| Action | Revise regulation for programmatic changes and implementation of statewide automation |
| Stage | Proposed |
| Comment Period | Ended on 1/17/2014 |
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15 comments
I urge legislators to keep in mind the families within the communities while considering any proposed child care regulation change. Working with families in Fairfax County, I have been able to see first hand how critical the child care subsidies are in the families efforts to achieve a viable quality of life. At Falls Church-McLean Children's Center 60% of our families work full time for minimum wage. Several of our families work more than one job, and still fall within the guidelines of our nations definition of "working poor". The proposed 72-month limit on child care subsidy could greatly affect these families. The typical time that families require child care for their children is for the first 12 years of their life. While the first 6 years may include full-time child care, even when children go to school before and after care is necessary in order for the families to maintain employment. Likewise, many families have more than one child, and would not be able to access child care for the second child, if the first child's care was during the proposed 72 month limit. This regulation will definitely affect the bottom line of our state budget, but by no means thinks of the economic value of a self sufficient family.
Please consider local alternative fee scales to continue. The ability for localities to meet the specific needs of their families allows the local specialists to consider the economic challenges within their own communities. If the state moves to a state wide fee scale, families will have an increased percentage of copay each month. Working with these families first hand, we see how every penny they earn is calculated to ensure their families well being. We have several families that struggle to keep their children fed, and clothed in addition to maintaining a safe, and secure living environment. An increase in their percentage of copay would greatly affect the other areas of caring for their children. The local fee scale for parents in Fairfax County is currently 2.5% to 10% of the gross income, if the county is required to use the proposed staet fee scale, families will pay between 5% to 10% of their gross income. For many families the extra 2.5% can mean the difference between buying a coat for their child to stay warm. Please think of the families and their deisre to provide for their children in every respect, not just in regards to child care.
On behalf of the Fairfax County Child Care Advisory Council I would like to thank you for this opportunity to provide comments on the proposed changes to state child care regulations (22VAC40-661). The Child Care Advisory Council is an appointed board of ten members representing each of the nine Fairfax County magisterial districts and one at-large member appointed by the Chairman of the Board of Supervisors. The purpose of the Council is to advise the Board of Supervisors on programs and policies related to child care.
The Council considers the child care subsidy program a key strategy for helping working families in our community to remain employed and to ensure that children are cared for in regulated child care settings. We believe that providing support to working families and promoting children’s school readiness and ongoing success through quality early childhood programming is a worthy investment for our community and for the Commonwealth.
The proposed child care regulations include changes that we believe impede the County’s ability to meet the needs of working families in our community. We request that the proposed requirement to limit participation in the child care subsidy program and the removal of local alternate fee scales be amended to ensure that localities have the flexibility needed to successfully administer the program.
While many families participate in the subsidy program for fewer than six years, there are some families whose income does not increase sufficiently over time to enable them to afford the cost of care. If they are no longer able to participate in the program, families may not be able to continue to work, or may make difficult, unsafe choices for their children. We are concerned that families who cannot afford child care may leave school age children home alone or depend on them to care for a younger sibling. With the cost of child care in Fairfax County ranging from $8,000 and above for a preschooler, and $14,000 and higher for an infant, the loss of the child care subsidy may be untenable for a family with low income.
The proposed regulations no longer allow for the use of local alternate fee scales. As this Council has commented to the Department of Social Services before, we are concerned that the loss of the local fee scale will negatively impact the most vulnerable, at-risk families in our community whose continuous employment is dependent upon access to affordable child care. This local fee scale has worked well in the County for many years and helps to mitigate the economic challenges faced by families with low incomes in a community with high costs of living. The median income of families in our child care subsidy program is $25,992, which is well below the County median family income of $119,634. If the County is required to use the proposed state fee scale, families with the lowest incomes will see their fee change from 2.5% to 5% of their gross income for care, a 100% increase.
We respectfully request that the proposed child care regulations be amended to allow localities the option of implementing a per family limit on receipt of subsidies rather than requiring the limit, and that the use of local fee scales continue to be allowed.
Sincerely,
Hugh M. Cannon
Chairman, Fairfax County Child Care Advisory Council
January 12, 2014
Ms. Joan Ayers
Child Care Program Consultant
Virginia Department of Social Services
801 E. Main Street
Richmond, VA 23219
Dear Ms. Ayers:
Cornerstones, formerly Reston Interfaith, is submitting these comments in response to the proposed changes in Virginia’s Child Care and Development program. Virginia’s working families are still facing major challenges in this economy and the childcare subsidy program for low-income working parents and their children is an essential support with documented positive outcomes for employers and employees and our economy, and for direct impact on positive child development, school readiness and learning potential of the students who benefit from a quality childcare background.
Given the very real financial challenges faced by families, and previous changes that had the effect of limiting local options (at local cost) for time-limited supports for job seekers or those in part-time situations, we ask that you reconsider the proposed changes, or at least continue options that give maximum flexibility for localities to administer a program that is responsive to the needs of families, employees and child care providers in each region.
Cornerstones serves individuals and families unable to meet the basic expenses in our high cost of living community of Northern Virginia, connecting them to vital resources that help them build more stable and self-sufficient lives. We have worked in partnership with state and local government and other community partners to provide quality human service programs since 1970.
Cornerstones’ Laurel Learning Center has provided child care and related community services to low and moderate-income families since 1977. Laurel Learning Center serves nearly 140 infants, toddlers and children; the majority of our slots are reserved for families who depend on the subsidy to provide care for their children while they work. Access to affordable, quality child care is a critical need for all working families. Laurel Learning Center serves those who face the greatest challenges obtaining and paying for quality care. Childcare subsidies play a critical role in supporting the efforts of families with low incomes to achieve and maintain self-sufficiency. The Virginia Child Care Development program of subsidized childcare is not only a critical “anti-poverty” or safety net program; it is a vital tool in economic development.
The proposed changes to Virginia’s childcare regulations (22VAC40-661) will hurt families and limit localities ability to effectively administer the program to meet the needs of the working families in their jurisdiction. In Fairfax County that adds up to more than 4,700 families and we ask you to reconsider these proposed changes.
VDSS Proposed Change: Limit Child Care Subsidy to 72 Months per Family
Position: Opposed to Limits; Continue Current Local Option
Since 1970, Cornerstones has served nearly 300,000 men, women and children who are homeless, living in poverty or with low-incomes or special needs. That includes thousands of children and families we have served through Laurel Learning Center over the years who benefited from a quality, affordable childcare program as they worked to find better paying jobs, reduce debt and maintain the quality of living for themselves and their families.
