Letter to OSSE: Recommendations for CCDF State Plan

May 20, 2024
Advocacy Letter

Sara Mead
Deputy Superintendent of Early Learning
Office of the State Superintendent of Education
1050 First Street NE
Washington, DC 20002

Dear Deputy Superintendent Mead,

On Saturday, March 16, over 75 Under 3 DC members joined the Office of the State Superintendent of Education (OSSE) in a virtual town hall on the Child Care and Development Fund (CCDF) State Plan. Under 3 DC is a coalition that is committed to building an equitable, high-quality early childhood system that secures a strong start for every infant and toddler in the District.

Throughout the town hall, parents, early learning program directors, support staff, and early educators shared their experiences, provided feedback, and offered solutions directly to OSSE on topics governed under the CCDF State Plan. We want to express our gratitude to OSSE for listening to the community. OSSE’s partnership and willingness to hear directly from parents and early learning professionals is a strong step toward making CCDF work better.

We understand that OSSE is updating the CCDF State Plan under guidance from a recent federal rule on CCDF. We applaud the Administration for Children and Families (ACF) and the U.S. Department of Health and Human Services (HHS) for the regulatory changes that lower child care costs for families, improve provider payment rates and practices, and simplify enrollment in the Child Care Subsidy Program. The required changes are positive for families and child care providers participating in the subsidy program. We hope that they will be the foundation for ensuring affordability for all families. The encouraged changes provide a pathway for the District of Columbia to continue to be a leader in child care affordability and accessibility.

This letter is intended to highlight the actions that OSSE can take through updates to DC’s FY2025-FY2027 CCDF State Plan based on feedback directly from Under 3 DC and our analysis of the federal rule.1 Given that OSSE is currently updating the District’s CCDF State Plan, we encourage the agency to consider the following proposals: 

Increase child care affordability

We applaud the District for expanding eligibility for the Child Care Subsidy Program up to 300% of the federal poverty line (FPL) and for passage of the Birth-to-Three for All DC law, which stipulates that no family should spend more than 10% of their income on child care upon full implementation. 

The federal rule calls for capping CCDF co-pays at 7% of family income. While all subsidy program family co-pays are currently under 7% of family income in DC, we encourage OSSE to explicitly include a 7% cap on family co-pays in the State Plan and to remove barriers for families by further reducing current family co-pays.

The federal rule encourages lead agencies to waive co-pays for families with incomes up to 150% FPL, for children who are in foster and kinship care, for children experiencing homelessness, for families with a child with a disability, and for families with a child enrolled in Head Start or Early Head Start. We commend OSSE for already waiving co-pays for children who are in foster and kinship care and for those experiencing homelessness. 

While DC’s current co-pay rates are $0 for families with incomes up to 100% of the FPL, OSSE should, in the FY2025-FY2027 State Plan, extend its child care financial burden relief to families with incomes up 150% of FPL, for families with a child with a disability and for families with a child enrolled in Head Start or Early Head Start. This would make child care free for thousands of DC families.2 

Through our broader work with families and throughout the town hall, we have heard countless stories about how, even with the subsidy program, child care continues to be unaffordable and inaccessible for many families with low incomes in the District of Columbia.3 OSSE can and should take the steps above to make child care more affordable for DC families.

Increase the supply of child care

Using grants and contracts

Under 3 DC members support the federal rule’s requirement that OSSE provide some services through grants and contracts to increase the supply for child care for nontraditional hour care and for children with disabilities.4 Broadening the use of contracts would require providers to reserve seats for certain subsidy-eligible children, which would increase the supply of child care for children in qualifying families in the District. This would also provide added stability for early learning programs that can benefit from fully funded grants or contracts. 

