Universal Preschool Update - March 16, 2023

Can you please provide some more clarity/context to the statement that was made at the UPK breakout session at the CASE conference that districts should be prepared to have to supplement this program with General Fund dollars?

The example at the CASE Conference was of a district that was expanding from part-time to full-time and also expanding the number of classrooms. If a school district expands beyond what the current demand is, that could result in the district having to use funding other than UPK.

In year one, there is a hold harmless provision, which applies if a school district or community-based provider has lower funding through UPK than the amount of funding generated through CPP to serve children in the 2022-23 fiscal year.

It appears that some students with IEPs were assigned to a parent's second choice when they are reporting that they are choosing a district program as #1 preference. What is the status of this?

CDEC is working with LCOs to address these situations on a case-by-case basis.

When will we know how many three-year-old “slots” will be funded for our program? We have received substantially more three-year-old matches than the number that I estimated will be funded.

CDEC is not determining “slots” for school district providers serving three-year-olds. Applications for three-year-olds will be provided to school districts in a batch. How districts allocate the static amount of funding they receive to those applicants will be determined by the school districts.

 

What messaging will parents receive on March 30 when the first match goes out and they have applied for a full-day spot? At this point, they've been told that they "might be eligible for full day funding." If we don't know until April 10 if they are funded, there will be a few weeks where communication might not be accurate? Am I misunderstanding this?

Families that qualify for additional hours will receive messaging before March 30 on the status of the funding for additional hours. At this time, we are unsure of the extent to which we will be able to award that funding because we are statutorily mandated to first serve all eligible preschool students with disabilities in accordance with IEPs, four-year-olds, and three-year-olds with at least one qualifying factor. We will look at the number of students in the system during the week of April 10 to better determine our ability to meet the funding needs for children eligible for additional hours.

We understand that many providers, including districts, have already hired their staff and purposed their classrooms, and many have had long standing full-day offerings for children with qualifying factors. We also understand that it is imperative to inform providers and families as soon as possible as to how many children will be served with the additional 15 hours.

Am I understanding that three-year-old funding is committed to us (districts) not only for this coming year but in the future as well?

Statute requires the commitment continues in perpetuity and is adjusted annually by inflation.

Is the three-year-old calculation based on CPP funding for three-year-olds or total CPP funding?

The three-year-old calculation is based on CPP funding for three-year-olds in FY 2022-23, while the state and federal special education funding will continue to be distributed by CDE.

Calculation of rates, distribution of funding, and calculation of revenues are all independently operating items under UPK. For students with IEPs – including three-year-olds - they will receive whatever funding is needed to fund the general education portion of their seat up to the number of hours as prescribed in their IEP.

The calculation of UPK rates took place in accordance with statute and the minimums dictated in relevant law.

Regarding the statutory “carve-out” for three-year-olds with qualifying factors that are not special education students, if they are an eligible child under that applicable Rule via qualifying factor(s), then they receive that funding as an eligible three-year-old-or-younger child. This funding, as spelled out in statute, follows that eligible three-year-old. The funding levels dictated by law for three-year-olds-and-younger are tied directly to that child and the services they are eligible to receive via their qualifying factor(s) and statute.

Lastly, it should be noted how the Preschool Programs Cash Fund (PPCF) receives revenue from multiple different sources, which is why there appears to be a disconnect sometimes in how revenues versus expenditures are calculated. The calculation of the “transfer” and calculation of various funding level minimums for certain populations of children is not tied directly to any one source of revenue, but is all distributed out of the PPCF in accordance with statutory prioritization and operational requirements, with the PPCF having access to multiple sources of revenue.

How do we ever increase the number of three-year-olds that we can serve and get funded for them?

Funding is targeted and limited. Any three-year-old with an IEP will receive the UPK rate to fund the general education portion of their seat up to the number of hours as prescribed in their IEP.

We are very concerned that LCOs have not been trained related to legal requirements for school districts for identifying and serving preschool children with disabilities. How, when and by whom will the LCOs and community-based providers be trained to ensure that there are legally defensible and consistent practices across the state, in compliance with state and federal law?

