Policy – AMERICORPS: Health and Child Care
Blue Box | 2022 Terms and Conditions |
Green Box | Directly from the Regulations |
Purple Box | Policies/FAQs |
Subgrantees of funded programs must be in compliance with this Health Care Policy.
Health Insurance
- Funded programs are required to provide health insurance to FT – 1700 hour members unless members provide proof of other coverage upon enrollment.
- Funded programs may offer health insurance to less than full-time members serving in a full time capacity (serving at least 30 hours/week) and use AmeriCorps funds but are not required to do so. See Terms and Conditions below for eligibility and other details.
- All FT must sign a waiver if they decline AmeriCorps coverage – but must have other coverage to do so. This waiver must be kept in their file.
- All covered members must have proof of coverage in their file regardless of source of coverage.
- Funded programs may offer health insurance to all members if desired. AmeriCorps share of funding may not be used for this. EAP Subgrantees may also provide health care to members.
- The Corps Network offers a compliant AmeriCorps health plan for members.
All Subgrantees must be in compliance with this Childcare Policy.
Child Care
All Full-time members are eligible for Child Care. Effective January 1, 2017:
- Full-time EAP members are eligible to apply for the AmeriCorps Child Care Benefit
- Guidance has been published that outlines child care benefit support that may be provided for members who are placed in a temporary suspended status. To qualify for coverage while under temporary suspended status, members must meet all of the requirements as outlined in the Q & A below.
Are members eligible for child care benefits while under suspension?
No. Members are not eligible for benefits while under suspension. However, if a member is put in a temporary suspended status and meets all of the below requirements, that member may be eligible to receive up to 12 consecutive weeks of continued benefits:
- The Member may not be suspended for cause and/or other disciplinary actions (an example of a qualifying suspension would be if a member was given a temporary suspension under the Family Medical Leave Act);
- The Member must intend to return to service;
- Member must certify he/she needs the continued benefit in order to be able to return to service
To ensure no lapse in coverage, the grantee/Subgrantee must notify the AmeriCorps Child Care benefit administrator (GAP Solutions, Inc.) in writing within five business days after a member’s status changes. Costs incurred due to the grantee’s failure to keep the benefit administrator informed of changes in a member’s status may be charged to the grantee’s organization.
For more information on the AmeriCorps Child Care Benefit Program, please visit:
http://www.americorpschildcare.com.
The system requires Members and providers to complete new applications online. Every use must create an account to complete their application online.
Below are highlights of the website:
- The AmeriCorps Child Care website gives members and their child care providers all the information they need before they apply. The information is specific to their state of residence. (http://www.americorpschildcare.com)
- The AmeriCorps Child Care website is easy to navigate via mobile devices.
- Members and their Child Care providers must register online to be able to apply.
- AmeriCorps members and their Child Care providers can track their application status online via their user accounts.
- AmeriCorps providers will be complete and submit childcare attendance sheets online.
- We continue to offer payments to Child Care Providers via electronic deposit. Child Care providers enrolled in Electronic deposit receive payments within 1‐2 business days of having their invoices processed and approved without the delays of the postal system. Child Care Providers can still choose to get paid by check if they prefer.
- AmeriCorps Child Care Program ‐ GAP Solutions, Inc. ‐ 205 Van Buren Street ‐Suite 205 Herndon VA 20170 ‐ Toll‐Free Number: 1‐855‐886‐0687 ‐Fax Number: 1‐800‐521‐5415
Requirements:
- Programs are required to offer child care benefits to eligible FT ‐ 1700 hour members.
- Eligible members must sign a waiver if they decline the AmeriCorps benefit. This waiver must be kept in their file. See AmeriCorps guidance below for eligibility requirements.
- Eligible members using the benefit must have proof of this in their file.
