Transcript of Final State Plan Hearing and QRIS Objection Posted Online

Verbatim Transcript of Final CCDF State Plan Hearing and QRIS Objection Posted Online

The verbatim transcript of the Final Hearing of the Child Care Development Fund State Plan has now been posted online.

Please note that NO member of SECAC representing the child care industry (or otherwise), who would dare to present derogatory and unfounded characterizations (potential defamation) of fellow child care providers to SECAC committee members but who do have a vote on the implementation of the CCDF State Plan, even bothered to attend!  (OUT OF TOUCH!)

Fortunately, Administrative Procedures Law instructs the following:

(i) “Rule” means the whole or a part of an agency regulation or other statement of general applicability that implements, interprets or prescribes:

(i) Law or policy, or

(ii) The organization, procedure or practice requirements of an agency. The term includes the amendment, repeal or suspension of an existing rule.

§ 25-43-3.105. Economic impact statement, requirement and conditions.

(1) Prior to giving the notice required in Section 25-43-3.103, each agency proposing the adoption of a rule or amendment of an existing rule imposing a duty, responsibility or requirement on any person shall consider the economic impact the rule will have on the citizens of our state and the benefits the rule will cause to accrue to those citizens.

2) Each agency shall prepare a written report providing an economic impact statement for the adoption of a rule or amendment to an existing rule imposing a duty, responsibility or requirement on any person. The economic impact statement shall include…

(e) An analysis of the impact of the proposed rule on small business;

(g) A determination of whether less costly methods or less intrusive methods exist for achieving the purpose of the proposed rule where reasonable alternative methods exist which are not precluded by law;

(3) No rule or regulation shall be declared invalid based on a challenge to the economic impact statement for the rule unless the issue is raised in the agency proceeding. No person shall have standing to challenge a rule, based upon the economic impact statement or lack thereof, unless that person provided the agency with information sufficient to make the agency aware of specific concerns regarding the statement in an oral proceeding or in written comments regarding the rule.

(3) Before the adoption of a rule, an agency shall consider the written submissions, oral submissions or any memorandum summarizing oral submissions, and any economic impact statement, provided for by this Article III.

(2) An action to contest the validity of a rule on the grounds of its noncompliance with any provision of Sections 25-43-3.102 through 25-43-3.110 must be commenced within one (1) year after the effective date of the rule.

On February 19, 2016, child care leadership representing the Mississippi Child Care Coalition raised formal objection to the proposed “re-write” and continuation of Q.R.I.S. embedded in the 2017-2019 CCDF State Plan.

To review the transcript, please click here.

Fight the Power (and boorish disrespect), y’all!

 

 


Dear Editor:

Dear Editor:

In reference to Sunday’s Clarion-Ledger article, “Bill could break cycle of inaction on child care in Miss.”, I wish to say Mississippi has an Interagency Council for the coordination of agencies and services. It is called the State Early Childhood Advisory Council and was established in compliance with federal statute.

Senate Bill 2274 appears to be exactly as referenced by Petra Kay in the Clarion-Ledger – a struggle for “who will be in charge” of limited resources including the Child Care Development Block Grant.

Senator Wiggins’ bill does not address the unfunded mandate for child care providers to hold a B.S. Degree in Early Childhood in order to be deemed “a quality rated center” or the costs that would be passed along to parents as a result.

SB 2274 would either create more duplication of services or eliminate the Governor’s Early Learning Council (SECAC) and thus remove the large majority of stakeholders from the policy making table.

SB 2274 appears to be in support of a plan that was reviewed by national education experts twice, FAILED twice in the Race to the Top- Early Learning Challenges and did not secure the federal resources needed to implement the poorly rated plan. See CL article, December 10, 2014, “Mississippi misses out on federal preschool money – again”. http://www.clarionledger.com/story/news/2014/12/10/mississippi-misses-federal-preschool-money/20194705/

This “crisis” has no real merit.

Debbie Ellis

Mississippi Association of Licensed Child Care Providers

Greenwood, MS


HECHINGER’S “CRISIS IN CHILD CARE” SMEAR CAMPAIGN IS BROUGHT TO YOU BY KELLOGG!

