A Notable Farewell

A Notable Farewell

Laurie Smith, SECAC Executive Director and architect of required Standard and Comprehensive child care center designations has taken a post with the U.S. Department of Labor.

She now resides in Washington, D.C.

We bid her farewell.

 


No New Enrollment…Again! Unstable! Irresponsible!

No New Enrollment…Again!  Unstable!  Irresponsible!

Remember this? March 6, 2018

“Effectively Defunded and Market Rates Increases Not Even Mentioned at SECAC!”

The Governor’s policy makers did not conduct an Economic Impact Study to determine the impact of SECAC’s plan on private citizens and small businesses.

The Governor’s policy makers did not follow Administrative Procedures Law.

This conduct of state actors is unprecedented and proving to be the most irresponsible, hostile and destabilizing in the history of Mississippi’s CCDF.

SECAC/MDHS has held Mississippi to zero new child care enrollment state-wide for five years now and recently terminated approximately one-half of all children who were being served by employing new, draconian eligibility requirements and adding extra hurdles sure to eliminate large numbers.

Remember this? March 27, 2018

“Child Care Collateral Damage is Unhealthy for this State, Life Changing and Wide Spread!”

Employers have lost entry-level but well-trained, employees willing to fill stubborn vacancies.

The child care infrastructure developed and based in the private sector (much like the developing charter school infrastructure) is crumbling, particularly in rural areas, as owners serving low-income children go out of business.

John Davis has appointed Dana Kidd as MDHS Deputy Director of Federal Programs.

In a very recent meeting with MDHS Executive Director John Davis, I was introduced to MDHS Deputy Director of Federal Programs Dana Kidd.

According to Ms. Kidd, CCDF program redress and announcements are to come expeditiously.

Postscript

During that lunch meeting with SECAC Executive Director Laurie Smith, DHS Executive Director John Davis and myself, Mrs. Kidd, a whiz with more than 30 years experience in the administration of economic assistance and federal programs, was given primary authority for getting the child care economic assistance program up and running.

With her knowledge of federal guidelines, Mrs. Kidd swiftly aligned distribution policy and authorized the DHS release of child care assistance in short time.

What remained of the child care infrastructure developed to serve low-income children was given a temporary reprieve!

Moving forward, Mrs. Kidd met with us, heard our concerns, provided reasonable influence in the development of child care policy and encouraged our stakeholder participation.

In fact, after sending her my thoughts on aligning new enrollment with the academic year, Mrs. Kidd encouraged me to also send a timely Email of my suggestions to Andrea Sanders who was, at that time, placing proposed CCDF policy into the required HHS structure of the CCDF State Plan.

 

Email I sent to Andrea Sanders Aug 8, 2018:

Because the exit of full time children is immediate, widespread and happening on approximately the same day throughout the state, the current process of issuing new enrollment simply cannot keep up in a manner sufficient to support the operating budgets needed for many rural area facilities…not to mention quality! The gains recognized for CCPP providers through the current release of funding and the implementation of the rates increase is lost for many due to the large exodus of full time children. It is often a huge source of immediate and swift financial stress.
In addition, other re-determinations scheduled throughout the year as twelve months of services expire for families are still further destabilizing and place children, suddenly, out of learning environments and readiness programs with no thought given to that child’s education.
You cannot, simply cannot, even attempt or expect truly effective preschool programs in rural programs where very large numbers of children enrolled are low-income children without aligning all re-determination and new enrollment with the new school or academic year.  
The Planning and Development Districts knew this. They aligned all re-determinations for April/May and then issued new enrollment Certificates for October…thus, classes were formed and children were ready to be received at the start of the new FFY (but should have aligned with the academic year as a “‘best practice”‘ support). This was done statewide! 
Further, no Change of Provider forms were received/processed from April through August.
I recommend this practice be fine tuned and the former PDD process be reinstated to align with the academic year as soon as possible even if it requires allowing for 18 months or more of services for some initially.

The PDD’s terminated Certificates while also issuing new enrollment Certificates at the same time. They understood that no business could operate without sufficient customers. McDonalds would close if too few purchased their meals!

And one year later…with precious little recovery time, we are right back where we started with No New Enrollment!

Unfortunately, we have just learned from others that since Mrs. Kidd’s return from FMLA (Family Medical Leave Act), she was given a very reduced role in matters of the CCDF; recently, she was completely removed from child care duties altogether – and it shows!

