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 

www.ucmagency.org