We understand federal and state funding constraints and concern over waiting lists, and assume that the proposed regulation is an attempt to cap – however artificially – a program that works best if it is flexible and individualized to each family’s particular situation. Although many families receive child care subsidies for fewer than 72 months (6 years), there are some working families whose income does not increase sufficiently over time to enable them to afford the cost of care. This is particularly true in this high cost of living area. We have seen a number of working families who have lost their jobs in this bad economy, and recovery will take some time.
With the proposed regulation to limit care, if a family has used child care for five years and a second child is added to the family, the family will only be eligible for subsidy for one more year. After that the family will be responsible for paying the full cost of care for the infant and the older child. Even in the case where there is only one child in the family, we could be jeopardizing this benefit for a child at a time when the impact of school readiness and continued academic enrichment supports could be critical.
In Fairfax County tuition for one infant ranges from approximately $14,500 to $16,000 annually, an amount that is well-beyond the incomes of the majority of the families we serve and that can account for 30-50% of their total income. This proposal will not work for many families and will erase the gains made by those who are working so hard to pull themselves out of homelessness or other financial crisis, and who are gradually increasing their income and earning potential to fully support their families.
As we have seen over time, when families have to choose between keeping a roof over their head, or ensuring they have gas or bus fare to travel to their jobs, they may be forced to leave their children in unsafe, unregulated childcare. School-age children may be left at home unattended, adding to risks for a number of outcomes. This regulation would put that school-age child at risk at a time when they most need the continued support for readiness and academic achievement that quality centers can offer.
Discontinuing a subsidy for a working family jeopardizes their employment and undermines the investments already made in supporting their efforts to become economically self-sufficient. Families who benefit from this program are working and contributing the tax base. As their incomes rise, they pay a greater share of their total childcare costs.
Currently, Fairfax County and other jurisdictions have an option of imposing limit on a family’s receipt of childcare subsidy if it makes sense in that community, after careful review of the implications. We support a continuation of the existing policy to allow local agencies the option to impose the limit or not, based on a careful review of local circumstances.
VDSS Proposed Change: Establish a Statewide Sliding Fee Scale
Position: Opposed to Statewide Scale; Continue Local Alternate Fee Scales
Current child care regulations authorize the state to approve local alternate fee scales as well as impose a statewide sliding fee scale for all families enrolled in the subsidized child care program. According to Fairfax County Office for Children, VDSS has indicated its intent to remove approvals for alternate scales that meet the needs of families in areas like Fairfax County, and to establish a single statewide fee scale for all families. This will have the effect of requiring a percentage payment for every non-exempt family, regardless of the difference in cost of living or other circumstances.
Fairfax County has operated under a waiver to use a local sliding fee scale, rather than the state fee scale, to determine parent copayments for child care. The Fairfax County fee scale works because it best meets the needs of families in Fairfax and takes into consideration the economic challenges specific to living in this area. Under the current Fairfax County fee scale, parents pay from 2.5% to 10% of gross income for care. If the county is required to use the proposed state fee scale, families will pay between 5% and 10% of their gross income for care. Families with the lowest incomes will change from paying 2.5% to 5% of their gross income, a 100% increase in their copayment. This comes at a time when cuts in other critical safety net programs means that families may receive less support through food stamps and are being required to absorb a greater share of their housing costs due to cuts in the Housing Voucher and Public Housing programs. Adding the additional burden of mandatory increased costs towards childcare fees could significantly jeopardize the program.
Cornerstones supports amending the proposed regulations to continue to allow the use of alternate fee scales would better ensure that localities are able to adjust the scale to meet the needs of families in their communities and take the locality-specific conditions under advisement.
VDSS Proposed Change: Applicants must be 18 Years of Age
Position: Continue Local Option for Age-Eligibility for Program
Over the years a number of parents under the age of 18 have received subsidized childcare in Fairfax County while they have completed high school. Several Fairfax County Childcare Resource Centers specialize in working with teen mothers and can attest to the great impact this program has for those young people, particularly if their family or guardian is not in a position to absorb the tremendous costs of quality childcare. Childcare subsidies have enabled these teens to stay in school, complete their high school education, and enter the workforce. Because these young parents are particularly vulnerable, a childcare subsidy is a key component of the safety net needed to ensure that they and their children are safe and well. We support a local option to support serving teen parents will enable localities to continue these beneficial programs, particularly if the family is working with Fairfax County, a local school system, nonprofit or other community program such as Nurturing Parents or Healthy Families that ensures that the childcare subsidy is being leveraged as intended to support the teen mother and child.
VDSS Proposed Change: Registration and Cooperation with DCSE
Position: Continue Local Option for Working with Families to Register and Pursue Support
As a stewardship measure, VDSS has proposed regulations to require those families who are in receipt of a subsidy to also register and cooperate with the Division of Child Support Enforcement (DCSE) to locate an absent parent or establish paternity or a support order, except under certain conditions. Many families would benefit financially or otherwise from that assistance from an absent spouse, and it would address some concerns about shortfalls in program funding to meet all the need.
However, we have seen through our work that there are instances where the mandated registration can unintentionally hurt the family or put them at risk of abuse or loss of other rights – many of which have been articulated by other respondents. Parents may fear reprisal from the non-custodial parent and will be concerned about jeopardizing a child’s relationship with that parent. In cases where parents have an informal support arrangement and the custodial parent reports this income on the child care subsidy application, this requirement will change that relationship and may force parents into adversarial roles, often at the expense of the child. Families who are recent immigrants to this country and those who are not native English speakers face a number of language and cultural barriers which may impede their ability to meet this requirement. This is another area where VDSS and DCSE may want to give consideration to assigning this responsibility for determining the registration requirements to the local agency.
We recognize that the ongoing budget challenges and need to balance the benefits for those currently using the program v. those on waiting lists. As stated above, we believe that the childcare fee subsidy and TANF investments should be viewed by the Commonwealth of Virginia as an economic development incentive to support a healthy, productive economy and to provide Virginia’s children additional developmental supports. Thank you for the opportunity to provide input to these proposed regulations. Please feel free to contact us if you have additional questions.