A child care press conference will be held on Monday, February 8, 2016, on the second floor of the Capitol at 10:00 AM.

HECHINGER’S “CRISIS IN CHILD CARE” SMEAR CAMPAIGN IS BROUGHT TO YOU BY KELLOGG!

The Hechinger Report knew the Mississippi Committee to the U.S. Commission on Civil Rights was investigating potential Disparate Impact in Mississippi’s child care quality rating system before publishing harmful, unsubstantiated child care complaints (that should not have been disclosed because Courts have ruled no public interest exists in unsubstantiated complaints) and expressed its disdain for Constitutional Due Process of Law in Sunday’s Clarion-Ledger – its partner.

Seems to me they may as well partner with the paparazzi and the National Inquirer!

Hechinger is funded by the W. K. Kellogg Foundation which is actively involved in the promotion and support of Mississippi’s Pre-K Collaborative and QRIS.

Up to now, it has seemed, particularly to self-employed child care providers, that the strategy (in Mississippi) of some Pre-K Collaborative supporters (including some media outlets, public policy groups and member organizations) may be to lift up their member programs (and gainful employment through associated grants) by disparaging self-employed child care providers (the majority of which are Black and/or women owned and operated Programs) through selective reporting, adverse policy, exclusion, and marginalization.

Perhaps the idea is to bully the citizenry and working parents, over time, into agreement that child care and time spent with us is not safe or where a child should be; only six hours of public Pre-K such that they would be funded to advise/provide/report can really meet a family’s work support and early learning needs.

And such strategy would be particularly necessary when Frank Porter Graham’s recent Evaluation of Mississippi’s very costly yet unavailing QRIS and measured child outcomes in the recent legislative review of the Pre-K Collaborative are scathing!

The Joint Legislative Committee on Performance Evaluation and Expenditure Review from PEER: The Mississippi Legislature’s Oversight Agency, is the only external Early Learning Collaborative evaluation available to legislators because:

  • there is no child care regulatory oversight for Pre-K classrooms such as is required in other states;
  • there is no QRIS classroom requirement such as is required for Pre-K classrooms in other states so Mississippi cannot compare Pre-K “quality”;
  • the physical standards as governed by the Early Learning Guidelines are less stringent for existing Mississippi Pre-K classrooms than they are for child care classrooms and standards have recently been weakened for new construction through July 2017.

The report does not recommend increased funding or additional staff for Pre-K.

Click here to read more.

A child care press conference will be held on Monday, February 8, 2016, on the second floor of the Capitol at 10:00 AM.

This is your opportunity to unite as the small business child care industry and present the facts.

Stand up for your small business!

Come stand with us!

A message from Carol Burnet of MLICCI:

Dear Friends of Child Care,
You may have read The Hechinger Report articles in the 1/30 issue of the Clarion Ledger. If you did, you probably feel accused of harming the wellbeing of the children enrolled in your center. We are angry that the Clarion Ledger and the Hechinger Report teamed up to promulgate such accusations that harm centers like yours that do everything possible to support children and families. We want you to know that you are doing great work on behalf of your children and families, and we know that you do this work against great odds. Instead of being insulted in the state newspaper, you should be heralded as champions for our state’s low-income working families.
This type of cheap shot gets thrown at child care periodically. For example, a couple of years ago there was a terrible article in the New Republic entitled, “The Hell of American Day Care.” I wrote a response that ran in The Nation and on the Bill Moyers national blog. You can read it here. So this diversionary tactic is not new. Unfortunately, it takes the focus off the need to finance the system we all “say” we want while at the same time tarnishing all the terrific child care champions like you and making low-income working parents feel terrible about using the child care they need. This is not a helpful contribution to the many challenges we face in Mississippi about child care. We have been standing up for child care centers a very long time, and we will continue to do that. We know what a difference you make in the lives of low-income working families and we are grateful to you.
If Hechinger and the Clarion Ledger wanted to be helpful, they would be honest, not diversionary, and promote more funding for child care services to build the system. Articles like this “say” they want to see that more low-income children can be served and more centers can afford to operate and hire staff with early childhood training and equip learning centers. Everyone likes to beat up on child care while starving child care for resources. Our nation and our state have shrunk the number of children served in the child care subsidy program to a 15-year low. To pretend this is about anything other than the nation’s failure  to finance the kind of system everyone pretends to want is just that – pretending.
Help us push Mississippi to build the robust child care system we all know families need. And thanks for all you do for Mississippi’s low-income working families!
Carol Burnett, Executive Director
MS Low Income Child Care Initiative
Child Care Matters.
See what’s happening on our social sites
 
