FFYF Submits Comments on 2023 Child Care and Development Fund NPRM

On July 13, the Administration for Children and Families (ACF) announced a notice of proposed rulemaking (NPRM) that would strengthen the Child Care and Development Fund (CCDF) – the program that includes the Child Care and Development Block Grant (CCDBG) and supports 1.5 million children and their families each month with child care assistance. This NPRM proposes a variety of changes to lower the cost of child care for families, improve child care provider payments and practices, streamline the eligibility and enrollment process for families, and make other technical changes to improve clarity and program implementation. While this NPRM doesn’t come with any new funding, it does build upon Biden’s recent executive order to increase access to high-quality care and support caregivers. 

FFYF submitted comments highlighting several proposed improvements that will strengthen early care and education (ECE) systems, and discussed areas for further thought. FFYF applauds ACF for proposed changes that will allow children, families, and providers to have a better child care experience, including:

• Capping CCDF co-payments at no more than 7% of an eligible family’s income;
• Paying providers prospectively and based on enrollment rather than attendance;
• Encouraging Lead Agencies to waive co-payments for families with incomes up to 150% of the federal poverty level (FPL) along with eligible families caring for a child with a disability;
• Requiring Lead Agencies to post clear, accessible information about their co-payment sliding fee scales online; 
• Requiring Lead Agencies to use grants and contracts to build child care supply in underserved areas and for underserved populations;
• Clarifying that Lead Agencies may pay amounts above the provider’s private pay rate to support quality, offset the costs of providing care, and support the continued stability of providers; 
• Expediting families’ access to services by facilitating presumptive enrollment and encouraging an online application option.

FFYF also proposed a variety of recommendations including suggestions to ensure these changes have strong monitoring and enforcement mechanisms so that providers do not see their payments decrease, that families have access to information they need to make informed decisions about child care and will not experience an increase in costs, and to establish clear guidance paired with supportive assistance for states to implement these changes fully and faithfully. 

Without additional funding, it may be challenging for states and territories to implement the proposed rules, forcing Lead Agencies to make difficult choices that could compromise the quality and accessibility of care. Ultimately, significant and stable investments from Congress are needed for CCDF to effectively support all eligible families in accessing quality child care programs. 

The full text of the letter appears below.

Download8.25.23-FFYF-2023-NPRM-Comments-pdf.pdf (154.54 kB)