Online Market Rate Survey Due January 18, 2016 (See your Email In-Box.)

Online Market Rate Survey Due January 18, 2016   (See your Email In-Box.)

The scope of the current Market Rate Survey has been increased to account for not only market rate, but also provider cost.

DECCD has added a section to the Market Rate Survey to collect information regarding costs incurred by the provider for the provision of child care. 

Given provider feedback, DECCD now rightly suspects that many providers set their rates based on subsidy reimbursement rather than the actual costs of providing care. Therefore, DECCD designed the Market Rate Survey to include two very distinct sections.

The first section captures market rate information and WE FEEL SHOULD BE THE ONLY SECTION in a MARKET RATE SURVEY.

The second section is an additional optional page that captures provider costs information and one WE FEEL SHOULD BE A SEPARATE COSTS ANALYSIS SURVEY if designed to collect data other than market rates.

But for notice of a “Market Rate Survey”, DECCD has not convincingly explained its reason for wishing to conduct costs analyses, but it is not necessarily a bad thing.

In geographic areas of Extreme Poverty such as the Delta, the very low reimbursement rates paid by DECCD (the lowest in the state) may not cover the actual costs of providing proper care, let alone “high quality early learning environments”.  So the Administration for Children and Families has allowed alternative “costs analysis” to be conducted to better ensure equal access and more equitable resources to all providers throughout the state. The alternative information gathered in Part II could enable DECCD to set higher rates in the Delta than the geographic Market Rate Survey (Part I) process now allows.

The Problems:

HHS Psychobabble – The Administration for Children and Families has placed DECCD in an impossible situation with this unfunded mandate: DECCD is required to increase reimbursements from current 2004 Market Rates to no less than 2014 Market Rates and serve the same number of children… without any increase in CCDBG funding…(wait for it)…“to the extent that is possible”!  (LOL)  Psychobabble!

History – Providers feel recent past Market Rate Survey data has been manipulated by CCDBG funded sub-grantees conducting the collection of data to reflect a much greater percentage of market rates paid to providers than was actually so.

Providers believe CCDBG Funded sub-grantees did not weight or rule out the majority of surveys, most of which were completed by low-income providers that could not even report a market rate! (The DECCD CERTIFICATE VALUE IS NOT A MARKET RATE but rather, is only a percentage of a Market Rate. The market rate (price of care) is the fee per child paid by non-subsidized families for child care services!)

Given that sub-grantee conduct, it is difficult now for providers to work so intimately (to provide personally identifiable financial data) with those same people or to have faith in their knowledge and application of valid survey processes to combine two completely different sets of data for one outcome. 

Conflict of Interests -A CCDBG Quality set aside for expanded infant and toddler care (a current CCDBG Quality option) could help the lead agency to increase the rates while also helping to better maintain the current number of children served, but we do not feel we are likely to hear that recommendation from policy making sub-grantees positioned by DECCD to influence consideration of an award of a still greater percentage of CCDBG Quality funding to support their programs.  (Illinois, California and Louisiana sometimes issue a RFP for an outside, private business to conduct their states’ Market Rate Surveys!)

Accountability – The CCDBG requirement to conduct a Valid Quality Needs Assessment to identify and follow the will of the people in how millions and millions of quality dollars are to be spent in Mississippi’s 2016 State Plan (which involves the Market Rate Survey and the final determination of provider rates) has not even been mentioned, whispered, disclosed or completed by DECCD.

Psychological Prompts – Due to a provider’s Constitutional Right to Privacy, Part II of the “Rate Setting Tool” is  OPTIONAL.  You do not have to complete Part II to submit your Market Rate Data, BUT YOU WOULDN’T INITIALLY GUESS THAT BASED ON THE LANGUAGE USED BY DECCD THAT IMMEDIATELY EXCLAIMS AT THE END OF PART I:

“THIS SURVEY IS NOT COMPLETE.”

Such a declaration may be just enough to prevent providers serving middle to upper-income families (who are the only providers who can define the going child care rates) from submitting anything.

Only those who read further will see Part II is not required for submission.

