Shrinking the Number of Child Care Providers Down to a Level that May Be Supported by Inefficient CCDF Funding: It’s Economics!

Shrinking the Number of Child Care Providers Down to a Level that May Be Supported by Inefficient CCDF Funding:

It’s Economics!

HHS Market Correction and Government Failure

In economics, market failure is a situation in which the only way for my small business to be better off is for someone else’s business to become worse off.  (Click here.)

The existence of a market failure is often the reason governments may intervene to correct a particular market. ‘Economists are often concerned with the causes of market failure and possible means of correction. Analysis of market failure should play an important role in many types of public policy decisions and studies.

‘However, government policy interventions, such as taxes, subsidies, bailouts, wage and price controls, and regulations (including poorly implemented attempts to correct market failure), may also lead to an inefficient allocation of resources, sometimes called government failure.’

“Government failure occurs when the government intervention causes a more inefficient allocation of goods and resources than would occur without that intervention and when an agency performs inadequately, including when it fails to intervene or does not sufficiently intervene.” (Click here.)

Twice now, I have personally heard State Actors in Mississippi share their thoughts that there are too many licensed child care programs serving low-income children to support the CCDF assisted enrollment needed for each small business to be successful and included in the development of universal Pre-K.

One floated the merger of community-based private businesses while another suggested the Mississippi State Department of Health should just not issue any new child care licenses.

Of course, as was recently pointed out by one representing self-employed child care providers, that is nothing short of economic policy perspective favoring government intervention in the market process to correct the market or as he said, “fascism”.

“Fascism operated from a Social Darwinist view of human relations. The aim was to promote superior individuals and weed out the weak.” (Click here.)

The Propaganda Ministers of Systematic Underinvestment (Government Failure)

Almost two decades ago, the Child Care Development Fund was created as a work force support system to low-income parents transitioning from Welfare to Work.

Many well established, quality child care programs with long waiting lists that received full payment in advance did not have to discount fees or wait to be reimbursed in order to fill vacancies or provide the diversity of mixed socio-economic incomes.

Programs that were willing to participate could only do so in a very limited way due to the losses that would occur as a result of accepting below market rate child care assistance as well as the additional administrative burden of reporting to states for payment.

HHS researched a formula for setting rates that middle income providers would accept – 75% of Current Market Rates.

Even still, there were not enough slots available to absorb the large number of low-income children in sudden need of care.

With the full force of HHS and federal resources, MDHS went out seeking those who would operate child care facilities and be willing to serve low-income children and children of color.

Grants for facilities were made available and SBA loans were granted.

Licensing was assisted and the largely segregated low-income child-care-market was born!

Now, HHS has decided the government-child-care-market it created through the Child Care Development Fund over a period of two decades is no longer solely a work support system. It must be redesigned to demonstrate, and qualify (with degrees), and compare (equal) to Head Start and Title I Preschool programs without sufficient HHS monitoring for leveraged or equal per child stipends (parity) and without sufficient CCDF funding.

HHS has initiated a “market correction” for the redistribution of wealth (the CCDF)…no matter the consequence or social injustice (for the public interest and safety of the children).

HHS has allowed Mississippi to reimburse even Tier I low-income providers at 75% or less of 2004 market rates for over a decade and in spite of three increases in the minimum wage.

In fact, for many years, HHS has accepted many Plans from many states throughout the nation demonstrating inadequate reimbursement fees (falling far below HHS’s “scientifically proven” and recommended rates for providing low-income children access to “high quality” programs).

And when HHS finally did intervene, it diminished the possibility of ever providing “high quality” for child care programs serving large numbers of low-income children (which are so prominent in segregated Mississippi) by requiring states to increase per child reimbursement fees only up to a percentage of 2014 Market Rates as payment to providers in FY 2017-2019 (government failure).

In the recent “Pre-K Collaborative-early-learning -modelonlylobbying-campaign carried out by The Hechinger Report (through the absolute comedy of all white reporters interviewing all white policy makers on “the race issue”), Louise Davis, chair of the Early Years Network, who manages all of Mississippi’s CCDF quality funding, stated that the MOST CRITICAL problem with crippling reimbursements that obstruct quality in low-income child care settings is, “Most of these directors are in it for their heart. They don’t have a business background. These directors … don’t know how to do a budget.”  (Click here.)

