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

www.cornerstonesva.org