Specifically, grants and contracts to reserve seats at child care programs that provide non-traditional hour care and care for children with disabilities would increase access to child care where there are currently significant shortages. Parent town hall participants identified a clear need for more programs that operate non-traditional hours and provide services for children with disabilities. One parent was fired from her restaurant job because they could not find care for their child during their work hours. Another parent shared that while they were able to access the Child Care Subsidy Program and obtain a voucher for their child, they could not find a program that could serve their child who has autism and special needs. Grants and contracts, as encouraged by the federal rule, would work to increase access to care for these populations. 

“For my Nando’s job, I had to work 5 pm to 10 or 11 pm. Day cares don’t run that late. I ended up getting fired because I didn’t have anyone to watch my kids.”

“My child has special needs. That made us qualified for health insurance and a child care voucher. I remember thinking at the time, ‘Wow, that’s so wonderful maybe I could indeed stay working and get help with her’. When it came to finding an actual qualified authorized vendor who could deal with a young child with severe autism and special needs, I could not find any. Unfortunately, my older kid did not even get to really use the voucher. We never found a provider.”

Further, grants and contracts will help the District quantify the number of affordable seats available to families based on the total contracted seats. Currently, we understand that it is difficult for OSSE to articulate the total universe of available subsidized seats since participating child care providers have no obligation to reserve a set number of seats for children with vouchers. This limits the ability to assess whether our supply of affordable seats is adequate to meet the total demand for them, whether there is an underutilized supply, and what other gaps exist in serving families with low incomes.

Improving reimbursement practices 

We applaud OSSE for revising its CCDF State Plan in 2021 to base subsidy payments largely on enrollment rather than attendance. We support the federal rule’s requirement for this practice as it will increase stability for providers and could incentivize more provider participation in the subsidy program. 

Building off this progress, the federal rule requires OSSE to pay providers prospectively, in advance of or upon delivery of services, rather than retrospectively, after the early learning program has provided care for the child and absorbed upfront costs. Under 3 DC  is in full support of this policy, as retrospective reimbursement places providers in the precarious position of needing to have cash upfront to cover the costs of serving families in the subsidy program and their fixed costs such as staff salaries, rent, utilities, insurance, and cleaning, regardless of the regularity of attendance of the children enrolled in their program and the timeliness of payments from parents and the District. Ensuring prospective payments is a critical part of addressing the high and volatile cost of providing child care. While we understand that implementing prospective payments for providers might be time consuming for OSSE, we encourage OSSE to do so as swiftly as possible. These changes improve financial stability among child care subsidy providers. They also encourage more providers to participate in the subsidy program, thus expanding the child care options available to families with fewer resources.5

The quote below from a child care program director who participated in the town hall further exemplifies the importance of swiftly implementing prospective payments for subsidy providers. 

“Reimbursement by OSSE does have a significant impact on programs. [Delays in reimbursement/being paid retrospectively creates] a huge cash flow challenge. And this also stretches our financial resources thin and affects our ability to cover immediate expenses such as staff salaries and facility maintenance. [Delayed payments] means that there’s often a delay between providing care for each child and receiving reimbursement.”

Improve ease of enrollment in and build awareness of the Child Care Subsidy Program 

Current subsidy program utilization is low

In addition to improving child care affordability and provider stability, OSSE must take steps to address low subsidy utilization rates. In fiscal year 2023, there were 4,720 infants and toddlers receiving subsidies. We estimate that an additional 5,611 infants and toddlers were eligible to participate in the program but did not. This means there are nearly twice as many infants and toddlers in families who would be eligible for subsidy based on income than there are infants and toddlers enrolled in the subsidy program.6 The recommendations below are intended to reduce the gap in subsidy utilization numbers in the District. 

Building community awareness about the Child Care Subsidy Program 

In the town hall, several parents shared that when they began looking for child care, they did not know there was a program available to reduce the cost. To further exemplify this issue, parents stated,

“I just wanted to say really quickly that I had no idea that this subsidy program even existed up until just a couple days ago… In fact I know of a handful of other parents that live throughout the District who are also unaware of this program. Some of them have neurodivergent children, they were actually really excited when I told them about this program.”

