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.

 


Get rid of the “bad” ones? (Dr. Chad Allgood is Stigmatizing Child Care!)

Get rid of the “bad” ones? (Dr. Chad Allgood is Stigmatizing Child Care!)

Prepare for fines and/or closure or contact your legislators today!  

My Facebook friend and I have been having lively debate regarding the role of child care licensure and her Facebook friend, Dr. Chad Allgood, formally of MSU Quality Stars Q.R.I.S. (That program was abolished in 2015 by popular demand! According to paid consultants, after millions and millions of CCDF dollars spent in Q.R.I.S. administration over eight years, only 63 child care facilities out of 1,700 actually held a quality rating or measured up to national bench marks because his organization did not update the scoring scale. Coincidentally, DECCD did not have sufficient funding to provide quality incentive bonuses to all providers who participated. Could that have influenced scores and choice of obsolete scales?)

Likewise, I do not support reducing the number of child care facilities down to a number that will allow Child Care Licensing to begin unannounced, long and disruptive “Observation Based Inspections” or four inspections per year where fines may be imposed as they are often in the hundreds and thousands of dollars.

I do not support the act of Child Care Licensing interfering in voluntary quality improvement exercises by asking the technical assistance coaches with other agencies to lodge complaints with Child Care Licensing on child care centers rather than correct any errors on site for the those seeking quality improvement.  I find that counterproductive to quality improvement and to be a little too desperate and eager to rack up fines and demonstrate power.

I do not support inspecting a child care provider 12 times over an 8 week period and/or alleged stalking (allegedly picked up on surveillance cameras) as that meets the legal definition of harassment – that’s not conduct any state actor should be engaged in! (It is precisely why the number of inspections is preset by lawmakers. It also demonstrates that legislators should add specific verbiage to the words “one and more as needed” as well as look into the agency’s process of screening “complaints” and/or abuse of power.)

I do not support reducing the number of licensed child care programs down to a number to promote any state actor’s need for recognition, relevance or to duplicate services, push a personal agenda or embed his own program of unfunded national bench marks/recommendations into licensing, particularly when there is only statutory authority to promulgate minimum standards. (See the Economic Impact Statement – fines/business closures are not addressed.)

I do believe my Facebook friend is right about one thing, however, and that is that work of Dr. Chad Allgood is to get rid of child care centers. He has already revoked many child care licenses based on fines imposed in a single licensing period and at least one excited licensing official has already announced that she can close down a child care facility anytime she wants!

State actor contempt has become so intense, in fact, at a recent meeting on obesity, an employee of the Mississippi State Department of Health revealed that because so much animosity and hostility has been demonstrated towards licensed child care providers, she actually removes her MSDH name badge before trying to collaborate with child care providers because otherwise, they will have nothing to do with her.

I think it is clear that new leadership is needed in Mississippi.

My Facebook friend feels I just have no respect for the leadership and asked me to name just one I respected.

It took a minute!

I listed Dr. Micca Knox of the Child Care Academy for having the professionalism and strong character to refuse to allow her technical assistance coaches to file complaints with the Office of Child Care Licensing following technical assistance sessions with unsuspecting child care providers she truly wishes to empower.  (She is a former elementary school assistant principal with experience in effectively guiding and training teachers.)

My Facebook friend did not attend the Road Show so I have agreed to post clips of what I did film.

I was having camera issues – I switched it off! 

I just didn’t feel I could watch a replay of smooth-talking doublespeak and I was so hoping Dr. Chad Allgood would see the error of his ways and make the decision not to bully and stigmatize child care or technical assistance opportunities with fines.

That has not happened…and Judas betrayed Jesus with a kiss.

So now,  I yield and hope you and she can feel the mood and determine for yourself if measurable improved quality or improved health and safety is even a possibility under this leadership in this environment.

I, for one, do not exonerate him when he says he was once a Director, for I do not identify any relatable kinship as he is conducting himself and his office – this is some serious stuff!

I think it is more about who he thinks he is today and who he wants to be.