Greg White, MSW, Chief Operating Officer - greg.white@cornerstonesva.org
Courtney Park-Jamborsky, Director, Laurel Learning Center - courtney.park@cornerstonesva.org
Jody Tompros, LCSW, Division Director, Family/Child Health – jody.tompros@cornerstonesva.org
Respectfully submitted by,
Kerrie Wilson, Chief Executive Officer
kerrie.wilson@cornerstonesva.org
11150 Sunset Hills Road, Suite 210
Reston, VA 20190
571-323-9555
January 16, 2014
I am urging legislatures to really think about the proposed 72 month limit for child care subsidy per family. The limit would devastate so many children and would do nothing but create a vicious cycle, including parents losing their job because of no childcare, to children being placed in unregulated, unsafe care or home with siblings too young to provide childcare. If a child enrolls in a subsidy child care program as an infant and hits the 72 month limit while still in the subsidy program where would a parent place that 6 year old? If the parent should have another child where would a 6 year old and younger sibling go for child care so the parent can work?
In my 12 years as the Director of Laurel Learning Center in Reston, VA I have witnessed hard working parents raising families in a very expensive Fairfax County. Many of the parents work 2 jobs and seem to balance their lives more successfully because of the quality care that the subsidy program allows. Childcare tuition without subsidy at Laurel Learning Center for just one child runs between $13,000-17,500 per year. Many of our families annually income averages between $30,000-40,000 per year.
A single Dad of a 7 year old daughter has had his daughter enrolled at Laurel Learning Center since she was 2 years old. He delivers pizza for Papa Johns during the day and works as a security guard on the weekends. With his days always working he somehow manages to see his daughter perform at our center’s piano recital. If he were to lose child care subsidy if the 72 month limit is imposed his daughter would be alone after school at the age of eight. She would just be one of the 100s of children that will lose care with the 72 month limit.
I request that the proposed 72 month limit of child care subsidy be amended and allow localities the option of implementing a per family limit on receipt of subsidies.
Courtney Park-Jamborsky
January 14, 2014
Ms. Joan Ayers
Child Care Program Consultant
Virginia Department of Social Services
801 E Main Street
Richmond, VA 23219
Dear Ms. Ayers:
For nearly thirty years, United Community Ministries’ (UCM) Bryant Early Learning (BEL) Center has served as a resource to parents, children, and the community by providing high quality child care to low income parents. We know that through this critical service, parents are in a better position to keep their jobs, therefore increasing their self-sufficiency and that children benefit from exposure to the fundamental social, emotional, and academic skills that prepare them for a life of learning and achievement. Child care subsidies play an important part in delivering this service ensuring that families have access to and can afford a safe, regulated early learning setting such as BEL. For many families, child care subsidies are the only form of assistance they receive.
The proposed changes to state child care regulations (22VAC40-661) that are listed and described below will limit the ability of local agencies to make decisions that are in the best interest of the families in their communities and may negatively impact families in many parts of Virginia.
Proposed 72-month limit on a receipt of child care subsidy
At the BEL Center, many families receive child care subsidies for fewer than six years. However, there are also some working families whose income does not increase sufficiently over time to enable them to afford the cost of care. With the proposed regulation, if a family has used child care for five years and adds a second to the family, the family will only be eligible for subsidy for one more year. After that, the family will be responsible for paying the full cost of care for the baby and the older child. In Fairfax County tuition for one infant ranges from approximately $14,500 to $16,000 annually, an amount that is clearly beyond the scope of families with low incomes.
In addition to the impact to babies and other young children, limiting the receipt of subsidy will likely result in families using unsafe, unregulated child care for children over the age of six. Without a child care subsidy, families may have to choose to leave school age children at home during out-of-school hours, at an age when children may not have the skills or emotional maturity to be at home alone. This creates increased risk for a range of negative outcomes including engagement in unsafe activities and vulnerability to gang involvement. Moreover, quality school age child care can help narrow the achievement gap by boosting student achievement and academic gains for low income students. Discontinuing a subsidy for a working family jeopardizes their employment and undermines the investments already made in supporting their efforts to become economically self-sufficient.
UCM supports legislation that continues to allow local agencies the option of implementing a limit to better ensure that localities are able to meet the needs of the families and children they serve in their communities.
Proposed requirement that families register/cooperate with DCSE
UCM recognizes that registering with the Division of Child Support Enforcement (DCSE) provides families with additional resources to support their economic well-being and independence. Families with low incomes who apply for assistance at UCM are made aware of DCSE and are encouraged to obtain child support benefits for their children.
Requiring DCSE registration, rather than encouraging and supporting registration, may, however, discourage families from applying for the subsidized child care services they need in order to work and pay for child care. Without affordable child care, parents may lose their jobs and no longer use regulated child care. In addition to keeping families working, subsidized child care is a support that enables children to attend quality child care programs that help to prepare them for success in school.
In cases of domestic violence parents may be fearful of registering with DCSE, which would preclude them from accessing affordable child care, thereby creating additional stress for an already at-risk family.
Families may view this requirement as intrusive and burdensome. Parents may fear reprisal from the non-custodial parent and will be concerned about jeopardizing a child’s relationship with that parent. In cases where parents have an informal support arrangement and the custodial parent reports this income on the child care subsidy application, this requirement will change that relationship and may force parents into adversarial roles, often at the expense of the child. Families who are recent immigrants to this country and those who are not native English speakers face a number of language and cultural barriers which may impede their ability to meet this requirement.
While UCM will continue to educate and encourage families to register with DCSE, we support legislation that allows localities the option of requiring DCSE registration as it better ensures that localities are able to meet the needs of families in their communities.
Proposed requirement that applicants for subsidized child care must be 18 years of age
For nearly thirty years, UCM has provided parents under the age of 18 subsidized child care at the BEL Center while they have completed high school. Child care subsidies have enabled these teens to complete their high school education and to enter the workforce. Children born to teen parents have unique needs as they are more likely to suffer the risks of low birth rate and premature birth than children of older parents who are more likely to receive prenatal care. Because these young parents are particularly vulnerable, a child care subsidy is a key component of the safety net needed to ensure that they and their children are safe and well.
UCM requests that the State amend the proposed regulation to support serving teen parents enabling localities to continue these beneficial programs.
Proposing removal of approved alternate fee scales and proposing that a state-wide sliding fee scale be established
For over 15 years Fairfax County has had a waiver from the Virginia Department of Social Services (VDSS) to use a local sliding fee scale, rather than the state fee scale, to determine parent copayments for child care. The Fairfax County fee scale works because it best meets the needs of families in Fairfax and takes into consideration the economic challenges specific to living in this area. Under the current Fairfax County fee scale, parents pay from 2.5% to 10% of gross income for care. If the county is required to use the proposed state fee scale, families will pay between 5% and 10% of their gross income for care. Families with the lowest incomes will change from paying 2.5% to 5% of their gross income, a 100% increase in their copayment. At BEL, the majority of children face multiple risk factors the most common of which is poverty: 76% come from extremely-low to low-income families. For these families, an increase in fee of 2.5% can mean the difficult choice between buying new shoes for a child or putting nutritious food on the table. Worse yet, some families may choose to place their child(ren) in unsafe, unregulated settings fees become out of their reach.
