The Mississippi Low-Income Child Care Initiative (MLICCI) is submitting written comments regarding Mississippi’s Child Care and Development Fund (CCDF) FFY 2019-2021 State Plan. Below we provide section-specific feedback.
Mississippi’s 2019-2021 CCDF State Plan acknowledges the significant changes in Mississippi’s CCDF program that occurred over 2017-2018. While the MDHS characterizes policy changes in 2017 and 2018 as occurring in the context of a “field-test year” (See, 7.4.6) for new parent and provider requirements, MLICCI urges the agency to continue current efforts to reinstate eligible parents terminated in 2017 and 2018 due to new procedures and continue its reported effort to eliminate the Pending Funding List.
MLICCI is encouraged to see the Standard Center designation deadline extend to October 2019. We are encouraged by the growing interactional nature of MDHS’s approach to child care providers and parents and we urge the agency to continue moving in this positive direction.
1.2.2
– The Plan identifies other state or territory agencies and community-based organizations as entities that conduct eligibility determination. MLICCI recommends providing a publicly available list of such entities on the MDHS and SECAC websites.
1.2.3
– The Plan references written agreements between MDHS and other agencies that perform administrative and implementation responsibilities and work related to the CCDF plan. MLICCI recommends providing a publicly available list on the MDHS and SECAC websites of agencies and other entities that are contracted or have formally agreed to conduct work related to CCDF administration and implementation and identify what work these entities are engaged to conduct related to CCDF administration and implementation.
1.4.1
– MLICCI recommends that MDHS provide additional detail and further clarification in the Plan regarding the proposed evaluation of child care need in Mississippi and more detail regarding what government entities may be engaged in a partnership to develop child care centers (i.e., city or county government?
A local social services agency?). MLICCI recommends that MDHS identify what indicators the agency will employ in evaluating child care need (i.e. eligible children and parents, available slots, affordability of child care)
– MLICCI recommends providing more detail and clarification in the Plan regarding several referenced committees to inform the following queries:
- How will MDHS work on committees at MSDH, MDE, SECAC, and HS to strategically develop full-day services that meet the needs of working families? When will these meetings occur? Will they invite the public?
- How will MDHS work in ongoing meetings with MDE and participate with collaborative groups with private funding to identify gaps in child care and develop strategies and set goals for meeting needs; and what are the collaborative groups with private funding?
– The Plan references formal coordination of the Mississippi Department of Employment Security (MDES) and the State Early Childhood Advisory Council (SECAC) to identify common goals and strategies across work force and early childhood sectors. We recommend MDHS explore whether non-referred CCDF clients could receive WIOA Priority of Service and if so, urge this policy change with MDES and WIOA partners. Low-income single mothers need child care to work or attend school or job training, but they also need a pathway to higher earnings. Single mothers are also the large share of adult CCDF and TANF recipients. Thus, we encourage MDHS to focus on services and programming for single mothers who need a combination of upskilling that will lead to a living wage and child care as a work support, in addition to other essential work supports.
1.5.2
– We applaud MDHS for identifying public pre-K expenditures and MSDH funding in the State Plan as sources of the required state match and MOE for FFY 2019-2021. When MDHS is unable to meet the matching portion of CCDF, the state loses millions of dollars and it takes years to recover as parents languish on the CCPP Pending Funding List. This happened in 2003 and again in 2016. CCDF helps keep Mississippi working and should be a priority for MDHS state funding. In addition to the language included in the state plan, we recommend that MDHS include language supporting a partnership with private non-profit organizations and other partners to identify sources of privately donated funds that can
be counted toward the match and MOE requirement. Further, we encourage MDHS to work with state legislators to support a state appropriation bill that allocates to the fullest extent possible General Funds of approximately $7 million to MDHS specifically to meet the state matching requirement. Such legislation was introduced during the Mississippi 2005 Regular Session. While it did not pass, we encourage MDHS to explore this policy proposal as a potential legislative solution to secure state CCDF matching funds in the future.
– We are encouraged by MDHS efforts to work through WIOA to identify private businesses to develop workforce and child care programs. We recommend that MDHS work through WIOA and with private organizations providing job training to women who have child care needs to identify a pipeline of prospective employees that will need child care to transition into jobs. Further, we recommend that MDHS encourage employers to work with training providers to align the credentialing pathways that meet employer needs to ensure that private businesses investing in the provision of child care for employees will have a trained pool of applicants who have a need for child care and higher paying work.
