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