Alyson Silkowski Institute for Children, Poverty, and Homelessness NAEHCY 2014 Annual Conference October 28, 2014 Creating a Child Care Subsidy System that Works for Homeless Families

Learning objectives What is the Child Care and Development Fund (CCDF)? How are states administering CCDF and to what extent are the needs of homeless families addressed? What’s the policy outlook for CCDF, and how can you support homeless families’ access?

Presentation Overview Homeless Families and Child Care Overview of CCDF CCDF Implementation at the State Level Policy Outlook at the Federal Level Q&A/Discussion

Homeless Families and Child Care Mothers who have experienced homelessness are more likely to use informal care and have work disrupted more frequently due to unreliable care They are also less likely to have received child care assistance Source: Institute for Children, Poverty, and Homelessness, Profiles of Risk: Child Care, Child Care Subsidy Receipt Among Single, Employed Mothers Using Child Care Poor but stably housed

Average Annual Cost of Center- based Child Care for a Four-year- old in 2012 (by state) Source: Child Care Aware of America, Parents and the High Cost of Child Care: 2013 Report.

Homeless Families and Child Care Barriers to Access: High cost of care Inflexible care arrangements Lack of awareness/information Lack of documentation Restrictive eligibility requirements

Presentation Overview Homeless Families and Child Care Overview of CCDF CCDF Implementation at the State Level Policy Outlook at the Federal Level Q&A/Discussion

What is the Child Care and Development Fund? Primary federal source of child care assistance for low- income families, serving nearly 1.5 million children each month Block grant providing over $5 billion annually to states, territories, and tribes Authorized under the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996 Administered by the Administration for Children and Families (ACF), U.S. Department of Health and Human Services (HHS)

Who is Eligible? Federal guidelines state that a child must: 1)be under 13 years old or under 19 and “physically or mentally incapable of caring for himself or herself, or under court supervision” 2)reside with a family whose income does not exceed 85% of State Median Income (SMI) 3)reside with a parent (or parents) who are working or attending a job training or educational program; or need to receive protective services

Who is Eligible? States: can prioritize certain eligible families (such as homeless families) set their own income eligibility limits set copayment levels and waive fees entirely determine reimbursement rates define what qualifies as work, training, and a protective services need

Who is Served? 1,455,100 children: 66% are 0-5 and 34% are ,200 families Children are served by 415,107 child care providers, in different types of care settings How many children are homeless is NOT known Source: U.S. Department of Health and Human Services, FY 2013 CCDF Data Tables (Preliminary Estimates, October 2014).

Presentation Overview Homeless Families and Child Care Overview of CCDF CCDF Implementation at the State Level Policy Outlook at the Federal Level Q&A/Discussion

CCDF State Plans Every two years, states are required to submit a plan to HHS describing how their CCDF programs will be administered over the following two fiscal years States must hold at least one public hearing to solicit feedback on a draft of the plan Plans are submitted on the July 1 st prior to the start of the fiscal year in which the plans become effective (Fiscal Year 2014–15 plans were due July 1, 2013 and became effective October 1, 2013)

CCDF Policies Policies described in the Fiscal Year 2014–15 State Plans for all 50 states and the District of Columbia: Eligibility and priority rules Job and housing search Documentation Cost of care Provider policies Continuity of care The CCDF Policies Database, 2012

Eligibility Protective Services: States are allowed to define children in need of “protective services” Six states (Arizona, Florida, Massachusetts, New York, Ohio, and Washington) include homeless children as an eligible “protective services” population  All but Arizona may waive the copayment and income eligibility requirements for these families; activity requirements still apply in some cases 39 states provide assistance to children receiving or in need of protective services

Priority Rules Priority Populations: States must prioritize “children with special needs” and “families with very low incomes” but can define those two groups Seven states include homeless children in one of these definitions: Delaware, Hawaii, Maine, Massachusetts, Minnesota, North Dakota, and Utah New Mexico and North Carolina indicate other priority rules are in place for homeless children

Priority Rules Priority Populations:

Job and Housing Search Job Search: Housing search : All but six states (Alabama, Louisiana, Michigan, Ohio, Virginia, and Wyoming) allow some subsidy recipients time to search for a job Time allowed ranges from 80 hours in Alaska to one year or more in the District of Columbia and Idaho Median time limit is 56 days Granted only for current subsidy recipients in 16 states Qualifying activity in some cases in seven states: California, Massachusetts, New Hampshire, New York, Utah, Vermont, and Washington

