On behalf of the Culpeper Department of Human Services (9 members), I would like to thank you for the opportunity to provide comments on the proposed state child care regulations.

Current regulation states, “The beginning date of service payment is the date the signed application is received by the local department if the family is determined eligible within 30 days and the selected vendor is approved and eligible to receive subsidy as of the date of application.” Once all required documentation is received from a participant, this regulation allows workers to authorize services from a start date that supports a family’s work or job training schedule.

The proposed regulations include changes to the begin date of Service Payments. The proposed regulation states, “Payment for services will be effective the date the applicant is determined eligible and a vendor that meets all program participation requirements is selected”.

For example, a participant provides a signed completed application on Tuesday 3/13/18 and needs childcare to start on Thursday 3/15/18. However due to a variety of circumstances beyond the applicants control, to include but not limited to:  the employer has failed to complete the verification form thus delaying the Child Care workers ability to certify the case in the VaCMS system.  Other factors that cause delay of authorization of services include VaCMS system errors and latency.

It then becomes the parent’s responsibility to cover the cost of care until these issues can be resolved.  In addition, the participant’s employment could be at risk, as they are not able to assure that they will have childcare coverage from the needed start date. The concern is that Local agencies will not be permitted, by regulations and the VaCMS system, to authorize coverage that a family qualifies for, due to various circumstances beyond their control.

The Economic Impact Analysis from July 31, 2017 states, “According to DSS, payments for retroactive time periods create some administrative difficulties. With the proposed change, the payments will start when eligibility is determined. This change will ensure that payments are not made prior to the provider’s approval and streamline the administration of payments.” Currently, The VaCMS system does not allow services to be authorized prior to a provider’s approval by the Vendor Manager. This is currently not an issue. The Impact Analysis also states, “This change will likely reduce the amount of subsidy payments by up to a month for new recipients and provide some savings or help serve the individuals on the waiting list sooner”. There is a reduction in waiting lists statewide and many localities are struggling to expend their current allocations. Localities who have waiting list are being encouraged, by the Virginia Department of Social Services, to clear them.

The Child Care and Development Block Grant Act of 2014 address ‘Family-Friendly Eligibility Policies’. The implementation of the proposed regulation, to authorize services effective with the date the applicant is determined eligible, is more restrictive than federal requirements. As well, it does not support a family’s path to self-sufficiency. It rather supports and benefits the administrative and finance processes of the Child Care Subsidy program administration.  The proposed regulation puts finance first rather than families and children and does not strengthen the Child Care Subsidy program’s role as a work support program for low-income families.

Thank you for the consideration of our comments. Please do not hesitate to contact me with any questions or if additional information is needed.