AMERICORPS TERMS AND CONDITIONS 2022
VIII. LIVING ALLOWANCES, OTHER IN-SERVICE BENEFITS, AND TAXES
D. Healthcare Coverage. Except for EAPs, Professional Corps, or members covered under a collective bargaining agreement, the recipient must provide, or make available, healthcare insurance to those members serving a 1700-hour full-time term who are not otherwise covered by a healthcare policy at the time the member begins his/her term of service. The recipient must also provide, or make available, healthcare insurance to members serving a 1700-hour full-time term who lose coverage during their term of service as a result of service or through no deliberate act of their own. AMERICORPS will not cover healthcare costs for dependent coverage.
Less-than-full-time members who are serving in a full-time capacity for a sustained period of time (e.g. a full-time summer project) are eligible for healthcare benefits. Programs may provide health insurance to less-than- full-time members serving in a full-time capacity, but they are not required to do so. For purposes of this provision, a member is serving in a full-time capacity when his/her regular term of service will involve performing service on a normal full-time schedule for a period of six weeks or more. A member may be serving in a full-time capacity without regard to whether his/her agreed term of service will result in a full-time Segal AmeriCorps Education Award.
Any of the following health insurance options will satisfy the requirement for health insurance for full-time AmeriCorps members (or less than fulltime members serving in a full-time capacity): staying on parents’ or spouse plan; insurance obtained through the Federal Health Insurance Marketplace of at least the Bronze level plan; insurance obtained through private insurance broker; Medicaid, Medicare or military benefits. AmeriCorps programs purchasing their own health insurance for members must ensure plans are minimum essential coverage (MEC) and meet the requirements of the Affordable Care Act.
On Friday May 2, 2014 the U.S. Department of Health and Human Services (HHS) announced a Special Enrollment Period (SEP) for members in AmeriCorps State and National programs, who are not provided health insurance options or who are provided short-term limited duration coverage or self-funded coverage not considered MEC. Members in the AmeriCorps State and National programs and their dependents in the Federally-facilitated Marketplace (FFM) are eligible to enroll in Marketplace coverage when they experience the following triggering events:
- On the date they begin their service terms; and
- On the date they lose any coverage offered through their program after their service term ends. (Source: 45 CFR § 155.420(d)(9)).
Members have 60 days from the triggering event to select a plan.
Coverage effective date is prospective based on the date of plan selection. A copy of the HHS Notice, which provides instructions on how to activate the special enrollment period is available at https://www.cms.gov/CCIIO/Resources/Regulations-andGuidance/Downloads/SEP-and-hardship-FAQ-5-1-2014.pdf.
Members can also visit healthcare.gov for additional information about special enrollment periods:
https://www.healthcare.gov/coverage-outside- open enrollment-enrollment-period/
If coverage is being provided via the Healthcare Marketplace, and thus third-party payment is not an option, programs must develop a process to reimburse members for monthly premiums. Reimbursements for health insurance premiums are considered taxable income for the member, and programs must have a way to document such reimbursements.
E. Temporary Leave, Healthcare, and Benefits. If temporary leave is appropriate, grantees have the flexibility to determine the duration of the absence and may choose to continue providing health or other benefits to the member during the period of absence. The member may be suspended (via compelling personal circumstances) during the period of temporary leave. If suspended, the member may not receive a living allowance.
The length of the leave should be based on two considerations: (1) the circumstances of the situation; and (2) the impact of the absence on the member’s service experience and on the overall program. If the disruption would seriously compromise the member’s service experience or the quality of the program as a whole, then the grantee may offer the member the option of rejoining the program in the next class or completely withdrawing from the program.
The Federal Family Medical Leave Act, (FMLA) applies to full-time staff and members that have served for more than 12 months and at least 1,250 hours when the grantee has 50 or more employees/members at a work/service site per 29 U.S.C. 2611. See 42 U.S.C. 12631; 45 CFR § 2540.220.
