(A) Successful State Systems

Comments

Research shows that adverse early experiences (such as those experienced through maltreatment) negatively impact brain development and contribute to poor educational, socio economic, and health outcomes for individuals over the life course (Center on the Developing Child at Harvard University, 2010).

• One-third of all child abuse victims are younger than four years, and children under one year had the highest overall victimization rate at almost 13 percent. Victimization of children under age one is also the most lethal.
• Eleven percent of child abuse victims were reported as having a disability
• Eighteen percent of child abuse victims were exposed to domestic violence in the home.

(U.S. Department of Health and Human Services, Administration for Children and Families, Administration on Children, Youth and Families, Children’s Bureau. (2010). Child Maltreatment 2009. Available from http://www.acf.hhs.gov/programs/cb/stats_research/index.htm#can)

Any effort to dramatically improve educational outcomes for High-Need children, such as the Race to the Top Early Learning Challenge opportunity, should require States to include a detailed plan for meeting the early care and education needs of the most vulnerable infants, toddlers and preschoolers, namely those who are involved in the child welfare system or differential response system, and those identified or at-risk of disabilities and developmental delays.

To this end, the Administration should require that State child welfare agencies, Medicaid and/or State Children’s Health Insurance agencies, and Community Based Child Abuse Prevention Fund lead agency be included as required Participating State Agencies to help develop this plan. In addition, the Administration can promote coordination of this plan with existing federal opportunities such as the recently announced “Early Education Partnerships to Expand Protective Factors for Children with Child Welfare Involvement” discretionary grant from the Administration for Children, Youth and Families (HHS-2011-ACF-ACYF-CO-0185).

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

Source citation:
Center on the Developing Child at Harvard University (2010). The Foundations of Lifelong Health Are Built in Early Childhood. http://www.developingchild.harvard.edu

The draft requests participation, coordination, and integration among a broad array of state agencies with oversight over early learning programs and funds. FFYF lauds this list for its comprehensiveness, as we believe giving each of these stakeholders both a seat at the table and a clear expectation for executing the state’s plan is essential for proper oversight and for meaningful collaboration. The draft also highlights the important work to develop and implement the early learning data system that aligns with the State Longitudinal Data System; we support the approach that is outlined in the draft.

We recommend four areas for clarification and modification in the final requirements:

In criterion (A)(5)(a), related to repurposing and reallocating funding, we anticipate that states will need and appreciate additional specificity and clarity to guide implementation of funding alignment. We recommend identifying essential practices in reallocation and repurposing, such as “braiding” and “blending” of funding streams and continuity of enrollment (including unifying eligibility time periods across funding streams to assure service continuity, intensity, and duration), and requiring states to address how they will implement them—with the goal of providing full-day, full-year programs and continuity of care for young learners. These approaches are critical to achieving learning outcomes for at-risk children, and states will benefit from clear expectations in this area. In general, more explicit instruction to states to address financing from public and private sources is recommended.

We encourage more explicit attention to the role of Head Start and Early Head Start. Because these programs fall outside the realm of any state agency, the federal government is better positioned to play a leadership role with these programs. To that end, we offer two recommendations for your consideration. First, Head Start and Early Head Start will need to be incorporated into the state data system, and we urge you to have the States address how they will approach including Head Start children, staff, and programs. Second, strong guidance to the Head Start grantees and the regions on inclusion in the state’s early learning data system, along with other allowable and important ways these programs can and should participate in the Early Learning Challenge, would be vital to achieving the level of integration envisioned.

In criterion (A)(3)(c), we recommend clarifying that demonstrated actions of support, including commitment of Title I funds, partnerships and collaborations with local early childhood providers, and philanthropic funds to support Challenge efforts, will be weighed more favorably than letters of support.

Finally, the State Advisory Council will play an important role in many states. In the final document, a greater emphasis could be placed on the anticipated partnership with the Council throughout the application process and grant implementation.

Thank you for the opportunity to comment on the Race to the Top Early Learning Challenge (RTT-ELC) Program.

We recommend:

1. The RTT-ELC program should require states to use RTT-ELC funds to substantially increase the percentage of children served by the Child Care Development Block Grant (CCDBG) child care program without reducing reimbursement rates.

