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

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.