In January 2016, over 1,500 NAEYC members completed a survey to share their appreciation for – and their concerns about – the proposed regulations from the Administration for Children and Families implementing the 2014 reauthorization of the Child Care and Development Block Grant (CCDBG). NAEYC then submitted comments reflecting the collective experience and expertise of the field.
Last week, in a significant accomplishment, ACF issued the final CCDBG regulations, marking an important step forward for children, families and educators by clarifying the goals of the law, improving the health, safety and quality of child care, supporting the early childhood profession, and making child care assistance more accessible and stable for families.
We are delighted to report that many of our recommendations, as well as those submitted in partnership with the National Women’s Law Center and CLASP, were recognized and responded to in the final regulations, and we continue to be gratified by the inclusion of the six components of a professional development framework aligned with those that NAEYC has identified and supported.
Some highlights of the final rule include the following requirements for states to:
· Establish minimum twelve month eligibility periods (which leads to much-needed consistency for children, families and educators).
· Establish a graduated phase-out of subsidies for families who, at eligibility redetermination, exceed initial State income thresholds but still have modest incomes. (This allows families to say yes to a small raise, without worrying that accepting the increase would result in losing their child care because of it).
· Describe policies to prevent suspension and expulsion of children birth to age 5 in child care and other early childhood programs (a matter of deep importance to NAEYC and many members, families and partner organizations).
· Improve important provider payment practices, including: base payments to providers on child attendance rather than enrollment; take the cost of providing quality child care into account when setting provider subsidy payment rates; show how base payment rates enable providers to meet health, safety, quality, and staffing requirements; and use valid methodologies to update rates at least every three years.
In addition, among the areas for which NAEYC provided comments, we find that the final rule:
· does not prohibit providers from charging families fees above co-pays, a desirable but problematic strategy that threatened accessibility of quality care;
· integrates increasing compensation throughout the regulation as a strategy for improving quality;
· requires background checks for all adults over the age of 18, including those in a family child care home;
· maintains a three-month period to complete orientation or pre-service training, with appropriate supervision in place; and
· requires states to monitor providers receiving CCDF funds (including those that are license-exempt), at least annually.
Please stay tuned for more information and tools from NAEYC and partner organizations – and in the meantime, feel free to do your own reading via fact sheets and slideshows from ACF.
Finally – and crucially – we look forward to continuing to work with you and all of our partners to secure new federal and state investments to support the implementation of the CCDBG law and rule, so that all eligible children and families can benefit from improvements to the health, safety and quality of child care.