A Proper Economic Impact Statement Should be Required. To Act Otherwise is Irresponsible.

Posted: March 19, 2019 | Author: | Filed under: "Race to the Top", Administration for Children and Families, CCPP-approved Provider, Child Care Advisory Council, Child Care Development Fund, Child Care Licensing, Child Care Mississippi, DECCD-MDHS, Early Learning Guidelines (ELG), HHS ACF Office of Child Care, Mississippi Building Blocks, Mississippi Health Department, Mississippi State University, MS Department of Health, MS Department of Human Services, NAEYC, NSparc, QRS Mississippi, Quality Rating System, School Readiness Mississippi, SECAC, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: , , , , , , , , , , , , , , , , | 1 Comment

A Proper Economic Impact Statement Should be Required. To Act Otherwise is Irresponsible.                                   

“Whenever I walk in a room, everyone ignores me.”

(Click here.)  See page 15 of 23 of the Administrative Procedures Law (APL).

§ 25-43-3.109. Contents, style and form of rule.

(3) An agency may incorporate, by reference in its rules and without publishing the incorporated matter in full, all or any part of a code, standard, rule or regulation that has been adopted by an agency of the United States … if incorporation of its text in agency rules would be unduly cumbersome, expensive or otherwise inexpedient. The reference in the agency rules must fully identify the incorporated matter with an appropriate citation.

Because HHS does not require Standard and Comprehensive Centers, SECAC/MDHS should include 658G(a)(2), the code that is available in the federal statute mandating the choice of 1 out of 10 quality activities from which SECAC/MDHS were to have allowed a proper (and not manipulated) Mississippi needs assessment to determine:

  • Training and professional development.
  • Improvement of early learning guidelines.
  • Implementation of a quality rating system.
  • Improving the supply and quality of infant and toddler care.
  • Expanding resource and referral services.
  • Facilitating state licensing compliance.
  • Evaluating child care programs’ effectiveness, including positive impacts on children.
  • Supporting voluntary accreditation.
  • Supporting quality health, physical activity and nutrition standards in child care settings.
  • Any other quality improvement activity that can be measured.

The quality determined by SECAC, is written to allow for the annual elimination of small business service providers (most of whom are members of a protected class – the other elephant in the room) who do not demonstrate ongoing and ever more…and still more…costly national standards over time without mention of the fact that those to be most impacted receive only 75% of 2015 market rates enacted in 2018 – the first increase in as much as 15 years and possibly the last one for 15 years more.

Regardless, all are expected to transition from a Standard Center to a Comprehensive Center which SECAC has recommended be staffed with caregivers who hold Master’s degrees – a huge investment for any small business that will likely be passed on in increased child care fees to young, middle income parents who are just starting to build careers but do not qualify for state subsidy. 

SECAC/MDHS implemented this CCDF State Plan without identifying or providing the rules by which centers will be determined eligible to continue to serve low-income children.

Further attempts to redress this again would likely not be any less exhausting or any less heated than it was when I first raised this primary concern with policymakers.

In fact, it would likely just be said, as it is usually said by state actors, academia and others when we dare to question, that self-employed child care providers do not care about children.  We are only interested in making money.

“I can rise from the ashes like a phoenix only so many times.”

After five years of effectively defunding the Program through no new enrollment for low-income parents entering the work force and other SECAC/MDHS patterns and practices, (coupled with heavy-handed adoptions by the Mississippi State Department of Health Child Care Licensing/BOH),  I liken the needed child care provider ”buy in” of this CCDF State Plan as nothing short of a suicide pact. 

Demoralizing child care providers while financially defeating small businesses providing LICENSED child care services will NEVER sufficiently serve the needs of work force development or bring about quality child care or school readiness in Mississippi and has not justified any one competing early learning model, quality grant, technical assistance team, or agency as ”THE most worthy of CCDF quality funding” or as ”THE leading edge of leadership”.

More than two years in, I have not seen that this leadership can administrate a cost prohibitive quality rating system with any more expertise and success than the QRIS previously in place. Costs to low-income providers are still costs! Unstable CCPP funding is still unstable! More bias, prejudice and contempt for self-employed providers serving low-income children is, no less, bias, prejudice and contempt whatever the reigning early learning model!

