Early Learning Coalition

Minutes: Date/Time: Location: Members Present: Excused Absent members: Unexcused Absent Members: Staff Present: Guest/Public: Called to order: Early Learning Coalition of Brevard County, Inc. Board of Directors Meeting Tuesday, May 19, 2015 at 4:00 p.m. Early Learning Coalition of Brevard, Conference Room 1018 Florida Ave, Rockledge, FL Donna Beettam, Alan Bergman, Mark Broms, Priscilla DeNino, Stephanie Bryant in attendance for Ian Golden, Robert Green, Jeffery Harrison, Natalie Jackson, Tom Peer, Myrna Shimei and Travia Williams Terri Barlow, Cathy Beam, Marci Brilley, Lori Duester, Mike Durante, Mica Layne, Beth Mills and Althea Puzio Sky Beard, Jessica Beecham, Gwen Hertlein-Haber, Cathie Odom, Emily Orndorff and Tina Snyder Alan Bergman called the meeting to order at 4:06 p.m. Pledge of allegiance took place and introductions were conducted. Quorum was not established. Agenda Item Summary/Discussion Action/Follow-up Consent Items a. Minutes: April 21, 2015 The Consent Items approval vote b. Directors Report will be via email, because quorum Committee Reports: Executive/Finance Committee: Alan Bergman requested that Sky Beard provide the report to the Board. Sky Beard reported to the Board that the Executive/Finance Committee meeting was held on May 18, 2015. The following agenda items were discussed: Approval of April 13, 2015 Minutes Seacoast Bank Presentation: Bank representatives came and discussed different account types for the Coalition Child Care Provider Fraud Case: No update available Legislative Update: To be discussed later in meeting Preliminary Budget: Will bring final budget to Board for approval in June OEL Reob Request: Alan signed the letter that will be mailed to OEL requesting additional funds Fiscal Reporting Draft: Sky informed the Board that currently Coalition staff and the Committee are working on revising the fiscal reporting that is brought to the Board. Provider Representative Seat Term Clarification: The Coalition is currently waiting on OEL to clarify information regarding the term length for the Provider Representative seats. was not established. No Action/Follow-up Required Old Business Finance Report and Waiting List/New Enrollment Update: Cathie Odom reviewed with the Board the Utilization Reports and Graphs (see attached). Cathie reported to the Board that for the month of April there was a surplus; however, there is still a projected annual deficit. The Coalition has submitted a reob letter requesting funds to cover the projected deficit. There was discussion regarding the increase in DCF referrals No Action/Follow-up Page 1 of 3 May 2015 Minutes

New Business and how the Coalition is preparing to handle this increase next fiscal year. Sky explained that during the June meeting there would be discussion regarding the changes that are to come to early learning programs at the Federal level. Gwen Hertlein-Haber informed the Board that there are currently 1,308 children on the waitlist and about 75% of the children are birth to five-years-old. The Coalition staff is currently calling off families from August 2014. Legislative and Budget Update: Sky discussed the turn of events at the end of the Legislative session. Early learning bills did not pass and a state budget was not finalzed. The Governor has scheduled a special session for June 1-20, 2015 to pass a budget by June 30, 2015. Once the state budget is passed, the Coalitions must still wait until OEL allocates the funds statewide. Anti-Fraud Plan Approval: The Anti-Fraud Plan was emailed to the Board previously to review. Gwen explained to the Board that the major change is the simplicity of the plan. Revisions were made to the act of abuse or overpayment matrix (see attached). However, because quorum was not established, the vote to approve the plan will be done via email. Mark Broms asked if there was a count of how many fraud cases have been managed with the Anti-Fraud Plan. Coalition staff informed the Board that there are currently two different spreadsheets that contain many cases. Robert Green asked if there was fraud protection for the child care providers. Coalition staff informed the Board that provider fraud is addressed in child care provider contracts and it is not addressed in the Anti-Fraud Plan. The Anti-Fraud Plan approval vote will be via email, because quorum was not established. Key Result Area Committee Meetings: Sky informed the Board that due to several Board members being absent, several of the committees may wish to not meet until the next scheduled meeting or members may attend another committee meeting: Diversified Funding Committee: Did not meet Parent Education and Family Engagement: Did not meet Improve Technology: Did meet Quality Initiatives: Did meet Tapping into Board Talent: Did meet o Robert Green will be the new Champion Public N/A Comment Adjournment The meeting was adjourned once all Committees adjourned. Next Meeting June 16, 2015 No Action/Follow up Page 2 of 3 May 2015 Minutes

May 2015 Board of Directors Minutes Approved: Respectfully Submitted, Approved Signature Date Signature Date Executive Coordinator Executive Director Page 3 of 3 May 2015 Minutes

Board of Directors Meeting Tuesday, May 19, 2015 4:00 pm I. Call to Order AGENDA II. III. IV. V. VI. VII. VIII. IX. Pledge of Allegiance Coalition Roll Call by Self Introduction Consent Items a. Minutes: April 21, 2015 b. Director s Report Committee Reports a. Executive / Finance Committee Old Business a. Finance Report and Waiting List/New Enrollment Update b. Legislative and Budget Update New Business a. Anti-Fraud Plan Approval b. Key Result Area Committee Meetings Public Comment Adjourn Next Meeting: June 16, 2015