Only about one in six children eligible for federal child care assistance under CCDBG receives it - and this may worsen in FFY 2012. Mississippi is serving only about 16% of the state’s eligible children, another 14,000 are on the waiting list and an additional 4000 were recently terminated from the program. As Helen Blank of NWLC said in November 2010 testimony to Congress (http://www.nwlc.org/resource/testimony-helen-blank-subcommittee-children...) “With limited funding states are forced to make Solomon-like choices between serving fewer families, asking parents receiving child care assistance to contribute more toward the cost of care, or paying child care providers who serve subsidized families lower rates.” High income families can afford to buy quality child care services for their children. Low income families cannot. Without a requirement that states expand CCDBG child care subsidies to a larger number of eligible families, the RTT-ELC Program threatens to exacerbate this current grim inequity by making services to a fortunate few higher quality by leaving the overwhelming majority of low income families without access to any services at all.

2. The RTT-ELC program should require states to a) demonstrate steps taken to minimize interruptions in child care services in the CCDBG child care subsidy program, and b) report measured improvements resulting from these steps.

The RTT-ELC Program should require states to provide evidence that they have taken substantive steps to reduce instability in child care services and to meet the needs of families. Resources to help states are available from the Urban Institute:
“Child Care Instability” offers strategies for reducing interruptions in child care services for low income children. http://www.urban.org/publications/412278.html.
“Designing Subsidy Systems to Meet the Needs of Families,” offers strategies for improving child care subsidy systems for families. http://www.urban.org/publications/411611.html

3. The RTT-ELC program should require states to provide evidence that re-determination periods and eligibility requirements in CCDF match Head Start and state-funded pre-k/early childhood programs to enhance system alignment. A policy brief written by CLASP makes the case for these steps toward early childhood system alignment: http://www.mschildcare.org/CLASP_System_Alignment.pdf

For example, many states require re-determination in the CCDBG program more frequently than once per year. Mississippi requires re-determination every six months. Some states have done cost/benefit analyses (some assisted by NCCIC) and determined that such frequent re-determinations do not reveal a number of ineligible parents adequate to justify putting the entire system through such a process so frequently. Annual re-determination would increase system alignment with Head Start, Early Head Start, and state early care and education programs.

Also, some states, like Mississippi, require single parents to file for child support in order to qualify for CCDBG child care. Neither Head Start nor pre-k programs require single parents to initiate child support cases against the absent parent in order to qualify for services. Removing this requirement from CCDBG child care would increase system alignment – and it would remove barriers to child care assistance for parents who need it most: single low-income working parents.

4. The RTT-ELC program should require states to provide evidence that QRIS and other quality improvement measures do not increase the cost of child care services to low-income working parents.

In Helen Blank’s above-cited testimony to Congress she said, “The federal commitment is paramount. Unlike K-12 education, the bulk of public funds for child care and other early childhood programs are federal, not state or local.” Apart from public funds, child care services are paid through parent fees, which exceed the cost of college tuition in many states. Where quality improvements increase the cost of child care and public funds are inadequate to cover these additional costs, parent fees are increased - this prices poor children out of care or the improvements don’t occur. Either outcome prevents quality improvements from reaching poor children who need these and benefit most.

In quality rating systems where rate enhancements are tied to reimbursements in the CCDBG child care assistance program, the number and duration of subsidies are critical to the success of the financing strategy. In states like Mississippi where only a tiny percent of eligible children are served by the child care subsidy program and rules in the subsidy program result in frequent interruptions in service, the number of subsidies is low and the duration of subsidies is both short and unpredictable. Therefore, this financing strategy is inadequate and unreliable to support quality rating system requirements.

States should be required to demonstrate that quality rating systems do not increase parental fees that make child care services unaffordable for low income working parents.

5. The RTT-ELC program should require states to provide a dedicated revenue stream or use RTT-ELC funds to help pay the cost of higher wages for higher levels of education in the child care workforce.

When child care workers obtain higher levels of education they expect higher wages, and rightly so. If funds are not available for this purpose, workers with higher levels of education will move into sectors that pay higher wages. In Mississippi the CCDBG child care subsidy delivery system doesn’t have enough money to pay higher wages to child care workers who obtain higher levels of education. These workers move into Head Start programs that can afford higher wages. (Head Start programs receive significantly more federal funding on a per child basis than CCDBG child care.) When Head Start workers earn higher levels of education they move into public schools where they are paid higher wages. Etc. Requiring higher levels of education without providing funding to support higher wages siphons workers out of child care settings or drives parent fees higher.

Thank you,
Carol Burnett
Executive Director, Mississippi Low Income Child Care Initiative
Former State Child Care Administrator