The Public Interest

In their paper, “Is Market Failure a Sufficient Condition for Government Intervention?”, economists Art Carden and Steve Horwitz write, “…even when the market provides less than ideal outcomes, government actors will put in place policies that won’t necessarily produce a better market outcome, but may reflect their own priorities.” (Click here.)

Economist Robert Schenk writes, “…those who are involved in government have the same motivations that those in the private sector have; that is, they are motivated by a narrow concept of self-interest: wealth, fame, and power.”

“There is no guarantee that policies made by representatives pursuing their own interests will be in the interests of the society.”  (Click here.)

The U.S. Department of Health and Human Services “positioned a study” demonstrating the effects of a child’s physical environment on intellectual and social development.

This developed into a multi-million dollar “quality” industry that includes marketing of programs designed to rate child care centers according to the physical environment, the number of staff with college degrees, and reduced child/staff ratios. These programs are called Quality Rating and Improvement Systems.

In all this time of HHS endorsed “QRIS”, this is what we have learned:

In 1999, a comprehensive, longitudinal study by the RAND Corporation of Colorado’s QRIS program, one of the longest-running in the country, found Q.R.I.S. programs are expensive and complicated to administer, that state funding to sustain QRIS in the future may not be available, and worse, QRIS programs do not raise learning or social development outcomes for students. (Click here.)

Fourteen years later, QRIS proved no better!

In 2013, Education Week Reported “Child-Care Rating Systems Earn Few Stars” and said the tool falls short in predicting quality. Researchers, “who were from several universities, found that children attending highly rated pre-K programs did not have significantly better results in math, pre-reading, language, and social skills when they finished the programs, compared with the children attending lower-rated programs.” (Click here.)

Gail L. Zellman, the principal investigator on the Qualistar study for RAND, said:

 “The field has not sufficiently determined how to evaluate quality and how to assess it in a valid way.”

So, why the continued and heavy push for QRIS?

Perhaps government market correction in spite of government failure and an inefficient CCDF – without stimulus – requires the “excludability policy” QRIS provides.

Excludability

“Excludability deals with the ability of agents to control who uses their commodity, and for how long – and the related costs associated with doing so.” (Click here.)

“A public good is excludable if you can prevent somebody from using it.” (Click here.)

QRIS allows states to draft a tool that will be used to exclude child care programs in the “public interest” market correction for “improved” school readiness and social development.

In Mississippi’s Early Learning Collaborative Act of 2013, QRIS is the tool used for child care excludability.

In the RFP for stabilizing MDHS Slots Contracts, QRIS was the tool of excludability.

In the only opportunity to receive anything above a percentage of 2004 Market Rates in Mississippi in more than a decade, QRIS was/is the tool of excludability.

Re-write Mississippi Quality Stars if you want, but QRIS will still be the tool of excludability!

Add a “State Approved” curriculum if you like; QRIS will still be the tool of excludability!

QRIS, by design, redistributes the wealth to those programs more financially able to participate in costly (so-called) improvements in the first place, deepening class disparity and inequality.  (According to the MLICCI Step-Up  QRIS research, the average amount of “up-front” funding that it takes a center to move from a 1-star to a 2-star rating is approximately $40,000 per center.) See SECAC QRIS Executive Summary by clicking here.

It does not necessarily result in a socially desirable distribution of resources or the overall well-being of society.

For instance, MDHS is required, in the State Plan to raise reimbursement fees from 2004 Market Rates to 2014 Market Rates, increase quality funding, begin to monitor 1,200 hundred in-home providers who are not licensed, serve the same number of children (HHS doesn’t specify whether or not MDHS must maintain children in full-time care and part-time care), set re-determination for a true calendar year regardless of ongoing parental employment, and all is to be done with little or no new funding.

Such demand by HHS can only be met if child care programs are weeded out, and the wealth is redistributed, in some cases, in a way counterproductive to quality.

HHS “washes its’ hands” of the actual market correction applicability, the populations that are helped and harmed by its policies and potential disparate impact culpability through a little thing called “states’ flexibility” or the “State Plan”.