UCM urges the State to amend the proposed regulations to continue to allow the use of alternate fee scales would better ensure that localities are able to meet the needs of families in their communities.
Respectfully submitted,
Elizabeth McNally
Deputy Director, United Community Ministries
elizabeth.mcnally@ucmagency.org
571-255-8986
January 16, 2014
Mary Ward
Subsidy Program Manager
Virginia Department of Social Services
801 East Main Street
Richmond, VA 23219
Dear Ms. Ward,
I would like to offer the following comments on proposed changes to child care regulations, 22 VAC 40-661.
The child care subsidy program was originally designed to allow low-income parents to work and support their families. In order to do this, Virginia needs to adequately fund the child care subsidy program and to adopt policies that are fair to families and fair to child care providers. It is short-sighted to do otherwise. To support families, child care programs need to be affordable and accessible. To support children, our future wage earners, the programs need to provide safe and quality care. To be fair to families and providers, policies must be in place that encourage participation.
I support the proposal to reduce subsidy application processing time from 45 days to 30 days. This will make a positive difference to families who have secured employment and need reliable child care.
I do NOT support the proposed cap on subsidy payments for children with special needs. It is heart-wrenching to watch families of children with special needs try to find child care. By definition, this type of care requires additional expertise, and it is expensive to provide. In Virginia, where subsidy reimbursement rates are already so low, a cap on the payment rate to providers will further reduce the supply of care for children with special needs.
I support continuing the current policy of allowing a locality the option of imposing a time limit.
I do NOT support the six year limit on receipt of child care subsidy. The Child Care and Development Fund covers children through age 12. It just doesn’t make sense to limit child care to only six of those years. It also doesn’t make sense to provide some children in a family with adequate care and condemn younger children in the same family to unsafe, unregulated child care or to force parents are out of the workforce when they presumably have six years of work experience. It would seem like a positive option for some families is to space their children so the family can save for the expensive infant and toddler care. In Fairfax County tuition for one infant ranges from approximately $14,500 to $16,000 per year, far out of reach of eligible families who are denied child care assistance. The answer to the waiting list is to provide more funding for child care, not to impose a time limit.
I do NOT support the proposed requirement that families register/cooperate with DCSE. I urge you to “encourage” families to register with DCSE, instead of making this a condition of eligibility for child care assistance.
I do NOT support the proposed requirement that applicants for subsidized child care must be 18 years of age. Child care subsidies enable teen parents to complete their high school education and enter the workforce.
I do NOT support the proposed removal of approved alternate fee scales and proposal that a state-wide sliding fee scale be established. Localities should be allowed to continue the use of alternate fee scales to ensure they are able to meet the needs of families in their communities. The Fairfax County fee scale works takes into consideration the economic challenges specific to living in this area. Local decision-making on fee scales is in the best interest of families.
I appreciate this opportunity to provide comments on the proposed regulations and thank you for your consideration.
Sincerely,
Rosemary A. Kendall, Ph.D.
Early Childhood Education Consultant and Advocate
The Fairfax County Community Action Advisory Board (CAAB) wishes to add its name to the list of organizations and individuals who have concerns about Virginia’s proposed changes to the state child care regulations (22VAC40-661). The CAAB is the only local advisory board that includes representatives of Fairfax County’s low income population and has advocated for many years for programs that it believes do the most to help low income individuals and families achieve economic security. Affordable child care has been at or near the top of this list since its inception.
Affordable child care is one of the most important supports we can provide for people who need to work. Without affordable child care, many parents would have to leave the workplace. Child care assistance is essential to continued economic growth and preserves local investments in welfare to work programs. In addition to affecting working families, the existence of affordable child care affects the business community as well. When families are not able to afford child care services, the vitality of many small businesses are at risk, including child care providers themselves. If families who receive subsidies are no longer able to afford child care, some centers may have to close classrooms, lay off staff, or even close.
Proposing removal of approved alternate fee scales and proposing that a state-wide sliding fee scale be established
The CAAB has serious concerns with the changes being made that prevent Fairfax County from utilizing its own sliding fee scale. The fact that families currently paying a minimum of 2.5% of their gross income for care will have to pay 5% of their gross income for care starting in September is disheartening, but the fact that this change is being instituted simply for the sake of statewide uniformity is unconscionable. The cost of living throughout the state of Virginia is not uniform. The chart below illustrates the kind of increase with which families will need to cope: A family of four with a gross monthly income (GMI) of $1,921 (or an annual income of $23,052 which is just above the federal poverty guideline) will pay an additional $576 in copayments annually if the family has one child in care. This is a significant increase when a family may well pay over $1,000 per month for an apartment in Fairfax County.
|
|
GMI for Household with Four Members |
% of Payment |
Monthly Copayment Amount |
Annual Total |
|
VDSS |
$1921 |
5% |
$96 |
$1,152 |
|
Fairfax |
$1921 |
2.5% |
$48 |
$576 |
This is simply unacceptable. Raising the rates on our most vulnerable residents by 100% for no good reason is a cruel and unusual punishment. While not all of them will see such a dramatic increase, the Office for Children estimates that over 500 families with incomes at or below 100% of the Federal Poverty Level will see their fees increase as a result of this change. Please reconsider your decision to deny Fairfax County permission to use the alternate fee scale that has served this community so well for the past 14 years.
Proposed 72-month limit on a receipt of child care subsidy
Families who need the child care subsidy are working their way back to economic security and are in a period of transition.Often they have traveled a long way to get back on their feet and they may still have a long way to go to be truly economically secure.Pulling the rug out from under them would have a devastating effect.During a tenuous economic recovery, it does not make sense to institute a policy which would make it more difficult for people to continue working.The best way to eliminate the waiting list for subsidies is to increase the amount the Commonwealth budgets for the subsidy, not to remove people from the program before they are ready.
Families who receive the fee-system child care subsidy in Fairfax County have a median household income of $25,992 in a County where the overall median household income is around $100,000. The average range of the cost of center-based care for a preschooler is $8,000 to $13,000 per year, comparable to the cost of average fees and tuition to college. Center-based infant care is even more expensive; running $14,500 to $16,000 per year in Fairfax County. Only the cost of housing (21%) takes a larger percentage of a family’s household income in average in Virginia than child care (20%).
