Comments entered by Debbie Ellis into the official record at the requested DHS Child Care Payment Policies Manual Public Hearing 8/29/19:
Narcissistic Manner!
According to Forbes magazine, ‘When leadership behaves in a narcissistic manner, and see themselves as superior with overwhelming contempt for others, they are following a hubristic path.’
The Hubris Syndrome often leads to disaster through incompetent behavior and the mistreatment of people brought on by arrogance and self-delusion.
Hubris Syndrome, in this case, is compounded by DHS staff members and SECAC members carrying out everything the Program micro-managers suggest, without question, whether it be the “influence” of SECAC Executive Director Laurie Smith or SECAC President Mimmo Parisi, both of whom are positioned to benefit greatly from this plan long after this governor’s term expires (just as previous Councils have somewhat done).
The mistreatment of low-income parents and the child care providers serving them is demonstrated by policy makers in the blanket announcement, via memo, of ever reduced monthly “accounts receivable/reimbursements” – already in effect – when, in fact, it is a significant amendment which automatically triggers a public hearing and an economic impact statement and requires specific redress in the Child Care Payment Program Manuel.
Disgraceful administrative behavior is demonstrated through a 32 months long attempt to trick this state’s work force support system, child care providers, into required Q.R.I.S. through very costly National Standards – the NAEYC self-assessment that makes up the Standard Application – and by denying the long term intent of the tool, refusing to publically propose the rules for adoption, foregoing the legally required public hearing through a play of Administrative Procedures Law wording – primarily led by Laurie Smith and Mimmo Parisi – suggesting this plan for quality is required by federal guidelines when the basis of their manipulation is not recognized as the official needs assessment required by the CCDF, but rather, an unofficial SECAC Q.R.I.S. listening session “survey” designed by NSparc to conclude only need for a new and improved Q.R.I.S. of their design which takes out the stigma by not assigning stars, says it is not Q.R.I.S. and calls for CCDF Program debarment instead!
Such bizarre rationale, the rules, economic impact statements (preferably not conducted by NSparc due to the conflict of interest), type specific scales and the SECAC Long Range Strategic Plan also require specific APL redress including a public hearing and inclusion in the Child Care Payment Program Manuel.
To have put child care providers through the mental anguish and this Epic Fail known as theyears long and ongoing initial launch of the Standard Application without proper adoption and redress demonstrates abuse of power or incapacity…or both.
And to those practicing narcissistic leadership style including members of SECAC, you are not the victim outlined in my reports of misconduct.
You are the individuals who are responsible, complicit and accountable.
Like CCPP Providers, your work and actions, both individually and collectively, are also up for judgment.
All are free to resign.
I object to this adoption of the Child Care Payment Policies Manual as I believe it, like the previous adoptions, is morally, ethically and legally wrong and most deceptive and unfair to the child care infrastructure recruited and developed over decades to accept and serve low income children in Mississippi.
I also believe the SECAC plan vaguely mentioned in its pages is unsustainable without serving fewer disadvantaged children in the state holding the national record for the highest number of children and families living in extreme poverty who need work force support – child care – in order to maintain employment and just maybe, break the cycle.
Your silence and/or treatment of CCPP Providers and that impact on the innocent, low-income babies we willingly serve (the weakest and most expendable in your scheme) and your management of CCDF and TANF funds is predatory and shameful!
Perhaps, more so than preschool, what we really need is universal Sunday School!
For more than 40 years, the National Black Child Development Institute (NBCDI) has been at the forefront of engaging leaders, policymakers, professionals, and parents around critical and timely issues that directly impact Black children and their families. We are a trusted partner in delivering culturally relevant resources that respond to the unique strengths and needs of Black children around issues including early childhood education, health, child welfare, literacy, and family engagement. With the support of our Affiliate network in communities across the country, we are committed to our mission “to improve and advance the quality of life for Black children and their families through education and advocacy.”
When selecting a national organization for membership, you may also consider NBCDI!
REMEMBER… THIS IS UNOFFICIAL ADVICE. THIS GUIDANCE IS BASED ON MY EXPERIENCE AND EXPERIENCES SHARED BY CCPP PROVIDERS.
FOR OFFICIAL RESPONSES AND LINKS, CONTACT DECCD.
The Standard Application required in order for you to be considered as a continuing CCPP provider was Emailed to providers in sets of alphabetical order.
