the same, are not linked OR are entered incorrectly.
  • PRODA ID used does not belong to the person completing the application OR has been entered incorrectly. The PRODA ID must be the ID of the person with management and control who is completing the application.
  • Business or service registration IDs used have not been able to be verified.

Insufficient evidence

Applications that do not include enough evidence to support the claim will not be approved and services will need to reapply to be considered for a supplementary payment.

Common errors include:

  • Not attaching evidence; evidence that is not linked to attendance; evidence that is not linked to hours of care provided in current period; evidence is about future demand not current hours of care; or claims for more children attending than are currently enrolled at a service.

All services must continue to record attendance for the children in their care. If a service is doing this through their third party software, the reports from this software can be used as evidence. This would show the enrolment IDs, attended hours and session hours.

When preparing supporting documents, personal information including names and dates of birth must be redacted. Multiple attachments can be provided in a zip file.

Incorrect information

Where a service finds they have made a mistake on an application after it has been submitted, this cannot be corrected without submitting a new application. Corrections lodged via email cannot be considered.

Common errors include:

  • Current number of children entered as a fortnightly figure rather than weekly.
  • Current number of children taken from enrolment numbers not attendances.
  • Current hours of care reflected as weekly figures rather than fortnightly.
  • Current hours of care reflected as the difference between previous and current hours rather than total new hours of care.”

 

What is the incentive for family day care services and educators to offer non-standard care with the way the new ECEC Relief Package payments are being calculated?

Currently the calculation of the average service fee takes into account non-standard hours care provided during the reference fortnight (beginning 17 February 2020).

FDCA has sought advice from the Department about the potential negative impact of the new ECEC Relief Package on availability of non-standard care. The Department has advised that if you have increased non-standard care delivery since the reference fortnight your service may apply for a higher payment level to account for this.

The Government has developed a new online “Supplementary Payment Form”  currently for use by services in these situations. To access the form, click here (scroll to the bottom of the page). We recommend reading our email bulletin sent to services on Friday, 10 April before completing the form.

The Department has also informed FDCA that they are also looking at alternative funding mechanisms to incentivise the delivery of additional non-standard hours care to frontline workers. We will update members as soon as we know more on this.

 

What are the current requirements about collecting gap fees? I thought that only applied if your service was closed by a health authority?

This section only applies for care provided between 23 March 2020 and 5 April 2020.

Following the Government’s announcement of the ECEC Relief Package on 2 April 2020, the Government is now allowing services to waive the out-of-pocket charges they would normally follow up on, where a service remains open but children aren’t attending. Where a service remains open but children are not attending. This new rule is designed to provide some fee relief for parents and at the same time encourage families not to withdraw their children from child care and to make use of absences and additional absences. This change applies retrospectively from 23 March 2020 and extends on the rule previously announced which allowed services who had been directed to close by a public health authority to waive the gap fee for parents.

While centre-based care services are able to waive these fees automatically, family day care providers are being asked to apply to the Department of Education, Skills and Employment by emailing childcareintegrity@dese.gov.au “if they believe their service or families need this assistance”. Note that services that do this will first undergo a compliance check.

 

As a family day care service, are we allowed to keep charging our educators the fees that keep our service running?

Internal fee arrangements between a family day care service and an educator are a commercial business arrangement. As such, the Government does not regulate or intervene on these matters. However the Government has, as part of broader messaging around the COVID-19 response, appealed to all businesses to look at their rate of fees and charges and see if they can reduce them in recognition of the unprecedented times being experienced, and also in consideration of other complementary government initiatives such as the JobKeeper Payment Scheme. The ATO is administering the JobKeeper Payment scheme, so for the latest information on eligibility rules and how the scheme will work, go to www.ato.gov.au/General/JobKeeper-Payment/.

 

When will my service start to receive the ECEC Relief Package payments?

Payments commenced from the week beginning 6 April 2020 and will continue until the week ending 21 June 2020, unless otherwise notified by the department. To assist services with cash flow while they apply for the JobKeeper Payment scheme and/or apply for a higher rate of payment through the exceptional circumstances Supplementary Relief Payment (if required), the department combined the second and third ECEC Relief Package payments to all services, including family day care .

The Department advises that other subsequent payments will stay on a weekly cycle at this stage. Note that this advance payment will mean there will be one less weekly payment at the end of the twelve week payment period, meaning payments will conclude 21 June 2020, instead of 28 June 2020 as previously stated.

 

Will my service continue to receive payments under the ECEC Relief Package if my service is directed to close by health authorities due to COVID-19?

Yes. You are still eligible to receive this payment if your service is directed to close on public health advice or for other valid health and safety reasons.