He has been pushing four inspections per year since he arrived from Q.R.I.S. He once announced four inspections for the Delta only because it was the only district with sufficient licensing officials or few enough centers to carry it out.  I suppose by January, when this is scheduled to begin, he feels he will have closed enough child care centers and/or generated enough money to support his quality team and carry out four inspections per year state wide. He will surely be seen and heard then – to hear him tell it as he did in Hattiesburg, he will be known and called upon for his quality program nationwide!

So, prepare for fines and/or closure or contact your legislators today!

The Mississippi Legislature sets the number of times a child care facility may be inspected!

According to Dr. Allgood, one inspection is still a viable option and remains on the table.

Get rid of the “bad” ones? (Chad Allgood is Stigmatizing Child Care!)

 

I don’t think that program is new!

PRIOR TO THIS POST: I tried speaking to a member of Dr. Chad Allgood’s Quality Team at the Road Show but she walked away from me. I tried speaking to him, but I didn’t have time to wait. I telephoned his office and left a message. He made no effort to contact me in return.

For on site technical assistance sessions in transitional activities, effective discipline of young children, age appropriate lessons, nutrition, emergency preparedness and more that are not an inspection or held under threat of any monetary penalties to be reported online, contact the Child Care Academy in your area or Email Dr. Micca Knox at: mknox@mccb.edu

The Road Show Video

 

 

 

 


Technical Assistance Inspections Scheme


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.


Aug. 10th Debbie Ellis vs. Mississippi Department of Health Jackson, MS

Aug. 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!

Follow and Like Delta Licensed Providers!

 

 

 

 


Notice of Public Hearing on Rules to Amend the Child Care Payment Program Policy Manuel

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 policy designed 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.)

 


FOUR INSPECTIONS IN DELTA STOPPED!

FOUR INSPECTIONS IN DELTA STOPPED!

Jim Craig, Director of the Office of Health Protection with the Mississippi State Department of Health has announced that four inspections of licensed child care facilities in the Delta has stopped!

The Department of Human Services recently increased funding to the Department of Health for the operation of the child care licensure program from 1 million to 2 million dollars annually.

In the sub-grantee plan submitted by the Health Department to DHS, the first order of business was to use the additional funding to create many new state agency jobs (very similar to those formally held by QRIS monitors and EYN staff) up to one MSDH employee for every 50 licensed child care facilities (until it had reached a total of 30 strong and all, of whom would need “training”)!

Next, MSDH proposed to conduct 4 compliance inspections of licensed child care facilities per year (which also increases the opportunity/odds for an even greater number of fines to be assessed and still greater revenue for the agency. At the October, 2014 meeting of the Mississippi Board of Health attended by child care providers, State Health Officer Dr. Mary Currier reported a “significant” portion of the operating budget of the Mississippi State Department of Health was funded and supported by fines the agency levied against individuals and businesses.)

Mississippi Code requires just one compliance inspection per year, but the rule also already allows for as many inspections as needed and justified by probable cause!

Likewise, the CCDFBG requires one compliance inspection per year.

In a letter sent tonight, Mr. Craig explained he had some questions and concerns about the recent four inspections “pilot” in the Delta and that he now wishes for the agency to review other approaches to protect the health and safety of our state’s most precious resource.

Please be advised, on July 11, 2013, a report from the inspector general of the U.S. Department of Health and Human Services says Mississippi is violating federal rules by failing to enforce health and safety standards for home-based centers receiving federal subsidies. The report singles out Mississippi, saying it does nothing to comply. (Click here.)

Under new rules, the federal government is requiring unannounced inspections, a fuller background check, increased first aid and health training and a better definition of “physical safety” for In-Home child care sites.

In light of this, we ask Mr. Craig for his consideration of a what would be a much more responsible plan at this time. That is to say, first expend additional funds to implement a plan for monitoring the required health and safety standards for approximately twelve hundred home-based centers in Mississippi currently operating without regulation.

Mississippi State University has estimated that more than half of the state’s children are in unlicensed settings. Using CCDF funds to comply with the federal requirement to monitor home-based child care settings serving the majority of Mississippi’s young children would be a noble cause.

In the meantime, we thank him for his thoughtful leadership.