“A lot of people don’t know how to start looking for childcare. I called [a program] to ask how much a center charged and if they had space. I had no idea about a voucher.”

We encourage OSSE to take concrete steps through the FY2025-FY2027 CCDF State Plan, to increase awareness of the Child Care Subsidy Program, and to share information about the program and how to apply. Specifically, OSSE should conduct ward-by -ward outreach to families with infants and toddlers, at family shelters, community events, places of worship, and diaper distribution banks to raise awareness of and subsequently increase participation in the subsidy program. 

Improve the Child Care Subsidy Program application process

Reduce application processing times

Across the board, parents shared frustrations about the lengthy wait times they are forced to endure to get their subsidy program application processed. Family support workers described having to know who to call to get applications processed and shared stories of parents who lost their jobs waiting for their applications to be approved. In the updated State Plan, OSSE should describe its plans to work with DHS to speed up subsidy application processing time

The federal rule encourages lead agencies to use online application processes to make enrollment in the Child Care Subsidy Program easier and faster for families, and we commend OSSE for standing up an online application. While we are confident the online application will eventually make applying for the program more accessible, we ask that OSSE include in the State Plan how it will work with the early childhood stakeholder community to consider necessary improvements to the application. More information about issues with the online application can be found in the appendix at the end of this letter. The quotes below from parents in the town hall further showcase prevalent issues with the online application. 

“I tried the online voucher application, and it was not mobile-friendly.”

“The online application is too hard. It’s good if you have a laptop. I don’t think anyone knows about it. There are a lot of Facebook mommy groups, but they don’t know about it.”

Expand categorical eligibility

The federal rule also encourages lead agencies to use a family’s enrollment in other public benefit programs to verify eligibility for the Child Care Subsidy Program, which would reduce administrative costs and connect families to child care more quickly. We encourage OSSE to continue its practice of using categorical eligibility to ensure that families accessing Temporary Assistance for Needy Families (TANF) and the Supplemental Nutrition Assistance Program (SNAP) are also considered eligible for the Child Care Subsidy Program and to expand the use of categorical eligibility to include enrollment in other programs such as Medicaid and the Alliance Health Care Program, as well as children of teen parents, children with disabilities, and children in families experiencing domestic violence.

Adopt presumptive eligibility

Further, the federal rule clarifies that a lead agency can consider a child presumptively eligible (if a child is plausibly assumed to meet basic federal requirements) prior to completing verification of their eligibility. OSSE should include presumptive eligibility policies in its CCDF State Plan. Allowing child care subsidy funds to be used for up to three months (or until full eligibility is determined) will speed up enrollment timelines and reduce barriers for families seeking to enroll. Presumptive eligibility will ensure that children are able to access safe, high-quality care that meets their needs, without processing time delays. 

All of the policies above stand to improve processing time and to reduce burdens on the Child Care Subsidy Program application itself. In the town hall, parents expressed how lengthy wait times, complicated application requirements, and paperwork make it extremely difficult to enroll. 

“The turnaround time, the people reviewing the applications need to be faster. This is people’s lives. They need this. We don’t need to make it extremely hard.”

“It takes up to 30 days to process a voucher. If it goes beyond that time, the application must be resubmitted. We lose many teen parent students due to loss of their child care spots.”

“I was only like 18, so I didn’t have anything under my name, so I had to bring my mom’s paperwork and her ID ….It was just a lot of paperwork that I didn’t have …. It took at least 6 months.”

