Priority 3: Competitive Preference Priority - Including all Early Learning and Development Programs in the Tiered Quality Rating and Improvement System

To receive competitive preference under this priority, the State's Plan must be designed to increase the number of children from birth to kindergarten entry who are participating in programs that are governed by the State's licensing system and quality standards, with the goal that all licensed or State-regulated programs will participate. The State must demonstrate in its application that--

  1. It has a licensing and inspection system that covers all programs that are not otherwise regulated by the State and that regularly care for two or more unrelated children for a fee in a provider setting, or that it has a High-Quality Plan to implement such a system by June 30, 2013; and
  2. All licensed or State-regulated Early Learning and Development Programs participate in the State's Tiered Quality Rating and Improvement System, or that it has a High-Quality Plan to implement such a system by June 30, 2013.

Comments

  • Add “The State’s Plan may be aligned with other existing State plans for child and youth services.”

On behalf of the Office of the Governor of the State of Illinois, the Illinois State Board of Education and the Illinois Department of Human Services: We support the Administration’s goal of improving the quality of early learning and development programs through the expansion of the number of programs participating in the State’s QRIS system. However, there are specific provisions under this priority that require clarification.

Priority 3(a) provides that States demonstrate that they have a licensing and inspection system that covers all programs that are not otherwise regulated by the State and that regularly care for two or more unrelated children in a provider setting for a fee or that they have a High-Quality Plan to implement such a system by June 30, 2013. We request that the Administration clarify whether this section means that all providers that care for more than one child unrelated to each other or more than one child unrelated to the provider must be part of the States licensing and inspection system OR if the States must have some oversight and monitoring system in place for all providers that are not required to be licensed if they regularly care for children for a fee. Licensing has a very distinct meaning to States.

Priority 3(b) requires States to demonstrate that all licensed or State-regulated Early Learning and Development Programs participate in the State’s Tiered Quality Rating and Improvement System or that it has a High-Quality Plan to implement such a system by June 30, 2013.

We request clarification on whether this means that all types of programs need to participate (e.g. pre-school, home visiting, child-care) or that every program within a type needs to participate by June 30, 2013. We would recommend that States be encouraged to increase participation by as many individual programs as possible through increased marketing and other incentives, but that the system remain voluntary.

On behalf of the Office of the Governor of the State of Illinois, the Illinois State Board of Education and the Illinois Department of Human Services: We support the Administration’s goal of improving the quality of early learning and development programs through the expansion of the number of programs participating in the State’s QRIS system. However, there are specific provisions under this priority that require clarification.

Priority 3(a) provides that States demonstrate that they have a licensing and inspection system that covers all programs that are not otherwise regulated by the State and that regularly care for two or more unrelated children in a provider setting for a fee or that they have a High-Quality Plan to implement such a system by June 30, 2013. We request that the Administration clarify whether this section means that all providers that care for more than one child unrelated to each other or more than one child unrelated to the provider must be part of the States licensing and inspection system OR if the States must have some oversight and monitoring system in place for all providers that are not required to be licensed if they regularly care for children for a fee. Licensing has a very distinct meaning to States.

Priority 3(b) requires States to demonstrate that all licensed or State-regulated Early Learning and Development Programs participate in the State’s Tiered Quality Rating and Improvement System or that it has a High-Quality Plan to implement such a system by June 30, 2013.

We request clarification on whether this means that all types of programs need to participate (e.g. pre-school, home visiting, child-care) or that every program within a type needs to participate by June 30, 2013. We would recommend that States be encouraged to increase participation by as many individual programs as possible through increased marketing and other incentives, but that the system remain voluntary.

We recommend changing the criteria language to reflect the importance of children’s successful transition into kindergarten and to encourage strong relationships and coordination between Early Learning and Development Programs and public schools. For example, we recommend replacing “from birth to kindergarten entry” with “from birth through transition to kindergarten, ” as follows:

“To receive competitive preference under this priority, the State Plan must be designed to increase the number of children from birth “through transition to kindergarten” who are governed by the State’s licensing system . . . “

We also urge the secretaries to consider that Family, Friend and Neighbor Care (FFN, also referred to as informal or unlicensed care), serves a vast majority of High-Need Children under age 5. FFN care is also often the most common, if not the only, form of care in rural communities. Thus, FFN providers represent a critical opportunity for promoting positive child outcomes.

