Good Afternoon,  I am a Supervisor of child care in our county and we have very few vendors for this program.  It is a great program for people working and needing help.  It is crazy that I as a tax payer for the state are paying for child care for people to job search, when working people could be left out due to limited space.  I understand the concept, but people are using this as baby sitting and have no intention of finding a job.  As was stated in the email there should be structure and time limits to this.  How long should child care be provided for someone to job search.  Everyone is hiring, if you want a job you should be able to find one in a couple of months max.  I would ask that you consider changing this policy.

Carolyn

I am a childcare worker and have noticed the following issues with current guidelines.  

1. Job search.  I completely understand allowing job search as a valid need to CC; however, there should be some regulations with this.  I have parents who are not working, and have not worked since receiving the care over a year ago - yet they still claim they are doing a job search.   At the least: at redetermination if the parent is not, nor has not worked in the past 12 months, the need of job search is should no longer be valid.  If they've worked, but lost that job and in another job search, that would be acceptable.  The problem is spots for children at the centers.  Parents who are working are not able to find spots for their children.  
2. Increased income limits.  This should not be limited to families with children under 5 or not yet in Kindergarten.  Parents with school age children need after care and care on the many, many non-school days (teacher work days, inclement weather days, holidays and summer).  Many times these 5, 6, 7 year old children are "being cared for" by a 11, 12, 13 year old sibling; or worse, going home to an empty house 'for only 20- 30 minutes".  This is just not acceptable.  

Please take these two items in consideration in future policy.  

After reading over the document I did not see when the proposed new rates will be determined. Also I think a vendor should be able submit an adjustment of rate form twice a year instead of just annually. My company has had to raise tuition twice this year just to keep up with inflation in the Northern Virginia region. This means parents who may not have had an AMR now will for the remaining part of your cycle. I also think there needs to be some consideration of changing the attendance tracking policy. Most childcare fairies bill out on a weekly basis, so the need for a parent to swipe everyday seems tidius. Especially for families with multiple children. Please consider paying vendors based on monthly enrollment rather than attendance.

I applied for the subsidy childcare program for our three children,
ages 6, 3 and 1. We were told that we missed the cutoff for childcare assistance by $350.00. As you can imagine, this is very disheartening and disappointing to our family of five. My husband and I both work full time jobs, pay our bills, are involved in our community, church and are upstanding citizens. We are trying to make ends meet, provide for our children, and set an example of what hard working Americans look like. Middle class is no longer middle class. There are also other factors that go into not being able to afford childcare such as insanely high medical bills that we endured last year. Between the repercussions of medical bills mixed with raising childcare prices, inflation with our income NOT reflecting the cost of living these days, you can imagine we’d like the same opportunities to have childcare help! It’s unfair that because we make $350 over the “limit”, we are not eligible or allowed to have help. There has to be something you can do to reconsider us hardworking families that are trying to best by our children, live paycheck to paycheck and barely make ends meet . 

Considering that the state has put a hold on the VA Quality rating program in exchange for VQB5, it would be ideal for the following portion to reflect the new & current program vs. one that vendors can no longer participate in (and have not been able to for some months now). 

Through September 30, 2024, tThe Department will pay more than the established MRR to vendors participating in the Tiered Reimbursement Pilot. The Pilot includes child care providers who have achieved a 4 or 5 Virginia Quality Level. Each child enrolled in those programs, birth – 5 years, will be eligible to receive a 7% tiered rate add-on to their payment  

Hello! I am the President of a religious exempt facility. Our area is an EXTREMELY low income area, and with getting a minimum reimbursement simply because we are an exempt facility, it’s not fair to parents. Here’s why - we charge $200 per week and get roughly $125 per week, leaving parents o have to cover the remaining $75 and the enrollment fees of $110. I realize I hat we could reduce our rates, however, that would cause us to pay staff members minimum wage, which would cause major turnover and continue the low income cycle. Religious and campy facilities that are DSS providers have to maintain much of the same regulations as fully licensed facilities do, so there should be no reason to put religious demon facilities in a different tier than other licensed facilities. Please consider maintaining the same rates for exempt facilities as you do other licensed facilities. Thank you.

Upon enrollment parents will indicate part-time or full-time and children are enrolled based on parents choice.  Most child care centers have weekly rates not daily.  If a child is enrolled FT - then the weekly tuition should be paid in full for the week and based on space being held not attendance. More absents days should be allowed (especially while we’re still in this pandemic). We offer an affordable rates but it’s a little difficult to get paid if absents are exceeding the limit because families uses their absents up due to covid.  Please consider more absentee annually.  As well as paying child care based on weekly cost not daily swipes.