Reduce barriers to participate in the Child Care Subsidy Program

Establish more flexible work and education requirements 

In an effort to reduce barriers to participation and to prioritize families with the lowest income in the Child Care Subsidy Program, OSSE should consider including the following proposals in its FY2025-FY2027 CCDF State Plan. The long-standing federal work and education requirements to participate in the CCDF create barriers for parents trying to enroll in DC’s Child Care Subsidy Program. While we know OSSE cannot remove the federally mandated work requirements, OSSE should modify the child care subsidy eligibility criteria to increase the amount of time that parents can be looking for a job, reduce the number of required work/education hours, and include more qualified allowable activities (in addition to education and employment). Current employment and education requirements prohibit participation in the program for some parents, many of whom do not have control over their work hours or time in school. A child should not miss out on the benefits of early childhood education simply because their parent is not employed or in school. Expanding the eligibility criteria is an essential flexibility that OSSE should take advantage of to allow more families to participate in and benefit from the subsidy program. Parents in the town hall expressed how the current requirements feel backward in nature. For many parents, they first need to have child care in place, before they’re then able to secure a job. 

“I couldn’t get a job at first because I didn’t have child care. My parents work, can’t watch him. Before I even got a job, I needed to be sure he would be in day care.”

“After I gave birth to my second …. They told me that I didn’t qualify a voucher. I needed a job, but I couldn’t get a job because I didn’t have day care …”

Strengthen the definition of and transparency around child care quality

Throughout the town hall, we heard from parents and directors alike on the importance of finding or running a high-quality child care program. Many parents and providers, however, do not have the information they need to understand whether definitions of quality set by OSSE align with their perspectives and priorities, nor do they feel that OSSE has engaged them to inform those definitions. Providers expressed misalignment between current Capital Quality standards and national accreditation standards such as those set by NAEYC. A few providers explained that they are accredited by NAEYC, which is difficult to achieve but are then given a ‘preliminary’ quality rating by OSSE. Providers explained that the current quality rating system disincentivizes subsidy participation (which requires quality observations from OSSE) because programs don’t feel that the quality rating system by OSSE is accurate or transparent and that they will receive lower subsidy reimbursements based on their quality rating. 

The parents in the town hall expressed how difficult it is to locate high-quality child care, in part due to the complex and sometimes inconsistent definitions of quality set by OSSE. Parents explained how they can see quality ratings on my Child Care DC, but they often don’t know what they mean or how they are defined, which renders them less meaningful. One parent said, 

“In 2021, the site did not list provider websites, pricing, or enrollment info, so we had to contact each provider directly to inquire about a tour.  It contained quality indicators but did not define them, so quality was not a meaningful descriptor… OSSE has a gazillion materials to comb through to try to figure out what the indicators mean, and most are too vague [or not written at an accessible reading level] to be useful…”

Parents also shared their own definitions of a quality program – play-based, print-rich, low child-teacher ratios, good communication, safe, turnover rates, etc. – and their uncertainty about how their definition of quality might not align with OSSE’s, which makes it difficult to understand which programs could be right for their child. 

As the District strives to provide more high-quality child care options, and to address the issues above, it is vital for OSSE to engage both parent and provider perspectives when defining and implementing quality systems. Parents need reliable information that helps them choose the best care for their children, and providers require clear, fair guidelines and support to meet those expectations. In the updated State Plan, we recommend that OSSE describe how it will collaborate with parents and providers to strengthen the District’s approach to defining and communicating quality, create meaningful quality ratings and tools that are accessible and useful to families; and ensure transparency and clarity for providers in how to achieve and maintain a high-quality program.

Work more with stakeholders on the ground

We are appreciative of OSSE’s efforts to garner community input on the State Plan and for participating in the town hall. We learned, however, that many program directors feel left out of OSSE decision-making on policies and programs that are often critical to their work. For future State Plans and in the implementation of new and ongoing programs, we encourage OSSE to engage in regular consultation with stakeholders on the ground. Specifically, OSSE should explicitly articulate in the State Plan how the agency will work closely with program directors, educators, families, and other relevant stakeholders as it continues the implementation of existing programs and as it stands up new programs and policies. An iterative process with early learning stakeholders would be mutually beneficial for both OSSE and child care programs and should be prioritized in earnest going forward. 

