Child Care Subsidy (CCS) Governance Policy
POLICY CONTENT
To comply with legislation when either applying or maintaining the Child Care Subsidy (CCS) a CCS Governance Policy is required. Our policy covers: evidence ensuring ongoing compliance with Education and Care National Law and Regulations, Family Assistance Law, Australian Taxation laws, Australian Securities and Investment Commission (ASIC) and the Australian Government’s guidelines provided in the Child Care Provider Handbook (2019). Our financial integrity is transparent as we provide information about our organisation size and structure, decision making processes, employment procedures, fit and proper checks operational structure, financial viability and risk management.
NATIONAL QUALITY STANDARD (NQS)
| QUALITY AREA 7: Governance and Leadership |
|---|
| 7.1 | Governance | Governance supports the operation of a quality school |
| 7.1.2 | Management Systems | Systems are in place to manage risk and enable the effective management and operation of a quality school |
| 7.1.3 | Roles and responsibilities | Roles and responsibilities are clearly defined, and understood, and support effective decision making and operation of the school. |
RELATED LEGISLATION
| Child Care Subsidy Secretary’s Rules 2017 | Family Law Act 1975 |
| A New Tax System (Family Assistance) Act 1999 | Family Assistance Law – Incorporating all related legislation for Child Care Provider Handbook in Appendix G dese.gov.au/resources-child-care-provider... |
PURPOSE
Our School aims to comply with the Child Care Subsidy legislative requirements associated with operating a fee reduction service for eligible families. We understand the Department of Education, Skills and Employment (the department’s) approach to maintaining the financial integrity of all child care funding. Our School has a genuine commitment to meet our obligations to maintain financial integrity and have effective compliance systems in place to ensure child care funding we receive is administered appropriately. Our School accepts the legal responsibilities associated with claiming Child Care Subsidy within the Family Assistance Law. We will continuously examine our business and service model to identify opportunities to cater to the needs of our families and community. (Child Care Financial Integrity Strategy, 2019).
SCOPE
This policy applies to families, staff, educators, approved provider, management and visitors of the School.
APPROVED PROVIDER DETAILS
To claim Child Care Subsidy to pass onto families as a fee reduction, our School must be approved by a delegate of the Secretary of the Department of Education, Skills and Employment by showing the required evidence and information to ensure ongoing compliance with the Family Assistance Law. Our School will ensure all reporting requirements for claiming and administering CCS payments will be maintained. These include the requirement for the provider to undertake fit and proper checks on all relevant key personnel and ensuring background checks have been undertaken for relevant key personnel.
Required information includes:
| Provider Approval Number | |
| School Approval Number | |
| Business Name | |
| Trading Name | |
| Contact Person | |
| Telephone | |
| Mobile | |
| Address | |
| NQA IT System details | Are you registered? YES ☐ NO ☐ |
| Provider Entity Name | |
| ABN | |
| Relevant Entity Documents (Financial Statements, signed partnership agreement etc) provided | YES ☐ NO ☐ |
| Financial Management Checks | Submit an extract from the National Personal Insolvency Index Bankruptcy search, include a Nil Result (dates no more than three (3) months prior to the application Current and historical personal name extract search of the Australian Securities and Investment Commission (ASIC) dated no more than three (3) months before the date of the application. Evidence that the person does not appear on the banned and disqualified register of ASIC |
| Details in which the provider or their personnel have an interest | |
| External Management Organisation | Is your School under the management of an external group? YES ☐ NO ☐ |
| Number of years of operation |
[The approved Service can only be operated by the Approved Provider and must continue to be delivered as the same type of service that was approved. If the Service is sold to another provider, that provider will need to obtain its own separate approval and continue to comply with any conditions of their approval.]
OUR SCHOOL AND BUSINESS STRUCTURE
The following information describes the type and size of our childcare school operation, including personnel, recruitment and professional development strategies, fee structure, philosophy and financial position.