MINUIES: ÞATEJTIfiIE: LO(ATION: I,IEfiIBER5 PRESENT: Ð((USEÞ ABSENT IIIEI{BERS: TINÐ((TEEÞ ABSENT MEJVIBERS: STAFF PRESENT: GIJEST/PIIBU(: (ATIED TO ORDER: EARLY LEARNING (OALITION OF BRÉVARD (OUNTY, IN(. Board of Directors Meeting Tuesday, April 2L, 2015 at 4:00 p.m. Early Learning Coalition of Brevard, Conference Room L0L8 Florida Ave, Rockledge, FL Terri Barlow, Cathy Beam, Alan Bergman, Marci Brilley, Mark Broms, Priscilla DeNino, Mike Durante, lan Golden, Robert Green, Nancy Grzesik, Jeffery Harrison, Natalie Jackson, Beth Mills and Althea Puzio Donna Beettam, Lori Duester, Mica Layne, Myrna Shimei and Travia Williams Tom Peer Shamprell Baumgardner, Sky Beard, Jessica Beecham, Michelle Dockery, Sue Falcioni, Gwen Hertlein-Haber, LaShaundra McGhee, Selena McNeely, Cathie Odom, Emily Orndortf, Jennifer Shields and Tina Snyder Staff from Brevard Public School's Florida First Start Program Alan Bergman called the meeting to order at 4:O4 p.m. Pledge of allegiance took place and introductions were conducted. Quorum was established. A(ptDt ftet SrJttÂRY/Dts(rrSStOr t noil/frclril{p Consent ltems a. Minutes: March 1-8,2015 b. Directors Report Committee Reports: Executive/Finance Committee: Alan Bergman reported to the Board that the Executive/Finance Committee meeting was held on April 13, 2015. The following agenda items were discussed: Fiscal Reporting Options to Board - Cathie presented a few different ways that fiscal reporting is done at other Coalitions. Likes and dislikes were discussed. The committee provided recommendations and Cathie is working on slightly revising the report based on those recommendations.. Legislative Update - Sky provided an update regarding the status of the state budget and early learning bills. o Final Board Composition Rule - Sky provided a copy of the final Board Composition Rule to the committee for discussion. There are some additional conversations to occur with certain board members so that we can clarify their role on the board based on the statute and rule. Sky will follow up with board members individually if necessary.. Board Meeting Agenda - Discussed the format for today's meeting.. SchedulinB of May Executive/Finance Committee Meeting - Rescheduled for Monday, May 18,2075 Nancy Grzesik motioned for the Consent ltems to be approved. Robert Green seconded the mot on. The motion passed unanimously by allboard members. No Action/Follow-up Required Page 1 of 2 April 2015 M nutes

Old Business New Business Public Comment Kev Result Area Committees: lt Comm ttee: Reported that at the last meeting, there was discussion regarding ELC, EFS, housekeeping and the phone system update is currently on hold. Diversified Funding Committee: Mike Durante reported that the Committee is currently finding new alternative forms for fundraising. Finance Reoort and Waiting List/New Enrollment Update: Cathie Odom reviewed with the Board the Utilization Reports and Graphs (see attached). Cathie reported to the Board that there is a projected SggO,Ooo deficit. The Coalition is asking OEL for additional funds to cover the deficit. There are currently L200 children on the waitlist. Provider Termination Update: Sky Beard reported to the Board that the child care provider discussed previously will have their contracts terminated 30 days after the date of the letter served by the Coalition's attorney. At the end of the 30 days, the provider will no longer be able to serve SR children and families were notified. Presentation - Florida First Start Program: The staff from Florida First Start presented an overview of their program to the Board (see attached). Barnes and Noble - Terrific Teacher Event Mav 30th 10:00 am - 2:00pm: Sky informed the Board of the event that will be on May 3Oth. N/A No Action/Follow-up Adjournment The meeting was adjourned at 5:10 p.m Robert Green motioned for the adjournment of the Board meeting. Nancy Grzesik seconded the motion. The motion passed unanimouslv by all Board members. Next Meeting May L9, 2015 No Action/Follow up April 2015 Board of Directors Minutes Approved: ly Submitted Approved Executive Coordinator Date Signature Executive Director Date Page 2 oî 2 April 2015 Minutes

Director s Report May 2015 State and Office of Early Learning (OEL) Update: Sky Beard attended the Association of Early Learning Coalition s Annual Meeting on May 12 15, 2015 in Bradenton. The meeting offered a guest speaker related to raising match dollars and provided opportunities for sharing of best practices and problem solving amongst the Executive Directors of Early Learning Coalitions. Coalition Update: The Coalition is still communicating with the State Attorney s office related to options for settling the pending child care provider fraud case. Sky Beard communicated the latest information with the Office of Early Learning and they provided guidance related to the case. This information was then shared with the State Attorney s office and the ELC Executive/Finance Committee. The Coalition hosted a Brunch and Learn on Saturday, May 9 in honor of National Provider Appreciation Day. The event provided an opportunity for providers to receive professional development while at the same time be honored by the ELC for the work that they do each day to educate young children. ELC is partnering with Barnes and Noble in West Melbourne for an early childhood book fair and Terrific Teacher award ceremony. On Saturday, May 30, Coalition staff will be present in the store to provide activities for children and offer information about Child Care Resource and Referral. In addition, the Coalition will also be celebrating three teachers with Terrific Teacher Awards as nominated by the children they serve, parents or their coworkers. A percentage of purchases made at Barnes and Noble in the store on the day of the event will go to ELC as well online sales through June 5 (mention of ELC or code on voucher to be provided). The Coalition was recently awarded a $1,000 community grant from The Darden Foundation. Thanks to the support of the LongHorn Steakhouse in Viera, the Coalition was recognized as a recipient of their community giving. ELC is serving an increasing number of children living in foster homes, placed with relative caregivers and residing in homeless and domestic violence shelters. The awarded funds will allow the Coalition to purchase age appropriate books for children that will be focused on the emotions that they feel, dealing with trauma and change as well as easing the transition to a new family or home. Sky Beard continues to participate as a member of the Help Me Grow Planning Committee. The committee is discussing options for expanded developmental screening and case management services in Brevard County if additional dollars were to come available for Help Me Grow expansion sites. The ELC will play an important role in this expansion if dollars become available.

