I am ecstatic about most of these changes, since we will finally be prioritizing education and stability in a child's life, instead of focusing on the activities of parents and testing the resiliency capabilities of children.

However, I am extremely concerned by this portion of the proposed law (emphasis added):

I. The eligibility period for TANF (nonVIEW), transitional child care, Fee Program, and Head Start begins with the effective date of the approval of the child care subsidy and services application. The eligibility period for VIEW and SNAPET participants begins with the date of referral from the VIEW or SNAPET program.

I fear that this has the potential to have a disparate impact on the families that we serve in addition to putting unnecessary additional pressure on all child care workers.

If found eligible, all other programs offered through DSS have an effective date as the date that a signed application is received by the agency (Social Security benefits and every other government program that I can think of also follows this principle, regardless of differing processing time frames).  Under this proposed change, however, not only would the same application be treated differently depending on the budget line that would be used, but also clients will now be at the mercy of their assigned worker’s work schedule, work load, and possibly prejudices and work ethic, instead of a consistent and equitable policy.

As an example, If a grandparent receives custody of a grandchild and applies online for Medicaid, TANF, and Child Care on the same day, the child care worker must wait until the Eligibility worker approves the TANF before we can approve TANF (nonVIEW) child care (grandparents are usually over income if we processed prior to TANF being approved).  Both Eligibility and Child Care workers have 30 days to process our respective applications.  If this change were to occur, not only will we continue having to be at the mercy of EWs processing their application first (typically it’s after the 20th day), the grandparents would now be responsible for paying out of pocket until the child care worker is able to process the application (usually very close to the 30th day). If all of this is to avoid manual attendance sheets, perhaps a better idea is to allow local agencies to issue eppic cards.  I think that would remedy much of the problems without having a negative impact on the clients that we are supposed to serve and help reach self sufficiency.

I implore you to reconsider this portion of the proposal.