My name is Clara Battle, and I am the owner of Big Minds Little Steps and a Licensed Home-Based Child Care Provider in Virginia. I am submitting this comment because I believe the proposed Child Care Subsidy Program Guidance Manual provides an opportunity to better recognize home-based child care providers as the small business owners that many of us are.

Operating a licensed home-based child care program involves much more than caring for children. We are responsible for managing our businesses, maintaining licensing compliance, keeping financial and tax records, obtaining insurance, purchasing supplies and equipment, and meeting the many other responsibilities that come with operating a child care business.

Many home-based child care providers have taken the additional step of legally establishing their businesses as LLCs, corporations, or other business entities. We do this for legitimate business reasons, including creating a clear distinction between our personal and business affairs and operating our child care programs as professional businesses.

For that reason, I believe the Child Care Subsidy Program Guidance Manual should clearly address whether a licensed home-based child care provider may participate in the program using the provider's legally established business entity.

If a provider has established a legal business entity through which the child care program operates, there should be clear guidance explaining how that entity is treated for provider enrollment, W-9 documentation, banking information, tax reporting, and subsidy payments.

This is particularly important because home-based child care providers should be able to understand how their business structure will be recognized before enrolling in the Child Care Subsidy Program. Providers should not have to choose between establishing their businesses in a manner that separates their personal and business affairs and participating in a public program designed to help families access child care.

I respectfully encourage the Virginia Department of Education to use this revision of the Guidance Manual to provide greater clarity and consistency for licensed home-based child care businesses. Specifically, I ask the Department to clarify how a provider's legally formed business entity may be recognized within the Child Care Subsidy Program and, if different requirements apply to licensed home-based providers and licensed child day centers, clearly explain those differences and the legal or programmatic basis for them.

Home-based child care providers are an important part of Virginia's child care infrastructure. We are also entrepreneurs and small business owners. The Child Care Subsidy Program Guidance Manual should provide clear guidance that recognizes both roles.

Thank you for considering my perspective as a Licensed Home-Based Child Care Provider and small business owner.

Respectfully submitted,

Clara Battle
Owner, Big Minds Little Steps
Licensed Home-Based Child Care Provider