The subject of reimbursing families for their role as ICC
members is one that can generate intense discussion. The IDEA Part C
regulations state the following: “…the Council may use funds under this part to
– (3) Pay compensation to a member of the Council if the member is not employed
or must forfeit wages from other employment when performing official Council
business and (3)(b) Except as provided in this paragraph (a) of this section,
Council members must serve without compensation from funds available under part
C of the Act”.
First, what do you mean when you say compensating?
Some states pay ICC members who are not employed or who must
take a day off without pay from their job to perform their council duties. This
compensation is often used for families, but can also be used for providers who
provide direct services to children and their families. For families this can be the first step in
acknowledging that they too are professionals! It means valuing their time and
expertise.
O.K, but what about reimbursements?
Most states reimburse families who serve on their ICCs for
travel costs. Others cover travel and lodging if the participant must travel a
great distance for an ICC meeting. Some states still provide lunches to ICC
members—though not as many a few years ago, nowadays many ICC members pack
their own lunch or purchase one nearby.
Some states purchase train or plane tickets for families in advance,
this has a three-fold advantage, 1) families are not waiting for reimbursement;
2) tickets can be purchased in advance and staff can search for the lowest
ticket price; and, 3) families don’t risk having these costs reported on a 1099
form (see more on this below). Sometimes states use third-party
contracts—consultants or PTIs—to assist with this. This can mean that the
contractor can arrange to pay families quickly for their receipted expense or
pay for those expenses directly. These are important considerations for states
so that they can insure that all families who are interested in serving their
state have the ability and opportunity to do so.
What about childcare?
Some states do not reimburse for childcare costs due to
concerns about the state’s liability. Other states simply have families provide
a receipt that attest that they paid someone for childcare, listing the number
of children and hours paid. Other states have a maximum amount for all
reimbursement costs and families can use it to cover whatever costs they
encounter, which can remove concerns about a state’s potential liability. States
often factor in the higher rates families may have to pay for specially trained
childcare providers or nursing staff.
What do folks call these payments?
Some states call all of these payments reimbursement; others
call it all a stipend, while still others refer to the compensation as an
honorarium. The concern, for families, is that some of these payments are
reimbursements for expenses and others may be compensation. However, once a family receives any payments
above $600 they will receive a 1099 form indicating that they have received
income. For some families, who receive
Medicaid due to income, this could mean that the price of being at the policy
table might mean they might not have needed Medicaid coverage. It is important that families keep close
records on what expenses they have incurred because of their policy work, and
what payments, if any, they have received. Families may have to consult a tax
professional to insure that they are not paying taxes on reimbursements.
How do they pay parents?
Some states have forms that are due ten to thirty days after
an ICC meeting. Families must fill out,
sign the forms, and attach the appropriate receipts. And, as discussed earlier, some contractors
can pay families immediately, and file the paperwork after the meeting.
Thoughts?
Does your state ICC have a policy regarding reimbursing
families for their expenses? Is your state
doing something novel? We would like to
hear from you.