HHS stops just short of requiring QRIS as such, but it does require states to report how they will move more children into “high quality” care as defined by the state.

Class Disparity and Inequality

Nowhere is the class disparity and inequality brought on by HHS intervention (and often, the failure to intervene) better demonstrated than in The Hechinger Report’s article, “The Race Issue”:

“In visits to 30 child care centers in central Mississippi, reporters saw centers split along lines of race and class.”

“There is a direct link between how much parents can pay and how much a child care center can charge that, in turn, dictates the size of daycare budgets for salaries and supplies. Many centers serving low-income black children can’t offer the same resources as those that cater to middle- and upper-middle class white children, such as expensive playgrounds, highly educated teachers or lower-than-required staff-to-child ratios.”

“The reimbursement a family receives for child care tuition varies depending on a child’s age and family income, but assistance only covers a percentage of a center’s tuition. That means centers that serve low-income children often receive reimbursements that cover only a fraction of what it actually costs to run a daycare.” (Click here.)

Disparate Impact

There are other laws to be considered by HHS and government actors when adopting CCDF policy including the Small Business Administration Act, the Unfunded Mandates Act, Administrative Procedures Law, The Takings Clause, and the Title VII Civil Rights Act – all which may have been ignored at times. It is either that, or there has been too little uniform reporting gathered by HHS for it to truly determine if its policies governing low-income child care have resulted in socially desirable distribution of resources or if they have resulted in further class disparity and inequality.

Many argue HHS Policies are deepening the cycle of poverty for low-income working parents and the low-income child care industry that HHS seeks to correct – often which are minority owned and disadvantaged small businesses.

Under Title VII Civil Rights Act, disparate impact theory involves a claim that a facially neutral practice is being applied in a manner as to disadvantage members of a protected class.

December 1, 2015, (six months ago) the Mississippi Advisory Committee to the U.S. Commission on Civil Rights issued an Advisory Memorandum to the U.S. Commission on Civil Rights regarding the Committee’s months long investigation of the federal Child Care and Development Fund (CCDF) and related programs, and the potential for disparate impact on the basis of race or color as a result of the State’s discretionary administration of these funds. The investigation and subsequent Memorandum found that many eligible children, predominantly within the African-American community, were not serviced by the subsidy program and that funding that should have gone to support eligible children was redirected. (Click here.)

The investigation also found that the program rating system used in Mississippi to promote higher quality childcare limited the participation of African-American owned and operated childcare facilities.

The Mississippi Committee recommended the HHS Office of Child Care should conduct or commission a thorough study of the validity of the QRIS evaluation criteria as a predictive measure of improved developmental outcomes for children. This study should include a review of evaluation outcomes in diverse communities to ensure criteria are culturally relevant to diverse populations, and that they do not unduly disadvantage any particular protected class. (Click here.)

I know of no such HHS investigation that is now in the works – my point exactly!

In fact, the HHS Office of Child Care declined to participate in the Mississippi Committee’s panel discussions in the first place.

March 14, 2016, by majority vote, the United States Commission on Civil Rights (“Commission”), issued a letter recommending program changes to the Child Care Subsidies Distribution Program in the state of Mississippi within the purview of the Administration for Children and Families (ACF) and Health and Human Service (HHS). (Click here.)

Commission Chairman Martin R. Castro on behalf of a majority of the Commission stated, “When the most vulnerable and needy children are prevented from accessing urgently needed resources because of their race, color or other improper reasons, it is the role of this Commission and our State Advisory Committees to demand action and changes. To fail to heed these recommendations by our Mississippi State Advisory Committee will continue to doom a generation of children to living in the cycle of poverty—and that must not be allowed.”

The Commission stated:

“The Quality Rating and Improvement Systems (QRIS) program which is purported to promote higher quality child care appears to instead penalize and costs so much that it excludes the participation of African-American owned and operated child care facilities.”

During Mississippi Committee hearings, CLASP reported that Mississippi saw a decline of 53 percent in the number of low-income children served between 2006 and 2013.

Since 2013, the number of licensed child care programs overall has shrunk from 1,800 to 1,500 while the number of less costly, unlicensed in-home providers has increased (redistribution of wealth/child care on the cheap). Where is the “highly qualified teacher” in unlicensed, in-home care?

