Virginia Regulatory Town Hall
Agency
Department of Social Services
 
Board
State Board of Social Services
 
chapter
Child Care Program [22 VAC 40 ‑ 661]
Action Revise regulation for programmatic changes and implementation of statewide automation
Stage NOIRA
Comment Period Ended on 5/11/2011
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Next Comment     Back to List of Comments
5/11/11  2:25 pm
Commenter: Toni Cacace-Beshears

Comments on proposed changes to Child Care Subsidy processing
 
Cap subsidy payments for children with special needs in order to bring consistency to such payments and to permit programmatic oversight of costs.
 
A cap on subsidy payments for special needs is okay as long as the rates are reasonable. Finding caregivers for those children are challenging. But how will the cap be determined, by the higher rates in Northern VA, by the lack of many providers in Southwest? Because a center can’t legally charge a different rate for special needs children, this should not affect center based care. It would be in the case of an individual, or specialized center that has higher rates.  
A change will limit the maximum of one annual registration fee paid per child to a child care vendor. A
limitation on payment of registration fees will result in more funding available for payment of direct
services in order to serve as many families as possible.
 
The problem with this is if there is a change in program through no fault of the family. A center closes, there is CPS allegation, center burns down, etc. the family should have the opportunity to have help. Currently the one annual registration has been in place here, and if a parent chooses to change programs, then it is not paid. Having the policy to never allow a second payment due to no fault of the family is hard on families.
 
A change is proposed to eliminate the payment of activity fees charged by providers. This change is
made in order to serve as many families as possible
 
Many programs charge an activity fee to cover some of the costs for programming that is a once a year fee. Summer is the best example, instead of increasing prices, summer activity fee is charged to cover the extra cost of field trips, activities and transportation. This does not acknowledge what is happening in the market. Putting a cap on the amount would be more fair to providers.
 
A change is proposed to require that all applicants for Child Care Subsidy be at least 18 years of age.
This change is required to ensure that applicants meet the legal age required to enter into the contractual
arrangement required in the Child Care Subsidy Program.
 
The children born to teenage/ minor mothers are some of the most at risk children. If they do not have subsidy available, then those parents will have an even harder time returning to school and or supporting their children. This could be solved with the parent or guardian of a minor co-signing the contract. If not, then it might force minor parents to give up custody to their parents in order to get services.
 
A change is proposed to require that all applicants and recipients cooperate with the Division of Child
Support Enforcement as a condition of eligibility for the Child Care Subsidy program. Cooperation with the
Division of Child Support Enforcement is intended to result in additional support and services for families.
 
This poses a greater problem for so many families that have a precarious, but workable arrangement. If a parent chooses to go this route, there is no guarantee that the state will be able to collect payments from an absent parent. If a family has an informal agreement, they should not be forced to be registered with the state program that could potentially cut their support system that is in place. The fallout could be those children are in a greater risk because eligible parents won’t apply, or those families have the income they are receiving removed because the state is unable to enforce child support.
 
A change is proposed to require that applications for Subsidy be processed within 30 days. This change
from 45 days to 30 days will require local departments to respond more timely to applicants and will bring
the Child Care Subsidy Program into alignment with other public assistance programs.
 
This standard should also apply to the processing time to the vendors.  
 
A change is proposed to limit receipt of Child Care assistance to 60 months per family. This change will
permit eligible families with young children to receive Child Care services through the period in a child’s
life when the cost of care is the most expensive, thereby helping families as they strive for self-sufficiency.
 
As families move towards self sufficiency, they are not typically there in five years. The loss of the help puts additional pressure on the families when they are starting to get some stabilization. One of the biggest concerns is the potential increase in latch-key kids in the communities at a time when the children need some support and guidance. There could be some guidelines that potentially have a smaller reimbursement for longer periods of time. When there are other siblings, that might have come into the programs during the second or third year, would run out and put those children at risk for finding quality care.
CommentID: 17565