When that failed, it was renamed QRIS (Quality Rating and Improvement System).
Because QRIS (Quality Rating and Improvement System) has been ineffective, today’s buzz is QSS (Quality Support System).
A well-deserved explanation for you – Early Learning Nation recently acknowledged the following:
While nobody opposes quality per se, the pandemic and the reckoning over racial equity have raised urgent new questions about QRIS. Are the criteria fair and equitable? Do the systems succeed in expanding transparency and accountability? Can the flaws be remedied? Or is it time to admit defeat?
According to Kelly Etter, Ph.D., vice president of Early Childhood Equity Initiatives with the Policy Equity Group, evidence is mounting that this supposedly evidence-based approach to the early education classroom experience is, at best, ineffective—andin many cases it may be racist and destructive.
Across the nation, some states heavily invested in QRIS are now attempting to salvage what they can of their financial investment in QRIS.
National consultants, perhaps heavily enmeshed in the big business of QRIS, are being hired to guide states through a process of “rebuilding” QRIS.
To better understand the process many states are engaging in, see four short videos in a series titled, “Knocking it Down and Rebuilding QRIS”. (Click here to view.)
Today in Mississippi, through town hall meetings and surveys, non-profits, advocates, policy makers and stakeholders are now asking you what you think a single Quality Support System for all early learning programs should look like.
While you may see positive steps taken to address equity and a fairer, more just method of observation and evaluation (the awarding of stars, levels, badges, etc.) than in previous versions of QRIS, there is little or no discussion in this process regarding the serious concerns for equality in funding streams that make sustained and equitable achievements possible.
We already know firsthand that addressing CCDF policies will bring about more stability in CCPP funding and strengthen child care programs and therefore, should be part of any agenda for CCPP providers when giving suggestions for “one quality system for all”.
We saw immediate improvements in learning environments through national and state recommendations to provide a higher rate of fees, to waive parental co-pay, to reimburse full payment for full time enrollment and more at the start of the pandemic.
National and state policy makers, advocates, and stakeholders quickly defined exactly what policies were needed to make child care viable and capable of working successfully early on in the crisis.
They knew what was needed then… and they know now!
Child care is still healing – we are not out of the woods yet. With elementary schools and Head Start once again holding in person classes, child care is working hard to rebuild enrollment (our funding stream).
Given the recent national consensus of underfunded child care at the basis of Build Back Better, I feel a comprehensive approach which includes funding policy and funding disparities discussionsshould be in the scope of development of every single quality measure recommendation for all early learning programs going forward. (The underfunded question of child care and high-quality is not resolved – Build Back Better failed.)
High quality child care is expensive. It has been said the business of child care is not a dilemma, but a trilemma — between cost to centers, student access and teacher compensation.
I have oftenheard that child care providers just need business advisors and shared purchase power – good suggestions and helpful – but not even close when resolving to redress the huge disparities among funding streams expected to equally fund and sustain the same stringent requirements set forth in the ITERS and ECERS scoring scale for high-quality programs.
Is fair and effective change even possible for all programs in this environment?
Can QRIS really be “fixed” in a piecemeal fashion?
What do you want your program to look like in a single Quality Support System post-pandemic?
How do you want your program and business investment to be “marketed” to parents and the public at large through a single Quality Support System? (Positive marketing is how we secure our funding stream.)
What will be required for a CCPP program to be successful among all early learning programsregardless of inadequate or unstable funding that wasn’t addressed in well over a decade ofdismal quality initiatives in Mississippi?
If stakeholders, advocates, early learning professionals and ideologists driving a single preference in the development of a quality initiative for all programs get it wrong again, who has the most to lose personally?
Who will suffer the greatest stigma and harm? Mississippi’s workforce support system? CCPP providers?
Are quality options available that may be valid, less costly for successful provider participation than previous Mississippi models and more favorable to child outcomes? (MDE Early Childhood Education is offering training in the CLASS assessment tool.)
As decisions for quality are being made, it is necessary for us – the business community – to have invited and thorough conversation with our funding partner – MDHS.
The good news: I do not believe it is in the best interest of MDHS or workforce development to adopt potentially disparate, high risk, or destructive (underfunded and punitive) accountability measures for its own CCPP program.
If we succeed in “high-quality” and good child outcomes, then MDHS succeeds!
