2021 General Operating Fund Staff Wages and Benefits Guideline PHASE 1: January to June 2021 PHASE 2: July to December 2021
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2021 General Operating Fund Staff Wages and Benefits Guideline PHASE 1: January to June 2021 PHASE 2: July to December 2021 Peel Region Licensed Child Care Service Providers Centre-Based Programs Early Years and Child Care Services Release Date: June 1, 2021
Table of Contents SECTION 1: INTRODUCTION ............................................................................................................... 3 GOF Strategic Alignment and Objectives ........................................................................................... 3 SECTION 2: ELIGIBILITY CRITERIA..................................................................................................... 3 Change in Operator, Transfer, Sale or Closure .................................................................................. 4 SECTION 3: ELIGIBLE EXPENSES ...................................................................................................... 4 SECTION 4: GOF - STAFF WAGES AND BENEFITS (SWB) ................................................................ 5 Distribution to Staff ............................................................................................................................. 5 Payment to Staff - Requirements........................................................................................................ 6 Changes in Staff Complement ............................................................................................................ 6 SWB Funding - Surplus & Shortfall ..................................................................................................... 6 For-Profit Owners/Operators Eligibility................................................................................................ 7 SECTION 5: HISTORICAL FUNDING.................................................................................................... 7 SECTION 6: GOF UNDERSPENDING .................................................................................................. 8 SECTION 7: ACCOUNTABILITY MEASURES ...................................................................................... 8 A. Requirement to Keep and Provide Supporting Documentation ................................................ 8 B. GOF and Rate Increase Requests........................................................................................... 8 C. Requirement to Submit Information on Time............................................................................ 9 D. Key Performance Indicators (KPIs).......................................................................................... 9 E. GOF Reconciliation Report ...................................................................................................... 9 F. Recoveries .............................................................................................................................. 9 G. Audit Approach ........................................................................................................................ 9 H. Other Financial Reporting Requirements ................................................................................. 9 SECTION 9: CONTACT US ................................................................................................................... 9 APPENDIX A: INELIGIBLE EXPENSES .............................................................................................. 10 APPENDIX B: ELIGIBLE POSITIONS ................................................................................................. 11 APPENDIX C: CHANGES TO THE GOF STAFF DISTRIBUTION POLICY ......................................... 12 APPENDIX D: GOF UNDERSPENDING CALCULATION EXAMPLES ................................................ 13 2
SECTION 1: INTRODUCTION This Guideline provides licensed child care centres with key information regarding the 2021 General Operating Fund (GOF) to support staff wages and benefits for Phase 1 (January 1 to June 30) and Phase 2 (July 1 to December 31). To learn more about your requirements, you should review this Guideline and your EYCCS General Operating Fund Agreements. Federal Supports for Staff Wages: In 2021, service providers are required to continue to maximize federal supports for staff wages and benefits (e.g. CEWS) as long as it is available. If you are eligible to receive federal supports/CEWS but choose not to apply you will not be eligible for the portion of GOF that would have otherwise been supported through CEWS. GOF Strategic Alignment and Objectives GOF Components Strategic Priority GOF Objectives (as applicable) Staff Wages and High Quality • Enhancing staff wages and benefits above Benefits (SWB) mandatory requirements. • Reducing the wage gap between Early Childhood Outcome: Service Educators working in licensed child care settings providers recruit and school boards. and retain qualified Historical Funding staff by: • Maintaining previous years staff wage/benefit grants Pay Equity • Continuing to meet pay equity obligations Administration • Offset a portion of incremental audit and administration expenses. Funding • In 2021, the GOF Administration Funding allocation includes both GOF and WEG Administration Funding. SECTION 2: ELIGIBILITY CRITERIA To be eligible to receive the 2021 GOF, you must: 1. Be a licensed child care provider in Peel Region with a signed EYCCS Fee Subsidy Agreement dated on or before October 31, 2019. • Programs supported through Capital Funding investments will be prioritized to receive SWB. • Historical Funding is only available to service providers who previously received the former Wage Subsidy in 2015. 2. Demonstrate the Region’s Authentic Participation requirements: a) Inclusion of children in receipt of fee subsidy; b) Continuous quality enhancement practices; and c) Inclusion of children with special needs by participating in Peel Inclusion Resource Services. 3