 
MS Low-Income Child Care Initiative | 204 Walker Street | Biloxi, MS | MS | 39533

 

 

 

 


US Commission on Civil Rights Meets Today: Is Mississippi’s QRIS effectively a Tool to Screen a Protected Group Out?

US Commission on Civil Rights Meets Today: Is Mississippi’s *QRIS effectively a Tool to Exclude a Disproportionate Number of a Protected Group from Top Tier Quality Bonuses and Pre-School Participation?

Open Meeting     Thursday     2 PM Central    

Call 888-505-4369   Give ID #4796911

Public Comment Period at the End

Disparate impact is a way to prove racial discrimination based on the effect of a policy or practice rather than the intent behind it.

For example, requiring all applicants for promotion (**or a reasonable increase from a percentage of 2007 market rates only through top tier quality bonus payments) to receive a certain score on a standardized test (or QRIS Evaluation) could adversely affect candidates of color.

Objective criteria, such as tests, evaluations, degree requirements, and physical requirements may be challenged under a disparate impact theory.

These cases rely heavily on statistics, published statements, data, and number crunching, which require assistance from experts and attorneys.

As an example, providers offer these statements to demonstrate potential intent to screen out and exclude a disproportionate number of people and minority owned small businesses through Mississippi’s Quality Stars:

“The QCCSS is an important step in identifying subpar centers, though the rating system does not directly measure child learning.”

Mississippi First- Leaving Last in Line

     Rachel Canter, Executive Director

 

“STAND YOUR GROUND LEGISLATORS, DON’T GIVE IN TO THOSE WHO WILL WHINE AND MOAN ABOUT HOW HARD THIS WILL BE ON SOME CENTERS. THEY NEED TO BE CLOSED AND REPLACED WITH ‘QUALITY’ OPERATIONS, NOT JUST SITES THAT MAKE A PROFIT FOR THE OWNER.”

Gulflive.com

education1st

Over a period of several months, the Mississippi Advisory Committee to the U.S. Commission on Civil Rights has heard testimony and received information upon which it has based the final draft of an Advisory Memorandum of Recommendations to Congress which address potential racial discrimination in the administration of the Child Care Development Fund in Mississippi. (Click here.)

In addition to requested redress of Mississippi’s QRIS, the Committee’s findings state, “a number of African-American child care facility owners continue to view at least some of the state’s administration of CCDF as intentionally discriminatory on the basis of race. In the example of the ***electronic finger scanning initiative, the state maintains the program purpose was to address fraud. Some providers however, saw it is as an unnecessary barrier intended to withdraw support from communities deemed unworthy.”

“Furthermore, shortly after the program’s cancellation, the MDHS announced that all TANF workplace participants, who had previously been working in child care facilities across the state, would be removed and placed at ****alternative work sites because child care providers were not hiring them when they had completed six months of workplace job training. Many child care providers however, saw the move as direct retaliation for their resistance to the finger scanning initiative.”

The Committee will meet today to agree upon its final draft Advisory Memorandum, Thursday, November 19th at 2pm Central time. All Committee meetings are open to the public. If you wish to address the Committee directly you may join the call by dialing 888-505-4369 and providing the conference ID 4796911. A public comment period will be observed at the end of the meeting.

Melissa Wojnaroski, Civil Rights Analyst with the U.S. Commission on Civil Rights, Midwest Regional Office in Chicago, has announced it is possible that the U.S. Office of Civil Rights Enforcement will conduct further, more extensive investigations of potential Civil Rights violations following the submission of the Mississippi Committee’s work.


* ” Child-Care Rating Systems Earn Few Stars in Study” – Ed Week (click here); “QRIS Rating Systems Do Not Improve Learning or Social Development for Children” – Rand study (click here).