The CDEC-CDE MOU requires that CDE establish specific training and certification requirements related to Part B of IDEA for the CDEC, LCOs and Preschool Program Providers. Initial training was offered by CDE to LCO contacts on February 17 and March 16, 2023. Ongoing training and certification requirements will be established by CDE in the Exceptional Children’s Educational Act Rules. Administrative Units, consistent with ECEA statute, continue to be responsible to make the final determination for the placement in an educational program of any eligible child with a disability through the child’s IEP team (C.R.S. 22-20-102). CDE has released guidance on educational standards for preschoolers with IEPs, as well as FAQs addressing placement.

Districts need direct guidance on how to hold spots for students who are at-risk and won’t register until July/August. It appears that UPK slots are filling more than perhaps there is capacity for. Will there be funding in the fall for families who register late? How can districts highly impacted by poverty assure our families that there is room for them in the fall?

CDEC recommends that providers put the total number of seats in the system and then leverage the exception process to “hold” seats for students with an IEP. Providers should manage the seats as they have in the past.

The different program models will be difficult to achieve and manage on short notice. Finding out in Nov 2022 about the 10/15/30 hour reimbursements did not give programs a lot of notice to create those programs. We have been operating a 5 day/week preschool program for many years, but with transportation and contractual restraints we still don’t hit 15 hours. We are at 13.75 which is significantly more than 10 but won’t allow us to get the 15-hour reimbursement. What do you advise?

Many districts adjusted their programs to the fit 10/15/30 reimbursement rates. Districts are not required to offer 15-hour programming. However, a program higher than 10 hours but lower than 15 hours will be paid the 10-hour rate.

Our district has been the main full day preschool/child care provider for many years. Our programs have used state funds to support high needs three-year-olds, based on risk factor qualifications and special needs with full day preschool. Having no option for the increased funding reimbursement for our full day three-year-olds will be a hardship to our community. With almost half of our classrooms currently offering full day to our families who work or go to school, it will be not equitable to not offer tuition supported full day to our three-year-olds, especially those with special needs. We will continue to offer tuition but not all families can manage the fees or qualify for CCAP. What do you advise?

School districts have the ability to craft a program for three-year-olds that have at least one qualifying factor. The amount of funding allocated to this purpose is set in statute and cannot be increased through any action of the Department. School district providers will be able to determine how that funding is allocated to serve students in the district.

For three-year-olds that do not qualify for universal preschool with qualifying factors, decisions will need to be made about how to offer preschool. Offering preschool to three-year-olds that do not qualify will require us to have a uniquely different enrollment, and funding system. What guidance do you have?

Historically, three-year-old funding has not been universal. It was a targeted program and will continue to be a targeted program with limited funding.

Concerns over accurately finding students with disabilities during the universal application process--if they have an IEP, they have to come to us to get their services-not a community or home provider. Worry - kids get placed in the wrong place based on IEP. No safety net - really counting on parents to understand and check the IEP box on the application. What is the latest information about this?

To address these concerns, CDEC worked with CDE to draft a letter that will be sent to every family that self-indicated that their child had an IEP.

Funding formulas and timelines: We need clarity on how and when districts will receive the funds. There are rumblings of getting disbursements every few months based on enrollment. How will this system work when trying to do district budgets that are based off of set revenue numbers? If money is allocated every few months based off of enrollment, does that mean prorated revenue? Do we cut staff when revenue drops?

Currently for UPK, it is expected that providers will have four quarterly payments during the year starting with a first payment in August, followed by payments in November, February, and May. Providers will need to ensure children are enrolled as there will be a true up and potential reallocation of seats, as necessary, to ensure seats are maximized and children are served.

At the start of each school year, CDEC (or the LCO, which is responsible for receiving and distributing UPK Colorado funds) will distribute a portion of the funding to providers based on the numbers of children expected to enroll as estimated in the community plan. The remaining funding will be distributed throughout the year, adjusting the amounts based on actual enrollment.

This allows for adjustments during the year should enrollment not match the anticipated planned enrollment. There is no expected change in the distribution timing of state and federal special education funds by CDE to Administrative Units special education.