| Entity Type (Partnership, Private Company, Sole Trader, Public Company etc) | |
| Information provided with application for provider approval | YES ☐ NO ☐ |
| Number of Managers | Managers may include Director, Nominated Supervisor, appointed Project Manager of multiple services. |
| Number of operation personnel | Educators, administration and trainees |
| Recruitment and Professional Development Plans | Recruitment process and documentation Professional Development |
| Structure of the business | See diagram on next page. |
| Number of sites and locations | |
| Service Type |
OPERATIONAL STRUCTURE
| Address of Service | |
| Days of Operation | |
| Hours of Operation | |
| Weeks of Operation | 50 weeks [Close Dec xx / Jan xx] |
| Fee Schedule | |
| Number of Licensed Children | |
| Services Provided |
|
| Current Employees & Qualification | Name |
| Qualifications | |
| Collection of Fees | Payment types accepted [Credit card, external provider?] Centrelink arrangements [Managed via your CCMS Provider] |
| Liabilities | Do you have any significant liabilities such as loans, hire purchase etc? [Submit the name of the organisations here. Actual amounts may be requested.] |
| Are other services operated by the Approved Provider? | |
| Does the Approved Provider operate other businesses under the legal entity? | Please provide details of other businesses and how they fit into the service (including any RTO organisations the business may be associated with) |
| External Management Organisation | Is Service under the management of an external group? YES ☐ NO ☐ |
| CCS Administration | Identify who will oversee the administration of CCS within the service Identify where administration tasks will be located (if off-site provide details) |
Organisational Structure Diagram [Decision making hierarchy]
Source: CCS Provider Handbook dese.gov.au/resources-child-care-provider...
FINANCIAL OBJECTIVES
Our primary target for 20__ is to increase enrolment placements from xx% to xx% [If your service is full replace this statement with: Our primary objective is to maintain 100% occupancy and consistently review our waitlist management procedures.]
To achieve the above result, we routinely utilise the following promotional strategies:
[Submit a list of routine promotional activities. This may include referral strategies, events, advertising, signage etc.]
To maintain a competitive position within our marketplace fees are reviewed annually and all associated functions are governed by our ‘Payment of Fees Policy’. This includes; management of fee increases, the collection of a Bond, collection of late fees, absences and public holidays.
NON-COMPLIANCE RISK MANAGEMENT
To ensure our continued commercial, operational and financial viability our School will maintain a current Quality Improvement Plan (QIP), Professional Development and Training Plan, Personnel files, Professional Indemnity and Public Liability Insurance and a Child Care Management System. We understand our obligations to comply with requirements for the governance and financial administration of payments of child care funding and continually monitor and evaluate our school’s financial viability.
| TYPE OF RISK | PREVENTION / STRATEGIES IN PLACE | ACTION TO BE TAKEN |
| CCS Compliance | Submit the title of your approved CCS software provider | How do you monitor accuracy and any potential issues/error? |
| Insurances | What insurance policies are established? | Are they automatically renewed? Are they reviewed annually? |
| Service Competition | Insert a statement regarding your ‘self-assessment’ and ‘quality improvement planning’ process. | How do you monitor continuous improvement? Is it a weekly/monthly agenda item? |
| Submission of sessions | This is usually managed via your approved CCS software. Submit a statement to reflect this. | Ongoing |
| Submission of vacancies | This is usually managed via your approved CCS software. Submit a statement to reflect this. | Ongoing |
| Staff Skills and Knowledge | Submit a brief statement describing how you facilitate your Professional Development Plans and associated training | Annually Quarterly Monthly |
| Accurate Data Reports | This is usually managed via your approved CCS software. Submit a statement to reflect this. | Daily Weekly |
NOTE: As with any business changes, you may want to seek further guidance from your financial management team, legal advisor, management committee, board, accountant and/or other financial advisor as to how these changes may specifically affect your Service.
