The increased income limit has helped so many families and should continue; however, excluding families with children over 5 from the increased limit is a true disservice to not only the families but the children as well.   These school age children need a safe place not only after school, but on the many non-school days (teacher work-days and inclement weather days) throughout the school year and summer-time.   

PLEASE reconsider this and allow the income limit to be based household size REGARDLESS of the age of child. 

Most of these children that we are not able to provide assistance in paying a licensed daycare are being left either unsupervised for the entire day or left with inappropriate teens or adults where, in some cases, abuse has happened.      

I understand early education is important, but so is the mental, emotional and physical well-being of ALL our children. 

Thank you for considering this very important change to the income limit; based on household size regardless of the age of the children in the home.  

When we are creating an authorization NOA manually for a vendor switch for example, we only have the option of selecting increased or decreased care. Can we add a third option? Because in this particular case, care amount will remain the same. We could add "Authorized care" or "Vendor switch," as a third option.

please let licensed family homes have more then 4 kids with there ratio, and also pay licensed family homes the same as a licensed center. We are doing the same amount amount of work if not more with all the different roles that we have. Long as the licensed family day home has the help I don’t see what the problem is! Please change asap!! There’s a great need for childcare and this could help out ALOT!!!!

As a LFDH Provider I was very grateful for the increase that rolled out not too long ago.  However, I feel that Licensed centers and LFDH should be under the same amount of pay per day per child. We work just as hard if not harder than those in a center. We have many job roles we must perform each and every day. We're teachers, nurses, maids, cooks, accountants, bookkeepers, referees, and sometimes even counselors to parents. I guess what I'm trying to say is we feel inadequate and to me it's just not fair. The majority of money we earn goes directly right back into our business. We play a very important role in our communities as we provide quality care in a loving safe environment, and it just feels like we get the short end of the stick :(

I know everyone has a lot of work to do but this revision is an opportunity to simplify and this document is over a hundred pages long. I work for a privileged early childhood program that would be happy to participate to bring greater access to our services and community of support but the administrative burden of this program is so significant we simply cannot justify participation. 

On page 51 and 52 is it possible to remove all use of the term Alien. I gave up reading at page72. I wish there was a commitment to simplifying. I know there are some positive changes coming but they are buried in a 260 page document. 

Thank you for the opportunity to comment on the proposed technical changes to the Child Care Subsidy Program Guidance Manual.

My comments reflect Child Care Aware of Virginia’s staff and our collective experience in working with parents and child care programs throughout Virginia.

Under Section 3.5 Copayments, section “A. Copayment Scale,” it is great to see family copayments capped at 7% of gross countable income for families with a child or children receiving child care assistance. The introductory paragraph cites federal law as requiring families to make a contribution to the cost of care through a copayment. The introduction then says “Families whose household income exceeds 100% of the federal poverty guidelines are required to pay a monthly copayment based on household income according to the sliding copayment scale in Appendix B, except TANF recipients."

While the Virginia Subsidy Program guidance was drafted in May 2023, on July 13, 2023, the U.S. Department of Health and Human Services proposed new CCDF rules, which allow states greater flexibility in waiving co-payments for families.

The 2016 final CCDF rule under Section 98.45(k)(4) said, “(4) At Lead Agency discretion, allows for co-payments to be waived for families whose incomes are at or below the poverty level for a family of the same size, that have children who receive or need to receive protective services, or that meet other criteria established by the Lead Agency.”

The July 2023 proposed CCDF rule modifies Section 98.45(k)(4) to offer greater flexibility to states.

“(4) At Lead Agency discretion, allows for co-payments to be waived for families whose incomes are at or below 150 percent of the poverty level for a family of the same size, that have children who receive or need to receive protective services, that have children who have a disability as defined at § 98.2, or that meet other criteria established by the Lead Agency.”

The comment period for the newly proposed federal CCDF regulations ends August 28, 2023. The agency expects to issue final regulations in the spring of 2024. We urge consideration for additional flexibility under Section 3.5 Copayments Section A, to insert language that would allow Virginia to waive co-pays for families earning up to 150% of the federal poverty level and also for families with a child with a disability in the event that this additional flexibility for states is finalized in the final federal rule.

Family co-payments can be a barrier to accessing child care subsidy for low wage earning families. The most recent U.S. Census Bureau Household Pulse Survey (June 28-July 10, 2023) found that 123,667 Virginia parents were not working because they were caring for children not in school or child care. Furthermore, 36.7%  of Virginia families with children had difficulty paying their household bills in the past 7 days.  While there is not good data on the number of children who have special needs in Virginia families who might also want and need child care, we do know from talking with parents that parents of children with disabilities have a much harder time finding child care.

Allowing for this additional flexibility to support parents while the Virginia comment period for the proposed new subsidy manual is open means that families in Virginia could be supported much sooner than waiting another 8-9 months (or longer) to propose such changes at a later time.