F. Administration of Childcare Payments. In general, AMERICORPS will provide for childcare payments, which will be administered through an outside contractor. Requirements and eligibility criteria are in the AmeriCorps regulations, 45 CFR § 2522.250. AMERICORPS will not cover childcare costs for members who serve on a less than full-time basis for a sustained period of time, or who have ceased serving. Programs may provide childcare to less-than-full-time members serving in a full-time capacity, but they are not required to do so. Recipients that choose to provide childcare and will claim the costs of childcare as matching costs, as approved in their budget, may contact the childcare contractor for technical assistance. The criteria for member eligibility are contained in 45 CFR § 2522.250. Also, see the AmeriCorps Childcare Benefits Program website
(https://americorpschildcare.com/) for more detailed information on childcare benefits.
G. Notice to Childcare Benefit Administrator and Providers. The program must notify AMERICORPS’s designated agents in writing within five business days after a member’s status changes in a manner that affects the member’s eligibility for childcare. After five days, the recipient will be liable for any erroneous payments made to a childcare provider for an AmeriCorps member ineligible to receive AmeriCorps childcare benefits. Examples of changes in status include: changes to a member’s scheduled service so that he/she is no longer serving on a full-time basis, terminating or releasing a member from service, suspending a member for cause for a lengthy or indefinite time period, temporarily suspending a member for cause and/or other disciplinary actions, and/or any other change in the member’s service status that could have an impact on childcare benefit eligibility. Program directors should contact the childcare provider on childcare related changes.
Regulations > 2522 PART 2522—AMERICORPS PARTICIPANTS, PROGRAMS, AND APPLICANTS > 2522.200 Subpart B—Participant Eligibility, Requirements, and Benefits
§ 2522.250 What other benefits do AmeriCorps participants serving in approved AmeriCorps positions receive?
(a) Child Care. Grantees must provide child care through an eligible provider or a child care allowance in an amount determined by the Corporation to those full-time participants who need child care in order to participate.
(1) Need. A participant is considered to need child care in order to participate in the program if he or she:
(i) Is the parent or legal guardian of, or is acting in loco parentis for, a child under 13 who resides with the participant;
(ii) Has a family income that does not exceed 75 percent of the State’s median income for a family of the same size;
(iii) At the time of acceptance into the program, is not currently receiving child care assistance from another source, including a parent or guardian, which would continue to be provided while the participant serves in the program; and
(iv) Certifies that he or she needs child care in order to participate in the program.
(2) Provider eligibility. Eligible child care providers are those who are eligible child care providers as defined in the Child Care and Development Block Grant Act of 1990 (42 U.S.C. 9858n(5)).
(3) Child care allowance. The amount of the child-care allowance may not exceed the applicable payment rate to an eligible provider established by the State for child care funded under the Child Care and Development Block Grant Act of 1990 (42 U.S.C. 9858c(4)(A)).
(4) Corporation share. The Corporation will pay 100 percent of the child care allowance, or, if the program provides child care through an eligible provider, the actual cost of the care or the amount of the allowance, whichever is less.
(b) Health care. (1) Grantees must provide to all eligible participants who meet the requirements of paragraph (b)(2) of this section health care coverage that—
(i) Provides the minimum benefits determined by the Corporation;
(ii) Provides the alternative minimum benefits determined by the Corporation; or
(iii) Does not provide all of either the minimum or the alternative minimum benefits but that has a fair market value equal to or greater than the fair market value of a policy that provides the minimum benefits.
(2) Participant eligibility. A full-time participant is eligible for health care benefits if he or she is not otherwise covered by a health benefits package providing minimum benefits established by the Corporation at the time he or she is accepted into a program. If, as a result of participation, or if, during the term of service, a participant demonstrates loss of coverage through no deliberate act of his or her own, such as parental or spousal job loss or disqualification from Medicaid, the participant will be eligible for health care benefits.
(3) Corporation share.
(i) Except as provided in paragraph (b)(3)(ii) of this section, the Corporation’s share of the cost of health coverage may not exceed 85 percent.
(ii) The Corporation will pay no share of the cost of a policy that does not provide the minimum or alternative minimum benefits described in paragraphs (b)(1)(i) and (b)(1)(ii) of this section.
