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The table below shows comments received at this web site about the following rule:

CCDF Plan 2019-21
The Child Care and Development Fund (CCDF) is the primary source of federal funding for child care subsidies for low-income working families and funds to improve child care quality. The Department of Early Learning (DEL) is required to submit a CCDF Plan every three years.

DEL uses these comments, and other input during the rule making process, to help us write and adopt the permanent rules. For proposed rules only, DEL will prepare one response to all of the comments received, in what is called a “concise explanatory statement” required by RCW 34.05.325. The department sends the concise explanatory statement to everyone who commented or testified on the proposed rule, and to anyone who asks for it.

Agree/Disagree: Disagree

Comment: The new rule that requires background checks before hire would make operation of a center near to impossible without a major change in DEL’s background check response time. We would need online instant background checks. Also there would be a need for temporary provision of staff in case of emergencies, say where an employee walks off the job or fails to show up. Another important point would be the need to accept other private, immediate background checks that are more prompt and responsive.

Date Submitted: 6/9/2018 6:26:20 PM

Agree/Disagree: Neutral

Comment: May 22, 2018 Matt Judge, Child Care Administrator Washington State Department of Early Learning PO Box 40970 Olympia, WA 98504-0970 Dear Mr. Judge, On behalf of Public Health – Seattle & King County (Public Health), I am writing to encourage the Department of Early Learning to include key health and safety supports in the Child Care and Development Fund (CCDF) Plan. This is essential for protecting infants and young children in licensed child care and early learning settings. Public Health – Seattle & King County supports state expansion of access to child care health consultation. A growing base of evidence links child care health consultation to positive changes in child care providers and the health outcomes of young children—especially infants and toddlers. Specifically, research shows that child care health consultation is associated with improved safe sleep practices that reduce sudden infant death syndrome (SIDS), improvements in immunization status, reduced respiratory and gastrointestinal illnesses, and decreased expulsions – which disproportionately affect young boys of color. For many vulnerable children in care, infant nurse consultants may be the first to identify health and developmental concerns, as well as ensure their daily environments are safe. Our local health department is able to offer this vital service to a limited number of child care providers in King County, but we know this isn’t possible for other jurisdictions due to resource constraints and access barriers. Many child care providers are therefore forced to go without conducting consultations, which violates licensing requirements and best practices outlined by the American Academy of Pediatrics. New investments within the CCDF Plan could support: - A dedicated nurse to provide remote consultation via phone or Skype for child care providers with geographic barriers; - Additional nurses and community health workers in underserved regions of the state; or - A streamlined system for child care providers to connect with health consultants. Any of these would dramatically increase access to child care health consultation throughout the state. Public Health – Seattle & King County also supports additional funding to reduce toxics in the child care environment. A recent sample study found that in six of seven Seattle child care centers, nap mats contained toxic flame-retardant chemicals that cause serious health problems—including obesity, cancer, and early puberty. Replacing these mats can be costly, especially for child care providers with limited revenue. Additional funding in the new CCDF Plan to identify toxics in child care settings, and to provide education, support, and resources for mitigation, could ensure that more child care providers are truly able to implement changes that reduce young children’s exposure to harmful chemicals when they are most vulnerable. The health of our youngest and most vulnerable children is a priority that deserves full protection. Again, I respectfully request that your department considers revisions to the Child Care and Development Fund Plan that includes increased resources for child care health consultation and additional resources to reduce toxic materials in child care settings. Thank you for considering these comments. I appreciate the opportunity to provide our input and welcome any questions or requests for further information. Sincerely, Patty Hayes, RN, MN Director Public Health – Seattle & King County Work: 206.263.8285 Patty.hayes@kingcounty.gov

Date Submitted: 6/9/2018 4:52:08 PM

Agree/Disagree: Disagree

Comment: Does taking the CCDF money actually cost the State of Washington more money than it receives when all the bureaucratic burden of administering the program and the large number of state employees requiured is considered?

Date Submitted: 6/9/2018 4:03:08 PM

Agree/Disagree: Disagree

Comment: 5.3.Enforcement "...approach to licensing emphasizes supporting them to meet standards..." This needs to be the culture of DEL/DCYF. The rules have to be reasonable, transparent, achievable within cost constraints, and not micromanaging an environment with children actively engaged. There are hundreds of examples of compliance agreements for ridiculous things and examples of inconsistent licensing enforcement.