What I have seen is that such conduct and conflict has driven state actor personal agenda and ambition, fostered a hostile and disruptive work environment for CCPP providers and low-income families, violated the privacy rights of private citizens working for private companies and prevented any meaningful discussion of reasonable policies and assurances needed for expanding quality resources in the existing small business infrastructure developed by the CCDF to provide LICENSED child care services to low-income children.

Just weeks ago, SECAC asked a legislator to sponsor a bill to abolish the SECAC and replace it with a Children’s Cabinet which would remove child care representatives completely from the policy making ROOM and thus, take away all Program ownership – a quest I see as more so for power than for vested quality and improvement.

Fortunately, it died on the calendar.

Given the level of contempt and disrespect all leadership has demonstrated for CCPP child care providers and small businesses over the years, it is no wonder that costs and sustainability of QRIS activities and the huge burden to providers and economic impact QRIS causes them to realize has always been the elephant in the room!

For state actors to continue to ignore costs and consequences without regard for those who are to be adversely impacted and to implement underfunded national standards/SECAC mandates without proper adoption and without a proper economic impact statement – without the tools and input needed to make sound decisions – is reckless to the stability, availability, and affordability of ALL LICENSED child care, reckless to an industry embedded in small businesses, and reckless to work force development in rural communities.

These facts are why national standards were NOT adopted when the CCDFBG was enacted. 

”Houston! We’ve got a problem! What have we got on the spacecraft that’s good?  We just lost the moon.”                                                                                                                                               Apollo 13

Click here to see the number of facilities (24) in Mississippi that pass muster in the accreditation of NAEYC standards which are embedded as the child care center evaluation in the SECAC/MDHS Standard Application. Ten percent, (10%) of child care programs across the nation hold NAEYC accreditation. Note that most have more stable funding sources other than the CCDF. Further note that providers accepting Mississippi Certificate’s of Payment receive less than 1/3 the funding of a comparable Head Start Program.

Also see QRIS Rating Systems Do Not Improve Learning or Social Development of Children.

TUESDAY’S PUBLIC HEARING – The Costs of Required QRIS to Small Business

Posted: March 15, 2019 | Author: | Filed under: Administration for Children and Families, Business Ethics, CCPP-approved Provider, Child Care Development Fund, Child Care Mississippi, DECCD-MDHS, HHS ACF Office of Child Care, Mississippi Building Blocks, MS Department of Human Services, NSparc, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: , , , , , , | Leave a comment

TUESDAY’S PUBLIC HEARING – The Costs of Required QRIS to Small Business

Should you attend this public hearing scheduled for a time that may be difficult for you to properly staff, travel to and/or attend on a normal business day?

  • Well, how did you “score” on the first online application?
  • Did you receive timely technical assistance or understand how you may have been determined to need technical assistance?
  • How has the child care industry and families been helped or harmed overall by this SECAC/MDHS leadership over five years?

The answers to the questions above should guide you in making that decision.

Objections and challenges have been formally presented to the adoption of the Mississippi CCDF STATE PLAN:

  • What are the costs of this revised, yet REQUIRED, QRIS? 
  • What are the rules (the scale by which you will be graded each year) as a candidate for continued Program participation as a qualified CCPP Provider or as a candidate for CCPP Program expulsion (one who may NO LONGER serve children receiving Mississippi Certificates of Payment)?
  • Has Mississippi, given the fact it collects the lowest child care fees in the nation, demonstrated it can sustain ongoing and ever more costly (NAEYC) NATIONAL STANDARDS without eliminating children and providers/programs and driving up all parent fees to the detriment of today’s workforce development?
  • Does this Economic Impact Statement demonstrate/assure a level-playing field for those serving large numbers of the ”Haves” or the ”Have-nots” to be a Comprehensive Center or to even continue as a Standard Center over five years?
  • What will the ”determination” of SECAC rules be over time? Shouldn’t those who are to be and have been impacted have all clearly stated rules prior to this MDHS adoption and prior to any such previous implementation?
  • Is the ”blank check” SECAC/MDHS has taken in the normal, non-emergency promulgation of rules ever permitted or granted to any council or agency under Administrative Procedures Law or does this conduct defeat the very purpose of the Administrative Procedures Act?
  • What are the reasonable use rules for the new system of records developed by NSPARC at Mississippi State including the collection of workforce social security numbers and other personally identifiable information including Email addresses?
  • Given such legitimate concerns, how can such a plan ever gain the full approval of “astute” federal monitors?
  • How can legitimate concerns be PROPERLY redressed and how do you think the plan can be improved within its’ framework for the greater good of ordinary citizens and families?