HHS mandates do not necessarily result in a socially desirable distribution of resources or the overall well-being of society.

Mississippi Quality Stars

In just over the decade that the Mississippi Early Childhood Institute has received millions and millions of dollars to serve as administrator of Mississippi’s Quality Stars, and many millions more have been awarded to provide technical assistance to improve “quality” in child care, Mississippi, at its’ most recent assessment reported (61%) were rated as 1 Star – the lowest level.

After ten years, less than 20% or 74 of only 383 programs participating (including those enrolled in CLASS.) were rated at the 3, 4- or 5-Star levels required to participate in Pre-K or be deemed “high quality”.

“Monica May, director of the QRIS program, said the program trains evaluators to be consistent. ” (Click here.)

“May said some complaints of racial bias in QRIS may stem from the way the quality rating system started out in the state.”

“In 2011, the state adopted a more comprehensive quality rating program, which also included efforts to help centers improve.”

Yet, in 2015, External Evaluation of QRIS Conducted by the Frank Porter-Graham Group revealed the following truths:

  • In a block structure, fewer than 20% of programs earned a Level 3 or 4; in the point and hybrid structures, more than 70% of programs achieved a Level 3 or 4. Block structures generally provide greater challenges to improvement in ratings. Mississippi continues with the block scoring system in spite of the known and growing popularity of the less stringent hybrid scoring system.
  • Nationally, the most common classroom observation reassessment period is every 3 years. Mississippi requires reassessment annually unless a program wants to maintain its current rating in which case it is every 2 years.
  • Mississippi’s Quality Stars system is the only system in the nation that requires providers to finance and maintain a parent resource center.
  • There is no due process for appealing a score.

Click here to review the evaluation and see pages 22-23 for low provider participation rates.

Seventy-five percent of Mississippi providers have rejected QRIS as a measure of quality.

MDHS has planned to continue with Quality Stars anyway without conducting a statewide quality needs assessment as required by HHS.

Rather, MDHS manipulated a survey presented only to parents of children enrolled in the few child care programs participating in QRIS.

In June, 2015, Mississippi appointed a Mississippi Quality Stars Re-write Committee.

I do not know who the members of that committee are. I am told it’s a secret.

Notice of their meetings is not posted on the web site or the Mississippi Public Meeting Transparency Website as required by Mississippi Code Section A 025-0041-0013. (Click here.)

I have also not been able to locate the committee’s minutes online.

Minutes must be recorded within 30 days and are a public record and must reflect the members present and absent; any votes taken; etc. (Click here.)

I have suggested that all the information be posted to the agency’s appropriate web page in order to practice transparency and inform stakeholders.

For now, it is either top secret and classified or requires that I travel to inspect the record and minutes at MDHS State Office.

Economics

The correct and effective use of available resources and economics is the study of how people deal with scarcity.

The State Early Childhood Advisory Council has been charged with the implementation of the 2017 – 2019 CCDF State Plan.

SECAC has appointed many committees and work groups to carry out this work.

Notice of some committee meetings has been posted on the SECAC Upcoming Meetings Page. (Click here.)

All SECAC Committee meetings and sub-committee meetings are also governed by the Mississippi Open Meetings Act and Mississippi Code Section A 025-0041-0013.

Therefore, self-employed child care providers and all who are personally vested (with commercial loans) or interested parties and stakeholders may be informed and attend as many meetings as they wish.

There are choices other than QRIS that may really improve quality.

They do not have to be embedded into QRIS to be successful.

If government actors insist only on embedding other quality initiatives into QRIS, then they are, in fact, insisting on retaining the “power of excludability” that may forever “evolve” to suit their funding priorities.

(If most severe exclusion has been done to us once, it can be done again.)

SECAC is looking now to develop a successful low-income child care early learning model.

Mississippi Building Blocks is such a model.

MBB improves the lives of children and it does not require QRIS.

We should not support or participate in ongoing, most stringent excludability policy and potential disparate impact.

Economics is a science of choice making and making the best choice among alternatives given inefficient CCDF funding and government failure.

If that cannot be accomplished without all/greatest harm to just one sector of Mississippi’s early learning system, then HHS and all government actors should be held to account.