Equity Issue for Students: The system is first come, first served. Families that are on top of things will fill out the application right away. Seats will fill and families with the most risk factors will no longer have priority over accessing preschool chairs. How should districts handle this?

While UPK Colorado is a universal program, it is not first-come, first-served. Matching is done in rounds. While families who wait to apply may not get matched with their first choice, in the majority of communities across the state, there are plenty of seats available and most families will be matched with a provider. We will use the data received from rounds one and round two to address shortages across the state during the summer.

When and how are numbers of children and payments for them to districts being determined?

Beginning in the 2023-24 school year, CDEC will base the amounts distributed on the per child rates by provider. CDEC (or the LCO, which is responsible for receiving and distributing UPK Colorado funds) will distribute a portion of the funding to providers based on the numbers of children expected to enroll as estimated in the community plan, starting with a first payment in August. The remaining funding will be distributed throughout the year, adjusting the amounts based on actual enrollment. This allows for adjustments during the year should enrollment not match the anticipated planned enrollment.

At our new preschool, we have intentionally kept tuition rates low, partially due to ESSER funds and partially to stay competitive with other childcare and preschool sites to build our client base. It is our understanding that the amount determined by the UPK funding formula must be the same or more as the general tuition charged, or we will be paid at the lower rate. There is no doubt that we will need to increase our tuition as we have been running at a deficit, however, that is going to make tuition costs extremely high for those that do not qualify for a UPK grant due to our high personnel costs. For example, our projected UPK rate is $4,885.88 for 10 hours per week. If you divide this across nine months, the tuition fee would be $542.88/month. We are currently charging $250.00/month for the same amount of time which is comparable to other preschools in the area. What do you suggest?

The UPK provider rate is based upon region and has no bearing on the tuition a provider charges. Providers do not need to adjust their tuition to match the UPK rate.

How will the Universal Application system be updated with current facility availability?

Providers enter this information into the system. As families are matched to the provider, the provider’s seat count will be adjusted.

How long will programs need to hold space available for a “matched” family if they do not end up registering for the program?

Once families receive a match (March 30 in the first round) from a provider, they will have two weeks to accept or decline the offer. If a family does not act, the offer will be considered declined.

How will families know that District locations (AUs) are the only ones who are able to serve students with IEPs (s/IEP or students with disabilities - SWDs)? Same question for three-year-olds, either with or without any eligibility factors?

CDE and CDEC have created a notification to families who have indicated in the UPK application process that their child has an active IEP. The notice will make it clear that for the family to access IEP services, the provider selected for UPK by the parent must match the school identified on the child’s IEP. The AU may provide special education and related services to a preschool child with a disability in a variety of settings, including a public program administered by a school district or AU. Services may also be provided in Head Start programs or in private or community-based programs, as long as the private or community-based program meets the educational standards of the AU and CDE and the IEP team determines such placement can provide FAPE. If there is a school district preschool program available, the AU may choose, in accordance with the child’s IEP, to make a Free and Appropriate Public Education (FAPE) available to a preschool child with a disability in the school district preschool program. For more information about the determination of an appropriate educational program for preschoolers with IEPs see CDE’s FAQ, particularly questions and answers 5 and 6.

What will the funding structure look like (quarterly payments?) for students who become (or who are no longer) eligible after the start of the school year?

Currently, it is expected that providers will have four payments during the year starting with a first payment in August, followed by payments in November, February, and May. Providers will need to ensure children are enrolled as there will be a true up and potential reallocation of seats, as necessary, to ensure seats are maximized and children are served.

How can programs respond to the sudden increase in hours from 10-15? We currently have an 11-hour program with little to no flexibility to alter it given our responsibility to serve three-year-olds. We currently run a four-day per week model which is 10.66hrs/week of preschool. The move to 15 hours/week would require an upheaval of our entire structure. This leads to contractual questions by teachers and transportation/nutrition implications. Right now the fifth day per week is used for trainings, cleanings, etc. required by licensing regulations. We have advocated for years that school district preschools not be required to comply with all of the same licensing regulations as private preschools. If the same licensing regulations stay in place and we have 15 hours per week of required preschool, we will have a hard time keeping us with those requirements. What do you advise?