POLICIES, PROCEDURES OR DOCUMENTS TO SUPPORT CCS APPLICATION
| Related Policies, Procedures or Documents | Obligations under CCS |
| FIT AND PROPER CHECKS | |
| CCS Personnel Policy Recruitment Policy Job Descriptions Recruitment Policy CCS Notifications Policy | The CCSPersonnel Policy ensures key personnel who submit data to CCS are registered with PRODA and have relevant Provider and Service background checks, including WWCC and reference checks, determining whether a person is fit and proper as per Family Assistance Law requirements. The CCS Personnel Policy outlines procedures for management to notify DESE and if required the regulatory authority in the event of key personnel not meeting the requirements to remain fit and proper, including the change in status of WWCC. The CCS Notifications Policy outlines guidance for Approved Providers to notify the Department of Education, Skills and Employment in relation to changes relating to personnel. The Recruitment Policy ensures all staff are required to hold a current WWCC before they begin working with children in any capacity. Working in line with the CCS Personnel Policy staff are required to submit any documentation required for background checks related to the position they are applying for. |
| STAFF RECRUITMENT | |
| Recruitment Policy Child Safe Environment Policy | Job Descriptions states educators are required to have up to date knowledge and compliance of the law/ regulations/ acts (including Family Assistance Law for staff who submit data to CCS). The Recruitment Policy outlines that the Approved Provider or assigned nominee will approve all recruitment decisions as outlined in the Recruitment Policy. The Recruitment Policy provides details regarding advertising strategies and opportunities. The policy outlines background checks (WWCC, reference checks, PRODA background checks) required for specific positions. The position outlines induction and probation periods for all employees. |
| ENROLMENT AND ACCS | |
| Enrolment Policy CCS Procedure Guide Job Descriptions | The Enrolment Policy refers to guidelines for CWAs and submission to CCS of enrolment details. Our Enrolment Policy provides guidance for parents and management regarding the requirements for Complying Written Agreements (CWA) which must be signed before a child enters care. The policy outlines details which must be included on the CWA and outlines any conditions when a new CWA is to be signed. The policy states an enrolment notice must be submitted within 7 days of a signed CWA and enrolment acceptance. The Enrolment Policy provides details regarding the ACCS process. It provides guidance to the types of ACCS and how parents/services can apply for ACCS. Additional statements refer to families that must be approved for CCS to be eligible for ACCS and that families who are claiming ACCS are signing a CWA on enrolment. The policy outlines steps for the service to apply for ACCS (Child Wellbeing). The CCS Procedure Guide provides guidance to services regarding the administration of CCS, including information relating to CWA and ACCS. Refer to the Director/ Nominated Supervisor Job Description where the Director/ NS will be responsible for working with families and agencies regarding ACCS eligibility and application requirements. The Service Administration will be responsible for entering ACCS applications into the CCSS software in collaboration with the Director/ NS as per Enrolment Policy and CCS Handbook. |
| INVOICING AND STATEMENTS | |
| CCS Account Policy Payment of Fees Policy | The Payment of Fees Policy outlines procedures regarding invoicing and providing statements to families. A Statement of Entitlement will be provided to families each fortnight as per CCS requirements. The CCS Account Policy provides details regarding when invoices will be issued to families. Invoices and Statements are available to families upon request. |
| THIRD PARTY SOFTWARE SECURITY | |
| CCS Compliance Checklist/ Audit Cyber Safety Policy | The Cyber Safety Policy outlines that the Approved Provider will ensure the CCSS software used at the service has policies and procedures regarding safe storage of sensitive data before using the software, the Approved Provider will review the privacy policy of the CCS software on a yearly basis or as required. The Approved Provider will review any potential threats to software security on a monthly/ yearly basis. The Director/ Nominated Supervisor will advise the Approved Provided as soon as possible regarding any potential threat to security information and access to data sensitive information. Any breaches of data security will be notified to the Office of the Australian Information Commissioner (OAIC) by using the online Notifiable Data Breach Form. The Approved Provider will ensure all Personnel using the software will have their own log in username and password. Personnel are encouraged to change their password for CCS Software every 6 months. Each Personnel who is responsible for submitting attendances and enrolment notices to CCSS will be registered with PRODA as a Person with Management or Control of the Provider or as a Person with Responsibility for the Day-to-Day Operation of the Service. The Approved Provider will review/audit staff log ins on a monthly basis and ensure this procedure is followed by all staff who access CCS software to submit data to CCS. The CCS Compliance Checklist/ Audit will be used each month by the Approved Provider to review usernames and passwords of staff using CCSS Software and to review the privacy policy of individual CCSS Software. The Approved Provider will use the CCS Compliance Checklist/Audit to ensure usernames and passwords used for CCSS Software have not been shared or compromised. The CCS Compliance Checklist/Audit covers details regarding ensuring the data is submitted to CCS accurately and checked against service records. Data submitted to CCS: Enrolments, Attendances, CCS Payments, Personnel and Record Keeping is cross referenced from CCS Software to service records; Enrolment forms, Sign In/out Sheets, Personnel records, Proda records. For example: The attendance sign in/out record is cross referenced against attendance reports recording attendances submitted through the CCS Software, the cross referencing is recorded on the CCS Compliance Checklist/Audit each month by the Approved Provider. |