If you have not received yours, first check the SPAM box in your Email account before contacting DECCD. That may save you some time.
You are encouraged to attend the trainings and orientation on how to complete the application and discuss curriculum samples provided by your Child Care Academy.
For additional technical assistance or to review other curriculum, visit your Child Care Academy!
A WEBINAR providing guidance on the Standard Application is required and made available to you with your application. The webinar, like the application requires Internet access.
You may view the webinar on your smart phone, ipad, lap top or desk top computer. Any device you choose to view the webinar is okay with MDHS.
If the MDHS system crashes on you as some providers have reported, send an Email to Candice Pittman or DECCD. (Develop a draft copy of your work just in case the system cannot recover it following a system crash.)
I have never seen a Comprehensive Application, so I do not know what the rules will be and it is not included in the CCPP Policy Manuel, but I think you have to first register as a Standard facility.
It has been my experience that the rules are being somewhat disclosed to providers as they are developed via Email so check your Email every day!
I do not know how or when the applications submitted will be scored or considered so I cannot answer those questions but you may call DECCD or visit the web site for more information as/when it becomes available.
VIDEO: More Frustration and Ongoing Confusion at Town Hall with DHS.
Town Hall Partial Transcript/Analysis
Providers: (Beginning minute 38:00)
“It (safety training) was a total disaster. We were registered. They ran out of Scan Trons and didn’t have enough seating.”
“If his staff members were not provided Scan Trons, will they get credit for attending the training?”
DHS:
“No.”
Providers: (Beginning minute 40:00)
‘People apply for child care and are told there is no money for new funding now. What happens to the money (that was being used) for the children taken off the program (aged out, parent didn’t have a cell phone, etc,)? What happens to the money that was being used for those children who are now terminated? Is that money going back into the system? Where is it being put?’ (Is it being put back into the program to fund new children?)
DHS has not issued any known new enrollment in approximately four years, but it has terminated families on a regular basis in all that time.
DHS:
“We are serving as many children as we can serve with the money that we have. And we are looking at increasing the rates andthen we will look and see if we can serve more children.”
Mississippi’s CCDF State Plan is only conditionally approved because HHS determined the rates increase initially proposed by DHS did not support the quality care DHS now proposes to require.
The new and improved rates to be proposed following a second market rate survey have not been released by policymakers and were not disclosed through Administrative Procedures.
DHS has conceded that APL must be started over because such material (as required by law) was omitted in the last DHS proposal to adopt.
See the video below and submit any questions you might have to MLICCI. (Click here.)
June 29, 2017, self-employed child care providers viewed an example of the explanations that are being provided by policymakers responsible for implementing the revised State Plan adopted by SECAC at a special Town Hall Meeting hosted by MLICCI with the Mississippi Department of Human Services.
A new video explains what is meant by “compliance”.
Written policies are scheduled to be made available for public comment through the Secretary of State’s Administrative Bulletin and proper APL processes.
MLICCI is hoping to host other such Town Hall Meetings throughout the state.
Following last Tuesday’s meeting of the Standard Application Workgroup held at DHS and presented by its consultant, NSparc, it was announced during the June 22, 2017 meeting of the State Early Childhood Advisory Council that pages 10-21 of A Family Based Unified and Integrated Early Childhood System will not remain in the plan.
Although it will remain on the SECAC web site for now, it will be removed from the plan and from requirement.
SECAC member Ed Langton thanked CDNA President Deloris Suel and JSU professor Dr. Latasha Hedley for their due diligence in attending SECAC committee meetings and lending input as members of the public.
DHS Announces APL to be Started Over
Following heated debate at the Standard Application Workgroup and guidance from the Governor’s Small Business Regulatory Advisory Commission, DHS has agreed that some material that should have been included in the recent proposal to adopt Standard and Comprehensive requirements for participating centers was “left out” and therefore, the processes required by Administrative Procedures Law will begin again. Thirty days more will be added to the implementation timeline.
The CDNA meeting is still on schedule for tomorrow so that providers may discuss recent activity and changes regarding the implementation of the Child Care Development Fund.
Should a weather event prevent this gathering, a notice will be posted to this blog.
DHS Adopts Standard and Comprehensive Centers Without the Governing Policy
There is no indexed Filing for June 14, 2017 listed in the Administrative Bulletin.
To find public notice of the June 14th final DHS adoption of Standard and Comprehensive Centers without the APL required governing Program policy, you must “walk backwards” all the way to the first Notice of April 12, 2017 in order to see it.