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!

 

 


Clarion-Ledger – Early education programs, including Building Blocks took a beating…

Clarion-Ledger –  Early education programs, including Building Blocks took a beating…

Education policy had an interesting time of it this legislative session under the Republican supermajority’s leadership, leaving a legacy of charter school expansion, appointed superintendents and more school district consolidations.

Early education programs, including Building Blocks, took a beating, though funding for reading coaches and other resources for the third grade reading gate was kept at the same level as last year.

http://www.clarionledger.com/…/more-charter-schoo…/83299958/

More charters, fewer districts 2016 education legacy

Charter school expansion, appointed superintendents and district consolidations will be the legacy of the 2016 legislative session.

 

 

 


Legislators Should Fund Early Learning Success! Call Today!

Legislators Consider Early Learning Funding copy


How did The Hechinger Report Gain Information Contained in a Child Care Worker’s Personnel File for Publication?

How did The Hechinger Report  Gain Information Contained in a Child Care Worker's Personnel File for Publication?

Is this a preview of the touted (SB2274) Early Childhood Services Interagency Council “character” and does such conduct really validate increased funding for the Early Learning Collaborative?

Freedom of Information Act 

The Freedom Of Information Act intends to hold government accountable through transparency and gives the public an opportunity to monitor the functioning of their government.

The Hechinger Report and The Clarion-Ledger requested complaint and inspection reports for every licensed child care facility in District V, which spans a large part of Mississippi, including Jackson, Vicksburg and Yazoo City.

The Mississippi State Department of Health said it would cost $40 an hour to pay someone to pull the records, a fee that was reduced to roughly $20 per hour after The Hechinger Report filed a complaint with the Mississippi Ethics Commission.

Relevant public interest under the FOIA is “the citizens’ right to be informed about what their government is up to.”

Steering “High Quality” (QRIS) is Against the Interest Congress Intended in FOIA

On December 1-4, 2016, on the Facebook page of The Hechinger Report, reporters wrote:

“We want to hear from parents about their experiences finding safe, high quality places to leave their children…” (Click here.)

“Wanted to be sure that everyone knows we’ve got an inspection report from every child care center in the Mississippi Department of Health’s District Five (Claiborne, Cophia, Hinds, Madison, Rankin, Simpson, Sharkey-Issaquena, Warren and Yazoo counties.) Curious about how your center fared? We’re happy to share! Let us know what centers you’re interested in.”

FOIA Exemption 6: It is not enough that the information might aid the requester in lobbying efforts. Hypothetical public benefits cannot outweigh significant invasion of privacy.                                                     U.S. Department of Justice

A request for more information as to what was being released to the public yielded the following response from The Hechinger Report:

Nothing we have is confidential…We have copies of complaint reports that are marked substantiated or unsubstantiated but any reference of those complaints would say clearly if they were substantiated or unsubstantiated.”

Alleged Defamation

On January 31, 2016, The Hechinger Report and the Clarion-Ledger published “Mississippi child care in crisis: State’s weak oversight puts children in harm’s way”. It reveals investigations The Hechinger Report conducted at centers that may have been targeted based on the unsubstantiated complaints and identification of individuals disclosed and received in its FOIA request from the Mississippi State Department of Health.

In one case, although The Hechinger Report did not provide hospital records or lab results from the parent or anything that would hold up in a Court of Law verifying an infant had in fact been given juice or medicine that made him sick, it chastised the Mississippi State Department Health for insufficient investigation and/or for not substantiating that such an incident had indeed taken place.

The U.S. Supreme Court has ruled that such a statement on the part of The Hechinger Report may be defamatory.

The Scoop – “We Want Absolute Power!”

On February 1, 2016, The Hechinger Report teased the question, “Who should fix problems with Mississippi’s early childhood system?”

It went on to report, “The Department of Health has the most control — it’s the only agency that can open or close a center and impose fines — yet there are holes in its monitoring process, according to advocates and legislators.

That narrow approach limits how effectively the state can monitor centers, said Cathy Grace, co-director of the Graduate Center for the Study of Early Learning at the University of Mississippi.

Some lawmakers have suggested the Department of Education should take a larger role in regulating centers.”