| DATA INTEGRITY | |
| Fraud Prevention Policy Fraud Corruption Prevention andProcedure CCS Compliance Checklist/ Audit Cyber Safety Policy Cyber Safety Procedure | The CCS Compliance Checklist/ Audit is used each month to identify any data anomalies within incorrect data submissions are picked up in a timely manner. This checklist is used as a tool to facilitate fraud prevention and ensures data integrity within our Service in relation to correct data entry for enrolments, attendances, CCS payments, personnel, and record keeping. The Fraud Prevention Policy and Fraud Corruption Prevention Procedure outlines that CCS Software will be monitored by the Approved Provider to ensure data integrity and security is maintained by all staff who process CCS payments to families. Attendances are cross referenced against child booking reports to ensure sessions are correct when submitted to CCS. Sessions which require resubmission are resubmitting to CCS within 14 days. CCS payments are checked by the financial officer each month and any anomalies are discussed with the Approved Provider and Director/ Nominated Supervisor. CCS Payment reports and invoices are electronically stored each week for future cross referencing and checking. |
| FRAUD PREVENTION AND DETECTION | |
| Fraud Prevention Policy Fraud Corruption Prevention and Detection Procedure Code of Conduct Policy Termination of Employment Procedure | The Fraud Prevention Policy and Fraud Corruption Procedure outlines fraud prevention and detection in relation to CCS data, internal controls to prevent fraud and reporting of fraudulent activity and/or corruption. Including details of the Child Care Tip Off Line. The policy outlines that an internal audit regarding CCS payments will be completed by the Approved Provider/ Finance Officer each month to ensure payments received by the Australian Government recorded in the service bank account reconciles with the payments recorded in the CCS Software system The Code of Conduct Policy and Termination of Employment Procedure provides actions to follow regarding termination of employment following a breach of conduct. |
| RECORD-KEEPING | |
| Record Keeping and Retention Policy Payment of Fees policy | The Record Keeping and Retention Policy refers to how records are maintained and managed in a private and confidential manner, in accordance with legislative requirements including the Family Assistance Law. Records relating to CCS are kept for a period of 7 years as per CCS Handbook. The Payment of Fees policy outlines procedures for staff to follow in regard to supplying parents with invoices and Statement of Entitlements, invoices are issued weekly in arrears (adjust as required) and Statement of Entitlements are issued to families fortnightly. |
| NOTIFICATIONS | |
| CCS Notifications Policy | The CCS Notifications policy has been developed to ensure all notifiable circumstances and situations pertaining to the administration of Child Care Subsidy are reported in accordance with relevant legislation. The CCS Notifications Policy has been developed from the guidelines within the Child Care Subsidy Provider Handbook. |
| FEES AND DEBT RECOVERY | |
| Payment of Fees Policy Overdue Fee Payment Procedure | The Payment of Fees Policy outlines that our fees have been developed in line with our business plan. Our Payment of Fees Policy provides families with a clear understanding of the service fee structure, payment requirements and CCS benefits prior to enrolment. This policy provides guidance to families for fees that are payable when children attend, such as pupil free days, sick days, family holidays, public holidays and service closure periods. Our Overdue Fee Payment Procedure outlines processes for staff and families regarding late payments of fees. |
| COMPLAINTS-HANDLING | |
| Fraud Prevention Policy Fraud Prevention and Detection Procedure Payment of Fees Policy Dealing with Complaints Policy Dealing with Complaints Procedure | The Dealing with Complaints Policy and Payment of Fees Policy provide procedures for families to follow regarding complaints and disputes relating to fees, invoices, CCS payments, statement of entitlements and other CCS related issues. Families who have a complaint regarding CCS payments can refer to the CCS tipoff line, details are provided in the Dealing with Complaints Policy, Fraud Prevention Policy and Payment of Fees Policy. |
SOURCE
Australian Government Department of Education, Skills and Employment. Applying for Child Care Subsidy (CCS) Approvaldese.gov.au/child-care-subsidy/applying-c...Australian Government Department of Education, Skills and Employment. Child Care Package (2021)
dese.gov.au/child-care-package
Australian Government Department of Education, Skills and Employment. Child Care Provider Handbook (2018)
dese.gov.au/resources-child-care-provider...
Australian Government Department of Education, Skills and Employment. Guide to Additional Child Care Subsidy (child wellbeing) (2019)
dese.gov.au/additional-child-care-subsidy...
Australian Government Department of Education, Skills and Training. Business support tools and resources for child care services
dese.gov.au/business-support-tools-and-re...
Australian Government Department of Education, Skills and Employment. Child Care Financial Integrity Strategy, 2019
dese.gov.au/financial-integrity/resources...
Australian Government Department of Education, Skills and Employment. Mandatory Documents for Care Subsidy Approval Applications August2019
dese.gov.au/child-care-package/resources/...
Australian Government Department of Education, Skills and Employment. Child Care Subsidy (CCS) Specified Personnel Roles (2020)
dese.gov.au/child-care-package/resources/...
Australian Government Department of Education and Training (2017) Child Care Services Business Support Resource – A guide for considering your businessdese.gov.au/key-official-documents-about-...