UnderColor of Law, DHS has willfully and deliberately put forth the proposed amendments as only a minor action(alleged fraud) to replace terms such as “licensed” and “unlicensed” with the more appropriate term “CCPP-approved”, and insists that “designating” centers that meet all the additional requirements above licensing requirements to become eligible to redeem CCPP vouchers as either Standard or Comprehensive Centers is not aSignificant Amendment.
No Economic Impact Statement has been provided.
The SECAC plan is scheduled to be effective July 14, 2017.
In the meantime, an open meeting of the Standard Application Workgroup is scheduled to meet Tuesday, June 20, 2017. The meeting will be held at MDHS in the 8th floor training room (Room 830) from 10 a.m. – 12 p.m.
The Workgroup will learn of some of the governing policy that has been developed by SECAC, NSparc and DHS thus far.
Rule-making for Comprehensive and Standard Centers is ongoing.
To review Notice of the Final Adoption of the rule, however, click on the red link below:
Agency:MISSISSIPPI DEPARTMENT OF HUMAN SERVICES Compilation:No Proposed Date: 5/8/2017 Final Date: Effective Date:Withdrawal Date: Rule: NOTICE OF HEARING – Part 17-Child Care Payment Program (CCPP) Policy Manual, system number 22601 Summary: Amended Child Care Payment Program (CCPP) Policy Manual pursuant to Amendments of the Child Care and Development Block Grant (CCDBG) regulations at 45 CFR 98 and Miss. Code Ann. §43-21-353. System Number: 22699
Agency:MISSISSIPPI DEPARTMENT OF HUMAN SERVICES Compilation:No Proposed Date:4/12/2017Final Date: 6/14/2017 Effective Date: 7/14/2017 Withdrawal Date: Rule: Part 17-Child Care Payment Program (CCPP) Policy Manual Summary: Amended Child Care Payment Program (CCPP) Policy Manual pursuant to Amendments of the Child Care and Development Block Grant (CCDBG) regulations at 45 CFR 98 and Miss. Code Ann. §43-21-353. System Number: 22784
Notice of Public Hearing on Rules to Amend the Child Care Payment Program Policy Manuel
The APA defines a “rule” as “the whole or a part of an agency statement of general or particular applicability and future effect of a law or policydesigned to implement, interpret, or prescribe law or policy or describing the organization, procedure, or practice requirements of an agency and includes the approval or prescription for the future of rates, wages, corporate or financial structures or reorganizations thereof, prices, facilities, appliances, services or allowances therefore or of valuations, costs, or accounting, or practices bearing on any of the foregoing.” (Click here.)
NAEYC Criteria as a Strategy for Improving Child Care
As you know, child care providers asked to review the Draft Standard Application on March 15, 2017, were presented self-assessment mirroring NAEYC criteria (which is closely aligned with ECERS) including a “required personnel registry”.
While it is the duty of DHS to carry out the implementation of the CCDF State Plan, the policy-makers and individuals responsible for sweeping change for disadvantaged child care small businesses are the members of the Governor’s SECAC. (Click here to review limited contact info and identification of State Early Childhood Advisory Council members. SECAC Committee members making the recommendations determining whether or not you will have the privilege to continue to serve low-income children for less than market rate – on a year by year basis based on assessment scores – are not listed.) Please do not contact me for telephone numbers. I have no such information I am willing to share. Thanks!
At the SECAC meeting held on March 23, 2017, I incorrectly reported only 2 NAEYC accredited child care centers in Mississippi – there are actually, currently 30 and most represent more stable sources of funding than the CCDF. Check it out! Hover your mouse over each blue balloon. (Click here.)
That is also a gain of 1 since 2007. See the 2007 NAEYC graphic below.
Ten percent, (10%) of child care programs across the nation hold NAEYC accreditation.
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 operate (equal) to Head Start and Title I Preschool programs without parity and without sufficient CCDF funding.
SECAC announced Mississippi’s CCDF State Plan was being carried out with NO REQUEST for additional CCDF funding.
Reprinted from Accreditation Update, Fall 2007, a publication of the National Association for the Education of Young Children
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.
Promoting business-friendly public policies that support parental employment with quality early learning opportunities for the Delta's childcare-age population.
MLICCI is hoping to host other such Town Hall Meetings throughout the state.
Delta Licensed Providers 
Recent Comments