ELCB FY 13.14 Grant Allocation - Direct Service Utilization Report Subsidized Child Care Billing Period Children SERVED (unduplicated) Per child Cost 97CF0 97R00 97GTA 97GNW 97G00 97P00 97GSD 97RSP Total Direct Service Expenditures Monthly Direct Service Allocation Match required** Match obtained July-14 3,703 $ 385.11 $ 268,161 $ 131,286 $ 73,135 $ 803,186 $ 150,281 $ 1,426,050 $ 1,280,371 $ 48,191 $ 30,763 August-14 3,755 $ 325.87 $ 233,748 $ 110,124 $ 67,792 $ 686,666 $ 125,311 $ 1,223,640 $ 1,072,116 $ 41,200 $ 34,366 September-14 3,577 $ 329.05 $ 225,158 $ 101,884 $ 67,577 $ 667,871 $ 114,536 $ 1,177,026 $ 1,014,804 $ 40,072 $ 25,806 October-14 3,614 $ 342.55 $ 244,965 $ 109,366 $ 67,523 $ 690,961 $ 125,177 $ 1,237,992 $ 1,134,767 $ 41,458 $ 61,089 November-14 3,665 $ 310.73 $ 237,535 $ 92,850 $ 69,427 $ 625,048 $ 113,954 $ 1,138,815 $ 1,044,964 $ 37,503 $ 28,884 December-14 3,723 $ 351.16 $ 268,841 $ 105,492 $ 73,342 $ 725,737 $ 133,964 $ 1,307,376 $ 1,169,495 $ 43,544 $ 29,198 January-15 3,670 $ 331.24 $ 252,565 $ 88,325 $ 70,235 $ 678,559 $ 125,956 $ 1,215,640 $ 1,145,666 $ 40,714 $ 58,526 February-15 3,617 $ 304.93 $ 244,032 $ 84,959 $ 60,605 $ 599,600 $ 113,754 $ 1,102,950 $ 1,154,698 $ 35,976 $ 41,517 March-15 3,608 $ 332.98 $ 273,699 $ 94,349 $ 61,949 $ 648,338 $ 123,070 $ 1,201,404 $ 1,133,665 $ 38,900 $ 36,837 April-15 3,513 $ 337.45 $ 284,964 $ 103,025 $ 56,439 $ 618,619 $ 122,408 $ 1,185,456 $ 1,221,947 $ 37,117 $ 38,046 May-15 $ - $ - June-15 $ - $ - Final Invoice $ - $ - TOTALS 3,645 $ 335.11 $ - $ 2,533,668 $ - $ 1,021,660 $ 668,024 $ 6,744,585 $ 1,248,411 $ - $ 12,216,349 $ 11,372,492 $ 404,675 $ 385,032 Remaining Match Required $ 19,643 *Match required does not have to be obtained monthly, overall total must be obtained by end of fiscal year and may include in-kind. OCA 97CF0 97R00 97GTA 97GNW 97G00 97P00 97PP0 97GSD 97RSP Billing Group SPECIAL NEEDS (Priority 8) BG1 - AT RISK (Protective Services / DCF referrals: Priority 2 - Birth to 9; Priority 5 - ages 9 to younger than 13) BG3AP - TCA APPLICANT (Temporary Cash Assistance: Priority 3 - Birth to K eligible; Priority 7 - K eligible to younger than 13) BG3 - TCA NON-WORKING (Temporary Cash Assistance - Priority 1 - Birth to younger than 13); BG3R - RELATIVE CAREGIVER - At Risk ( Priority 2 - Birth to 9; Priority 5 - ages 9 to younger than 13); BG3W - TANF ONLY (Temporary Assistnace Needy Families - Priority 3: Birth to K eligible - Priority 6: K BG3W - TCA WORKING (Temporary Cash Assistance - Priority 1 - Birth to younger than 13); BG5 - TCC (Transitional Child Care - Priority 4: Birth to K eligible - Priority 7: K eligible to yo BG8 - ECONOMICALLY DISADVANTAGED (Priority 3 - Birth to K eligible; Priority 7 - K eligible to younger than 13) CCEP - Child Care Executive Partnership (Not Prioritized) GOLD SEAL DIFFERENTIAL - all priorities & ages (provider qualified) WRC - TCA RESPITE (Temporary Cash Assistance - Priority 1 - Birth to younger than 13) Child Care Executive Partnership Program Billing Period Children SERVED Per child Cost 97PP0 Monthly Direct Service Allocation Year to Date Actual July-13 $ - $ - YTD Spending Rate (overall) 89.42% Expected YTD Spending Rate 83.24% August-13 YTD Surplus / Deficit (overall) ($843,856.40) September-13 October-13 CCEP YTD Spending Rate (overall) 0.00% Expected YTD Spending Rate 0.00% November-13 YTD Surplus / Deficit (overall) $0.00 0 December-13 January-14 February-14 March-14 April-14 May-14 June-14 Final Invoice TOTALS #DIV/0! #DIV/0! $ - $ -

