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Advocacy Reports
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November 2016 Quarterly Advocacy Report:

The State underwent a complete rewrite of the ODJFS licensing rules for child care providers. The current licensing rules (totaling 47 rules) will now be replaced with the proposed rules (totaling 25 rules). 
These rules went through clearance twice in 2016
OACCP commented both times and worked directly with ODJFS and CSI
Will be effective in December – however we continue to work with CSI on several concerns.


Training on the New Rules
The training will be a web-based training available on the ODJFS child care website and the slides will be voiced-over to go into details of the changes outlined on the slides. The targeted date of the publication is the week of November 28, 2016.


SUTQ has undergone many changes in procedures this year in addition to formal rule changes.  OACCP worked closely on SUTQ changes such as:
How serious risk non-compliance impacts a rating
Instructional time
2-star transition
Elimination of the SUTQ Guidance Doc & “blue sheet”
Other proposed rules just completed clearance 10/4/16


Last year a new interpretation was made that put the use of the MFSAB in limbo.
OACCP worked with ODJFS to assure the continued use of the MFSAB however, ODJFS agreed to allow ODE to “own” the training of the MFSAB driver
ODE introduced new training requirements earlier this year in which OACCP quickly raised concerns and they were then pulled for review – we are keeping a watchful eye on this one


This year ODH proposed new guidelines to anyone who held a food operators license – which includes most child care centers
In the initial proposed regulations all “food handlers” (which under their definition would be just about any child care center employee) would be required to complete a level 1 certification before handling, prepping or being responsible for holding food temperatures. 
OACCP voiced concerns and has worked with ODH who has now suggested an exemption for child care centers and schools
Still continuing to watch as the rules are not yet finalized
Be aware that new ODH regulations went in to effect this past year that will require a supervisor at each food service operation to hold a level 2 certification.  This will be required as of March of 2017
On November 19, 2014, President Obama signed into law bipartisan legislation that made many important changes to the CCDBG Act. These historic changes to the child care program focused on reforming child care in this country to better support the success of both parents and children.
In September of 2016, OCC published new rules to provide clarity to states on how to implement the law and administer the program in a way that best meets the needs of children, child care providers, and families.


These new CCDBG/CCDF rules fell into the following categories:

1) protect the health and safety of children in child care;

2) help parents make informed consumer choices and access information to support child development;

3) support equal access to stable, high quality child care for low-income children; and

4) enhance the quality of child care and better support the workforce.


We continue to work with ODJFS and the Governor’s office on how these new rules may or may not affect the way we regulate or pay for child care services in Ohio.


*Head Start also updated its HSPS this year. 
*Where possible, the Federal Child Care rules align child care requirements with new Head Start regulations, including certain requirements for background checks and health and safety trainings for staff. 


One new Federal HS & CCDBG/CCDF rule that will significantly impact our state is the new regulations on background checks.
Comprehensive background checks every 5 years for child care staff members (including prospective child care staff members and individuals with unsupervised access to children) of all licensed and CCDF-eligible providers (which includes licensed providers who do not receive CCDF funds)
Similar to how we currently do background checks on administrators, the employee/prospective employees fingerprints must be sent directly to the state for the STATE to complete a comprehensive background check and return the “thumbs up or thumbs down” results to the provider within 45 days. 
These new procedures will go into effect by September 2017.


Under the law, a comprehensive background check has 5 components, including:
a search of the State criminal and sex offender registry in the State where the staff member resides and each State where the staff member has resided for the past 5 years;
a search of the State child abuse and neglect registry in the State where the staff member resides and each State where the staff member has resided for the past 5 years ;
Federal Bureau of Investigation (FBI) fingerprint checkVisit disclaimer page using the Next Generation Identification (which replaced the former Integrated Automated Fingerprint Identification System); and
a search of the National Sex Offender Registry.


The Career Pathways Ladder is currently being reviewed for potential changes
An initial draft was reviewed by OACCP and comments shared with ODE/ODJFS
Stay tuned:  we expect the next version of the CPL draft to be shared with the ECAC in November.


