MISSISSIPPI LOW-INCOME CHILD CARE INITIATIVE

MISSISSIPPI’S CHILD CARE AND

DEVELOPMENT FUND AT 20:
A CRITICAL MOMENT FOR LOW-INCOME WORKING
FAMILIES AND DECISION-MAKERS

Matt Williams
Director of Research
October 2018
“ Topsy Turvy”
During its first twenty years, Mississippi’s Child Care and Development
Fund (CCDF) program has gone through many, varied changesi:

- it was called the certificate program but is now the Child Care
Payment Program (CCPP);
- its administration has been de-centralized at a regional level and is
now centralized
- its caseloads have risen, and dropped, and risen and dropped;
- its parental redetermination was every 6 months, then once a year
with a rollover by priority group on September 30th, to every 12 months
with no rollover;
- its quality enhancement has gone from Child Care Connections
Mobile Training Vans travelling the state in 1999 to the OCY Director’s
Credentialing training as the sole contracted training to the expensive
(and unfunded) Quality Rating System (QRS) to Standard Centers
potentially accessible (and mandatory) for all in 2018;
- its priority populations have gone from very few to many;
- expenditures have gone up and down, up and down;
- its eligibility and documentation requirements have gone from
simple, to complex, to punitive, back to simple;
- it had a “waiting list” and now it has a “Pending Funding list”, which
has ballooned to more than 20,000 and been completely eliminated in a
matter of one year for better and worse;
- its special initiatives to reduce fraud include proposed biometric
finger scanning of parents (2012) and one of the most rigid CCDF proof
of residency policies ever implemented by a state (2016)

Many changes have occurred in Mississippi’s CCDF program over the

years. This report shows that expenditure decisions and policy decisions
greatly influence how many working parents and children are receiving
assistance at the end of the day.

While the following report offers many findings about CCDF in

Mississippi, we attempt to lift up one fundamental observation: that is,
when Mississippi spends more on direct services, it serves more children
and more parents can work or attend training or education. When the
state increases spending on non-direct services, when it makes mass policy change
or drastically reconfigures programs without adequate consideration of the end-user
experience of CCDF, the level of children served tends to reduce.

While the state’s CCDF program has been no stranger to redesign and revamping
through the years, here’s what hasn’t changed in Mississippi through all of this,
since the 1998 CCDF Final Rule went into effect:

The rate of single moms at or below poverty who can’t afford child care and
need to work and gain skills to earn a living wage hasn’t changed.ii

Poverty Among Single Mother-Headed Households Hasn't

Changed in Mississippi
60%

50%

40%

30%

20%

10%

0%
Poverty Rate of Single Mother-Headed Households

2005 2016

The number of young, low-income children who live with a working parent
hasn’t changed. The number has hovered between 100,000 – 110,000 for many
years.iii

The percentage of young, CCDF-eligible low-income children actually served

has remained extremely low. It has hovered between 10%-20-% for years.iv

The race and ethnicity of those Mississippians who participate in CCDF hasn’t
changed since this data has been collected and made available. Over the life of
Mississippi’s CCDF program, about 9 out of every 10 children served by the state are
African-American.v

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 The Mississippi Low-Income Child Care Initiative (MLICCI) was founded the day the
1998 CCDF Final Rule went into effect. MLICCI remains an organization focused on
and committed to CCDF policy and mitigating its negative impact on parents and
providers, lifting up its positive impact and creating additional economic security
solutions for low-income mothers and their families. Now, in 2018, we offer the
following report looking back on CCDF in Mississippi. Particularly, we hope this report
can provide policymakers with some lessons learned and inform recommendations for
where CCDF may be headed in Mississippi.

CCDF Policy Background

Prior to CCDF, child care assistance to states came from the Child Care and
Development Block Grant (CCDBG) Act of 1990 and from multiple streams of funding
under Title IV-A of the Social Security Act. The Personal Responsibility and Work
Opportunity Reconciliation Act (PRWORA) of 1996 repealed former child care
assistance programs that were authorized under Title IV-A of the Social Security Act
and amended Section 418 of the Social Security Act to provide new child care
entitlement and matching funds to states. The PRWORA also amended the CCDBG
Act of 1990, renaming CCDBG funds Discretionary funds and authorizing newly
approved mandatory and matching funding streams under Section 418 of the Social
Security Act to fall under CCDBG Act rules. The newly combined and unified child
care funding streams were titled the Child Care and Development Fund (CCDF). In
1998, the United States Department of Health and Human Services (HHS)
Administration for Children and Families (ACF) Office of Child Care (OCC) finalized
federal rules for CCDF and in August of that year the CCDF Final Rule went into
effect.vi

The Critical Need for Affordable

Child Care in Mississippi
There is a critical shortage of affordable child care in Mississippi. This shortage keeps
moms from achieving economic security for their families. An adequate supply of
affordable child care would greatly strengthen efforts made by public and private
entities to increase the state’s labor market participation rate by increasing

4
participation and retention of parents in jobs and in workforce training programs.
These are all strategies aimed at strengthening women’s economic security in
Mississippi. Affordable child care is a critical element of a mom’s economic security—
particularly, a single mom who heads her household without the support of a partner
or spouse. But even low-income two-parent households struggle to afford the cost of
child care.

No matter how the

data is sliced, the
number of children
with low-income
working parents in
Mississippi who
need child care
assistance
consistently
overwhelms the
number who receive
CCDF. In the below
figure, we offer an
illustration of how
limited affordable
child care options are for low-income working parents with young children.

Using the National Center for Children in Poverty’s (NCCP) estimate of the number of
young children (under the age of 6) who are below 200% of the federal poverty level
(approximately in line with MS CCDF income eligibility for a family of 3) and who live
with a working parent as an approximation of CCDF-eligibility, we look at how many
of these 102,268 CCDF-eligible young Mississippi children may be receiving
assistance through CCDF or through another public program. This proxy variable for
CCDF-eligible children reflects only children under the age of 6 even though CCDF
serves children up to age 12 (though, about 60% of the monthly average number
served are below the age of 6). We use federal monthly average caseload data
showing the distribution by age of CCDF recipients and we derive an estimate for the
number of children under age 6 receiving CCDF assistance in Mississippi each
month, on average. There are far fewer affordable childcare options for low-income
working parents with children between 6 and 13 years, so the gap in those eligible
between ages 6-13 versus those served is even more significant than the gap among
young children. There may be some degree of overlap between children served by
5
CCDF and Head Start/Early Head Start, potentially double-counting some of those
included in the number served in this illustration and public pre-K serves 4 and 5 year
olds.vii

To illustrate the magnitude of the unmet need for affordable child care in Mississippi,
the below figure provides the number of children reported to be served by Head
Start and Early Head Start, the number enrolled in one of the state’s public pre-K
programs, the monthly average number of children under age 6 receiving CCDF
assistance and the number of low-income children with a working parent under age 6
likely not receiving assistance from any public child care or early childhood program.
The most recent data for each of these categories was used for the below graph.

More than 60,000 young, low-income children living with a working parent are likely
disconnected from any publicly available Mississippi early childhood program.

102,268 Potentially CCDF-Eligible Children Below 6 years of age

70,000
60,614
60,000

50,000

40,000

30,000 24,307

20,000
10,440
6,907
10,000

0
Served by Head Start/EHS Enrolled in Public Pre-K Served by CCDF (Under Not Served by Any Publicly
Age of 6 - Monthly Available Early Childhood
Average) Program

Potentially CCDF-Eligible Young Children

Child care policy issues rest at the intersection of race and gender. More than 90% of
children receiving CCDF assistance in Mississippi are African American and most
working CCDF parents are mother breadwinners and single-heads of household.viii

Child care can be transformational for parents, particularly single mothers. Because
child care assistance is so limited, low-income single moms, who earn less than
$20,000 annually on average in Mississippi, have few options and child care can often
be one of their largest household expenses.ix When a parent can’t afford child care, it
results in a financial loss for the family when they are forced to quit work or reduce

6
hours to provide care. When a parent has access to a CCDF voucher it can become
the single most impactful support in moving her closer to a living wage. Average
child care costs for an infant and a toddler could easily add up to nearly half of the
average Mississippi single mother’s annual income.

A working mother’s decision to seek child care can sometimes be made more difficult
when her responsibility to care for her children hinders her efforts to earn income so
she can maintain her home. CCDF exists in theory to ensure a mother doesn’t have to
choose not to work or not to place her child in a child care setting that meets her
needs.

More than 8 in 10 single parents in Mississippi are single mothers.x Child care for
working single moms is essential for the growth of Mississippi’s economy and its
overall economic health. Child care is critical for women to be economically secure.
Strengthening Mississippi’s economy requires an intentional focus on improving
women’s economic security.

In 2018, the MLICCI partnered with the National Women’s Law Center (NWLC) to
release a research brief looking at issues of women’s economic security. This research
found that Mississippi’s women make up nearly half of the overall workforce and are
the primary breadwinners in more than half (53.5%) of Mississippi families. Mississippi
registers the nation’s highest rate of women as primary breadwinners of families.
Women are co-breadwinners in another 24.9% of families in Mississippi. While
women make up a large share of heads of households in Mississippi, nearly 6 in 10
Mississippi workers living below the poverty line are moms and women. The report
found that 75% of minimum wage earners in Mississippi are women—the highest
share in the nation. Accordingly, the report also found that Mississippi has one of the
nation’s largest gender wage gaps for year-round, full-time workers, the highest
poverty rate for women, one of the highest uninsured rates for women and the lowest
national rankings for women’s and children’s health outcomes. Ultimately, the report
found that the annual loss of earnings due to the current gender wage gap, which is
perpetuated by pay discrimination, occupational segregation and other factors, is the
equivalent of 27 months of child care for one 4-year old.xi

Child care policy and spending decisions have an immense ripple effect on families
and economies. If a mother working in a low-income job has child care assistance
one day and loses it the next, it often means she immediately must work less or quit
work altogether because her wages no longer support the cost of care. If she lives in
a county that has experienced persistent poverty and stagnant job growth, until she
can gain access to assistance again or significantly increase her earnings, she may
7
remain disconnected from work and from an opportunity to support her family. This
also means her children may experience disruptions in early learning and cognitive
development. She is also far more limited in her ability to purchase goods and
services in her city or county.

If she purchases her care from a provider serving low-income working families, then
her loss of child care assistance also affects the revenue of the provider, and in many
cases, the ability of the provider to continue serving the community.

Child care is a critical support that facilitates a parent’s entry into the workforce,
supports their employment retention and their efforts to increase or upgrade skill sets
and educational attainment. Increasing access to affordable child care options for
more low-income moms to address the large unmet need is a policy imperative in
Mississippi, particularly given Mississippi’s high share of women in the state’s
workforce and the disproportionate share they represent in low-paying jobs and
workers below the federal poverty level. Investing in child care as a work support
both for working parents and those attending job training or education is aligned
with the state’s human services and workforce development goals.

Child care vouchers can significantly reduce the cost of care for working parents and
will cover most of the cost of care for the lowest income parents. CCDF provides
federal funds to states to use for vouchers that working parents and those
participating in an approved training or educational program can take to the child
care provider of their choice and use to purchase services. Mississippi requires
parents or caregivers to work 25 or more hours per week or attend an approved
education or job training activity and earn no more than 85% of State Median Income
(SMI). Mississippi uses its CCDF program to also provide child care to Temporary
Assistance to Needy Families (TANF) recipients, Transitional Child Care (TCC)
recipients, children who are homeless, children in protective services/foster care and
children served by the state’s home visitation program, Healthy Homes Mississippi
(more explanation of how these various populations are served in the report’s
discussion of priority populations). Currently, 85% of State Median Income for a
family of three is $3,640 per month.xii

8
The Caseloads
Children
The number of children served by CCDF in Mississippi is made available through
federal data as a monthly average. It shows in 2005, 2006, 2007 and 2010, the state
reports serving more than 30,000 children each month, peaking at just over 39,000
as the monthly average in 2006. Between 2004-2007, the state had implemented
several new policy changes, Hurricane Katrina in 2005 resulted in 3,000 temporary
provisional vouchers (according to MDHS annual reports), and American Recovery
and Reinvestment Act (ARRA) funds following the 2008 Great Recession coincided
with an increased monthly average during 2010. Most years from 1998 to 2016,
federal Mississippi data shows between 15,000 to 25,000 children served per month,
on average.

Mississippi CCDF Monthly Average Caseload

45,000

40,000

35,000

30,000

25,000

20,000

15,000

10,000

5,000

0
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Average Number of Families Served Average Number of Children Served

While federal data provides a monthly average, the Mississippi Department of Human
Services (MDHS) also regularly reported their number of children receiving CCDF
vouchers. There is wide discrepancy for many years between the state-reported total
and the federally reported monthly average. The discrepancy is explained by
statistical differences in state-reported and federally reported data, specifically that

9
the state reports a cumulative unduplicated yearly total for the fiscal year as opposed
to the federally reported monthly average.

It is worth note that in 2004, the MDHS began reporting the number of children
served as an “unduplicated” count, though it is not clear from available information
whether the state-reported figure in prior years represented a duplicated count. Early
years of federally reported data note that Mississippi’s data reporting was
unreliable.xiii

The Number of Children Served -

Federal and State Data Comparison
70,000

60,000

50,000

40,000

30,000

20,000

10,000

0
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Federal Data - Monthly Average State Data - Unduplicated Total

State reported data is not available for years 1998, 2000 and 2001. Federal data for
2017 was not available as of the date of this report.

Notably, the MDHS reported serving 40,000 or more children in nine of the
seventeen years of data published in MDHS annual reports. A drop in the
unduplicated count of children served occurred in 2004 and 2005, coinciding with
the newly implemented child support enforcement requirement, which required
CCDF recipients to initiate child support collections against the absent parent.
Additionally, this period was marked by CCDF funding retrenchment after a series of
policy decisions: MDHS failed to meet the state CCDF matching requirement in 2003,
it transferred a very small amount of TANF to CCDF in 2004, and it abruptly
decreased TANF direct child care spending after eliminating a TANF direct funded
child care program. Overall direct services spending was comparatively low in 2004.

10
State reported data indicate MDHS had recovered its pre-2004 level of service by
2006, reaching 40,000 or more children until an abrupt decline from 2012 to 2013.
Between 2011-2012, several significant policy changes occurred.

The MDHS eliminated contracts with long-time Designated Agents (DAs) and
structurally shifted administration and oversight of CCDF in Mississippi from nine
regions to a centralized state office.

Also during this time, MDHS proposed biometric finger scanning of parents or
caretakers as a required step to sign children in and out of centers. This proposal was
widely criticized by providers and parents for several reasons, including the invasive,
stigmatizing nature of “finger printing” and the significant cost taking critical CCDF
funds away from direct services to working parents and their children.

The state also established 12-month eligibility periods during this time. While 12-
month eligibility, now required as of the 2014 CCDBG Act, is a better policy for the
stability of low-income working parents and their families, the trade-off may be
serving less by virtue of fewer families rolling off of the program at 6-month intervals
and, in theory, a more likely successful recertification with 12-month periods allowing
more time for gathering required documents and making other necessary
preparations.

The combined effect of these policy changes coincided with the largest year-to-year
caseload reduction in Mississippi’s CCDF history.

In 2012, the state reported 45,390 children served. In 2013, after significant policy
changes had taken full effect, the MDHS reported serving 29,386 children.xiv

While the state has not in recent years achieved services to children that match pre-
2013 levels, the state-reported data started to show signs of recovery, serving more
than 30,000 children in 2014-15. As of 2017, however, the number of children served
has dropped to 24,187. This is the lowest state-reported number of children served in
Mississippi based on data available in MDHS Annual Reports.

A declining number of children served from 2015 - 2017, as in previous years, likely
coincided with several key policy changes and funding lapses. In 2016, the MDHS
began a process of implementing new CCDF policies. The state implemented a new
policy for parental eligibility determination and redetermination. These changes,
such as a new proof of residency process that had a rigid documentation
requirement (more on this later in the report), were documented as resulting in many
parental terminations.xv Additionally, the MDHS was unable to meet the full matching

11
requirement for FFY 2016, meaning the state again forfeited available CCDF funds
which may have started to effect its caseload during FFY 2017.xvi

Through the history of Mississippi’s CCDF program, major structural shifts in program
administration, funding lapses and mass changes in parental eligibility procedures
tend to be followed by a caseload reduction, as is evident by sharp caseload
reductions from 2003-2005, from 2012-2013 and from 2015-2017.

CCDF Waiting List;

Pending Funding List
Mississippi has maintained a moment-in-time snapshot of the waiting list for CCDF
services since 2001, and has reported data in MDHS annual reports most years.

Number on CCDF Waiting List or Pending Funding List

25,000
21,050

20,000

15,000 12,964
12,372
10,422
8,997 8,998 9,444
10,000 7,961 8,050 7,840

5,000
2,392
1,600
107 330 90 0 0 0
0
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Number on Waiting List or Pending Funding List

*In the above graph, data is not available and was not reported in MDHS annual
reports for 2014 and 2015. Note that in 2010, the state reported “0” children on the
waiting list. Data for 2018 was as of August 18th, 2018, as reported by MDHS at the
CCDF 2019-2021 State Plan Public Hearing. MDHS indicated that with increased
federal funds the Pending Funding list should be fully served.

