CHAPTER 6 CHILD CARE SUBSIDY PAYMENTS

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1 CHAPTER 6 CHILD CARE SUBSIDY PAYMENTS Child care subsidies in California take one of two forms. Either CDE contracts directly with the program that provides care, or indirectly with an APP, who in turn pays the providers chosen by families. See Chapters 1 and 5 for more information about this distinction. In both cases, DSS and CDE place restrictions on the rate providers may be paid with public funds for their services, and imposes conditions on providers before they can be paid with those funds. The State also defines the levels at which families can be required to share in the cost of child care services, and the amount they must pay. In sum, the State will pay up to a maximum amount for child care services provided to eligible families by approved providers. CDE and DSS have very detailed regulations on how public funds must be spent for child care services. The basic rule is that [s]tate contract funds must be spent on reimbursable costs for eligible children. 1 The extensive reporting and auditing requirements that are placed on CDE and DSS contractors are beyond the scope of this manual. For assistance please contact Child Care Law Center. VOUCHER-BASED PROGRAMS PAYMENT PROCEDURES MAXIMUM REIMBURSEMENT RATE AND REGIONAL MARKET RATE SURVEY Payment levels in the public subsidy system are linked to the private child care market through both the Regional Market Rate (RMR) survey and the requirement that providers cannot charge more to families receiving child care subsidies than they charge unsubsidized families. 2 CDE determines annually the maximum amount the subsidy system will pay child care providers for voucher- 1 CAL. DEP T OF EDUC., CHILD DEVELOPMENT ATTENDANCE AND FISCAL REPORTING AND REIMBURSEMENT PROCEDURES (2010) [hereinafter, Greenbook ], 2 CAL. EDUC. CODE 8222(a) (c) (2010). Numerous requirements are also placed on providers to ensure they are not taking advantage of the subsidy system, including submitting rate sheets to both the APP and R&R, posting rates in facilities, and limiting increases in rates for subsidized families to only once per year. CAL. EDUC. CODE 8222(d) (g) (2010). APPs are responsible for verifying the information submitted by providers. CAL. EDUC. CODE 8222(h) (2010). 95

2 Chapter 6: Child Care Subsidy Payments based care through the RMR survey. 3 The survey determines the market rate based on geographic location (county); type of child care setting (centers, family child care homes or license exempt); the amount of care provided and payment schedule (full or part-time, monthly, weekly, or daily); and the ages of the children served (infants, preschool, and school-age). Child care providers who receive subsidies are paid the rate they usually charge for unsubsidized families, up to a maximum known as the reimbursement ceiling. Reimbursement ceilings are set as a percentage of the RMRs in each county, 4 and are currently set at the 85 th percentile of the RMR for providers in the county offering the same type of child care for the same age child. 5 These ceilings are designed to control state costs for subsidized care while allowing families access to the vast majority of local providers. 6 A reimbursement rate that exceeds the ceiling may be used only when no more than two child care providers in a region care for children of families with child care subsidies. 7 For license-exempt child care, no survey is conducted to establish the regional market rate; instead, the license-exempt rate has been set at 90% of the reimbursement ceilings for family child care home providers. 8 As discussed in Chapter 5, the reimbursement rate for license-exempt child care is often lower than the minimum wage. 9 The current CDE reimbursement rate ceilings are available on the CDE website at: C.F.R (b)(2) (requiring a market rate survey at least every two years); CAL. EDUC. CODE 8265,.5 (2010); 5 CAL. CODE REGS (e); MPP CAL. EDUC. CODE 8266, (2010); 5 CAL. CODE REGS (a), 18413(a), 18428(a). See also CAL. EDUC. CODE 8357(a) (2010) (detailing CalWORKs child care Regional Market Rate issues). 5 MPP ; MB 06-16; CAL. DEP T OF SOC. SERVICES, ACL 06-29, CHANGES TO IN/OUT OF MARKET RATES, 75/25 RULE, STATE MEDIAN INCOME (SMI) AND FAMILY FEE SCHEDULE (2006), 6 CAL. EDUC. CODE 8357(a) (2010); MPP CAL. CODE REGS (c); MPP CAL. CODE REGS (b). For a copy of the Regional Market Survey of California Child Care Providers, contact the Child Care Law Center. 9 CAL. DEP T OF EDUC., REIMBURSEMENT CEILINGS FOR SUBSIDIZED CHILD CARE (2006), (In 2010, in Los Angeles county, part-time hourly care for a child six years old or older being cared for by an exempt child care provider is compensated at a rate of $3.36 per hour.). 96

