You Have a Second Chance – Comment and Have a Voice about The Federal Rules that will Regulate Your Child Care

Every single child care provider should be commenting on this proposed rule and we all have a second chance to do it!  This is your opportunity to tell the federal government, from your working and caring perspective, if you support this rule, think parts of it are unmanageable or if something should be considered that they haven’t thought of. 

Your thoughts count.  Federal agencies are REQUIRED to read what you have to say.  Learn about the rule.  Child Care Aware did a series of webinars and has a website dedicated to it.  Read through or watch and understand what you are commenting on and then go for it.  New Deadline is August 23 to comment.  I encourage you to comment even if you don’t agree with the below. This is your business and your future.

Child Care Development Fund Rule

Comment Now: Child Care Development Fund

It’s time to understand how the Child and Adult Care Food Program Model Comments affect you and your operations.  These are the recommended model comments, make them your own or use exactly what is on the model comment.

Now I ask you to turn on your imagination.  Get in your Delorian or other time travel contraption of your choice and place yourself in your care 3-5 years from this very moment…

First

You call your friend irritated because you just had your 4th announced visit for monitoring purposes. So many visits between the CACFP and the new ones set forth because of the new regulation.  While you are venting you remember those emails you got encouraging you to comment on the Child Care Development Fund Proposed rule.  Now you wish you could go back in time.

If you could go back in time, you would use the first recommendation from CACFP leaders regarding the CCDF rule which recommends that the unannounced visits done by the CACFP monitor with which you already established a relationship meet the required “on-site monitoring visits in the proposed rule.”

CACFP Leader Comment 1

1.  Recommendation:  Providers participating in CACFP should be considered to have met the proposed new requirement for child care providers to be subject to on-site monitoring, including unannounced visits.  (45 CFR 98.41(d)) 

We agree with the Office of Child Care’s recommendation in the rule that CCDF Lead Agencies “to coordinate with other entities that already have inspection and on-site monitoring mechanisms” including CACFP.   CACFP monitoring visits should meet the proposed new on-site monitoring requirement for providers to receive subsidy.   Providers participating in CACFP should be considered to have met the new proposed requirement for child care providers receiving subsidy payments to be subject to on-site monitoring, including unannounced visits.   Child care providers can submit documentation of CACFP participation to certify they have met the new on-site monitoring requirement.

Second

You just got notice that you have to do nutrition training.  You call your CACFP sponsor and say "but I already did this training."  Your sponsor informs you that the nutrition training requirement notice was not for CACFP participation it was for the new CCDF regulation.  Then you remember seeing something about this in the recommended comments from our CACFP Leaders.

If enough of us had commented to encourage the rule makers to accept CACFP nutrition education as training hours for the new nutrition training requirement we wouldn’t have to fit yet another training into our schedule.

CACFP Leader Comment 2

2.  Recommendation:  CACFP nutrition education should qualify as training hours to meet the new child care nutrition training requirement for providers.  (45 CFR 98.41(a)(3)(vi))

CACFP nutrition education should qualify as training hours to meet the new nutrition training requirement:  “age-appropriate nutrition, feeding, including support for breastfeeding, and physical activity.”  CACFP nutrition education is free and focused on helping to facilitate low income providers understanding of early childhood nutrition and feeding with the benefit of observing meals served in child care.  Consistent with the Healthy, Hunger Free Kids Act CACFP is required to provide nutrition and physical activity education and training.  State Lead Agencies can coordinate with the CACFP agencies and sponsoring organizations to allow providers to meet the new nutrition training requirements through CACFP nutrition education. 

Third

Sometimes it doesn’t feel like it’s worth it to participate in the food program.  You know it should be an important factor to parents but sometimes parents don’t understand how CACFP participation reflects the quality of your care.  Recommendations 3 and 4 will help you teach and show parents how participating in CACFP doesn’t only provide their children with nutritious meals but ensures the child care environment is “safe, healthy and nurturing.”

CACFP Leader Comments 3 and 4

3.  Recommendation: Include CACFP participation as a minimum reporting requirement for provider-specific quality information posted on the user-friendly web-site, and the report to parents on the qualifications of the provider they have chosen.  ((45 CFR 98.33(a)) and 45 CFR 98.33(c))

Reporting on CACFP participation will strengthen the important new requirements focused on providing comprehensive consumer education.  A robust accounting of provider qualifications, certifications, and licensing status including CACFP participation will be very useful to parents. 

4.  Recommendation: Include CACFP participation as one of the indicators of quality in the “transparent system of quality indicators” including QRIS systems. (45 CFR 98.33(b)) Non-CACFP eligible providers would be required to meet the CACFP standards.

Including CACFP participation as a quality indicator will help realize CCDF’s goal to “serve children in safe, healthy, nurturing child care settings that are highly effective in promoting learning, child development, school readiness and success.”  As the rule preamble points out, CACFP supports good nutrition in child care, “research has shown that public programs can improve the nutritional quality of the food, as children who receive food through government-regulated programs (e.g., the U.S. Department of Agriculture Child and Adult Care Food Program) eat healthier than those bringing food from home.”  The research and reports have identified CACFP as key to preventing obesity and supporting good nutrition in early childhood settings.   In addition, studies, including U.S. General Accounting Office and HHS supported research, have shown CACFP supports not only good nutrition but also quality child care.

Comment on the regulations that will govern your business.  Second chances don't always present themselves.  Comment now.

Comment

Samantha Marshall, M.A.

Samantha is, just like you, excited to make a difference in our community and our world. With a Master of Arts degree in English Literature, you might ask how she found herself building and writing for a website focused on child care. From 1995 through 2001, Samantha started her career working for Child and Adult Care Food Program (CACFP) sponsors which introduced her to the importance of non-profits, community and quality child care. Her experience with Sponsors, State Officials, and Family Child Care Providers left a great and lasting impression. Later in her career and her most recent position at SAGE Publications, an academic publisher, was as a product manager for a new online resource! During this time many of Samantha's passions collided. A love for the written word, children and the proliferation of knowledge as well as a fascination with the resources the internet gives us, building a community for child care on ChildCareInfo.com is the perfect way to make the difference she wanted to. Needless to say, she is very excited to be an active part of creating and building ChildCareInfo.com.