Middle and upper-income providers have no incentive to participate in this process anyway and concerned provider groups have been given no guarantee that County Extension Field Representatives will visit middle and upper-income providers (with whom Extension Field Representatives likely have a professional/training relationship) in order to personally collect the appropriate market rate data (as we have suggested they might do).

Market Rate Surveys are Due January 18, 2016.

Providers may complete the online survey by clicking here:

https://msudafvm.co1.qualtrics.com/SE/?SID=SV_bNm7Kua5xFm3ey9

Participate as you see fit.


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!

 

 

 

 


US Commission on Civil Rights Meets Today: Is Mississippi’s QRIS effectively a Tool to Screen a Protected Group Out?

US Commission on Civil Rights Meets Today: Is Mississippi’s *QRIS effectively a Tool to Exclude a Disproportionate Number of a Protected Group from Top Tier Quality Bonuses and Pre-School Participation?

Open Meeting     Thursday     2 PM Central    

Call 888-505-4369   Give ID #4796911

Public Comment Period at the End

Disparate impact is a way to prove racial discrimination based on the effect of a policy or practice rather than the intent behind it.

For example, requiring all applicants for promotion (**or a reasonable increase from a percentage of 2007 market rates only through top tier quality bonus payments) to receive a certain score on a standardized test (or QRIS Evaluation) could adversely affect candidates of color.

Objective criteria, such as tests, evaluations, degree requirements, and physical requirements may be challenged under a disparate impact theory.

These cases rely heavily on statistics, published statements, data, and number crunching, which require assistance from experts and attorneys.

As an example, providers offer these statements to demonstrate potential intent to screen out and exclude a disproportionate number of people and minority owned small businesses through Mississippi’s Quality Stars:

“The QCCSS is an important step in identifying subpar centers, though the rating system does not directly measure child learning.”

Mississippi First- Leaving Last in Line

     Rachel Canter, Executive Director

 

“STAND YOUR GROUND LEGISLATORS, DON’T GIVE IN TO THOSE WHO WILL WHINE AND MOAN ABOUT HOW HARD THIS WILL BE ON SOME CENTERS. THEY NEED TO BE CLOSED AND REPLACED WITH ‘QUALITY’ OPERATIONS, NOT JUST SITES THAT MAKE A PROFIT FOR THE OWNER.”

Gulflive.com

education1st

Over a period of several months, the Mississippi Advisory Committee to the U.S. Commission on Civil Rights has heard testimony and received information upon which it has based the final draft of an Advisory Memorandum of Recommendations to Congress which address potential racial discrimination in the administration of the Child Care Development Fund in Mississippi. (Click here.)

In addition to requested redress of Mississippi’s QRIS, the Committee’s findings state, “a number of African-American child care facility owners continue to view at least some of the state’s administration of CCDF as intentionally discriminatory on the basis of race. In the example of the ***electronic finger scanning initiative, the state maintains the program purpose was to address fraud. Some providers however, saw it is as an unnecessary barrier intended to withdraw support from communities deemed unworthy.”

“Furthermore, shortly after the program’s cancellation, the MDHS announced that all TANF workplace participants, who had previously been working in child care facilities across the state, would be removed and placed at ****alternative work sites because child care providers were not hiring them when they had completed six months of workplace job training. Many child care providers however, saw the move as direct retaliation for their resistance to the finger scanning initiative.”

The Committee will meet today to agree upon its final draft Advisory Memorandum, Thursday, November 19th at 2pm Central time. All Committee meetings are open to the public. If you wish to address the Committee directly you may join the call by dialing 888-505-4369 and providing the conference ID 4796911. A public comment period will be observed at the end of the meeting.

Melissa Wojnaroski, Civil Rights Analyst with the U.S. Commission on Civil Rights, Midwest Regional Office in Chicago, has announced it is possible that the U.S. Office of Civil Rights Enforcement will conduct further, more extensive investigations of potential Civil Rights violations following the submission of the Mississippi Committee’s work.


* ” Child-Care Rating Systems Earn Few Stars in Study” – Ed Week (click here); “QRIS Rating Systems Do Not Improve Learning or Social Development for Children” – Rand study (click here).