3 Child Care Subsidies in California FACTORS CONSIDERED IN ESTABLISHING THE MAXIMUM REIMBURSEMENT RATE California law establishes payment levels for subsidized child care based on a variety of factors, and includes adjustments for special circumstances described below. In addition to the factors used to establish the Regional Market Rate (geographic location, type of setting and age of children served), the maximum reimbursement ceilings for voucher-based child care subsidies can vary depending on the following factors: Number of hours of care; The time that care is needed (e.g., during the day, or on evenings or weekends); and Whether the child has exceptional needs or is severely disabled. 10 MAXIMUM REIMBURSEMENT CEILINGS FOR SUBSIDIZED CARE HOURS OF CARE The maximum reimbursement rate depends in part on the number of hours of care provided. Care may be provided by the hour, day, partial week, full week, partial month, or full month. 11 Full-time monthly rate is used when the child receives over 30 hours of care per week for a month, and care occurs every week in the month. 12 Part-time monthly rate is used when the child receives hours of care per week, and care occurs every week in the month. 13 Full-time weekly rate is used when the child receives more than 30 hours of care per week, but not necessarily for a whole month. 14 Part-time weekly rate is used when the child receives hours of care per week, on at least 3 days per week. 15 Daily rate is used when a child receives six or more hours of care on three or fewer days per week, or, under some circumstances, when a parent has an unscheduled need for child care for more than six hours per day per occurrence. 16 Hourly rate is used when a child receives no more than six hours of care on any day and no more than 15 hours in the week, or, under some 10 5 CAL. CODE REGS CAL. CODE REGS CAL. CODE REGS (f) CAL. CODE REGS (e) CAL. CODE REGS (d) CAL. CODE REGS (c) CAL. CODE REGS (b). 97

4 Chapter 6: Child Care Subsidy Payments circumstances, when a parent has an unscheduled need for child care for six hours or less per occurrence. 17 The hourly rate is also available to pay for the portion of child care services that exceed 52.5 hours per week and is not included in the provider s full-time weekly or full-time monthly rate. The hourly rate may be used under these circumstances only if the family uses a single child care provider to meet the entire child care need. 18 Ordinarily, providers are compensated on the basis of a single rate category, unless using more than one category results in a lower payment. 19 CARE OFFERED DURING NON-TRADITIONAL HOURS For licensed providers who offer evening or weekend care, an adjustment increases the maximum payment ceiling for full-time weekly, and part-time or full-time monthly child care services under the following circumstances: When a child receives care between 6 p.m. and 6 a.m. on weekdays or anytime on weekends, the provider s usual payment rate is multiplied by 1.25 when more than 50 percent of the need for care occurs during this period. 20 If more than ten percent but no more than 50 percent of the care occurs during this time, the provider s usual payment rate is multiplied by It is often complicated to determine the appropriate reimbursement rate category, especially for low income families whose need for care differs from traditional work hours and varies from week to week. 22 CARE FOR CHILDREN WITH DISABILITIES A rate adjustment applies to child care services provided to children with exceptional needs, and a larger rate adjustment applies to services for severely disabled children CAL. CODE REGS (a) CAL. CODE REGS (a)(3) CAL. CODE REGS CAL. CODE REGS (b)(1) CAL. CODE REGS (b)(2). 22 MPP ; 5 CAL. CODE REGS