 

Will I still be able to apply for CCCF Special Circumstances grants, as previously was the case?

The CCCF grant opportunity closed on 3 April 2020 and is no longer available for new applicants. For providers who are currently receiving a CCCF grant, there is no change. For those who have already lodged an application for CCCF Special Circumstances Grant for COVID-19 reasons, these are currently being considered by the Department.

 

Many parents have contacted my service saying they want access to the free childcare announced by the Government. Do I have to accept new enrolments at this time?

In short, the answer is no. Services and educators are not compelled to accept new enrolments from families as a result of the new package. On this matter the Government has advised that under the new ECEC Relief Package “services must prioritise care to children of essential workers, vulnerable and disadvantaged children, and children who were previously enrolled. There is no obligation for services to take on new families, increase hours of care or re-enrol those that have withdrawn if services do not have enough staffing to provide care or cannot meet health and safety obligations. Prioritising of new children (if capacity exists) is a business decision.”

 

How do I know if my service is eligible for the JobKeeper Payment scheme?

The ATO is administering the JobKeeper Payment scheme, so for the latest information on eligibility rules,  how the scheme will work, and to apply go to www.ato.gov.au/General/JobKeeper-Payment. Eligibility rules include:

  • the business has a turnover of less than $1 billion and their turnover will be reduced by more than 30 per cent relative to a comparable period a year ago (of at least a month), or
  • the business has a turnover of $1 billion or more and their turnover will be reduced by more than 50 per cent relative to a comparable period a year ago (of at least a month), and
  • the business is not subject to the Major Bank Levy

Not-for-profit entities (including charities) and self-employed individuals (businesses without employees) that meet the turnover tests that apply for businesses are also eligible to apply for JobKeeper Payments.

In order to receive JobKeeper Payments, employers must have been in an employment relationship with eligible employees as at 1 March 2020, and confirm that each eligible employee is currently engaged.

 

What should I do if I think my service is eligible to receive the JobKeeper Payment subsidy?

The latest information about eligibility rules and how to enrol in the scheme are now live on the ATO’s website at www.ato.gov.au/General/JobKeeper-Payment/.

In the meantime, FDCA encourages services that think they may be eligible, to talk to their accountant about their ability to demonstrate the required reduction in turnover. Note that the ATO has included specific information for tax professionals at www.ato.gov.au/General/JobKeeper-Payment/.

 

I am a Council Service. I have heard that I might NOT be eligible for the JobKeeper Payment scheme. How do I find out?

FDCA has already raised this matter with the Department of Education, Skills and Employment and is awaiting clarification. It appears to be a broader ECEC sector issue that has been flagged across multiple departments and is currently being considered by the Department as a matter of high priority. However, we are still awaiting resolution of this matter. We will provide an update as soon as we have new information. In the meantime, we encourage you to register for updates at the ATO website by clicking here. We also encourage you to contact the relevant department or regulatory authority in your state or territory to check if there are any local initiatives that may assist you.

 

When will JobKeeper Payments commence?

The JobKeeper Payment subsidy scheme will start as of 30 March, with first payments received in the first week of May 2020. This means payments will be backdated in monthly arrears payments to employers and sole traders from the ATO. Enrolments in the scheme have now open to eligible employers, sole traders and other entities. The ATO is administering the JobKeeper Payment scheme, so for the latest information on eligibility rules and how to enrol for JobKeeper Payment, go to www.ato.gov.au/General/JobKeeper-Payment/.

 

Can my service still access the JobKeeper Payments if I have already closed and stood down my staff?

To access support through the JobKeeper Payment scheme, you must have been in an employment relationship with nominated employees as at 1 March 2020. You may re-engage stood down employees to be able to access support for them through the JobKeeper Payment scheme. The ATO is administering the JobKeeper Payment scheme, so for the latest information on scheme eligibility rules and how it will work, head to www.ato.gov.au/General/JobKeeper-Payment/.

 

What financial assistance is available to me if I voluntarily choose to close my service?

The majority of initiatives that the Government has announced to assist small businesses responding to the challenges of COVID -19 emergency, such as the recently announced Early Childhood Education and Care Relief Package and the JobKeeper Payment scheme  are targeted at keeping businesses open.

If you make a business decision to close your service voluntarily, and you have not beendirected or advised to close by a health agency or state regulator, no payments will be made under the ECEC Relief Package.

 

Therefore we encourage you to talk to your accountant in the first instance to investigate how you might be able to stay open while this current crisis exists. Bear in mind you may have additional obligations to your staff during the COVID-19 emergency so do visit www.coronavirus.fairwork.gov.au to check.

Remember if you decide to close your service, either voluntarily or as advised, you must notify your state and territory regulatory authority within 24 hours.