Date Submitted: 6/9/2018 3:23:19 PM

Agree/Disagree: Disagree

Comment: 5. Nutrition This is an optional standard. Requiring providers not enrolled in the USDA Child Care and Adult Food Program to follow CCAFP is regulatory over reach. Abiding by CCAFP rules is more expensive than basic healthy eating and many families will find it too restrictive, too unappetizing, and too insensitive to their family's traditions and favorite foods. All costs have to be passed on to parents.

Date Submitted: 6/9/2018 3:07:01 PM

Agree/Disagree: Disagree

Comment: 5.2.2 Immunization Providers must, at their annual inspection, show proof of vaccination or acquired immunity to vaccine-preventable diseases for all children in care. WHAT? Are children with Certificates of Exemption, including for medical reasons, no longer allowed to be enrolled in child care? Which specific vaccine-preventable diseases as there are many which do not require childhood vaccination?

Date Submitted: 6/9/2018 2:53:17 PM

Agree/Disagree: Agree

Comment: Twelve month eligibility for continuity of care.

Date Submitted: 6/9/2018 2:04:55 PM

Agree/Disagree: Disagree

Comment: 3.1 Eligible children and families $1 Million in assets and still eligible for child care assistance! This defies common sense. If you have $!M in assets, sell some of them. When child care providers often make little more than minimum wage, this is outrageous.

Date Submitted: 6/9/2018 2:01:49 PM

Agree/Disagree: Disagree

Comment: 2.5 Expulsion and suspension and FIND State offers professional development opportunities...behavior support, individualizing instruction, fostering resiliency... Look at how low the hourly reimbursement will be for special needs and those payments are only available for WCCC. Where does the money come from for one on one instruction or behavior support when all the parents are paying privately? The paragraph about FIND needs to be expanded to include facts about when and where it has been used and the outcomes.

Date Submitted: 6/9/2018 1:55:48 PM

Agree/Disagree: Disagree

Comment: 2.5.6 Suspension and expulsion The CCDF draft and the proposed WAC changes do not value the safety of providers, staff, and the other children in care over a dangerous child. Unless the State intends to accept all legal, financial, and moral liability for a staff member or another child being injured, suspension or expulsion must be a decision made by the child care provider who carries all the responsibility. We might be able to help a child and family with behavior challenges, but would be foolish to enroll such a child if we risk staff and other families quitting because the state dictates when we can end care for an out of control or physically dangerous child.

Date Submitted: 6/9/2018 1:46:39 PM

Agree/Disagree: Disagree

Comment: 4.3 SUBSIDY Special needs rate. Minimum wage January 1, 2020 $13.50. With taxes approximately $14.95 per hour for a 16 year old without education or experience. $15.89 maximum will just barely cover one on one support by staff at the lowest level.

Date Submitted: 6/9/2018 1:12:21 PM

Agree/Disagree: Disagree

Comment: I do not agree with requiring cleared background checks before an employee can work. I agree with the current policy and find the new one requiring ADVANCE background checks to difficult for situations in which you need a new hire to begin immediately or you need a substitute teacher or a volunteer. Until DEL can process same day background checks they should not require this.

Date Submitted: 6/9/2018 8:28:56 AM

Agree/Disagree: Disagree

Comment: I find this new action proposal appalling. I wonder how long these individuals have spent in an actual early childhood setting running the operations from day to day, week to week, to be able to bring these types of motions up!!!! Finding quality candidates is hard enough let alone keeping these teachers on a consistent basis. If we are not able to hire upon the interviewing process; hiring staff and maintaining state ratios will make our jobs as directors even more difficult than it already is when we have to wait weeks sometimes months to get a completed background check. I highly disagree with this motion!

Date Submitted: 6/8/2018 3:02:26 PM

Agree/Disagree: Disagree

Comment: This would be not possible to run a center and service the community when background checks could take up to a month to come back.

Date Submitted: 6/8/2018 1:59:37 PM

Agree/Disagree: Disagree

Comment: Requiring a person to have a background check before starting work at a childcare center is not practical. The background check takes too long. We cannot expect people to be unemployed for a month while they wait for the background check to come back. It is already difficult to find people, this will make it impossible.

Date Submitted: 6/8/2018 1:55:04 PM

Agree/Disagree: Neutral

Comment: I believe that what type of Childcare service you provide is your choice. A child is a child and across the board the subsidy rates should be the same no matter if you have an in home or center based.