ELCB FY 13.14 Grant Allocation - Direct Service Utilization Report Month Target Enrollment # of Children Served Avg Daily Rate / Child # of Days School Age Notes Overall Expected Child Care Overall Actual Child Care Monthly Spending Surplus / Deficit YTD Expected YTD Actual 7/31/2014 3650 3703 $16.74 23 FT (23 days) $ 1,280,371 $ 1,426,050 111.38% $ (145,679) $ 1,280,371 $ 1,426,050 8/31/2014 3650 3755 $14.81 22 FT (10 days) $ 1,072,116 $ 1,223,640 114.13% $ (151,524) $ 2,352,486 $ 2,649,690 9/30/2014 3650 3577 $15.67 21 FT (2 days) $ 1,014,804 $ 1,177,026 115.99% $ (162,222) $ 3,367,291 $ 3,826,716 10/31/2014 3650 3614 $14.89 23 FT (1 day) $ 1,134,767 $ 1,237,992 109.10% $ (103,226) $ 4,502,057 $ 5,064,708 11/30/2014 3650 3665 $14.80 21 FT (4 days) $ 1,044,964 $ 1,138,815 108.98% $ (93,850) $ 5,547,021 $ 6,203,523 12/31/2014 3665 3723 $15.27 23 FT (7 days) $ 1,169,495 $ 1,307,376 111.79% $ (137,881) $ 6,716,516 $ 7,510,899 1/31/2015 3650 3670 $14.40 23 FT (5 days) $ 1,145,666 $ 1,215,640 106.11% $ (69,974) $ 7,862,182 $ 8,726,539 2/28/2015 3650 3617 $14.52 21 FT (1 day) $ 1,154,698 $ 1,102,950 95.52% $ 51,749 $ 9,016,880 $ 9,829,488 3/31/2015 3650 3608 $15.86 21 FT (5 days) $ 1,133,665 $ 1,201,404 105.98% $ (67,739) $ 10,150,545 $ 11,030,893 4/30/2015 3550 3513 $15.34 22 FT (1 day) $ 1,221,947 $ 1,185,456 97.01% $ 36,491 $ 11,372,492 $ 12,216,349 5/31/2015 3450 $15.34 22 FT (2 days) $ 1,177,771 $ - $ 12,550,264 6/30/2015 3400 $15.34 21 FT (21 days) $ 1,112,038 $ - $ 13,662,302 Final Invoice YTD Totals 3645 $15.25 263 $ 13,662,302 $ 12,216,349 107.60% $ (843,856)

Early Learning Coalition of Brevard County Inc. Year to Date Comparison April 2015 Slot Utilization FY 14.15 to FY 13.14 $14,000,000 $12,000,000 $10,000,000 $8,000,000 $6,000,000 $4,000,000 $2,000,000 $- Budgeted Year to Date (YTD) Actual YTD Percent Actual vs. Budget YTD FY 14.15 $11,406,913 $12,216,349 107% FY 13.14 $10,402,900 $9,998,647 96% FY 14.15 to FY 13.14 Comparison Surplus/Deficit $150,000.00 Surplus $100,000.00 $50,000.00 $0.00 July September November January March May ($50,000.00) ($100,000.00) ($150,000.00) ($200,000.00) FY 14.15 FY 13.14

Early Learning Coalition of Brevard County Inc. Year to Date Comparison April 2015 School Readiness Match Actual to Forecast & Comparison to FY 13.14 $500,000 $450,000 $400,000 $350,000 $300,000 $250,000 $200,000 $150,000 $100,000 $50,000 $0 FrcstThs Yr Actual 14.15 Actual 13.14 Enrollment FY 14.15 Compared to FY 13.14 (Month of April) 3540 3520 3500 3480 3460 3440 3420 3400 3380 3360 3340 3320 3,513 3,389 FY 14.15 FY 13.14 Comparison: Prior to Current Month Enrollment 3,513 3,608 April March

5/19/2015 ELC board of directors meeting May 19, 2015 Anti-Fraud Plan 6M-9.400 - the anti-fraud plan must be board approved prior to submitting to OEL no later than June 30 of each year. Three tiered structure remains with a program violation, level of offense, occurrence and corresponding penalty. Level and penalty structure compressed in the FY15-16 plan and sanctions adjusted or removed. Act of Abuse or Overpayment Matrix Changes Offense FY 14-15 Plan Proposed FY 15-16 Plan Unintentional act resulting in an overpayment Four levels with multiple occurrences and penalties Two levels less than or equal to $700 and greater than $700. Penalty written notice; remain in service with a repayment plan in good standing; terminate if decline repayment and may not reapply to waitlist until paid in full. Intentional act resulting in an overpayment Two levels with multiple occurrences and penalties Three levels - less than or equal to $700, greater than $700 without a false application and greater than $2,000 with a false application. Penalty terminate and reapply to waitlist; terminate and recover improper payments through a repayment plan; terminate and submit to Dept of Financial Services (DFS). 1

Anti-Fraud Plan The Early Learning Coalition of Brevard (ELC) has adopted an anti-fraud plan with a three tiered offense approach. The three tiers are: 1. Intentional Act of Abuse Prior to Receiving Services 2. Unintentional Act of Abuse Resulting in an Overpayment 3. Intentional Act of Abuse Resulting in an Overpayment Each area has a type of violation, level of offense, occurrence and a corresponding penalty as noted in Exhibit I. In addition, Act of Abuse as defined in this matrix is to use wrongly or improperly; misuse. When an ELC employee (as designated in Exhibit II) becomes aware of instances of actual, potential or suspected fraud and abuse by a recipient of School Readiness (SR) or Voluntary Prekindergarten (VPK) Education Program benefits, they are mandated to investigate the act in accordance with the Suspected Fraud in the Early Learning Programs procedure (Exhibit III). In addition, repayment agreements, if necessary, will be made in accordance with the Suspected Fraud and Repayment Agreement Reporting procedure (Exhibit IV) and ELCB-FM-0002-09 Improper Payments policy (Exhibit V). Furthermore, staff follows procedures to ensure verification of child care referrals from other organizations (Exhibit VI) and services must be provided and not terminated under a valid referral regardless of prior or suspected fraudulent activities. The ELC does not have a fraud hotline; however public assistance fraud flyers (Exhibit VII) are posted in meeting spaces, anonymous telephone calls are accepted and researched and potential fraud penalties are discussed with recipients when their rights and responsibilities are explained. Designated ELC employees are trained at a minimum annually in client fraud prevention practices to recognize red flags such as questionable documentation, inconsistent paperwork or statements, quality interviewing and data quality report irregularities. Furthermore, the Coalition completes an annual self-assessment using OEL s Internal Control Questionnaire. Policies and procedures are also reviewed on an annual basis to ensure compliance with statute, rule and other guidance. If a recipient of SR or VPK benefits is found to be in violation of program guidelines they are informed of their termination of benefits via a Notice to Discontinue Services (Exhibit VIII). The notice includes a statement of how the recipient may obtain a copy of their file for review and will be translated into the recipient s native language if prior Coalition communications were translated. A copy of the Confidential Information Record Request Form and corresponding External Records Requests Policy is documented in Exhibit VIII-A. If a waitlist applicant is found in violation of submitting fraudulent forms prior to receiving services they will receive a Notice of Ineligibility (Exhibit IX) and may reapply to the waitlist when eligible. If the recipient or applicant is able to provide necessary documentation to resolve the issue, an appeal is not involved and services will be reinstated or the applicant will be added to the wait list. If the recipient is unable to resolve the issue through this pre-appeal process and believes the conclusion of