After only one child care certification period and three months now, in to the termination of large numbers of children on assistance, DECCD Director Kristi McHale, who has been employed at DHS about twelve months, still maintains her instruction of no new enrollment even as large numbers of the children that survived Program eligibility have exited for public school!

Worse, through DECCD, DHS General Counsel Andrea Sanders – who now has taken primary authority after only two years of employment with DHS – released a memo, without proper APL, notifying of changes in the delivery of payment for child care that have already started:

What is new?

”On the first of each month, CCPS will look at the previous month to see which children had a birthday. CCPS will pay the appropriate rate based on the child’s new age. For example, if a child turns 13 months old in November, then CCPS will pay the new rate starting in December.”

Children terminated + Children moved to Part-time reimbursement status + No new enrollment + less reimbursement and squeezed payments each month rather than at the next re-certification period = predatory underfunding while requiring costly Q.R.I.S.

A child care Rally at the Capitol is being planned for September!

Plan to attend!


Is Q.R.I.S. Technical Assistance Primarily to Degrade and Cause Licensing Inspections and Fines?

Is Q.R.I.S. Technical Assistance Primarily to Degrade and Cause Licensing Inspections and Fines?

At least two African-American child care providers, who will not be named here, reported last week that after allowing technical assistance coaches into their facilities to work with staff – just as the CCDF State Plan calls for – their small businesses were met by child care licensing officials at the start of the following business day and excessive fines were imposed.

Since that time, it has been alleged that technical assistance coaches have been instructed by agencies to report all observations and anything caregivers might be doing incorrectly to licensing officials.

Keep in mind that many of the former, unsuccessful Q.R.I.S. coaches are now with MDHS technical assistance sub-contractors and I suppose still enjoying the open fault they find with you as a quality measure – however misguided and counterproductive.

If these allegations are founded, and I believe they are, then I am sorry your staff was not coached, guided and “improved” in a safe space, but rather, unwittingly inspected.

Under such circumstances, the attitude of purported help does not foster learning or training for anyone but rather, only more degradation, so perhaps you should wait to accept technical assistance after Standard and Comprehensive Center criteria and scoring scales are defined.

Sadly, such technical assistance is just what we have expected.

March 11, 2016, the United States Commission on Civil Rights investigated the application of Q.R.I.S. in Mississippi and stated in a letter to Mr. Eric Blanchette of the Office of Child Care, Region IV: “The Quality Rating and Improvement Systems (QRIS) program which is purported to promote higher quality child care appears to instead penalize and costs so much that it excludes the participation of African-American owned and operated child care facilities.”

Recommendations included allocating funding to support child care facilities in low-income areas, and reviewing the effectiveness of evaluation criteria for child care facilities and its ability to predict improved developmental outcomes for children of diverse communities; and creating written policies and guidelines regarding factors that define quality in child care.

Regardless, Dec. 7, 2016, SECAC presented a very rigorous process of maximizing funding and services to families and child care programs by utilizing a Family-Based Unified and Integrated Early Childhood System:

Each year centers will go through an initial eligibility process and subsequent annual redetermination processes. Any center that fails to meet the basic requirements for its designation will be given six months to successfully implement a corrective action plan. The corrective action plan will be developed by an external evaluator in consultation with the child care center director and technical assistance coach. Failing to reach goals outlined in a corrective action plan will result in loss of designation at the end of the current annual eligibility term.”

Once eligible, centers must engage in continuous quality improvement based on a scale that assesses the extent to which a center should engage in additional technical assistance for maintaining and improving quality”.

“Scale scores will help centers maintain eligibility to redeem vouchers.”

Unfortunately, the scale to maintain eligibility to continue to serve low-income children has not yet been identified or provided by SECAC.

SECAC has explained that because HHS has required quality, the proper Administrative Procedures Law to adopt and implement a Family-Based Unified and Integrated Early Childhood System is not required.

The Mississippi State Department of Health (also funded in part by the CCDF) has a long history of implementing Q.R.I.S. standards by circumventing Administrative Procedures Law which are most punitive and possibly financially devastating to a particular type and class of child care provider.

Click here to see the economic uncertainty of Mississippi’s existing child care infrastructure and Q.R.I.S.