Date Submitted: 6/8/2018 1:39:02 PM

Agree/Disagree: Disagree

Comment: I just heard that the CCDF that is being submitted very soon will require that new employees must have CLEARED background checks before they begin employment! This will completely and effectively force many of us to close our doors on those days when we have an unforeseen circumstance arise that puts us out of ratio. I am talking about those times when an employee goes to break and never returns or leaves for the day and never returns or gives a very short notice and we don't have time to hire a replacement. These situations are real and DO happen to all of us centers. Unless DEL is able to process same-day background checks, this new requirement will cripple us and make it impossible to manage our centers. Please rethink this and do NOT put this system into place.

Date Submitted: 6/8/2018 1:35:56 PM

Agree/Disagree: Disagree

Comment: I received an email today from WCCA that said part of the the proposed CCDF stipulates the staff will be required to clear their background checks before starting employment with centers. The email said that this topic came up during the CCDF webinar and Matt Judge with DEL verified that this new requirement would apply to all providers. I do not have enough words to express how damaging this piece of the CCDF would be to centers, mine included. Portable Background CHecks through DEL can take weeks, even months to clear. We would lose candidates to other positions and our children will suffer by not having adequate staffing. Please, please, please remove this requirement from the CCDF!!!

Date Submitted: 6/8/2018 1:25:35 PM

Agree/Disagree: Disagree

Comment: Staff must be able to work while they are waiting for a background check to be cleared as long as they are always supervised by another staff who has cleared a background check.

Date Submitted: 6/8/2018 1:20:03 PM

Agree/Disagree: Disagree

Comment: I FEEL THE MONEYS SHOULD GO TO ALL CHILDREN AND THEY ARE COVERED BY MNEDICAL EITHER THRIOUGH PARENTS OR STATE AND HAVE ACCESS TO A NURSE OR DR AND EACH YEAR DEL KEEPS LOWERING THE AGE FOR PROGRMS AND NEEDS OF FUNDING UNTIL WE ARE DOWN TO THREE AND IN FUTUR TWO YEARASOF AGE IN SPEAKING WITH PARENTS THE UN BOME PARENTS FEEL THEY PUT THE CHILDREN IN HOME CARE FOR A HOME ATMOSPHERE AND TO LEARN TO BOND AND SHARE AND THEY CAN ALSO LEARN BURT NORT AS A SCHOOL ROUTINF E OR ASET SCHEDU;LE

Date Submitted: 5/28/2018 6:01:26 PM

Agree/Disagree: Neutral

Comment: I believe that with this rule we also need to actually raise what is being paid for State Children so that it's being increased with wages going up.

Date Submitted: 5/24/2018 12:11:33 PM

Agree/Disagree: Disagree

Comment: I think out door pre schools should follow the same rules as homecare or center care.

Date Submitted: 5/23/2018 1:44:51 PM

Agree/Disagree: Disagree

Comment: I disagree that family childcare homes should receive higher rates then centers. it cost much more to operate a center then it does in home. our rates are already too low we are struggling to stay in business with minimum wage and everything going up.

Date Submitted: 5/23/2018 11:53:45 AM

Agree/Disagree: Disagree

Comment: 4.3.1 To use a market rate survey to set subsidy rates is reactive instead of proactive. If the rates are only changed every three years, it is not taking into account the other changes currently happening and happening in the near future. These changes include aligning WACs and increasing facility standards which will require extra funds, increasing staff education which will need to be compensated in wages and benefits, and staying ahead the changes in upcoming increases of minimum wage requirements. Minimum wage alone will heavily impact early learning providers. The current rate for an infant in licensed care for Region 1 is $34.03 per day. Right now, it costs a program that operates 12 hours per day, $138 in wages for one employee to care for infants from open to close, yet subsidy payments only covers at most $136.12 per day if four full time infants are enrolled. How can an early learning program survive on this? Subsidy rates do not even pay an infant teacher’s wages at minimum wage! The costs of business is much higher than just paying teacher wages. How will an early learning program survive when minimum wage reaches $13.50 in 2020? 4.3.2 Differential rate for higher quality should be the same additional rate for licensed family homes and licensed centers, if not higher for licensed centers which require additional funds to reach and maintain quality. For instance, if a licensed center reaches a level 3, they should also receive a 10% increase in order to meet the costs of reaching and maintaining this quality level. Family homes and licensed centers have the same level rating system and requirements of points to meet those levels, therefore family homes and licensed centers should be provided an equal rate for meeting each level of quality. This higher quality rate should not be included in the MRS determined rates in order to offset subsidies, but to be above what is needed from subsidies to cover the cost of business in order for the higher quality bonus to fund maintaining and continuing to improve quality on top of minimum requirements.