The state maintains a list of children whose parent has indicated their need for child
care as a work support by applying for CCDF services. Mississippi currently refers to

12
this list as the “Pending Funding” list. The state notes in current policy that families on
the list are not deemed eligible until they are processed from that list based on the
availability of funding and priority population. For years, the state referred to this list
as the “waiting list” and for several years it was referred to as the “number of children
remaining eligible.”

The “list” has ballooned and rapidly diminished several times. It serves as a good
indicator of the demand for child care as a work support among Mississippi’s working
parents, and particularly single African American mothers. It can also tell us when the
state is increasing the reach of CCDF and when policy changes act as deterrents to
parents signing up for services.

The number of children on Mississippi’s waiting list plummeted from 2004-05,

following the state’s implementation of the child support requirement in CCDF, which
had shown negative impacts on TANF and SNAP recipients already subject to the
requirement. MLICCI learned from surveys and focus groups of child care providers
at the time that many parents had removed themselves from the waiting list following
the child support requirement.xvii According to state-reported data, there was not a
subsequent uptick in the unduplicated number of children served in 2005 that could
be correlated with more children served from the waiting list. However, the MDHS
reported in its 2005 Annual Report the waiting list was reduced due to placing $2
million of additional funds into vouchers by eliminating the payment of provider
registration fees from CCDF vouchers, enforcing child support cooperation among
CCDF recipients and by eliminating a dual system of tracking potentially eligible
CCDF children. In 2006, the list remained low, but the state-estimated 3,000
provisional emergency Hurricane Katrina vouchers during this time may have
influenced a lower number. The list was back up to nearly 9,000 by 2008.

The state again reported a near elimination of the CCDF waiting list in 2009-10, which
coincided with the infusion of federal recovery dollars following the Great Recession.
Unlike the abrupt elimination of the waiting list from 2004 – 2005, which did not result
in a correlated uptick in children served, in this instance the abrupt elimination of the
waiting list coincided with increased discretionary spending from ARRA funds and an
increase in the state-reported unduplicated child caseload was noted for multiple
years during which ARRA funds increased discretionary spending on direct services.
Though, by 2011 the waiting list was back up to nearly 13,000 children.

By 2017, the Pending Funding list had reached its highest level, growing to more
than 21,000 children. In 2018, due to the 2018 Congressional increase in CCDF
discretionary funding over two fiscal years and significant policy changes regarding
13
parental redetermination, the state reported having reduced the Pending Funding
list to 1,600 and indicated that the Pending Funding list would be fully served with
additional federal funds for FYs 2018 and 2019.

Through Mississippi’s CCDF history, the number of children on the waiting list has
significantly fluctuated. Significant reductions in the list have followed changes in
eligibility policy that didn’t result in a corresponding increase in children served.
Infusions of additional dollars and spending on direct services did result in a
corresponding elimination of the waiting list, as is evident from 2010 and 2018
increases in federal CCDF funds. Recent increases of the Pending Funding list,
particularly in 2017, followed periods of funding lapse and significant policy change.
Consistently, however, Mississippi working parents have shown a demand for CCDF
services that is greater than what can be met, underscoring the importance of child
care to their economic security.

Providers
Federal CCDF regulations require state lead agencies to establish regulations that
uphold parental choice, or a parent’s ability to use their CCDF voucher to purchase
child care from the provider of their choosing, regardless of the type of provider.
However, states can require providers, both regulated and unregulated, to comply
with different rules or procedures to be eligible to serve children receiving a CCDF
subsidy.

Currently, Mississippi distinguishes between licensed center-based care, which is

highly regulated, and family care and in-home care. As of the 2019-2021 CCDF State
Plan, the MDHS has indicated that in-home care will no longer be supported by
CCDF and that family care providers must register with the state department of
health. This change is likely related to the new federal requirement that states must
inspect unlicensed centers receiving CCDF funds, which imposes a significant cost.
Licensed center-based care providers are currently undergoing a new process for a
quality designation referred to as “Standard”. This new designation will generally be
required for providers to participate in CCDF and providers must comply by October
2019 (roughly one year from publication of this report).

The total number of Mississippi providers receiving CCDF funds has significantly
shrunk since 1998 when the total number was about 5,500. The total number in 2016
was 1,508.xviii

14
In past years, however, Mississippi’s CCDF delivery system has seen a range of
providers serving eligible families.

Federal data for Mississippi provides the number and type of providers receiving
CCDF funds. Family home providers represented the largest number of providers
from 1998 to 2013. From 2004 to 2010, the number of family home providers
receiving CCDF funds more than doubled reaching more than 5,600 providers in
2010, but then sharply declined to 2,200 in 2011 and to only 342 in 2016.

The number of center-based providers has remained very consistent over the life of
Mississippi’s CCDF program. In 1998, 1,138 regulated center-based care providers
received CCDF funds. In 2016, 1,030 regulated center-based care providers received
CCDF funds.

Number of Providers Receiving CCDF Funds by Type of Provider

and Federal Fiscal Year
9000
8000
7000
6000
5000
4000
3000
2000
1000
0
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Child's Home Family Home Group Home Center Total

Payment Method
Since 2005, 95-100% of children served in Mississippi’s CCDF program have been
served through certificates, or vouchers. From 1998-2004, the state served a higher
proportion of children through grants/contracts. Mississippi has issued non-
competitive slot-based contracts in which providers are funded for a certain number
of slots. The contractor must determine eligibility of families using policies set by
MDHS.xix

15
Children by Type of Care
Throughout the life of Mississippi’s CCDF program, most children have been served
through center-based care. In 2016, 92% of children served by CCDF attended
center-based care.xx

Currently, a clear majority of parents using CCDF vouchers select licensed (or,
regulated) care versus unlicensed (unregulated) care. Correlated with the drop in the
number of family and in-home unregulated care providers following 2011, the
percentage of children served by CCDF who are enrolled in regulated child care
settings began significantly trending upward after 2011 and has continued that
trajectory into 2016.

In Mississippi’s current setting, a clear majority of children served by CCDF are in

center-based, licensed child care.

Average Monthly Percent of CCDF Children in

Regulated vs. Unregulated Care
93% 96%
100% 88%
90% 79% 82%
78% 77%
80%
70%
60%
50%
40%
30% 22% 23% 21% 18%
20% 11%
7% 4%
10%
0%
2000 2010 2011 2012 2013 2014 2016

Average Monthly Percent CCDF Chlidren in Licensed, Regulated Care

Average Monthly Percent CCDF Children in Unlicensed, Unregulated Care

The Funds
Where Does Child Care Money Come from?

CCDF revenue comes to the state in three streamsxxi:

1. Discretionary funds – these are funds that are authorized by the Child Care and
Development Block Grant (CCDBG). These funds make up the majority of CCDF
16
revenue the state receives each federal fiscal year. The state typically puts
discretionary funds toward direct services and other expenses related to quality,
administration, and other program expenses.

2. Mandatory funds – or, the “Child Care Entitlement to States (CCES)”, are authorized
by Section 418 of the Social Security Act. The state typically puts these funds in direct
services.

3. Matching funds and Maintenance of Effort (MOE) Funds – these funds are
promulgated under the “Child Care Entitlement to States” mandatory fund rules and
require a state match. Mississippi generally receives the nation’s highest Federal
Matching Assistance Percentage (FMAP) rate for its CCDF matching requirement,
based on its Medicaid matching percentage. Generally, Mississippi’s FMAP is
between 75%-77%. If the state does not meet the full match, however, it forfeits the
funding. The state generally puts these funds toward direct services. The state also
has an MOE and it can count a portion of TANF direct child care expenditures toward
the CCDF MOE.

Together, these funding streams make up CCDF. Rules governing the CCDBG Act
generally apply to each of the funding streams. This gives the state-designated Lead
Agency wide policy-making discretion. In Mississippi, the Mississippi Department of
Human Services is the Lead Agency and the executive director of MDHS is appointed
by the governor.

One additional CCDF funding stream is the federal Temporary Assistance for Needy
Families (TANF) federal fund transfer -- Up to 30% of the state’s TANF block grant
amount (or about $27 million) can allowably be transferred to CCDF. The state has
regularly transferred 20% of TANF federal funds to CCDF. When TANF funds are
transferred to CCDF, they are considered CCDF discretionary funds.

TANF funds can also be spent directly on child care. When TANF funds are spent
directly on child care, funds are not subject to CCDBG Act rules.

Together, Mississippi’s total child care spending is the sum of its total CCDF
expenditure (including funds transferred from TANF) and its TANF-direct child care
spending.

On average, Mississippi has been allocated $6.3 million in Mandatory funds, $16
million in federal matching funds, $31.7 million in Discretionary funds and $18 million
transferred from TANF each FFY. Aside from the first two years of CCDF
implementation in Mississippi, its CCDF federal allocations have remained relatively

17
consistent. In 2009, the state received an infusion of $31 million in American
Recovery and Reinvestment Act (ARRA) funds as additional discretionary funds in
CCDF. In 2018, Congress passed a budget that doubles Mississippi’s discretionary
allocation for at least two federal fiscal years. This federal funding increase is
comparable to the opportunity Mississippi had in 2010 with the temporary infusion of
ARRA funding that resulted in the highest number of children served in Mississippi’s
CCDF history and highest single-year expenditure on direct services.xxii

CCDF Federal Allocations

$40,000,000

$35,000,000

$30,000,000

$25,000,000

$20,000,000

$15,000,000

$10,000,000

$5,000,000

$0
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Federal Mandatory Funds Awarded Federal Matching Funds Awarded

Federal Discretionary Funds Awarded ARRA Discretionary Funds

Mississippi has consistently transferred 20% of its federal TANF funds to CCDF. In
2004, however, the state only transferred $2.8 million, or approximately 3% of the
state’s federal TANF funds. The timing of this anomalously low TANF transfer to
CCDF coincided with a period when state CCDF funds had suffered a significant
reduction following the state’s inability to meet matching requirements in 2003. It
also coincided with the elimination of the TANF direct funded child care certificate
program.

While federal data is not yet available, the MDHS reported in January 2017 that it
committed the maximum TANF transfer to CCDF for the first time, which will amount
to roughly $27 million.

In the early 2000s and up to 2003, Mississippi provided TANF recipients with child
care certificates through a separate program and funded these certificates with TANF
funds.xxiii While still maintaining a separate program for TANF recipient child care in

18
2004, the state no longer reported funding the program with TANF funds in 2005. By
2005, TANF and CCDF were linked and TANF recipients became a priority
population for CCDF.

TANF Transfer to CCDF

$30,000,000

$25,000,000

$20,000,000 $17,353,516

$15,000,000

$10,000,000

$5,000,000 $2,828,019

$0
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

TANF Transfer

How has Mississippi spent

child care funds?
Mississippi’s total CCDF expenditure in any given year reflects spending of the
current year’s grant, in addition to previous fiscal years’ grants.

States have obligation and liquidation requirements, based on federal law. When a
state obligates funds, it means funds are committed for a specific expenditure,
including a voucher for a family or a slot-based contract or sub-grant with another
entity. Liquidation occurs when payment is made to an independent child care
provider or sub-grantee as a result of the obligation. States have different deadlines
for the different CCDF revenue streams.

For CCDF Discretionary funds, states have until the end of the second fiscal year
following the award to obligate funds, and the end of the third fiscal year to liquidate
funds. For CCDF Mandatory funds, states that are requesting CCDF Matching funds

19
must obligate Mandatory funds by the end of the first fiscal year, but there is no
specific date by which states must liquidate Mandatory funds. For CCDF Matching
funds, states must obligate the funds by the end of the first fiscal year and liquidate
by the end of the second fiscal year. CCDF MOE funds must be obligated and
liquidated by the end of the first fiscal year. These varying obligation and liquidation
deadlines for CCDF funds give states multiple years to expend one fiscal year’s
allocation.xxiv

We have provided data that shows how much the state spent in CCDF funds during
the federal fiscal year, which includes revenue from all appropriation years. Data
reflecting total expenditures from revenues from “all appropriation years” provides a
total amount of spending for the year, regardless if the funds spent were awarded
that year or in previous years. While we have provided an overall CCDF expenditure
from 2000-2016, more specific expenditure category data is only available for years
2003-2016.xxv

Total FFY CCDF Expenditure

$120,000,000
$108,977,645

$100,000,000 94,947,000
$89,512,999 $90,428,489
78,202,753 $78,429,261 $81,392,320
$80,783,551 $81,999,951
$76,844,883 $67,497,532 $78,130,324 $74,770,313
$80,000,000 $74,446,338
$70,936,702
$67,902,283
65,059,000

$60,000,000

$40,000,000

$20,000,000

$0
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Total FFY Expenditure

TANF direct child care expenditures significantly diminished after 2004. In the early
2000s, the state established the TANF Child Care Certificate Program. This program
served TANF recipients and funded services directly with TANF dollars. At the time,
the state reported this policy freed up CCDF dollars to serve more non-TANF
working parents earning at or below 85% of State Median Income (SMI). In addition
to funding a TANF-specific child care certificate program using TANF direct

20
spending, the state transferred 20% of its TANF block grant to CCDF during this time,
with exception of 2004.xxvi

TANF Direct Child Care Spending, federal and state MOE

$30,000,000

$24,815,359
$25,000,000
$20,516,737 $20,300,342
$20,000,000

$15,000,000
$10,275,244 $1,715,430
$10,000,000 $7,848,096 $8,050,230 $1,715,430
$1,715,430
$4,927,071 $4,811,970
$1,719,679
$5,000,000
$1,669,221 $1,709,280 $1,711,181

$0
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
-$1,398,458
-$5,000,000

TANF Direct Child Care Spending

The abrupt reduction in TANF direct spending on child care was followed by a deep
retrenchment of total state child care spending, which is the sum of total CCDF
expenditures (including the TANF transfer to CCDF) and TANF direct child care
spending (including TANF federal and MOE spending in excess of the amount that
can be counted toward the CCDF match).xxvii

Between 2001 – 2005, Mississippi’s total child care spending declined by $43 million.
During this period, Mississippi’s caseload reduced. In 2004-05, the state spent fewer
dollars on direct services than any other year in Mississippi’s CCDF program history.

21
 Mississippi's Total Child Care Spending
$120,000,000 113,748,307
108,973,396
101,302,682
86,487,195
$100,000,000 92,609,539 84,465,124 90,432,738
85,404,697 78,429,261
81,993,801
77,669,663
$80,000,000 71,191,666 74,446,338
70,709,173 70,936,702

$60,000,000

$40,000,000

$20,000,000

$0
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Total Child Care Spending

For the purposes of this analysis, the above chart includes TANF Maintenance of
Effort spending on child care only in excess of the amount that can be “double-
counted” toward the CCDF MOE. This method is consistent with the Mississippi
Office of State Auditor’s 2007 “A Review of the Child Care and Development Fund
(CCDF) Program in Mississippi.”xxviii

Mississippi has been required by federal law to spend at minimum 4% of funding

awarded in a fiscal year on quality activities. The reauthorized CCDBG Act of 2014 will
require states to spend 9% of funds awarded in a given year on quality activities by FY
2020 and by FY 2017, states were required to spend an additional 3% annually on
quality activities targeted to infants and toddlers.xxix

Since 2008, Mississippi’s spending on quality activities has trended upward, from
$4.4 million in 2008 to more than $11 million in 2016.

22
 Mississippi CCDF Quality Activity Expenditures
$14,000,000

$11,566,781
$12,000,000
$10,283,467
$9,914,520
$10,000,000 $8,848,587 $8,545,058
$7,618,114 $6,944,679 $7,269,776 $8,039,123
$8,000,000 $7,021,755 $6,287,076 $7,120,434
$5,811,009
$6,000,000
$4,445,197
$4,000,000

$2,000,000

$0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Quality Activities &Targeted Infant/Toddler Quality

Since 2008, Mississippi’s expenditure on quality activities as a share of total

expenditure has increased from 5% to 15% as of the most recent federal data. In most
federal fiscal years, Mississippi’s spending on quality activities surpasses what federal
law requires as a minimum quality spending level.xxx

18%
Quality Activity Expenditures as a Percent of Total CCDF
15%
16% Expenditures
14% 13% 13%

12% 11% 11%

10%
10% 10%
10%
9%
8% 8% 8% 8%
8%

6% 5%

4%

2%

0%
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Quality Spending as Percent of Total Expenditure Federal Requirement

23
Mississippi’s expenditures on direct services were their lowest in 2004, the same year
the state reported an anomalously low TANF transfer to CCDF. This was also the year
that preceded the sharp decline in TANF direct spending on child care, as noted
earlier. Direct services expenditures peaked in 2010 with additional ARRA
discretionary funds. From FFYs 2009 – 2011, the state spent $30 million in ARRA, and
$25 million additional dollars in 2010 alone. Peak direct services spending years were
2007 and 2010-11, the latter due to the infusion of ARRA funds. Spending on direct
services tends to fluctuate by millions each federal fiscal year, with a recent drop from
FFY 2015 to 2016.

Direct Services Expenditure

$100,000,000 $93,539,011

$90,000,000
$74,459,386
$80,000,000 $67,173,581 $73,921,720
$66,779,696 $62,474,797
$70,000,000 $63,851,743 $65,536,691
$60,848,423 $56,540,150 $60,475,100
$57,205,027 $57,626,745
$60,000,000 $52,962,679

$50,000,000

$40,000,000

$30,000,000

$20,000,000

$10,000,000

$0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Direct Services Expenditure

Direct services expenditures per capita, based on the state-reported non-duplicated

number of children served in the federal fiscal year, started to trend upward in 2012.

