A Proper Economic Impact Statement Should be Required. To Act Otherwise is Irresponsible.
Posted: March 19, 2019 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: "Race to the Top", Administration for Children and Families, CCPP-approved Provider, Child Care Licensing, child care licensing Mississippi, child care Mississippi, child care quality rating systems Mississippi, DECCD, DECCD-MDHS, Early Learning Guidelines (ELG), Market Survey Rates, MDHS, Mississippi CCDF State Plan, proposed amendments to the regulations governing child care, QRS Mississippi, Quality Rating System; DECCD-MDHS; CCDF Quality Improvement, SECAC Mississippi 1 CommentA 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
Also see QRIS Rating Systems Do Not Improve Learning or Social Development of Children.
MECA CONFERENCE – February 16, 2019 Jackson State University
Posted: February 2, 2019 Filed under: Administration for Children and Families, CCPP-approved Provider, Child Care Development Fund, Child Care Mississippi, HHS ACF Office of Child Care, Jackson State University, MS Department of Human Services, School Readiness Mississippi, U.S. Department of Health and Human Services | Tags: Administration for Children and Families, CCPP-approved Provider, child care Mississippi, child care quality rating systems Mississippi, DECCD, DECCD-MDHS, Early Learning Guidelines (ELG), equal access, Market Survey Rates, MDHS Leave a commentREGISTER TODAY!
MECA CONFERENCE – February 16, 2019
Jackson State University
Aug. 10th Debbie Ellis vs. Mississippi Department of Health Jackson, MS
Posted: June 30, 2018 Filed under: Administration for Children and Families, Child Care Advisory Council, Child Care Licensing, HHS ACF Office of Child Care, Mississippi Board of Health, Mississippi Health Department, U.S. Department of Health and Human Services, Uncategorized | Tags: Administration for Children and Families, Child Care Licensing, child care licensing Mississippi, child care Mississippi, Early Learning Guidelines (ELG), Mississippi Child Care Licensing, Mississippi Health Department, Mississippi licensed child care, proposed amendments to the regulations governing child care, SECAC Mississippi Leave a commentAug. 10th Debbie Ellis vs. Mississippi Department of Health
Petition for Restraining Order halting unlawfully assessed fines regarding the Maximum Capacity of a Classroom
Ms. Ellis sues on behalf of herself and ALL similarly situated child care providers.
Friday
August 10, 2018
9:00 A.M.
Before the Honorable Denise Owens
Hinds County Chancery Court
316 S. President St.
Jackson, MS 39201
Your support is greatly appreciated!
Please make plans to attend in a show of solidarity!
Please like and share on your Facebook page!
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Dr. Rhea Bishop of the Kellogg Foundation Lends Support and Encourages A Strong Child Care Provider Network Across the State of Mississippi!
Posted: February 21, 2018 Filed under: "Race to the Top", Administration for Children and Families, CCPP-approved Provider, Child Care Development Fund, Child Care Mississippi, DECCD-MDHS, Early Childhood Education Mississippi, Early Learning Guidelines (ELG), HHS ACF Office of Child Care, Jackson State University, Kellogg Foundation, Mississippi Legislature, MLICCI, MS Department of Human Services, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: Administration for Children and Families, CCPP-approved Provider, child care licensing Mississippi, child care Mississippi, DECCD, DECCD-MDHS, Early Learning Guidelines (ELG), Kellogg Foundation, Market Survey Rates, MDHS, Mississippi CCDF State Plan, SECAC Mississippi Leave a commentDr. Rhea Bishop of the Kellogg Foundation Lends Support and Encourages A Strong Child Care Provider Network Across the State of Mississippi!
(MECA Conference)
”Vote. Show up politically and raise some san when it comes to the children and families you serve.” Dr. Rhea Bishop
See video below.
Between the workshops and Conference Ballrooms, the topic most discussed among the more than 300 child care providers attending the MECA Conference was the extended HHS deadlines by SECAC/MDHS and failure to yet release the Child Care Development Fund and the necessary resources to generate just the operating capital needed to maintain the full day, full-year work-force support (low-income child care) system developed and deeply embedded in the private sector.
