CCS PROVIDER REFUSAL AND HOW TO AVOID IT
In family day care, although you may be passionate and confident in your ability to operate an education and care service, that won’t be enough for the Federal Regulatory Authority when you submit your application for CCS approval.
You must be able demonstrate the governance arrangements and operations of your family day care service to be granted approval.
The number one reason for CCS provider refusal is the lack of business planning. And, did you know that if your application for CCS is refused, which is common, you will have to wait an additional 18 months before applying again?
A CCS provider refusal could end your dreams of running your own family day care service. You see, if you are not successful in your application for CCS the first time the state regulatory authority may seek to have your service approval revoked, and may request you surrender your approved provider approval. This would be devastating when you have worked so hard to get that far.
The Family Assistance Legislation clearly states the ‘delegate’ (regulatory department) assessing your application must refuse to approve an application for CCS if the applicant does not meet the fit and proper requirements. Being determined as fit and proper to administer government funds is a stringent assessment which includes, in detail, how you will operate the service from a business perspective.
So to avoid CCS provider refusal, it’s crucial you develop a business plan that demonstrates how you will operate. You need to consider things such as:
– how will you recruit, screen and appoint staff and educators?
– which operating systems will you have in place to manage accounts and finances?
– what training and supports do you have in place for staff and educators?
– how will you advertise your service?
– how will you enrol families and what supports you will offer?
– how will you manage educators if they become ill and cannot provide care?
– what staff are you going to employ and their responsibilities (delegation of authority)?
– if something should go wrong, how will it be managed and in what time frame?
– what are you going to charge families and for what (fee schedule)?
– what is the reporting structure within your service?
A business plan will prepare you to operate your service, which, technically, you should commence operating within 6 months of being granted your service approval.
By not having adequate business arrangements in place the regulatory officer assessing your application has no choice other than CCS provider refusal if they cannot determine your business practices and may conclude;
– You do not have the ability to manage accounts
– You do not have the systems in place to monitor finances
– You do not have a sound understanding of the Family Assistance Legislation
– You do not have procedures in place to identify fraudulent activity
– You not have the ability to train and monitor staff
Time and again people come to JPS with their CCS provider refusal letter from the Department, and in almost all cases, the rejection letter states ‘the approved provider did not demonstrate appropriate arrangements to ensure the service will meet its obligations’ and are not ‘fit and proper’ to operate an education and care service.
So, how do you avoid CCS provider refusal?
First things first – start your business plan immediately. The moment you submit your application to become an approved provider is the best time to commence a business plan because it is a living document that is not written in one night, but evolves over time.
(The CCS Application Head Start Package might be helpful for you. Check it out here)
Business planning to avoid CCS provider refusal
Let’s be very clear, you are submitting an application to be approved to administer CCS to families and asking the Federal Government to give you access to millions of dollars of taxpayers’ money.
So, when your time comes to submit your application, the last thing you want is to hear is that you are not ‘fit and proper’ to administer the Child Care Subsidy. If you receive a CCS application refusal notification then have to wait 18 months before re-applying, and if you want to operate without CCS, you have to charge full fees to families, which is almost impossible.
The Department of Education, Skills and Employment have a job to do which is to protect taxpayers money, and just because YOU know you can do it, doesn’t mean THEY do – so that’s why your business planning is the key to avoiding CCS provider refusal.
As it is taxpayers’ money you will be administering, you are obligated to have measures, systems and processes in place to protect it.
The JPS CCS Application Head Start Package is designed especially for the the CCS application process but still requires work from you. Without knowing your particular service, including what exactly you are offering as part of your fees, what hours you will be operating, and how you will establish your reporting and responsibilities. I can only guide you to make your own business decisions to include in the plan to avoid CCS provider refusal.
It’s perfectly reasonable to use templates for business planning, policies, etc. but if do not personalise the template, the regulatory authority will recognise that you have not customised to your service and will refuse the application.
A business plan is the most valuable resource in the entire process of becoming an approved service provider. The CCS Strategic Business Plan (which is included in the JPS CCS Application Head Start Package) will guide you through:
– establishing your fees
– undertaking the market research to prove there is a need for more child care places where you intend to operate
– develop your 12 month cash flow protections to prove you will be a viable business
– delegate responsibilities to any staff you plan on employing including service coordinator, accounts manager etc.
– how you will market and advertise your service to attract enrolments and educators
It lays out everything you need to prove you are capable, and that you have thought through how your service will operate. It includes guidance around managing risks and taking advantage of opportunities a new service may face.
A family day care service approved for 15 educators has the capacity to provide care for 105 children and, including part time care arrangements, could see you responsible for hundreds of parent accounts. We are all too aware of the risks of fraudulent practices in family day care – how will you mitigate the risk of fraud in your business? This is something you must be able to demonstrate in your business plan and policies to be approved.
In summary, the best advice I can give you is to start your business plan before you even submit your first application. If you have already submitted your first application, then commence your business planning immediately or risk not being granted approval.
The last few years has seen the application process become more stringent than in previous times with many applicants not being granted, so why would you even risk not doing all you can to get it right the first time?
Check out the CCS Head Start Application Package here.
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