I am an owner of a center in far southwest VA. First off I have to say THANK YOU as I am happy that there will hopefully be an increase in subsidy pay to meet the cost of the actual spot. This will help with teacher incentives, pay raises, additional staffing to cover when other staff calls out, etc., 

However, I would hope that you could do a system much like NC where the center director  inputs the child's attendance into the computer system and then the center is paid a weekly rate for the spot being held versus daily swiping. A lot of parents lose their cards, forget to mark absences, don't find the time to swipe, etc., I feel more like a warden tracking these families down to swipe daily or catch up on swiping then anything else. 

I also agree with many comments about job search and such. It needs to be limited to one to two months of job search depending upon the current job market. Currently there are jobs everywhere so I think one month is more than fair. 

I like the set family co-pays as well because it makes it easier on me when doing the billing side of things to know it is just one of so many options instead of 1001 variables. 

I was very worried about having to get self pay parents to pay the same rate and am relieved that at this moment it will not be required. 

The yearly registration fee should be increased to $125.00. 

Christmas Eve and New Year's Eve should be a paid holiday.

Parent Code of Conduct should be instilled. 

Thank you for upping the amount paid for infants and toddlers.  However, the 2 year old rate is just too low. You have set the State ratio for 2 year olds at 1:8 (and we keep our younger 2's at 1:6), however, we are paid as if they are a 1:10. Our 2 year olds pay $75-$95 overmarket a week, while infants and preschoolers will only be $45 a week this year.  Rates need to be based on ratio.  There is a big difference between a 2 year old and a 5 year old.

First of all, thanks so much for the increase.  I have a few suggestions; first it is very challenging to get parents to swipe in and as a director I spend a lot of time trying to monitor this so that we can get paid.  I would suggest providers get paid per enrollment and not per attendance/ swipes. Also we close our center for vacation two weeks a year (once in summer and once in winter) I believe this is necessary to avoid staff burn out, so that we can provide quality care, I believe providers should not have to lose pay when we are closed for vacation; and families should not have to take on that charge because they may have to find someone else to care for their child.  

I also believe the annual registration fee should be increased to at least $150 as that fee is typically used for annual books and supplies needed to provide high quality care.

The fee should be increased for all ages; it looks as if there isn’t an increase or a minimum increase for children 2 and older.  Why?  We are still providing quality care to them and still need staff and everything else for them.  

I also believe that before and after school rates should be full time rates because we have to reserve a slot for those children and hire full-time staff for them.   It is much appreciated what you have done and it would be nice to just fixed this all once ain’t for all right now 

I want to acknowledge that the increase in rates is going to make a significant impact for a lot of programs and a lot of families. I'm grateful that this is happening. At the same time I'm concerned about the number of programs that participate in this subsidy and the bureaucratic challenges that prevent programs from participating. This document downloaded as a PDF is over 200 pages. We must do better to make this content navigable.

I think the move towards increasing eligibility to include job search is wise and I think everyone deserves high quality early childhood education so there's no reason to limit the time period in which an individual has to job search. It is essential that we continue to allow for more out of school days as 15 days barely provides the holiday allotment leaving very few professional development days which are essential to high quality care.

Additionally we need to continue to push towards a more predictable funding stream. I would go further than those on this comment who advocate for weekly rates and advocate instead for a monthly rate. High quality programs need to be able to be able to have predictable income in advance of providing services to pay teachers so that those services can be provided. 

The quality of training for early childhood educators needs to be addressed. No required trainings are useless and I don't believe the move to adjust trainings in this document is adding value. I am concerned that the VQB5 is just another failed attempt to improve quality by focusing on the academics at the cost of care which is essential to the well-being of young children.

I think if I were to say my biggest priority of all of this would be as I said first. Focus on brevity I know it is rarely a goal in the regulatory context but it would increase accessibility and be immensely helpful to existing providers as well. 

Good Afternoon!

There are three changes that I feel are necessary to offer all Virginia's access to quality child care.

1. Individuals determining eligibility are looking at gross income, not take home income.  This can be a significant difference.  Families may qualify if a worker looked at net income instead of gross income.  My suggestion is to mirror this with SNAP benefits where each family is allowed a standard deduction off their gross pay.
2. The definition in the Guidance manual for job search is "a structured, time-limited period during which the participant is required to search for and/or obtain employment".  What is the time limit period? An individual can self-certify they are job searching and receive essentially free child care based on the fact they have no income.  At redetermination, they certify again they are job searching and get essentially free child care for another year.  Where are the time limits?  A person is required to search for and/or obtain employment.  There is no checks or balances, just a word that I am job searching.  A person does not have to provide any type of verification they are job searching.  Where is the accountability?  
3. Expanded eligibility only applies if a family has one child who is five years of age or younger and has not yet started kindergarten.  A family who is over the initial income limit would still qualify, if and only if, they are under the 85% SMI and have a child under 5.  No child younger than 5 and over the initial income limit, sorry, you don't qualify.  How is this fair?  To me, this is discrimination against families who have children older than five.