**According to the MLICCI, base reimbursement rates for providers through the CCDF program are already low— approximately 60 percent below Mississippi’s market rate. As such, many providers who depend on these funds cannot afford to make the necessary improvements to achieve higher rating.

*** The Xerox e-Childcare finger scan method of payment was proposed by Jill Dent who served at that time as the DECCD Director at MSDH.  Regardless of her highly contested proposal/policies/ideology being defeated in State Court, Jill Dent was appointed and now serves as Director of the Department of Education’s Pre-K Collaborative which requires QRIS participation among child care providers and costly maintenance of mid to upper tier quality scores.

**** Newly developed alternative TANF work sites (post State Court) include new placements in Head Start Programs (also licensed for child care) even though it is most likely that participating Head Start Programs CANNOT hire the TANF workplace participants as teacher-aides unless or until the TANF workplace participants complete 12 units of college coursework or CDA classes to meet Head Start employment requirements.    Adversely impacted child care providers (including those who formerly hired TANF workplace participants) note Head Start is not funded by the Child Care Development Fund and therefore, Head Start programs are now favored by MSDH because they were not involved in public opposition to the proposed Xerox e-Childcare finger scan method of payment.

 

 


MS Advisory Committee to the U.S. Commission on Civil Rights To Approve Final Report Thursday

The MS Advisory Committee to the U.S. Commission on Civil Rights will meet Thursday by telephone conference to discuss approval for publication of an advisory memorandum regarding federal child care subsidy distributions in the State, and potential disparate impact on the basis of race or color. (Click Here.)

Disparate impact discrimination demonstrates an adverse effect of a practice (such as Mississippi’s Quality Stars) or standard that is neutral and non-discriminatory in its intention but, nonetheless, disproportionately affects individuals having a disability or belonging to a particular group based on their age, ethnicity, race, or sex.

Title VII prohibits use of neutral tests or selection procedures that have the effect of disproportionately excluding persons from Programs participation.

The Committee will meet next for final discussion and approval of this memo on Thursday November 19th at 2pm Central time.  All Committee meetings are open to the public. If you wish to address the Committee directly you may join the call by dialing 888-505-4369 and providing the conference ID 4796911.  A public comment period will be observed at the end of the meeting.

 


Pleas Continue for Increased Phase I Funding of “Flawed” Pre-K Collaborative Plan!

 

Update:

There was no increased funding for the Early Learning Pre-K Collaborative.

This provides opportunity to address flaws in the process of collaboration as well as the economic impact (to child care) of braided Head Start/Child Care Development Fund money used to finance a single child enrolled in Early Head Start Programs which are moving into full day/full year operations.

Remember to thank legislators for this needed period of Program redress.

 

Pleas Continue for Increased Phase I Funding of “Flawed” Pre-K Collaborative Plan!

Monday, March 23, 2015, Bobby Harrison of the Daily Journal Jackson Bureau reported that in the budget bill for education that legislators sent to Gov. Phil Bryant last week, funding for the collaborative is not increased, remaining at $3 million.

He stated, however, various sources have said recently that additional funds for the pre-K collaborative could be placed in other budgets during the final days of the 2015 session.

“The budget is not done by any means,” said House Speaker Philip Gunn, R-Clinton. “The budget decisions are ongoing.”  (Read “Plans to raise pre-K funding stalled.”)


On December 17, 2014 10:19 AM, the Hechinger Report (Columbia University) published the following: “Why Did Mississippi Lose out on Preschool Funding — Again?” (To read in full, click on this link.)

Mississippi’s flawed application and underdeveloped plans to provide preschool for all children is partly to blame for why the state’s youngest learners were bypassed once again for federal funds that could have provided a boost to early education, a review found.

Last week, Mississippi was passed over for a preschool grant that would have tripled the number of children enrolled in early education classes in four years, increased the number of highly qualified preschool teachers and boosted salaries, according to the state’s application.

The state scored seventh out of nine applicants for a specific preschool development grant, and is one of the only states in the South to lose out.

Officials who reviewed Mississippi’s application noted many deficiencies, including vague statements and an overall lack of evidence and details. “If Mississippi wants federal funds for preschool, it must first develop the “necessary infrastructure and capacity for scaling up a sustainable preK program.”