fraud was made in error, then he or she may file a formal written appeal for review by the executive director (ED) or the Coalition board of directors designated executive staff person (ESP). A summary of the formal written appeal process is listed below and detailed information is documented in Exhibit X and XI. Written Appeals Summary 1. A written appeal must be submitted to the ED or ESP. The appeal must fully describe the nature of the error the recipient believes has been made with supporting documentation. 2. The appeal shall be postmarked, faxed, emailed or hand delivered before the date of the discontinuation/suspension of services. Failure to file a timely appeal waives the right of appeal. 3. If a timely appeal is filed, the recipient will not be suspended or terminated from the program until the written decision of the ED or ESP or the original date of the discontinuation/suspension of services, whichever is later. 4. The ED or ESP must respond to the recipient in writing within thirty (30) days of receiving the appeal with a decision as to whether the suspension or termination will be upheld or modified. 5. The recipient who wishes to appeal the decision of the ED or ESP may request further review by an appeals committee in accordance with subsection (e) of 6M-9.400. The request must be submitted to the Coalition in writing within ten (10) calendar days of the date of the ED/ESP written response. 6. Steps for review by the appeals committee are listed below: a. The recipient is given the opportunity to present their position during a scheduled appeals committee meeting. The recipient is informed this is a public meeting and any information presented may be used by other state agencies. b. The appeals committee is selected by the Chairman of the Board and a chair named. c. The appeals committee will meet within forty-five (45) calendar days of receipt of the recipients appeal. d. The recipient has up to thirty (30) minutes to present their appeal and any information they wish the committee to consider. e. Coalition staff excluding the ED or ESP (whichever made the initial decision) shall be available to provide any information requested by the committee. f. The appeals committee will consider all statements, review all documents and may request additional evidence or information if necessary to make a decision. The final determination letter will be suspended for the length of time given to provide the additional information. g. An appeals committee selected staff member, excluding the ED or ESP, will take minutes of the event and final determination of the appeal. h. The appellant will be notified in writing of the final determination within ten (10) days of the appeals committee meeting. i. The appeals committee determination is final.

Exhibit I Act of Abuse or Overpayment Matrix Intentional Act of Abuse prior to receiving services (anti-fraud) Program Violation Level Occurrence Penalty Submitting fraudulent forms during initial application period and/or not meeting Not approved for purpose of care services. Client may when initially reapply to waitlist when determined eligible. N/A Any eligible. Offense Program Violation Level Occurrence Penalty Unintentional Act of Abuse Does not affect eligibility and may affect co-pay. Examples may include but are not limited to: non reporting of survivor benefit, child Less than or Resulting in an support, second job, equal to Written notice sent Overpayment salary increase, etc. $700 First noting offense. Client remains in services with a repayment plan in good standing. Greater than $700 Second or More Any Terminate services if client declines or does not comply with repayment agreement. Client may not reapply to the waitlist until paid in full. Client remains in services with a repayment plan in good standing. Terminate services if client declines or does not comply with repayment agreement. Client may not reapply to the waitlist until paid in full.

Exhibit I Act of Abuse or Overpayment Matrix Offense Program Violation Level Occurrence Penalty Examples: no purpose of care for over 60 days, over Intentional Act of 200% of FPL, Termination with 14 day Abuse Resulting questionable Less than or written notice. in an household equal to Client may reapply to Overpayment composition, etc. $700 First waitlist. Termination with 14 day written notice. Greater than $700 without a false application Greater than $2,000 with a false application Second or More Any Any Recover improper payments through a repayment plan. Termination with 14 day written notice. Recover improper payments through a repayment plan. Termination with 14 day written notice. Case submitted to Dept of Financial Services (DFS). Client may not reapply to the wait list until DFS investigation complete and client in compliance with the order. Notes: First offense penalty applied strictly on dollar amount. Second offense penalties or higher take both dollar amount and number of occurrences into consideration. After a client satisfies a penalty, no special restrictions apply.

Early Learning Coalition of Brevard County, Inc. Organizational Chart Exhibit II Executive Director Executive Coordinator Director of Business Operations Director of Quality Assurance Administrative Coordinator Director of Program Initiatives Administrative Coordinator Director of Information Technology Director of Human Resources Business Coordinator Provider Services Administrator Family Services Administrator South Family Services Administrator North Family Resources Administrator Outsourced Server Maintenance/Backup & Help Desk Human Resources Specialist Facilities Specialist Accounting Specialist Finance Specialist Finance Administrator Contract & Procurement Coordinator Reimbursement Coordinator Senior Reimbursement Specialist Records & Database Management Specialist Records Assistant QA Coordinator Provider Relations Coordinator (2) QA Specialist (3) Eligibility Specialist Melbourne (6) Palm Bay (2) Screening & Assessment Specialist (2) Eligibility Specialist Titusville (1) Rockledge (5) Screening & Assessment Specialist (2) CCR&R Coordinator CCR&R Specialist Melbourne (2) Rockledge (4) Inclusion Coordinator CCR&R Program Support Specialist Melbourne (1) Titusville (1) Rockledge (1) Reimbursement Specialist (2) Primary Anti-Fraud Contact Gwen Hertlein-Haber Director of Program Initiatives ghaber@elcbrevard.org (321) 637-1800 x 2061