5 Child Care Subsidies in California CHILDREN WITH EXCEPTIONAL NEEDS For children with exceptional needs, the provider s usual payment rate is multiplied by California law defines children with exceptional needs 24 as: Infants and toddlers (0 through 36 months), who have been determined eligible for early intervention services pursuant to the California Early Intervention Services Act; 25 and Children (3 through 21 years) who have been determined to be eligible for special education and related services by an individualized education program team. 26 In order for the provider to receive the exceptional needs adjustment to her usual rate, the child(ren) must have an active individualized family service plan or individualized education plan, must be receiving early intervention services or appropriate special education and related services, and must have specific disabilities and require the special attention of adults in a child care setting. 27 In addition, the increase to the caregiver s rate is permitted only when there is documentation that the additional services and/or accommodations are being provided for the particular child with exceptional needs, and such services and/or accommodations result in an on-going financial impact on the child care provider. 28 Note that the laws protecting people with disabilities, such as the Americans with Disabilities Act (ADA), Section 504 of the federal Rehabilitation Act, and California s Unruh Civil Rights Act, generally prohibit providers from charging unsubsidized families a higher rate for providing care for their child(ren) with disabilities. 29 The underlying policy encourages providers to distribute any additional costs of providing care for a child with a disability across all of the families that pay for child care services. The legislature has determined that public policy encouraging providers to serve subsidized children with exceptional needs favors the state paying an increased rate to those 23 5 CAL. CODE REGS (a)(1). 24 CAL. EDUC. CODE 8208(l) (2010). 25 CAL. GOV T CODE 9500 et seq. (2010) CAL. CODE REGS et seq. 27 CAL. EDUC. CODE 8208(l) (2010). Children with special needs include children with mental retardation, hearing impairments (including deafness), speech or language impairments, visual impairments (including blindness), serious emotional disturbance (also referred to as emotional disturbance), orthopedic impairments, autism, traumatic brain injury, other health impairments, or specific learning disabilities 28 5 CAL. CODE REGS (b) U.S.C (2010); CAL. CIVIL CODE 51(b) (2010); See CHILD CARE LAW CENTER, CARING FOR CHILDREN WITH SPECIAL NEEDS: THE AMERICANS WITH DISABILITIES ACT (ADA) AND CHILD CARE (2003) (Contact Child Care Law Center, [email protected] for a copy of this publication). 99

6 Chapter 6: Child Care Subsidy Payments providers, since the subsidy is comprised of public funds contributed by all taxpayers. Please contact Child Care Law Center, with questions about the application of the rate adjustment for children with exceptional needs or severely disabled children. SEVERELY DISABLED CHILDREN Children who are severely disabled qualify for an adjustment rate of California law defines severely disabled children as: Children with exceptional needs (birth through 21 years) who require intensive instruction and training in programs serving pupils with the following profound disabilities: autism, blindness, deafness, severe orthopedic impairments, serious emotional disturbances, or severe mental retardation; and Individuals who would have been eligible for enrollment in a developmental center for handicapped pupils on January 1, As with children with exceptional needs, the extra payment rate for severely disabled children is provided only when there is documentation that additional services and/or accommodations for that particular child are being provided, and such services and/or accommodations result in an on-going financial impact on the provider. 32 METHOD OF PAYMENT FOR VOUCHER-BASED CARE DIRECT PAYMENT TO PROVIDER Generally, payment for CalWORKs child care is made by the CWD/APP that administers the subsidy directly to the licensed child care provider. 33 In the case of in-home license-exempt child care, California law allows agencies administering child care subsidies to pay the CalWORKs parents, who are expected to use the subsidy to pay their child care provider themselves. 34 See Chapter 5, for a discussion of employment law issues and information about payment for license-exempt child care. DSS regulations allow providers to be 30 5 CAL. CODE REGS (a)(2). 31 CAL. EDUC. CODE 8208(y) (2010) CAL. CODE REGS (b). 33 CAL. EDUC. CODE 8357(e) (2010). 34 CAL. EDUC. CODE 8357(e) (2010) (stating that if care is provided in the home of the recipient, payment may be made to the parent as the employer, and the parent shall be informed of his or her concomitant legal and financial reporting requirements). 100