Date Submitted: 5/20/2018 1:01:12 PM

Agree/Disagree: Disagree

Comment: I just don't understand how a family home can receive higher subsidy payments per child then a Center based operation! More and more requirements for the Teachers, Owners/Operators are a good thing but who pays for that in the long run? Teachers will want more money for what they know but the system is not balanced. When 60% of your income goes towards employees, employee taxes, business taxes at the end of the year and general operation costs how is that feasible? It has been said that the first 3 years of a child's life are the most important. I think its time to reward the people who are solely responsible for making sure the staff provides that type of atmosphere. I understand that providers depending on where the live get paid different rates but when you have your business in Yakima and someone from Benton City which is a very small town makes $2 more per child something is wrong. We all do the same job and should be providing the same service why should business make more then another?

Date Submitted: 5/18/2018 3:39:00 PM

Agree/Disagree: Neutral

Comment: Yes, for more DSHS funding for all the providers and make the parents more responsible for how they use this money. Do you have any idea how many parents drop their kids off in PJ's? I'm talking about parents that go back home to bed! Why not require parents also getting this money to have some parenting classes, also check where they are working more often? Do you know that a parent can take 1 college class and still bring their kids to childcare daily? It happens all the time and the parent or parents flunk out of school, how is that even possible when they kids are in daycare 10 hours a day for 1 hour of class the parent attends. STOP PUNISHING THE PROVIDERS WITH ELECTRONIC ATTENDANCE ETC ETC, go after the parents sleeping using childcare while they run around with boy/girl friends and sleep! excuse all the punctuation errors i'm pissed and a tax payer these funds are misused by so many parents!

Date Submitted: 5/18/2018 3:12:47 PM

Agree/Disagree: Disagree

Comment: funds should be equal to all families-- why diffrenciate children learning-- EACH child deserves learning... As a home child care provider and level # EA rating- I can use fund to create bette enviorment BUT leaving in city where low income enrollment is not feasible- This doesnot men that children in care cannot have better funding--- I was decline for funding as do not have any low income enrolled- Well I do not have any low income call or inquiry past 2 years..... why limit funding to build future?//

Date Submitted: 5/18/2018 2:05:16 PM

Agree/Disagree: Disagree

Comment: According to this draft, planned reimbursement rates will be higher for licensed family child care homes then rates for Centers. I have ran a licensed child care home and currently operate 2 Centers. Centers have more overhead costs then a family child care home and should be reimbursed accordingly. Centers also have the capacity to offer more subsidy spot-it seems important to ensure that Centers are well supported and find it financially viable to continue accepting DSHS subsidies.

Date Submitted: 5/15/2018 8:28:49 AM

Agree/Disagree: Neutral

Comment: Thank you for the opportunity to voice my comments. This submission bolsters the Child Care Development Fund (CCDF) and DEL’s mission to improve child care quality. This proposal is requesting the CCDF provide grant funding for a nurse consultant who has child care and pediatric experience to work remotely with early learning programs that have no access to a nurse consultant. This recommendation is for a pilot project to fund a nurse or nurses to provide monthly support to child care providers with infants via technology, i.e. Skype, Face time, etc. throughout the state. This nurse consultant position would also be available to provide phone/email triage to early learning programs that do not serve infants. There is clear evidence that there are many child care programs across the state that do not have access to health professionals which are specific to the Early Learning community. When there are no nurse consultants available, the centers are limited on who they can call for help when health/safety concerns arise. Funding this proposal could help eliminate this situation. The funds would be used to assist Early Learning programs with developing health care plans for children with special needs, medication and emergency care plan development. This consultant would be versed in topics such as infant development, child development, safe sleep, disaster preparedness, nutrition, behavioral and social emotional support as well as WAC requirements. Website development and up-to-date materials will be integral to this project. These consultations will provide much needed advice to the directors, teachers and families in a timely manner. Nurse consultation supports one of the most vulnerable populations; children. This strategy will improve the quality of child care provided to the infants, and young children in Early Learning settings. Please consider funding this proposal. Thank you for your consideration.

Date Submitted: 5/3/2018 2:17:20 PM

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