**According to the MLICCI, base reimbursement rates for providers through the CCDF program are already low— approximately 60 percent below Mississippi’s market rate. As such, many providers who depend on these funds cannot afford to make the necessary improvements to achieve higher rating.

*** The Xerox e-Childcare finger scan method of payment was proposed by Jill Dent who served at that time as the DECCD Director at MSDH.  Regardless of her highly contested proposal/policies/ideology being defeated in State Court, Jill Dent was appointed and now serves as Director of the Department of Education’s Pre-K Collaborative which requires QRIS participation among child care providers and costly maintenance of mid to upper tier quality scores.

**** Newly developed alternative TANF work sites (post State Court) include new placements in Head Start Programs (also licensed for child care) even though it is most likely that participating Head Start Programs CANNOT hire the TANF workplace participants as teacher-aides unless or until the TANF workplace participants complete 12 units of college coursework or CDA classes to meet Head Start employment requirements.    Adversely impacted child care providers (including those who formerly hired TANF workplace participants) note Head Start is not funded by the Child Care Development Fund and therefore, Head Start programs are now favored by MSDH because they were not involved in public opposition to the proposed Xerox e-Childcare finger scan method of payment.

 

 


MS Advisory Committee to the U.S. Commission on Civil Rights To Approve Final Report Thursday

The MS Advisory Committee to the U.S. Commission on Civil Rights will meet Thursday by telephone conference to discuss approval for publication of an advisory memorandum regarding federal child care subsidy distributions in the State, and potential disparate impact on the basis of race or color. (Click Here.)

Disparate impact discrimination demonstrates an adverse effect of a practice (such as Mississippi’s Quality Stars) or standard that is neutral and non-discriminatory in its intention but, nonetheless, disproportionately affects individuals having a disability or belonging to a particular group based on their age, ethnicity, race, or sex.

Title VII prohibits use of neutral tests or selection procedures that have the effect of disproportionately excluding persons from Programs participation.

The Committee will meet next for final discussion and approval of this memo on Thursday November 19th at 2pm Central time.  All Committee meetings are open to the public. If you wish to address the Committee directly you may join the call by dialing 888-505-4369 and providing the conference ID 4796911.  A public comment period will be observed at the end of the meeting.

 


QRIS Final Evaluation Presentation Tomorrow! Yáll Come!!

FINAL EVALUATION_tomorrow


SECAC MEETING July 23, 2015 (Previous Public Comments on QRIS)

SECAC Council Meeting

July 23, 2015 10:00 AM – 12:00 Pm

Woolfolk Building Room 145

501 North West Street

Jackson, MS

MEETING MINUTES MAY 28, 2015, 10:00 AM – 12:00 PM Stoneville, MississippiPublic/Additional CommentsEllis said as a licensed childcare provider, she agrees the licensing process should collect the professional development information. She said she doesn’t know if MSDH can collect information that doesn’t involve licensing. She said regardless, the licensing application needs to be simple and clear so that it doesn’t become a headache for providers. She said in regard to QRS listening sessions and Frank Porter Graham, a disparate impact of QRS across Mississippi has been noted by the U.S. Commission on Civil Rights. She said it needs to be determined if the number of low-income or African American children are having an impact on QRS scores – that is, if there is a racial or class bias. She said QRS is expensive and does not measure child outcomes, so what is the point when there are disparate impacts on childcare centers? She stated that QRS needs to focus on helping private child care centers in a real way. Measuring student growth through assessment should be the measure on whether the assistance was effective. Centers need real help over time, not just one or two visits from a TA. She asked Dr. Smith to disseminate this concern. Dr. Parisi asked if there are specific findings that back up this concern. Ellis said yes. She said the fact that there are only two Delta facilities that have good QRS ratings over the course of eight or nine years is a finding that suggests there might be disparate impact. She said a disparate impact doesn’t mean the process is intentionally biased. Dr. Smith said when she sees a report on this subject, she will share it.

disparate impact discrimination Disparate treatment is one of the theories of discrimination under Title VII of the United States Civil Rights Act; the other theory is disparate impact. Disparate impact discrimination demonstrates an adverse effect of a practice or standard that is neutral and non-discriminatory in its intention but, nonetheless, disproportionately affects individuals having a disability or belonging to a particular group based on their age, ethnicity, race, or sex. Title VII also prohibits use of neutral tests or selection procedures that have the effect of disproportionately excluding persons in a protected class.


