To Whom. The Child Care. Education. children and enacted in efficiency. EEBG, not a. then need

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1 March 15, 2016 California Department of Finance, Education Systems Unit 915 L Street Sacramento, CA Via to: Re: Early Education Block Grant To Whom It May Concern, The Child Care Law Center is the only statewide legal support center solely dedicated to ensuring that good quality child care and early education is available to every child, family, and community, with particular attention to the child care needs of those who are low income, have disabilities, or face other barriers to obtaining and keeping the child care they need. We offer this input in response to the Administration s proposal to consolidate funding for the California State Preschool Program (CSPP), Transitional Kindergarten (TK) and the preschool Quality Rating and Improvement System grant (QRIS) into a single Early Education Block Grant (EEBG), to be administered by Local Educational Agencies (LEAs). The Administrationn has directedd that the EEBG should target services to low income and at risk children and their families, consistentt with the Local Control Funding Formula enacted in We applaud the Administration s focus on low income early learners and on efficiency of funding streams, but have significant concerns about the EEBG proposal. I. The Budget Process Offers An Inadequate Forum forr Consideration of the EEBG Proposal During the four sessions that the Administration held to gather input regarding the EEBG, not a single voice offered unmitigated support for the proposal, nor support forr the budget process as a vehicle for working out acknowledged problems it raises. Thee Administration has offered further details in the May Revision. Under the structural limitations of the budget process, the EEBG proposal would then need to be finalized in the month between the release of the May Revision and June 15, 2016, when the state constitution requires the legislature to present a final budget to the governor for his signature. There is no policy benefit to this process in comparison with full, legislative deliberations, and there is significant potential for harm to our systems, childrenn and working families. Numerous, immediate opportunities exist to further efficiency in our early learning systems, which do not carry the risks of the EEBG. The state could direct the California Department of Education Early Education and Support Division (EESD) to work with contractors on reporting to the legislature by a certain date with a proposal to consolidate contracts for certain EESD programs, or with a proposal to streamline the state s complicated rate system for contractors, without creating a single block grant directed to LEAs. 1

2 II. Minimum Standards Should Embrace the Zero to Five Continuum, and the Full Day, Full Year Needs of Low Income Families A. Minimum Standards Should Bridge, Not Further Divide, Our EESD and K 12 Programs Standards for training and credentialing, staff ratios, monitoring, and other health and safety and quality guarantees should encompass all programs for children from birth to age five. Minimum standardss should not depend on whether the program currently sits within or outside of the Proposition 98 guarantee. If we want to build a bridge between the child care and early education system and the K 12 system, it needs to be a longer bridge, that encompasses infants and toddlers as well as three and four year olds. Otherwise, we only change the timing and nott the nature of the current schism. A longer bridge will require more, substantive conversations between the K 12 and early education communities than possible through the budget process, such as by including K 12 representatives on the State Advisory Council on Early Childhoodd Education and Care. B. Minimum Standards Should Be Consistent with the Child Care Development Block Grant To Support the Need of Low Income Children for Full Day, Full Year Programs Low income families need full workday, full year programs. Existing subsidized preschool programs rely on a range of federal, state and local resources to make such programs possible. Some of the funds that programs rely on, such as CSPPP and QRIS, sit within the Proposition 98 guarantee, but others do not, such as General Child Care Program contracts, or Alternative Payment Program vouchers in programs that are not fully contracted. Some of the funding streams that programs layer includee Child Care and Development Block Grant (CCDBG) funding. The CCDBG Act of 2014 ( Reauthorization )) and proposed federal regulations that are expected to be finalized this summer, include numerous provisions relevant to standards for training and credentialing, staff ratios, monitoring, and other health and safety and quality guarantees. The need to create a bridge encompassing programs for children from birth to age five; the need to create programs that can meet the full day full year needs of low income families; and, the need for many existing programs thatt already include CCDBG funds to comply with Reauthorization all demand that we first determine and then consistently apply the standards by which California plans to comply with Reauthorization, before developing potentially conflicting standards. Similarly, monitoring and compliance occur in existing EESD programs through the Community Care Licensing Division s Child Care Licensing Program ( Licensing ), through EESD reviews, and through the unrelated QRIS system. The EEBG would dissolve the QRIS system, and create LEA basemonitoring. The CCDBG programs potentially outside either Licensing or EESD health and safetyy and quality further requires the State to create a system for monitoring compliance with CCDBG health and safety and quality standards. Rather than risk lack of regulation or a duplicative system, we should first establish a CCDBG compliant monitoring system for all early learning programs. 2