Thanks for you time, energy, effort and all you do behind the scenes for the program!

The job search eligibility factor should me more closely monitored. Many families who are employed or in school are having difficulty finding space available for their children, and thus their application is denied. Jobs are available everywhere we look- there is no legitimate need for a parent to have access to 12 months of child care and have no employment at the end of that period, then be eligible again for another 12 months, and so on. Why not have a 90-day eligibility period for job search like we do for homelessness? At the end of 90 days, the parent  must submit employment verification or the case closes. At the same time, now that children are in school, why would a parent need before and after care for job search? The time they have while the child is in school is adequate time for the parent to apply for jobs, interview, etc. I think the state has their eligibility requirements crossed- job searching parents with school-age children should not be eligible, while working parents with children in school should be eligible for the income exception even without a child under 5 years old. Please consider additional changes.

I applaud the efforts in increasing rates throughout our area. What I don’t understand is how there is not an increase in the 810 area for children that are 2 and up.  

We spend more than 10 hours a day with these children ( some 12+ hours) teaching, educating, training, potty training, etc on a daily basis and we are rarely able to increase our rates (once every 4-5 years, if that).   Only to have childcare workers tell their clients they are able to utilize care up to 12 hours a day.  Where does anyone else in the country or state work at for 12 hours a day, and 5 days a week without being paid overtime.  Can we get any lawmaker to tell us that they work 60 hours a week with 20 of those considered overtime but you are not paid time and a half.   And they wonder why educators are burned out and pay is so little.  

In addition, the care we provide for school children including transportation fees to and from schools. At what point in the true cost estimator calculator were these fees added.   So we are to just take an additional loss of gas, bus maintenance and expenses because parents feel this fee is included in weekly tuition rates which again have not been increased.  

On top of this, to see that home providers are being paid more than Centers for these same children sound ludicrous especially seeing that a center has more exposure, expenses, payroll, everything is much higher than home based providers.   This is coming from a provider with 30 yrs experience throughout several states with both a home based and center based background. 

If it wasn’t for the love of the children., I would say it’s time to walk away. 
we want quality, but no one truly wants to pay for it.  
Advocacy I’m on my way 

I would like the job search to be eliminated as currently there are many job openings and the economy is prosperous. Keeping job searching as an approved activity, we are encouraging parents to stay at home while we are paying for daycare and take funding from parents who actually work and are in need of childcare. I had stay-at-home moms telling me that their friends told them they can just say they are searching for a job and they qualify for childcare, when they in fact have no intent to look for a job but they are lying. Also, the income limit is excessively high. Please lower it to what it was prior to covid. Thanks for your consideration!

Weekly tuition should be paid in full to a provider.  It is impossible to operate on a day to day  
attendance.  Especially once absents are limited to 36 a year and the parent have used them all.  At that point if the child have used all the absents and miss a day or all week - we do not get pay but must hold their spot not know when they will return.  Non working parents are not consistent with using the service and should be reevaluated for continuous of service - if they go a lengthy period not utilizing the service.

please consider paying by the week for the space a child is enrolled for vs daily attendance.

please consider more absentee days annually.

please consider we are not back to normal, and although kids are enrobed they are not always in attendance due to COVID, non working parents who pick and choose when they want to use the service.  Yet we still have to hold their spot - because DSS will not close the case during this pandemic.

The staff is working hard trying to adjust to this new curriculum  and if $ is coming in because parents have used up all the absents - we can afford to pay the staff their worth for the new trainings, new adjustments, and extra work we are asking from them to meet the requirements of VDOE.

This is a financial burden on the business as we are experiencing this as I type.  Parents have used up there absents, have missed days and we can not get paid but yet they can walk back in after a week or 2 of no communication and no tuition payment from neither the parent or DSS.

After observing the effects of expanded eligibility for over a year, the most noticeable outcome observed is that unstructured, unlimited job search as an approvable activity for child care eligibility is now preventing employed parents/caretakers from accessing care for their children. This is occurring even in areas with a relatively plentiful supply of providers.  Continued eligibility, into a second year of job search, is a wasteful use of taxpayer funded public resources and is not “responsive to families’  needs and realities,” which is a stated goal of the subsidy program.

Prolonged job search also undermines other foundational program goals. It does not “ support the family goals of economic self-sufficiency ,”   “ensure that the child care program contributes to the broader objective of self-sufficiency” or “ provide child care to children with parents who are trying to achieve independence from public assistance”

because subsidy applications from employed parents are now being denied due to their inability to find child care.