3. Meet minimum wage ($14.25 per hour) and mandatory benefit requirements without utilizing GOF (SWB and/or Historical Funding), Wage Enhancement Grant (WEG) and/or other provincial funding. 4. Have business management practices which align with the Region’s priorities identified in the Early Years and Child Care Service System Plan: 2019-2024. 5. Be in good standing with respect to financial/contract compliance and reporting requirements for all funds provided. Non-compliance with this requirement might impact service provider eligibility for all EYCC funding programs. Change in Operator, Transfer, Sale or Closure Please see the Service Provider Handbook for information related to changes in Operator, Transfer, Sale or closure. In the event of: • A shares transfer when the licence remains unchanged, a new service provider may be considered ineligible to receive Historical Funding and Pay Equity. • An asset sale or for any reason where a new licence is issued, the service provider may be considered ineligible to receive GOF-SWB and may no longer be eligible to receive Historical Funding and Pay Equity. • Closure: If a program ceases to operate, the Region at its discretion may prorate the agency’s GOF funding amount. Note: The Region reserves the right to review continued GOF eligibility on a case by case basis. SECTION 3: ELIGIBLE EXPENSES 2021 GOF Eligible Expenses Expense Description Category Staff Wages and Benefits* (use as per your most recently approved GOF Distribution Plan) Staff wages • Enhance licensed child care program staff wages (over-and-above existing and benefits minimum wage requirements). enhancements • Support incremental employer mandatory benefit costs that result from GOF wage enhancements. • Continue to offset the employee or employer portion related to a non- mandatory benefit plan (e.g. health and dental benefits). 4
2021 GOF Eligible Expenses Expense Description Category Historical Funding* Staff wages & • Improve the wage and benefits of eligible positions working in a licensed child benefits care program (over-and-above existing wages and regulatory requirements for enhancements minimum wage and mandatory benefits). Staff positions should not receive less than what they received in 2015 Wage Subsidy payments. • Cover mandatory employer contributions resulting from increased salary and benefit costs related to Historical allocation funded salary. • Support benefit costs (if previously approved by the Province). Administration Funding Audit/ • Offset incremental audit and/or administration/booking costs incurred to Administration/ administer Region of Peel funding or reporting requirements. Bookkeeping • Support internal process to track data and expenditures to fulfill reporting costs requirements (both regional and provincial). • Additional costs associated with the internal payment processes required to provide GOF/WEG to staff. Note: To streamline administration funding for service providers, beginning in 2021 the Region is combining the Wage Enhancement Grant (WEG) and the GOF Administration Funding amounts. The combined Administration Funding allocation will be issued through GOF. Expenditures not listed above are considered ineligible. See Appendix A for examples of ineligible expenses. For questions about eligible and ineligible expenses, please email EarlyYearsSystemDivision@peelregion.ca. * Refer to Appendix B for a detailed list of eligible and ineligible positions. SECTION 4: GOF - STAFF WAGES AND BENEFITS (SWB) Distribution to Staff In order to issue the GOF- SWB, you must: 1. Ensure that you meet your regulatory requirements for minimum wage and mandatory benefits. Since October 1, 2020, the minimum wage in Ontario is $14.25 per hour. 2. Continue to use your most recently approved GOF Distribution Plan methodology and follow the process described in the Changes in Staff Complement subsection of this guideline. 5