Exhibit III Early Learning Coalition of Brevard County, Inc. Procedure Issue Date: 09/13/12 Corresponding Policy: ELCB-FS-0001-12 Subject: Suspected Fraud Originating Department: Family Services Revision Date(s): 10/21/2014, 5/7/2015 Date Approved by Executive Director: November 7, 2012 Subject: Suspected Fraud in the Early Learning Programs References: 45CFR98, Code of Federal Regulations; Chapters 1002.51-79 and 1002.81-97 Florida Statute; Rules 6M-4 and 8, Florida Administrative Code. Corresponding Policy (s): ELCB-FS-0001-12 Definitions: Client shall mean the parent, family member, or guardian that is the recipient of services for their child(ren) enrolled in an Early Learning Program. Early Learning Programs shall mean any program funded with local, state, and/or federal funds administered by the Coalition; the primary programs are School Readiness and Voluntary Prekindergarten. Data quality reports shall mean Office of Early Learning (OEL) reports designed to identify potential errors related to children and providers participating in Early Learning Programs. Suspected fraud and/or misrepresentation shall mean 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. Examples of suspected fraud or misrepresentation 1. Providing false or misleading information or withholding information in order to participate in or receive payments under the Early Learning Programs. 2. Failing to disclose a change in circumstances or material information that could directly impact eligibility decisions. 3. Falsifying records or documents. 4. Assisting or aiding any person in committing any of the above acts. Procedure: ELC staff is trained at a minimum annually on how to detect and prevent fraud, abuse, and overpayment. Fraud is also a standing agenda item for the ELC Board of Directors.

Client fraud prevention techniques include but are not limited to: 1. Review previous interview screens look for inconsistent paperwork or statements regarding household composition, employment, residency, etc. 2. Check employment information paid by personal check or cash. Document name of person verifying information and double check during redetermination periods. 3. Ask additional questions if questionable documentation received. If documentation unclear services are not reauthorized or authorized for three months with follow up. 4. Review rights and responsibilities with the client and stress the importance of reporting changes within 10 days. 5. Research data quality reports every month and train on irregularities. When ELC staff becomes aware of instances of actual, potential or suspected fraud and abuse in the operation of the Early Learning Programs, whether identified internally or reported to us, the following steps shall be taken: 1. Preliminary Investigation: Conduct a preliminary investigation to determine the likelihood a fraudulent act has been committed. Such preliminary investigations may include, but need not be limited to: conducting in person interviews, making telephone calls to related parties, researching Clerk of Courts recent cases, Clerk of Courts official records and Social Network sites, and/or conduct an attendance monitoring. 2. Refer to the Act of Abuse or Overpayment (Chart I) to determine program violation level, occurrence and penalty. 3. Depending on the occurrence per level, the specialist will follow the penalty structure and notify the client accordingly. Notification will vary from a letter noting the offense to immediate termination and submission of a Suspected Fraud Referral Record Form to the Department of Financial Services (DFS). 4. For offenses requiring restitution of overpaid benefits, a repayment agreement will be instituted in accordance with ELCB-FM-0002-09 Improper Payment policy. In the event a referral is received for child care under protective services or TANF the Coalition will contact the referring agency to verify. Services must be provided under a valid referral regardless of prior fraudulent activities. 5. For offenses requiring submission to DFS, the specialist will complete the Suspected Fraud Referral Record Form and submit to the ED or designee within 3-5 business days. A brief written summary of the situation must be documented on the Suspected Fraud Referral form by the individual reporting the case, identifying the details of the applicant/client or providers case. The following must be cited: a) What information the individual provided or failed to provide, which impacts their eligibility for services or reimbursement b) The issues of concern and any available evidence such as a falsified application, attendance record or other documentation. c) The summary should provide factual information, specify dates and address questions of Who, What, When, Where and How. Last Revised 5/7/2015 Page 2 Location on W:\Fraud\Policy & Procedures

d) If incorrect payment has occurred, the extent, duration and amount of the incorrect payment must be clarified. Upon signature of the Suspected Fraud Referral Record Form the information is entered into the Investigation Log by Levels spreadsheet, reviewed by Cathie Odom, Director of Business Operations (321) 637-1800 ext. 2010 then data entered into the OEL Fraud Referral System (FRS) per the OEL FRS guide. In addition, the case will be referred to the Department of Financial Services, Public Assistance Fraud Unit (DFS) for further processing. For offenses that do not rise to the level of submission to DFS, the Coalition institutes a repayment agreement corresponding to the penalty structure in Chart I and in accordance with the Suspected Fraud and Repayment Agreement Reporting procedure and ELCB-FM-0002-09 Improper Payments policy. Intentional Act of Abuse prior to receiving services (anti-fraud) Act of Abuse of Overpayment - Chart I Offense Program Violation Level Occurrence Penalty Submitting fraudulent forms during initial application period and/or not meeting purpose of care when initially determined eligible. N/A Any Not approved for services. Client may reapply to waitlist when eligible. Offense Program Violation Level Occurrence Penalty Unintentional Act of Abuse Does not affect eligibility and may affect co-pay. Examples may include but are not limited to: non reporting of survivor benefit, child Less than or Resulting in an support, second job, equal to Written notice sent Overpayment salary increase, etc. $700 First noting offense. Client remains in services with a repayment plan in good standing. Second or More Last Revised 5/7/2015 Page 3 Location on W:\Fraud\Policy & Procedures Terminate services if client declines or does not comply with repayment agreement. Client may not reapply to the waitlist until paid in full.

