These comments are provided in response to the proposed child care regulations [22 VAC 40-661] by Bethany House of Northern Virginia, Inc.  Bethany House has provided emergency shelter and supportive services to victims of domestic violence in Virginia since 1979.  For 34 years, women and children at risk in the Commonwealth have reached out to Bethany House to help them escape from abusive home environments and develop resources to attain healthy self-sufficiency.  We provide wrap-around services that include safe housing, transportation, basic needs, employment support, counseling, life skills classes, and children’s services.   

It is important to note that financial abuse plays a large role in many unhealthy relationships. The abuser may use the family’s finances to control and manipulate a partner who becomes dependent on them for food, clothing, housing and other basic needs.  As a result, employment plays a critical role in helping our clients break free of abusive relationships.  The benefit of having their own income means our clients do not have to depend on an abusive partner to provide basic needs, feed their children, or even buy back-to-school supplies.

Having suffered from financial control, including not being able or allowed to work, the majority of our clients are low-income to extremely low-income when they first exit the abusive relationship.  These women depend on child care subsidies to successfully and permanently leave abusive partners and rebuild lives free from abuse.  The victims we work with cannot find or maintain employment without affordable and reliable child care.  Child care subsidies are without a doubt a lifeline for many of our clients. 

These comments are intended to share our experiences in working with victims of domestic violence who access child care services through local government offices. 

Proposed requirement that families register and cooperate with DCSE:

Clients of Bethany House do not exit their intimate partner relationships frivolously; they do so out of fear and out of a desire to create a safe environment for themselves and their children.  Quite often, it becomes necessary for these individuals to cease contact with their abuser, absent a court order, in order to preserve their newfound freedom and security.  Simply exiting the relationship is not enough to insure safety.  The risk of violence for a victim of intimate partner abuse remains statistically significant for up to two years after ending the relationship. Ongoing contact with an abuser places many victims at further risk of harm, including homicide, and may place the children at risk of parental abduction or retaliatory homicide.  This is a very real concern for victims of domestic violence. Throughout the Commonwealth, family and intimate partner violence accounts for one-third of all homicides in the state.  In Fairfax County, that number is even higher.  Over half of homicides (57%) were domestic-violence related, and the majority of those homicides occurred after the victim ended the relationship.

It is our contention that requiring families to register and cooperate with Division of Child Support Enforcement (DCSE) will place victims of domestic violence and their dependent children at risk from an abusive partner. Furthermore, this risk may deter families eligible for child care support from seeking a child care subsidy.  Fear that an abuser may locate them precisely because they sought government support places a burden on victims of violence and will further isolate these vulnerable families and imprison both the parent and children in poverty. 

The proposed regulations include an application for relief from the requirement to register and cooperate with DCSE. However, the criteria required to merit a waiver have been described as stringent, at best.  We request that VDSS consider the ramifications of this requirement carefully in order to insure the long-term health and viability of a victim of domestic violence and her dependent children.

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

The proposed regulations suggest a limit of 72-months in which a family may be eligible to receive the child care subsidy.  This limitation places a significant burden on single wage-earning families with multiple children, such as those families served by Bethany House. As identified in the preceding section, a significant challenge for many of our clients is finding and maintaining stable employment.  The average family entering BHNV’s emergency shelters is a woman with two children, but a client may also have three, four or more small children.  Again, I state with emphasis that these families are entering BHNV’s shelters in order to escape domestic violence.  The proposed 72-month restriction would severely limit a mother with multiple small children from reaching self-sufficiency and may propel her back into an abusive relationship once she has reached the 72-month limit as she will no longer have the ability to work without child care. 

In enacting the proposed changes, at-risk families with multiple children may be forced to choose between the lesser of many evils. A victim of domestic violence may benefit from short-term sufficiency, but under the proposed changes at 72 months she will have to choose between returning to a relationship where the victim is financially dependent on an abuser, find cheaper, unregulated child care, or leave her children at home while she works with the hope that nothing will go wrong.   All of these solutions carry significant risks to young children who do not have the ability or maturity to improve their circumstances on their own. 

We strongly urge VDSS not to penalize at-risk families with multiple children by limiting their access to subsidized child care.  We recognize that limitations may be necessary in order to extend benefits to as many needy families as possible, but those limits should be made at the local level by individuals who understand intimately the challenges faced by their neighbors. 

We thank you for your consideration of these comments and others provided through public comment. 

Respectfully,

Catherine Hassinger

Executive Director