Important: if you are unable to continue using your approved distribution policy (e.g. need to remove the seniority criteria), refer to Appendix C of this guideline. Payment to Staff - Requirements You are required to: 1. Distribute funding to eligible staff positions as part of your regular payroll process/schedule (e.g. biweekly / monthly) during each phase in 2021. • One-time and/or cash payments are not permitted. • GOF cannot be carried over from Phase 1 to Phase 2. • GOF cannot be carried over to 2022. 2. Include a ‘General Operating Fund’ notation and the amount payable on each paystub. Changes in Staff Complement If you experience a change (increase/decrease) in staff complement you must inform your Early Years Specialist as soon as the change is known. If you experience an increase in staff complement you must: 1. Reallocate SWB funds among all eligible staff using your most recently approved GOF Distribution Plan/Policy. Note: If you need to change your distribution policy, refer to Appendix C of this guideline. 2. Update the Staff Communication Letter and review the updated Staff Communication Letter with all staff within 2 weeks of the change. Staff Communication Letters must be retained and made available upon request. 3. Keep all signed Staff Communication Letters on file for 7 years for regional review, as required. If you experience a decrease in staff complement you must not redistribute unused GOF to existing staff. Unspent funding is considered surplus. Please refer to Section 6: GOF Underspending for direction on how to use leftover GOF. SWB Funding - Surplus & Shortfall You should continuously review your SWB budget (funding amount) and forecast how much you are expecting to spend by the end of each phase so that you can take corrective action. Changes in staff complement within a fixed-funding amount may result on the following situations: Situation Requirements Balanced Budget: Service No action is required. provider fully spends funding Note: If you are eligible for the CEWS, you should have through regular payroll underspending as you must maximize the CEWS first and only issue the portion of GOF not covered through the CEWS. 6
Situation Requirements Shortfall: you run out of funding Increases in staff complement will not result in a change to the before the end of a phase (June funding allocation. If you run out of SWB funding you may 30 or December 31) choose to: • Stop GOF-SWB payments to staff. If you choose this option, you are required to clearly communicate this decision to staff and your Early Years Specialist; or • Maintain salary and/or benefit enhancements. In this case, staffing costs over and above the approved SWB funding amount are your sole responsibility. Surplus: you expect to have Refer to Section 6: GOF Underspending for direction on how leftover funding by the end of to use leftover/surplus GOF. each phase For-Profit Owners/Operators Eligibility Owners/operators in a supervisor role or in another position to support ratios are eligible to receive at a maximum an amount equal to the average enhancement amount distributed to staff if they are employed by the child care agency and receive a T4. This amount will be prorated according to the amount of time the owner/operator spends in that role. The total eligible amount is the maximum allowed regardless of the number of owners/operators. Owners/operators have the option to accept the funding or flow it back into the program to further enhance staff wages. For example: Service provider ‘A’ received $20,000 to support staff wages and benefits. The average amount distributed to staff as an enhancement is $2,500. Based on the average, owners/operators in a full-time supervisor role would be eligible to receive up to $2,500 as automatically calculated by the Funding Distribution Plan and $1,250 if they support ratios 50% of the time. SECTION 5: HISTORICAL FUNDING This funding is available to service providers who previously received Wage Subsidy in 2015. Historical Funding is intended to improve wages and benefits of eligible staff positions working in a licensed child care program, making child care more affordable for families. If you receive Historical Funding, you must: 1. Use this funding consistently with previous Wage Subsidy payments provided to eligible staff positions. This includes: a. Ensuring that staff do not receive less than what they received in 2015. b. Using funding for eligible expenses only. c. Allocating a reasonable portion of the funding to each position in a way consistent with the achievement of your pay equity plan. Note: For each phase in 2021 the distribution of Historical Funding cannot exceed $4,767 ($794.5/month) for program staff and $1,285 ($214.1/month) for non-program staff. If you are 7
eligible for CEWS, you can only use Historical Funding to cover the portion of the enhancement that is not supported through CEWS. 2. Include Historical Funding payments in the job rates used by service providers in pay equity calculations (as applicable). 3. Promptly report to the Region any significant reductions in service levels (including reduced operating capacity) and/or staffing that is not temporary in nature. Funds not utilized will be recovered through the Region’s reconciliation process. Please refer to Section 6: GOF Underspending for direction on how to use leftover GOF. 4. Ensure that the Payment to Staff Position Requirements section of this guideline are met (these requirements are also applicable to Historical Funding). SECTION 6: GOF UNDERSPENDING The Region anticipates there will be underspending in GOF during 2021 due to service providers accessing the federal CEWS. Service providers that expect to have leftover GOF may use their underspending in 2021 to offset existing base wage expenses for program staff only. • Any offset to base wages must be for wages paid above minimum wage ($14.25) that is not supported through CEWS, WEG or any components of GOF (e.g. SWB, Historical Funding and Pay Equity). • You can only offset base wages