Elimination of Quality Achievement Awards - $12M cut

On July 1, 2016, Quality Achievement Awards were eliminated
After input from advocates, including OACCP  a one year “hold harmless” for three, four, and five-star programs that serve at least one child on ODJFS subsidy was implemented

Planned Elimination of Head Start/PFCC blended funding - $12M cut

In the summer of 2016, the Governor’s office clarified how funding streams could be used together.  That clarification would change how Head Start and ODJFS funding could be used together.
Current practice allowed ODJFS rate to be calculated using the hours the child was in Head Start.  The state changed that practice to disallow Head Start hours from being used to calculate ODJFS payment.
The change resulted in ODJFS payments going from full-time to part-time or hourly.
After much opposition from advocates, the Administration delayed implementation of this change until July 1, 2017.


Consolidation of payment rate categories - $4.1M increase


On July 1, 2016, payment rate categories were consolidated from  six to three.  Categories A, B, and C were joined into category D.  Categories E and F remained the same.
This consolidation provided a slight base rate increase for former categories A, B, and C because category D’s rates were slightly higher than A, B, and C.

Base child care rate changes & Step Up to Quality tiered rate changes - $17.2M increase

On September 4, 2016, Governor’s office announced that $12 million was being put into rates for star-rated programs.  Some of this funding went into base rates, and some went into enhanced SUTQ rates.  Tiered rates were also increased by $5.2M at the time that the elimination of the QAA was implemented.

Implementation of Two-star transition - $1.8 M increase


State-purchased curriculum and assessments - $1M increase


The Administration purchased curriculum and assessments from Creative Curriculum in an effort to help ease costs for providers.  The state also intends on picking up the direct costs of training providers on the curriculum.


The reauthorized CCDBG Act changed the Plan cycle for CCDF from a biennial to a triennial Plan period; thus, the FY 2016-2018 Plan will cover a 3-year period.   The Plan submission deadline was extended from July 1, 2015 to March 1, 2016, with an effective date of June 1, 2016 through September 30, 2018.
OACCP gave verbal and written testimony on Ohio’s State Plan and will continue to work with ODJFS and the Governor’s office the next rewrite
Ohio’s State Plan received conditional approval, specifically calling out concerns to reimbursement rates.  


OACCP is currently working with VFC to develop a workgroup to complete a crosswalk of the new CCDBG/CCDF federal rules, the Ohio State Plan, and in the weeds implementation of state regulations
OACCP members are conducting site visits with legislators to help educate them on our industry issues
OACCP is working with Willa and other Alliance members to develop our next State budget strategy
Alliance/OACCP legislative day is scheduled for March 22, 2017



Advocacy Reports

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Advocacy Reports from Quarterly Meetings
Item Name Posted By Date Posted
2017 Advocacy Day Flier.pdf PDF (273.1 KB) Administration 1/26/2017
District Map Senate.pdf PDF (134.37 KB) Administration 1/26/2017
District Map _ The Ohio House Of Representativ.pdf PDF (260.54 KB) Administration 1/26/2017
Head Start Layering Policy Brief PDF (437.68 KB) Administration 8/5/2016
Legislative Visit Sample Agenda.pdf PDF (214.6 KB) Administration 6/6/2016
2016_Legislative_issues.pdf PDF (193.68 KB) Administration 6/6/2016
OACCP Governors Sign On Letter PDF (270.73 KB)  more ] Administration 4/6/2016
Advocacy Issued to Discuss w/ Legislative Visits PDF (190.21 KB)  more ] Administration 4/6/2016
Advocacy Training Power Point PDF (1.98 MB)  more ] Administration 4/6/2016
Ohio Educational Excellent Proposal PDF (89.46 KB) Administration 2/17/2016
Budget Update 2015 PDF (247.92 KB) Administration 2/17/2016
Clearance 7843 Comments PDF (339.16 KB) Administration 2/17/2016
SUTQ Cost Calculator-Ground Works Study.pdf PDF (411.29 KB) Administration 2/16/2016
SUTQ -Serious Risk Sanctions.pdf PDF (295.38 KB) Administration 2/16/2016
Rules in Clearance -.pdf PDF (187.7 KB) Administration 2/16/2016
FY 2016-17 Gov Budget Proposal.pdf PDF (73.51 KB) Administration 2/16/2016
3-StatePlan2016-2018 Draft (2).pdf PDF (1.07 MB) Administration 2/16/2016
2-PublicHearingNoticeStatePlan2012.pdf PDF (26.03 KB) Administration 2/16/2016
Revision by OACCP FFY 2016-18 State Plan PDF (407.06 KB) Administration 2/16/2016
MBR –Eligibility & Payment Policies.pptx PPTX (74.57 KB) Administration 2/16/2016
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