Office of Child Care inquiring what should be included in State Child Care Development Fund plans

Update – The Afterschool Alliance has drafted comments on this notice that can be reviewed here.

The three-year cycle for State Plans for Child Care and Development funds is upon us, and the federal government is now providing an opportunity to comment on the form states must fill out to get their plans approved. The document, known as the FY2025 – 2027 Child Care and Development Fund Preprint, can be reviewed through August 27, 2023.

After the review, the Office of Child Care (OCC) at the US Department of Health and Human Services (HHS) will finalize the pre-print. States, in collaboration with partners and stakeholders, including statewide afterschool networks, will then use the pre-print to determine how they will implement the almost $11.5 billion annually that comes from HHS to support low-income working or schooling families with high-quality child care options for children ages 0 to 13.

After drafting responses to the pre-print and no sooner than January 2024, states will need to open their plan for review and feedback, including holding at least one public hearing that is widely publicized with a minimum of 20 days’ notice (see pre-print section 1.3.2). The plan must specify how public comment was taken into consideration.

After submission to and approval from the OCC, the plans will go into effect beginning October 1, 2024.

The state plans, as set out in the pre-print, will need to include information critical for school-age providers, including how the state will require licensing and license exemptions, state policies for background checks, state requirements for health and safety training, state investments in program quality, state use of grants and contracts, school-age appropriate professional development, in staff supports, adoption of any school-age standards or accreditation processes, and what the state will include in its consumer education databases. States have 9 percent of funds they must spend on increased program access and quality, and the plan will also account for how states endeavor to invest these funds. Plans also set out key elements of program access, such as income eligibility and co-payment criteria for families, payment rates for providers, and serving special populations.

The 2025-2027 CCDF Plan Pre-Print significantly mirrors the last pre-print cycle in 2022-2024, under which states are currently operating. A few newer areas include more detail on the background check process that states have in place to ensure a clear, timely response for providers and additional focus on the needs of staff supports such as bonuses and stipends, health and leave benefits, and paid training such as scholarships, tuition support, or debt relief. The new pre-print also suggests that paying providers at a market rate percentage lower than 50 percent does not allow equal access for families and will not be accepted by HHS. The previous cycle set the minimum at 25 percent.

School-age children make up 45 percent of those served with CCDF funds, and school-age-only providers often need their own set of considerations in order to ensure access and quality, including:

• Different health and safety requirements. For example, being trained in trauma-informed care, mental health first aid, and early adolescent development rather than safe sleep practices for infants.
• Different licensing requirements. For example, having staff trained in youth development and recreation rather than a degree in early care and licensors trained to observe and support school-age settings
• Different physical setting requirements. For example, policies that support access to subsidies for children served within their school-day buildings or policies that allow transportation on the buses used for the regular school day
• Separate School-Age Quality Standards to participate in quality improvement systems that are designed around best practices for school-age youth

Most importantly, school-age families, statewide afterschool networks, and school-age providers need to be represented at every stage in the CCDF planning process to ensure that a continuous, connected system of quality care is available as children age and develop.

The Afterschool Alliance will submit comments on the pre-print and share our comments in an upcoming blog. The OCC has been responsive to input from the field in the past, and as a result, each year, an increasing number of sections in the plan do specifically mention the needs of the school-age population. Friends of afterschool are encouraged to submit their own comments on the pre-print and are also welcome to echo our own.

Additionally, it is a great time to start connecting with the State Child Care Administrative Agency in your state (you can also contact a regional administrator for a connection) and your Statewide Afterschool Network to ensure you are part of the upcoming planning process and that school-age children and the programs which serve them are an integral part of the state’s overall vision for the next three-year cycle.