Documentation Documentation requirements: 24 states require families to provide birth records for the child in need of care or other documentation of the child’s identity or age States are not asked if they have grace periods in place for families to provide the required documents

Co-payments: Three states (Illinois, Maine, New Hampshire) require ALL families to pay a fee 35 states do not require a fee from some families at or below FPL 13 states do not require any families at or below FPL to pay a fee Cost of Care

Co-payments: Cost of Care

Co-payments: Cost of Care

Other fees: States may allow providers to charge parents the difference between the maximum reimbursement rate and their private rate, registration fees, for meals and incidental fees States were not specifically asked if providers are allowed to charge transportation fees in these plans, but they were in the plans and 40 states indicated that they do Cost of Care

Provider Policies Tiered reimbursement rates: Payment for absences: 11 states have higher reimbursement rates for child care providers who offer care during nontraditional hours Some states set a maximum number of billable absences per month or year, while others allow providers to bill for a full week or month of care as long as the child attended the program at least once

Continuity of Care Eligibility redetermination: Eligibility extensions: Two-tiered income eligibility: 27 states schedule redetermination at 12 months Some states may require interim reporting for certain populations (‘at-risk’ or ‘protective services’) 14 states extend period of eligibility for families enrolled in Early Head Start or Head Start 17 states set a higher income threshold for continuing eligibility

Additional Findings In total, 18 states mention homeless families in plan No state indicated that they collaborate with the State Coordinator for Homeless Education or school liaisons in creating or implementing the plan Two states (Arizona and Massachusetts) specifically indicated that a portion of funds dedicated to quality improvement will be used to improve services for and outreach to homeless families

Improving States’ Systems Prioritize and incentivize homeless families’ enrollment Coordinate with the State Coordinator for Homeless Education Incorporate shelters and other homeless service providers into outreach planning (via Continua of Care?) Establish contracts with homeless service providers Use quality improvement funds to improve homeless families’ access to, quality of and continuity of care

Presentation Overview Homeless Families and Child Care Overview of CCDF CCDF Implementation at the State Level Policy Outlook at the Federal Level Q&A/Discussion

Movement at the Federal Level House and Senate reached an agreement on the Child Care and Development Block Grant (CCDBG) Act House passed bill in September Senate will vote on bill in November Would be the first reauthorization in 18 years Bill makes significant health and safety improvements AND includes provisions to improve homeless families’ access to care 2014 set to be a historic year for CCDF!

Policy Change Improving Access to Child Care for Homeless Families Act of 2013 Child Care and Development Block Grant Act of 2014 Eligibility based on homelessness status ✔ Homeless children included as a priority population ✔ Coordination with programs serving homeless children required ✔✔ Funds should be used to ensure immediate enrollment of homeless children while documentation is obtained ✔✔ Immunization grace period for homeless children mandated ✔✔ States required to demonstrate that cost is not a barrier for homeless families ✔ Eligibility redetermination cannot take place sooner than 12 months ✔ Monthly data on homeless children’s enrollment required ✔✔ McKinney-Vento Homeless Assistance Act definition of a homeless child should be used ✔ Authorizes pilot program to identify best practices in serving homeless children ✔ Yes but “immediate” removed Yes but language weakened

What can you do? Educate and advocate for the policies discussed today. Find out who administers CCDF in your state. Participate in the CCDF plan public hearing process in your state. Provide feedback on what should be included in your state’s plan. When HHS releases new CCDF regulations, submit a comment. Let HHS know new provisions related to homeless children must be strong and clear.

Key takeaways state plans suggest that states have a long way to go to address the specific barriers homeless families face — firstly, experts on homelessness need a seat at the table — but some states have already taken steps to better facilitate homeless families’ enrollment When implemented, legislative and regulatory changes will bring important and long-awaited improvements. These developments at the federal level provide prime opportunities to raise awareness of the care needs of homeless families and children.

Learning objectives What is the Child Care and Development Fund (CCDF)? How are states administering CCDF and to what extent are the needs of homeless families addressed? What’s the policy outlook for CCDF, and how can you support homeless families’ access?

Presentation Overview Homeless Families and Child Care Overview of CCDF CCDF Implementation at the State Level Policy Outlook at the Federal Level Q&A/Discussion

Questions or Comments? Contact: Alyson Silkowski Institute for Children, Poverty, and Homelessness x. 1215