Danny Spreitler, a member of the state’s Board of Education and executive director of a foundation focused on early childhood, said that before the state applies for more grants, it needs to improve collaboration between state agencies and preschool programs.

“I honestly don’t think this is the time for us to be out here trying to figure out money, until we get our ducks in a row,” he said. We need to take this next year, 2015, and rather than look at massive expansion, we’ve got to get more reliable data on the programs that are working and sit down … look at what’s working,” and then “figure out how to take it statewide.”


During the development of Mississippi’s “flawed application”, Mr. Spreitler said he feared the plan was written to squeeze out private child care centers in favor of Head Start and school districts. (Click here.)

The 2012 Harvard Law School Legislative Recommendations for Expanding Early Childhood Education in Mississippi affirmed Mississippi voters support a pre-k program so long as it sets high standards, includes private providers and preserves local control.

 


Mississippi Preschool Enrollment Top Ten in Nation!

 

Child Care helps to place Mississippi in the Top Ten!

Top Ten in the Nation! copy


Disparate Intent?

 


UPDATE:

The Education Appropriations Bill Passed. It will not go to Conference and the Early Learning Collaborative will not receive an increase in Phase I funding.

We will continue to work now to build an appropriation for the Child Care Development Fund in the next Legislative Session – 2016!

Disparate IntentClick here and scroll down to read comments of “education 1st”.

Click here to read about Arizona and Massachusetts Early Learning Funding.

Arizona Governor Jan Brewer proposed to provide $9.6 million in additional funding to address the growing need for child care assistance for children in CPS and to prevent 4,000 low-income children currently receiving child care assistance from losing it.

Massachusetts Governor Deval Patrick, in his FY 2014 budget, proposed to spend an additional $51.6 million for child care assistance to serve infants, toddlers, and preschool-age children who are currently on the waiting list. The governor also proposed to provide $30 million for a new initiative related to the state quality rating and improvement system that would support teacher training, professional development, and classroom grants; $13 million to increase reimbursement rates for providers serving children receiving child care assistance.


MDE Makes Quite a Stretch Promoting (In-House?) Pre-K!

MDE Makes Quite a Stretch Promoting (In-House?) Pre-K!

It was such a stretch, it took review of the entire interview to get her message which boiled down to this – chronic absenteeism in kindergarten should be countered with (In-House?) expansion of Pre-K (?)!

View the Clarion Ledger’s interview of Dr. Carey Wright during MDE’s Chronic Absenteeism Press Conference: Report: Chronic absenteeism a problem for Mississippi schools.

I do agree that chronic absenteeism places students behind their peers and behind in their studies. I do not personally know a teacher or educator who would not agree with that!

State Superintendent Carey Wright suggests some of the problem lies with the fact that kindergarten is only mandatory for students enrolled in public kindergarten classrooms.  She feels the importance of Kindergarten should be more elevated.

She states… other means to address issues surrounding chronic absenteeism would be to expand public school (In-House?) Pre-K classrooms.

Question:

Pre-K in Mississippi is not mandatory for any child.

If Dr. Wright believes kindergarten is not valued by parents in Mississippi, what makes her believe attendance in new Pre-K public school settings would be any different?

Mississippi has adopted the Early Learning Collaborative Act.

MDE and Mississippi First are pushing for an increase in Phase I funding from $3 million to $6 million.

MDE has been consulting with (inexperienced) Mississippi First for the implementation of the Early Learning Collaborative Act.  Keep in mind Mississippi First (Rachel Canter) defined quality improvement measures for children in child care as a tool to identify centers that are sub par.  (Dr. Wright’s home state of Maryland defined QRIS as a means to recognize child care providers and centers for their accomplishments – quite a different attitude and demonstration of goodwill and professionalism!)

Furthermore, in Ms. Canter’s recently released and incomplete State of Public Pre-K Report Book, child care data was not even included.

The Mississippi First plan for Pre-K expansion Dr. Wright is touting recently scored seventh place out of nine and failed to be funded in a national competitive grant process.   A quick review of the Preschool Development Grant application submitted by MDE reveals only one private child care provider was included in the application’s development .  This representative was Ms. Lynn Black of Tupelo.  She is the person who also stood with Jill Dent in a former MDHS news conference supporting a method of payment to provide low-income parents with less child care assistance.  In fact, the payment suggested was lower than its current lowest rates in the entire nation!   This resulted in less reimbursement to providers for their services.  (Click here to read “Both center owners and DHS agreed those savings would come from cutting payments to centers.)

