101118.Final CCDF Preprint Comments

November 19th, 2010
Attention: ACF Reports Clearance Officer
Administration for Children and Families
Office of Administration
Office of Information Services
370 L’Enfant Promenade, S.W.
Washington, DC 20447
Re: Comments on the Proposed FY2012 – 2013 CCDF Plan Preprint

To Whom It May Concern:
Thank you for the opportunity to comment on the proposed Fiscal Year 2012-2013 Child Care
and Development Fund (CCDF) Preprint. Preschool California is an advocacy and policy
organization in California supporting increased access to high-quality early education including preschool
and infant and toddler programs. Research consistently demonstrates the importance of investing in

high-quality early education programs, particularly for low-income children. Given this, we
applaud the Office of Child Care’s effort to raise the quality of programs funded through CCDF
and are eager to work at the state level in California to ensure that this preprint helps to
incentivize higher quality programs and stronger accountability of programs and systems for our
youngest learners. The reorganization of the preprint is very clear and helpful to states in
planning their use of the CCDF funds. While we are pleased with the overall preprint, our
comments will focus primarily on section 3, ―Health and Safety and Quality Improvement
Activities,‖ as this section’s changes represent the bulk of the new direction of the preprint. We
are pleased to see the preprint emphasize accountability and child outcomes of the quality
dollars.
The preprint’s focus on the four quality components—licensing and health and safety standards,
early learning guidelines, quality rating and improvement programs and systems, and
professional development systems and workforce initiatives—demonstrates an exciting new
focus of the CCDF quality funds on systems integration.
Section 3.1, “Activities to Ensure the Health and Safety of Children in Child Care,”: This
section requires the lead CCDF agency to report basic licensing and health and safety measures
of CCDF programs back to HHS, and to develop a plan for improving the quality of the care of
these programs. This requirement is particularly important for California as our lead agency, the
California Department of Education (CDE), is not responsible for licensing child care facilities.
This section incentivizes the CDE to work closely with the Department of Social Services and
their Community Care Licensing Division to set benchmarks for licensed and license-exempt
child development programs, and to collect uniform data towards meeting improvement goals.
Section 3.1.2, which requires the lead agency to document current licensing enforcement and to
come up with a goal for improving that enforcement, is particularly critical for California. Given
our budget deficits, California has had to cut back licensing enforcement to one unannounced
visit every five years. Most other states conduct these unannounced visits multiple times per
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year. We appreciate the emphasis on creating a plan to improve this situation in California.
Finally, we very much support the focus on data in section 3.2.7, particularly data that
demonstrates child outcomes. Too often, health and safety data are not linked to child outcomes,
even though we know how critical these basic provisions are for a child’s learning environment
and brain development. In addition, given the large portion of our children that utilize licenseexempt care, it is imperative that we know more about the care that these children are in, do
more to help those providers meet basic health and safety standards and promote research-based
early learning standards.
Section 3.2, “Establishing Early Learning Guidelines,”: This section requires the lead agency
to develop, implement and track standards that are developmentally appropriate for child
development programs funded through CCDF. California has developed ―Preschool
Foundations‖ for curriculum standards in early learning programs. The Foundations cover four
areas, including social and emotional development, language and literacy, English language
development and mathematics. The California Department of Education is scheduled to release
additional foundations in the several years that include science, art and other areas of curriculum.
In addition to the breadth of areas that the Foundations cover, they are also developmentally
appropriate, differing by age. California is the only state in the country to have in place Infant
and Toddler early learning standards. We are very proud of these standards and are eager to build
upon them in the coming years to continue leading the nation in this area. Section 3.2.6 urges
that early learning standards be aligned with both Head Start and K-12 standards and curriculum.
This component is critical. One of the main charges of each state’s Early Learning Advisory
Council (ELAC) is to coordinate the various funding streams, curriculum and professional
standards of child development programs to provide seamless, integrated and aligned care for our
youngest learners. As California’s ELAC begins its work, it is critical that the council has the
incentive from the CCDF requirements to push it to align and coordinate curriculum and
standards between programs.
Section 3.3, “Creating Pathways to Excellence for Child Care Programs through Program
Quality Improvement Activities including Quality Rating and Improvement systems,”: This
section requires the lead agency to develop and integrate Quality Rating and Improvement
Systems (QRIS) with CCDF programs and quality improvement activities. The focus on QRIS in
the CCDF plan raises its importance and timeliness. The five elements—program standards, nonmonetary supports, financial incentives, quality assurance monitoring, and outreach and
consumer education—align well with California’s current work in developing a QRIS. In
particular, the link to licensing, focus on special needs children and dual language learners and
the focus placed on outreach and public education mirror the QRIS discussions in the Early
Learning Quality Improvement Systems Advisory Committee (ELQISAC) in California. As our
ELAC continues the work of the ELQISAC in implementing their QRIS design, the data
requirements for program quality established by section 3.3.7 will be extremely helpful.
Section 3.4, “Pathways to Excellence for the Workforce – Professional Development
Systems and Workforce Initiatives,”: This section focuses quality improvement activities
toward much needed workforce development. This piece is critical, especially in California
where our mixed delivery system and disparate higher education opportunities leave us with an
often uncoordinated professional development system for early learning. The ELAC will work
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over the next several years to develop a statewide workforce registry, and coupled with the
implementation of our QRIS, will begin to streamline the workforce development programs and
offerings in the state. As the ELAC and CDE begin this work, it will be helpful for them to
follow the guidelines of cataloguing the higher education capacity, the training and TA capacity,
as well as the overall compensation, benefits and working conditions of our early learning
workforce. The data requirements will be very helpful in beginning to plan for the necessary
programs to increase the capacity and bandwidth of our professional development system.
California is working hard to implement a comprehensive, aligned, quality early learning system.
The new requirements within the CCDF preprint will incentivize California to coordinate its
quality programs and develop goals for improving these programs. It will also incentivize
California to begin collecting the data needed to evaluate these programs based on child
outcomes and ultimately to benchmark that progress to move us toward the high-quality early
learning systems that our youngest learners deserve.
We thank you for your leadership on behalf of young learners in both subsidized and nonsubsidized programs and look forward to using the CCDF Preprint as a guideline for building
early learning systems in California that lead the nation.

Sincerely,

Catherine Atkin
President, Preschool California

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