of program staff who are eligible for GOF. • Mandatory and non-mandatory benefits cannot be supported with leftover GOF. Refer to Appendix B for eligible program staff positions and Appendix D for how to calculate the amount that can be offset using GOF underspending. SECTION 7: ACCOUNTABILITY MEASURES To monitor the performance and impact of the funding and ensure that all GOF is invested in alignment to the outcomes and requirements outlined in this Guideline, the Service Provider Handbook and your EYCCS GOF Agreement, the following accountability measures have been implemented: A. Requirement to Keep and Provide Supporting Documentation • Retain all original supporting documentation for a minimum of seven years. • Provide copies of staff communication letters, `staff payroll records, T4 statements, bank statements, cancelled cheques, and pre-and-post GOF paystubs upon request. • Additional reporting or audit requirements may be implemented on a case-by-case basis B. GOF and Rate Increase Requests You cannot include costs offset by GOF or any other Regional funding on your Rate Increase Requests. 8
C. Requirement to Submit Information on Time Failure to submit complete information on time will result in progressive penalties, as outlined in the Late Filing Policy, your EYCCS GOF Agreement and the Service Provider Handbook. D. Key Performance Indicators (KPIs) You are required to submit KPIs as part of your GovGrants GOF progress reports. Your progress report may include submitting data such as: • Number of staff supported by GOF by position (e.g. RECE’s, Non-RECE’s, Supervisors, Cooks, other non-program staff) • Per hour staff enhancement supported through Historical Funding • Number of staff receiving non-mandatory benefits supported by Historical Funding • Dollar value of non-mandatory benefits supported through Historical Funding E. GOF Reconciliation Report You are required to submit your GOF Reconciliation Report by August 31, 2021 (Phase 1 GOF) and in January 2022 (Phase 2 GOF) through GovGrants. F. Recoveries You must return GOF funding to the Region in the following situations: • Unspent funding; • Closure of an agency; and, • GOF not used in accordance with the terms of the of the EYCCS GOF Agreement or this Guideline. Note: In this case, you may be deemed ineligible to receive other EYCCS funding. When the Region determines that a service provider must return all or part of their GOF amount, the service provider will be notified by e-mail. The amount owed must be repaid to the Region upon demand to maintain ongoing eligibility for funding. G. Audit Approach Through the Region’s audit selection process, you may be contacted to complete an audit/review of GOF. The Region also reserves the right to conduct check-ins at any time to assess service provider’s actual and projected expenditures. H. Other Financial Reporting Requirements You should refer to the Service Provider Handbook, Early Years and Child Care Services Financial Annual Information Return Guideline and your EYCCS Agreements for information on the Region’s financial reporting requirements. SECTION 9: CONTACT US If you require additional information or have questions about this Guideline, please contact your Early Years Specialist or e-mail: EarlyYearsSystemDivision@peelregion.ca. 9
APPENDIX A: INELIGIBLE EXPENSES 2021 GOF Ineligible Expenses Expense Category Description 1. Staffing costs • Budgeted wage compression or a situation of pay inequity in which, as the minimum wage increases, the gap between staff paid at minimum wage and those at a more senior/experienced level decrease. • Retiring bonuses, gifts and honoraria paid to staff, staff (including Administrator or owner) travel costs, staff uniform costs, etc. • Staff not employed in a licensed child care program. • Direct payment to any person who does not receive a T4 or T4A. 2. Legislative employment • Impacts due to legislative requirements or changes in legislation during law requirements the currency of this Agreement 3. Non-arm’s length • A transaction occurs at non-arm’s length when it is between two transactions not individuals who are related by blood, marriage, common-law transacted at fair partnership or adoption. When this occurs, the transaction would market value require additional documentation to ensure it has occurred at fair market value. 4. Professional fees • Fees paid as a condition of employment such as annual membership fees for the College of Early Childhood Educators and vulnerable sector/criminal reference checks. 5. Operating costs other • Program supplies and resources than staff wages and • Nutrition and meals for children in Programs benefits • Occupancy costs (lease/property rentals and utilities) • Debt costs, payments related to capital loans, mortgage financing, tax liabilities and operating loans • Transportation of children (i.e. vehicle lease, insurance, fuel costs) • Property taxes • Repairs and maintenance • Fees paid as a condition of employment, professional organizations, franchise fees and management fees • Organization, franchise management and other fees. 6. Costs supported • Training and Professional Education, Wage Enhancement Grant, through other Region of Special Purpose, Capital, Mitigation Funding, etc. Peel funding streams 7. Generating Revenue • You cannot use GOF to generate a revenue. Federal, provincial or regional child care funding cannot be used to contribute (directly or indirectly) to service provider’s reserves, surplus, profit, and/or retained earnings, etc. as applicable. This list is not exhaustive. Any expenditures not listed under the allowable expenses section of this Guideline are non-admissible. Refer to your EYCCS General Operating Funding Agreement for a list of ineligible expenses. 10
