Provider Viewpoint: Proposed child care regs address quality but ignore cost

Update: In today's Washington Post, a critique of D.C.'s tough licensing requirements for child care providers. Read the story here.

Editor's Note: On July 30, the D.C. Office of the State Superintendent of Education (OSSE) released proposed amendments to the District’s Child Development Facilities Licensing and Fee requirements. (View them here.) The public comment period was slated to end August 31, but the agency extended it to the end of this month to give people more time to review and weigh the changes.  

The following perspective is from Dr. Robert Gundling, an early childhood educator in the District. The views expressed are his own and do not necessarily reflect those of DC Action for Children.We note that D.C.’s child care regulations are rated second in the nation by NACCRRA, the National Association of Child Care Resource & Referral Agencies. 

OSSE’s proposed changes are appropriate and what early childhood professionals aspire to provide to the children and families in their programs. They reflect a shared commitment to ensure that the health, safety and well-being of each child is guaranteed and that there are program and service operating expectations that reflect current research and effective practice in the Early Care and Education field. They also create the opportunity to move forward in creating high quality programs and services.

However, the proposed regulations continue to ignore the true cost  that providers must pay to implement the regulations. It is easy to write the regulations when there is no requirement to make sure they are realistic and affordable to those operating programs. The danger is this thinking leads to unrealistic requirements that make it challenging at best and impossible at worst for some community-based providers to stay in business. The potential consequence is fewer licensed facilities with unregulated services for the families who need affordable child care in their communities in order to be able to work and earn a living. 

With fewer licensed facilities for parents to rely on, the desired outcomes for children are compromised. We risk undermining the success thus far in creating and sustaining high quality programs and services for young children, their families and the professionals who work with them.

OSSE should be congratulated for creating regulations that are in the best interest of the children. However, the agency should be expected to provide the leadership necessary to make it possible for community-based programs to obtain the funds to meet the regulations. This includes a robust grants program, public/private partnerships that provide opportunities to obtain the funding and resources necessary to meet the regulations and the creation of a licensing subcommittee of the Early Childhood Council, responsible for monitoring implementation and recommending changes that make the regulations realistic and possible for providers at attain.

Some specific issues and recommendations:

  • With the D.C. government’s commitment to universal Pre-K, it seems appropriate that all Pre-K programs, regardless of where they are housed, should comply with the regulations. That means, as a part of education reform, public schools, including charter schools, should be required to comply with the regulations. 
  • There should be an asset-mapping project to determine if there is the capacity to enroll early care and education teachers in higher education programs where they can earn the degrees necessary to keep their jobs. There should also be a report showing how the funds will be provided to make sure teachers of young children, regardless of where the program is delivered, are compensated at comparable levels, based on their qualifications and experience.
  • OSSE provide public with a report that lists the changes in the proposed regulations, justification for the change, benefit to children and the true cost for complying with the regulations added in the proposed regulations.
  • Since OSSE is including regulations that deal with program items, OSSE licensing staff should meet the qualifications of a director.