Greater than $700 Any Client remains in services with a repayment plan in good standing. Terminate services if client declines or does not comply with repayment agreement. Client may not reapply to the waitlist until paid in full. Offense Program Violation Level Occurrence Penalty Examples: no purpose of care for over 60 days, over Intentional Act of 200% of FPL, Termination with 14 day Abuse Resulting questionable Less than or written notice. in an household equal to Client may reapply to Overpayment composition, etc. $700 First waitlist. Termination with 14 day written notice. Notes: Greater than $700 without a false application Greater than $2,000 with a false application Second or More Any Any Recover improper payments through a repayment plan. Termination with 14 day written notice. Recover improper payments through a repayment plan. Termination with 14 day written notice. Case submitted to Dept of Financial Services (DFS). Client may not reapply to the wait list until DFS investigation complete and client in compliance with the order. First offense penalty applied strictly on dollar amount. Second offense penalties or higher take both dollar amount and number of occurrences into consideration. After a client satisfies a penalty, no special restrictions apply. Last Revised 5/7/2015 Page 4 Location on W:\Fraud\Policy & Procedures

Exhibit IV Early Learning Coalition of Brevard County, Inc. Procedure Issue Date: 10/15/2014 Corresponding Policy: Anti-Fraud Plan Subject: Suspected Fraud and Repayment Agreement Reporting Originating Department: Finance Revision Date(s): Date Approved by Executive Director: Purpose: To provide guidance for mandatory reporting of possible abuse or fraud to the Office of Early Learning s Office of Inspector General. Reference: Rule 6M-9.400 Florida Administrative Code (ELC Anti-Fraud Plan), ELCB-FS-0001-12, ELCB- FM-0002-09 1) All approved Suspected Fraud Forms (SFF) and Requests for Repayment Agreements (RRA) will be forwarded to Business Coordinator. 2) Business Coordinator will record SFFs and RRAs on the Client Investigation Log according to Exhibit I (Act of Abuse or Overpayment Matrix) of the Coalition s Anti-Fraud Plan. Record must indicate if client s services have been terminated or suspended, along with other pertinent information as determined by the Director of Business Operations for tracking purposes. 3) Business Coordinator will forward SFFs to Director of Business Operations for final review and will forward RRAs to designated Finance team member for processing. 4) Upon final review of SFFs, Business Coordinator will enter case information into the Office of Early Learning s Fraud Referral System (FRS) and record entry date on Client Investigation Log. 5) By the due date specified by the Office of Early Learning (OEL), if received, on the 10 th of the month, Business Coordinator will upload previous month s summary to OEL via SharePoint to ensure compliance with Rule 6M-9.400(3)c, FAC and OEL guidance for mandatory reporting.

Exhibit V Early Learning Coalition of Brevard County, Inc. Policy Number: ELCB-FM-0002-09 Department: Finance Department Staff Contact: Director of Business Operations Date Approved: 04/01/09 Date Last Modified: 05/07/2015 Subject: Improper Payments Background: 45CFR98, Code of Federal Regulations; Chapters 1002.81-97, Florida Statute; Rules 6M-4, 8, and 9, Florida Administrative Code; OEL Policy OEL-PI-0003-12. Policy: It is the policy of the Early Learning Coalition of Brevard County, Inc. to ensure a system of accountability for fiduciary responsibility of proper distribution of Federal and State funds and establishes the process of handling improper payments.

Procedure: A. General 1. The Coalition is responsible for ensuring fiduciary diligence in the implementation of the rules and regulations of the School Readiness and Voluntary Pre-Kindergarten (VPK) programs, and to seek repayment when payment and/or benefits have been provided improperly. 2. Any contractor, provider or client of School Readiness or VPK services, that receives State or Federal funds or benefits from the Coalition, are obligated to repay the funds for various reasons, including, but not limited to: Overpayment Payment made in error as a result of a lack of understanding or miscommunication by any party Disallowed payment due to ineligibility of the client or provider Disallowed payment as a result of an audit Disallowed payment as a result of non-compliance Reconciliation of a payment for the VPK or SR program Disallowed payment based on misrepresentation or fraud Interest earned on advanced funds Unexpended funds that remain at the end of the fiscal year 3. In all cases, the Coalition has the discretion to refuse any applicant, client or provider, any future participation in the VPK or School Readiness programs for fraudulent activity, non-compliance with requirements, lack of cooperation, failure to comply with rules, requirements or responsibilities of the School Readiness and/or VPK programs. 4. In all cases, it is the Coalition s responsibility to document and keep current information that reflects the status of any client or provider activity related to this policy. B. Incorrect Payments 1. Recoupment of incorrect payments such as those cited above must be sought regardless of errors or misrepresentation on the part of the client, provider, or Coalition. Once an incorrect expenditure has been identified by the Coalition, the following activities should occur: The Coalition must notify the provider of the incorrect payment and the reasons that caused the incorrect payment. Written confirmation must be sent to the provider confirming the amount of incorrect payment and what action is to be taken for recoupment. Last Revised: 5/7/2015 2

a. The written confirmation will be sent by regular U.S. mail and if no response, by certified mail, return receipt requested. b. A copy of the letter must also be placed in the provider s file, maintained by the Coalition s Finance Department. If the provider is continuing to provide care of children, then recoupment will occur by deducting the amount of the incorrect payment (known as prior period adjustment ) from the funds currently paid to the provider. If the provider is not continuing to provide care to School Readiness or VPK children, then the recoupment must be secured directly from the provider unless the incorrect payment was due to misrepresentation or fraud on the part of the client. The client will be responsible for repayment of funding to the Coalition if the cause of the incorrect payment was based on a client s failure to provide information that directly affected their eligibility for services and will be terminated or suspended in accordance with the Exhibit I (Act of Abuse or Overpayment Matrix) of the Coalition s Anti-fraud plan. 2. The Coalition is responsible for making diligent efforts to secure timely reimbursement for incorrect payments or ineligible services. If the sum of money owed is such that the responsible party cannot immediately repay, then the Coalition will develop with the responsible party, a written repayment schedule in accordance with Exhibit I (Act of Abuse or Overpayment Matrix) of the Coalition s Anti-Fraud Plan. The repayment schedule may allow for partial payments, but each responsible party is expected to repay the full amount within the required period. During the period covered in the repayment plan, the Coalition s Director of Business Operations or designee must monitor the repayment plan to ensure it is being followed and all documents must be filed accordingly. 3. Errors resulting in incorrect payments are ultimately the financial responsibility of the Coalition if recoupment proves unsuccessful. 4. Designated cases, where there is evidence to support a belief that the activity of the client, as indicated in Exhibit I (Act of Abuse or Overpayment Matrix) of the Coalition s Anti-Fraud Plan, or provider was fraudulent and certain amount thresholds are met, must be submitted to the Office of Early Learning via its Fraud Report System and subsequently the Division of Public Assistance Fraud, Department of Financial Services (DFS) for further evaluation and/or processing. Last Revised: 5/7/2015 3