24
 Direct Services Expenditure Per Child Served
$2,500
$2,126 $2,108 $2,178
$2,000 $1,868
$1,706
$1,548 $1,619 $1,654 $1,688 $1,633
$1,407 $1,481
$1,500 $1,378 $1,332

$1,000

$500

$0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Direct Services Expenditure Per Captia State-Reported Number of Children Served

Mississippi’s direct services spending as a share of its total FFY CCDF expenditure
has remained relatively consistent over the years. Direct services as a share of the
state’s CCDF expenditure peaked in 2010, consistent with the increased ARRA
funding. More recently in 2015 and 2016, direct services as a share of the state’s total
CCDF expenditures has trended downward, while spending on quality activities has
trended upward, along with the direct services expenditure per child served.

25
 Direct Services Expenditure As a Share of Total Expenditure
88%
86%
86%
84%
84% 83%
83%
82% 82% 82%
82% 81%
81% 81%
80%
80% 79%
78%
78% 77%

76%

74%

72%
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Direct Services Expenditure As a Share of Total Expenditure

The state spent between $3 - $5 million on activities to certify recipient and provider
program eligibility determination between 2003 – 2012.

State spending of CCDF funds on administration has gradually trended upwards over
CCDF’s history in Mississippi.

26
 Other Expenditures
$6,000,000

$5,000,000

$4,000,000

$3,000,000

$2,000,000

$1,000,000

$0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016
-$1,000,000

-$2,000,000

Admin Earmark_Targeted Funds Infants & Toddlers

Earmark School Age R & R N-Dir Srvcs - Cert Prog Elig/Det

Expenditures from CCDF discretionary funds in Mississippi fell below $40 million only
two fiscal years, in 2004 and 2005, coinciding with a minimal TANF transfer to CCDF
in 2004 and the loss of matching funds in the early 2000s. These funding trends
coincided with the elimination of the TANF direct funded child care certificate
program in 2004 and the inclusion of TANF recipients as a CCDF Priority Population.

CCDF Discretionary Expenditures

$70,000,000

$60,000,000

$50,000,000

$40,000,000

$30,000,000

$20,000,000

$10,000,000

$0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Discretionary Spending

27
As noted earlier, the expenditure data in this report reflect “all appropriation years”,
meaning that expenditures reflect current and previous year’s awards. States have
multiple fiscal years to spend allocated matching dollars. This means if a state does
not spend the required amount of matching funds to draw down the full federal
allocation, then its available funds to expend could be reduced over a two fiscal year
period.

When the state is unable to commit funds to its matching requirement, it forfeits
critical federal dollars. This was especially clear in 2003. The state’s matching
expenditures in 2013 were also reported at lower levels compared to most years.
Based on reports from the state, it will also not be able to draw down the full amount
of federal funds made available in FY 2016 thus matching expenditures may again
reduce moving beyond FY 2016.

CCDF Matching Expenditures

$25,000,000

$20,000,000

$15,000,000

$10,000,000

$5,000,000

$0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Federal Match State Match

The state’s mandatory and MOE expenditures have remained relatively consistent
over the years. The state consistently reports that 100% of mandatory expenditures
go to CCDF direct services. The CCDF MOE is “double-counted”. TANF MOE direct
child care spending is counted toward the CCDF MOE.

28
 CCDF Mandatory and MOE Expenditures
$9,000,000
$8,000,000
$7,000,000
$6,000,000
$5,000,000
$4,000,000
$3,000,000
$2,000,000
$1,000,000
$0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

CCDF Mandatory Spending CCDF MOE

Expenditure decisions greatly influence caseload trends. When Mississippi spent the
ARRA discretionary infusion quickly and primarily on direct services in 2010, it
achieved the highest reported number of children served. A 2010 survey MLICCI
conducted of child care providers found that 63% of surveyed child care center
directors experienced increases in the number of children receiving certificates,
resulting in 7 additional children served per center among the respondent group.
When the state failed to transfer adequate TANF funds to CCDF in 2004, direct
services spending was its lowest and the caseload reduced.

When the state spends the most on direct services, the caseload grows. When the
state increases spending on non-direct services, the caseload tends to reduce. When
the state spends more on TANF direct child care, more working parents are served
and more is spent on child care overall. While federal allocations tend to be
consistent year-to-year, CCDF expenditures and state dollars committed to CCDF
vary.

29
CCDF Policies
Administration and Eligibility Procedures

Our country has never been able to achieve consensus support for child care
assistance programs. Congressional debates over major federal child care legislation
through the years, including the Act for Better Child Care (ABC) and the Child Care
and Development Fund (CCDF), acknowledged the need for more funding for child
care assistance as the PRWORA imposed work requirements on single poor mothers.
As major federal changes to child care assistance were debated during the passage
of PRWORA in 1996, bipartisan speeches on the child care funding elements that
would eventually form CCDF pointed to the serious inadequacy of proposed federal
funding levels relative to the need among low-income working parents at that
time.xxxi
A conflicted national attitude about the importance of affordable child care for low-
income working parents has contributed to the failure of the issue to be crystallized
among state policymakers, state political leadership and the state’s general public. This
unfortunate omission of the public conscientious plays out most tragically in states like
Mississippi, where a high prevalence of low-wage work and stagnant wage growth
creates a pronounced unmet need for affordable child care, as noted earlier in the
report.

State CCDF policy and administration is critically important for low-income working
parents. The following offers analysis and reflections of what such policymaking has
looked like in Mississippi since CCDF went into effect.

CCDF policies are generally described in the state’s CCDF State Plan, which is now
required every three years and is typically followed by the more specific child care
policy manual, or currently the Child Care Payment Program Policy Manual. It is
generally in the state’s policy manual where the details of procedures and penalties
are described.

Given that CCDF is governed by CCDBG Act rules, states are given wide discretion in
CCDF policymaking as they are under other block grant structures. Mississippi has
designated the MDHS as the Lead Agency to administer CCDF and the executive
director of that agency is appointed by the governor. CCDF policymaking in
Mississippi has largely taken place at the agency-level and the state legislature, while

30
proposing numerous bills related to CCDF, has remained largely disengaged from
CCDF policymaking.

The creation of State Early Childhood Advisory Councils (SECACs) introduced an

additional policy advisory entity with direct influence over CCDF in Mississippi. States
were directed to establish SECACs under the 2007 federal Head Start
reauthorization, the Improving Head Start for School Readiness Act of 2007. SECACs
were tasked with bringing early learning stakeholders together to address a full
range of policy issues. Mississippi’s SECAC membership includes representatives of
different state agencies, early childhood stakeholders and other members appointed
by the Governor.

For many years, Mississippi’s CCDF delivery system was decentralized, as mentioned
earlier, and administered through nine designated agents.

A 2005 report on the utilization and outcomes of both parents and providers using
CCDF under the Designated Agents (DAs) found that while CCDF was viewed
positively by parents and providers, limited funding left too many unable to retain
services and those who did retain services reported problems with service delivery
and implementation of procedural requirements to retain CCDF assistance.xxxii The
John C. Stennis Institute of Government report applied "Backward Mapping"
against an Urban Institute model for best practices in CCDF administration to
develop these findings. They also conducted focus groups and surveys. Problems
cited by parents and providers surveyed at the time reflected lacking
communication from DAs to recipients and a lack of inclusion of the experience and
knowledge of the end-users of CCDF in the state's CCDF policymaking. Parents
reported an inability to obtain needed information, most often resulting in their
termination from CCDF for failing to comply with procedural steps that were unclear
to parents and providers, even when parents remained eligible for CCDF.

As a result of growing attention on the state's CCDF program and a number of issues
including funding shortfalls in the early 2000s, what began as a CCDF reform bill
in the Mississippi legislature in 2005 ended up being a requirement that the state
auditor conduct an audit of CCDF. House Bill 813 was passed during the 2005
Regular Session. It originally included measures that would require state “first in/first
out” TANF/CCDF grant management practices to avoid future state matching
issues.xxxiii Multiple reform measures were struck from the original version and the
audit bill was passed.xxxiv

31
In March 2007, the Mississippi Office of the State Auditor, at the time headed by State
Auditor Phil Bryant, published "A Review of the Child Care and Development Fund
(CCDF) Program in Mississippi". In it, the OSA took a position that affordable child
care for low-income working parents is a "critical element" in their ability to retain
employment. While the OSA found the state's CCDF program to be in compliance
with state and federal law, and while it found the state had generally implemented
internal fiscal measures to avoid any other losses of funds, it found "...weaknesses in
contractual and policy areas that lead to a loss of effectiveness and inconsistent
application of policies, rules and regulations statewide," and that such
"...inconsistencies lead to barriers in the certificate program for parents."xxxv

Under Designated Agents, parents and providers dealt with a maze of policies and
procedural steps.

In 2007, MLICCI The OSA noted the agency’s creation of a

surveyed a little more uniform child care policy manual as a policy
change that achieved more consistency in what
than 500 child care
had been a divided system.
centers participating in
But the OSA also noted policy changes that
CCDF.
were creating real barriers to access. The OSA
Nearly 6 in 10 (58%) noted the controversy surrounding the Child
reported having children Support Enforcement requirement implemented
on the CCDF waiting list in 2004, finding that the “…initial result of this
new rule was parents being required to go to
often resulting in
multiple locations to qualify their children,” and
providers arranging a that this new “…application process could be
payment plan, making it extremely difficult for parents with little or no
harder to finance their transportation, or time off, especially if there
were a problem with paperwork or documents
center.
that might require a return trip.”xxxvi

Given that cooperation with child support

enforcement required an additional application process, the OSA audit characterized
the requirement as creating a “dual-application” process that imposed additional
procedural burdens.

Under the DAs, Mississippi fractured its CCDF program into nine independently
functioning entities. While the OSA noted that the state agency had significantly
fewer staff in 2007 handling a much larger caseload compared to a 1993 state audit

32
of the state child care program, sub-contracting CCDF administration resulted in
many documented inconsistencies in policies and service delivery. In 2007, the state’s
audit of CCDF observed that, “With numerous sub-grantees (slot programs), and nine
DAs, consistent application of policy, regulation, contracts, etc., is critical.”xxxvii

In 2007, MLICCI surveyed a little more than 500 child care centers participating in
CCDF.xxxviii Nearly 6 in 10 (58%) reported having children on the CCDF waiting list,
often resulting in providers accepting a lower fee or arranging a payment plan,
making it harder to finance their center. Issues reported by providers in 2007
included:

- Paperwork gets lost and parents get put on waiting list

- The waiting list is too long. When a spot comes open, parents have moved or
dropped out of daycare
- Parents are continually told there are no funds available
- DAs don’t communicate with parents on the waiting list
- Some parents think the system is trying to get rid of them
- People on the waiting list lose their jobs because they don’t have needed
assistance for child care

Sixty percent of centers surveyed in 2007 reported serving parents who had been
denied CCDF assistance, accounting for more than 2,400 parents in the centers
surveyed. Reasons reported for denial in 2007 include:

- Not enough funds available

- Full-time students have to work 25 hours to have high enough priority for
certificates, and they can’t handle workload as well as a job and a baby
- Difficult to schedule 25 hours of work
- Income slightly over limit
- Applications lost
- Child support application not submitted

Perhaps one of the most salient findings from MLICCI’s 2007 survey of child care
providers was related to the child support requirement implemented in 2004.
Seventy percent of child care providers reported that mothers they serve have
declined to apply for CCDF because they do not want to initiate child support actions
against the father. This amounted to 1,509 potentially CCDF-eligible mothers who
had declined to apply for child care due to the child support requirement in the
centers surveyed. Mothers reported having informal arrangements with fathers,
33
having fathers residing in the home and wanting to avoid conflict, not knowing where
fathers currently reside and not wanting to provide an entryway into fathers being
involved in their lives.

As noted earlier, the implementation of Child Support Enforcement in CCDF

coincided with a sharp decline in the state’s CCDF waiting list, which was not
followed by a significant uptick in state-reported CCDF caseload data. Forty-four
percent of providers surveyed reported that mothers of children in their center
dropped out of the program when the child support requirement went into effect in
2004, totaling 1,310 mothers in the centers surveyed.

In 2010, MLICCI conducted another series of child care provider surveys, finding 74%
of provider respondents reported that child support was a deterrent for parents
applying for certificates and on average 6 mothers in their centers have declined to
apply for certificates due to child support enforcement requirements.xxxix

A common sentiment expressed by providers in MLICCI’s 2010 survey was captured

by one provider: “Cut a lot of the red tape that cause parents not to be able to
receive certificates.” When asked why children were losing certificates in 2010 (even
though, as was noted earlier, a significant number of centers reported increases in
CCDF children due to the temporary ARRA infusion), many of the answers were
similar to those gathered in 2007:

- Child support requirement

- Working 24 hours instead of 25
- Full-time students also required to work and students are dropped in May
- Parents don’t submit paperwork on time
- Parents lose jobs

Mississippi eliminated contracts with its Designated Agents administering CCDF

between 2011-2012. Based on a number of accounts from MDHS staff at various
public meetings MLICCI conducted in 2017, the transition from CCDF administration
by DAs to centralized administration of CCDF at the state level resulted in
administrative error regarding information and data on participants and other
program components. In effect, after the state eliminated contracts and centralized
CCDF administration, it also had to rebuild its CCDF program with limited
information. This significant administrative burden was followed by the largest year-
to-year decline in the state-reported number of children served between 2012 –
2013, when the state-reported caseload declined from 45,000 in 2012 to 29,000 in
2013.
34
MLICCI commissioned the National Equity Project to conduct a series of listening
sessions with key stakeholders in November 2012.xl Insights offered by session
participants focused on the omnipresent lack of resources, the lack of good policy
change, the fragmentation of both the child care system itself and within the
community pushing for change in child care, and the reality that perceptions of race
and gender affect how policy is created and applied. One participant observed that a
“…lack of money continues to mean we are ‘piecemealing’ a system together.”
Another observed that “…we need less fragmentation and more communication
among all the players.”xli

In 2012, as the state’s CCDF program was undergoing a major administrative shift
moving away from the Designated Agent system that a Stennis Institute study
described as “…costly, inefficient, and archaic,” a new proposal emerged that would
require centers and parents and other household designees participating in CCDF to
use biometric finger print imaging when signing their child in and out of their child
care center. The project carried an
Finger scanning requirement estimated lifecycle cost of $31.5 million
and its stated intent was to reduce
The project carried an
improper payments and intentional
estimated lifecycle cost of fraud. Parents and providers expressed
$31.5 million and its stated deep concern over privacy issues, the
invasive nature of such a system and the
intent was to reduce
stigma that comes with having to
improper payments and provide a fingerprint to pick up a child
intentional fraud. Parents and from a center.xlii
providers expressed deep A study of the state’s biometric finger
concern over privacy issues, scanning proposal noted that the state’s
recent decision to centralize child care
the invasive nature of such a and eliminate contracts with its
system and the stigma that designated agents was generally viewed
comes with having to provide positively by those CCDF impacted and
that its decision to impose finger
a finger print to pick up a printing of parents risked undermining
child from a center. any recent trust that had been built with
the end-users of CCDF. The study
analyzed the cost-benefit of the state’s decision to imposed finger scanning.xliii A
survey MLICCI conducted was referenced in the study and found that 68% of
providers did not support the finger printing proposal and nearly 70% thought the
35
requirement would deter eligible parents from applying for CCDF. The John C.
Stennis Institute for Government study found that Mississippi did not calculate the
rate of improper payments in its response to an HHS survey of state agencies, and
thusly the report could not produce any data or evidence to quantify or prove any
amount of fraud in the CCDF program. Such data and evidence would be needed as
inputs in any cost-benefit assessment. It also found that only one state—Louisiana—had
fully implemented a finger printing system for CCDF participants, while nearly all
other states that had considered or started implementation had since abandoned the
projects.xliv

Tension among parents and providers were heightened given the state’s proposed
biometric finger scanning requirement in low-income centers participating in CCDF
and also the ongoing adjustment to a new, centralized state child care system. At the
time, MLICCI also pointed to issues related to
Another observed,
increased procedural burdens on parents and
providers, arguing that the “finger scanning” “We have policy
proposal, as was commonly referenced, would issues because we
have also had parents and providers attend an are still a
orientation on how to use the technology at their
segregated
own expense, citing recent federal policy guidance
that finger imaging has a “chilling effect” on community — policy
applications. does not consider
A large volume of academic research has black children are
consistently shown that welfare recipients are the ones who really
perceived as being dishonest and fraudulent and need help.”
that Caucasian middle-class Americans generally
associate welfare recipients as single mothers of color. A participant in a National
Equity Project listening session on child care in Mississippi in 2012 observed that
“…race is a major factor in how policy is passed and applied.” Another observed, “We
have policy issues because we are still a segregated community—policy does not
consider black children are the ones who really need help.”

A lawsuit challenging the state’s implementation of the biometric fingerprint-imaging

proposal was filed in 2012 by child care providers participating in CCDF and other
partners.xlv The state failed to properly comply with the Administrative Procedures
Act (APA) when implementing the biometric finger imaging policy and the plaintiff
was successful on this basis (the APA is a state law that requires rule-making
procedures to be followed by state agencies creating state policy). The decision

36
prevented finger printing from going into effect statewide, though the state
continued with smaller-scale pilots before ultimately abandoning the system. MLICCI
pointed to the loss of child care funds as a major consequence for having to pay for
contracted work that was not ultimately put in place, putting funding for direct
services at risk, particularly given waiting lists building back up after the effect of the
ARRA infusion was fading.