So, join me and other small business and CCPP providers at the MDHS town hall on August 30, 2022, from 6PM to 8PM, 114A Second Street in Indianola. (Click here for more info.)
Hurry there, y’all!
We are running out of acronyms for “quality” initiatives!
“IT’S JUST EGREGIOUS…IT’S IMMORAL FOR US TO STAND HERE…TO SEE PEOPLE STEAL MONEY LIKE THAT!”
Oleta Fitzgerald, Children’s Defense Fund
The Children’s Defense Fund, the NAACP, the Southern Poverty Law Center and other non-profits held a press conference yesterday to say to Flowood Real Estate Broker, Senator Josh Harkins, and others supporting bills in the legislature that would require the State Auditor to audit the tax returns of Mississippians receiving TANF, SNAP and Medicaid benefits that they are scrutinizing the wrong “TANF beneficiaries”considering the ongoing embezzlement scandalof former MDHS Head John Davis, Nancy New and more!
Rather than withdraw his bill, Senator Harkins responded that if the state does not audit benefits, the state could loose the funding.
It is being suggested that if federal monitors do remove Mississippi from the direct administration of TANF/CCDF funds (a growing number now support legal action for a Court-ordered Conservator) it will be as a result of the alleged, ongoing misconduct and abuse of power in the implementation of federal block grants by those appointed to lead MDHS.
Reports have also surfaced alleging that, unknown to most, Medicaid is already interfaced with the IRS and has already “audited” the tax return of at least one low-income parent receiving benefits. In fact, says the mother, the income tax return was just “pulled” and used initially to determine eligibility.
Likewise, MDHS is now interfaced with many other agencies – all responsible for tracking and targeting recipients of benefits for the purpose of flagging fraud/program error.
I Do Not Know Why the DHS General Counsel is Collecting Child Care Fees
I do not know why DHS General Counsel Andrea Sanders initiated a new and expanded database to collect financial data/child care fees or how the information will be used.
I do know the purpose of A.P.L. (Administrative Procedures Law)
is to let you know what your government is up to!
Below is the Administrative Procedures Law and guidance for policy makers developing a new or expanded database which is applicable to all entities receiving CCDF funding including NSPARC and the Standard application:
Any organization proposing to establisha new system of records, or to enlarge an existing system, shall give public noticelong enough in advance of the initiation or enlargement of the system to assure individuals who may be affected by its operation a reasonable opportunity to comment.
(i)The reasons the information is planned to be and/or has been collected;
(ii) The way such informationis planned to be and/or has been used to further the proper performance of the functions of the agency;
(iii) An estimate, to the extent practicable, of the average burden of the collection (together with a request that the public direct to the agencyany comments concerning the accuracy of this burden estimate and any suggestions for reducing this burden);
(iv)Whether responses to thecollection of informationare voluntary, required to obtain or retain a benefit (citing authority), or mandatory (citing authority);
ROUTINE USE: Allows for the disclosure of a record outside of the agency without consent. Disclosure or use must be for a purpose which is compatible with the purpose for which the information was collected. (I don’t advertise rates – never have!)
Administrative Procedures Law also requires the following with regard to the Standardapplication:
§552. Public information; agency rules, opinions, orders, records, and proceedings
(C) rules of procedure, descriptionsof forms available or the places at whichforms may be obtained, and instructions as to the scope and contents of all papers, reports, or examinations;
(D) substantive rules of general applicability adopted as authorized by law, and statements of general policy or interpretations of general applicability formulatedand adopted by the agency; and
(E) each amendment, revision, or repeal of the foregoing.
Child care market rates are one rule established by DHS for reimbursement of services according to the age of the child. For example, an infant is assigned a higher rate of reimbursement than a full time child age two.
A substantive rule of general applicability is a separate rule that interprets how the market rate will be computed and paid to the CCPP provider. For example, up to August 1, 2019, a reimbursement rate was set as a constant for the whole of a Certification Period. Prescribed age adjustments were not made until rollover or the next, new period of Certification.
Now, DHS General Counsel Andrea Sanders has reformulated the general applicability of the rule to reduce the reimbursement rates each month throughout the active Certification period following a child’s birthday – the reimbursement rate is no longer set as a constant and naturally, less reimbursement will be paid each month.
The rates remain the same and therefore, do not require any further action.