For more on the findings of the USCCR, contact the federal CCDF monitor:

Eric R. Blanchette

Program Manager

Office of Child Care Region IV

Suite 4M60, 61 Forsyth Street

Atlanta, GA 30303-8909

eric.blanchette@acf.hhs.gov

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


The Alignment of NAEYC (National Association for the Education of Young Children) to ECERS (The Early Childhood Environment Rating Scale)

The Alignment of NAEYC (National Association for the Education of Young Children) with ECERS (The Early Childhood Environment Rating Scale)

As you have now learned, in order to be allowed to continue to serve children receiving Certificates of Payment after June 30th, you must, at the very least, teach a curriculum and submit to (yet) unidentified assessments of your classrooms and/or facilities – not assessments of student outcomes (Standard).

As you requested, at the SECAC (State Early Childhood Advisory Council) meeting, I entered objection to perceived unfunded mandates (absent any drafted policy or announcement of the increase in the below market rates) and asked that the following information be placed into the minutes with regard to the CCDF plan adopted by SECAC and the Standard Center Draft Application still under development:

A 1997 assessment of NAEYC by the National Center for the Early Childhood Work Force (NCECW) found, “Nearly 40 percent of the centers in this study which became accredited were rated as mediocre in quality on the Early Childhood Environment Rating Scale (ECERS), a widely-used and respected measure that is linked to child outcomes and is closely related to the NAEYC accreditation criteria. Since it is not fully clear from this study where in the process the causes of this shortfall in quality lie, we encourage NAEYC to undertake a reexamination of its accreditation criteria and of its validation and Commission approval systems.”

The 1997 study demonstrates the failed, outdated/extreme ECERS (QRIS) scoring scale – the Block scale – still utilized in Mississippi that was the basis of the overall conclusion that the licensed child care industry does not have the capacity to provide school readiness and is the tool of exclusion (for licensed child care programs) from Pre-K participation.

(We know now, the widely-used and respected measure does not improve school readiness or social development in young children.)

It further demonstrates how closely related NAEYC criteria is to the Early Childhood Environment Rating Scale (ECERS) and explains why some who did receive the DHS Draft Standard Application believed QRIS was now going to be required for all who serve low-income children.

The study also found centers that achieve NAEYC accreditation demonstrate higher overall classroom quality at the time of embarking on the self-study process, and show greater improvement in overall quality ratings, staff-child ratios and teacher sensitivity scores. (Click here.)

Centers that participate in NAEYC self-study but do not advance to the validation phase demonstrate no improvement in classroom quality, staff-child ratios or staff-child interactions.

The Ongoing Expectation to Meet the “NAEYC Gold Standard” Without the Gold

Providers allowed to participate in reviewing the Draft Standard Application presented by NSparc and DHS found themselves to actually be reviewing the upcoming NAEYC self-assessment.   

The SECAC plan requires centers to engage in continuous quality improvement based on the scale that assesses the extent to which a center should engage in additional technical assistance for maintaining and improving quality. 

Scale scores will be used to determine appropriate quality-improvement activities and the measurable improvement in services needed to maintain eligibility to redeem vouchers.

Each year centers will go through an initial eligibility process and subsequent annual redetermination processes following the general recommendations by the SECAC committees. (Click here to review page 8 and more of the SECAC plan.)

Therefore, I also entered the additional, following information into the minutes:

NAEYC Accredited , University of Southern Mississippi, Center for Child Development, Tuition and Classes –

$650/month
Infants and Toddlers under 32 months  

$550/month
Preschoolers between 32 months and 4 years

Non-Accredited, Suzie M. Brooks Child Care, 700 Martin Luther King Drive, Building 14, Greenwood, Mississippi –

$347/month
Certificate of Payment (Child Care Assistance) below market rate for Toddler under 32 months

The SECAC plan is scheduled to be in full effect July 1, 2017 – OPTING OUT

Due to the short turn around or period of transition, many providers have determined to begin the process to properly OPT OUT and refer low-income children (who may lose funding due to ever shrinking State resources) to In-home providers who have been grandfathered. (Unlicensed care will be much less expensive than micro-managed center care.)

Others have determined to find other uses for their facilities or to cut rates and serve only private pay families.

I have asked Jane Boykin to provide guidance on how to properly close your business. I will post the information soon.

In the meantime, it has been a difficult but sincere pleasure to represent you! You will be missed! We are sorry to be losing you and licensed care.