– MLICCI recommends providing more detail and clarification in the Plan regarding several referenced committees to inform the following queries:
- What does it mean that MDHS meets regularly with MDE, HS, and private entities to plan and start pilot programs and provide wrap-around services? And what model will be used to expand services in other underserved areas of the state and what are the underserved areas?
- How is MDHS working through WIOA to identify private businesses in MS to develop workforce and child care programs? What private businesses? Is the SNAP Employment & Training 50/50 reimbursement program being used to attract employers who retain employees receiving SNAP benefits? If so, has any employer taken advantage of this opportunity? If yes, what employers
and how much have they invested? - How is MDHS working through its workforce development division to identify private employers to partner with to develop child care provider relationships? What are these provider relationships and which employers and providers have partnered?
- What does it mean that MDHS meets regularly with MDE, HS and private entities to plan and start pilot programs and provide wrap-around services? What are the details of this model? Will this model be used to expand services in other underserved areas of the state?
1.7.1
– This section references a WIOA hub system that makes inter-agency referrals for job services. We recommend MDHS include language describing how the WIOA common case management service delivery effort interfaces with CCDF recipients, including both referred and non-referred CCDF clients. We recommend MDHS explore with WIOA partners whether CCDF clients specifically could receive WIOA Priority of Service and if so, urge this policy change with MDES and WIOA partners. Low-income single mothers need child care to work or to attend school or job training, but they also need a pathway to higher earnings. Single mothers are also the large share of adult CCDF and TANF recipients. Thus, we encourage MDHS to focus on services and programming for single mothers who need a combination of
upskilling that will lead to a living wage and child care as a work support, in addition to other essential work supports.
2.3.4
– We recommend including language in the Plan making clear that Head Start programs serving 3 and 4-year-olds are required to be licensed and that the only Head Start programs that are license-exempt are those that operate in conjunction with an Elementary school.
2.3.6
– We recommend including language in the Plan clarifying whether or not the criteria a center must meet to achieve the Comprehensive Center designation is finalized or still in development. Will the criteria for Comprehensive designations change as the proposed pilot is implemented and prior to the proposed 2021 phase-in of Comprehensive centers? The Plan references a future pilot and lists ten goals areas. Are these ten goal areas finalized or still in development? Is the Comprehensive Center pilot open to any child care center that volunteers to participate?
2.3.7
We recommend that MDHS eliminate center violations after five years where centers have had no subsequent violations.
2.4.3
– Child care centers need additional revenue, and the federal CACFP program offers additional revenue for centers serving CCDF eligible children. The CACFP as currently administered deters centers from participating and is unnecessarily burdensome, leading to a low take-up rate among eligible child care centers in Mississippi. We recommend that MDHS include language in the Plan and on its website identifying Healthy Centers Healthy Kids as a non-profit CACFP sponsoring organization that can help child care centers become a part of CACFP and receive administrative assistance that will ease the burden of participation so that centers and their children can benefit and so that Mississippi can take better advantage of this available federal revenue.
3.1.5
– MDHS needs to serve more parents. CCDF is designed to provide child care as a work support for low-income working parents. The priorities listed in 3.1.5 do not give non-referred working parents high priority. Specifically, 3.1.5 fails to include as a priority population parents who are working or attending an approved education/job training program whose income is between 50% – 85% of the state median income. We recommend including this priority population in the listing of priority populations in 3.1.5 to be consistent with the state’s current CCPP Policy Manual and consistent with the state’s income eligibility cap of 85% of SMI. Mississippi needs to serve more non-referred low-income working parents who are not in a program like TANF or TCC or foster care parents. Very few parents in the “non-referred” categories have received a CCDF voucher in the past several years.
- We urge MDHS to make non-referred low-income working parents earning below 50% of state median income and between 50% – 85% of state median income a higher priority for service in section 3.1.5.
- MDHS should earmark portions of direct TANF funds for CCDF eligible working parents who are “non-referred” clients to be spent on directly on child care from TANF.