On the surface, the reasoning behind this proposed change appears to be sound. There are an increasing number of families on the waiting list for subsidies (in Fairfax County alone there are 2,900; statewide there are 11,733) and limiting the time for receipt of subsidies may allow more of these families to be served. But, what happens to those families who still need the subsidies?
The story of one Fairfax County family receiving subsidized child care illustrates the value of helping families for longer than months.This family began its association with subsidized child care in 2005, when the mother was cleaning houses.After two years at a child care center, the older child made a successful transition to kindergarten, was identified for the gifted and talented program and now attends a third grade GT class.The younger child has been at the center for two years.The mother is now a caregiver for a senior adult. She has improved her English and is in the high school adult education program.The father works and is supportive of the family.Although this family has made substantial progress, they still need additional support before they achieve economic security.
Perhaps the worst reason to justify restricting child care support to months is the state’s desire to have arbitrary uniformity across jurisdictions.While it may appear to be easier in the short term to have the same rules in every community across the state, it is not necessary,
If this regulation change is enacted, what would happen to those families who would lose their child care subsidy?They may turn to unregulated and possibly unsafe care in an attempt to maintain their employment and put their children at risk, or they will be forced to leave the workplace and place their family’s livelihood in jeopardy.Either way, the safety and stability of a family is compromised with no discernible benefit to the Commonwealth.
These comments are provided in response to the proposed child care regulations [22 VAC 40-661] by Bethany House of Northern Virginia, Inc. Bethany House has provided emergency shelter and supportive services to victims of domestic violence in Virginia since 1979. For 34 years, women and children at risk in the Commonwealth have reached out to Bethany House to help them escape from abusive home environments and develop resources to attain healthy self-sufficiency. We provide wrap-around services that include safe housing, transportation, basic needs, employment support, counseling, life skills classes, and children’s services.
It is important to note that financial abuse plays a large role in many unhealthy relationships. The abuser may use the family’s finances to control and manipulate a partner who becomes dependent on them for food, clothing, housing and other basic needs. As a result, employment plays a critical role in helping our clients break free of abusive relationships. The benefit of having their own income means our clients do not have to depend on an abusive partner to provide basic needs, feed their children, or even buy back-to-school supplies.
Having suffered from financial control, including not being able or allowed to work, the majority of our clients are low-income to extremely low-income when they first exit the abusive relationship. These women depend on child care subsidies to successfully and permanently leave abusive partners and rebuild lives free from abuse. The victims we work with cannot find or maintain employment without affordable and reliable child care. Child care subsidies are without a doubt a lifeline for many of our clients.
These comments are intended to share our experiences in working with victims of domestic violence who access child care services through local government offices.
Proposed requirement that families register and cooperate with DCSE:
Clients of Bethany House do not exit their intimate partner relationships frivolously; they do so out of fear and out of a desire to create a safe environment for themselves and their children. Quite often, it becomes necessary for these individuals to cease contact with their abuser, absent a court order, in order to preserve their newfound freedom and security. Simply exiting the relationship is not enough to insure safety. The risk of violence for a victim of intimate partner abuse remains statistically significant for up to two years after ending the relationship. Ongoing contact with an abuser places many victims at further risk of harm, including homicide, and may place the children at risk of parental abduction or retaliatory homicide. This is a very real concern for victims of domestic violence. Throughout the Commonwealth, family and intimate partner violence accounts for one-third of all homicides in the state. In Fairfax County, that number is even higher. Over half of homicides (57%) were domestic-violence related, and the majority of those homicides occurred after the victim ended the relationship.
It is our contention that requiring families to register and cooperate with Division of Child Support Enforcement (DCSE) will place victims of domestic violence and their dependent children at risk from an abusive partner. Furthermore, this risk may deter families eligible for child care support from seeking a child care subsidy. Fear that an abuser may locate them precisely because they sought government support places a burden on victims of violence and will further isolate these vulnerable families and imprison both the parent and children in poverty.
The proposed regulations include an application for relief from the requirement to register and cooperate with DCSE. However, the criteria required to merit a waiver have been described as stringent, at best. We request that VDSS consider the ramifications of this requirement carefully in order to insure the long-term health and viability of a victim of domestic violence and her dependent children.
Proposed 72-month limit on receipt of child care subsidy:
The proposed regulations suggest a limit of 72-months in which a family may be eligible to receive the child care subsidy. This limitation places a significant burden on single wage-earning families with multiple children, such as those families served by Bethany House. As identified in the preceding section, a significant challenge for many of our clients is finding and maintaining stable employment. The average family entering BHNV’s emergency shelters is a woman with two children, but a client may also have three, four or more small children. Again, I state with emphasis that these families are entering BHNV’s shelters in order to escape domestic violence. The proposed 72-month restriction would severely limit a mother with multiple small children from reaching self-sufficiency and may propel her back into an abusive relationship once she has reached the 72-month limit as she will no longer have the ability to work without child care.
In enacting the proposed changes, at-risk families with multiple children may be forced to choose between the lesser of many evils. A victim of domestic violence may benefit from short-term sufficiency, but under the proposed changes at 72 months she will have to choose between returning to a relationship where the victim is financially dependent on an abuser, find cheaper, unregulated child care, or leave her children at home while she works with the hope that nothing will go wrong. All of these solutions carry significant risks to young children who do not have the ability or maturity to improve their circumstances on their own.
We strongly urge VDSS not to penalize at-risk families with multiple children by limiting their access to subsidized child care. We recognize that limitations may be necessary in order to extend benefits to as many needy families as possible, but those limits should be made at the local level by individuals who understand intimately the challenges faced by their neighbors.
We thank you for your consideration of these comments and others provided through public comment.
Respectfully,
Catherine Hassinger
Executive Director
January 16, 2014
Ms. Joan Ayers, Child Care Program Consultant
801 East Main Street
Richmond VA 23219
Dear Ms. Ayers,
I am writing on behalf of the Fairfax County Head Start Policy Council and wish to provide comments on the proposed changes to the Virginia Department Social Services, child care regulations. The County’s Head Start/ Early Head Start program provides services to 1,857 children and their families. Services are provided in family child care, home visiting and center-based options. Our Policy Council includes representation from all program options and from all three programs (Greater Mount Vernon Community Head Start, Higher Horizons Day Care Center, and Fairfax County Public Schools).
We appreciate the work that Virginia is doing to promote quality early care and education throughout the state. However, we are concerned that proposed changes will affect families and the administration of the child care subsidy program. It is my understanding two major regulation changes involve limiting child care subsidy participation to fee families to 72 months per family and requiring subsidy recipients to register with the Division of Child Support and Enforcement. A third major issue involves the intent by VDSS to establish a state-wide fee scale, which is likely to increase the co-payment percentages that some Fairfax families will pay. We support allowing each locality to have the option to implement these changes to better ensure that localities can meet the needs of families in their community.