During testimony in the 2012 lawsuit, state officials testified that providers
participating in CCDF were fraudulent as one of the justifications for proposing finger
printing. It was also revealed through testimony, however, as the Stennis Institute
study showed, the state could not produce evidence of intentional fraud in the CCDF
program to justify the major proposed investment.

The Stennis Institute study noted that the 2007 Mississippi OSA audit of CCDF
recommended that the state adopt a relatively low-cost child care e-debit card, which
could have achieved the same intended result as the biometric finger imaging
proposal, in terms of expected gains in program integrity.

In the years following major policy changes culminating in 2012 and 2013, very few
new CCDF certificates were issued and most that were issued went only to the top
priority populations, such as TANF, TCC and foster care. In 2017, MDHS stated in a
public meeting held by MLICCI that the agency had issued no new CCDF vouchers
since 2014.xlvi

In 2017, MLICCI analyzed data provided by the MDHS showing very few new
vouchers issued in the previous 3-year period. Nearly 70% of newly approved CCDF
families between December 2014 – August 2017 were families served by TANF, TCC,
foster care, protective services, a homeless agency or the state’s home visitation
program. Only 17% of newly approved applicants were parents working or attending
job training or education earning less than 85% of SMI. But these new applicants over
this nearly 3-year period amounted only to 5,776 new families served by CCDF.xlvii

While parents and providers reported issues related to communication and trust
while CCDF was administered through DAs, the transition to a central state office to
administer child care brought its own substantial administrative challenges. Over the
course of 2015-2016, during the period in which MDHS reported issuing no new
CCDF certificates, the MDHS was placed on a federal corrective action plan for
having a CCDF payment error rate of more than 10%.xlviii

In February of 2016, the MDHS received notice from the federal Department of
Health and Human Services Administration for Children and Families that the agency
37
would remain under an ACF-405 Corrective Action Plan until the state achieves an
error rate below 10%. At a public meeting held by MLICCI in 2017, an MDHS official
reported and later confirmed in an August 2017 published newsletter that the state
was placed under corrective action for not conducting annual redeterminations.xlix

The same month it was informed it would be monitored for CCDF error rates, the
state held a hearing on the 2016-2018 CCDF State Plan, much of which was
dedicated to the state’s implementation of new federal requirements resulting from
the 2014 Reauthorization of the Child Care and Development Block Grant (CCDBG)
Act. Mississippi’s State Plan was given conditional approval, pending corrective
actions requiring the state to implement new federal requirements (the state was
granted an extension to conduct federally required background checks), to resolve
redetermination issues and to increase reimbursement rates, which ACF described as
insufficient in its conditional approval letter to Mississippi.l

In October 2016, the state published its revised CCDF policy manual, implementing
the details of what it set out to accomplish in its 2016-2018 CCDF State Plan. In the
final version, the generally required new federal rules were incorporated, including
12-month eligibility for all CCDF recipients, new health & safety training
requirements, background checks, monitoring of unregulated (or, unlicensed)
centers and the inclusion of homeless children in those receiving CCDF assistance.

The state made additional, non-federally required changes. One such change that
seemed at first to be innocuous ended up being a significant procedural hurdle
during the state’s 2017 redetermination process. CCDF policy in Mississippi had long
included a “Proof of Residency” policy, which, for many years, described general
procedures for verifying an applicant or participant’s residency if deemed necessary.
In practice, as was reported by MDHS at a June 2017 public meeting held by MLICCI,
the agency had rarely if ever used the policy during eligibility determination or
redetermination. A likely reason is that applicants have long been required to
provide documents that verify who they and their children are, where they work and
how much they earn or where they attend training or school to satisfy general
eligibility requirements. Generally speaking, information gathered in these
documents (and also other files in a person’s case record for other programs that
would show residency) is found to be sufficient to reasonably document a person’s
residency.

In the 2016 state CCDF manual, however, the MDHS converted the “Proof of
Residency” policy into a mandatory procedural step in eligibility determination and
redetermination as opposed to a discretionary option. In addition to making proof of
38
residency a required step, the policy also increased the number of documents with
corroborating addresses needed to satisfy the requirement from 2 to 3. The new
policy required a state-issued photo ID along with two pieces of additional
documentation in the form of utility bills or other documentation, and each of the
three forms of documentation were required to have the same residential address.
Federal CCDF policy did not preclude a parent from changing addresses during their
12-month eligibility period. MLICCI contended that such a policy was unnecessary,
imposed an undue burden on parents and would serve only to terminate eligible
parents for procedural issues.

As the state’s redetermination process was unfolding under significantly revised

rules, MLICCI began hearing from parents and providers who were losing CCDF
assistance. Many reports indicated that the new proof of residency procedural step
was causing parents to miss redetermination deadlines, in many cases due to a
simple mismatch of addresses due to moves or temporary homelessness, or living
with parents, or a lack of any mailed documents with a name and address or the
inability to get a license updated. Many providers indicated they needed to be
included earlier in the 60-day notice period granted to parents who are up for
redetermination to assist with the new requirements. Many working parents were
losing assistance due to procedural steps, not ineligibility. MLICCI documented cases
in which mothers were contemplating leaving their job if they no longer received
child care. MLICCI held a series of child care policy town halls in 2017 throughout the
state in partnership with the Mississippi Legislative Black Caucus and with the
participation of MDHS at a number of meetings. This process and the summary
findings were offered by MLICCI in 2017.li

In 2018, MLICCI commissioned a study from Professional Associates, Inc. of the 2017
redetermination process, The Mississippi Child Care Policy Imperative: Assuring
Policy Implementation Maximizes Policy Intent.lii

Through data obtained via Public Records Act request, the study found that 59% of
parents lost CCDF assistance during the 2017 redetermination process —21% were
terminated and 38% were documented as giving “no response” to the
redetermination notice. Reasons for termination, as provided by MDHS, included
over the income criterion, no cooperation with child support, document insufficiency,
no online application, and no responses. No further breakdown of the data was
provided. From its focus group findings, which included parents who had both
regained and lost CCDF assistance, the 2018 study found that parents and providers
identified documentation requirements in general with a specific focus on the proof

39
of residency requirement as barrier to regaining eligibility, along with an “ineffective
MDHS communications system”.

Through data obtained via Public Following the accumulation of

growing evidence of the
Records Act request, the study
unnecessary burden caused by the
found that 59% of parents lost new proof of residency policy,
CCDF assistance during the MDHS significantly revised the
2017 redetermination process — policy in 2018, requiring only one
document, which could be a state-
21% were terminated and 38%
issued ID or other documents
were documented as giving “no showing Mississippi residence, and
response” to the redetermination it directs workers to look at other
notice. Reasons for termination, required documents for
reasonable proof of residency. The
as provided by MDHS, included
agency made a number of other
over the income criterion, no changes reducing document
cooperation with child support, requirements on parents in 2018.
document insufficiency, no Providers were also included in 60-
online application, and no day redetermination notices
(whereas before, they were
responses. No further included 30 days ahead of the
breakdown of the data was deadline). This was a welcome
provided. change of organizational culture
for providers and parents. MDHS
reports having reinstated a number
of parents who were terminated due to the new procedural steps in 2017, such as the
proof of residency requirement. MLICCI’s 2018 commissioned study of the recent
redetermination process noted that such actions are more in line with an
“interactional” approach to policy implementation, which is guided by the needs and
experience of the CCDF end-user.

Also in 2018, Mississippi began receiving a new federal increase of CCDF dollars that
will nearly double discretionary allocations as part of the 2018 federal budget,
bringing in an additional $39 million during federal fiscal year 2018 alone. This
infusion of discretionary funds, as in 2009 and 2010 with ARRA funds, is allowing
Mississippi to reduce its current Pending Funding list. Mississippi was able to serve
nearly 60,000 children during those peak spending years.

40
Reimbursement Rates
States set CCDF reimbursement rates for centers and co-payments for parents based
on family size and income. States also tie CCDF center reimbursement rates to quality
rating systems, just as Mississippi did under its QRS in which a higher reimbursement
rate was awarded as centers increased Star Levels, amounting to a 7%-25% increase.
Reimbursement rates are also based on the age of the child, full- or part-time care
and the type of care provider (for instance, family child care providers received a
lower rate).

In federal fiscal year 2016, a monthly average of 52% of families had a CCDF co-
payment and of those families with a co-pay, the mean co-pay was 13% of monthly
family income, according to federal data. In 2010, there were significantly more
families with a co-pay. Seventy-seven percent (77%) of CCDF families, according to
reported monthly averages, had a co-pay that was 5% of monthly family income on
average. In 2004, 89% of families had a co-pay that was 4% of mean family income on
average. The decrease in the share of CCDF participants who have a co-payment is
related to the increasing share of “referred clients”, a large share of which are
children in protective services or foster care, as part of the CCDF population.liii

For a family of 3 with $20,000 in annual gross income, current co-pay rates are about
$87.50 per month, according to MDHS.liv

For many years, the state maintained a relatively stagnant rate of provider
reimbursement.lv

Approximate Year Infant Full-Time Center, Maximum

Monthly Reimbursement
2011 $346
2014 $346
2018 $480

Full-time infant care at a licensed child care center under the new Standard Center
reimbursement rate is $480 per month. The new Standard Center reimbursement
rate, based on the previously existing rate the state cited for full-time center-based
infant care, $374.63, represents a 28% increase. These rates that were derived from
the 75th percentile market rates, according to the state’s 2016 Market Rate Survey
(MRS).

41
The recent provider reimbursement rate increase was federally required following
the CCDBG Act of 2014. The state received “conditional approval” of its 2016-2018
CCDF State Plan, implementing new provisions of the federal reauthorization of
CCDF. In Mississippi’s conditional approval letter for its Plan, the HHS ACF Office of
Child Care informed Mississippi that its CCDF reimbursement rates were set too low:
…the CCDBG Act of 2014 requires states and territories to take the cost of quality into account
when setting rates, and to set rates based on the results of the most recent market rate survey
or alternative methodology. We continue to be concerned that your rates may not allow for
equal access… Thus, the conditional approval of your Plan does not constitute a final
determination that your payment rates are sufficient to provide access to child care services for
eligible families that are comparable to those provided to families that do not receive
lvi
subsidies, as required by law.

Mississippi conducted the child care Market Rate Survey in 2016. It finalized the
results in 2018 and the new rates are going into effect as the state is currently in the
process of bringing all licensed canters into the new Standard Center designation.

In a 2010 MLICCI survey of center-based child care providers, comments were

collected detailing what happens when parents can’t afford child care fees. Common
answers included children couldn’t enroll, parents were encouraged to apply for a
child care certificate or the provider attempted to make a payment arrangement with
the parent.

The average monthly rate for infants reported by licensed child care centers surveyed
in 2010 was $380, which is not much more than the reported maximum
reimbursement rate at the time (the last reported rate before the 2018 increase was
about $375, according to the 2016 MRS). While 82% of providers responded that
they thought MDHS should raise reimbursement rates, 71% of providers surveyed
said that they would not want reimbursement rates to be increased if it meant fewer
children being served due to funds being spread thinner. Ninety-five percent of
providers in 2010 favored increasing funding for CCDF adequate enough to raise
reimbursement rates and not reduce the number of children served.

These survey results demonstrate the ongoing and strong commitment that CCDF
providers have to serving their communities, regardless of what the CCDF
reimbursement rate has been through the years. During MLICCI’s 2017 Child Care
Policy Town Hall Series, providers serving low-income working families described the
continued hardship that a lack of an increased reimbursement rate had on their
ability to keep participating in CCDF and serving parents using child care vouchers.
The newly increased reimbursement rates are no doubt welcome news.

42
Priority Populations
States are not required to establish priority populations for CCDF assistance.
Mississippi’s Priority Population policies have shifted over time, generally moving
from a minimal, simplistic framework following CCDF’s implementation, to a longer
list with more populations specifically identified for priority service.lvii

From 1999 – 2004, the state’s Priority Population policy was aimed at serving mothers
receiving and transitioning off of public assistance and working parents earning at or
below 85% of SMI. In 1999, Mississippi identified TANF recipients and individuals
transitioning of off of public assistance as the top two priority groups. Working
parents at or below 50% SMI were given 3rd priority and working parents between
50%-85% of SMI were given 4th priority. Between 2002 – 2004, the state removed
TANF from the CCDF priority populations and added teen parents attending school
full-time, special needs parents and children in protective custody/foster care, in this
order, as sub-priority groups under Priority 2, or eligible individuals earning at or
below 50% of SMI. TCC became the top priority population.

As noted earlier, TANF funds can be transferred to CCDF Discretionary funds (up to
30% of the federal TANF block grant) and spent directly on child care for TANF
recipients or individuals at risk of going on TANF. In the early 2000s, Mississippi
opted to spend TANF funds directly on child care and operated the TANF Child Care
Certificate Program to serve TANF recipients. Until 2005, Mississippi exercised its
option to simultaneously use direct TANF funds, a TANF transfer to CCDF and CCDF
funds to fund child care assistance for low-income working parents.

The variation in the percentage of families served by CCDF who are also participating
in TANF is consistent with changes in the state’s approach to serving TANF recipients
in need of child care. While the state simultaneously operated a child care certificate
program for TANF recipients, it reported serving no TANF recipients through CCDF.
The trend line of CCDF families reporting income from TANF shows the state’s
varying approach to child care for TANF recipients, and how TANF recipients were
folded into the state’s CCDF service population.lviii

43
 Average Monthly Percentage of Families Reporting Income from TANF,
Before and After TANF-Direct Funded Child Care Certificate Program, which
ended in 2004
100%
90%
80%
70%
60% 78% 82% 86%
50% 100% 100% 100%
40%
30%
20%
10% 22% 18% 14%
0% 0% 0% 0%
2002 2003 2004 2005 2010 2015

Receiving TANF Not Receiving TANF

By 2005, the state had discontinued the TANF Child Care Certificate Program as a
separate, TANF-direct funded program, and folded TANF and Transitional Child Care
(TCC) participants into the CCDF priority structure as the first two priority
populations, respectively. TCC is available to individuals for a period of 24 months.
Individuals whose TANF case closes due to earnings or other reasons are the primary
recipients of TCC.

To align CCDF eligibility rules with TANF rules, the state opted to require child
support cooperation of all CCDF applicants, whether TANF or non-TANF, after the
TANF Child Care Certificate Program was eliminated.

In 2005, the first two priority groups for CCDF again became TANF and TCC
participants, respectively. Working parents at or below 50% of SMI and between 50%
- 85% of SMI were given 2nd and 3rd priority, respectively. Those sub-populations
within the second priority population (at or below 50% of SMI) were also shifted in
2005. Children in protective services/foster care were given higher priority. Children
of parents deployed in the Mississippi National Guard and Reserve were added as a
priority population in 2005. Teen parents enrolled full-time in school were given less
priority in 2005.

In 1999, Mississippi identified only 4 CCDF priority populations. From 2002 – 2004,
Mississippi identified 6 priority populations.

44
While priority populations from 2002-2004 identified attending job training or
education or work as eligible activities to satisfy CCDF’s work requirement for parents
between 50-85% of SMI, in 2005 that policy changed.

In 2005, as indicated by priority populations at the time, the state required CCDF
recipients with income between 50-85% of SMI who were attending full-time
education or job training also to work the fully-required 25 hours per week. Feedback
collected by MLICCI in 2007, as noted earlier, showed providers reporting negative
outcomes for full-time students also required to work 25 hours per week.

From 2006-2010, the state identified six priority groups. Including sub-groups given
order of priority within main priority groups, the number of priority populations
actually totaled 10. The policy regarding priority for full-time students shifted during
this period. As a fifth priority population, Mississippi identified parents attending
school or job training full-time and working less than 25 hours per week. As the sixth
and lowest priority population, Mississippi identified parents who were full-time
students and not working.

From 2011-2015, the state removed separate priority groups for parents attending
school or job training, which were the fifth and sixth priority groups. The state
reverted back to 4 priority populations, with TANF and TCC recipients remaining as
the top two CCDF priority groups. For families at or below 50% of SMI, children in
protective services/foster care, children with special needs, children of parents
deployed in the Mississippi National Guard and children of teen parents enrolled full-
time in school were given priority within this income group.

In 2016, the state again re-structured its Priority Population structure to include
“Referred Clients”. Referred Clients are directed to CCDF assistance via their
caseworker or agency. For instance, child care for TANF recipients is requested by
the recipient’s caseworker, as opposed to a non-referred client, who would
independently apply for assistance via an application to the state office. Referred
Clients include TANF, TCC, Children in protective services, preventive services or
foster care, Healthy Homes Mississippi participants and Homeless families. The 2014
CCDBG Act required states to identify homeless children as a CCDF target
population.

Mississippi currently identifies 4 overarching Priority Populations, with a total of 11

sub-priority categories. As noted earlier, recent newly approved CCDF recipients are
“referred clients”.

45
In December 2015, MLICCI obtained data from the MDHS via a Public Records Act
request showing the distribution of 19,042 children served by CCDF (not including a
small number served by slot-based contracts). Of this sample, 53.7% of children
served had parents who were working or attending school and earning below 85% of
SMI and not receiving CCDF due to participation in another program. The majority of
remaining children in this 2015 sample were in families served by TANF, TCC, child
protective services or foster care and Healthy Homes Mississippi.

* See Appendix 1 for Priority Population information.

Eligibility Periods
Policies regarding eligibility periods and redetermination have only shifted several
times since the state has administered CCDF. Eligibility periods of 6 months were the
standard practice for many years in Mississippi’s CCDF program and now 12-month
eligibility is the federal requirement.