The public hearing scheduled for Tuesday, March 19, 2019, addresses at least one of the challenges – the previous failure of SECAC and MDHS to provide an Economic Impact Statement demonstrating the costs to small businesses and self-employed child care providers.

MLICCI is holding a strategic planning day tomorrow in Jackson so that we can share our concerns and recommendations prior to Tuesday.

For more information, left click the following links:

MLICCI March 16th Meeting, click here.

Administrative Procedures Law, click here.

MDHS Economic Impact Statement for the CCDF State Plan, click here.

Proposed Child Care Payment Program Policy Manual, click here.

Attend the MDHS public hearing!

Tuesday

March 19, 2019

10:00 AM to 12:00 PM

Civil Rights Museum

Community Room

 222 North Street

Jackson, MS 39201

See you there!

 

 

 

 

 

Celebrating MLICCI – Even More Relevant 20 Years In!

Posted: January 11, 2019 | Author: | Filed under: Administration for Children and Families, CCPP-approved Provider, Child Care Development Fund, Child Care Mississippi, DECCD-MDHS, HHS ACF Office of Child Care, Kellogg Foundation, Mississippi Legislature, MLICCI, MS Department of Human Services, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: , , , , , , , , | Leave a comment

Celebrating MLICCI – Even More Relevant 20 Years In!

An advocacy group representing healthy policies for low-income parents and the providers who serve them – does any other state have access to such support?

I am not aware of any other!

I have always felt we are very fortunate to have such organized and consistent advocacy right here in Mississippi!

Last March, MLICCI Executive Director Carol Burnett retained attorney Beth Orlansky with the Mississippi Center for Justice who was mere days, if not hours, from filing suit in State Court to stop the extreme vetting during the redetermination process that required the address on a parent’s photo ID to perfectly match the address on the bill the parent provided to verify residency when MDHS decided to stop such hate filled terminations voluntarily!

During the panel discussion held at the all expenses paid twentieth anniversary kick off held in Biloxi last October, MDHS attorney Andrea Sanders conceded VIOLATION OF APL saying that an economic impact statement demonstrating our costs to meet REQUIRED QRIS (rating scales for scoring applications) was being prepared…after the fact…but nonetheless, being prepared and will be followed with a public hearing!

Henry and Tawanda Ware of Greenwood at the MLICCI Twenty Year Celebration!

The best part of the Mississippi Low-Income Child Care Initiative that weekend, however, was the fellowship with friends and the family atmosphere – meeting  Carol’s very supportive husband, Matt’s lovely wife and precious son, and realizing what a good-looking couple Tawanda Ware (Bright Beginnings 1 & 2 of Greenwood) and her husband, Henry, truly are!

If you are not yet a member of our extended MLICCI family, you should be! Visit our website and get on the mailing list to receive all MDHS policy reports, MLICCI research findings and more!

Click here!

Or join us tomorrow to hear the research findings of the MLICCI commissioned study on new enrollment, redetermination processes and Certificates conducted by Dr. Betty Ward Fletcher which will demonstrate how we were impacted by the loss of so many students through the extreme and hate filled policies of 2018!

Saturday, January 12th at 10:00 a.m.

MS Civil Rights Museum Auditorium, 222 North Street, Jackson, MS

RSVP
This meeting is open to you and all your staff. We ask, however, that your RSVP so that we can provide adequate refreshments and materials for the meeting.

To see me, or to learn of the NATIONAL INFLUENCE of MLICCI to abolish finger scanning designed to pay child care fees ONLY by the hour and minute as a savings to the State, see the videos below! (The CCDF no longer allows reimbursement to providers by the hour and minute! Congratulations to all who supported that political action!)

Happy New Year and CHEERS TO THE NEXT TWENTY!