Make CCDF work better for early childhood educators

Improve communication between OSSE and educators

Based on feedback from early educators in the town hall, we encourage OSSE to explicitly state in the FY2025-FY2027 State Plan how the agency plans to communicate directly with educators. There are many requirements and policies in place that directly impact educators, yet educators have to rely on their facility leaders to communicate changes from OSSE. Educators have made clear that current communication processes and channels do not work for them, leading to confusion about what is required of them and, in the worst cases, harming their opportunities for career and salary growth. While this issue is not solely governed under CCDF, we hope OSSE will work to address this issue.

Improve professional development practices

In the town hall, teachers also shared their recommendations to address challenges they face in pursuing professional development requirements and their own goals. Teachers expressed the need for more regular training on how to use the Learning Management System (LMS), especially in multiple languages, and for more professional development opportunities on LMS. Specifically, teachers called for more training on cultural competency and sensitivity and on caring for children with disabilities. Additionally, teachers described the need for more advance notice and lead time before training requirements must be fulfilled. They shared that current practices do not provide enough notice for teachers to be able to engage meaningfully in the training while maintaining their other responsibilities. OSSE should identify strategies for strengthening professional development opportunities and systems as the agency updates the Professional Development section of the State Plan.

Ensure accountability and improve the work environment

Early educators in the town hall discussed the importance of OSSE oversight on program operations, including enforcing classroom ratio requirements, conducting unannounced inspections, and creating more spaces for educators to share instances of discrimination, abuse, and violence. We encourage OSSE to identify opportunities to strengthen accountability metrics to improve teacher work environments and child safety

Build a strong workforce data system with an improved credential registry 

Exacerbated by issues with Pay Equity Fund implementation, educators throughout the town hall (and in other engagements) called for a registry that they can individually update with their most up-to-date credentials and other relevant information. Again, instead of relying on their facility program leadership to process their updated credentials, teachers should have ownership of and the ability to update and own this information. OSSE should include explicit plans about the creation of an educator-led credential registry in the FY2025-FY2027 State Plan. 

Improve Language Access

Many of the early educators who participated in the town hall called for more dedicated OSSE staff who are bilingual and can provide technical assistance and troubleshooting resources for teachers. Along the same lines, they called for more professional development, especially in special education in Spanish. The FY2025-FY2027 State Plan should include more robust language access supports for educators and other stakeholders whose primary language is not English.

Closing

Again, this letter is not comprehensive of all the issues raised during the March town hall; because OSSE was present for the conversation, we chose to highlight key, actionable recommendations. 

Thank you for your consideration of the coalition’s recommendations for the FY 2025-FY 2027 CCDF State Plan. Please feel free to reach out if you have any questions. We look forward to further discussing these recommendations at the public hearings on May 29 and May 30.

Sincerely, 

Under 3 DC


Appendix

In addition to the town hall, over the past nine months, the Under 3 DC Coalition has conducted feedback sessions and a focus group to hear directly from parents, child care providers and other stakeholders on the child care subsidy program and other aspects of CCDF. Please see below for our summary of the feedback we have received to date. 

Increase awareness of the Child Care Subsidy Program 

The Under 3 DC Coalition worked closely with DC NEXT! to gather feedback on the child care subsidy program from parenting teens. This anecdotal data makes clear that OSSE needs to take steps to increase awareness of the Child Care Subsidy Program, as many of the expectant and parenting teens did not know that a child care voucher existed. 

In other feedback sessions, the Under 3 DC Coalition heard similar experiences from providers and parent support staff who stated that many of the families they work with were not aware that they were eligible for a child care subsidy and / or how the application process worked. 

To increase awareness, stakeholders suggest that OSSE use CCDF family engagement funding for an awareness and consumer education campaign about the subsidy program. The goal of this campaign would be to increase enrollment in the subsidy program and ensure that more children and families have access to affordable, high-quality child care. 