Redetermination procedures, as noted in 2017 for instance, have throughout CCDF’s

life in Mississippi presented parents and providers with procedural steps that require
resources or capacities they lack. For instance, earlier descriptions of the state’s child
support enforcement rule added steps many single mothers struggled to comply
with as did the proof of residency requirement in 2017. Each additional step required
by such policies comes with a cost—perhaps transportation or missing work, or both.
It also costs the provider, who barters or makes payment arrangements to continue
providing care so parents in their community can work. When redetermination
periods recurred so often, providers and parents expressed angst over the process in
focus groups and surveys.

In 2010, in a MLICCI survey of child care providers under the DAs, 49% of centers
reported an awareness of cases in which a DA lost documents or made processing
mistakes related to a parent’s application during redetermination.

In the same 2010 survey of providers, more than 80% of providers cited CCDF
redetermination as a cause of disrupted services. Asked to provide a preference
between 6-month and 12-month redetermination cycles, 81% of providers preferred
12-month eligibility.

Prior to 2012, the state implemented 6-month redetermination and a “rollover” policy
for certificates. The state’s policy was that if funds were insufficient to serve all eligible
families and their providers, current CCDF participants would lose eligibility on

46
September 30th, coinciding with the end of the federal fiscal year, and would re-apply
on October 1st, the first day of the new federal fiscal year. Certificates would be rolled
over and redistributed based on established priority populations.

In 2012, the state began redetermination of parents in the months of February,

March, April and May. This meant that parents were able to retain twelve consecutive
months of CCDF, in theory. But the state also continued its “rollover” policy. In effect,
if a parent fell into a lower priority group between the month they were awarded
assistance and the rollover date, if the state in fact rolled certificates over due to a
lack of funds, then the parent may be at risk of losing her certificate.

Year Redetermination Cycle

2009-2012 Six Months (with rollover Sep. 30)
2012-2015 12 Months
Occurs in months of February, March,
April, May, (with rollover Sep. 30)
2016 12 months
Source: Urban Institute CCDF Policies Database, https://www.urban.org/policy-centers/income-and-
benefits-policy-center/projects/ccdf-policies-database.

Quality Initiatives
Federal CCDF regulations require states to set-aside a minimum amount of CCDF
funds to enhance the quality of providers receiving CCDF funds to improve the
experience and overall outcomes of children served by CCDF. MLICCI has long
supported maximizing funds on direct services and pursuing strategies that enhance
quality while not taking too much away from direct services. Federal law gives states a
wide range of options to enhance quality, including investments in the professional
development of the child care workforce. (A listing of Mississippi’s Quality Initiatives
as described in state MDHS annual reports can be found in Appendix 2).

Quality initiatives in Mississippi have wavered between supporting teachers and

professional development, to rating environmental factors to achieve star levels that
correspond to a tiered reimbursement rate. Establishing Quality Rating Systems,
which Mississippi previously did, was one of a number of options states have had at
their disposal.

When CCDF was first implemented, the state’s primary quality activity was the
MDHS’s Office of Children and Youth (OCY) Director’s Child Care Credentialing
Program, which offered a 130-hour course of study and a state-recognized credential.

47
The OCY also conducted quarterly trainings, giving teachers contact hours to meet
child care licensing requirements. Special quality initiatives included two mobile
training vans travelling the southern and northern half of the state in 1999 delivering
materials and curriculums to centers.

By the early 2000s, the state added a number of CCDF quality initiatives. The state
implemented a childhood development scholarship program, paying for training that
could count toward an Associate’s Degree. MLICCI urged the state to also adopt a
wage stipend to couple with the educational support to retain more highly trained
individuals in child care centers. Too often, providers reported that they would lose
teachers to higher paying early childhood education jobs once they increased their
education. The state never implemented a wage stipend component to complement
the scholarship program (the model for this program is TEACH, the scholarship
program that the state adopted in practice, and WAGES, the wage stipend program
that the state did not adopt).

The state established Right From Birth, a partnership with Mississippi Public
Broadcasting to supply informational videos. The state also established a home
visitation program for in-home CCDF care providers. The Mississippi State University
Early Childhood Institute also had begun Partners for Quality Child Care, a quality
evaluation initiative using environmental rating scales and offering technical
assistance based on the findings. This would form the foundation for what eventually
became Mississippi’s Quality Rating System (QRS).

In 2005, the state began supporting a small-scale collaboration with Friends of

Children of Mississippi, Inc., to provide year-round child care for 12 young children
and their parents who also were participating in job training and employment
services at a WIN Job Center. This initiative lasted years, but no data was available to
assess program outcomes.

In 2006, the state reported the development of the Quality Rating System, or the
Mississippi Child Care Quality Step System (MCCQSS), following Senate Bill 2602, or
the Mississippi Education Reform Act of 2006, which authorized and set general
parameters for MCCQSS.lix The MCCQSS began using environmental rating scales in
provider quality assessments, or the Infant/Toddler Environmental Rating Scales
(ITERS) and the Early Childhood Environmental Rating Scales (ECERS), with a stated
purpose to assess, improve and communicate the level of quality in licensed child
care centers. The program was piloted in counties served by East Mississippi
Planning and Development District, one of Mississippi’s Designated Agents

48
administering CCDF at the time. If centers achieved better ITERS and ECERS scores,
they would also receive a higher CCDF reimbursement rate.

In 2007, the state offered the Child Care Development Associate Credential that
provided a Child Development Associate (CDA) associate credential through the
National Association for the Education of Young Children (NAEYC) for Professional
Recognition. The state no longer reported maintaining the previous OCY childhood
development scholarship program.

By 2007, the MCCQSS had served nine counties and by 2008 projected to serve 20
more counties. The emerging Quality Rating System continued to grow, offering
participating centers a 7% - 25% quality bonus for each child participating in the QRS
(Star 5 would yield a center 83% of the state’s Market Rate and Star 1 58% of the
Market Rate).

In 2008, 730 licensed centers had gone through ITERS and ECERS evaluations
through MSU’s Partners for Quality Child Care at MSU’s Early Childhood Institute. The
state’s QRS developed 5 Star levels, each with a corresponding increase in
reimbursement, with Star 5 as the highest level of quality.

In July 2009, the MCCQSS, also referred to as “Mississippi Quality Stars” or simply
QRS, was offered statewide. At the time, there were 337 participating licensed
centers. By 2013, a total of 522 licensed providers participated in QRS. A total of 415
were evaluated, and of those evaluated, only 9 were rated as 5 Star, while 85% were
at 1 and 2 Star levels. Mississippi’s QRS had a low take-up rate among licensed
providers, at its peak it reached one-third of licensed providers. Of those who did
participate, climbing the Quality Stars ladder was cost prohibitive.

In 2010, MLICCI surveyed providers about their experiences with the QRS. Fifty-five
percent of respondents participated in the QRS at the time. Most providers
responded that their motivation for participating in QRS was to improve the quality of
child care, increased funding and a desire to do what’s best for the children. MLICCI
asked providers to describe their experience with the QRS. Responses included,

- “very harsh grading system; couldn’t meet up to their standards”

- “challenging, hard work, and rewarding at the same time”
- “like the people I work with, but the program is too strenuous”
- “Finances mostly pose a problem in accomplishing all they have required”

Providers opting not to participate in QRS reported a lack of qualified staff and
general capacity and many cited a lack of funds to implement all the requirements.
49
An important point is that QRS, or any other quality initiatives during this time, were
mandatory, meaning that a provider was not precluded from being eligible to serve
CCDF children if they opted not to participate in QRS.

By 2014, the participation rate in QRS had not improved, nor had the rate of centers
achieving higher than Star 2. In July 2014, the MDHS consolidated all of its quality
improvement initiatives under one umbrella at MSU called the Early Years Network.
This included the Quality Rating System and other programs previously scattered
over multiple entities.

In 2016, 537 licensed centers participated in the QRS and the majority were Star
Level 1 and 2. The state noted in its 2016 Annual Report that it had convened a group
of stakeholders and planned to revise the QRS in the forthcoming year.

MLICCI had unearthed a significant body of evidence of the cost-prohibitive nature of

the QRS Star Level structure and the too-often negative experience providers had
with subjective raters, or individuals tasked with rating a center using ITERS and
ECERS. Achieving higher star levels was costly and those expected to participate
were providers serving low-income working families. No additional funds to
participate in the QRS were made available to centers.

MLICCI’s “Step Up” report was a long term study and pilot project consisting of 16
centers receiving funds and resources to climb the Quality Stars ladder. Detailed cost
per classroom calculations were documented, tracking every dollar of quality funds
invested and what benefits the center experienced. The study, which lasted from
2010 to 2014, showed that on average $11,500 per classroom was spent to climb just
one Quality Star level.lx MLICCI published results and called for adequate funding to
allow all centers, particularly African American owned centers serving large shares of
CCDF children and parents, to participate and improve their QRS ratings. MLICCI and
many in the low-income child care community saw this policy as creating a
segregated system, where African American low-income providers would struggle to
benefit and face lower revenues as providers that could afford the quality
improvements necessary to climb Star levels would continue getting higher CCDF
reimbursement rates. This approach posed serious harm to the overall financial
viability of African American owned centers serving low-income communities.

In an August 2016 MLICCI survey of providers, QRS was still viewed as cost
prohibitive by providers.lxi In early 2016, MLICCI testified about the financial harm
imposed by the QRS to the Mississippi Advisory Committee for the United States
Commission on Civil Rights. MLICCI testified about lack of access among African

50
American providers who most need additional investment and that without funding
to implement required quality measures, the system would only benefit those who
rely less on CCDF and who have funding for quality improvement already.lxii

By the end of 2016, Mississippi had eliminated its contract with the Early Years
Network and the quality initiatives it housed. The QRS was eliminated as part of the
contract termination.

In 2017, Mississippi’s reported quality initiatives looked far slimmer than in previous
years. The state identified only the newly established Early Childhood Academies—
housed at community colleges and under the Mississippi Community College Board
(MCCB)—and tasked with providing technical assistance under a new plan from the
Mississippi State Early Childhood Advisory Committee.lxiii

The Mississippi SECAC has played an increasing role in CCDF policymaking in recent
years. MLICCI has continuously pressed SECAC to focus on systems alignment and to
see CCDF through the lens of low-income working moms.

In 2016, as the state’s QRS was coming to an end after many years of minimal take-up
among licensed providers and significant state funds invested, SECAC released a
new early childhood plan called A Family-Based Unified and Integrated Early
Childhood System. lxiv This plan lays out a new framework for assessing quality in
CCDF-approved licensed center-based care. It has defined two quality designations
available to centers in order to serve CCDF children: Standard Center and
Comprehensive Center.

The state has not yet finalized what will be required for Comprehensive Centers and
has proposed pilots as a first step.

In its 2019-2021 CCDF State Plan, Mississippi has identified October 2019 as the
deadline that all licensed centers serving CCDF-eligible children must become
designated as a Standard Center.lxv The initial deadline was October 2018, but this
was later revised to give all centers an opportunity to be designated under the new
system.

Criteria for becoming a Standard Center are that a center must submit an online
application, it must be licensed or registered with the state department of health, it
must comply with all federal health & safety training requirements, it must have a
curriculum that aligns with the state’s Early Learning Guidelines and it must conduct a
personnel assessment. Health & Safety trainings are offered online and in-person
through the Early Childhood Academies (ECAs). Additionally, the ECAs provide

51
technical assistance on any matters pertaining to curriculum enhancement identified
by MDHS and the ECAs at no cost to the center.

A new Market Rate Survey was finalized in 2018. Two new rates were set: Standard
and Comprehensive rates. The Standard rate is at the 75th percentile of the Market
Rate.lxvi Many providers that received a higher reimbursement under QRS will receive
an increase with the Standard rate, given the previous QRS’s top Star 5 rate was 83%
of a lower overall Market Rate.

Members of SECAC have emphasized that the new system of Standard Designation
does not use environmental rating scales and will avoid establishing a segregated
system. Members of SECAC have acknowledged the shortfalls of the previous QRS.

At the 2018 State Plan public hearing, MDHS officials confirmed that the only
elements of the Standard Center online application that would disqualify a provider
from serving CCDF families would be failing to comply with federal health & safety
requirements and not submitting an online application altogether. The ECAs are
tasked with providing technical assistance to correct any other application
component that prevents a positive eligibility determination.

The state has moved in a substantially different direction with the implementation of
Standard Centers. Under the previous QRS, participation was voluntary. This meant
that a center’s ability to serve a CCDF family was not at risk if they didn’t participate.
Under Standard Centers, the state has opted to establish a mandatory quality
improvement designation for centers to retain eligibility to serve CCDF families.

At the time of this report, the state has not yet terminated any center’s CCDF
eligibility for not turning in a Standard Center online application or for any other issue
related to online application responses. But the deadline, while one year from this
writing, is approaching. It is unclear at this stage how the shift to a mandatory quality
improvement requirement will affect the overall CCDF delivery system and the
number of providers who are eligible to serve CCDF families.

CCDF Policymaking,
Gender and Race
Racial and gender equity is only achieved when a group’s level of access to public
resources, to education, to the labor force and to economic opportunity cannot be
predicted solely by their gender and by their race. Structural racism exists when
52
policies, procedures and practices that create or perpetuate adverse outcomes for
people of color are legitimized when codified in our structures and institutions
governing public policy and the allocation of public resources. This is particularly
evident when negative impacts of current policies on the end-users of CCDF are well-
documented yet do not inform or initiate change.

When CCDF policies hinder a parent’s ability to access resources to retain child care
assistance or when funding is lost due to state or agency budget decisions and fewer
can be served than who should be, such acts legitimize a policy that has a negative
effect on primarily one racial group. As mentioned earlier in the report, in Mississippi
that group is unequivocally African American single mothers and their children.

For each year that data has been reported, an overwhelming majority of children
served by CCDF in Mississippi are African American.lxvii

Monthly Average Percentage of Children Receiving CCDF Child

Care by Race/Ethnicity in MS
100% 90% 90% 90% 92% 92% 91%
87% 88% 87% 89% 87% 88% 89% 88% 87%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Native Alaskan/Native American Asian African American

Native Hawaiian/Pacific Islander White Multi-Racial

While CCDF in Mississippi has served primarily African-American children and their
working parents over the program’s life, CCDF is still inadequate to meet the need
among Mississippi’s African American low-income working families. The Center for
Law and Social Policy (CLASP) found in a 2016 study that CCDF in Mississippi only
reaches an estimated 16% of CCDF-eligible African American children.lxviii

In February 2016, the U.S. Commission on Civil Rights conducted field research and a
public hearing to examine the racial impact of how CCDF subsidies are administered
and distributed in Mississippi. The Commission issued a report, Low Income Child
53
Care Subsidies Distribution in the State of Mississippi, documenting testimony from
early childhood and other stakeholders regarding the impact of Mississippi’s CCDF
policymaking on African Americans. MLICCI provided testimony based on its
experience documenting the impacts of CCDF policies from the perspective of child
care providers and parents over many years and several surveys. The Commission’s
report found that a number of Mississippi’s discretionary state policy options
“unnecessarily” restrict eligible families in greatest need from accessing CCDF, that
the state’s Quality Rating System had been less accessible to African American early
care and education providers and that the state reported a large unspent,
unobligated balance of federal TANF funds, which as noted earlier could have
allowably been spent directly on child care above and beyond the state’s allowable
transfer of TANF funds to CCDF. The Commission’s report led to national
recommendations for states to examine how their CCDF programs are administered
and how they are addressing racial disparities.lxix

Research examining the “users” of CCDF underscores the importance of seeing

CCDF at the intersection of race and gender in Mississippi. CCDF policies will hinder
or help overwhelmingly African American single mothers and their children.

MLICCI’s 2018-commissioned study, The Mississippi Child Care Policy Imperative:

Assuring Policy Implementation Maximizes Policy Intent, uses the lens of racial equity
to understand and appropriately contextualize the impact of child care policy
decisions in Mississippi. It asserts that, “If, as a result of institutional policies and
procedures, a lack of access occurs disproportionately among African American
children, whether willful or inadvertent, then this is racial inequity.” When policies
result in a lack of access among African American children, it has often been due to a
procedural step imposed on their African-American mother breadwinner and single
head of household. Therefore, every policy governing CCDF administration and
eligibility procedures should be seen not only through a lens of racial equity, but
through a lens of gender equity, which is hindered when access to economic security
and opportunity is denied. CCDF policy issues exist at the intersection of gender and
race. The long-documented pattern over time suggests certain CCDF policies have
not included an informed racial and gender equity lens, as evidenced by the
prolonged impact of certain state policies documented as causing single mothers the
denial of CCDF assistance even when they are work- and income-eligible.

54
Conclusion
Critical moments have shaped Mississippi’s CCDF program. It is nearly impossible to
sum up the administration, spending and policymaking for such a complex program
over such a long period of time in one or two short sentences. In our research, we
observed moments where sharper year-to-year changes in caseloads or in
expenditures were, in most cases, likely influenced by a confluence of factors. For
instance, looking at the state-reported caseload drop following 2012, we also saw
that tensions among providers and parents were heightened due to the “finger
scanning” proposal, we documented evidence showing the state was still newly
adjusting to centralized administration of CCDF and rebuilding a program with an
insufficient administrative record, and we documented how the infusion of ARRA and
the jolt it provided to CCDF direct services spending had faded by this time. Also, by
2012, the state had moved to 12-month eligibility as opposed to 6-month eligibility.
All of these factors may have influenced a sharp caseload drop, but it is difficult to
isolate a single variable as the cause for some of the more notable shifts.