Districts are not required to offer 15-hour programming. There is a 10-hour rate and a 15-hour rate. A district may offer an 11-hour program, but would be paid the 10-hour rate.

We have to hold spots for special education students we locate all year long. Will we get funded right away for these “holds” even if the student may not be in the seat? We cannot over-commit our seats available since we know we will bring in special education students all year.

School districts will receive funding as long as they can prove projections. However, if seats are not filled, the seats will not be funded.

We must serve all special education students. It appears that the priority for serving kids isn’t reflecting the fact that all spots may be filled with special education. It appears that four-year-olds get preference over a three-year-old special education. If not, I don’t think it's very clear as to the “priority” that special education will always get spots and families may lose a spot if we have more special education students to serve- even mid year changes could cause us to remove a non-special education child from the program. What information do you have?

The statute specifies prioritization of funding as follows: • All eligible preschool students with disabilities in accordance with IEPs • 4-year-olds / year-before-kindergarten – a minimum of 10 hours/week • Eligible three-year-olds (and-younger with historical waiver) who meet a qualifying factor per rule • Additional hours for eligible 4-year-olds / year-before-kindergarten, per rule and subject to available appropriations Because providers will be paid quarterly as opposed to once a year, there will be funding to add additional staff during the year based on needs.

Demand will be over what we have capacity for - how will parents understand this when it has been sold as free preschool for all students?

Every child in the year before they are eligible for kindergarten is eligible for up to 15 hours of free preschool, “subject to the availability and capacity of preschool providers.”

Requiring 180 days or 360 hours doesn’t work with our capacity. If we have to meet this, we would reduce our capacity and limit how many can attend our preschool program. What should we do?

UPK Colorado does not require 180 days. It requires 360 hours for the 10-hour rate or 540 hours for the 15-hour rate. The 360 hours is consistent with what was required for part-day CPP funding in the past. There is no expectation regarding the number of days.

Is there a way to see the complete list of providers? We were told in January that this was in the works.

This is a list of providers that signed up for the first round of matching. The final list of participating UPK providers will be available by June 30, 2023.

The idea of a “gap year” still exists. We often have students with IEPs who start with us at age 3 and they are in preschool for 3 years. So we will have funding for the three-year-olds and they will have UPK funding for the year before they start kindergarten. How will these students be funded who continue to be eligible for preschool but are no longer 3, but will not enroll in kindergarten for 3 years?

Each child will only receive funding for UPK for one year. However, if an IEP team determines a child needs more than two years of preschool, a district can apply three-year-old funding provided via qualifying factor for the first two years and UPK funding for the final year.

What if we see a growth in three-year-olds receiving services that is well beyond our allocated funding?

Statute specifies prioritization of funding as follows: • All eligible preschool students with disabilities in accordance with IEPs • 4-year-olds / year-before-kindergarten – a minimum of 10 hours/week • Eligible three-year-olds (and-younger with historical waiver) who meet a qualifying factor per rule • Additional hours for eligible 4-year-olds / year-before-kindergarten, per rule and subject to available appropriations Therefore, there is no limit on three-year-olds with an IEP that can receive funding.

Will 4-year-old special education students get additional funding above the UPK rate? Districts have been getting ½ PPR for those students. In some districts, that is over $12,000 per year and the UPK rates are significantly less than that.

No, they will not receive a ½ PPR rate.

What communication will be sent to parents letting them know that the number of hours available (part time, half time or full time) will be dependent on what providers can offer?

Providers indicate their available offerings in their profiles in the UPK portal. When a family ranks its top five choices for providers, the family is selecting the specific hours offered by that provider.

As a large district we have the capacity to primarily offer part-time programming, with very limited half-time and full-time opportunities. For students that qualify based on additional factors for full-time programming (special education students, etc.), why can’t families benefit from accessing additional programming from other providers (especially if it provides continuity of care)? This appears to be a significant equity issue for students and families.

Districts may subcontract with providers for continuity of care to meet the needs of kids with qualifying factors.