UPDATE: Workforce Investment Opportunity Act Public Hearing Change of Venue

UPDATE:  To be held at 239 N. Lamar Street, 12th Floor, Con.Room C

workforce meeing update

 

Workforce Investment Opportunity Act State Plan Public Hearing  July 22,2015     5:30 p.m.     MS Dept. of Education Auditorium     359 North West Street      Jackson, MS

SECAC Meeting     July 23, 2015      10:00 a.m.     Woolfolk Building Room 145     501 North West Street      Jackson, MS     Conference Call: (888)572-7734     Public comments are welcomed and received at the end of each SECAC meeting.

 

WIA Flyer

 

 


Frank Porter Graham QRIS Final Evaluation to be Presented July 29, 2015

FINAL EVALUATION copy


Pleas Continue for Increased Phase I Funding of “Flawed” Pre-K Collaborative Plan!

 

Update:

There was no increased funding for the Early Learning Pre-K Collaborative.

This provides opportunity to address flaws in the process of collaboration as well as the economic impact (to child care) of braided Head Start/Child Care Development Fund money used to finance a single child enrolled in Early Head Start Programs which are moving into full day/full year operations.

Remember to thank legislators for this needed period of Program redress.

 

Pleas Continue for Increased Phase I Funding of “Flawed” Pre-K Collaborative Plan!

Monday, March 23, 2015, Bobby Harrison of the Daily Journal Jackson Bureau reported that in the budget bill for education that legislators sent to Gov. Phil Bryant last week, funding for the collaborative is not increased, remaining at $3 million.

He stated, however, various sources have said recently that additional funds for the pre-K collaborative could be placed in other budgets during the final days of the 2015 session.

“The budget is not done by any means,” said House Speaker Philip Gunn, R-Clinton. “The budget decisions are ongoing.”  (Read “Plans to raise pre-K funding stalled.”)


On December 17, 2014 10:19 AM, the Hechinger Report (Columbia University) published the following: “Why Did Mississippi Lose out on Preschool Funding — Again?” (To read in full, click on this link.)

Mississippi’s flawed application and underdeveloped plans to provide preschool for all children is partly to blame for why the state’s youngest learners were bypassed once again for federal funds that could have provided a boost to early education, a review found.

Last week, Mississippi was passed over for a preschool grant that would have tripled the number of children enrolled in early education classes in four years, increased the number of highly qualified preschool teachers and boosted salaries, according to the state’s application.

The state scored seventh out of nine applicants for a specific preschool development grant, and is one of the only states in the South to lose out.

Officials who reviewed Mississippi’s application noted many deficiencies, including vague statements and an overall lack of evidence and details. “If Mississippi wants federal funds for preschool, it must first develop the “necessary infrastructure and capacity for scaling up a sustainable preK program.”

Danny Spreitler, a member of the state’s Board of Education and executive director of a foundation focused on early childhood, said that before the state applies for more grants, it needs to improve collaboration between state agencies and preschool programs.

“I honestly don’t think this is the time for us to be out here trying to figure out money, until we get our ducks in a row,” he said. We need to take this next year, 2015, and rather than look at massive expansion, we’ve got to get more reliable data on the programs that are working and sit down … look at what’s working,” and then “figure out how to take it statewide.”


During the development of Mississippi’s “flawed application”, Mr. Spreitler said he feared the plan was written to squeeze out private child care centers in favor of Head Start and school districts. (Click here.)

The 2012 Harvard Law School Legislative Recommendations for Expanding Early Childhood Education in Mississippi affirmed Mississippi voters support a pre-k program so long as it sets high standards, includes private providers and preserves local control.

 


Mississippi Preschool Enrollment Top Ten in Nation!

 

Child Care helps to place Mississippi in the Top Ten!

Top Ten in the Nation! copy