GEEARS’ Comments on Draft State Child Care Plan

Re: Draft Child Care and Development Fund (CCDF) Plan for Georgia FFY 2019-21

Dear Commissioner Jacobs:

On behalf of GEEARS: Georgia Early Education Alliance for Ready Students, I thank you and your department for the hard work that you have put into drafting the proposed CCDF plan for Georgia and for the opportunity to submit comments on the plan.  As you know, GEEARS works to ensure that all of Georgia’s children enter kindergarten prepared to succeed and are on a path to read to learn by third grade. 

High-quality care and early childhood education services help ensure that even the most at-risk children arrive at kindergarten ready to learn. A large body of research shows that children who live in poverty and have access to high-quality early care and education are more developed cognitively, socially, emotionally and academically than children who did not receive similar education. In addition, research also points to the role that high-quality, stable care can play in buffering the effects of adverse childhood experiences; ensuring that families can become self-sufficient; and promoting a high-quality current and future workforce for Georgia’s business community.  The CCDF plan for Georgia is a key driver of our work to improve quality and promote access for vulnerable children and families.

 Our comments below generally follow the chronology of the draft plan and are not in order of priority.

We endorse the Department’s commitment (Section 2.1.2., 2.5.5., 7.3.1.) to the use of Inclusion Specialists to provide training and resources to families and providers regarding services and supports available under IDEA and assistance with referrals to programs.  We recommend that you expand the role of Inclusion Specialists to support the mental health needs of infants and toddlers and in addition, we hope that, in the future, increased numbers of Inclusion Specialists can be deployed to the field.  In an expanded role, the responsibilities of the Inclusion Specialist would include the provision of developmental screening to individual infants and toddlers presenting with adjustment challenges.  In this way, children may be properly referred for early intervention services, and risks for additional school and mental health problems can be mitigated.  Inclusion Specialists would also be available to provide consultation to child care providers on how better to serve children who have experienced toxic stress in their home environments.  Early intervention and linkage to needed support services will help reduce rates of expulsion (Section 2.5.6) due to behavioral problems in this young population.  A solid social and emotional foundation increases the likelihood of success for young children, and the expansion of the role of the Inclusion Specialist will help the early childhood community better support the psychological well-being of young children in Georgia.


Developmental screenings and referrals to services are critical components of a system that serves children and families.  As the work of the Family Support Consultants (Section 2.6) matures, we look forward to learning more about progress and about the needs that you are identifying.  We view the Family Support role so optimistically and hope to work with you to help support these efforts.


Subsidized child care is a vital support to parents who are striving for self sufficiency through work or furthering their education.  We urge you to include in the definition of education (Section 3.1.2) an associate’s degree in addition to vocational training, and we appreciate that you include language suggesting that possibility.


We appreciate the reduction of family copayment by 15% for families receiving care at a provider that has earned a star rating in Quality Rated (3.4.3.) This has been an ongoing priority of DECAL advisory groups (Section 4.4.1), and your leadership has clearly taken this into account.


In our continued support for quality early care, we endorse the Department’s adoption of a subsidy grant program for Quality Rated child care providers (4.1.3. and 4.3.2.), and we hope that you will expand this program as new funds become available.  Moreover, we request that you explore ways such as networks to make family child care providers eligible for these grants.


As we seek to improve access to care for infants and toddlers, we strongly believe that the infant and toddler reimbursement rates should be raised to reflect the lower teacher to student ratios required for their care (4.3.1.). Georgia, and many other states, have low reimbursement rates under CCDF for infant and toddler care. Currently, the lack of a higher tiered reimbursement rate for infants and toddlers is a disincentive for center-based and family-based providers to provide care to this population.  By raising the rates, you will attract more centers and family-based programs to open more classrooms for infants and toddlers, thereby helping fill the gap.  In addition (Section 3.1.5), we wonder if you might consider infants and toddlers a priority population in much the same way that children in Georgia Pre-K are so deemed. Currently, infants and toddlers are under-represented in the CAPS population, and this might be a way to ensure entry.


As you state in the plan, stakeholder feedback has strongly indicated the desire for the CAPS program to serve an average number of 50,000 children (Section 4.4.1), and we are hopeful that with new federal funding, the program might be expanded to provide even more access.  There does not seem to be any indication in the draft plan, however, about how the Department is addressing any delays in eligibility determinations.  We know that the transition from DFCS to DECAL has continued to present challenges, and we respectfully request more information about how you are working to address this.  Moreover, we are hopeful that, as new state or federal funds become available, the state will have a commitment to serve 50,000 children to better meet the needs of families in Georgia.


We appreciate the Department’s attention to the physical activity needs of young children (5.2.2.a.2.), as exemplified in the rules requiring 1.5 hours of outdoor activity for non-infants and one hour for infants.