Proponents of the former QRIS and the Early Learning Collaborative administered by the Department of Education were quick to say, ”We told you that CCDF administration under the leadership and guidance of the State Early Childhood Advisory Council (SECAC) was going to be worse.”
Truthfully, I have not forgotten the leadership promoting a QRIS that continued to use a method of scoring known to have failed even some of the few (10%) centers across the nation worthy of costly accreditation by NAEYC!
When the rest of the country adopted the new and more flexible QRIS scoring method developed after that finding which allowed the award of points for improvements made, Mississippi policy makers did not!
As a result, many providers serving low-income children who were indeed making quality gains in many areas continued to be consistently barred from Early Learning Collaborative Pre-K participation.
I have not forgotten, and never will, the very aggressive and negative lobby they supported and contributed to through the Hechinger Report newspaper series, ”Crises in Child Care” where in every case of noted ”crisis”, there appeared a photograph of a Black owned and operated facility with posed staff and in the one case of a ”good” program, there appeared a photograph of the African-American worker doing as instructed by the white director of the white owned child care facility…institutional racism as I saw it and very unfair to those providers agreeing to be interviewed only later to learn that they had depicted in such a poor light. (Click here.)
The message they hoped to be conveyed to our legislators and all Mississippians was: ”The Low-Income Child Care Industry does not have capacity to prepare little children for school”.
In that way, all the more reason to justify a Pre-K Collaborative policy makers’ wish to propose an Interagency Council which would assume the duties of CCDF administration, licensing, determine how the CCDF quality dollars would be spent and remove child care providers from the policy making table!
Proposed in the Senate by Senator Brice Wiggins, the legislation failed.
So, this past Saturday, I responded that I still believe that the SECAC plan is a better fit for the low-income child care industry and that some very good policies had been adopted as a result.
Adverse child care payment policies began long ago under previous administrations and have progressively become more harsh.
I did concede, however, that we had expected the Governor’s policy makers to follow Administrative Procedures Law.
They did not.
They did not identify the Quality Needs Assessment required by HHS to determine how the quality dollars should be spent. (Click here.)
They have not filed an amended state plan with the Secretary of State which would have outlined NSparc’s role, market rates, and discretionary spending.
There was no public hearing.
They did not and have not provided an Economic Impact Study outlining the impact the SECAC plan will have on small businesses.
The rules of a Standard and Comprehensive Center have not been provided.
They just did not and have not followed the law, including privacy law and HHS guidance on the collection of Social Security numbers in a new system of records…so, yes…bad… alarming… destabilizing…irresponsible…unprofessional and possibly the greatest disparate impact ever for needy parents and disadvantaged small businesses in Mississippi.
Therefore, it should be no surprise to anyone, just as the Pre-K Collaborators had done, the Governor’s SECAC policy advisor recently proposed a Children’s Cabinet – an Interagency Council which would assume the duties of CCDF administration, licensing, determine how the CCDF quality dollars would be spent and remove child care providers from the policy making table.
When Representative Deborah Dixon moved for the House of Representatives to reconsider this legislation which had stalled, the NAYS presented so loudly, the Speaker did not even have to open the voting machine. The proposed legislation died on the calendar.
Perhaps, the majority of Representatives, like many Mississippians, do not feel any additional layer of costly and 
overbearing bureaucracy, whether proposed on behalf of the Pre-K Collaborative or those representing the SECAC Plan, is a justifiable expense or truly necessary to best administrate Programs for children.
Apart from that, I believe the SECAC plan, with the right leadership, could be developed as the most inclusive and effective early learning model for child care early learning programs…with a little more work and law-abiding consideration of stakeholder input through proper and transparent APL (Administrative Procedures Law).
The current policy makers, more than 15 months in, appear to be unprepared for the enormity of effort and the time frame required and needed to sufficiently implement the plan.
So, we wait and many have fallen because no industry can be so severely under enrolled and underfunded for such a long period of time without irreversible harm.