On February 2, 2016, Hechinger tweeted: “A few legislators have prioritized child care in Mississippi including @Brice Wiggins.”

§ 25-61-11  Personnel Files Not Public Record

On February 7, 2016, The Hechinger Report and The Clarion-Ledger published “Turnover, low pay may undermine child care in state”. On the same day Hallmark premiered “Kitten Bowl III” in support of shelter and rescue adoption, The Hechinger Report revealed the work history portion of a personnel file as follows:

“On a Wednesday morning in June 2014, xxxxxxxx, director of xxxxxxx Center sat in her office as a parent accused a worker of grabbing her son’s neck. The worker had been hired five months earlier, with no experience in child care. Her background included 10 months as a vet assistant, two months as a sales associate at an art gallery and one month at an animal shelter where she “took care of the cats,” according to records from the Department of Health’s Division of Child Care Licensure.

The point was to demonstrate that the accused had no former experience as a caregiver, a violation of the Regulations, and The Hechinger Report could have just said that but then, that might not have been adequate to be highly offensive to a reasonable person.

Instead, it set work at the Humane Society/shelter apart in dramatic quotations as though this employment is unworthy and allegedly violated both the Privacy Act and Mississippi Code which prohibits disclosure and release of personnel records or any part of such record in the agency’s possession. (Click here.)

Child Care Small Business Discrimination

February 8, 2016, child care providers held a news conference at the Capitol to announce a Mississippi Committee finding to the U.S. Commission on Civil Rights of potential gender and race discrimination towards child care small businesses in Mississippi’s early learning system. The report listed recommendations to be considered that would improve quality for children in these environments without additional costs to this state!
 
Child Care Priority
Brice Wiggins did not attend.

 

Limiting the Pool of Talent!  Snubbing Most Stakeholders!

On February 9, 2016, Bill 2274, Education, was posted. The Bill seeks to establish full control of all financial resources and authority over all Programs for preschool aged children. It would eliminate the Governor’s State Early Childhood Advisory Council and with that, remove the following stakeholders from the early learning policy making table: child care providers from each Congressional District; Building Blocks, Excel by Five, The Center for Education Innovation, nSpark, Mississippi State Extension Service, and more.

 

LOL!
The Hechinger Report dutifully laid the groundwork for SB2274 and the one model takeover of all early learning (by the Pre-K Collaborative) last week espousing the following:
 “But many child care workers and advocates don’t trust the Department of Human Services. In 2012, the agency rolled out a controversial policy requiring all parents who receive child care assistance from the state to scan their fingerprints when picking up and dropping off children.”
 Is it possible that these investigative reporters do not know that the individual responsible for the large scale alienation of providers – through the purchase of the finger scanning payment system (designed to reduce the amount of child care assistance low-income parents received as a large savings to the agency) – Jill Dent, is now the Director of Early Childhood Education at MDE!  (Have I mentioned Rachel Canter?  Click here.) We would not trust our right to hold an operating license with MDE for sure!  LOL!

 

Stolen Joy!  Industry-Wide Demoralization! 
We might need “a home”, but feel the influence and interviews in the Hechinger series of articles and its very narrow collection of expertise, its report of a defunct opportunity (T.E.A.C.H.) and the touting of a twice failed plan (Race to the Top) have more than demonstrated the leadership child care providers would be subjected to under the proposed Early Childhood Services Interagency Council. We fear it might be as disproportionate and hateful as we believe the Hechinger Series to be thus far.

Adversity is the rule for child care and working families when law gives some state actors the upper hand, so we wisely prefer and support a balance of power. Technology and the State Early Childhood Advisory Council make that possible.

 

Sticking with SECAC!
Child care providers wish to have equal input at the policy making table at SECAC, the ONLY place where we have been welcomed.
We feel the research and work done through SECAC’s Blueprint for Early Education encompasses the genius, expertise, combined resources and sustainability necessary to affordably improve child outcomes in all Mississippi communities (benefitting all constituents) – not just a selected few. It is the least likely to cause controversy, the least likely to have a Disparate Impact and the least likely to supplant the embedded private child care industry. (Click here.)

So, we think we will keep our seats, and ask the Hechinger reporters to kindly have one.

