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 Proposed
Comment Period Ended on 1/17/2014
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1/17/14  9:37 am
Commenter: Sharon Zamarra, Fairfax County Community Action Advisory Board

Proposed Child CAre Regulations
 

The Fairfax County Community Action Advisory Board (CAAB) wishes to add its name to the list of organizations and individuals who have concerns about Virginia’s proposed changes to the state child care regulations (22VAC40-661).  The CAAB is the only local advisory board that includes representatives of Fairfax County’s low income population and has advocated for many years for programs that it believes do the most to help low income individuals and families achieve economic security.  Affordable child care has been at or near the top of this list since its inception.  

Affordable child care is one of the most important supports we can provide for people who need to work.  Without affordable child care, many parents would have to leave the workplace.  Child care assistance is essential to continued economic growth and preserves local investments in welfare to work programs.  In addition to affecting working families, the existence of affordable child care affects the business community as well.  When families are not able to afford child care services, the vitality of many small businesses are at risk, including child care providers themselves.  If families who receive subsidies are no longer able to afford child care, some centers may have to close classrooms, lay off staff, or even close.

Proposing removal of approved alternate fee scales and proposing that a state-wide sliding fee scale be established

The CAAB has serious concerns with the changes being made that prevent Fairfax County from utilizing its own sliding fee scale.  The fact that families currently paying a minimum of 2.5% of their gross income for care will have to pay 5% of their gross income for care starting in September is disheartening, but the fact that this change is being instituted simply for the sake of statewide uniformity is unconscionable.  The cost of living throughout the state of Virginia is not uniform.  The chart below illustrates the kind of increase with which families will need to cope:  A family of four with a gross monthly income (GMI) of $1,921 (or an annual income of $23,052 which is just above the federal poverty guideline) will pay an additional $576 in copayments annually if the family has one child in care.  This is a significant increase when a family may well pay over $1,000 per month for an apartment in Fairfax County.

 

 

GMI for Household with Four Members

% of Payment

Monthly Copayment Amount

Annual Total

VDSS

$1921

5%

$96

$1,152

Fairfax

$1921

2.5%

$48

$576

This is simply unacceptable.  Raising the rates on our most vulnerable residents by 100% for no good reason is a cruel and unusual punishment.  While not all of them will see such a dramatic increase, the Office for Children estimates that over 500 families with incomes at or below 100% of the Federal Poverty Level will see their fees increase as a result of this change.   Please reconsider your decision to deny Fairfax County permission to use the alternate fee scale that has served this community so well for the past 14 years. 

Proposed 72-month limit on a receipt of child care subsidy

Families who need the child care subsidy are working their way back to economic security and are in a period of transition.Often they have traveled a long way to get back on their feet and they may still have a long way to go to be truly economically secure.Pulling the rug out from under them would have a devastating effect.During a tenuous economic recovery, it does not make sense to institute a policy which would make it more difficult for people to continue working.The best way to eliminate the waiting list for subsidies is to increase the amount the Commonwealth budgets for the subsidy, not to remove people from the program before they are ready.

Families who receive the fee-system child care subsidy in Fairfax County have a median household income of $25,992 in a County where the overall median household income is around $100,000. The average range of the cost of center-based care for a preschooler is $8,000 to $13,000 per year, comparable to the cost of average fees and tuition to college.  Center-based infant care is even more expensive; running $14,500 to $16,000 per year in Fairfax County.   Only the cost of housing (21%) takes a larger percentage of a family’s household income in average in Virginia than child care (20%).  

On the surface, the reasoning behind this proposed change appears to be sound.  There are an increasing number of families on the waiting list for subsidies (in Fairfax County alone there are 2,900; statewide there are 11,733) and limiting the time for receipt of subsidies may allow more of these families to be served.   But, what happens to those families who still need the subsidies? 

The story of one Fairfax County family receiving subsidized child care illustrates the value of helping families for longer than months.This family began its association with subsidized child care in 2005, when the mother was cleaning houses.After two years at a child care center, the older child made a successful transition to kindergarten, was identified for the gifted and talented program and now attends a third grade GT class.The younger child has been at the center for two years.The mother is now a caregiver for a senior adult. She has improved her English and is in the high school adult education program.The father works and is supportive of the family.Although this family has made substantial progress, they still need additional support before they achieve economic security.

Perhaps the worst reason to justify restricting child care support to months is the state’s desire to have arbitrary uniformity across jurisdictions.While it may appear to be easier in the short term to have the same rules in every community across the state, it is not necessary,

If this regulation change is enacted, what would happen to those families who would lose their child care subsidy?They may turn to unregulated and possibly unsafe care in an attempt to maintain their employment and put their children at risk, or they will be forced to leave the workplace and place their family’s livelihood in jeopardy.Either way, the safety and stability of a family is compromised with no discernible benefit to the Commonwealth.

CommentID: 30935