I am the Executive Director of ACCA Child Development Center. Founded in 1967, it is one of the human service programs funded by the Annandale Christian Community for Action. We provide affordable, high-quality early education to 183 children, ages 3 months to 5 years.

The children served come from low-income families, and the areas we cover are multicultural, with high concentrations of immigrants.

A large number of our children come from single-parent homes with multiple siblings, where the primary caregiver is usually working for longer than eight hours and often in more than one place of employment. The average income of our parents is $25,000 per year. Also, many of the families are not native English speakers. At present, 80% of our children are Latino.

Research has shown the benefits of providing high-quality early education to minority children. Providing young children with a healthy environment in which to thrive is not only good for their future, but it is great for the public’s fiscal bottom-line. Three recent studies found returns between $4 and $13 for every dollar invested in early learning. Program participants followed into adulthood benefited from increased earnings while the public saw returns in the form of reduced special education, welfare, crime costs and increased tax revenues.

Because of federal, state and county subsidies for tuition and donations from community partners, our tuition rates are among the lowest in Fairfax County. Without such support, our families could not afford our program. Make no mistake, our parents work hard; they love their children; but they need help. The subsidy for child care is essential if they are to enroll their children in early programs that meet their educational needs.

In recent years, the state and county have changed the way tuition subsidies are administered. Some of the changes have been positive, but others have created problems. In this regard, the proposed changes to state child care regulations (22VAC40-661) that are described below will limit the ability of child care providers to make decisions that are in the best interest of the families in their communities.

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

Eligibility in the fee program is limited to a total of 72 months per family. Receipt of assistance in any other category does not count toward the 72-month limitation.

Although many families receive child care subsidies for fewer than six years, there are some working families whose income does not increase sufficiently over time to enable them to afford the cost of care. With the above regulation, 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 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 may 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.

Currently, localities have an option of imposing limit on a family’s receipt of child care subsidy. Continuing to allow local agencies the option of implementing a limit would 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

“…An applicant or recipient of child care subsidy services must provide the information required by the Division of Child Support Enforcement to locate an absent parent, establish paternity, or establish a support order, unless a basis for good cause for noncooperation is determined by the program.

We recognize 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 subsidized child care should be encouraged to obtain child support benefits for their children. In Fairfax, staff refer single-parent families in the child care subsidy program to the DCSE.

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 afraid to register 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. 

Although the regulations indicate that an applicant must provide the information required by DCSE to locate an absent parent, establish paternity, or establish a support order, unless a basis for good cause for noncooperation is determined by the program, the requirements for establishing and documenting “good cause” are stringent and may be difficult to meet.

Even though families should be encouraged and supported as they apply for benefits through DCSE, giving localities the option of requiring DCSE registration would better ensure 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

A change will ensure that applicants for subsidized child care meet the legal age requirement to enter into the contract to receive child care subsidy payments.

Over the years a number of parents under the age of 18 have received subsidized child care in Fairfax County while they have completed high school. Child care subsidies have enabled these teens to complete their high school education and to enter the workforce. 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. A local option to support serving teen parents will enable localities to continue these beneficial programs.

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

“…Copayments are established by the department. All families receiving child care subsidy have a copayment responsibility except those families whose gross monthly income is at or below the federal poverty guidelines who are recipients of TANF, participants in the SNAPET program, or families in the Head Start program will have no copayment.”

Current child care regulations authorize the state to approve local alternate fee scales as well as impose a state-wide sliding fee scale for all families enrolled in the subsidized child care program.  During the past year VDSS has indicated its intent to remove approvals for alternate scales that meet the needs of families in particular areas and to establish a single state-wide fee scale for all families. In effect, without the inclusion of alternate fee scales, VDSS will be able to mandate at the state level, a single set of percentages by which parents copayments will be calculated. Unless there is an option for a local scale, a locality cannot develop a system for parent copayments that meets the needs and the economic reality of that locality.

For over 15 years Fairfax County has had a waiver from the VDSS to use a local sliding fee scale, rather than the state fee scale, to determine parent copayments for child care. The Fairfax fee scale works because it best meets the needs of families in the county 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.

Sincerely,

Maria-Isabel Ballivian

Executive Director