This year, the California Department of Education’s Early Education and Support Division (EESD) is making revisions to their child care regulations to make improvements for families and child care providers. They want to hear from experts—people like us who provide direct care—by January 9, 2017.
This week, the Department of Education hosted phone calls to hear from Child Care Providers and other experts. Several SEIU Local 99 members participated and gave valuable input. You can read notes about the suggestions that were made here. If you weren’t able to join the calls, you can still send your recommendations – but the Department of Education needs to hear from you by this Monday, January 9.
Here is what you need to do:
- Write an email listing the changes you want to see in the state’s child care regulations. Send it to eesdtitle5@cde.ca.gov and cc nrinconksido@seiu99.org
- The Department of Education asks that you reference the regulation number that you want to change when making your recommendations. For example, if you want to recommend a change to AP payment practices, you would write: “I am commenting in regards to 18226 Plan for Provider Payments.
You can view the existing regulations by clicking here and here. If you cannot determine a reference, simply say that you are proposing a change to Chapters 19 and 19.5 which cover the child care voucher program, state preschool and networks.
- Below is a sample email that you can send. Feel free to edit it any way you’d like.
- Be sure to send your email by the deadline of Monday, January 9, 2017 to eesdtitle5@cde.ca.govand cc nrinconksido@seiu99.org
Let’s keep making our voices heard for quality early education and care!
Tonia McMillian, Child Care Provider and SEIU Local 99 Treasurer
__________________________________________
SAMPLE EMAIL. Cut and paste it into your email account, make your edits and send to eesdtitle5@cde.ca.gov and cc nrinconksido@seiu99.org by Jan. 9
To Whom It May Concern:
Thank you for the opportunity to give input on changes to the state’s Title 5 regulations. As a child care provider, I’ve seen firsthand what providers like me and parents need from our state’s child care system, and offer my input based on my experience every day working in California’s child care system.
I suggest changing 5 CCR section 18226 Plan for Provider Payments. I would amend the language to set a specific paydate for providers rather than having each agency determine its own date that meets a “timely” definition. I suggest that if providers submit a complete and accurate invoice by the 5th of the month following when care was provided, we receive payment by the 15th of that month. I am making this recommendation because dates vary widely by agency, making planning difficult as a business owner with set expenses. In addition, standard provider practice is to receive payment on the same week/day/month as providing care, so already we are receiving reimbursement for subsidized families much later, which is a hardship for us.
I suggest changing section 18223 regarding provider grievance procedures. I recommend that you establish an independent third-party ombudsperson whose responsibility it is to address grievances that cannot be resolved at the agency level. I suggest this change because the current practice of utilizing a Uniform Complaint Procedure is established for a parent, not a child care provider.
I suggest changing section 18224 regarding written materials a provider receives. I suggest adding languages that requires agencies to provide an accounting in writing with reimbursements each month that explain at a minimum what ceiling was used, for how many hours, and any other factors that contribute to the reimbursement amount calculation. I also propose a training offered at least once a year for providers to understand the agencies’ practices around calculating reimbursements.
I suggest changing section 18075 reimbursement rate categories. I suggest eliminating duplication between weekly and monthly rate ceilings, and adding language that prioritizes assigning a set part-time or full-time rate ceiling where possible than a variable rate ceiling. This will allow better stability for providers and families.
I suggest changing section 18076 regarding limitations on use of reimbursement rate ceilings. Specifically, I suggest changing the requirement that state reimbursement rates cannot exceed rates charged to private paying parents.
Further regarding reimbursement rates, I recommend that rates paid for subsidized children should not be connected to rates that providers charge for unsubsidized families. If this connection remains, I then recommend that providers should also be able to submit a rate adjustment to agencies 30 days prior to rate ceiling increases, and should be provided information 60 days prior to rate ceiling changes to utilize in making decisions on rates they charge.
I recommend requiring that rates be set at a way that ensures that providers are paid the equivalent of $15 per hour as well as can pay all assistants working in our child cares at $15/hr. This helps us ensure quality care. We also should establish a career ladder, with higher compensation above the $15/hr rate recognizing providers who achieve higher skill levels.
I recommend changing the practice regarding background checks being connected to a provider’s license only. Specifically, providers need to receive confirmation of background check approvals and have some centralized way to check on approval if a possible employee has already received background check clearance.
I recommend improvements to notifying parents about changes in parents’ eligibility that impacts care we provide, including reimbursement we expect. A best practice to make standard is a form CCRC has that providers have parents sign to access to each other’s updates, called Authorization for Release of Information.
I recommend that the state require a minimum of two weeks’ notification and payment when a subsidized child is leaving care. This is the standard that most providers follow with non-subsidized families.
I will be following closely the CDE’s work to update these regulations this year. Please keep me informed. Additionally I suggest that CDE meet with a group of providers and our union representatives to give further input on these topics.
Best,
YOUR NAME