 

“Truth isn’t truth”- the Final CCDF Public Hearing!

Posted: August 21, 2018 | Author: | Filed under: "Race to the Top", Administration for Children and Families, CCPP-approved Provider, Child Care Development Fund, Child Care Mississippi, DECCD-MDHS, Early Learning Guidelines (ELG), HHS ACF Office of Child Care, MS Department of Human Services, SECAC Mississippi, Suel v MDHS, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: , , , , , , , , , , , , | Leave a comment

“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 TECHNICAL ASSISTANCE?

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 who determine 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 bring greater 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 and required 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 (prior to 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 assure individuals 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 exist which 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.

GOOD GRIEF!

 

 

 

 

Fool me once, shame on you. Fool me twice? Failure to Launch!

Posted: June 29, 2018 | Author: | Filed under: Administration for Children and Families, CCPP-approved Provider, Child Care Development Fund, Child Care Mississippi, DECCD-MDHS, HHS ACF Office of Child Care, MS Department of Human Services, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: , , , , , , , , , | Leave a comment

Fool me once, shame on you. Fool me twice? Failure to Launch!

SECAC has had eighteen months to fully develop the rules for Standard and Comprehensive centers, and yet, MDHS is being compelled to repeat the same Administrative Procedures Law violation to adopt the words Standard and Comprehensive without the rules.

We gave them time to fully develop the SECAC strategic plan (and initially supported them) all the while the child care assistance program was effectively defunded! As a matter of fact, former MDHS Deputy Director Cathy Sykes and CCDF Administrator (now of NSPARC) even announced that there would be no new enrollment…at a SECAC meeting!

We have all been adversely impacted.

It was adopted without Public Notice, without a Public Hearing, without Public Comments and without the rules.

As a result, incompetence has flourished and infrastructure continues to crumble! ( It is estimated/alleged that approximately 20% -25% of licensed child care in Mississippi communities has been lost.)

Can we afford to risk such widespread industry harm again?

Maybe SECAC needs to sit this one out!

Watch the 24 minute video of the CCDF Public Hearing/Provider Input Session carefully. (Click here.)

Email your comments on the CCDF State Plan to CCDFcomments@mdhs.ms.gov.

You may also share your thoughts with the Governor at info@governorbryant.com.

In the meantime, remember the advocacy provided by MLICCI more than one year ago?

Mississippi Low-Income Child Care Initiative Public Comments on Proposed Child Care Payment Program (CCPP) Policy Manual

Public Hearing, May 30, 2017

  • The State Early Childhood Advisory Council (SECAC) and the Mississippi Department of Human Services (MDHS) have not yet finalized specifically what centers have to do, what the application process will be or what costs may be required for becoming “standard” or “comprehensive” centers under the SECAC’s new plan, A Unified and Integrated Early Childhood System. Without this information, the Mississippi Low-Income Child Care Initiative is unable to fully understand how the proposed changes in the CCPP Policy Manual will impact parents and providers. Before finalizing the CCPP policy manual, thereby formally adopting a SECAC plan and process that has yet to be finalized, MDHS and SECAC should inform centers what is required to become designated as a “standard” and a “comprehensive” center. Details regarding the eligibility process for a CCPP-approved provider should be included in the CCPP Policy Manual, not just in the new SECAC plan. Before child care providers are able to embrace the new requirements of SECAC’s plan and MDHS’s formal implementation of SECAC’s plan through this proposed CCPP manual, providers must first understand:
    • If they will be unable to continue participating in CCPP based on responses to the Standard Center Application before being offered and receiving technical assistance;
    • If all centers that need technical assistance will receive it before losing CCPP eligibility; and,
    • If providers are likely to incur expenses to comply with corrective action plans designated by technical assistance providers

 

 

 

 

Open and Honest Dialog! Video of CCDF State Plan Provider Input Session/Public Hearing

Posted: June 25, 2018 | Author: | Filed under: Administration for Children and Families, CCPP-approved Provider, Child Care Development Fund, DECCD-MDHS, HHS ACF Office of Child Care, MS Department of Human Services, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: , , , , , , , | 2 Comments

Open and Honest Dialog! 

