The Northern Virginia Association for the Education of Young Children (NVAEYC) represents more than 1,250 early childhood teachers, family child care providers, parents and other professionals who care about and work to promote the healthy development of all young children.

We offer the following comments on proposed changes to child care regulations, 22 VAC 40-661. 

The subsidy program providers a crucial safety net for low-income working families. NVAEYC members know these families, see the different a subsidy makes, and know how difficult the current system can be. We are pleased to see 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. However, we are very concerned that some of the other proposed changes to state regulations will negatively impact families in the program. 

Proposed cap on subsidy payments for children with special needs in order to bring consistency to such payments and to permit programmatic oversight of costs.

We urge you to not adopt this proposal and maintain current payment rates for subsidy for children with special needs. Child care for children with special needs is in limited supply and very difficult for families to find. This care is more expensive to provide, and early childhood programs are doing what they can to make ends meet while serving the families who need them. Especially in our state 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. The proposal documents acknowledge this challenge. These are not consequences to be taken lightly.

Proposedsixyear limit on receipt of child care subsidy. “A change to limit the time families may receive subsidized child care will permit more eligible families who are on a waiting list to be served.”

We urge you to continue the current policy of allowing a locality the option of imposing a time limit, instead of making six years the statewide mandate. There are working families in Northern Virginia whose income does not increase sufficiently over time – even over a six-year period - to enable them to afford the cost of care in this area.  For families with more than one young child, this limit will not cover the years prior to school entry. 

In Fairfax County tuition for one infant ranges from approximately $14,500 to $16,000 per year, far out of reach of a family eligible for but denied child care assistance. Discontinuing a subsidy for a working family will jeopardize their employment and undermine the investments already made in supporting their efforts to become economically self-sufficient. 

Limiting the subsidy may also result in families using unsafe, unregulated child care. Quality early childhood and school-age child care can help narrow the achievement gap by boosting student achievement and academic gains for low income and minority students.

This proposal won’t allow more families to be served; it would allow different families to be served. This is deeply challenging but we do not support dis-enrolling children from the early care and education program of their parent’s choice. The consequences for that child cannot be justified. We must work together to increase state investment to enroll off the waiting list, but not at the elimination of services for those currently enrolled.  

Proposed requirement that families register/cooperate with DCSE. 

We urge you to “encourage” families to register with DCSE, instead of making this a condition of eligibility for child care assistance. The proposed requirement will actually discourage families from applying for the subsidized child care services they need in order to work and pay for child care.  And without access to affordable, reliable child care parents put their employment at risk.   

A study released by Child Care Matters (2004) found that this kind of requirement was "preventing income eligible families from applying for child care subsidy, hurting enrollments in regulated early education programs, and undermining a parent's ability to access safe and quality child care." 

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 at-risk family.  In cases where parents have an informal support arrangement and the custodial parent reports this income on the child care subsidy application, this proposed requirement will change that relationship and may force parents into adversarial roles at the expense of the child.

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.

Proposed requirement that applicants for subsidized child care must be 18 years of age. 

We urge you to not adopt this proposal. Child care subsidies enable teen parents to complete their high school education and enter the workforce.  These young parents are particularly vulnerable and the child care subsidy is a key component of the safety net needed to ensure that they and their children are safe and well.  Children who do not complete high school are less likely to be a part of the educated and skilled workforce that our state needs now and in the future. 

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

We urge you 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. 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. 

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. While these may sound like small changes, on a low-wage family budget the change is insurmountable. Local decision-making on fee scales is in the best interest of families.

We appreciate this opportunity to provide comments on the proposed regulations and thank you for your consideration. 

Sincerely,

Paige Beatty and Gay Hitchcock, Co-Presidents, Northern Virginia Association for the Education of Young children