 

 

 


Equal Protection of the Law – Please Share With Hechinger

Equal Protection of the Law- Please Share With Hechinger

A law can be neutral on its face or in purpose, but still be applied in a discriminatory manner. In yick wo v. hopkins, 118 U.S. 356, 6 S. Ct. 1064, 30 L. Ed. 220 (1886).

“The equal protection guarantee extends not only to laws that obviously discriminate on their face,but also to government action having a discriminatory purpose, effect, or application.

Equal Protection Clause

The right of all persons to have the same access to the law and courts, and to be treated equally by the law and courts, both in procedures and in the substance of the law. It is akin to the right to due process of law, but in particular applies to equal treatment as an element of fundamental fairness.

“No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States.” (Click here.)

You may wish to share this post on your Facebook page and with The Hechinger Report, the Clarion-Ledger, the Board of Health, the Kellogg Foundation, MDHS (the CCDF Grant Administrator), Congressmen and legislators. 

Tell them the “experiment” touted (if not recommended) by The Hechinger Report below is a Violation of the Equal Protection Clause of the U.S. Constitution:

“Delta child care inspections to double”

(Click here to read full article.)

The Mississippi Delta contains the highest concentration of Black owned and operated child care small businesses in the poorest region of the state.

 

 

 

 

 


The Hechinger Report Supports MSDH Unlawful, Discriminatory Rule-Making as Experimental

The Hechinger Report Supports MSDH Unlawful, Discriminatory Rule-Making as Experimental

The Hechinger Report is sponsored by the Kellogg Foundation and partners with the Clarion Ledger.

The Hechinger Report has explained everything. (Click here.)

The MSDH licensing staff created undue burden and disparate impact racial discrimination on a disproportionate number of providers in a protected class as an “experiment”!

Disparate Impact racial discrimination and undue burden in Mississippi may be normalized as nothing more than an “experiment” by Jackie Mader and Sarah Butrymowicz, but for the vast majority of Mississippi Delta residents who are not white, it is demoralizing, terrorizing and oppressive.

Perhaps that is why, in order to show provider support of Violation of Mississippi Code, Violation of Administrative Procedures Law, Violation of the Equal Protection Clause of the U.S. Constitution and Violation of the Civil Rights Act, through increased frequency of inspections in the Delta only, the duo took to interviewing a child care provider just east of Jackson and one in Flowood!

We appreciate the attorneys, early learning professionals, Collaboratives and policy makers who have spoken with Delta child care providers, who do not support such arbitrary enforcement, for expressing concern for the development of a licensing police state when it is really uncalled for.

We agree, already, the Mississippi State Department of Health has the authority to inspect a licensed facility more than once a year if there is probable cause to do so.

Licensed providers, in turn, may lawfully require licensing officials to present an administrative inspection warrant for any regulatory inspection.

However, in this case, additional fines have been assessed and substantive and procedural rights have been affected without lawfully required adherence to fair rule-making.

We concur with all who are alarmed that fines collected by MSDH may support agency salaries in times of highly visible budget cuts.

We also question why MSDH did not just first seek the provider support Hechinger now so desperately attempts to do by presenting the new rule to the Child Care Advisory Council and holding a public hearing.

Why does MSDH (Jim Craig) communicate its intent and conduct through the media while making no formal announcement to those affected?

The blatant hostility and disrespect noted for licensed child care providers in this Hechinger series article and this MSDH misconduct is in direct defiance of DHS’s intent for increasing CCDF funding to MSDH for the purpose of meeting the new federal requirement to monitor unlicensed, In-Home providers.

Bottom line – The Mississippi Department of Human Services will determine how MSDH uses CCDF funding, hopefully, beginning today.

CCDF funding simply cannot be exhausted in violation of federal and state law, no matter how you spin it.

 

 

 

 

 

 

 

 

 

 

 

 


New Name – the Childcare Directors Network Alliance, Inc.

New Name – the Childcare Directors Network Alliance, Inc.

Deloris Suel, founding member of the Childcare Directors Network Alliance, Inc.,  has announced the new name of the organization – not to be confused with the former CDN.

Why?

CDNA is now officially affiliated and partnered with Jackson State University in the sponsorship of the annual MECA Conference and more!

For more exciting information on how you can become a CDNA member, contact Deloris Suel at dsuel@comcast.net .

JOIN TODAY!