- MDHS should utilize the recent increase in CCDF discretionary funds to serve those children of working parents who are on the current Pending Funding list.
- MDHS should use the coordination proposed in section 1.4.1 between MDHS, SWIB and SECAC to give working parents higher priority for CCDF service to support work and to explore giving CCDF recipients WIOA Priority of Service.
– Parents who lose TANF or TCC do not have a seamless transition into regular CCDF eligibility and often lose their child care, which can have a negative impact on work.
- MLICCI recommends MDHS include language in the Plan regarding a strategy to create an interagency process for transitioning TANF or TCC clients from TANF or TCC child care to CCDF child care to prevent the loss of child care as TANF or TCC clients leave welfare for work.
- While MLICCI maintains that the maximum allowable TANF funds should be transferred to CCDF for child care (30% of federal TANF funds), TANF funds should also be spent directly on child care for TANF recipients, TCC recipients, foster care parents and others.
- MDHS should maximize TANF direct spending for TANF recipient direct child care
3.1.6
– MDHS retains the authority to extend CCDF eligibility for periods greater than 12 months to provide continuity of care and to align early childhood programs. MLICCI recommends that the state extend CCDF eligibility for periods greater than 12 months when appropriate for children who receive a CCDF voucher who are also enrolled in EHS, HS or in one of the state’s Early Learning Collaborative programs to align enrollment and ensure continuity of care across the different programs.
3.1.9
– Mississippi has required all single parents applying for CCDF, if they don’t already have one, to initiate a child support case against the other parent since 2004. While a portion of recipients served through CCDF funds are TANF recipients and are subject to that requirement and denial for non-compliance by state and federal law, the CCDF program is designed to serve an even wider range of low-income working parents who may not be income-eligible for TANF, but who are eligible for CCDF as a work support. When this requirement went into effect in 2004, MDHS reported that the waiting list for child care certificates fell from over 10,000 to 200 in less than two months.
A survey of 144 child care centers conducted by the MLICCI at the time showed that 1,284 children lost their child care certificates because of this requirement, an erosion of 40% of the children in the surveyed centers. At a 2016 statewide child care meeting, MLICCI surveyed 162 providers and 91% said the state’s child support requirement in CCDF keeps eligible parents they serve from applying. What’s more, neither Head Start nor public Pre-K in Mississippi has a child support requirement. New CCDF rules make clear that a primary program goal is to increase the share of eligible parents and children participating in the state certificate program.
New rules also make clear that aligning early childhood programs is key to improving the delivery and continuity of services for low-income families. To reduce complication in CCDF eligibility and delivery, MDHS should eliminate the Child Support requirement in CCDF so that parents can access the support they need for work and so CCDF in Mississippi can be better aligned with policies in other federal and state supported early childhood programs.
3.1.11 (c)
– We recommend that MDHS require a written notice to referred TANF clients explaining in writing at an appropriate reading level that parents who receive TANF benefits are entitled to an exception to the individual penalties associated with the TANF work requirement for any single custodial parent who has a demonstrated inability to obtain needed child care for a child younger than 6.
3.4.4
– In addition to waiving co-payments for TANF and homeless clients, MLICCI recommends the state exercise its option to waive co-payments for all families whose income is below the poverty level for a family of the same size and for those families who are receiving protective services.
4.1.1
– We recommend that MDHS collect race data on the CCPP providers.
4.1.3
We recommend that MDHS recompete the slot-based contracts at least every three years.
4.4.1
– In 4.1.5 of the Plan, MDHS states that in-home care providers are not currently eligible to serve CCDF children. MLICCI recommends including language in 4.4.1 clarifying the definition of part- and full-time family child care, which is currently allowed, to distinguish this allowable provider type from in-home care providers, who are no longer eligible to participate in CCDF.
– The Standard Center designation is a mandatory requirement for child care providers to be eligible to serve children receiving a CCDF voucher according to the most recent CCPP Policy Manual. The previous QRS was voluntary and non-participation did not result in a provider losing their status as a CCPP approved provider and, thus, losing the ability to be paid for CCPP services. Many licensed child care centers currently serving children receiving vouchers have not yet met the requirement to become designated as a Standard center. While the plan projects a future deadline for meeting this requirement of October 2019, several details remain unclear:
- Details provided in 4.4.1 and in 7.1.1 include information about the requirements to achieve the designation of Standard Center, but there is no reference to completing the Standard Center application online. Does that mean that the online application is no longer required? Are there now multiple avenues to complete the Standard Center application to achieve this designation?