The cost of living in our community is very high and many families are struggling, and the proposed changes will present additional road blocks to acquiring affordable quality child care. We hope that you will take these comments into consideration and allow localities to have the option of imposing the time limit on a family receipt of child care subsidy, the option of requiring DCSC registration and amending the proposed regulations to continue to allow the use of alternate fee scales to support the needs of the families in their communities.
If you have questions or would like to learn more about Head Start in Fairfax County we would welcome the opportunity to meet with you.
Sincerely,
Glendy Bowman, Chairperson
Proposed cap on subsidy payments for children with special needs in order to bring consistency to such payments and to permit programmatic oversight of costs.
I urge you to not adopt this proposal and maintain current payment rates for subsidy for children with special needs. Child care for children with special needs is in limited supply and very difficult for families to find. This care is more expensive to provide, and early childhood programs are doing what they can to make ends meet while serving the families who need them.
Proposed six year limit on receipt of child care subsidy. “A change to limit the time families may receive subsidized child care will permit more eligible families who are on a waiting list to be served.”
I urge you to continue the current policy of allowing a locality the option of imposing a time limit, instead of making six years the statewide mandate. There are working families in Northern Virginia whose income does not increase sufficiently over time – even over a six-year period - to enable them to afford the cost of care in this area. For families with more than one young child, this limit will not cover the years prior to school entry.
Proposed requirement that families register/cooperate with DCSE.
I urge you to “encourage” families to register with DCSE, instead of making this a condition of eligibility for child care assistance. The proposed requirement will actually discourage families from applying for the subsidized child care services they need in order to work and pay for child care. And without access to affordable, reliable child care parents put their employment at risk.
Proposed requirement that applicants for subsidized child care must be 18 years of age.
I urge you to not adopt this proposal. Child care subsidies enable teen parents to complete their high school education and enter the workforce. These young parents are particularly vulnerable and the child care subsidy is a key component of the safety net needed to ensure that they and their children are safe and Ill. Children who do not complete high school are less likely to be a part of the educated and skilled workforce that our state needs now and in the future.
Proposing removal of approved alternate fee scales and proposing that a state-wide sliding fee scale be established.
I urge you to amend the proposed regulations to continue to allow the use of alternate fee scales would better ensure that localities are able to meet the needs of families in their communities. Current child care regulations authorize the state to approve local alternate fee scales as Ill as impose a state-wide sliding fee scale for all families enrolled in the subsidized child care program.
I am the Executive Director of ACCA Child Development Center. Founded in 1967, it is one of the human service programs funded by the Annandale Christian Community for Action. We provide affordable, high-quality early education to 183 children, ages 3 months to 5 years.
The children served come from low-income families, and the areas we cover are multicultural, with high concentrations of immigrants.
A large number of our children come from single-parent homes with multiple siblings, where the primary caregiver is usually working for longer than eight hours and often in more than one place of employment. The average income of our parents is $25,000 per year. Also, many of the families are not native English speakers. At present, 80% of our children are Latino.
Research has shown the benefits of providing high-quality early education to minority children. Providing young children with a healthy environment in which to thrive is not only good for their future, but it is great for the public’s fiscal bottom-line. Three recent studies found returns between $4 and $13 for every dollar invested in early learning. Program participants followed into adulthood benefited from increased earnings while the public saw returns in the form of reduced special education, welfare, crime costs and increased tax revenues.
Because of federal, state and county subsidies for tuition and donations from community partners, our tuition rates are among the lowest in Fairfax County. Without such support, our families could not afford our program. Make no mistake, our parents work hard; they love their children; but they need help. The subsidy for child care is essential if they are to enroll their children in early programs that meet their educational needs.
In recent years, the state and county have changed the way tuition subsidies are administered. Some of the changes have been positive, but others have created problems. In this regard, the proposed changes to state child care regulations (22VAC40-661) that are described below will limit the ability of child care providers to make decisions that are in the best interest of the families in their communities.
Proposed 72-month limit on a receipt of child care subsidy
Eligibility in the fee program is limited to a total of 72 months per family. Receipt of assistance in any other category does not count toward the 72-month limitation.
Although many families receive child care subsidies for fewer than six years, there are some working families whose income does not increase sufficiently over time to enable them to afford the cost of care. With the above regulation, if a family has used child care for five years and a second child is added to the family, the family will only be eligible for subsidy for one more year. After that the family will be responsible for paying the full cost of care for the baby and the older child. In Fairfax County tuition for one infant ranges from approximately $14,500 to $16,000 annually, an amount that is clearly beyond the scope of families with low incomes.
In addition to the impact to babies and other young children, limiting the receipt of subsidy may result in families using unsafe, unregulated child care for children over the age of six. Without a child care subsidy, families may have to choose to leave school age children at home during out-of-school hours, at an age when children may not have the skills or emotional maturity to be at home alone. This creates increased risk for a range of negative outcomes including engagement in unsafe activities and vulnerability to gang involvement. Moreover, quality school age child care can help narrow the achievement gap by boosting student achievement and academic gains for low income students. Discontinuing a subsidy for a working family jeopardizes their employment and undermines the investments already made in supporting their efforts to become economically self-sufficient.
Currently, localities have an option of imposing limit on a family’s receipt of child care subsidy. Continuing to allow local agencies the option of implementing a limit would better ensure that localities are able to meet the needs of the families and children they serve in their communities.
Proposed requirement that families register/cooperate with DCSE
“…An applicant or recipient of child care subsidy services must provide the information required by the Division of Child Support Enforcement to locate an absent parent, establish paternity, or establish a support order, unless a basis for good cause for noncooperation is determined by the program.
We recognize that registering with the Division of Child Support Enforcement (DCSE) provides families with additional resources to support their economic well being and independence. Families with low incomes who apply for subsidized child care should be encouraged to obtain child support benefits for their children. In Fairfax, staff refer single-parent families in the child care subsidy program to the DCSE.
Requiring DCSE registration, rather than encouraging and supporting registration, may, however, discourage families from applying for the subsidized child care services they need in order to work and pay for child care. Without affordable child care parents may lose their jobs and no longer use regulated child care. In addition to keeping families working, subsidized child care is a support that enables children to attend quality child care programs that help to prepare them for success in school.
In cases of domestic violence parents may be afraid to register with DCSE, which would preclude them from accessing affordable child care, thereby creating additional stress for an already at-risk family.