Large numbers of child care providers are now needed for proper industry representation on the South Steps of the Capitol, Thursday, February 22, 2018, 10:30 AM, in Jackson. (Please sign in beginning at 10:30 AM and wear purple! RSVP to info@mssecure.org .)
- Tell the Governor low-income parents cannot work or complete job training without child care assistance.
- Tell him barriers and draconian redetermination policy is counter-productive to work force development. It will not Keep Mississippi Working.
- Child Care Keeps Mississippi Working!
- Tell the Governor that on Feb. 10, 2018, the Wall Street Journal reported: Historically low unemployment is forcing headway on an issue that has been around since women entered the workforce: child care. Businesses increasingly see it as an issue vital to their operations and communities, and policy makers from New Hampshire to Michigan to Colorado have identified it as key to freeing up workers to fill stubborn vacancies and building a talent pipeline.
- Tell the governor that in Louisiana, a coalition of corporate and university leaders delivered a blunt assessment in a mid-January op-ed in the Shreveport Times : “One of the fixes to our labor shortage is as obvious as the fact that the snow is frozen: Make it easier for parents to get quality, affordable child care.”
- Tell the Governor that Child Care Aware recommends that legislators at the state and federal level invest in the child care industry’s infrastructure to prevent gaps in supply and demand and the creation of Child Care Deserts.
- Tell the Governor it is not appropriate, in a democracy, for his policy makers to say they have not released CCDF funding because they do not yet know how they wish to spend the money when such expenditures were required to have been outlined in an amended state plan with an Economic Impact Study including the impact to small businesses, filed with the Secretary of State and commented upon in a public hearing. Even the Governor’s policy makers must follow Administrative Procedures.
- Tell the Governor we are losing an experienced and certified work force due to a forced reduction in employee work hours and that cause and effect is exactly opposite the quality building his advisors and policy makers purport.
- Ask the Governor to imagine what would become of his heavily touted Charter School Program, also embedded in the small business private sector, if Charter Schools were expected to receive only a percentage of the per pupil spending set in 2003.
- Ask the Governor what the fate of his heavily touted Charter School Program would be if they did not receive funding for new enrollment for more than four academic years!
- Tell him that we have experienced no new enrollment for low-income children in more than four fiscal years and no market rates increase as were required by the CCDF Reauthorization Act and originally scheduled to have gone into effect more than a year ago.
- Ask the Governor to remove all obstacles today and make all necessary changes needed to bring about the immediate release of the CCDF discretionary funding received months ago.
Dr. Bishop understands how far reaching SECAC/MDHS policy is for families, providers and communities and like most early learning people of goodwill, I think is concerned for inefficiency ($13 million lost due to failure to match in-kind funds) and the many extended HHS deadlines in the administration of Mississippi’s current CCDF.
She lifts us up with the following appreciation of facts:
- Child Care is a work force support system!
- Child Care small business ranks among the top five businesses driving local economies.
- The soft skills (empathy, negotiation, communication, making decisions, skills which characterize one’s ability to build relationships with other people) that we develop in young children go on to drive the national economy through a functional and efficient work force.
- You are needed.
- You are loved.
Listen to her inspiring message below and plan to join us in representing the child care industry at the Capitol on Thursday!
We also welcome the support of our colleagues who do not accept Certificates for this industry-wide, state led market disruption may impact you in time.
Please come and stand with us.
Feb. 22nd – Advocate for Child Care at the Capitol
Posted: January 25, 2018 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, Jackson State University, Mississippi Legislature, MLICCI, MS Department of Human Services, NBCDI, NSparc, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: 2007 Market Survey Rates, Administration for Children and Families, CCPP-approved Provider, child care Mississippi, DECCD, DECCD-MDHS, Early Learning Guidelines (ELG), equal access, Market Survey Rates, MDHS, Mississippi CCDF State Plan, Mississippi licensed child care, Quality Rating System; DECCD-MDHS; CCDF Quality Improvement, SECAC Mississippi Leave a commentFeb. 22nd – Advocate for Child Care at the Capitol
Child care providers who have questions and concerns about the administration of the Child Care Development Fund will have an opportunity to speak directly to their legislators on February 22, 2018 beginning at 10:00 AM on the second floor of the state Capitol Building in Jackson.
