January 30, 2016

Commissioner Amy Jacobs

Bright from the Start: Georgia Department of Early Care and Learning
2 Martin Luther King Jr Drive SE
Atlanta GA 30334
Re: Draft Child Care and Development Fund (CCDF) Plan for Georgia FFY
2016-2018
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 worked to ensure that all of Georgias children enter
kindergarten prepared to succeed and 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 rolls that high quality, stable care can play in buffering
the effects of adverse childhood experiences; ensuring that families have the
opportunity to become self-sufficient; and promoting a high quality current and
future work force for Georgias 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.
The DECAL draft addresses many aspects of quality and access for families in
Georgia, but we will focus on just a few of the key components of the plan in these
written remarks. Further comments are included in the attached table.
We commend DECAL for proposing to increase income eligibility limits to families
who earn 65% of the state median income. 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. It is important to note that while the
new plan raises eligibility limits to 65% of SMI from the current 50% level, it does
not propose an increase all the way to 85% of SMI, the maximum limit that the
federal legislation allows.
We are also strongly supportive of DECALs plan to increase reimbursement rates to
providers to 50% of market rate and to increase the tiered reimbursement rate for
providers participating in the states Quality Rated Program to up to 75% of the
market rate. Quite simply, we cannot expect even the best-intentioned child care
providers to provide high quality care at minimal rates of payment, and these

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 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.
While we strongly endorse these proposals to increase access to quality care, we
recognize that, without additional funds from either the federal or state
government, it is likely that Georgia will serve significantly less families once this
plan is enacted. The effect of a contraction in numbers of families served could
have serious consequences for Georgias work force as well as for the well-being of
some of Georgias most vulnerable children. We urge the Governor and the
legislature to increase state funding for this program and will continue to work at
federal and state levels to secure needed funds. In the meantime, we respectfully
request that DECAL provides us with projected numbers of children who will likely be
affected by a cut in services. In addition, we urge DECAL to establish a uniform and
transparent process for putting families on a waiting list, for monitoring the time it
will take for eligible families on the waiting list to be served, and for ensuring that
the waiting list process is implemented with fidelity throughout the state.
There are several aspects of the proposed plan that appear to be very promising but
still require further development. We would like to partner with DECAL as you
develop plans for increasing access to developmental screening and consider how
to implement a graduated fade-out of benefits. Moreover, we are particularly
excited about the departments plan to define and measure access, and we would
hope to plan a role in that work. Finally, please let us know how we can best assist
you in defining and achieving your vision of establishing regional centers for high
quality infant toddler care.
Again, we appreciate your work to ensure that the draft plan reflects our shared
commitment to high quality early education for Georgias children, and we are
proud of our continued partnership with DECAL. We thank you for the opportunity
to submit feedback and direct your attention to the attached table that contains
additional questions, suggestions and comments on various sections of the draft
plan.
Sincerely,

Mindy Binderman
Executive Director

AdditionalCommentsandQuestionsfromGEEARS

SECTION

1.6
2.2.7
2.2.8

COMMENT
WewouldlikeforDECALtoinvestigatewaystoexpandthepartnershipwith
QualityCareforChildrenssharedservicesalliance.
Canyouclarifyhowyouplantodevelopapolicytoaddressthepreventionof
expulsionandsuspensionofpreschoolandschoolagechildren?
WeconcurwithVoicesforGeorgiasChildrenssuggestionthatthisgroup
shouldincludetheprovidercommunity.AsVoicesstates,accessingEPSDTis
achallengeacrossthestate.Providershaveindicateditisinpartduetotwo
primaryreasons:lackofaccesstoprovidersfortherapeuticreferrals
(Treatment),protocoltofollowEPSDTatwellvisitsischallengingtofollow
andfrequentlyresultsinunbillabletime.Partnersshouldalsoincludethose
thatcanaddcapacityfortrainingthroughmanpowerandforums/platformsto
providetrainingschildcareassociations,e.g.,QualityCareforChildren,
universities.IncludeinCDAcurriculumasectiononEPSDTand
developmentalscreeningsthiscanincludeinformalsignsthatproviderscan
observeinclassroomsversusformalscreeningmeasures.Includethestate
workingwithDepartmentofCommunityHealthonaplanforreimbursement
ofscreeningsbychildcarefacilities,andtheCMOsonanimplementationplan.

3.1.3

3.1.6
3.2.1

3.2.2
4.1

4.1.3
4.4.1

5.1.2
5.2.2
6.1.7

6.3.3
7.3
7.4.2

WeurgetheDepartmenttocountatleast2yearsofcollegetowardsearninga
4yeardegreetobeincludedintheeducationrequirementdefinition.Research
showedthat,duringthelastrecessionindividualswithpostsecondarydegrees
weremorelikelytobeemployed.Inaddition,childrenwhosemothershavea
collegeeducationscoreseemtodobetteracademically.
Whatisthemethodforallowingafluctuationinearnings?Howwillthe
Departmentensurethatallcasemanagersapplythispolicyequally?
Thelackofprioritizationoffamilieswithverylowincomesseemstorun
countertothepurposeofCCDF.And,whilethesefamiliesarenotchargeda
copay,theycanstillbechargedthedifferenceintuitionbetweenthesubsidy
amountandprivateratebytheprovider.
OtherpartnersmightincludeOurHouseandGenesisShelter
The requirement that informal child care can only be
provided when no other licensed care is available within a
reasonable geographic area, during non-traditional hours
when licensed care is not available, or if the child in care is
determined to meet a special needs definition is reasonable.
HowareoutcomestrackedintheE3Zs?WhatpercentagesofQualityRated
CentersintheE3ZscurrentlyacceptCAPS?
Wesupportgrantsto2and3starcentersbutwanttoensureageographic
distributionthatensuresthatcentersreceivinggrantsareinareasofhighneed.
GEEARShopestoworkwithDECALasitattemptstodefineandmeasure
access.
Wearegladtoseethatsomeregulationsonexemptprogramssuchas
appropriateratioandgroupsizerequirementswillbeestablished.
Theseunannouncedmonitoringvisitsareimportant!Thisisagoodstep
towardspossiblymonitoringthefullrangeofexemptprogramsincludingthose
thatwillnolongerbeeligibleforCAPS.
WhatisthecurrentstatusofDECALScholars?Fundingwasfrozeninthefall.
Whatistheapplicationprocess?Doteachershavetogetpreapprovalto
participate?Howistheprocessbeingcommunicatedtoteachers?
TheteacherbenefitslistedareonlyforPreKteachers.Itshouldbenotedthat
infantandtoddlerteachersdesperatelyneedsimilarbenefits.
Wearegladtoseeadditionalresourcesdevelopedtosupporteducatorsin
usingtheGELDS
Howwillregionalcentersbefunded?HowwillDECALpartnerwithservice
providersandotheragenciestoprovidearangeofservicesincluding
screenings,eligibilitydeterminations,andotherservices?
HowdoesDECALevaluationandmeasurethequalityoftechnicalassistance?
ProviderstellusthatTAisofmixedquality.

7.6.1

Whilethisplanwillhelpimprovequality,itdoesnothingtoincreasethe
numberandpercentageoflowincomechildrenserved.Infact,itislikelythat,
withoutanewstateinvestmentintheprogram,lesschildrenwillbeservedthat
arecurrentlyreceivingCAPS.