Not Expendable!  Keep Mississippi Working

The private child care industry is Mississippi’s workforce support system and we congratulate Governor Bryant on the creation of 2,500 new jobs in Clinton!

 

The Legislature’s Oversight Agency –
PEER’s Objective Evaluation
The Joint Legislative Committee on Performance Evaluation and Expenditure Review of the Early Learning Collaborative (PEER: The Mississippi Legislature’s Oversight Agency) does not recommend increased funding or additional staff for the Pre-K Collaborative.
In an Executive Summary, PEER reports:
“MDE awarded funding to four collaboratives that utilized a prekindergarten curriculum found through rigorous research to have “no discernable effects” on student learning.
…after the first full year of implementation, prekindergarteners in the program’s participating collaboratives achieved the end-of-the-year target score on the Kindergarten Readiness Assessment less often than children enrolled in other public pre-kindergartens.”
I have just checked and you may check as well if you like – no desperate child care smear campaign has changed those findings.  (Click here.)
 
 
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MECA CONFERENCE FEBRUARY 20TH

MECA Flyer copyMECA Registration Form


Providers Overwhelmingly Reject MS QRIS. DECCD Continues. Who is in Charge?

Millions and Millions copy

Click here: QRIS Rating Systems Do Not Improve Learning or Social Development for Children

Click here: Child-Care Rating Systems Earn Few Stars in Study. Tool said to fall short in predicting quality.

Click here: “Evaluation of Mississippi Child Care Quality Stars Program” (Pages 35-36).


Ignorance or Arrogance? The DECCD 2016 CCDBG State Plan Work

2016 State Plan Work 2 copy

UPDATE: CENTRAL PLANNERS AWARD CCDBG FUNDING CONTRACTS WITHOUT CONDUCTING REQUIRED QUALITY NEEDS ASSESSMENT

The Early Years Network contract was awarded to a single agency who serves as the fiscal agent.  This agency works with other agency partners to provide high quality services.

Contract Awardee: Mississippi State Universtiy Extension Service
Contract Partners
(alphabetical order):
Mississippi Center for Education Innovation
Mississippi State University Early Childhood Institute
 NEW FUNDING Save the Children  (Head Start)
 NEW FUNDING University of Mississippi Center for Education Research and Evaluation
University of Southern Mississippi
Department of Child and Family Studies
Institute for Disability Studies

Visit: http://www.mdhs.state.ms.us/early-childhood-care-development/child-care-resources/quality-enhancement/the-early-years-network/  

FACT :

Since DECCD took the Certificate Program In-House, approximately 250 Licensed Child Care Facilities have gone out of business.  It has not yet been determined if a disproportionate number of those failed businesses were owned and operated by members of a protected class.  However, no or few Certificates funding newly enrolled children have been issued by DECCD this fiscal year which began Oct. 1, 2015, (citing lack of funding) so the number of failed businesses serving large numbers of low-income children is expected to rise due to the fact Low-income Providers have not been able to fill vacancies left when children began the new school year last August or aged out of the Program.

Webinar Questions and Answers:

http: //www.mdhs.ms.gov/media/318009/Webinar-1_Questions-and-Polls.pdf

Q: What document will be provided in advance as a basis for development? Anything other than the 2013 Plan?

A: DECCD will not release a draft of the State Plan until such time as the Office of Child Care releases a final version of the State Plan Preprint.

http://www.mdhs.ms.gov/media/318968/Webinar-3_comments.pdf

Question: Is it also the consideration of state policy makers to reduce the assistance such low-income families now receive in order to attempt to serve the same number of children while increasing grants for quality? If so, will you be providing an Economic Impact Statement?

DECCD Response: States have been required by the 2014 Reauthorization to make greater investments in quality activities and program oversight processes such as monitoring providers. At this time, the state’s allocation of funds has not increased. DECCD will make every effort to judiciously allocate limited resources in order to comply with federal regulations and to meet the needs of our clients.

Any future policy changes proposed by DECCD will be presented to the Attorney General’s Office for review. DECCD will follow the instructions provided by legal counsel regarding program performance and the requirement of any Economic Impact Statement.

 

 

 

 

 

 


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.

 

 


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.