Please come and shine like the star you are!
Although child care providers have been anxiously awaiting the long overdue announcement of Mississippi’s new child care rates (federally mandated increases) expected to be announced at today’s SECAC meeting, the January 25th meeting has been canceled. (Click here.)
The next SECAC meeting is also scheduled for February 22, 2018.
MARK THIS IMPORTANT DATE!
In addition, attend the MECA Conference on February 17, 2018 in partnership with the Childcare Directors Network to learn more about the issues facing Mississippi’s child care industry and strengthen your voice by becoming a full, supporting, statewide member.
In the meantime, to raise very urgent concerns or to discuss low-income child care services with your Senator and Representative today, call the Capitol Switchboard and send a message in to them. Ask them to give you a call.
Capitol Switchboard: (601) 359-3770
UPDATE: May be Down Again!
Posted: November 21, 2017 Filed under: 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, NSparc, QRS Mississippi, Quality Rating System, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: Administration for Children and Families, CCPP-approved Provider, child care Mississippi, child care quality rating systems Mississippi, DECCD, DECCD-MDHS, Early Learning Guidelines (ELG), equal access, Market Survey Rates, MDHS, Mississippi CCDF State Plan, Mississippi child care, Mississippi licensed child care, QRS Mississippi, Quality Rating System, SECAC Mississippi Leave a comment
UPDATE: THE SYSTEM IS BACK UP!
May be Down Again!
BY REQUEST
Providers began to report MDHS system failure again just one day after DECCD issued new deadlines for uploading data to complete the required online Standard Child Care Center Application.
At the Child Care Academy Curriculum Training Session held today in Hinds County, the CCA trainer explained that DECCD had acknowledged problems with uploading data and that DECCD described such system failure as a computer ”glitch”.
Regardless, today, DECCD continued to issue redetermination deadlines and NSparc continued to contact providers directly to encourage them to submit their data.
There has been no known courtesy call, notice or explanation of any system failure or computer glitch from DECCD or NSparc to any affected provider who may be working in vain to submit their data at this time.
If you experience problems and fear missing your deadline, call DECCD or the Office of the Governor for assistance.
They’re Up for Now!
Posted: November 15, 2017 Filed under: 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, QRS Mississippi, Quality Rating System, SECAC Mississippi, U.S. Commission on Civil Rights, U.S. Department of Health and Human Services, Uncategorized | Tags: Administration for Children and Families, CCPP-approved Provider, child care Mississippi, child care quality rating systems Mississippi, DECCD, DECCD-MDHS, Early Learning Guidelines (ELG), equal access, Market Survey Rates, MDHS, Mississippi CCDF State Plan, Quality Rating System, Quality Rating System; DECCD-MDHS; CCDF Quality Improvement, SECAC Mississippi 1 Comment
They’re Up for Now!
Following weeks long crashes, data dumps and a suspension in ”Provider Redeterminations”, MDHS has reinstated redetermination deadlines for all affected child care providers. Check your Email so that you will not be eliminated by made up rules that have never before received public comment or rules that may still be a secret, raising questions such as, ”What is a Comprehensive Center and how should we know if we would like to be one?”
I guess the rules of Administrative Procedures do not apply to powerful/advantaged state actors who are making up the rules governing service providers as they go or are allowing their associates to make up the rules as they go…all without public notice.
Brace for Economic and Disparate Impact!
Buckle those seatbelts, providers!
Rise above this severe child care industry turbulence and submit your data into unknown stratospheres!
Arrive on time!
”Laugh, Live, and Love” in the knowledge that together, we are flying united…United that is!
Enjoy this viral video clip from Jimmy Kimmel Live which was featured on Fox, CNN and most major news networks. (Warning: Strong and insinuated language may be as offensive to some as the state actor contempt for disadvantaged small businesses is to us…but it is well deserved, best describes the obvious attitude of policy makers who should know that they are violating APL and it fits my theme!) (We have just got to lighten up if we are to survive this flight!)
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