3 III. The EEBG Should Support Our Existing Strongly Local and Targeted Early Education System The Administration n has repeatedly emphasized that its goals are targeting of funds and local control. The CSPP has always means tested and targeted low income families. And the child care and early education system, which includes the CSPP, operates within an elaborate system of local resource and referral programs and local planning councils designed to assess and meett local needs. In contrast, LEAs have not historically targeted children and families based on income or developed early education standards, and the EEBG proposal comes at a time when theyy are still adjusting to the targeting demands of the Local Control Funding Formula, and the needd to adjust developmental orientation in implementing TK. Targeting low incomthat low income families need. This in turn dictatess the definitions of age, income or at risk eligibility, and priority for service. Programs and families benefit from consistent definitions of eligibility and priority to meet this need for ull day/full year care. Eligibility and priority standards that are families further requires ensuring access to the full day/ /full year programs consistent across EESD programs best achieve this goal. IV. Funding Mechanisms Must Ensure A Robust, Mixed Delivery System. A. Funding Must Come First The California Department of Finance has confirmed thatt the EEBG does not include additional funding for early education programs, because the Administration believes that early education program reforms (i.e., targeting funds to those most in need,, aligning funding with local priorities) are needed before additional funding is provided to these programs. Yet in the K 12 context, the Administration has recognized that sweeping changes requiree substantial money and time. To achieve in the K 12 system the reforms it sets as preconditions for funding in the early education system, the Governor s budget allocates $2.8 billion for implementation of the Local Control Funding Formula (LCFF) for school districts and charter schools its largest Proposition 98 funding increases. Instead of adding funding, governor s proposal would eliminate the historic entitlement to school for children who turn 5 by September of the year they enter school. By consolidating g TK, which is based on Average Daily Attendance, into a limited block grant with the discretionary CSPP, the proposal threatens to reduce overall funding and public early education opportunities for children birth to age 5. Without additional funding, there is simply no way thatt the proposed reforms could occur without harming the opportunities of the young children and families the system currently serves. Moreover, under the EEBG proposal, programs that currently have large, low income populations in addition to TK enrollment will be disadvantaged compared too those with small, low income populations and the same levels of TK enrollment. Thus, in contrast to its stated purpose to target funds to low income students, the EEBG risks allocating less funds to districts with more low income students and more funds to districtss with fewer low income students. 3

4 B. Funding Must Ensure A Mixed Delivery System Current programs for three and four years olds, includingg the CSPP, operate within a mixed delivery system that includes both centers and licensed family child care homes, non profit and for profit programs, large and small, free standing and on school sites. Maintaining this mixed delivery system is fundamental to parent choice and a holistic approach to earlyy learning in the zero to five age group. Our mixed delivery system is also necessary to maintain capacity other jurisdictions that have enacted broad preschool expansions, such as Oklahoma and New Jersey and New York City, rely on a combination of private and public providers subject to qualityy standards to meet capacity needs. The mixed delivery system is further integral to meeting the needs of low income working families, who disproportionately need extended time, year round programs, which are difficult to reconcile with the scheduless and competing facility and staff needs of LEAs. Wee are also informed that LEA policies and union contracts prevent contracting between LEAs and community based programs in some localities. Mixed delivery child care providers contracted under state and local programs, use a variety of creative ways to supplement funding, which would be burdened under the Administration s proposal. An example are so called title 5 preschool programs that are not fully contracted by EESD, and instead contract to offer half of their spaces at little or no cost to low income families, while maintaining half on the free market for purchase by families, with or without child care and early education vouchers. Another example is Preschool For All, which First 5 San Francisco administers through a mixed delivery system of community based, public/private programs. The EEBG, by directing all early education funding through LEAs, does not mesh as well as our current funding system with either of these two approaches. C. We Should Not Suppress Funding For Early Education By Eliminating The Entitlement For Children Historically Served In the K 12 System. The Kindergarten Readiness Act of 2010 (Chapter 705, Statutes of 2010) amendedd the Education Code to change the required birthday for admission to kindergarten and first grade. At the same time, it established the TK program for the children with fall birthdays whom it att the same time locked out of Kindergarten. The EEBG says to the same group of children: some of you will continue to have a right to start school in the year you turn five, but some of you will not, depending on local decisions. Thus, the proposal to consolidate the entitlement TK program, currently based on Average Daily Attendance, into a limited block grant with the discretionary CSPP, will reduce overall funding and public early education opportunities for children birth to age five. 4

5 D. The Carve Out for Community College Funding Fails To Recognize Its Distinct Role, And Riskss Creating An Insufficiently Funded, Parallel CSPP California s community colleges often rely on braided funding from multiple sources, including both Proposition 98 CSPP and non Proposition 98 child care funding to fulfil the important, multiple purposes of the early childhood education lab schools. These lab schools not only provide child care for low preparing for a teaching certificate or degree. The carve out for these programs within Proposition 98 CSPP, which income student parents, but also provide supervised clinical experiences for student teachers is otherwise is directedd to the EEBG, would create a parallel preschool program subject to potentially different standards and requirements than preschool programs administered through LEAs, and yet with funding insufficient to meet the more extensive purposes of community college lab school programs. Provisionss for funding to community college lab school programs should instead recognize their unique role and complex purposes. Sincerely, Anna Levine Senior Staff Attorney 5