Testimony of Audrey Kasselman, Policy Analyst, before the District of Columbia Office of the State Superintendent of Education

June 4, 2024
Testimony
Person Testifying: Audrey Kasselman
Title: Policy Analyst, Under 3 DC
Testimony Heard By: District of Columbia Office of the State Superintendent of Education

Thank you for the opportunity to submit written testimony. My name is Audrey Kasselman and I am a Ward 1 resident and a policy analyst with DC Action and the Under 3 DC Coalition. Under 3 is committed to securing a strong start for every infant and toddler in DC. My testimony emphasizes the importance of maintaining essential changes and recommends further improvements to the District’s Child Care and Development Fund state plan for FY25-FY27. While we commend OSSE for taking meaningful steps to address the needs of families and providers, there is still much more to be done to achieve equity in our child care system.

First, we want to express our gratitude to OSSE for partnering with the Under 3 DC coalition and joining our Town Hall earlier this year to get feedback on various topics governed by the CCDF state plan. We also appreciate the stakeholder engagement sessions and the platform provided for the early learning community to share their experiences and recommendations. We are pleased to see changes in the draft plan that will significantly benefit parents in the most challenging situations, families with very low incomes, and child care providers and early educators. 

Reducing barriers to entry for the Child Care Subsidy program

We applaud OSSE for taking measures in the draft state plan to reduce barriers for parents seeking child care assistance through the subsidy program. Specifically: 

  • Removing the 20-hour work and education requirements (Section 2.2.2)
  • Expanding the definition of working and attending an education program to include more parents (Section 2.2.2)
  • Expanding categorical eligibility to reduce paperwork and application processing time (Section 2.1.1)

The elimination of the 20-hour work and education requirement is a transformative change for parents. We have heard from numerous parents – who work in the gig economy, who have had their hours reduced, and who are enrolled in part-time education programs – that the 20-hour requirement is burdensome from both a paperwork standpoint and from an equity perspective. We wholeheartedly believe that all children should have access to child care, regardless of how many hours a parent is working or in school. 

Expanding the definition of “working” for eligibility into the Child Care Subsidy program to include job search activities and parents receiving unemployment insurance will make more parents eligible for the program and alleviate the need to secure employment before obtaining affordable child care. Similarly, broadening the definition of “attending an education program” to include high school or GED programs, certificate programs, and one-year diploma programs will increase access to affordable child care for young parents and parents going back to school to complete their education. 

Categorical eligibility is a tool that aligns child care eligibility with select other public programs, so that a family deemed eligible for certain public programs does not have to separately apply for child care assistance. We are pleased to see OSSE continue categorical eligibility with TANF and SNAP Employment and Training (E&T) and expand categorical eligibility to include applicants participating in Department of Employment Services or other District employment or job training programs, and applicants receiving unemployment insurance. We encourage OSSE to continue expanding categorical eligibility to include more public programs. A more expansive categorical eligibility policy has the potential to significantly reduce paperwork while simultaneously speeding up application processing times. Categorical eligibility is a meaningful way to minimize burden on families and providers and ensure that families do not have to wait, or give up (due to too much paperwork and lengthy processing time) trying to access the care that they need. 

These changes to the draft state plan are likely to increase eligibility for the Child Care Subsidy program, therefore broadening access to high-quality child care for more families in the District. These changes will expedite the processing of subsidy applications, to the benefit of parents who currently have to wait months for approval which forces them to miss out on job opportunities, promotions, and timely high-quality care for their children. For child care providers, whose businesses are often harmed by delays in application processing, expanded categorical eligibility can mitigate this harm. For more details on how these and other highlighted changes could benefit the early learning community please see a recent letter we sent to OSSE on the matter. 

Making child care more affordable and accessible

We appreciate OSSE’s initiatives to make child care more affordable for District parents by: 

  • Waiving co-pays for families facing various barriers, including families at 150% of Federal Poverty Level and below, for children enrolled in the Quality Improvement Network (QIN) program, children of adults with disabilities, children of teen parent(s), children in families experiencing domestic/family violence, children with parents participating in addiction recovery programs, Temporary Assistance for Needy Families (TANF) recipients, and children of parents engaged in job search  (Section 3.3.1)
  • Continuing existing policy of waiving co-pays for families experiencing homelessness and for families with children with disabilities (Section 3.3.1)
  • Increasing the supply of child care for children with disabilities through a new competitive grant program (Section 4.5.1)

Given the high cost of child care in the District, waiving co-pays for families in the most challenging situations is a crucial step toward making child care more accessible and affordable. Waiving co-pays will alleviate the financial burden on families facing the greatest hardships, enabling them to secure stable, quality care for their children. For child care providers, this means more families in their programs, as families will be able to afford care. 

The Access to Quality Child Care for Children with Disabilities grant program is a promising approach to increasing the supply of child care for children with disabilities, which is not currently meeting demand. This grant program could also provide added funding and stability for child care providers. For the program to be successful, we encourage OSSE to provide robust support, training and resources to the child care providers serving children with disabilities, and focus efforts to grow the workforce of educators and specialists with the skills and training to work with young children with disabilities. Resources and training must not only be available, but also aligned with the program’s needs to ensure that providers can successfully serve children with disabilities. Additionally, OSSE should clarify the relationship between grantees of this program and Strong Start, as well as OSSE’s efforts to coordinate these two programs.