C. Delinquent Collection of Repayment 1. The status of repayment becomes delinquent when the provider/client fails to repay the full amount that the provider/client owes by the repayment date specified in a Court s Restitution Order. Notice of delinquency will be sent to the designated Probation Officer. 2. If, the Coalition entered into a repayment schedule, the account becomes delinquent when the provider/client fails to submit any payment specified in the repayment schedule, or repay the account in full within six months after the repayment date specified in the repayment schedule. 3. Once an account becomes delinquent, the Coalition will within ten (10) days, send a demand letter by regular U.S. mail with delivery confirmation. The first demand letter will include the following: Full amount owed; Reason for the delinquency; Demand for immediate repayment of the full amount within 30 calendar days of the demand letter; Description of the collection efforts that the Coalition will use if the provider/client fails to repay; Provider/client s right to dispute the delinquent account under the Fair Debt Collections Practices Act by submitting a written dispute to the Coalition within fourteen (14) days after issuance of the demand letter 4. If the provider/client fails to make payment within the time period specified in the first demand letter, a second and final demand letter will be sent within ten (10) days by certified, return receipt requested, regular U.S. Postal Service. The second demand letter will include: Full amount owed; Reason for the delinquency; Demand for immediate repayment of the full amount within ten calendar days; Provider/client s right to dispute the delinquent account by submitting a written dispute to the Coalition within thirty (30) days after issuance of the previously sent first demand letter; Notice that the client or provider will not receive further state or federal funds unless full payment is made; Notice that the Office of Early learning may report a delinquent account for collection by DFS if the provider/client fails to repay the account in full by the date required in the second demand letter. Notice that legal action and/or collection efforts may be taken by ELC to recoup any monies owed to ELC from provider/client. Last Revised: 5/7/2015 4

Exhibit VI Early Learning Coalition of Brevard County, Inc. Procedure Issue Date: 3/21/14 Corresponding Policy: ELCB-SR-0002-08 Subject: Partnering Agency Referrals for School Readiness Services Procedure Originating Department: Revision Date(s): 10/1/2008; 02/01/2010; 09/14/2011; 11/01/2012; 3/21/14, 10/9/14 Date Approved by Executive Director: Subject: Partnering Agency Referrals for School Readiness Services Procedure References: Office of Early Learning School Readiness Standard Eligibility Review Program Guide; Rule 6M-4.100-4.210, F.A.C.; Chapter 1002.81-97 Florida Statue Corresponding Policy (s): Partnering Agency Referrals for School Readiness Services Policy Definitions: At-risk child -. Includes the following children that the Department of Children and Families (DCF) refers for SR services: A child from a family that DCF or a designated sheriff s office is investigating for child abuse, neglect, abandonment or exploitation. A child who is in a diversion program that DCF or its contracted provider runs and who is from a family that is actively participating in and complying with departmentprescribed activities, including education, health services or work. A child from a family under DCF or a contracted service provider s supervision for abuse, neglect, abandonment or exploitation. A child placed in court-ordered, long-term custody or under the guardianship of a relative or non-relative after DCF or its licensed contractor terminated parental custody. A child in the custody of a parent who is a victim of domestic violence and is residing in a certified domestic violence center. A child in the custody of a parent who a DCF-certified homeless shelter verifies as homeless. Child Care Application and Authorization forms: referral received from the local CareerSource, Department of Children and Families and contracted community-based providers, which contains all required information and signatures of the parent, referring agency representative and authorizing coalition worker.

TCA- Temporary Cash Assistance recipients of TANF (temporary aid to needy families) subject to Federal work requirements TCC- Transitional child care for families transitioning off TANF to work Procedure: I. All referral forms received from the Department of Children and Families or partnering agencies will be reviewed to ensure the referral indicates the following: a. The name and contact information of the agency/case worker making the referral. b. A current authorized child care begin and end date listed for the selected review period. c. The name of the child(ren) authorized for eligibility. d. The dates of birth for the child(ren). e. The name and address of parent(s). f. The eligibility for referral, which includes status, such as assistance, nonassistance, RCG, TCA, TCC, At-Risk-PI, -PS, -FS, In-Home, Out-of-Home, Medicaid Eligible, Custody home, Medicaid eligible, custody, etc. g. A purpose for care, such as protection, employment, work activity or education. h. The number of hours authorized or identified as full-time, part-time or both. i. Transitional child care (TCC) referrals must also include the TCC period. j. A signature and date for the authorizing agency representative or supervisor, parent and coalition representative. II. Electronic child care referrals are acceptable. However, they are required to be transmitted via a secure server. III. If dates or required items are missing, designated staff will request a new referral or contact the referring case worker and make an electronic post-it change on the referral. Any changes should be signed and dated by the coalition representative and include the date, time and name of authorizing case worker. It would be recommended to have documentation of the change (email or fax). The coalition should document attempts to obtain information missing on referrals; two documented attempts would typically represent due diligence. a. Note: For clients under Protective Services (PS) or Protective Investigation (PI), Florida s Office of Early Learning expects the safety of these children is a priority. Services should not be denied due to an administrative error on the child care referral or if the child care authorization date is prior to the signature date of the referring agency. Coalition staff should work with the referring agency to make the needed corrections for any administrative error. IV. Designated staff and/or eligibility staff will determine the correct child care authorized begin and end dates are based on the category of care(billing group) requested: Last Revised 10/9/14 Page 2 Location on W:drive