But, there were other instances in our research that were more isolated,
demonstrating how directly impactful some policy decisions were on providers and
parents reliant on CCDF. For instance, the caseload grew dramatically after the
abrupt and substantial infusion of ARRA funds in CCDF direct services expenditures
in 2010. This was a clear case of more money resulting in more kids served. When the
state eliminated the TANF Child Care Certificate Program and folded TANF into
CCDF in 2004, it also required child support enforcement for all CCDF recipients, it
reduced its spending on child care directly from TANF and it transferred a very low
amount of TANF to CCDF. It was also still recovering from a failure to meet CCDF
matching requirements and a loss of federal funds in the early 2000s. These policy
decisions resulted in the share of non-TANF low-income working families receiving
CCDF to reduce and the lowest federal fiscal year direct services expenditure (2004)
ever reported by the state. These factors may have directly influenced a lower state-
reported CCDF caseload number in 2004 and 2005.

In 2018, the state is moving in a positive direction. Though, given CCDF’s history in
Mississippi, the state has not landed on an approach to CCDF administration it has
stuck with yet and some early childhood stakeholders are cautiously optimistic
moving into the third decade of CCDF in Mississippi. The state has consistently and
continues to spend a majority of CCDF funds on direct services. For the first time, the
state opted to maximize its TANF transfer to CCDF for federal fiscal year 2017,
55
transferring the full 30% allowed. The state also has significantly more CCDF
discretionary dollars coming in during FFYs 2018 and 2019 thanks to Congress’s
2018 budget deal, which included the CCDF increase. These additional funds will be
sufficient to eliminate Mississippi’s CCDF Pending Funding list and recent state
reports indicate this is a real possibility. The additional funds will also allow the state
to increase the number of children served and increase the number of low-income
working parents who can participate in the labor market. The state also now has
longer eligibility periods for all CCDF populations and no longer has a “rollover”
policy. CCDF recipients retain assistance for a full twelve consecutive months. The
state also has increased CCDF reimbursement rates to the 75th percentile of the
Market Rate. And the state’s new quality improvement strategy, while now mandatory
for CCDF providers, seems to be structured to maximize access and the state has
explicitly stated its intention of avoiding the creation of a segregated system only
accessible to providers with more money and resources. The state has also extended
the deadline to bring all centers into the new system to October 2019.

While CCDF in Mississippi is not easily summed up, here are some general takeaways
and recommendations based on our research and observations from 20 years of
CCDF spending and policymaking that we hope policymakers will keep in mind as
CCDF in Mississippi continues to transform in its third decade:

Money Makes a Huge Difference and there’s not enough to meet the
basic need. Direct Services must be the spending priority.
When Mississippi had to spend a large, temporary infusion of ARRA dollars, it
put the lion’s share in direct services and our caseload skyrocketed. Even then, with
an extra $30 million to spend quickly, the number of kids we served barely touched
half who were eligible in the state. When state matching funds have been inadequate
to draw down the full federal amount available, the level of service has dropped. This
means CCDF funds are fragile and direct services should be maximized. This also
means that funding for child care assistance for working parents must be increased,
both at the federal and state level. Low-income working parents need reliable, stable
child care to work. Support services that enable a parent to work can also support the
environment a parent needs to focus on increasing their skills through training or
education. This makes attaining a living wage a more realistic option.

Direct services have remained as the highest share of the state’s CCDF
expenditures during federal fiscal years. While a slight decline was noted in recent
years, still most dollars the state spends in CCDF is currently reported as going to

56
direct services. Maximizing the state’s direct services expenditure is critically
important given the shift to minimum 12-month eligibility periods and increased
spending on quality activities. Minimum 12-month eligibility may reduce the total
number of children and families the state will be able to serve, assuming a higher
number of parents would cycle off of assistance after 6 months under previous
policies (though, in many cases, for procedural reasons and not ineligibility). While
this is a positive change for parents and providers, it may spread limited funds
thinner—a point that MLICCI has long made and a reality that early childhood care
providers must mitigate. Additionally, every dollar spent outside of direct services
limits the potential number of children and families served. Mississippi’s constant
deficit of eligible children served—due to already-inadequate funding—necessitates
this funding policy. The state will face a challenge in balancing the priority to fill the
unmet child care need with increased spending on quality activities.

While federal funds are inadequate to meet the need for CCDF in Mississippi,
our research documented moments when the state invested more dollars in child
care. At one point in time, the state funded child care certificates for TANF recipients
using TANF funding, it transferred TANF to CCDF and it spent CCDF funds. Putting
more federal and state dollars in child care for the working poor was achieved in the
past and is possible in the future. Maximizing the transfer from TANF to CCDF is also
critically important, as evidenced in 2004, the year of the state’s lowest TANF transfer
was also its lowest reported CCDF direct services expenditure, resulting in a lower
caseload number.

Mississippi has a tremendous opportunity — similar to what it had between

2009-2011 with ARRA funds — with increased CCDF funds in federal fiscal years 2018
and 2019. The increase will be even more than the ARRA infusion, nearly doubling
the state’s discretionary funding allocation, which make up the bulk of federal CCDF
funds. The state has already reported that increased federal funds will allow it to
eliminate the Pending Funding list and data last reported publicly shows the MDHS is
well on its way to accomplishing that important goal. While the state has increased
CCDF reimbursement rates to providers and is shrinking the Pending Funding list, it
must also work to increase the overall number of children served with additional
funds.

57
Our recommendations include:
• Maximize expenditures on direct services

• Use 2018-2019 CCDF Discretionary fund

increase to increase the number of children
served to at least 40,000

• Support the creation of an inter-agency task

force to identify all funds that can allowably be
spent on child care assistance or child care as a
work support and create recommendations for
streamlining and maximizing those funds

• Continue transferring 30% of TANF to CCDF

• Increase TANF direct spending on child care

• Request additional appropriation from the
legislature in the amount necessary to meet the
state CCDF matching requirements to prevent
any future loss of potential federal CCDF funds

58
CCDF administration and policies have been inconsistent through the years. This has
fueled tension and distrust between providers, parents and the state agency.
Improving this relationship must be a priority.

This reality is evidenced by numerous focus groups and surveys conducted in

Mississippi over many years and even as recent as MLICCI’s 2018 study of the 2017
CCDF redetermination process. Mississippi must acknowledge this reality and build
relationships with CCDF providers and parents within a context of healing and trust-
building. Improving this relationship is imperative not only for providers and parents
who are reliant on CCDF, but also for MDHS as they administer a complicated
program that helps keep Mississippians in jobs and in job training—a primary goal of
our state’s current political leadership. CCDF providers and parents know how
policies play out on the ground and they must be the most vital resource in CCDF
policymaking. They know how well CCDF works and how transformational it can be
when access is simple and designed to eliminate disparities that are in large part the
result of poverty. CCDF providers and parents would be the best resources for
explaining to state legislators how important and how impactful CCDF is when MDHS
is seeking an adequate state budget allocation from the legislature so it doesn’t ever
have to leave child care funds on the table. Building trust between CCDF
policymakers and the end-users of CCDF will result in an even stronger program.

Racial and gender equity have not guided CCDF policymaking in Mississippi.
Policy guided by an equity lens will allow CCDF to be a catalyst for economic
growth.

Surveys and focus groups conducted over many years show a common thread
of race and poverty cited by providers and parents as factors leading to what in their
view has been punitive policymaking and a lack of program oversight. Such instances
were evidenced in the 2016 U.S. Commission on Civil Rights report. MDHS’s choice
to hold the 2019-2021 CCDF State Plan public hearing on a Saturday and in the
Mississippi Civil Right Museum in Jackson, MS no doubt represented an intentional
and symbolic set of choices to recognize the context within which CCDF
policymaking occurs. These choices made by the agency may be seen as an
intentional effort to set a positive tone with CCDF providers. CCDF in Mississippi is
most relied upon by black single mothers and their children. Any decisions that
impede access to CCDF also impede opportunities that a black single mother has to
improve her circumstances, and thusly denies equal access to economic opportunity.
Policy guided by a gender and racial equity lens will reduce barriers to accessing

59
CCDF and instead will make access easier and will help increase employment
retention and increase skills to fill jobs that are currently out of reach to many low-
income single moms.

The State Makes CCDF Policy Unnecessarily Complicated for No Reason. It

should stop.

Based on our research of Mississippi’s CCDF program over the last twenty
years, policy change that is responsive to needs expressed by parents and providers
is generally implemented with little increased administrative burden and makes a
positive difference, as reported by those who rely on CCDF. Conversely, policy
change that is implemented in response to an assumed problem that is not
expressed by the provider or parent is generally implemented with complication and
increased administrative burden and often has a negative effect, as reported by
CCDF end-users.

For instance, one example documented in our research was best captured in
the 2007 OSA Audit of the state’s CCDF program. In it, OSA discussed a number of
policy changes the MDHS had made since CCDF went into effect. It cited the decision
to implement Child Support Enforcement for all CCDF participants and as a condition
of CCDF eligibility, even though federal law did not require the policy. While
feedback provided by parents and providers regarding the new requirement was
negative, the policy remained in place, and, as discussed in this report, coincided
with the elimination of a TANF direct funded child care program for TANF recipients.
The OSA discussed this policy as having a “dual application” effect, making the
process more burdensome for working parents when implemented.

The OSA also cited a policy change that was based on a need as documented
and expressed by providers and parents using CCDF under the DAs, which was a
segmented CCDF delivery system. Under the system, providers were left with
inconsistent policy guidance and information. When the agency created a uniform
policy manual, providers were better informed and policy compliance improved.

The Stennis Institute’s report on biometric finger scanning noted a similar

moment in 2012, describing the policy decision to require finger scanning—a policy
based on an assumption and deeply opposed by the end-users of CCDF—after it had
just eliminated the DA system and centralized CCDF, which was a policy decision that
was viewed favorably by providers and parents at the time and the agency faced little
resistance from parents and providers in implementing that policy decision.

60
 In 2008, a decade following the implementation of CCDF, MLICCI
commissioned a report from the Urban Institute synthesizing CCDF policy research
and identified policy approaches that best support low-income families.lxx The report
ultimately found that CCDF policies created with the intention to simplify processes,
reporting requirements and procedures for parents and providers, with a particular
focus on reducing termination of CCDF and creating flexibility for parents’ temporary
changes that may affect eligibility, are mutually beneficial for those who rely on CCDF
and for state agencies, which generally have an interest in lowering administrative
burden.

The 2014 CCDBG Act now requires states to establish policies that avoid
imposing any undue burden on parents seeking to attain or maintain their CCDF
assistance. Undue burden occurs when a parent has to interrupt work, training or
school to comply with CCDF eligibility requirements. It is in the state’s interest to
simplify CCDF eligibility procedures so as to avoid imposing any undue burdens on
parents seeking CCDF assistance.

Policy approaches such as expanding the CCDF priority population list to such
an extent that CCDF’s initial target population (working parents below 85% SMI) now
represents an increasingly declining share of CCDF recipients, and particularly new
recipients, demonstrates the result of making CCDF policy too complex. Many other
policies have demonstrated this same tendency: the still-active child support
requirement (the decision to link TANF and CCDF so inextricably to the point of
importing arguably TANF’s most harmful policy to single mothers), or the ‘finger
scanning proposal’, or the newer (but now eliminated) “proof of residency” policy, are
all examples of unnecessarily complex policies that end up harming the CCDF end-
user and overly burdening the MDHS.

The state must separate what policies and priorities actually meet the needs of
CCDF end-users (as they report) from those that respond to an ideology or
assumption, which often fuels discontent among those who need CCDF most.

61
 Our recommendations to make
CCDF policy less complicated:
- Eliminate the child support requirement from
CCDF policy
§ do not require non-TANF CCDF recipients
to comply with Child Support Enforcement
to be eligible for CCDF
§ create an alternative policy allowing
parents to sign an affidavit stating the
father is contributing to the support of
children
- De-link TANF from CCDF
§ Re-establish the TANF Child Care
Certificate Program with TANF Direct
Spending to free up CCDF funds for non-
TANF working parents
- Simplify priority populations
§ Re-establish 2002-2004 Priority Population
Structure to diversify the eligible
populations receiving CCDF

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CCDF is an Under-Funded Federal Work Support Program. CCDF policy must be
seen through the lens of single mothers reliant on CCDF as a work support, and
not as a platform for “quality improvement” experiments. Quality investment
and improvement must be accessible to all providers and its goal must be to
reduce disparities in the early childhood system.

We already know what works for low-income parents—supports they can rely
on, supports that are easy to access and last long enough, and jobs that pay a living
wage. Quality improvements are required by federal law, but states have a range of
options. Often, as MLICCI has learned from providers over the years, investment in
the professional development of the child care workforce helps improve the
experience of children in the center and the overall quality of the child’s educational
experience. For many years, as this report showed, the state supported child care
teachers in earning a CDA and a scholarship for credit-based training that would
count towards an Associate’s degree in early childhood education. While this quality
improvement makes a real difference on the ground level, child care centers serving
low-income communities struggle to afford higher wages that are justifiably expected
with increased levels of education. Without the state also supporting a wage stipend
to retain more highly qualified teachers in centers, such a strategy may create a road
out of child care.

Assessing an individual center’s level of “quality” can often be a subjective

process, even when using evidence-based environmental rating scales. This was
documented during MLICCI’s Step Up study of Mississippi’s QRS. Any state-
administered system of “quality” that is tied to an increased reimbursement rate or
required for provider CCDF eligibility will leave some providers disconnected from
the system, due either to an associated cost that a provider cannot meet or to a
bureaucratic process that providers are not complying with. The state should take this
into consideration as it implements the new Standard Center mandatory designation
for quality improvement. The 2019-2021 CCDF State Plan also describes a number of
new professional development strategies, such as a “Work Based Learning Pathway”,
which seems to be reminiscent of an “earn and learn” system, but these details have
yet to be finalized by this writing.

Other recommendations regarding CCDF quality initiatives include:

- Establish TEACH and WAGES as quality improvement strategies. TEACH

provides a structure for an early childhood scholarship. WAGES provides a

63
 structure for centers receiving a stipend to supplement income of teachers
increasing their educational attainment through TEACH to retain them in the
classroom.
- Given it is a mandatory requirement, explore alternative options to Standard
Center designation for licensed center-based providers who don’t want to
participate, but want to continue serving CCDF children

CCDF can be transformational. Make it simple. Connect it to the Working Poor.

Get employers to see its benefit. And it will be transformational.

Getting employers to see the benefit of the significant investment the state makes
each year in providing child care that enables Mississippians to participate in the
labor force is critical for increasing investment and interest in CCDF. We encourage
the state to set a goal of providing each CCDF recipient with information related to
the state’s “Middle Skills” job openings and its related workforce training options. In
particular, we recommend the state ensure CCDF recipients are given priority for
core and intensive state work-based learning opportunities and job training services.
Child care as a work support is crucial, but equally crucial is increasing the earnings
of mothers who rely on CCDF. Many of these mothers need training and education to
enter a higher-paying field. If simplified, CCDF can help make this transformation for
parents and simultaneously advance the state’s workforce goals and better meet the
needs of employers in Mississippi.

CCDF is yet at another critical moment in 2018 after yet another massive
overhaul.

MLICCI is deeply committed to working with all stakeholders in early

childhood to improve the economic security of low-income working Mississippi
mothers and their families. What form will the program take from here? What will the
many recent changes look like? We’ll see you in ten years.

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For questions about this report or to obtain any referenced data on file with the
author, email: [email protected].