Families may view this requirement as intrusive and burdensome. Parents may fear reprisal from the non-custodial parent and will be concerned about jeopardizing a child’s relationship with that parent. In cases where parents have an informal support arrangement and the custodial parent reports this income on the child care subsidy application, this requirement will change that relationship and may force parents into adversarial roles, often at the expense of the child. Families who are recent immigrants to this country and those who are not native English speakers face a number of language and cultural barriers which may impede their ability to meet this requirement.
Although the regulations indicate that an applicant must provide the information required by DCSE to locate an absent parent, establish paternity, or establish a support order, unless a basis for good cause for noncooperation is determined by the program, the requirements for establishing and documenting “good cause” are stringent and may be difficult to meet.
Even though families should be encouraged and supported as they apply for benefits through DCSE, giving localities the option of requiring DCSE registration would better ensure that localities are able to meet the needs of families in their communities.
Proposed requirement that applicants for subsidized child care must be 18 years of age
A change will ensure that applicants for subsidized child care meet the legal age requirement to enter into the contract to receive child care subsidy payments.
Over the years a number of parents under the age of 18 have received subsidized child care in Fairfax County while they have completed high school. Child care subsidies have enabled these teens to complete their high school education and to enter the workforce. Because these young parents are particularly vulnerable, a child care subsidy is a key component of the safety net needed to ensure that they and their children are safe and well. A local option to support serving teen parents will enable localities to continue these beneficial programs.
Proposing removal of approved alternate fee scales and proposing that a state-wide sliding fee scale be established
“…Copayments are established by the department. All families receiving child care subsidy have a copayment responsibility except those families whose gross monthly income is at or below the federal poverty guidelines who are recipients of TANF, participants in the SNAPET program, or families in the Head Start program will have no copayment.”
Current child care regulations authorize the state to approve local alternate fee scales as well as impose a state-wide sliding fee scale for all families enrolled in the subsidized child care program. During the past year VDSS has indicated its intent to remove approvals for alternate scales that meet the needs of families in particular areas and to establish a single state-wide fee scale for all families. In effect, without the inclusion of alternate fee scales, VDSS will be able to mandate at the state level, a single set of percentages by which parents copayments will be calculated. Unless there is an option for a local scale, a locality cannot develop a system for parent copayments that meets the needs and the economic reality of that locality.
For over 15 years Fairfax County has had a waiver from the VDSS to use a local sliding fee scale, rather than the state fee scale, to determine parent copayments for child care. The Fairfax fee scale works because it best meets the needs of families in the county and takes into consideration the economic challenges specific to living in this area. Under the current Fairfax County fee scale, parents pay from 2.5% to 10% of gross income for care. If the county is required to use the proposed state fee scale, families will pay between 5% and 10% of their gross income for care. Families with the lowest incomes will change from paying 2.5% to 5% of their gross income, a 100% increase in their copayment.
Sincerely,
Maria-Isabel Ballivian
Executive Director
January 17, 2014
Department of Social Services
State Board of Social Services
801 E. Main Street
Richmond, Virginia 23219
Dear Chairman and Members of the State Board of Social Services,
On behalf of the Fairfax County Office for Children, I would like to thank you for the opportunity to provide comments on the proposed state child care regulations (22 VAC40-661). The child care subsidy program is a key strategy in Virginia for ensuring that families can be productive members of the workforce while their children attend early childhood and school age programs that support their school readiness and ongoing success.
Fairfax County recognizes the importance of affordable child care for families and for the economy and has long supported the provision of child care subsidies for working families. With a combination of federal, state and local funding, the County serves approximately 4,700 children monthly in the child care subsidy program. The median income of families in the program is approximately $26,000 and for many families, child care subsidies are the only form of assistance they receive. The Office for Children appreciates the Virginia Department of Social Services’ work administering the Child Care and Development Fund in the Commonwealth, and we value our ongoing partnership in serving children and families.
We are, however, concerned that some of the proposed changes to the child care subsidy regulations will impede localities’ ability to serve vulnerable families and best meet the needs of their community. We are requesting that the state amend the proposed regulations to provide for local options.
The proposal to require all localities to implement a six-year limit per family on the receipt of child care subsidies is one that we would request be changed so that the limit would be optional. While many families participate in the child care subsidy program for fewer than six years, there are some families whose incomes do not rise sufficiently within that time-frame to enable them to afford the cost of child care. If these families are no longer eligible to receive child care subsidies, the employment they have worked to continually maintain will be jeopardized. If parents cannot afford child care, they may lose their jobs, or may have to make difficult decisions regarding care for their children. One of many parents who would be impacted by this proposed regulation works full-time as a teacher in a child care program, works part-time at a retail store, and is close to completing her associates degree at Northern Virginia Community College. She has an eight-year-old who has attended child care since he was an infant, thereby making her ineligible for child care subsidies if a six-year limit is imposed. Her son is too young to be home alone before and after school and during the summer months, and she cannot afford child care without a subsidy. This parent is doing everything we would hope she could do to work toward self-sufficiency and care for her child -- losing the subsidy would jeopardize her continued progress and success. Other families who have a second child and have reached the six-year limit would face the overwhelming challenge of paying for infant care, which in Fairfax County can cost well above $14,000 a year. In addition to impacting parent employment, the six-year limit could result in school age children being left home alone, or responsible for caring for a younger sibling on their own.
Currently, localities have an option of imposing a limit on a family’s receipt of child care subsidy. We request that the proposed regulations be amended to continue to allow local agencies the option of implementing a limit which would better ensure that localities are able to meet the needs of the families and children they serve.
We also request that the proposed regulations be amended to continue to allow the use of local alternate fee scales for copayments. We recognize the important work VDSS has done to move toward implementing a sliding fee scale for localities in which families currently pay a flat 10% of gross income for care. Sliding fee scales are positive strategies for supporting families as they work toward self-sufficiency, considering family income and allowing fees to rise as income rises. However, we request that the state continue to allow the use of an alternate, local fee scale in lieu of requiring use of the state-wide fee scale. In Fairfax County our local fee scale accounts for the economic challenges faced by working families in our community. It has enabled us to meet the needs of many families, including those whose incomes are below or at the federal poverty limit. Currently families in Fairfax County pay from 2.5 to 10 percent of gross income for care. The proposed state-wide fee scale would require families to pay from 5 to 10 percent, doubling the payment for families with the lowest incomes. Continued use of a local fee scale would enable the County to better meet the needs of working families.