It is the new way the rates will be computed and applied that have changed – a separate act –the new formulation of general applicability – that triggers required APL and an economic impact statement. (See §552. (D) above.)
Mrs. Sanders did not follow the required APL.
She just put it into effect August 1, 2019, by simply authorizing a change in computer programming and then she casually announced it in a memo dated July 26, 2019.
It is a frightening agency practice to witness!
It is reminiscent of the same state actor advantage, arrogance and environment demonstrated through the attempted finger-scanning method of payment…announced to us in a letter from Xerox requesting our private banking information and access to our accounts!
I only have confidence in the proper applications of Administrative Procedures Law.
A Child Care Rally is being scheduled for later this month.
Dear Pre-School Collaborators, WHY ARE YOU ASKING FOR OUR INPUT NOW? A SURVEY ONLY?
Child Care Providers are now being asked to complete a survey for a SCORE BOARD (scoring our efforts in addition to the ETERNALLY AND EVER EVOLVING RULES OF the SECAC advisory only council) that some geniuses “thunked up” without our input.
Embattled: Meaningful HHS/State Court oversight is overdue.
Another round of required Standard application submissions was announced for embattled, low-income, CCPP child care providers and is underway for those who have not yet received Standard Center designation.
After submission, the applications are scored in some way by someone to serve as the basis to determine if a provider may continue to redeem funding vouchers and participate in Mississippi’s CCDF beginning October 1, 2019.
The rating processes, type-specific evaluation scales and points needed to achieve and maintain the required Standard Center designation, however, have still not been identified, disclosed, defined or adopted 32 (thirty-two) months in from Program launch.
A BLANK Monopoly game board – without the pieces and without the Community Chest rules.
It is like being required to play a game of Monopoly on a BLANK game board…only lost child care provider properties will not be the imaginary Park Place or Vermont Avenue on a game board. They will be real and hard felt bankruptcies for all low-income child care providers whose applications fail to measure up – even over time – according to SECAC’s rules – the small business losses of which were never mentioned in the Economic Impact Study DHS General Counsel Andrea Sanders publicly stated was not required in the first place!
In this make-believe Kingdom of Contempt for CCDF Service Providers, no one dare to challenge the King or it’s “Off with their heads!”
But in Monopoly, it’s just called cheating!
Therefore, we have asked to meet with the CCDFBG Federal Monitor Eric Blanchette and are waiting for his response.
In the meantime, those who have allegedly been told that they have missed the deadline to qualify as a Standard Center who are trying to contact me, you may private message me on Facebook or send me an Email at: licensedprovider@AOL.com
Remember, you only have about five weeks remaining to prevent debarment, which will be much easier than reversing debarment.
Following the CDNA Conference Call, I still cannot identify one CCPP Provider who actually receivesCertificates who has been contacted by DECCD Director Kristie McHale for the needed CCPP provider expertise or input in the delivery of child care services in Mississippi and the administration of the Child Care Development Fund “McMoney”
In addition to her recent memo just up and announcing disruptive reductions in child care fees as children age or experience birthdays each month in spite of fixed preschool budgets, DECCD Director Kristie McHale has now released a proposed Child Care Payment Policies “McManual” that has many providers asking, “What the McHale?”!
However, CCPP providers on the conference call reported that they have found that statement not to be true!
On page 40, a significant change exists that requires all children in the household to have an open case of child support regardless of whether or not services are being requested for that child!
One provider explained that child support payments are counted in the family’s income and therefore, requiring child support for all children will best result in Kristie McHale’s apparent desired outcome of serving fewer children by making them ineligible and/or imposing a higher co-pay on the working poor – a new undue burden not required by the Child Care Development Fund Block Grant!
7. Proof of Child Support Cooperation (parent, if applicable) – All single, unmarried, or divorced parents must be in cooperation status with the Mississippi Division of Child Support Enforcement (CSE) requirements, in order to be eligible for child care assistance. Parents must be in cooperation status for all children listed in the household.
For years, MLICCI has advocated for the requirement of child support to be eliminated from CCDF eligibility requirements and yet, the requirement under this leadership is now more restrictive and burdensome than ever before!
Finally, regarding the recent memo announcing that children turning age five by September 1 will now automatically be placed in full time/part time status (Afterschool Care/Summer Care), I believe that was a careless mistake.