Appendix 1. Evolution of Priority Populations,

As Reported in State MDHS Annual Reports
1999 Priority 1 – TANF participants
Priority 2 – Individuals transitioning from public assistance to the
workforce
Priority 3 – Very Low Income parents under the 50th percentile of SMI at
risk of going back on TANF
Priority 4 – Low Income Parents between 50 - 85% of SMI
2002 – 2004 Priority 1 – Children of Parents Transitioning off of Transitional Child Care
(TCC)
Priority 2 – Below 50% of SMI at risk of going on TANF in following order
(A. Teen parents attending school full-time, B. Special Needs, C. Foster
Care/Protective Services, D. Children of all other eligible parents at this
income level

65
 Priority 3 – Between 50-85% of SMI, working or in approved
education/training program

2005 Priority 1 – child care for TANF

Priority 2 – child care for TCC
Priority 3 – Below 50% of SMI at risk of going on TANF in following order
(Children in protective services or foster care, Children with special needs,
Children of parent(s) deployed in the Mississippi National Guard and
Reserve, Children of teen parent(s) currently enrolled in school full-time,
Children of all other eligible parents at this income level
Priority 4 – Children of parent(s) in an approved full-time educational or
training program and working the required hours, whose income falls
above 50% of the SMI and at or below 85% of the SMI

2006 – 2010 Priority 1 – child care for TANF

Priority 2 – child care for TCC
Priority 3 – At or Below 50% of SMI at risk of going on TANF in following
order (Children in protective services or foster care, Children with special
needs, Children of parent(s) deployed in the Mississippi National Guard
and Reserve, Children of teen parent(s) currently enrolled in school full-
time, Children of all other eligible parents at this income level
Priority 4 - Based upon the availability of funding, children of parents
working the required 25 hours per week whose income falls above 50% of
the SMI, and at or below 85% of the SMI
Priority 5 - Based upon the availability of funding, children of parents in
an approved full-time educational or training program and working less
than 25 hours per week regardless of whether the family income reaches
up to 85% of the SMI
Priority 6 - Based upon the availability of funding, children of parents in
approved full-time education or training and not working

2011 - 2015 Priority 1 – child care for TANF

Priority 2 – child care for TCC
Priority 3 – At or Below 50% of SMI at risk of going on TANF in following
order (Children in protective services or foster care, Children with special
needs, Children of parent(s) deployed in the Mississippi National Guard
and Reserve, Children of teen parent(s) currently enrolled in school full-
time, Children of all other eligible parents at this income level
Priority 4 - Based upon the availability of funding, children of parents
working the required 25 hours per week whose income falls above 50% of

66
 the SMI, and at or below 85% of the SMI

2016 Priority 1 – Referred Clients

- TANF
- TCC
- Children in protective services, preventive services or foster care
- Healthy Homes Mississippi participants
- Homeless families
Priority 2 - Special or At Risk populations up to 85% of the State
Median Income including (in following order)
- Single parents with special needs
- Children with special needs
- Parents deployed in the Mississippi National Guard or Reserve
Priority 3 - Children of very low income working parents whose
income is at or below 50 percent of the State Median Income and who
are at risk of going on TANF (in following order)
- Children of teen parents currently enrolled in school full-time
- Children of all other eligible parents at this income level
Priority 4 - Based upon the availability of funding, children of parents
working the required 25 hours per week whose income falls above 50
percent of the SMI and at or below 85 of the SMI.
2017 – Priority 1 – Referred Clients
Present - Child care for Temporary Assistance for Needy Families (TANF)
recipients
- Child care for Transitional Child Care (TCC) recipients
- Child care for children who are homeless
- Child care for children served by the Mississippi Department of
Child Protection Services (MDCPS)
- Child care for children served by the Healthy Homes Mississippi
(HHM) home visitation program

Priority 2 - Special needs populations whose income is less than 85

percent of the State Median Income (SMI), in the following order

- Children of single parents with disabilities

- Children with special needs
- Children of parent(s) deployed in the Mississippi National Guard or
Reserve

Priority 3 - Children of very low-income working parent(s) whose income

is at or below 50 percent of the State Median Income (SMI), in the
67
 following order

- Children of teen parent(s) currently enrolled in high school full time

- Children of all other eligible parent(s) at this income level, including
parents enrolled in an approved educational or job training
program, whether working or not

Priority 4 - Based upon the availability of funding, children of parent(s)

working the required 25 hours per week and/or are enrolled in an
approved educational or job training program and whose income is
greater than 50 percent but less than 85 percent of the SMI

Appendix 2. Quality Activities and Initiatives, as reported in

MDHS Annual Reports
State Selected Quality Activities (Reported Activities are from MDHS
Fiscal Annual Reports)
Year
1999 The OCY Director’s Child Care Credentialing Program (implemented
January 1996)
- 130-hour course of study of best practice child care management
- 400 individuals have completed and are Credentialed Directors

The OCY Child Care Connections Mobile Training Vans

- Two mobile vans – one traveling the northern half of the state, the
other covering the southern half
- Brings free resources, curriculum guides and other materials to
centers

OCY Quarterly Early Childhood Development Training

- Six contact credit hours for 3 sessions and 9 available at
conference to assist provider in meeting licensure requirements
- 1,091 participants completed training
2002 – 2004 Mississippi State University Early Childhood Institute/Quality Evaluation
Initiative
- Evaluates licensed centers throughout state focusing on
improving level of quality using child care environment rating

68
 scales
- 250 centers selected to participate
- technical assistance is provided as part of the project

OCY Early Childhood Development Training

- Free early childhood development training provided to centers
throughout the state
- Assists caregivers in obtaining staff development hours required
for licensing

Right from Birth – Mississippi Educational Television

- Provides training on brain development during the first 18 months
of life
- Distributes tapes, printed materials to caregivers and weekly
workshops
- Provides contact credit hours for licensure
- Added “And Going to School” in 2004 as a series on successful
school habits
Nurturing Homes Project – Mississippi State University Extension Services
- Evaluates and provides training to in-home providers

OCY Early Childhood Development Scholarship Program

- Provides financial support for early childhood workers to obtain
professional development or training in early childhood that
counts toward an Associate’s Degree

OCY’s Director’s Credentialing Program

- Provides credentialing training
- 1,000 individuals have successfully completed credentialing
training as of 2003; (1,000 reported in 2003; 1,284 reported in
2004)
2005 Mississippi State University (MSU) Early Childhood Institute/Quality
Evaluation Initiative
- grant awarded to MSU to continue evaluation of licensed child
care centers throughout the State of Mississippi, focusing on
improvement of the level of quality offered at each center
- Technical assistance is provided in conjunction with the evaluation
component of the project
- Centers participating are evaluated using a nationally recognized
child care environmental rating scale

69
 Right From Birth and Going to School - Mississippi Public Broadcasting
(MPB)

Nurturing Homes Project - Mississippi State University Extension Services

** WIN/Job Center/OCY Collaboration - OCY in conjunction with

Friends of Children of Mississippi, Inc. implemented a pilot one-stop
shop on-site project that provided child care services to support
parents who were accessing educational resources and employment
training at the WIN Multi-Purpose Center. This project provided year
round child care for 12 children ranging in ages eight weeks to five
years old at any given time.

Office for Children and Youth Early Childhood Development Scholarship

Program

OCY’s Director’s Credentialing Program

- 1,502 served

2006 Development of a Quality Rating System for Mississippi Child Care

Providers - OCY staff and other Early Childhood Professionals completed
the development of Mississippi’s Child Care Quality Step System
(MCCQSS). The MCCQSS is a method to assess, improve and
communicate the level of quality in licensed early child care and
education settings. The MCCQSS has five components: Administrative
Policy, Professional Development, Learning Environments, Parental
Involvement and Evaluation. Mississippi adopted the motto “Step Up to
Star Quality.” The MCCQSS proposed goals are: prepare all children to
learn and be ready for school; teach children to learn, value and respect
authority; practice self-discipline, and be observant and practice
socialization skills. As licensed child care providers advance to higher
levels of quality care, they receive a higher reimbursement. The
implementation phase and pilot program of MCCQSS will begin in
counties served by East Central Planning and Development District.

Nurturing Homes Project - Mississippi State University (MSU) Extension

Services

OCY’s Director’s Credentialing Program

70
 “Right From Birth” and “Going to School”

The Mississippi State University Early Childhood Institute/Quality

Evaluation Initiative

WIN Job Center/OCY Collaboration

2007 Nurturing Home Initiative - Mississippi State University (MSU) Extension

Services-
The Nurturing Home Initiative provides educational training and
technical assistance to unlicensed in-home childcare providers that offer
full-day full-year child care services to eligible families. This initiative is a
statewide effort to improve the quality of care being provided within “In-
Home” child care settings. The training and evaluation activities
delivered through this initiative will have a measurable impact on the
improvement and enhancement of quality care.

Partners for Quality Child Care, MSU Early Childhood Institute (ECI) - This
initiative provides quality technical assistance and assessments for
caregivers in licensed child care settings throughout the state and
identifies the high level of quality child care through the use of nationally
recognized environmental rating scales. The Infant/Toddler
Environmental Rating Scales (ITERS) and the Early Childhood
Environmental Rating Scales (ECERS) are used to assess the
development and enhancement of licensed facilities.

OCY Director’s Credentialing Program/Mississippi Forum on Children

and Families Inc. Since its inception, a total of 1,911 child care
professionals have successfully completed the training.

Child Care Development Associate Credential OCY/University of

Southern Mississippi (USM) - Provides training and support to child care
workers in licensed child care settings statewide so they may obtain the
Child Development Associate Credential (CDA) through the National
Association for the Education of Young Children (NAEYC) for
Professional Recognition. The CDA is a nationally recognized credential
which documents an individual’s training to provide quality child care
services. Students may receive assistance for the cost of training,
applications and assessments. Students are trained to work with parents
71
 and other adults to nurture children’s physical, social, emotional and
intellectual growth in a child development framework.

MSU Extension Services

WIN Job Center/OCY Collaboration

Mississippi Child Care Quality Step System - OCY implemented the

Mississippi Child Care Quality Step System (MCCQSS) as a system to
assess, improve and communicate the level
of quality in licensed early child care and education settings. MCCQSS
has five components: Administrative Policy, Professional Development,
Learning Environments, Parental Involvement and Evaluation. Mississippi
adopted the motto “Step Up to Star Quality.” MCCQSS proposed goals
are: prepare all children to be ready for school; teach children to learn,
value and respect authority; practice self-discipline; be observant and
practice positive socialization skills. As licensed child care providers
advance in higher levels of quality care, they receive a higher
reimbursement. MCCQSS was launched in the East Central Planning and
Development District (ECPDD) as a pilot project serving nine counties in
SFY 2007. Beginning in SFY 2008, twenty additional counties served by
the Golden Triangle Planning and Development District (GTPDD), the
North Central Planning and Development District (NCPDD) and the
Northeast Planning and Development District (NEPDD) will be eligible to
participate in the MCCQSS.
2008 Nurturing Home Initiative - Mississippi State University (MSU) Extension
Services-

Partners for Quality Child Care, MSU Early Childhood Institute (ECI)

OCY Director’s Credentialing Program/Mississippi Forum on Children

and Families -

MSU Extension Services

WIN Job Center/OCY Collaboration

Child Care Development Associate Credential OCY/University of

Southern Mississippi (USM)

Partners for Quality Child Care, MSU Early Childhood Institute (ECI) -
Provides quality technical assistance and assessments for caregivers in

72
licensed child care settings throughout the state and identifies the high
level of quality child care through the use of nationally recognized
environmental rating scales. The Infant/Toddler Environmental Rating
Scales (ITERS) and the Early Childhood Environmental Rating Scales
(ECERS) are used to assess the development and enhancement of
licensed facilities. During SFY 2008, 730 licensed centers were served.

OCY Director’s Credentialing Program/Mississippi Forum on Children

and Families -
Provides child care center directors and staff 120 hours of module
training. The training is designed to evaluate the knowledge and skills of
child care professionals for successful completion of the Child Care
Management Best Practices, and further supports quality throughout
Mississippi’s child care system with professional development that offers
quality age-appropriate developmental activities in child care settings.
This initiative promotes the development of language, literacy, pre-
reading and numeracy skills of children. Since its inception, a total of
2,170 child care professionals have successfully completed the training.

Mississippi Child Care Quality Step System - OCY implemented the

Mississippi Child Care Quality Step System (MCCQSS) as a system to
assess, improve and communicate the level
of quality in licensed early child care and education settings. MCCQSS
has five components: Administrative Policy, Professional Development,
Learning Environments, Parental Involvement and Evaluation. Mississippi
adopted the motto “Step Up to Star Quality.” The proposed goals of the
program are:
■ Prepare all children to be ready for school.
■ Teach children to learn, value and respect authority.
■ Practice self-discipline.
■ Be observant.
■ Practice positive socialization skills.
As licensed child care providers advance in higher levels of quality care,
they receive a higher reimbursement. MCCQSS was launched in the East
Central Planning and Development District (ECPDD) as a pilot project
serving nine counties in SFY 2007. Beginning in SFY 2008, twenty
additional counties served by the Golden Triangle Planning and
Development District (GTPDD),
the North Central Planning and Development District (NCPDD) and the
Northeast Planning and Development District (NEPDD) were eligible to

73
 participate in the MCCQSS. Currently 78 licensed facilities are
participating in the QRS. As of June 30, 2008, one center received a
"Five Star" rating, with others rated a "Three Star" or "Two Star." These
centers are eligible to receive an ongoing quality bonus from 7% - 25%
for each child participating in the QRS.
2009 Nurturing Home Initiative, Mississippi State University (MSU) Extension
Services

Partners for Quality Child Care, MSU Early Childhood Institute (ECI)

OCY Director’s Credentialing Program,

Mississippi Forum on Children and Families

MSU Extension Services

WIN Job Center/OCY Collaboration

Child Care Development Associate Credential OCY/

Mississippi State University (MSU)

Project IMPACT (Improving and Maximizing Professional

Development for Childcare Teachers), Jackson State University
provides statewide training and evaluation activities for childcare
educators/providers to improve the quality of care for children in
licensed and/or unlicensed childcare settings. To date, Project
IMPACT has provided training to 641 childcare educators/providers.

OCY implemented the Mississippi Child Care Quality Step System

(MCCQSS) as a system to assess, improve and communicate the level of
quality in licensed early child care and education settings. MCCQSS has
five components: Administrative Policy, Professional Development,
Learning Environments, Parental Involvement and Evaluation. Mississippi
adopted the motto “Step Up to Star Quality.”
As licensed child care providers advance to higher “Star Step” levels of
quality care, they receive an ongoing Quality Bonus ranging from 7% to
25% if they serve subsidized families participating in the CCDF Childcare
Certificate program. MCCQSS was launched in the East Central Planning
and Development District (ECPDD) as a pilot project serving nine
counties in SFY 2007. Currently 337 licensed facilities are participating in
the Quality Rating System (QRS). As of July 1, 2009 the MCCQSS was

74
 offered statewide.
provides quality technical assistance and assessments for caregivers in
licensed child care settings throughout the state and identifies the high
level of quality child care through the use of nationally recognized
environmental rating scales. The Infant/Toddler Environmental Rating
Scales (ITERS) and the Early Childhood Environmental Rating Scales
(ECERS) are used to assess the development and enhancement of
licensed facilities. During SFY 2009, 804 licensed centers were served.

2010 Nurturing Home Initiative, Mississippi State University (MSU) Extension

Services

Partners for Quality Child Care, MSU Early Childhood Institute (ECI)

OCY Director’s Credentialing Program 2,588 served

MSU Extension Services

WIN Job Center/OCY Collaboration

Child Care Development Associate Credential

OCY/Mississippi State University(MSU)

Project IMPACT

The Quality Rating System (QRS) Enhancement Project provided child

care directors with supplies for the math, science and listening centers.
The centers also received detailed descriptions of how the materials fit
with the Early Childhood Environmental Rating Scale and the MS Early
Learning Guidelines which are components of the QRS.

OCY implemented the Mississippi Child Care Quality Step System

(MCCQSS) as a system to assess, improve and communicate the level of
quality in licensed early child care and education settings. MCCQSS has
five components: Administrative Policy, Professional Development,
Learning Environments, Parental Involvement and Evaluation.

Mississippi adopted the motto “Step Up to Star Quality.” As licensed

child care providers advance to higher “Star Step” levels of quality care,
they receive an ongoing Quality Bonus ranging from 7% to 25% if they
serve subsidized families participating in the CCDF Childcare Certificate

75
 program. MCCQSS was launched in the East Central Planning and
Development District (ECPDD) as a pilot project serving nine counties in
SFY 2007. Currently 426 licensed facilities are participating in the Quality
Rating System (QRS). As of July 1, 2009 the MCCQSS was offered
statewide.

2011 Allies for Quality Care Program – This ECCD funded program serves
eligible, randomly selected child care centers located in Hinds and
Rankin counties. The focus of this effort is to address the programmatic
needs of child care centers through evaluation and intense on-site
technical assistance. The program provides direct assistance to
participating centers in an effort to improve the learning environment in
each classroom through increased ITERS and ECERS scores; improve the
nutritional quality of food provided to children; and develop an
operating budget for the program and identify cost saving
opportunities.

Nurturing Home Initiative, Mississippi State University (MSU) Extension

Services

Partners for Quality Child Care, MSU Early Childhood Institute (ECI)

ECCD Director’s Credentialing Program 3,878 served

MSU Extension Services provides training on the Mississippi Early

Learning Guidelines, three and four-year- old programs. To date, 9,450
child care providers received distance training and 16,394 received face-
to-face training. The Early Learning Guidelines Training is an essential
tool used to prepare Mississippi’s youth for “Ready To Learn.”

WIN Job Center/ECCD Collaboration

Child Care Development Associate Credential ECCD/Mississippi State

University (MSU)

Project IMPACT

The Quality Rating System (QRS) Enhancement Project

ECCD implemented the Mississippi Child Care Quality Step System

(MCCQSS) as a system to assess, improve and communicate the level of
quality in licensed early child care and education settings. Components

76
 of MCCQSS include: Administrative Policy, Professional Development,
Learning Environments, Parental Involvement and Evaluation. Currently
497 licensed facilities statewide are participating in the Quality Rating
System (QRS).
2012 Allies for Quality Care Program

Nurturing Home Initiative, Mississippi State University (MSU) Extension

Services

Partners for Quality Child Care, MSU Early Childhood Institute (ECI)

ECCD Director’s Credentialing Program, MSU Extension Services 3,958

served

Mississippi Early Learning Guidelines Training, MSU Extension Services

Child Care Development Associate Credential ECCD/MSU Extension

Services

WIN Job Center/ECCD Collaboration

ECCD implemented the Mississippi Child Care Quality Star System

(MCCQSS) to assess, improve and communicate the level of quality in
licensed early child care and education settings. Components of
MCCQSS include: Administrative Policy, Professional Development,
Learning Environments, Parental Involvement and Evaluation. Currently
536 licensed facilities statewide are participating in the Quality Rating
System (QRS).

2013 Allies for Quality Care Program

Nurturing Home Initiative, Mississippi State University Extension

Services

Partners for Quality Child Care, MSU Early Childhood Institute

provides quality technical assistance and assessments to caregivers in
licensed child care settings throughout the state and identifies high
levels of quality child care through the use of nationally recognized
environmental rating scales. The ITERS and ECERS are used to assess the
development and enhancement of licensed facilities. During SFY 2013,
110 licensed centers were served with technical assistance.