Video of CCDF State Plan Provider Input Session/Public Hearing

 

”It is by design that we meet at the Mississippi Civil Rights Museum. 

Today is a day of healing.” 

                                                                  Interim DECCD Director Andrea Sanders, Esq.

 

MDHS Deputy Director Dana Kidd, Interim DECCD Director Andrea Sanders, Esq., and Economic Assistance Director Amanda Fontenot, J.D., presented an overview of the proposed CCDF State Plan to child care providers and advocates on Friday, June 22, 2018 in Jackson.

These women represent the new face of the Lead Agency in the administration of the Child Care Development Fund.

This post is different from most – I have actually placed my text into the body of the video taken of the CCDF State Plan Provider Input Session/Public Hearing.

Due to the time needed to process HD video, I have not yet included the excellent comments presented by providers and advocates, but I may do so at a later date, as time permits or by requests.

Please view the 25 minute video below to learn of much wanted changes and also, pause as needed.

Urgent Child Care Providers’ Meeting Wednesday

Posted: June 18, 2018 | Author: | Filed under: Administration for Children and Families, Business Ethics, CCPP-approved Provider, Child Care Development Fund, Child Care Mississippi, Clarion-Ledger, DECCD-MDHS, General, HHS ACF Office of Child Care, MS Department of Human Services, QRS Mississippi, Quality Rating System, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services | Tags: , , , , , , , , | Leave a comment

Urgent Child Care Providers’ Meeting Wednesday

Does the June 22nd Public Hearing Agenda Demonstrate a New Pattern of DHS Good Faith Effort?

Posted: June 14, 2018 | Author: | Filed under: Administration for Children and Families, Business Ethics, CCPP-approved Provider, Child Care Development Fund, Child Care Mississippi, Clarion-Ledger, DECCD-MDHS, General, HHS ACF Office of Child Care, MS Department of Human Services, NAEYC, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: , , , , , , , , , , | Leave a comment

Does the June 22nd Public Hearing Agenda Demonstrate a New Pattern of DHS Good Faith Effort?

“When we as people, a free people, go wobbly on the truth, even on what may seem to be the most trivial of matters, we go wobbly on America.  Only societies able to pursue the truth and challenge alternate realities can be truly free.”           Rex Tillerson

In exchange for the recent release of YEARS DELAYED CCDF discretionary funding (Certificates) to families eligible for child care assistance and the very delinquent yet federally required 2016 increase in child care market rates, child care leadership who have met in recent weeks with policy makers have questioned if they were being expected to grant absolution for – even support of – alternative realities detrimental to the practice of democracy and the lawful administration of the Child Care Development Fund.

(In nearly eight years time – during the term of Governor Phil Bryant – new enrollment in the child care assistance program was allowed once under the DECCD administration of Laura Dickson only. Further, from October 1, 2003 – April 30, 2018, MDHS did not increase the child care market rates/fees even following the federal requirement to do so in 2016.)

In February, former, proud, small business owner President Donald Trump signed legislation doubling the CCDF assistance to meet the workforce needs of historic jobs growth.

Since that time forward, MDHS Deputy Director Dana Kidd has kept her word for expedient redress of our grievances as demonstrated in the very recent release of funding to qualifying parents and the 2016 market rates increases we will finally realize next week.

But that has been in contrast to the failed and ongoing rhetoric of SECAC and other policy makers with regard to out-and-out agency misconduct and untruths.

Alternative realities continue to be clearly posted on both the State Early Childhood Advisory Council web site and the MDHS Early Care and Development web site.