Early learning teachers are the most critical element of high-quality early learning, and the most vital contributor to child success.  We commend the Department’s commitment to the DECAL Scholars program (6.1.3.)  Building the skills of these early learning professionals helps lend to the success of infants and toddlers in their care. In addition, the focus on training for special needs including programs serving children with disabilities, dual language learners, and children who are experiencing homelessness is appreciated. We also strongly support the one-time bonus for professionals completing an infant toddler credential as well as the infant toddler language and literacy classroom grants. 

(Section 4.6.2)


We have reviewed and strongly endorse PFCCA’s recommendation to strengthen the quality and financial viability of family child care learning homes by establishing six to eight Family Child Care Support Networks in Georgia. Experts on child care financing have emphasized the importance that larger scale models have on ensuring quality care while other studies have pointed to the importance of the role that family child care plays in serving infants and toddlers, providing care at nontraditional hours, and being responsive to cultural differences.  This suggestion seems to help address financial viability and quality.  On a related note, we are hearing more concerns around the state regarding the need for care for children whose parents work nontraditional hours, and we ask the state to consider enhanced rates to encourage providers to offer such care.


We also strongly support GSAN’s recommendation to ensure that data is available for and filterable by age. Currently, it is often difficult to discern which centers are serving school age and/or early learning populations. Having better access to this information will allow us to better understand the current landscape, continuum of care, and where specific supports are most in need.


We recognize that the state plan was drafted before it was determined that Congress would pass historic new funding for the Child Care and Development Block Grant. We do hope you may consider using the new opportunity to make some additions to the proposed state plan.


We have been advised by our national partners that this is NOT a one-time funding opportunity and that it should be treated as funds that will be continued every year.  As with any increase, we understand that Congress always has the discretion to pull the funding at any time in future federal fiscal years; however, there are some reasons why we do not believe they will pull back this funding:

  • The increase is part of a two-year budget deal commitment – Congress is likely to implement a Continuing Resolution this year, assuring funds for at least two years.
  • The two-year budget deal was part of a normal process – Congress usually passes two-year budget deals and does not ordinarily cut major funding streams without good reason – especially funding streams that are designed to provide direct services to families.
  • This is not ARRA. ARRA was specifically billed as one-time funding designed to jumpstart the economy. If Congress intended the money to be one time, Congress would have included budget language clarifying the fact that this funding was one time in order not to raise expectations.
  • In fact, Congress specifically said in report language that funding can be used to create new slots. Congress would not have done that if it intended the money to be one time.

Other states have recognized that this funding is expected to be ongoing and have made plans with this in mind. Arkansas will be using the funds to pay for 3,800 new child care voucher slots. Florida plans to increase payment rates and serve children currently on their waiting list. Maine and Maryland are also increasing reimbursement rates.


With this in mind, we make the following suggestions on some ways that Georgia might best make investments with the new funding:


We urge DECAL to increase income eligibility limits to families who earn 65% of the state median income consistent with the intent indicated in the CCDF state plan for 2016-18. Child care is an essential work support for hard working low-income families, and child care subsidies enable these families to maintain a path towards self-sufficiency.  We think this increase is reasonable because federal legislation allows eligibility to 85% of SMI.


We also request that you consider increases to the provider base rate and to tiered reimbursement rates.  We urge you to make 3-star reimbursement rates up to 75% of the most recent market rate survey.  In addition, we urge you to update the base rate to a higher percentage of the most recent market rate survey since tiered reimbursement is based upon that.   Quite simply, we cannot expect even the best-intentioned child care providers to provide high-quality care at minimal rates of payment, and increased reimbursement rates are a step in the right direction. Increased reimbursement rates will provide an incentive for more providers to serve families who depend on the child care subsidy and will, in addition, provide important funding that will allow historic providers to increase and sustain the quality of care.  Higher reimbursement rates from the state also remove another barrier for families as providers can require the family to pay the difference between the reimbursement rate and the cost of tuition.  With higher reimbursement rates, that gap will decrease. 


Several other suggestions we made earlier in these comments, such as expansion of subsidy grants and additional Inclusion Specialists with expanded roles, could also be funded with these new federal dollars.

Again, we appreciate your work to ensure that the draft plan reflects our shared commitment to high-quality early education for Georgia’s children, and we are proud of our continued partnership with DECAL. We are pleased to partner with DECAL on the Quality Rated public awareness campaign that is mentioned in the plan as well as on other key initiatives such as the expansion of E3Zs (Section 4.6.3).  We thank you for the opportunity to submit feedback are happy to answer any questions that you may have.



Mindy Binderman
Executive Director