There has been lots of information provided through different meetings. What is the plan for ensuring consistent information is available as school districts and providers have similar questions beyond the published FAQs? CDEC promised regular updates in writing across the field along with regular town halls with Dr. Roy. We keep hearing about more meetings but are not seeing anything.

CDE is holding special education meetings and CDEC-CDE are hosting Town Hall meetings twice a month. If you would like to receive invitations for the town halls, please contact Jeannie Lira at jeannie.lira@state.co.us.

Has there been any official release on the priority that will take place for funding (i.e. at 15 hours with one qualifying factor)? Also, can you confirm that if funding runs out, it is possible we will have students we are serving that we would not receive funding for? Is the expectation that districts will use their general fund dollars to fund this?

Under the UPK statute, beginning in school year 2023-24, funding from the Preschool Program Cash Fund (PPCF) administered by CDEC will be provided to qualifying providers, and according to statute must be prioritized as follows for students: • All eligible preschool students with disabilities in accordance with IEPs. • 4-year-olds / year-before-kindergarten – a minimum of 10 hours/week. • Eligible three-year-olds (and younger with historical waiver) who meet a qualifying factor per rule. • Additional hours for eligible 4-year-olds / year-before-kindergarten, per rule and subject to available appropriations.

Why are we sending out UPK batch data before the training for management of said data is not ready yet? This will cause confusion as people start messing around in a system without proper training.

Training information was sent to providers on the same day they received the matches.

When will we know what is funded and what isn’t? What will parents be told when the matches are released on March 30? Will it say that they get 10, 15, 30 hours?

Families will find out which provider their child was matched with on March 30 and will have two weeks to accept or decline the match. CDEC hopes to know how many children will be served with the additional 15 hours after April 10.

CDEC language: “Providers will only see the students that have matched with their program. Providers will not see the students on the waitlist nor the size of the waitlist for their program(s).” This is a huge issue of concern. How can it be possible that we won’t see all the applicants? What if we know there’s an IEP student in the mix but due to parental error they didn’t add that to their profile? What if there’s a sibling in the mix and the parent neglected to acknowledge that in their application? This can’t happen this way or it will cause a cascade of follow up problems that we will have to work through. We absolutely need discussion and resolution on this.

UPK Colorado gave districts additional time to do a cross-check between the children that were matched to them and the children they currently serve, children of siblings and children of employees, as well as those with an IEP.

CDEC language: “When a provider declines a match, they will have to sign the following attestation: Please enter the reason why you are declining placement for this child. A child can only be declined for an exception reason that you explicitly stated when you registered for UPK and only by providers with exception approval from CDEC. All declines will be reviewed by UPK administrators and the child may be placed again at your location. If you attempt to decline a child for an unapproved reason you may be removed as a UPK participant.” I am very alarmed by this. It feels incredibly “big brother” and flies in the face of local control. While we understand that you want to be sure that we are giving children every opportunity to apply and attend a program, we still have local decisions that need to be made. Please explain this a bit more.

UPK Colorado is committed to family choice and to the equitable delivery of universal preschool.

CDEC language: “When a provider declines a match that the system has made, that student’s status changes to Declined for that program. The Declined status ensures that the student will never be matched to that program again.” This is majorly concerning and problematic. Just because we decline a student in the early going doesn’t mean there won’t be space later for that child. This is especially concerning if we can’t access our wait lists. What if a student drops out two weeks into school – wouldn’t a declined student potentially be the next one up on the waitlist? This seems confusing and honestly a bit shortsighted. What are we missing?

If a child is declined, it has to be for a specified reason. That child will then be matched to a different program. Family choice is honored in the UPK Colorado matching process.

I would very much like to revisit the concept of an exception for school districts who would like to hold spots for at-risk students. If we aren’t allowed to do that, it will cause significant issues with our population of students who want to register in July/August and are automatically excluded from our program as other parents have gotten in ahead of them. At-risk students are the kids who truly need UPK but are often the ones who either aren’t tech-savvy or have more pressing issues that cause them to not register until the school year is upon us. This issue has to be addressed.

School districts are allowed to hold spots.