APPENDIX B: ELIGIBLE POSITIONS General Operating Fund (GOF) General Operating Fund (GOF) 2021 GOF SUMMARY OF ELIGIBLE - Staff, Wages & Benefits - Historical (GREEN) AND INELIGIBLE (RED) Salaries Employer's Salaries Employer's Employer's Employer's POSITIONS (above Mandatory Non- (above Mandatory Non- (January 1 to June 30, 2021) minimum 1 2 Mandatory minimum 1 2 Mandatory Benefits , Benefits , wage) Benefits wage) Benefits 3 Child Care Program Staff Registered Early Childhood Educators (RECE) ✓ ✓ ✓ ✓ ✓ ✓ Supervisor ✓ ✓ ✓ ✓ ✓ ✓ Assistant Supervisor ✓ ✓ ✓ ✓ ✓ ✓ Program Staff without ECE ✓ ✓ ✓ ✓ ✓ ✓ Early Child Care Assistants ✓ ✓ ✓ ✓ ✓ ✓ Supply Staff (regular casual employment status) ✓ ✓ ✓ ✓ ✓ ✓ Permanent summer staff that work for numerous weeks each year to cover ratios ✓ ✓ ✓ ✓ ✓ ✓ Director-approved program staff (take the place of an RECE e.g. Montessori Teachers) ✓ ✓ ✓ ✓ ✓ ✓ Non-Program Staff Bus Drivers ✓ ✓ ✓ ✓ ✓ ✓ Housekeeping ✓ ✓ ✓ ✓ ✓ ✓ Cooks ✓ ✓ ✓ ✓ ✓ ✓ Special Needs Resourding Staff ✕ ✕ ✕ ✓ ✓ ✓ Janitorial staff ✕ ✕ ✕ ✓ ✓ ✓ Administrator ✕ ✕ ✕ ✓ ✓ ✓ Clerical staff ✕ ✕ ✕ ✓ ✓ ✓ Maintenance Staff ✕ ✕ ✕ ✕ ✕ ✕ Unpaid Students ✕ ✕ ✕ ✕ ✕ ✕ Volunteers ✕ ✕ ✕ ✕ ✕ ✕ Students not in a permanent position ✕ ✕ ✕ ✕ ✕ ✕ Owners/Operators who do not occupy an eligible position ✕ ✕ ✕ ✕ ✕ ✕ Fee for service contracts (including temporary staffing agencies) ✕ ✕ ✕ ✕ ✕ ✕ Notes: 1. Service Providers should seek professional financial guidance regarding employer mandatory benefit payments to staff. Additional information is available on the Canada Revenue Agency website: Employers' Guide - Payroll Deductions and Remittances 2. Only incremental employer mandatory benefit costs that result from GOF- SWB or GOF- Historical salary enhancements. 3. If previously approved by the Province Service Providers should contact their EYS if they have any questions regarding: The eligibility of a position A position not listed on this chart 11
APPENDIX C: CHANGES TO THE GOF STAFF DISTRIBUTION POLICY If you are unable to continue using your most recently approved GOF Distribution Plan methodology in 2021, you are required to: 1. Contact your Early Years Specialist as soon as you become aware of the change. Your Early Years Specialist will provide you with a GOF template change request document, if applicable. 2. Develop a transparent and equitable method of distributing the GOF amount to eligible positions. Funding may be distributed using some or all of the following categories: • Total number of hours worked or a flat amount; and/or • RECE qualifications (only recognized qualification). Note: Early Years Specialists may inform service providers on how to use their staff wages/benefits funding to ensure that the GOF outcomes are achieved. 3. Return a completed GOF template change request document and Staff Communication Letter to your Early Years Specialist. 4. Participate in a review of your GOF template change request document and provide further information as requested by the Region. 5. Review the Staff Communication Letter with all staff once your GOF template change request document has been approved. 6. Adjust staff wages and benefits according to your new approved GOF Distribution Plan. 7. Have all eligible staff sign off on the approved communication letter. 8. Submit a copy of the signed letter to the Region as part of the 2021 GOF Reconciliation Report. 12
APPENDIX D: GOF UNDERSPENDING CALCULATION EXAMPLES • Service providers that expect to have leftover GOF after distribution of funding to eligible staff as per their distribution policy may use their underspending in 2021 to offset expenses for existing base wages of program staff only, who are eligible for GOF. • Any offset to existing base wages must for wages paid above minimum wage ($14.25) and not supported through CEWS, WEG, or any components of GOF. EXAMPLE #1: Staff works for a base wage of $20.00 per hour Portion of base wage $20.00 (base wage) x CEWS at 55% = $11.00 supported through CEWS at 55% (% supported would vary by provider) Portion of base/minimum $14.25 (minimum wage) - $11.00 (CEWS portion) = $3.25 wage that must be paid by the provider Maximum of base wage $20.00 (base wage) - $11.00 (CEWS portion) - $3.25 (provider portion) = $5.75* that can be offset by GOF underspending *The provider can use GOF underspending to offset $5.75/hr of this staff wages. EXAMPLE #2: Staff works for a base wage of $14.25 per hour (minimum wage) Portion of base wage $14.25 x 55% = $7.84 supported through CEWS at 55% (% supported would vary by provider) Portion of base/minimum $14.25 (base wage) - $7.84 (CEWS portion) = $6.41 wage that must be paid by the provider Maximum of base wage $14.25 (base wage) - $7.84 (CEWS portion) - $6.41 (provider portion) = $0* that can be offset by GOF underspending *The provider cannot use GOF underspending to offset this staff person’s wages. 13
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