- What is the status of centers without the Standard Center designation but currently participating in CCPP between now and 10/19? Will these centers be reimbursed for child care services through CCPP? What reimbursement rates will apply?
- If the online application is still the only avenue for centers to complete the application to become a Standard center, we recommend that MDHS consider application pathways for providers currently in the state’s CCPP system so that they remain part of that system and so parents can choose the provider who is in their community and who best meets their needs.
- We recommend that MDHS consider offering on-site technical assistance with completing the Standard Center Application and we recommend identifying the newly established Early Learning Academies as this TA provider.
4.6.1
– Where can the state strategic plan that is referenced be found for review? We recommend providing a URL to the referenced strategic plan in 4.6.1.
4.6.2 (d)
We recommend that MDHS recompete the slot-based contracts at least every three years.
Re: those counties where DHS contemplates giving priority because there is currently no provider in the county, we should look at those counties. What’s the # of eligible children? What’s the population? This data could clarify the extent of the need in those counties.
5.1.3
We recommend clarifying language regarding license-exempt child care providers. We recommend including language in the Plan making clear that Head Start programs serving 3 and 4-year-olds are required to be licensed and that the only Head Start programs that are license-exempt are those that operate in conjunction with an Elementary school.
5.2.2.11
We recommend that MDHS not advise parents and providers that “Physical discipline, including spanking, performed on a child by a parent, guardian, or custodian in a reasonable manner shall not be deemed abuse.” There are instances where an instance may, in fact, need to be reported as abuse; and putting this in the plan may leave providers thinking they don’t need to report when they actually do.
6.1.1 – 6.1.3
– The State Plan describes new professional development strategies in section 6.1.1. This section also projects a new child care directors’ credentialing program that is to be developed. The coaching process described in section 6.1.3 sounds extensive. Child assessment, quality assurance and monitoring, and data collection described throughout the plan is proposed but the specifics are not provided. MLICCI urges
MDHS to avoid designating one particular professional development pathway to quality compliance and ensure providers are able to pursue the pathway of their choice and that best meets their needs. Additionally, we urge MDHS to provide financial stipends to child care centers to provide staff with wage supplement bonuses tied to higher levels of education designed to retain teachers who obtain higher levels of professional development through the identified pathways. These stipends could serve as financial incentives for child care teachers to remain in child care centers and would help providers retain a more highly qualified workforce and avoid a roadway out of child care centers and into
secondary education. Further, we recommend that MDHS provide more information in the Plan, including:
- Provide clarity about how the proposed professional development categories will be implemented, including how providers will achieve these categories, whether these categories will become requirements, whether MDHS will provide support to reach these categories.
- We urge DHS to provide wage supplemental stipends for staff as financial incentives for attaining higher levels of training/education that section 4.6.1 says MDHS is exploring.
- What is the Work-based Learning Pathway the community college board is currently developing and is it connected to MDES or WIOA?
- Provide more information about the proposed new child care directors’ credential, including who will develop this and when, how it will be made available to providers, will it become a requirement, will MDHS provide providers with support to attain this new credential?
- What data will be gathered, how and by whom? What will the data be used for? How will the data be used for monitoring? How will child assessments be administered? Who will collect child assessment data and how will this data be used?
7.3.1
– What is the series of focus groups and workgroup meetings DHS held to assess the feasibility of standard and comprehensive designations, and what data from these groups informed the standard and comprehensive applications?
7.4.1.4
says that quality assurance and monitoring is part of the SLDS data. Actually, data is referenced throughout this plan and it raises this question in every case – assuming in every case, and certainly in the case of SLDS that NSPARC will be doing all the data gathering. How will that work? What data? How will it be used? Also, it says DHS will launch statewide child screening assessments. What does that
mean?
7.4.6
– What is the lead agency preferred provider registration platform? Is this the Standard Center online application? We recommend providing some additional clarifying language regarding the definition of “preferred provider registration platform”?