Research shows that FFN providers often have similar needs and characteristics of the parents of the children in their care. As we have learned from several States, the Strengthening Families Protective Factors are useful for framing and informing strategies to support FFN providers. Like parents, FFN providers benefit from efforts to
* Increase provider resilience to encourage positive, trusting and caring relationships with children and their parents.
* Facilitate social connections within their communities and with other FFN providers.
* Ensure access to concrete supports in times of need.
* Deepen their knowledge of parenting and child development
* Support them in promoting the social and emotional competency of their children.

QRIS criteria for FFN providers must also be accompanied by opportunities and resources to encourage their involvement and meet their needs. Most critical for this population, these opportunities must be linguistically and culturally appropriate for the diverse populations of informal care providers.

State Strengthening Families efforts offer examples of creative approaches to supporting FFN care providers, for example, through community cafes, free training and workshops, and stipends and support for them to participate.

Another effective strategy is to link or integrate support into community activities available for young children, such as Play & Learn groups, which started in Hawaii and have now spread to communities in several other States. These are facilitated play groups for young children and their caregivers and/or parents, run by community organizations in a variety of locations including libraries, community centers, family support centers, etc.

A 2007 evaluation of Play & Learn groups in Seattle/King County, Washington found this strategy to be the most successful approach to supporting FFN caregivers. Among participating FFN caregivers and parents, 72 percent reported increasing knowledge about their role in helping children be ready for school and 77 percent reported changing what they do with the children in their care “a lot more”. Most strikingly, among FFN providers and parents who answered the survey in a language other than English, 87 percent reported knowing a lot more about helping kids prepare for school and understanding how children learn through play, with 92 percent saying they have changed their behavior because of what they’ve learned at Play & Learn.
(Source: Organizational Research Services, "Family, Friend and Neighbor Caregiver Project, 2007 Report" (prepared for Child Care Resources), January 2008. Retrieved from http://childcare.org/ffn-care/FFN-final-report-013108.pdf)

Signed,
Frank Farrow, Director, Center for the Study of Social Policy
Judy Langford, Senior Fellow and Director, Strengthening Families Initiative, Center for the Study of Social Policy
Teresa Rafael, Executive Director
National Alliance of Children's Trust and Prevention Funds

On behalf of the Office of the Governor of the State of Illinois, the Illinois State Board of Education and the Illinois Department of Human Services: We support the Administration’s goal of improving the quality of early learning and development programs through the expansion of the number of programs participating in the State’s QRIS system. However, there are specific provisions under this priority that require clarification.

Priority 3(a) provides that States demonstrate that they have a licensing and inspection system that covers all programs that are not otherwise regulated by the State and that regularly care for two or more unrelated children in a provider setting for a fee or that they have a High-Quality Plan to implement such a system by June 30, 2013. We request that the Administration clarify whether this section means that all providers that care for more than one child unrelated to each other or more than one child unrelated to the provider must be part of the States licensing and inspection system OR if the States must have some oversight and monitoring system in place for all providers that are not required to be licensed if they regularly care for children for a fee. Licensing has a very distinct meaning to States.

Priority 3(b) requires States to demonstrate that all licensed or State-regulated Early Learning and Development Programs participate in the State’s Tiered Quality Rating and Improvement System or that it has a High-Quality Plan to implement such a system by June 30, 2013.

We request clarification on whether this means that all types of programs need to participate (e.g. pre-school, home visiting, child-care) or that every program within a type needs to participate by June 30, 2013. We would recommend that States be encouraged to increase participation by as many individual programs as possible through increased marketing and other incentives, but that the system remain voluntary.

What do we do about public schools that providing early childhood education in the form of K4 and sometimes even K3? They are not required to meet licensing standards, and therefore do not participate in the Quality Rating systems.

