October 5, 2020
Deputy Mayor Kihn, Thank you for meeting with members of the DC child care provider community on Wednesday, September 23. As we shared with you, we are concerned about the timeline for the child care subsidy payment guideline changes and the lack of opportunities for input from the early learning community about these changes. Under the guidance updated on September 21, 2020, the child care sector is likely to be permanently damaged, resulting in an exacerbation of the District’s child care shortage. This guidance may also encourage providers to reduce or cease participation in the child care subsidy program to serve tuition-paying families, resulting in a loss of affordable infant and toddler seats in the District. A strong DC child care sector is indispensable to a strong economic recovery, and the subsidy program is an unmatched opportunity to stabilize and sustain it. To preserve this important sector and the number of available affordable seats, and to make it possible for early learning programs to continue providing quality care, we ask that you direct OSSE to:
● Delay start of new payment guidance to December 31, 2020: Providers need time to reopen safely and in a manner that is financially viable. As we shared, reopening entails taking time-consuming and costly measures to ensure the safety of children and staff and to comply with CDC and DC Health-mandated guidelines. These include restructuring existing space or identifying new physical space; purchasing supplies for multiple contained groups within a facility, hiring or rehiring teachers (many of whom have been furloughed or laid off in recent months); hiring additional staff to comply with group size restrictions, required classroom ratios, and other guidance; finding and purchasing limited-availability, costly, and often-backordered PPE and cleaning supplies, updating facility manuals and procedures, training existing and new staff on new guidelines; enrolling students; and many other measures. One month is not sufficient time to make these changes. Based on the experiences of providers who have already reopened, three months will allow child care businesses to take all necessary measures for reopening.
● Consult with providers in the development and implementation of guidance: Child care providers are best positioned to understand the impact of payment and other guidance on their businesses and on the families they serve. It is critical that OSSE work directly with them to develop guidance and plans for implementation to ensure the viability of the sector and to reduce the burden of guidelines on providers and families.
● Implement an emergency payment rate to account for losses due to COVID-19: Many providers, including those currently open and those temporarily closed with intentions to reopen, will experience significant payment drops as a result of the return to attendance-based payments. For many, returning to attendance levels prior to COVID-19 will be difficult or unachievable due to the impact of the restrictions necessitated by the health and safety guidelines, families’ reluctance to return their children to congregate care, and providers’ difficulty hiring sufficient staff. This will have a direct impact on payment amounts under OSSE’s new guidance and providers’ ability to stay in business and deliver high-quality programs.
Furthermore, providers are incurring increased costs to comply with health and safety guidelines, including the cost of PPE and cleaning supplies, additional staffing, learning supplies for and the cost of reconfiguring their spaces. To fairly support the majority of programs that will likely be unable to return to normal operating status while allowing flexibility for families seeking care and for providers enrolling new families, OSSE should implement an emergency subsidy payment rate to account for these unavoidable barriers to full enrollment, staffing, and attendance.
● Pay providers for virtual learning for all programs: Early learning programs have adapted to the needs and desires of staff and families who do not feel safe returning to congregate care by developing virtual learning programming. This has required an investment in supplies, technology, staff, and developing new lessons and schedules that are compatible with virtual learning. Virtual programs are an appropriate and valuable innovation that have allowed providers to continue supporting infants and toddlers’ learning and development, and to monitor children for developmental delays or child welfare concerns, and take action as necessary. As barriers to providing in-person care persist, OSSE should continue supporting this approach.
● Compensate COVID-19 absences: Discovery of a COVID-19 case or contact in a facility would result in the mandatory absence of an entire group of children and staff for up to 14 days. The updated payment guidance is not clear about whether group absences will be excused, and therefore paid, as is our strong recommendation. Providers should not be penalized for compliance with the law and protecting their staff and students. Clarity about payments will be important to providers’ ability to plan for and respond to such an incident.
● Issue waivers from licensing regulations to allow providers to use every available inch of physical space so that they may enroll as many children as is safe and possible.
● Exercise transparency about the subsidy program’s budget and expenditures It is critical that the District preserve high-quality, affordable infant and toddler early learning programs for the futures of its youngest residents and for the important role child care plays in DC’s economy. We hope that these recommendations and further conversations with the early learning community inform OSSE’s development and implementation of child care subsidy guidance. To ensure that this happens, we welcome any questions and the opportunity to continue working with you.
Sincerely, DC Association for the Education of Young Children DC Early Learning Collaborative DC Family Child Care Association DC Head Start Association Director’s Exchange Washington Association of Child Care Centers DC Action for Children