7 Child Care Subsidies in California paid in advance of providing the child care, or afterwards, 35 but the standard practice of CWD/APPs is to pay providers in arrears. PAYMENT FOR ABSENCES AND HOLIDAYS AND USE OF ALTERNATE PROVIDERS In all child care subsidy programs, the law recognizes that some special situations demand extra payments for care. DSS CHILD CARE PROGRAMS In CalWORKs Stage 1 child care, at county option, providers may be paid for care during excused absences of the child or parent. 36 Excused absences may include family emergencies, court appearances, a child s illness, or other circumstances. 37 Payment for excused absences may also include payment to a provider who has a policy of payment on a fixed schedule, whether the child attends or not. 38 Some CWDs continue to pay for Stage 1 child care while the parent is between welfare-to-work activities, particularly if the parent will otherwise lose their licensed child care provider. CDE CHILD CARE PROGRAMS In CDE child care programs, when a child is absent the provider should still be paid if the provider has a contractual policy of requiring unsubsidized families to pay for absences. 39 Up to 10 holidays per year are also compensated if the provider has a contractual policy that requires unsubsidized families to pay for holidays. 40 Alternate providers may be used by a subsidized family and paid for child care services if the regular provider has a paid holiday or if the child is ill. 41 Subsidy payments may not be made for hours a child is attending school. 42 DELAYED OR LATE PAYMENT CDE regulations require APPs to have a plan for timely payment of child care providers. 43 Although there is authority for requiring CWDs/APPs to pay 35 MPP MPP MPP MPP CAL. CODE REGS (b)(1) CAL. CODE REGS (b)(2) CAL. CODE REGS (c) CAL. CODE REGS (d)(1) CAL. CODE REGS

8 Chapter 6: Child Care Subsidy Payments providers in the same manner (weekly, monthly, etc.) as providers require payment by their unsubsidized families, 44 in practice, CWDs/APPs determine their agency payment schedule and pay providers in accordance with the agency s schedule. Some CWDs/APPs pay providers semi-monthly, while most issue payments on a monthly basis. It should be noted, however, that CWDs/APPs almost always pay in arrears for services, even if the provider requires unsubsidized families to pay in advance. Many providers face the problem of delayed or late payments by the CWD/APP. Delayed payments are those made after care is provided, and often the following month, but on schedule with the APP s payment plan. Late payments are those made after the scheduled date for payment. Frequently, CWDs/APPs withhold payments to providers due to the actual or alleged failure of parents or providers to submit the requisite child care time sheet and other documentation to the CWD/APP on a timely basis. Parents and providers often complain that CWDs/APPs misplace documentation that has been provided and unnecessarily delay payment. Late payments are problematic for providers who tend to be small business owners, often with no source of income other than child care. Child care providers do not have the right to challenge DSS, CDE or APPs child care subsidy decisions that affect them such as late payment, termination of a subsidy, or an incorrect payment amount. When there is a dispute between the provider and the CWD/APP regarding payment, there is no formal mechanism for resolution available to the provider as a CWD/APP contractor. 45 The first option is to use the APP s informal, internal grievance process which APPs are required to have available for providers. 46 Another alternative is to file a small claims court action against the subsidy recipient. In addition, the parent receiving the subsidy can file an appeal on behalf of the provider when late payment of the provider jeopardizes the family s child care, though there is some question whether this option is available to families under CDE regulations if no Notice of Action has been issued to the family. 47 Please contact Child Care Law Center for information, [email protected]. 44 CAL. EDUC. CODE 8222 (2010) ; CAL. DEP T OF EDUC., MB (1999). 45 The only option available to providers is the APP internal grievance process, which all APPs are required to have in place. 5 CAL. CODE REGS (c) CAL. CODE REGS (c). 47 MPP ; 5 CAL. CODE REGS (a). 102

9 Child Care Subsidies in California RETROACTIVE PAYMENTS See Chapters 2 and 5 for discussion of retroactive payment policies. CONTRACTED PROGRAMS PAYMENT PROCEDURES Both the general rules and the payment methodology that apply to contracted child care programs are very different from the rules and payment methodology for voucher-based programs. STANDARD REIMBURSEMENT RATE Contracted programs are compensated based on the number of children they serve and the number of days that child care services are provided. The payment rate is called the Standard Reimbursement Rate. 48 The California budget of establishes this rate as $34.88 per child day of enrollment, or $8,595 per annum based on 250 days of operation. 49 Reimbursement rates for contracted programs are adjusted based on the following factors: The number of hours per day the child is in care. 50 The age of the child, with separate rates for infants and toddlers. 51 Whether the setting is a child care center or family child care home education network. 52 If the child has exceptional needs or is severely disabled. 53 If the child is at risk of neglect, abuse, or exploitation. 54 If the child is limited-english-speaking or non-english-speaking. 55 FAMILY FEES AND CO-PAYMENTS Family fees and co-payments are two separate types of payments that parents receiving subsidized care may have to pay. Parents are charged a family fee as their share of the cost of care, based on their income and family size. Parents are 48 CAL. EDUC. CODE 8265, (2010); 5 CAL. CODE REGS , CAL. EDUC. CODE 8265(b) (2010); State Budget Act of 2007, item , provision CAL. EDUC. CODE (2010). 51 CAL. EDUC. CODE (b)(1)-(3) (2010). 52 CAL. EDUC. CODE (b)(1)-(3) (2010). 53 CAL. EDUC. CODE (b)(4)-(5) (2010). 54 CAL. EDUC. CODE (b)(6) (2010). 55 CAL. EDUC. CODE (b)(7) (2010). 103