Implementation, management, and supervision of this program would be almost impossible to say the least as:
• The work force that will be needed to train, supervise and monitor all providers licensed and non-licensed in any state would be exorbitant.
• It will be difficult to mandate these providers to provide a high quality program to all children who are under their care as many of them may be just “baby sitters.” There is no guarantee that children under this program would benefit completely and all monies granted for their care would be spent on them
• Education programs need to be comparable for all children from birth – kindergarten regardless of their settings. A task force would design the learning tasks, goals, and benchmarks from birth – kindergarten to ensure education is at the same level for all children. Ethnic and cultural backgrounds of caregivers may be a hindrance to its success.
• If ED is demanding quality then the providers need to be of that caliber also. Otherwise, there is no quality to give.
• The integrity of this program may be compromised if the caregiver is a relative.
• Not all caregivers will agree to be scrutinized by the government thus; they may not be able to provide the necessary quality program to all of the children under their care.
• It would be imperative for all caregivers to obtain state licensing in order to receive funding under this program. Periodic surprise visits by Department of Children and Family Services or any other similar entity may ensure continued success of this program.
• Licensed or un-licensed caregiver in any setting must declare to their clients that they are receiving government funds and must report how this money is spent.

We request you clarify the eligibility requirements to include how communities and local agencies will be expected to participate with state agencies and programs directly regulated and monitored by states – including Head Start grantees and associations, home visiting programs, and non-center based care.

Race to the Top should consider requiring states to spend resources on early childhood mental health consultation services, just as Early Head Start programs are federally required to do.

Early childhood mental health consultation places a professional consultant with infant mental health and early childhood expertise in the childcare center. The consultant improves the ability of staff, families, programs, and systems to prevent, identify, treat, and reduce the impact of mental health problems among children from birth to five years of age. The consultant works primarily to improve children’s social emotional well-being by building the capacity of Early Childhood Educators, parents and other caregivers to promote mental health, understand child development and manage challenging behaviors.

This relationship-based intervention strategy improves knowledge and competencies among Early Childhood Educators and parents. Consultation stabilizes children and families and strengthens programs and workforce for young children. Consultation reduces the incidence of preschool expulsion because Early Childhood Educators are better able to accommodate children with challenging behaviors. Parents who understand child development will set expectations for their child’s behavior that are more realistic, less frustrating to the child, and less likely to lead to child abuse. Consultation improves relationships and helps young children acquire the social, emotional and behavioral skills necessary to enter school ready to succeed.

Thank you,
Dr. Mimi A. Graham, Director
Florida State University
Center for Prevention & Early Intervention Policy
Tallahassee, FL

A good portion of pre-K children are not in licensed early childhood programs. They are either taken care of at home by family members or extended family/neighbors or at homes providing day care. The focus needs to be on outreach to those without defined programs and creating of ways to assist them in providing a rich environment to lay the foundation for K readiness. There also needs to incorporate into this a deeper understanding of the individual readiness of each child.

Generally, more clarity is needed around unregulated care. Specifically, in our highly regulated state, a provider is not required to be licensed if they care for "children from a single, unrelated family, for any length of time". "Two or more unreated children" is confusing and potentially even more restrictive.

Please clarify program types:
Does the following language (“All licensed or State-regulated Early Learning and Development Programs participate” in the QRIS) refer to center based child care, family child care, Head Start and public school preschool and home visiting programs, IDEA, Early Intervention, Early Head Start etc.? Please define the "State-regulated Early Learning and Development Programs" that this requirement refers to.
- Massachusetts Department of Early Education and Care (EEC)

Please remember that many many vulnerable young children are served in non-regulated, non-licensed informal kith and kin child care settings, with few if any quality expectations or reporting -- especially in the critical B-3 years.

Dr. J.M. Gruendel, CT

This is a key issue, as there are few quality requirements on non-licensed individuals who receive federal child care block grant funding through the subsidy program. While complicated to figure out, these settings care for many many of our youngest and most vulnerable young children.

Moving forward to improve quality and outcomes without attention to this part of the sector would be unwise.

Dr. J.M. Gruendel
CT

Priority 3 (a): Clarification needs to be provided regarding the inclusion of non-regulated programs in the licensing and inspection system. Does this include publicly funded preschool classrooms, informal family care, out of school time care arrangements, etc? Perhaps such a list can be included in the definition section of the document.