  • Specifically, OSSE should collaborate closely with parents and child care providers (including Level II providers) to co-create and co-design an advertising and outreach plan. 
  • OSSE should consider standing up a parent advisory board to begin a concentrated effort to inform parents about the availability of child care vouchers and how the process works.  

Reduce barriers to participation in the Child Care Subsidy Program 

A number of stakeholders, as mentioned in the letter above, called for eliminating or modifying the requirement that parents attend school or work to be able to receive a child care voucher. Participants shared that the current requirements make the program inaccessible to some people with part-time employment and certain jobs in today’s gig economy. We shared with participants that while work and education requirements are federally mandated, OSSE can loosen the requirements and expand flexibilities on the number of required work hours and accepted work activities to ensure more parents have access to child care. 

We also heard that the required work / education paperwork itself is burdensome. In one case, a provider shared that the burden of the application paperwork and documentation has forced some parents to leave her program. Participants called on OSSE to streamline and simplify all required paperwork. 

Improve child care subsidy application processing time and experience

Child care providers, support staff and parents that the Under 3 DC Coalition heard directly from all expressed concerns with how long it takes for a parent to be approved for a child care subsidy. Some questioned how long it takes for an application to be assigned a DHS caseworker in the first place, before it is then processed – citing too few DHS caseworkers. 

To speed up processing time, one stakeholder suggested that OSSE use CCDF funding to increase the number of DHS staff doing subsidy intakes. 

Stakeholders also suggested that OSSE incorporate trauma-informed care and ongoing anti-bias, youth-centered trainings for all government and child care providers to ensure that the experience applying for child care subsidy and enrolling in child care is positive and responsive to DC’s families. 

Increase awareness of and improve the online child care subsidy application 

Similar to the feedback we collected on the child care subsidy program as a whole, many parents and child care providers did not know that there was an online application, even when they knew that the subsidy program existed. OSSE should engage in significant outreach to make the online application widely known among families, child care providers and other early education stakeholders. And, as OSSE makes the online application well known, the agency should provide opportunities for families to ‘user test’ the application and directly provide feedback and for providers to receive training and support to learn how to use the online application. 

Of the few parents and parent support staff that had used the online subsidy application, it became clear that the online application is not mobile friendly, which is a significant barrier to many parents for whom a cell phone is the most accessible tool for accessing the application. We also learned that some participants found the application language to be unclear and difficult to navigate. Participants recommended that OSSE learn from other states that have successfully implemented an online application to learn from them and make adjustments accordingly. See more feedback on the online application here

Improve coordination & use a systems based approach 

Parents, parent-support staff and early learning program providers all expressed frustration with the fragmented nature of the District’s early learning system. Specifically, stakeholders called for more coordination between child care programs and Head Start / Early Head Start programs (which can enroll children whose parents are not in school or at work) and suggested using CCDF funds to improve the current consumer education website (mychildcaredc) to make it more user friendly and easier for families to identify programs that provide Head Start / Early Head Start programming. Participants also called for CCR&R and DHS staff to be trained and knowledgeable about all of the different child care options available for parents in DC and to coordinate their responses. 

  1. Note: this letter does not contain all of the feedback discussed in the town hall, but rather focuses on key recommendations from the discussion rooms that pertain to the new federal rule.

  2. According to census data, expanding to 150% would improve affordability for the around 1,600 children under age 3 in families in the 101-150% FPL. Depending on how OSSE defines disability, this could improve affordability for families of the 1,334 infants and toddlers who have an IFSP.

  3. Economic Policy Institute, “Child Care Costs in the United States: The Cost of Child Care in Washington DC,” accessed February 2023.

  4.  Note: it is essential for OSSE to provide the necessary additional supports for programs to be able to successfully provide high-quality care for children with disabilities.

  5. Alex Cooper and Diane Girouard, “Child Care Payments: Attendance Vs. Enrollments,” Child Care Aware of America, June 2021

  6. DC Kids Count, Key Measures Early Childhood, DC Action, 2022