We also request that the proposed regulation mandating that families applying for child care subsidies register with the Department of Child Support Enforcement be amended. It is important for children to have access to all available sources of income, and the Office for Children regularly refers single-parent families in the child care subsidy program to DCSE. We are concerned that requiring registration with DCSE will be a deterrent for some at-risk families and will preclude them from applying for child care subsidies. This could keep the child from benefiting from either source of economic support – child care subsidies and child support. There are multiple reasons this requirement would discourage families from applying for child care subsidy. These include impact on informal, successful support arrangements, language and cultural barriers, and fear of reprisal from the non-custodial parent. Although the regulations indicate that an applicant must provide the information required by DCSE “unless good cause for noncooperation is determined by the program”, the requirements for establishing and documenting “good cause” are stringent and may be difficult to meet.
We again request that the proposed regulation be amended to provide localities the option of requiring DCSE registration in order to better ensure that localities are able to meet the needs of families in their communities.
The final regulation we would like to address is the proposed requirement that applicants for subsidized child care must be 18 years of age. Over the years a number of parents under the age of 18 in our community have received child care subsidies while they have completed high school. This support has enabled them to place their infants in safe, regulated child care while they pursue their diploma, learn to be a parent and plan for their new family’s future. Because these young parents and their children are particularly vulnerable, the child care subsidy is a key component of the safety net the community, County and schools work to maintain for teen parents. We request that this requirement be reconsidered or that a local option to support serving teen parents be allowed.
We appreciate your consideration of our comments and support of our efforts to serve children and families in our community. Please do not hesitate to contact me should you have questions or need additional information.
Sincerely,
Anne-Marie D. Twohie
Director, Office for Children
The Northern Virginia Association for the Education of Young Children (NVAEYC) represents more than 1,250 early childhood teachers, family child care providers, parents and other professionals who care about and work to promote the healthy development of all young children.
We offer the following comments on proposed changes to child care regulations, 22 VAC 40-661.
The subsidy program providers a crucial safety net for low-income working families. NVAEYC members know these families, see the different a subsidy makes, and know how difficult the current system can be. We are pleased to see the proposal to reduce subsidy application processing time from 45 days to 30 days. This will make a positive difference to families who have secured employment and need reliable child care. However, we are very concerned that some of the other proposed changes to state regulations will negatively impact families in the program.
Proposed cap on subsidy payments for children with special needs in order to bring consistency to such payments and to permit programmatic oversight of costs.
We urge you to not adopt this proposal and maintain current payment rates for subsidy for children with special needs. Child care for children with special needs is in limited supply and very difficult for families to find. This care is more expensive to provide, and early childhood programs are doing what they can to make ends meet while serving the families who need them. Especially in our state where subsidy reimbursement rates are already so low, a cap on the payment rate to providers will further reduce the supply of care for children with special needs. The proposal documents acknowledge this challenge. These are not consequences to be taken lightly.
Proposedsixyear limit on receipt of child care subsidy. “A change to limit the time families may receive subsidized child care will permit more eligible families who are on a waiting list to be served.”
We urge you to continue the current policy of allowing a locality the option of imposing a time limit, instead of making six years the statewide mandate. There are working families in Northern Virginia whose income does not increase sufficiently over time – even over a six-year period - to enable them to afford the cost of care in this area. For families with more than one young child, this limit will not cover the years prior to school entry.
In Fairfax County tuition for one infant ranges from approximately $14,500 to $16,000 per year, far out of reach of a family eligible for but denied child care assistance. Discontinuing a subsidy for a working family will jeopardize their employment and undermine the investments already made in supporting their efforts to become economically self-sufficient.
Limiting the subsidy may also result in families using unsafe, unregulated child care. Quality early childhood and school-age child care can help narrow the achievement gap by boosting student achievement and academic gains for low income and minority students.
This proposal won’t allow more families to be served; it would allow different families to be served. This is deeply challenging but we do not support dis-enrolling children from the early care and education program of their parent’s choice. The consequences for that child cannot be justified. We must work together to increase state investment to enroll off the waiting list, but not at the elimination of services for those currently enrolled.
Proposed requirement that families register/cooperate with DCSE.
We urge you to “encourage” families to register with DCSE, instead of making this a condition of eligibility for child care assistance. The proposed requirement will actually discourage families from applying for the subsidized child care services they need in order to work and pay for child care. And without access to affordable, reliable child care parents put their employment at risk.
A study released by Child Care Matters (2004) found that this kind of requirement was "preventing income eligible families from applying for child care subsidy, hurting enrollments in regulated early education programs, and undermining a parent's ability to access safe and quality child care."
In cases of domestic violence parents may be afraid to register with DCSE, which would preclude them from accessing affordable child care, thereby creating additional stress for an at-risk family. In cases where parents have an informal support arrangement and the custodial parent reports this income on the child care subsidy application, this proposed requirement will change that relationship and may force parents into adversarial roles at the expense of the child.
Although the regulations indicate that an applicant must provide the information required by DCSE to locate an absent parent, establish paternity, or establish a support order, unless a basis for good cause for noncooperation is determined by the program, the requirements for establishing and documenting “good cause” are stringent and may be difficult to meet.
Proposed requirement that applicants for subsidized child care must be 18 years of age.
We urge you to not adopt this proposal. Child care subsidies enable teen parents to complete their high school education and enter the workforce. These young parents are particularly vulnerable and the child care subsidy is a key component of the safety net needed to ensure that they and their children are safe and well. Children who do not complete high school are less likely to be a part of the educated and skilled workforce that our state needs now and in the future.
Proposing removal of approved alternate fee scales and proposing that a state-wide sliding fee scale be established.
We urge you to amend the proposed regulations to continue to allow the use of alternate fee scales would better ensure that localities are able to meet the needs of families in their communities. Current child care regulations authorize the state to approve local alternate fee scales as well as impose a state-wide sliding fee scale for all families enrolled in the subsidized child care program.
The Fairfax County fee scale works because it best meets the needs of families in Fairfax and takes into consideration the economic challenges specific to living in this area. Under the current Fairfax County fee scale, parents pay from 2.5% to 10% of gross income for care. If the county is required to use the proposed state fee scale, families will pay between 5% and 10% of their gross income for care. Families with the lowest incomes will change from paying 2.5% to 5% of their gross income, a 100% increase in their copayment. While these may sound like small changes, on a low-wage family budget the change is insurmountable. Local decision-making on fee scales is in the best interest of families.
We appreciate this opportunity to provide comments on the proposed regulations and thank you for your consideration.
Sincerely,
Paige Beatty and Gay Hitchcock, Co-Presidents, Northern Virginia Association for the Education of Young children