  • Although listed as the Mississippi (CCDF) State Plan, the goal to establish Standard and Comprehensive Centers is nothing more than the SECAC Strategic Plan – it is not the CCDF State plan or specifically required format/template to have been submitted to Region IV HHS/ACF… which we have never seen!
  • The SECAC Strategic Plan was never vetted through a public hearing.
  • There has not been a Mississippi CCDF State Plan filed with the office of the Secretary of State since Jill Dent’s administration.
  • No economic impact study was conducted leading up to the disparate intent and effective defunding of the Child Care Development Assistance Program through no new enrollment for five consecutive years and the 2017 elimination/termination of approximately one-half of all remaining families receiving assistance.
  • The child care workforce Social Security Numbers initially required by NSPARC in order to even complete the online registration (or be locked out of the next screen) for federally mandated health and safety training are prohibited from submission to HHS/ACF and must be fully redacted from NSPARC data or tracking systems and research upon your written requests to NSPARC.
  • The ”PANTS ON FIRE” 2018 Market Rate Survey Report initially posted by SECAC and MDHS is is a very delinquent NSPARC 2016 Market Rate Report based on a 2015 data collection conducted by the EYN.
  • MDHS did not collect required market rates data in 2018!
  • The market rates listed for Comprehensive Centers is a moot point, for there are no Comprehensive Centers.
  • Even though MDHS embedded the word Comprehensive into a policies manual, no rules have been provided or written.
  • It is an alternative reality that SECAC and MDHS can facilitate an adoption of any word and then have the poetic license to make up the rules defining and governing the word as they go.

So, for all the immediate relief Mrs. Kidd has provided, we are still flying United. (Click here.)

The damage to a large percentage of child care infrastructure, particularly in rural areas, is likely irreversible.

But maybe, just maybe, our ongoing challenges to alternative realities have been heard by Interim Director Andrea Sanders as demonstrated by her communication below.

Do you think she will lift us above this violent Program turbulence and safely land what has been compared to a probable mid-air crash with no civilian survivors? (Some key policy makers have landed themselves quite well!)

I think she wants to try.

I think perhaps she is demonstrating a good faith effort.

I will be there on June 22, 2018.

You should be there too!

In the meantime, keep your parachutes on!

 

 

 

 

 

 

 

We Were Right to Pursue Legal Action in Suel v. MDHS and Xerox e-Childcare™.

Posted: May 14, 2018 | Author: | Filed under: Administration for Children and Families, CCPP-approved Provider, Child Care Development Fund, Child Care Mississippi, Clarion-Ledger, DECCD-MDHS, HHS ACF Office of Child Care, Mississippi Legislature, MS Department of Human Services, NSparc, Quality Rating System, SECAC, SECAC Mississippi, Suel v MDHS, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized, Xerox | Tags: , , , , , , , , , , , , , , | Leave a comment

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 than 2003 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”.)

At the time, Jane Boykin, President of the former Mississippi Forum and the first Director to serve in the administration of the CCDFBG congratulated providers saying, ”Child care providers stood with our State’s children for over a decade while the State diverted money from their care.” (Click here to read ”Did you hear? We Won!”.) (Click here to read ”Effectively Defunded and Marke t Rates Increases Not Even Mentioned at SECAC!”.) (Click here to view video, “It’s going to makes some of their program’s suffer.”) (Click here to read Financial Windfall from MDHS to Family Resource Center allows Staff Increase From 30 to 260!)

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 services comparable 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™!

 

 

 

 

 

 

 

Increased Child Care Rates Are Not Reflected On APRIL Ledgers!

Posted: May 3, 2018 | Author: | Filed under: Administration for Children and Families, CCPP-approved Provider, Child Care Development Fund, Child Care Mississippi, DECCD-MDHS, HHS ACF Office of Child Care, Mississippi Legislature, MS Department of Human Services, NSparc, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: , , , , , , , , , | Leave a comment

Increased Child Care Rates Are Not Reflected On APRIL Ledgers!

MDHS told child care leadership that NSPARC’s Proposed 2016 Market Rates (”incorrectly” posted on its website as the required 2018 Market Rates Report) would be reflected on the payment ledgers for April.

That has not happened!

Apparently, the deal was to accept the decrease in payment for school age care…or accept another stall in the required market rates increase that should have been in place approximately two years ago!

However, MDHS Deputy Director Dana Kidd has reported redress of the NSPARC proposed rates saying that there will now also be an increase in payments for school age care and more.

But when?

I have been told that MDHS is working with IT to see how quickly it can implement the increases.

I hope it will be before April reimbursement checks are mailed, for otherwise, more small business child care will be forced out of business this month due to the SECAC/MDHS defunding of the child care assistance program.

In the meantime, if you cannot reach MDHS by phone, contact your legislators.

A child care meeting in Jackson is now being discussed and planned.

Please stay tuned!

TRUST DHS OR FOLLOW US!

 

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