Soon after, MDE (Carey Wright) named Jill Dent as Director of the state’s Pre-K Collaborative Program … against the recommendation of child care provider groups. (It is a known fact that tuition fees determine level of classroom quality. The higher the fees collected, the higher the level of quality. The lower the fees collected, the less likely that provider will be able to provide the quality required to participate in a Pre-k Collaborative.) Clearly MDE does not understand or even consider the needs of child care centers and the hard work they provide to help children every day.

Finally, Senator Bryce Wiggins proposed a bill (luckily it failed) to create an interagency council through which MDE could work apart from the guidance of the State Early Childhood Advisory Council and perhaps, outside a make-up including representation of private child care providers. (The PEW Center for the States advises all stakeholders must come to the same table for successful Pre-K Collaboration and that at a minimum, collaborations involve school districts sub-contracting with qualified private providers to deliver a pre-k program. “Publicly funded pre-k can pose a threat to the viability of private providers by siphoning off a significant proportion of their pre-k enrollment to public schools. K-12 leaders need to be sensitive to these concerns and  communicate that one purpose of collaboration is to protect and preserve the community-based early childhood system.”)

The adverse attitude (impact) for child care demonstrated by State Superintendent Carey Wright (Rachel Canter) and MDE (Mississippi First) is not a stretch! In fact, some are convinced it comes perilously close to Disparate Treatment.

With regard to days absent, child care providers serving low-income children in districts with 32% poverty rates must report three consecutive days’ absence to DECCD and make contact with parents for an explanation as to why the children have not been in attendance. Perhaps a stretch from chronic absenteeism to Pre-K expansion would not have seemed so much so had the State Superintendent noted this reporting requirement for public opportunities for Pre-K in child care settings!

On December 18, 2014, Education Week reported Gilmore Foundation Pre-K Collaborator/Program insider and then member of the State Board of Education, Danny Spreitler as saying:

I honestly don’t think this is the time for us to be out here trying to figure out money, until we get our ducks in a row. We need to take this next year, 2015, and rather than look at massive expansion, we’ve got to get more reliable data on the programs that are working.” (Click here to read Mississippi Loses Out On Federal Pre-k Grant.)

The Education Week Report has also ranked Mississippi as number 9th in the nation for 3 and 4-year-old children attending preschool.  It would benefit the children of Mississippi if Dr. Wright would acknowledge the strength of Mississippi Childcare Workers and look at cost-effective ways of helping provide more funding for those children instead of creating another grade of Pre-K in the public schools.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


2012 Harvard Law School Legislative Recommendations for Expanding Early Childhood Education in Mississippi

2012 Harvard Law School Legislative Recommendations for Expanding Early Childhood Education in Mississippi

At approximately the same time Rachel Canter of Mississippi First released her much touted 2012 Leaving Last in Line legislative brief, the Harvard Law School released other Legislative Recommendations for Expanding Early Childhood Education in Mississippi.

 It is important to note that in many families today, both must work outside of the home, and these families benefit from full-time (and extended day) early childhood services. Many pre-K programs today particularly collaborative approaches combine program elements focus on cognitive, social and emotional development and childcare, however, are critical to meeting the diverse needs of young children and working parents.

Mississippi voters support a pre-k program so long as it sets high standards, includes private providers and preserves local control.

West Virginia created a public school preschool program in 1983 and passed legislation in 2002 to expand the initiative to reach all four year olds by 2012.

While state funding goes directly to the public schools, half of these programs must contract to collaborate with private centers and Head Start in order to meet the needs of all the state’s preschool children.

Collaborative Pre-K approaches can actually promote family values and benefit stakeholders such as Head Start and private childcare providers.

On February 23, 2015, Rachel Canter released an update to her 2012 State of Public Pre-k, sponsored by the Kellogg Foundation.  Available child care data demonstrating public opportunity for pre-K instruction was not included in the report.