I rather believe Kristie McHale did not realize that that particular wording, “full time/part time” as presented on the Child Care Certificate means Afterschool Care/Summer Care.
I think and hope she thought that particular language meant either full time care or Part time care (Afterschool Care/Summer Care).
Regardless, there has been no retraction or correction provided on this matter even though it has been pointed out to policymakers that Mississippi law allows children age five to remain in our full time instruction if parents so choose to do so.
I don’t know if Kristie McHale has ever reviewed an actual Child Care Certificate – frankly, I think this concern speaks to questionable experience and qualificationsto hold the positionof DECCD Director.
Such state actor irresponsible entitlement, deceit and abuse of power in the implementation of this CCDF State Plan should not be trusted.
It must be strongly challenged!
Prevalent bullying and open hostility for low-income providers and the personal ambition and agenda of those governing SECAC can only thrive when Administrative Procedures Law, Civil Rights Law and the Privacy Act is broken and we take no real action.
“Truth isn’t truth”- the Final CCDF Public Hearing!
Just when we begin to trust that new, high-ranking appointments at MDHS are at least trying to adhere to the fair and lawful treatment of much abused low-income child care providers, here comes Jacob Black!
As self-important policy makers use the power of position to move this kerfuffle that is “the SECAC Plan” one step closer to “legitimacy”,“unworthy low-income child care providers” are still anxiously waiting to receive full approval of the Standard Application they were required to complete eight months ago in order to continue to do business in this state!
While it may seem a minor fix to Mr. Black, it was not minor to the President of the state-wide organization, CDNA’s Deloris Suel who shared comments that although she was fully approved months ago, she received a call last week from NSPARC, representing itself at MDHS, saying that although she had been fully approved, they had concerns and felt she needed technical assistance. (Mrs. Suel uses the Frog Street Curriculum and her staff completed certified training in that Program’s alignment of Early Learning Guidelines with Jackson Public Schools.)
HOW WOULD NSPARC KNOW WHO NEEDS TECHNICALASSISTANCE?
NSPARC has no prior experience in early learning and licensed child care and may have been the least qualified agency in this entire state to lead the CCDF.
NSPARC’s forte is data collections and data mining. Perhaps then, it’s time would best be spent reviewing Privacy Law and the collection of Social Security Numbers and personally identifiable information without the statutory authority to collect it and the proper disclosure of each routine use its new system of records contains…including the categories of users and other like things a data company is just expected to know and follow.
HOW WOULD MDHS COUNTY DIRECTORS AND ELIGIBILITY WORKERS KNOW WHO NEEDS TECHNICAL ASSISTANCE?
TRUTH – the categories of users assigned to determine if your Standard Application was or was not fully approved were MDHS County Directors and MDHS Eligibility Workers – the individuals whodetermine if you are eligible for economic assistance and NOT curriculum or early learning specialists.
Now, these individuals had to receive some kind of training from someone in order to even begin such determinations.
When I requested that I be provided that very same training in order to review my own work (the highest form of evaluation is self-evaluation), Mr. Black took center stage to explain that “curriculum” was not a factor in determining whether or not a provider was approved.
TRUTH ISN’T TRUTH!
TRUTH – no one can fail the Standard Application – you just may not be fully approved and if you are not fully approved, you will not be able to serve low-income children going forward.
Providers succinctly refer to the effective result of the MDHS review as “passed or failed”.
Following exposure, MDHS County Directors and eligibility workers are no longer reviewing Standard Applications for approval. However, no one has disclosed who is doing that now and what their credentials are.
ALL HANDS ON DECK REQUIRED!
Jacob Black began his window dressing of the Standard Application saying MDHS is going to provide the technical assistance needed to fully approve all.
Tell that to the hundreds of providers who are suffering great angst, stress and worry at this very moment as they wait, eight months in, for very limited technical assistance necessary to full approval!
He notes that Mississippi Building Blocks, the former employer of the SECAC Executive Director who has guided this CCDF State Plan, has been added to the Child Care Academies to make technical assistance readily available.
I advise Mr. Black that when Q.R.I.S. was voluntary and not required, as it is in this plan, the Early Years Network and Mississippi Building Blocks combined could not service every facility!
This required Q.R.I.S. will require all hands on deck. It will need every true, recognizable and experienced early learning professional throughout the state! The Child Care Academy should also bring in Dr. Cathy Grace at Ole Miss, Dr. Louise Davis of Mississippi State Extension Family and Consumer Sciences, J.S.U., Alcorn, and more!
