(C) High-Quality, Accountable Programs

Comments

Further specific explanation would assist states in addressing this selection criteria.

FFYF wholly supports the goal of a robust continuum of early learning programs, all demonstrating quality and working on continuous quality improvement, regardless of funding stream. Given the complexity and variation in how services are delivered and programs are structured across the early childhood continuum, we recommend the following:

Include home visitation programs under the definition of “Early Learning and Development Program,” not only to be consistent with the definition of “Participating State Agency,” but also to recognize the critical and valuable role these programs play in the early childhood system and their contribution to early learning and development. This provides an important opportunity, commensurate with the increased federal commitment to home visiting programs, to assure appropriate unification and integration with other early learning services.

The draft calls for linking the Quality Rating and Improvement System to the state’s licensing system. We believe additional guidance and clarification will be needed to help states understand the federal expectations and the implications for the range of programs that are not currently encompassed by a state’s child care licensing system, such as school-based prekindergarten or home visiting. While bringing prekindergarten programs into the state’s licensing system might be an appropriate policy aim, that rationale does not hold for all home visiting programs. Therefore, we recommend noting that linkages are expected where appropriate.

In implementing the draft application’s vision for a comprehensive QRIS that covers all early learning programs, we anticipate a need for clarity about the best ways to accommodate different service delivery models, such as home visiting. Greater clarification would be helpful regarding the application of the QRIS to IDEA early intervention and preschool special education services. The current focus on inclusion and trends toward incorporating these services into programs for typically developing children suggests the need for greater explanation in the final guidance about QRIS and these programs. States will need assistance in understanding how speech-language or other therapy services that constitute core interventions through Parts B and C will be part of the QRIS.

Greater clarity could be provided about the concept of unified program standards. The draft endorses, as do we, the necessity of aligning program and practitioner standards to the early learning standards, and it also calls for common tiered program standards. We support this approach. However, providing states with additional clarity that certain aspects of program standards, particularly on structural items, such as ratios, may be different for classroom-based versus home visiting programs, would be helpful. This is implied in the definition for Program Standards, but would benefit from greater clarity.

In addition, in order to assure that the vision for program quality and accountability is fully realized, we recommend specifying that the validation of the QRIS (Section C.4) must include assurances that sufficient resources have been provided to programs to meet and sustain the standards and expectations that are set for them. It would be helpful to states, as well, to specify the level of rigor involved in validation.