10 Chapter 6: Child Care Subsidy Payments required to pay a co-payment only if the family chooses a child care provider who charges more than the maximum reimbursement rate. A family will have to pay both a family fee and a co-payment if the family s income is high enough to require a family fee and the parents choose a child care provider who charges more than the county s reimbursement ceiling. CO-PAYMENTS In CalWORKs Stage 1, a co-payment is the amount the client is responsible to pay, if she or he chooses a child care provider who charges a fee higher than the maximum child care subsidy payment rate. 56 Similarly, in CDE child care programs, a family that chooses child care that costs more than the maximum reimbursement ceiling must pay the extra as a co-payment directly to the provider. 57 CWDs/APPs are not required to monitor or ensure that parents actually pay co-payments to their selected providers. EXAMPLE: Maria and her 3-year old son live in Contra Costa County. The maximum amount the subsidy system will pay for full-time care in a family child care home in Contra Costa County is $ per month. 58 Maria chooses a provider who charges $ per month. Maria must pay a co-payment of $100 per month, the difference between the amount her provider charges and the subsidy reimbursement rate ceiling. 56 MPP (c)(2), (f)(1), CAL. CODE REGS (a), (b) (which does not use the term co-payment but is clear in its meaning: a family may choose a child care provider that charges more than the maximum the subsidy will pay, but in that situation, the family is responsible to pay the difference between the rate charged by the provider and the maximum payment rate). See also 5 CAL. CODE REGS (a)(4) ( The fee assessed and collected shall be either the fee indicated on the fee schedule, the actual costs of services or the contract maximum daily/hourly rate, whichever is least. ); 5 CAL. CODE REGS (b) (Stage 2), 18429(b) (Stage 3). 58 DEP T OF SOC. SERVICES, ACL 09-13, UPDATE TO ACL AND CHANGES TO INSTRUCTIONS REGARDING THE RMR PAYMENT CEILINGS AND FAMILY FEES (2009), CAL. DEP T OF EDUC., REIMBURSEMENT CEILINGS FOR SUBSIDIZED CHILD CARE (2009, effective 10/1/06), 104

11 Child Care Subsidies in California FAMILY FEES A family fee is a share of the cost of care that gradually increases as a parent s income increases. Family fees are calculated pursuant to a graduated fee schedule established by the CDE, based on the State Median Income (SMI) for all subsidized childcare. 59 The fee schedule takes into account the family's income and the family size to determine whether a fee must be paid at all and, if so, the amount of the fee. 60 Family fees may be charged whether the family is receiving subsidized child care through a voucher-based or a contracted program. Families begin to incur fees when their incomes reach slightly below 40 percent of the SMI; 61 the fee amount increases as the family s income grows. 62 EXAMPLE: Mrs. Garcia has 2 children. Her monthly income is $1,950. Based on the CDE fee schedule,, her family fee is $2.00 per day for full-time child care. If her monthly income increased to $3,628, her family fee would be $17.25 per day. 63 California law does not state definitively who must collect the family fee. Instead, each CWD/APP must determine the method of collection. Many agencies take responsibility for collection of family fees from parents, but others deduct the family fee from the provider s payment and require the child care provider to collect the fee from the parent. 64 This arrangement can lead to problems, creating tension between parents and providers, or leading the provider to forego fees because of the burden it places on low income families. 59 CAL. EDUC. CODE 8263(f), (a) (2010); 5 CAL. CODE REGS , 18414, 18429; MPP (Stage 1); CAL. DEP T OF EDUC., MB 06-16, CHANGES IN LAW AFFECTING ALTERNATIVE PAYMENT PROGRAMS AND FAMILY CHILD CARE HOME EDUCATION NETWORKS UTILIZING THE REGIONAL MARKET RATE CEILINGS. Federal law does not prohibit the charging of family fees, but it does recommend reasonable restrictions so family fees do not exceed 10% of a family s income. See 63 Federal Register 39,960; 45 CFR (fees should be affordable and should not impede access to child care). 60 CAL. EDUC. CODE 8263(e), (f) (2010); MPP (c)(2), (f)(1); CAL. DEP T OF EDUC., MB 06-19, REVISED CHILD CARE AND DEVELOPMENT FEE SCHEDULE EFFECTIVE JANUARY 1, (2006), [hereinafter MB 06-19]. 61 MB See the Parent Voices website for information regarding that organization s efforts to keep family fees affordable, 63 MB CAL. CODE REGS (h),