The emerging goal of universal Pre-K to support school readiness and child development is not compatible with the VDSS Child Care subsidy program in its current form.

Universal Pre-K calls for a different program configuration, with simplified policy and fewer eligibility criteria. Competition for a limited supply of child care spots will likely worsen, as

a number of providers say they intend to discontinue participation in subsidy when VQB5 becomes mandatory due to the additional demands it imposes.

As a FDH limited to only 4 children at a time, budgeting and finances are paramount. Being paid only twice a month when you have 4 of 4 children on subsidy is a grave hardship. Food and gas expenses alone is equivalent to one subsidy payment. (The food program payments are always late) Yet, we are still expected and required to provide the same quality consistently through out the month. There are times when I don’t pay myself dude to using my funds for the daycare needs. We are made to participate in programs to make sure we are quality providers but as the provider the services we receive for being a LEGALLY operating provider are subpar.  If I wasn’t dedicated to making things easy for the families I serve, subsidy would not be worth the hassle for me. 

Being paid based by days is also a burden. We have to maintain that spot with or without the child once the absences are used. 

I am a child care subsidy case manager and would like to comment on Job Search as an approvable activity to qualify for the child care subsidy.  I fully support job search as a need for child care, but strongly advise that limitations and accountability should be added to the guidance.

One problem we are finding in our locality is that provider spots get filled up with children of Job Searchers, leaving fewer available spots for children whose parents are working or in school. With the current job market (so many places hiring) and the ability to do most job searching on-line, it seems that 3-6 months could be the maximum approval time for job search as the activity. Recipients should definitely not be approved AGAIN for job search at the time of their annual Redetermination. It also seems there should be some method of accountability, as there was in the VIEW program. for parents to verify that they are actually conducting a job search.

Please consider raising subsidy rates, it hard to pay staff and keep up with rising minimum wages and rising costs of supplies, food, training etc.. Please consider changing pay by attendance being that centers charge by the week and the only source of income we receive is subsidy or private pay. Please consider changing the attendance tracking, keeping up with parent swipes is frustrating and if the parent miss the deadline then we are not paid. Please consider changing the required annual training, some of the training are repeated trainings and they are not free. Once a staff member has received their CDA or a training certificate they should not have to be forced to keep training/testing on information they have been taught and it's a burden on the staff member to continuously be charged for training each year or the center if they are covering training and development. It's hard to provide quality care on the subsidy budget, it's hard to pay quality/educated staff on subsidy budget, it's hard to have quality furniture/supplies/education on subsidy budget, the majority of our child are subsidy so please consider raising subsidy rates. 

Please consider raising subsidy rates, it hard to pay staff and keep up with rising minimum wages and rising costs of supplies, food, training etc.. Please consider changing pay by attendance being that centers charge by the week and the only source of income we receive is subsidy or private pay. Please consider changing the attendance tracking, keeping up with parent swipes is frustrating and if the parent miss the deadline then we are not paid. Please consider changing the required annual training, some of the training are repeated trainings and they are not free. Once a staff member has received their CDA or a training certificate they should not have to be forced to keep training/testing on information they have been taught and it's a burden on the staff member to continuously be charged for training each year or the center if they are covering training and development. It's hard to provide quality care on the subsidy budget, it's hard to pay quality/educated staff on subsidy budget, it's hard to have quality furniture/supplies/education on subsidy budget, the majority of our child are subsidy so please consider raising subsidy rates. 

I am in favor of maintaining the 2020 Model Policies to protect transgender students

How is it possible that there was no increase in the 3 and 4 year old programs for the Northern Virginia area. That is ridiculous. 

Virginia Promise Partnership (VPP) is a coalition of 30 leading organizations committed to securing quality, affordable child care for all Virginia families by 2030. We center our work around the voices of Virginia’s parents and providers through our Parent and Provider Advisories, who represent a diverse group of parents and providers from across Virginia.

The Child Care Subsidy Program (CCSP) is a critical program for many Virginia families which provides access to quality early learning and care. In general, our parents and providers have an awareness of the program and eligibility levels, believe that the program operates effectively, and they are appreciative of the access provided. 

One provider/guardian from the Roanoke Valley area stated that most of the families in her center are receiving benefits from this program, and that they only have a few families that are not eligible.

Some parents suggested more training for providers on how to fix the card “readers” for the VA Electronic Child Care system when they are not functioning. When a “reader” is broken, there is a tedious process to repair it and the alternate methods of attendance tracking are burdensome. More instruction or reminders may be needed for parents about checking in and out of the system, as well as the availability of assistance with the technology. 

The majority of our parents and providers noted that the CCSP has been a great asset for families. VPP appreciates the opportunity to provide feedback on this important program.