If Q.R.I.S. and National Standards are to be required for all by NSPARC, there are more qualified professionals who can bringgreater expertise and experience to the table. To exclude that talent and to monopolize all TA is to diminish customer service and the respect (if any) shown to providers and limits the spirit of excellence, diversity, creativity, and most unfortunately, the competitive advantage that allows initiatives to strive to set the work of their organizations apart from the rest.
In light of required Q.R.I.S., it is no longer clear to me why the EYN should have ever been removed from CCDF participation in the first place.
Waiting eight months or longer for technical assistance is not even close enough for government work!
RACE TO THE TOP WAS NOT BUYING IT!
I would refer Mr. Black to former Race to the Top Early Learning Challenge comments where Mississippi plans, including this one, were not highly rated nationally or selected for funding due to failure to demonstrate the plans as sustainable.
That is why an economic impact statement is critical to andrequired of this process before going any further.
I certainly hope MDHS is not counting on the President’s “jobs growth CCDF funding” – short-term money over two years – to embed behemoth long-term goals and costs.
Even under Mr. Black’s watch, the defunding of the CCDF Certificate Program, for the fifth consecutive year, and the extreme vetting of low-income parents during redetermination terminating approximately 10,000 children demonstrated what I believe was a desperate attempt to build this new bureaucracy (Cabinet or agency) and fund all the new state appointments this plan will require (priorto Congress’ recent act to double CCDF discretionary spending).
It was not and would not be conducive to this State’s economy and job’s growth to revert back to such hostile and improper funding decisions…ever!
DEVOTED TO CHILDREN
Mr. Black began his explaining of the Standard Application debacle by “taking center stage” and proclaiming his passion for children.
While I have no doubt as to his sincerity, I would note that Mr. Black is an attorney. His forte is the law. All due respect, but perhaps, given that he is a member of the Mississippi Bar, he should devote most of his time in lawyering and advising the legal requirements of all the components making up the CCDF Final State Plan.
I would suggest that he begin with review of the following:
Administrative Procedure Act
UNITED STATES CODE § 552a – Any organization proposing to establish a new system of records, or to enlarge an existing system,shall give public notice long enough in advance of the initiation or enlargement of the system to assureindividuals who may be affected by its operation a reasonable opportunity to comment (i.e., NSPARC’S Standard Application Data Set).
Administrative Procedure Act
UNITED STATES CODE § 552 – To the extent feasible, each rule should be written in clear and concise language understandable to persons who may be affected by it and each agency shall make a reasonable effort to make known to persons who may be affected when a rule becomes effective before any date established by subsection.
Administrative Procedure Act
MISSISSIPPI § 25-43-3.105. Economic impact statement, requirement and conditions.
Each agency proposing the adoption of a rule or significant 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. The economic impact statement shall include the following: An analysis of the impact of the proposed rule on small businesses; A determination of whether less costly methods or less intrusive methods exist for achieving the purpose of the proposed rule where reasonable alternative methods existwhich are not precluded by law.
Mr. Black, it is also your duty to make certain that the rights of persons dealing with the agency are not substantially impaired!
Please let us know when you have developed the rules and the requirements of Standard and Comprehensive facilities.
We Were Right to Pursue Legal Action in Suel v. MDHS and Xerox e-Childcare™.
Paying for child care services by the hour and minute, as Xerox e-Childcare™ was designed to do, is now prohibited by the Child Care Development Fund Block Grant!
This is not the first time over the last eight years policymakers at the highest level (SECAC members) proposed CCPP child care providers receive less than2003 market rate fees for child care services rendered.
In 2012, on such alleged recommendations, MDHS entered into a $10,000,000 contract with the Xerox Corporation to install and implement biometric finger-scanning machines designed to track the time and attendance of a child, down to fifteen minute increments, for reimbursement in child care fees that would pay less than the expected full-time fees for full-time slots industry standard and thus, generate ”savings” for the State. (Click here to read ”Separation of Corporation and State”.)
Child care providers filed and won a law suit for restraint of the implementation of the payment system due to the State’s failure to provide a proper Economic Impact Statement. (Click here to read ”Final Ruling – No e-Childcare”.)