77
 ***DECCD Director’s Credentialing Program, MSU Extension Service
provides child care center directors and staff 120 hours of module
training. The program evaluates the knowledge and skills of child care
staff for successful completion of the Child Care Management Best
Practices. The training also supports quality throughout Mississippi’s
child care system with professional development that offers quality age-
appropriate developmental activities in child care settings. The initiative
promotes children's

development of language, literacy, pre-reading and numeracy skills.

Since 2010, 116 child care professionals have successfully completed
the training; 51 have completed the Mississippi Directors Credential
Renewal; and 59 are enrolled or have completed the National Directors
Credential.

Child Care Development Associate Credential, DECCD/ MSU Extension

Service

WIN Job Center/DECCD Collaboration

DECCD implemented the Mississippi Child Care Quality Star System to

assess, improve and communicate levels of quality in licensed early child
care and education settings. Components of MCCQSS include:
Administrative Policy, Professional Development, Learning
Environments, Parental Involvement and Evaluation. Currently 522
licensed facilities statewide are participating in the Quality Rating
System. Of the 415 facilities evaluated:
H Five Star Rating: 9 facilities
H Four Star Rating: 18 facilities
H Three Star Rating: 35 facilities
H Two Star Rating: 81 facilities
H One Star Rating: 272 facilities
2014 Allies for Quality Care Program

Nurturing Home Initiative, Mississippi State University Extension Services

Partners for Quality Child Care, MSU Early Childhood Institute

DECCD Director’s Credentialing Program, MSU Extension Service

Child Care Development Associate Credential, DECCD/ MSU Extension

78
 Service

WIN Job Center/DECCD Collaboration

DECCD implemented the Mississippi Child Care Quality Star System to

assess, improve and communicate levels of quality in licensed early child
care and education settings. Components of MCCQSS include:
Administrative Policy, Professional Development, Learning
Environments, Parental Involvement and Evaluation. As of the end of
June 2014, 524 licensed facilities statewide are participating in the
Quality Rating System. Of the 398 facilities evaluated:
Five Star Rating: 11 facilities
Four Star Rating: 19 facilities
Three Star Rating: 36 facilities
Two Star Rating: 86 facilities
One Star Rating: 246 facilities
2015 In July 2014, DECCD aligned its quality improvement initiative programs
into a single network of services known as the Early Years Network. This
network includes all services previously offered by individual programs
such as Allies for Quality Care, Nurturing Homes, Partners for Quality
Care, Project PREPARE, professional credentialing programs, etc.
The Early Years Network provides services to early childhood care
professionals and families at no cost in the following 11 areas: Allies for
Quality Care Pilot, professional development, nutrition and physical
health, special needs and mental health, training and technical
assistance, business advising, community engagement, parent
education, child assessment, child care resource and referral sites, and
child care quality rating and improvement systems.
With the launch of the EYN, access to these services was streamlined by
giving parents and providers a single number/website/email address to
use to access a coordinated system of services. During SFY 2015, the
EYN provided services in all 82 counties to 34,884 early childhood care
professionals and 2,814 parents.

WIN Job Center/DECCD Collaboration

**Consolidation of quality initiatives in Establishment of Early Years

Network
he Mississippi Quality Stars program is Mississippi’s quality rating and
improvement system housed under the EYN. This program is designed

79
 to assess, improve, and communicate levels of quality in licensed early
child care and education settings. Components of MS Quality Stars
include: Administrative Policy, Professional Development, Learning
Environments, Parental Involvement and Evaluation. As of the end of
June 2015, 577 licensed facilities statewide are participating in the
quality rating system. Of the 396 facilities evaluated:
• Five Star Rating: 12 facilities
• Four Star Rating: 25 facilities
• Three Star Rating: 46 facilities
• Two Star Rating: 81 facilities
• One Star Rating: 232 facilities
2016 Early Years Network

WIN Job Center/DECCD Collaboration

The Mississippi Quality Stars program is Mississippi’s quality rating and

improvement system housed under the EYN. This program is designed
to assess, improve, and communicate levels of quality in licensed early
child care and education settings. Components of MS Quality Stars
include: Administrative Policy, Professional Development, Learning
Environments, Parental Involvement and Evaluation. As of the end of
June 2016, 537 licensed facilities statewide are participating in the
quality rating system. Of the 418 facilities evaluated:
•Five Star Rating: 7 facilities •Four Star Rating: 25 facilities •
Three Star Rating: 53 facilities
•Two Star Rating: 101 facilities
•One Star Rating: 232 facilities

** •As part of our dedication to continuous quality improvement, DECCD

convened a group of stakeholders from around the state to produce
recommendations for the improvement and revision of the Quality Stars
Program. This work is on-going into the next Fiscal Year.
2017 Early Childhood Academies

Healthy Families Mississippi

80
1
2
3

Endnotes
i
Resources of information regarding policies, programs and data used throughout this report can be found in Mississippi Department
of Human Services Annual Reports, http://www.mdhs.ms.gov/annual-reports/ and at the Mississippi Department of Archives and
History, http://www.mdah.ms.gov/arrec/digital_archives/governmentrecords/mdhs-ar. Accessed September 2018.
ii
2005 American Community Survey and 2016 American Community Survey 1-year estimate, Table B17010 for the state of
Mississippi. Data is specific to female householders with no husband present with related children below 18 years of age.
iii
This data has been cited and captured in documents put out by MLICCI for a number of years based on the National Center for
Children in Poverty’s customized estimates of American Community Survey data looking at young low-income children with a working
parent. MLICCI has used this data as an approximation for the number of potentially eligible children.
iv
MLICCI has long compared the number of young children receiving CCDF assistance with the number who may be income eligible
as an approximate estimate of the gap between those served and those who may be eligible.
v
This is based on federal CCDF data for Mississippi, available here: https://www.acf.hhs.gov/occ/resource/ccdf-statistics.
vi
Karen E. Lynch, “Trends in Child Care Spending from the CCDF and TANF,” Congressional Research Service,
https://fas.org/sgp/crs/misc/R44528.pdf.
vii
MLICCI uses NCCP’s most recent data showing the number of young low-income children with a working parent as an
approximation of CCDF eligibility status. NCCP’s data can be accessed through their Demographic Data Generator tool, at
www.nccp.org/tools/demographics using the 2016 American Community Survey. The data for HS/EHS
participation was taken from, https://www.nhsa.org/facts and https://www.nhsa.org/files/resources/2017-fact-
sheet_mississippi.pdf. Data on state public Pre-K participation is found here, https://newreports.mdek12.org. CCDF participation data
can be found in Table 9 here, https://www.acf.hhs.gov/occ/resource/ccdf-statistics.
viii
See Table 11, https://www.acf.hhs.gov/occ/resource/ccdf-statistics.
ix
See, http://www.mschildcare.org/wp-content/uploads/2017/06/child-care-and-work-training-FINAL.pdf.
x
Ibid.
xi
National Women’s Law Center, https://nwlc-ciw49tixgw5lbab.stackpathdns.com/wp-content/uploads/2018/01/MS-Is-Shortchanging-
Women-Fact-Sheet.pdf.
xii
Mississippi Department of Human Services, Section 3, pgs. 4-5, http://www.mdhs.ms.gov/wp-content/uploads/2018/08/CCDF-Plan-
for-MS-FINAL-DRAFT.pdf.
xiii
All state reported CCDF data is obtained from MDHS Annual reports, see End Note 1. All CCDF federal data used in the report is
obtained here: Programmatic statistics, https://www.acf.hhs.gov/occ/resource/ccdf-statistics; Funding statistics,
https://www.acf.hhs.gov/occ/resource/ccdf-funding-allocations; Expenditure statistics, https://www.acf.hhs.gov/occ/resource/ccdf-
expenditure-data-all-years.
xiv
Data as reported in 2012 and 2013 MDHS Annual Reports.
xv
See, http://www.mschildcare.org/wp-content/uploads/2017/11/2017-Town-Hall-Child-Care-Summary_C.pdf.
xvi th
Anna Wolfe and Sarah Fowler, “Human Services Leaves $13 million in Child Care Funds on the Table,” Clarion Ledger (January 29 ,
2018), https://www.clarionledger.com/story/news/local/2018/01/29/human-services-leaves-13-m-child-care-funds-
table/1065001001/.
xvii
MLICCI conducted parent and provider focus groups and surveys in 2005, 2007 and 2010. Data is on file with the author and
available upon request.
xviii
Data used in this section can be accessed here, https://www.acf.hhs.gov/occ/resource/ccdf-statistics.
xix
Ibid.
xx
Ibid.
xxi
Karen E. Lynch, “Trends in Child Care Spending from the CCDF and TANF,” Congressional Research Service,
https://fas.org/sgp/crs/misc/R44528.pdf.
xxii
MLICCI analysis of CCDF Funding statistics, https://www.acf.hhs.gov/occ/resource/ccdf-funding-allocations and Expenditure
statistics, https://www.acf.hhs.gov/occ/resource/ccdf-expenditure-data-all-years.
Work Street Work City, T: Work Phone, M: Mobile Phone;
81
Work State Work ZIP F: Work Fax Phone, Work Email, Work URL
xxiii
See, Mississippi Department of Human Services 2003 and 2004 Annual Report.
xxiv
Health and Human Services, Association for Children and Families,
https://www.acf.hhs.gov/sites/default/files/occ/rg_ccdf_fundamentals.pdf.
xxv
MLICCI analysis of Funding statistics, https://www.acf.hhs.gov/occ/resource/ccdf-funding-allocations and Expenditure statistics,
https://www.acf.hhs.gov/occ/resource/ccdf-expenditure-data-all-years. MLICCI greatly appreciates the Center for Law and Social Policy
(CLASP) for providing “all appropriation year” expenditures for FFYs 2000-2002 and for their guidance in analyzing CCDF expenditure
data.
xxvi
See MDHS 2002-2003 annual reports.
xxvii
TANF expenditure data is available here, https://www.acf.hhs.gov/ofa/programs/tanf/data-reports. The amount that MS regularly
reports as TANF direct child care spending in its state TANF MOE expenditures is $1,715,430 and this amount is also counted as its
CCDF MOE.
xxviii
Mississippi Office of the State Auditor, “A Review of the Child Care and Development Fund (CCDF) Program in Mississippi,” (March
27, 2007). The amount of TANF MOE the state counts as CCDF MOE will be captured in total CCDF expenditures, thus it is deducted
from TANF direct child care spending when calculating the state’s total child care spending so as to avoid double counting the amount.
xxix
Karen E. Lynch, “Trends in Child Care Spending from the CCDF and TANF,” Congressional Research Service,
https://fas.org/sgp/crs/misc/R44528.pdf.
xxx
The chart reflects spending from all appropriation years for a total annual estimate and does not reflect only
current fiscal year funds spent on only current fiscal year quality activities.
xxxi
Elizabeth Palley and Corey S. Shdaimah, In Our Hands: The Struggle for U.S. Child Care Policy, (NYU Press, 2014), pgs. 51-64.
xxxii
W. Martin Wiseman, C. Denise Keller, Joe Adams and Keith A. Smith, “Mississippi Child Care Development Fund: Program
Implementation, Evaluation and Impact Analysis,” The John C. Stennis Institute of Government, Mississippi State University, (January
7, 2005).
xxxiii
See, http://billstatus.ls.state.ms.us/documents/2005/pdf/HB/0800-0899/HB0813IN.pdf.
xxxiv
See, http://billstatus.ls.state.ms.us/documents/2005/pdf/HB/0800-0899/HB0813SG.pdf.
xxxv
Mississippi Office of the State Auditor, “A Review of the Child Care and Development Fund (CCDF) Program in Mississippi,” (March
27, 2007), pg. i. http://www.osa.ms.gov/documents/performance/ccdf-final.pdf.
xxxvi
Ibid.
xxxvii
Ibid, ii.
xxxviii
A copy of MLICCI’s 2007 survey analysis is on file with the author and available upon request.
xxxix
A copy of MLICCI’s 2010 survey analysis is on file with the author and available upon request.
xl
A copy of this report is on file with the author and available upon request.
xli
Ibid.
xlii
W. Martin Wiseman, “The State of Mississippi’s Use of Biometric Finger Imaging to Administer Child Care Development Funds: An
Overview for Decision Makers,” The John C. Stennis Institute of Government, Mississippi State University. A copy is on file with the
author and available upon request.
xliii
Ibid.
xliv
Ibid.
xlv
See, https://www.clarionledger.com/story/news/2016/03/31/finger-scanning-contract-limbo/82463104/.
xlvi
Mississippi Low Income Child Care Initiative, “2017 Child Care Policy Town Hall Series Summary” (Fall, 2017),
http://www.mschildcare.org/wp-content/uploads/2017/11/2017-Town-Hall-Child-Care-Summary_C.pdf.
xlvii
Data and information was obtained via Public Records Act request and is on file with the author and available upon request.
xlviii
Ibid.
xlix
See pg. 8, https://secac.ms.gov/wp-content/uploads/2017/08/CCPP-Vol1-Issue2-08-04-17.pdf.
l
See, https://www.acf.hhs.gov/sites/default/files/occ/mississippi_stplan_pdf_2016.pdf.
li
See, http://www.mschildcare.org/wp-content/uploads/2017/11/2017-Town-Hall-Child-Care-Summary_C.pdf
lii
A copy of this report is available with the author and at www.mschildcare.org.
liii
MLICCI analysis of programmatic statistics found here, https://www.acf.hhs.gov/occ/resource/ccdf-statistics.
liv
See, http://www.mdhs.ms.gov/wp-content/uploads/2018/08/Copay-Table-Update-1.pdf.

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lv
See 2011 rates pg. 46, http://sos.ms.gov/ACProposed/00019114b.pdf; See 2014-2015 rates pgs. 50-52,
http://www.sos.ms.gov/ACProposed/00020002b.pdf; See 2018 rates for Standard centers, https://secac.ms.gov/wp-
content/uploads/2018/05/Summary-Table-of-Rate-Changes.pdf.
lvi
See, https://www.acf.hhs.gov/sites/default/files/occ/mississippi_stplan_pdf_2016.pdf.
lvii
All information related to CCDF priority populations can be found in MDHS annual reports and in the Child Care Payment Program
Policy Manual, and in Appendix 1.
lviii
Programmatic statistics, https://www.acf.hhs.gov/occ/resource/ccdf-statistics
lix
See, http://billstatus.ls.state.ms.us/documents/2006/pdf/ham/Amendment_Report_for_SB2602.pdf.
lx
See, http://www.mschildcare.org/wp-content/uploads/2017/01/Step-Up-Final-Report.pdf.
lxi
See, http://www.mschildcare.org/wp-content/uploads/2017/03/provider-input-on-CCDF.pdf.
lxii
See, http://www.mschildcare.org/wp-content/uploads/2017/03/civil-rights-testimony-1.pdf.
lxiii
Information is available in MDHS annual reports.
lxiv
See, https://secac.ms.gov/wp-content/uploads/2016/12/EarlyChildCareSystemDescription-Formatted-12-06-16_2.pdf.
lxv
See, http://www.mdhs.ms.gov/wp-content/uploads/2018/08/CCDF-Plan-for-MS-FINAL-DRAFT.pdf.
lxvi
See, https://secac.ms.gov/wp-content/uploads/2018/05/Summary-Table-of-Rate-Changes.pdf.
lxvii
See Table 11, https://www.acf.hhs.gov/occ/resource/ccdf-statistics.
lxviii
See, https://www.clasp.org/sites/default/files/public/resources-and-publications/publication-1/Disparate-Access.pdf.
lxix
See, https://www.nbcdi.org/sites/default/files/resource-
files/NBCDI_CLASP%20Policy%20Brief%20CCDBG%20and%20Racial%20Equity.pdf.
lxx
See, https://www.urban.org/sites/default/files/publication/31461/411611-Designing-Subsidy-Systems-to-Meet-the-Needs-of-
Families.PDF.

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 THE MISSISSIPPI LOW-INCOME CHILD CARE INITIATIVE

Mississippi Low-Income Child Care Initiative improves the child care assistance
program serving low-income working parents and strengthens the financial viability
of the child care centers that serve them, so that no mother has to choose between
the job she needs and the child she loves.

Since 1998, MLICCI has been a champion for affordable care for Mississippi’s low-
income working parents.

Child care is expensive - sometimes costing as much or more than college tuition.
Mississippi’s Child Care Payment Program helps low-income working parents afford
the child care they need. These programs have been proven to increase
employment, reduce poverty, reduce absenteeism and turnover for employers,
contribute more tax revenue into the general fund, and support school readiness in
children.

Despite the benefits of early childhood education, the Mississippi Child Care
Payment Program only serves a fraction of eligible children. MLICCI tenaciously works
to change that.

Because of MLICCI’s deep relationships with low-income single mothers and

providers, we know that systematic racism and sexism impact the state’s current child
care assistance climate. Single mothers face an inequitable workforce. Providers
struggle to finance services in a punitive policy climate with inadequate revenue.
Because of these realities and their intersectionality, in 2015 we launched a campaign
to advocate women’s economic security. Our movement building is bolstered by our
growing gender analysis capacity, as well as our state and national policy partners.

MLICCI | www.MSCHILDCARE.org | @MLICCL1 | P: 228.669.4826 | OCTOBER 2018

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