12 Chapter 6: Child Care Subsidy Payments Families should always ask for and retain a receipt when they pay their family fees, whether to the CWDs/APPs or directly to their provider. 65 FAMILY FEES FOR CALWORKS CASH AID FAMILIES In general, because the countable income level of most families receiving CalWORKs cash assistance is so low, families do not meet the income level that would require them to pay a family fee. However, because of differences in the way DSS and CDE count income, some CalWORKs cash aid families receiving CalWORKs Stage 2 child care were required to pay family fees. In many of these families the parents were students, or only the children were receiving cash assistance. Legal services advocates recognized that forcing these families to pay family fees was inconsistent with welfare-to-work rules that require counties to provide necessary supportive services (not to mention, nonsensical and detrimental), and brought the issue to the attention of legislators. In October 2008, the law was changed to prohibit the charging of family fees to CalWORKs cash aid families. 66 CDE and many of its contractors were unhappy with this provision, and worked to reverse it, but were unsuccessful. Finally, in September 2009, CDE issued a Management Bulletin to its contractors informing them of the prohibition on charging family fees to cash aid families 67 and DSS issued an All County Letter with similar information to its CWDs. 68 At this point, no CWD or APP should be charging a family fee to a cash aid family; if you become aware of a situation in which fees are being charged, contact the Child Care Law Center. TERMINATION FOR NON-PAYMENT OF A FAMILY FEE Families using subsidized care with a contracted center are delinquent in paying fees after seven days from the date the fees were due. Families with voucher-based subsidies are delinquent in paying fees on the date their provider 65 5 CAL. CODE REGS (a). 66 CAL. EDUC. CODE 8447(g) (2010). 67 CAL. DEP T OF EDUC., MB 09-18, CHANGES IN LAW AFFECTING CHILD CARE AND DEVELOPMENT PROGRAMS. "Effective immediately contractors should no longer be charging a family fee for child care service to families in which any member of the family is receiving CalWORKs. Contractors will continue to assess family fees for former CalWORKs cash aid recipients. However, for families who continue to receive a CalWORKs grant on behalf of the children, such as safety net and sanctioned families, a family fee will not be assessed. 68 DEP T OF SOC. SERVICES, ACL 09-57, CALWORKS PROGRAM UPDATES REGARDING THE REGIONAL MARKET RATE, RESTRICTIONS TO THE DAILY RATE REIMBURSEMENTS, STATE MEDIAN INCOME, AND FAMILY FEES (2009). 106

13 Child Care Subsidies in California notifies the APP that fees have not been paid. 69 Families that are late in paying their family fee should not be immediately terminated from subsidized child care. Rather, the CWD/APP must inform the family about the effect of nonpayment of fees via a Notice of Action (NOA). The notice must include: The total amount of unpaid fees; The fee rate; The period of delinquency; that is, how late the payment is; and The fact that child care services shall be terminated two weeks from the date of the NOA unless all delinquent fees are paid before the end of the two-week period. 70 The agency administering the subsidy must work with the family and attempt to schedule repayment of the delinquent fees, and must accept a reasonable plan from the parents for payment of delinquent fees. 71 However, the CDE regulations are not clear as to whether the NOA must inform the family of the fee repayment plan option. The contractor must continue to provide services to the child(ren) so long as the parent(s) pays current fees when due and complies with the provisions of the repayment plan. 72 If the family fails to pay the family fee even after this reconciliation process, the subsidy can be terminated, and the family will be ineligible for a child care subsidy until all delinquent fees are paid CAL. CODE REGS (b),(c) CAL. CODE REGS (d) CAL. CODE REGS CAL. CODE REGS CAL. CODE REGS , (Stage 2), (Stage 3). 107