In the 2014 Child Care Development Fund Block Grant Reauthorization,Congress actually prohibited the same such squeezed child care payments to child care service providers at §98.45 – Equal access:
(a) The Lead Agency shall certify that the payment rates for the provision of child care services under this part are sufficient to ensure equal access, for eligible families in the area served by the Lead Agency, to child care servicescomparable to those provided to families not eligible to receive CCDF assistance or child care assistance under any other Federal, State, or tribal programs (meaning comparable to programs serving middle and upper income families).
(l) The Lead Agency shall demonstrate in the Plan that it has established payment practices applicable to all CCDF child care providers that:
(2) To the extent practicable, support the fixed costs of providing child care services by delinking provider payments from a child’s occasional absences by:
(i) Paying based on a child’s enrollment rather than attendance;
(ii) Providing full payment if a child attends at least 85 percent of the authorized time;
(iii) Providing full payment if a child is absent for five or fewer days in a month;
As you can conclude, Mississippi has just not supported or implemented much of the guidance given in the Block Grant or other law including APL and Privacy Law.
In fact, this past March, NSPARC even recommended less than 2003 Market Rates for after-school care!
NSPARC has also – in violation of Administrative Procedures Law – designed and embedded MOST COSTLY National NAEYC standards and self-measurements into the standard application process for child care providers wishing to continue to serve low-income children all the while it (NSPARC) has been holding up the implementation of increased reimbursements that providers need to meet national standards of quality by failing to post NSPARC’s findings and recommendations for market rate increases on the Internet within 30 days of its completion of data collection in September, 2016, … as required.
As many providers have said, ”It looks as though they intend to hurt us.”
And what is to be said of the oversight provided by Region IV ACF/HHS that had previously expressed great concern that the initial rates increases proposed by MDHS in 2015 would not support quality?
Last week, MDHS announced that rates for afterschool care will indeed increase from the current fees set in 2003.
MDHS has not announced just what the increase will be.
It is now in effect and will be reflected in the June 15, 2018 reimbursement check.
The $10,000,000 paid, or perhaps not paid, to the Xerox Corporation has never been disclosed.
Xerox e-Childcare™ biometric machines are still in boxes, collecting dust, in child care facilities throughout the state!
No effort was made in such cases to return equipment and seek a refund.
Perhaps, we did, however, stop any further waste of long-term investments in a program that is now obsolete!
We do not know what NSPARC has been paid or how it has been paid for its CCDF services – another violation of the block grant/state plan.
There is so much more to be addressed!
Stay in touch with your legislators.
Always remember, we were right to pursue legal action in Suel v. MDHS and Xerox e-Childcare™!
How Does Failure to Increase Rates Taken in 2015 Make a 2018 Market Rates Survey a Moot Point or Bring Another Threat of Delay in Any Increase?
Once again, MDHS has delayed implementation of the 2016 Market Rates increase…with less than five months remaining in this triennium … with yet, another threat.
The first threat was to take less than 2003 market rates for afterschool care or… receive further delay in any needed rates increase implementation by MDHS!
This threat is for us to take recommended increasesbased on 2015 ratesnext month and throughout the next triennium, or face still further delay in the implementation of any increase!
This is the usual MDHS approach!
In Fact, I would even say the MDHS Email explanation to us all yesterday was mendacious!
Otherwise, there would be no endeavor to pass increases, based on 2015 collected rates, as appropriate to fulfill the block grant requirements and MDHS duty to complete a new market rate survey for the upcoming 2019 -2021 triennium based on current 2018 rates!
The truth is, MDHS is and has been under obligation to both implement the rates outlined in the very delinquent 2016 Market Rate Report (after consideration of public comment) and to ALSO conduct a current 2018 Market Rates Survey in order to further amend rates meeting costs of operation as needed going forward.
Ms. Sanders, if you have a waiver from Mr. Blanchette or Region IV ACF/HHS to usurp the 2019 – 2021 triennium market rates study and recommendations with very poorly conducted 2016 – 2018 triennium market rates increases that should have been in place two years ago, please do share that with us as well!
Otherwise, stop the shameful threats and put this needed funding into still crumbling child care infrastructure TODAY!
Plan to consider 2018 amendments as needed!
We have no intention of rewarding alleged MDHS failure or such a hostile approach to leadership!
We have no intention of living with the same hostile MDHS leadership style that has been so harmful and adverse to the people of Mississippi.