 

 

                             

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


“The Thinning”. Limited Resources – Who Will Be Eliminated?

The Thinning. Limited Resources -Who Will Be Eliminated?

The only option – decrease the number.

A single test determines who survives.

If you don’t support our “Great Society”, then you are a parasite!

The Thinning.  See it on YouTube today!

Official Trailer:

 

Movie Preview:


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

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

It’s Economics!

HHS Market Correction and Government Failure

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

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

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

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

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

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

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

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

The Propaganda Ministers of Systematic Underinvestment (Government Failure)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Public Interest

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

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

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

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

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

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

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

Fourteen years later, QRIS proved no better!

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

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

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

So, why the continued and heavy push for QRIS?

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

Excludability

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Class Disparity and Inequality

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

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

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

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

Disparate Impact

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

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

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

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

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

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

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

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

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

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

The Commission stated:

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

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

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

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

Mississippi Quality Stars

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Economics

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

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

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

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

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

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

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

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

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

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

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

Mississippi Building Blocks is such a model.

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

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

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

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


Transcript of Final State Plan Hearing and QRIS Objection Posted Online

Verbatim Transcript of Final CCDF State Plan Hearing and QRIS Objection Posted Online

The verbatim transcript of the Final Hearing of the Child Care Development Fund State Plan has now been posted online.

Please note that NO member of SECAC representing the child care industry (or otherwise), who would dare to present derogatory and unfounded characterizations (potential defamation) of fellow child care providers to SECAC committee members but who do have a vote on the implementation of the CCDF State Plan, even bothered to attend!  (OUT OF TOUCH!)

Fortunately, Administrative Procedures Law instructs the following:

(i) “Rule” means the whole or a part of an agency regulation or other statement of general applicability that implements, interprets or prescribes:

(i) Law or policy, or

(ii) The organization, procedure or practice requirements of an agency. The term includes the amendment, repeal or suspension of an existing rule.

§ 25-43-3.105. Economic impact statement, requirement and conditions.

(1) Prior to giving the notice required in Section 25-43-3.103, each agency proposing the adoption of a rule or amendment of an existing rule imposing a duty, responsibility or requirement on any person shall consider the economic impact the rule will have on the citizens of our state and the benefits the rule will cause to accrue to those citizens.

2) Each agency shall prepare a written report providing an economic impact statement for the adoption of a rule or amendment to an existing rule imposing a duty, responsibility or requirement on any person. The economic impact statement shall include…

(e) An analysis of the impact of the proposed rule on small business;

(g) A determination of whether less costly methods or less intrusive methods exist for achieving the purpose of the proposed rule where reasonable alternative methods exist which are not precluded by law;

(3) No rule or regulation shall be declared invalid based on a challenge to the economic impact statement for the rule unless the issue is raised in the agency proceeding. No person shall have standing to challenge a rule, based upon the economic impact statement or lack thereof, unless that person provided the agency with information sufficient to make the agency aware of specific concerns regarding the statement in an oral proceeding or in written comments regarding the rule.

(3) Before the adoption of a rule, an agency shall consider the written submissions, oral submissions or any memorandum summarizing oral submissions, and any economic impact statement, provided for by this Article III.

(2) An action to contest the validity of a rule on the grounds of its noncompliance with any provision of Sections 25-43-3.102 through 25-43-3.110 must be commenced within one (1) year after the effective date of the rule.

On February 19, 2016, child care leadership representing the Mississippi Child Care Coalition raised formal objection to the proposed “re-write” and continuation of Q.R.I.S. embedded in the 2017-2019 CCDF State Plan.

To review the transcript, please click here.

Fight the Power (and boorish disrespect), y’all!

 

 


State Plan Final Hearing: Do You Feel Better Now?

State Plan Final Hearing: Do You Feel Better Now?

Do You Feel Better Now copy


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

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

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

Freedom of Information Act 

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

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

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

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

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

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

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

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

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

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

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

Alleged Defamation

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

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

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

The Scoop – “We Want Absolute Power!”

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

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

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

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

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

§ 25-61-11  Personnel Files Not Public Record

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

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

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

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

Child Care Small Business Discrimination

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

 

Limiting the Pool of Talent!  Snubbing Most Stakeholders!

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

 

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

 

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

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

 

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

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

Not Expendable!  Keep Mississippi Working

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

 

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

MECA Flyer copyMECA Registration Form