Recommendations to make the CCDF state plan work better for families and providers

As OSSE continues to refine the draft state plan before its submission to the federal government, we recommend the following changes: 

  1. Adopt presumptive eligibility while child care subsidy eligibility is being determined. (Section 2.1.1)
    1. Presumptive eligibility would allow families to receive temporary and immediate financial assistance to pay for child care while the DC Department of Human Services (DHS) verifies their eligibility for the program.
    2. The federal government encourages states to adopt presumptive eligibility and we urge OSSE to do so as well. 
    3. Presumptive eligibility would make a significant difference in the lives of parents and providers by ensuring that families do not have to wait to be approved by DHS to enroll in affordable child care. Right now, wait times are months long, hindering families from accepting job opportunities and preventing children from being enrolled in high-quality care when they need it.
  2. Implement policies to increase the supply of care outside traditional hours (such as evenings, overnight, weekends). (Section 4.5.4)
    1. Countless parents in the District need child care outside of traditional hours to be able to go to work and do their jobs. Currently, the demand for non-traditional hour care far exceeds the supply.1
    2. We encourage OSSE to increase the supply of non-traditional hour care through grants and contracts, by allowing families to use a child care voucher at multiple facilities and through other mechanisms to incentivize providers to offer this care. 
    3. Provide a timeline for OSSE’s review and analysis of current subsidy policies with the goal of increasing the supply of non-traditional hour care. 
  3. Collaborate closely with parents to establish updated and transparent definitions of quality in early education programs, facilitating a clear understanding among families, providers, and OSSE. (Section 7.1.1)
    1. Parents and providers have shared that they do not have the information they need to understand whether current definitions of quality set by OSSE align with their perspectives and priorities. Providers have expressed misalignment between Capital Quality standards and national accreditation standards such as those set by  NAEYC. Parents have 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.
    2. We encourage OSSE to 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. 
  4. Collaborate closely with parents to make improvements to the DC Child Care Connections website and the District’s Child Care Resource and Referral (CCR&R) system. (Section 9.2 and Section 9.3)
    1. Parents and providers have indicated that the current DC Child Care Connections website and the District’s Child Care Resource and Referral (CCR&R) system can be difficult to navigate and do not always provide clear, comprehensive, and accessible information. This makes it challenging for families to find and choose high-quality child care that meets their needs and for providers to update information about their program. 
    2. We urge OSSE to work collaboratively with parents and providers to improve these resources, ensuring that the information is user-friendly, easily accessible, and reflective of the needs and experiences of families and providers. 
  5. Continue to increase reimbursement rates to cover the true cost of care. (Section 4.1.1)
    1. We encourage OSSE to use CCDF resources to ensure subsidy reimbursement rates reflect the actual costs of providing high-quality child care to ensure financial sustainability for providers and to incentivize more providers to participate in the child care subsidy program. 
    2. Currently, reimbursement rates are lower than the cost of care, which leaves providers in the precarious situation of operating at a loss or on very thin margins when they accept Child Care Subsidy vouchers. By aligning reimbursement rates with the true cost of care, OSSE can help to ensure that providers are adequately compensated, which could improve the overall quality, stability, and quantity of affordable child care in the District.
  6. Streamline the process and reduce application review time for providers to join the child care subsidy program. (Section 4.1.1) 
    1. We encourage OSSE to reduce current bureaucratic burdens that make applying to be a provider that accepts child care subsidies time consuming and difficult. Addressing slow processing time will enable more providers to participate in the subsidy program, thus increasing the availability of child care options for families. 
    2. Expedite processing time for Quality and High-Quality programs seeking to expand to additional sites.
  7. Expedite implementation of prospective payments for providers participating in the child care subsidy program to comply with federal requirements. (Section 4.4.1).
    1. OSSE’s current practice of retrospective reimbursement places providers in a 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 timeliness of payments from the District. Ensuring prospective payments is a critical part of addressing the high and volatile cost of providing child care. 
    2. Prospective pay would improve financial stability among child care subsidy providers and encourage more providers to participate in the subsidy program, thus expanding the child care options available to families with fewer resources.
    3. We understand that OSSE plans to apply for a two-year waiver to give the agency time to stand up prospective payments for providers participating in the subsidy program. 
    4. We encourage OSSE to use as little of the two-year waiver runway as possible. While the waiver is in place, we urge OSSE to be transparent with the steps that the agency plans to take to meet this federal requirement within the stipulated time frame, including publishing a study of barriers in existing DC policy, and a work plan for implementing prospective payments.

In closing, we encourage OSSE to prioritize families and providers who face the greatest barriers to access. By implementing these recommendations, OSSE can create a more equitable and inclusive child care system that supports all families and providers in the District. We look forward to continuing our collaboration as OSSE finalizes the state plan.

Thank you.

  1. Sandstrom et al. “Nontraditional-Hour Child Care in the District of Columbia” (November 2018. Urban Institute. Available at https://www.urban.org/sites/default/files/publication/99768/nontraditional-hour_child_care_in_the_district_of_columbia_0.pdf