APL – rules must be understandable to persons who may be affected
THE REDETERMINATION PROCESS
The apparent Tools of Exclusion and the SECAC child care market correction in this time of limited CCDF funding appear to be coming to light as the CCPP application processes.
Many of you have received the controversial CCPP Standard Provider Application that is more than 40 pages printed and filled with much more required subservience of independent businesses and drudgery than child outcomes…which will not even be measured or formally assessed in standard centers.
I have been informed that a working parent of three who provided more than ample confirmation of eligibility was terminated because she supposedly did not update her current address.
Although I was asked to assist her in the redetermination process, I was not aware of all the redetermination documentation required and what needed to be updated or submitted other than for check stubs because she did not complete the application in my presence and DHS did not provide the application in the proposal to amend the rules.
The list of required supplemental material or definition of “fully comply” was not made available for public inspection prior to the recent 2016 CCPP adoption (that is still not available on the MDHS website).
APL requires that, to the extent feasible, each rule should be written in clear and concise language understandable to persons who may be affected by it and each agency shall make a reasonable effort to make known to persons who may be affected when a rule becomes effective before any date established by subsection. (An orientation on this process most impacting parents and small businesses or “touted TA” would have beenappropriate with regard to this specific change in agency practice.)
Failure to make clear that I would not receive Notice of Termination until it was just too late to prevent an interruption of services is why I raised no objection to its adoption at the 2016 public hearing.
It is my experience that a request – sent with my client’s faxed payroll stubs – for notice of anything further that needed to be done was sent, but that fax was temporarily “lost” at DHS and therefore, no hint of a problem resulting in termination for this client was given.
Please be informed, it is my experience that the parent only will receive 60 days’ notice of the period of redetermination and will be directed to a new online redetermination application requiring internet access and thus, perhaps even transportation to a public library.
It has also been my experience that the parent and provider will both receive 30 days’ notice prior to the deadline for all required supplemental material but providers will not be aware of needed updates in online redeterminations unless providers make contact with the DHS case worker or have the parent to call or allow providers to review the online application submitted.
Even then, providers may not know or recognize that a change of address is needed, particularly when the parent feels he/she has indeed fully complied.
It has been my experience that unless you are fortunate enough to reach your case worker when telephone calls are being received at DHS, you may not realize that there is an issue until it is too late.
Rather than receiving Notice of Termination two weeks prior to the parent’s deadline that must be met in order for his/her children to receive continued funding – as we were guaranteed to receive in the past and as we trusted and believed would be the agency practice to continue – it has been my experience that DHS is NOT providing Notice of Termination until after the stated deadline…when it is too late for me to help to prevent an interruption in services for the underprivileged families I serve.
Even then, I did not know the parent’s specific failure to “fully comply” until the DHS case worker was finally reached.
DHS will now spend two weeks more limited funding to this “non-compliant and unworthy family”…and I suppose others who may be truly unconfirmed… through a notice that was not aligned with the redetermination deadline.
I have said before that I feel that is just ridiculous fiduciary management – Mississippi doesn’t have money to throw away on those truly not qualifying when two weeks notice can be aligned with two weeks prior to the parent’s given redetermination deadline! Such alignment would solve all!
But I guess it is a small price to pay if the true intent is to create a barrier to twelve months of uninterrupted services.
(Well, the harsh reality is, DHS does not exclude or terminate SNAP and other benefits in this way. Not at all!)
What do you think?
You can make written comments on this practice and other proposed rules presented by SECAC on its website. Click here to review the Manuel and Click here to Email comments.
IN THE MEANTIME, QUALIFYING PARENTS WHO HAVE BEEN EXCLUDED FROM UNINTERRUPTED CHILD CARE SERVICES MAY REQUEST AN ADMINISTRATIVE HEARING.
CALL YOUR CASE WORKER FROM THE TIME YOU RECEIVE 30 DAY’S NOTICE FOR CLIENTS!
KEEP GOOD NOTES!
APL – rules proposed by state actors are required to be completely understandable to persons who may be affected in order to protect the public.
The impact and implementation of rules are not supposed to be a life-changing, devastating and unexpected “gotcha”!
Promoting business-friendly public policies that support parental employment with quality early learning opportunities for the Delta's childcare-age population.
understandable to persons who may be affected
Delta Licensed Providers 
Recent Comments