[59 FR 13796, Mar. 23, 1994, as amended at 70 FR 39600, July 8, 2005]
FAQs
C. 61. What are the program responsibilities and requirements in administering child care?
1. Informing the AmeriCorps Childcare Provider. In addition to determining a member’s eligibility at the start of the term of service, Program directors are required to notify the AmeriCorps Childcare Provider immediately in writing when:
- A member is no longer eligible for child care benefits due to a change in the member’s eligibility status (e.g., family income exceeds the limit, the child turns 13, a full-time member becomes a less than full-time member, or a member leaves);
- New or existing members become eligible for child care benefits;
- A member wishes to change child care providers or a child care provider will no longer provide child care services; or
- A member is absent for excessive periods of time (five or more days in a month).
Costs incurred due to the grantee’s failure to keep the AmeriCorps child care provider immediately informed of changes in a member’s status may be charged to the grantee’s organization.
2. Less‐than‐Full‐time Members. Although no portion of child care expenses for less‐than‐full‐time members may be paid from Corporation funds, Programs may choose to provide child care to half‐time embers from other sources.
3. Payments. Payments or reimbursement for child care benefits will be made for eligible members to qualified providers from the date child care need was established after service began. The amount of child care allowance may not exceed the applicable payment rate established by the State where the member is serving for child care funded under the Child Care and Development Block Grant Act of 1990. No payments and reimbursements will be made in the event the AmeriCorps member was ineligible, or if the provider was not qualified under the state guidelines.
4. Less Than Full‐Time Members Serving in a Full‐Time Capacity. Less than full‐time members who are serving in a full‐time capacity for a sustained period of time (such as a full‐time summer project) may be eligible for child care and health care benefits supported with Corporation funds
C. 62. If the AmeriCorps child care provider does not cover all of a member’s child care expenses, is it allowable for the program to use other AMERICORPS grant funds to cover the remaining unpaid balance? Can they use grantee funds for this expense and report this as match?
Yes. They can use AMERICORPS funds or grantee funds and count them as match as long as it does not exceed the allowance rate as set forth in 45 CFR §2522.250 (a)(3).
C. 65. The AmeriCorps grant provisions state that members may not receive health insurance paid for with AmeriCorps funds if they already have another type of health insurance. Does this apply to members who have Medicaid or Medicare coverage?
Full‐time members are entitled to health insurance coverage even if they are on Medicaid or Medicare. Medicaid and Medicare coverage are considered wrap around coverage, which means that they will pick up any costs that the health insurance policy provided by the member’s AmeriCorps program does not cover.
C. 81. Are programs required to provide health care insurance for members on Medicaid?
You must provide health care coverage to all full-time AmeriCorps members even if they are eligible for Medicaid. The U.S. Department of Health and Human Services (HHS) has taken the position that members receiving Medicaid have coverage available to them through AmeriCorps. Because Medicaid “wraps around” other available health care coverage, Medicaid will pick up only those costs that are not covered under the AmeriCorps policy. Members who remain on TANF will continue to receive Medicaid for their dependents. Members who lose TANF due to the living allowance usually can continue to receive extended Medicaid coverage for their dependents for up to one year. Applicants receiving these benefits should consult with their caseworkers before enrolling in AmeriCorps.
C. 82. Are programs required to provide Accidental Death and Dismemberment Insurance?
Programs are responsible for ascertaining whether state law requires the provision of Workers’ Compensation for members. In states where Workers’ Compensation is not required, you must obtain Accidental Death and Dismemberment (ADD) insurance to cover any member who is injured or killed in a service-related accident. The Corporation does not endorse any particular provider of ADD insurance. There is no minimum requirement for ADD insurance; however, programs should be sure that the ADD insurance is sufficient to cover in-service injuries or accidents. If a member is injured on the job, that member could hold the program responsible. There have been situations where the program didn’t have the required ADD insurance and faced medical bills for an injured member. While ADD insurance is an allowable cost, medical and legal bills resulting from not having ADD insurance aren’t.