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April 20, 2020

 

Please see below the letter that was sent by OACCP to the Ohio Department of Jobs and Family Services regarding our recommendations for the re-opening of child care centers in the State of Ohio. Although we do not yet know when centers will be permitted to open, we have offered solid suggestions to the state on how to re-open centers in the best way possible.

 

At OACCP, we will continue to support our members through this crisis by offering guidance that will help you as a business owner. Please take a few moments to thoroughly review our suggestions as they will help you in your planning as well. More information will be coming out to members over the next few weeks as we all start planning to re-open.

 

This letter was sent from OACCP to ODJFS on April 17, 2020:

Recommendations for the Transition Phase

There Is No Economic Recovery Without Child Care

 

Ohio, like the rest of the Country and the World, has been engulfed in the severe impact of COVID-19. Ohio has been a leader during the mitigation phase of this pandemic. It is now time for Ohio to lead in the Economic Recovery of our nation.

 

Some child care programs will not survive this crisis. The decisions our leaders make, the actions they take and the words they say will matter and effect the cost, duration and recovery speed of child care programs and ultimately the success or failure of Ohio’s economic return.

 

OACCP recognizes that during the transition phase we will not be able to return to business as usual. We understand that there will need to be a period of time where we transition from the severe needs of the pandemic response back to a new normal of doing business. In this phase careful planning for people (staff, children, parents & community), supply chains (purchasing power, service provider availability, and supply availability), facilities (cleaning, disinfecting, deferred maintenance, changes in set-up to accommodate new requirements), and financial implications (new revenue forecasts & budget gaps) will need to be implemented. The State has an important role to play in the recovery of the child care industry as it implements new strategies in Its policy/regulations, financial support structures, quality support structures, workforce development, communications and ensuring the availability of essential resources.

 

In doing our part to reopen the economy, please see the recommendations below on how we believe we can reassure our staff and customers that we are doing everything possible to provide the highest quality the safety in this incredibly unideal time.

 

Regulations

We believe direct guidance from ODJFS on these above elements are necessary for providers, staff and families to feel safe retuning to group child care settings. We respectfully request that ODJFS consider the following:

 

1. ODJFS adoption of temporary child care rules set to expire on a given date and to return to pre-COVID19 regulations. These rules should include a small subset of current regulations and also include guidance on:

• Essential Center Supplies:

o Thermometers requirements/instructions for use

o Alcohol Wipes or rubbing Alcohol/hydrogen peroxide and cotton balls o Hand Soap

o Disinfectant/Bleach

o Gloves medical vs. non medical grade o Aprons, smocks, lab coats, button down shirts o Masks

o Eye Protection

• Reducing the Spread of Illness – policies regarding attendance, social distancing, building visitors, etc.

• COVID-19 FAQ’s

• Temporary meal modifications/considerations

• Changes to child arrival and health checks

• Conducting temperature checks

• PPE expectations for child care

• Wearing masks - staff/children considerations • Cleaning, Sanitization and Disinfecting expectations

• Response requirements for:

o A teacher/staff test positive

o A teacher/staff has been tested and is waiting a result o Not enough staff

o Temporary closure procedures o Mandatory isolation of staff/child/ parent o Voluntary isolation staff/child/parent o Symptoms in a household of staff or child o School closure due to COVID19

• Changes to hygiene practices such as:

o Handwashing guidance and activities

o Toothbrushing o Diaper changing & toileting

• Sleeping/Nap time considerations

• Playground considerations

• Field Trip considerations

• Ratio and group sizes should be maximized to the extent it is healthy to do so. Any temporary changes to ratio and group size should have an expiration date or threshold. Unlike younger children, School age children have a better ability to social distance themselves within a space.

 

OACCP and its members have developed guidance documents on each of these areas that could be used as a basis for setting up these temporary regulations.

 

2. The subset of current regulations utilized during this transition should be minimal in nature and gradually step programs back into full compliance of standard pre pandemic regulations. Immediate return to 759 regulations to implement and monitor by over 7000 providers will be overwhelming for both providers and ODJFS licensing staff. Many of these regulations can be safely layered over time to balance the need of a foundation of safety and the ability to regain footing.

 

OACCP has identified rules that could be layered for temporary limitation and gradual reintroduction that it can provide upon request.

 

 

Financial

The Labor Department statistics of small business informs us that as many as 50% of small businesses will not reopen after a crisis, and another 25% will close within 2 years of a crisis. The National Association of Education of Young Children (NAEYC) conducted a recent survey of providers that expressed a similar expectation with 30% of providers nationally stating that they could not survive a closure of more than 2 weeks and another 16% stating that they could not survive a closure of more than a month. We feel a little more optimistic outcome with the supports that Ohio has instituted with the continuation of PFCC funding for the duration of the Governor’s required closure and the support of Federal PPP and EIDL loans. However, the access and impact of those loans for child care providers has yet to be seen.

 

Child care is a critical foundation to the economic success of our state. There is no economic recovery without child care. Child care programs will undoubtably close due to the effects of this pandemic and its associated economic devastation. However, the policy decisions that our state leadership makes will greatly impact which programs and how many permanently close. These short-term decisions will also have long lasting effects that will define the future of the child care industry for the next 10-20 years. We respectfully ask that the following be considered:

 

1. Quality must still be prioritized during this challenging time while balancing the need for supporting the quantity of child care that will be needed to support low-income families.

2. Even small changes to ratio and group size have a significant impact on a programs economic stability. Payment for publicly funded child care must cover the cost of any changes in ratio either through a temporary change to the reimbursement rate or a grant/stipend. The State also must recognize that changes to ratio and group size will also have an impact on the affordability of child care for private paying citizens in addition to the state supported child care program.

3. In this time of incredible uncertainty, businesses will need some foundation of reliability in payment in order to entice them back into the market. If revenues do not cover the variable cost of providing services, businesses are in a financial catch 22 of losing less money by not operating. In order to ensure access and sustainability of the child care market publicly funded and privately paid child care providers the State should institute restart grants and/or a gradual reduction of the closure payments for PFCC providers for a minimum of 6+ months after the closure requirement is lifted.

4. It is time to rethink how traditional reimbursement payments are administered in Ohio. Now is the time to encourage families and providers to keep sick children out of child care programs. However, providers will still require a consistent reliable payment in order to confidently operate. As has been done for the temporary pandemic programs, ODJFS should continue paying providers by enrollment vs.

attendance.

5. The timing and ability of programs to reopen will vary depending on individual program needs and access to staff, resources and funding. The continuation of Pandemic Days will be necessary in order to meet the flexibility required for programs to open at a time once they have been able to obtain needed supplies to open safely.

 

Step Up to Quality (SUTQ)

We know the brain science, we have the research, we’ve create the framework and we have the state data that proves the theory that quality matters for young children. Ohio and its early childhood providers have invested hundreds of millions into the quality infrastructure of our early childhood system. While we recognize the challenges that our State will have with budget pressures, now is the time to lean in to this investment, not lean away from it. We understand that priorities and funding may need to be adjusted in the short-term, but we also know that for the long-term health of our youngest learners we cannot destroy the quality foundation in which we provide. Respectfully we recommend the following:

 

1. SUTQ programs should be prioritized in the consideration of financial and infrastructure support for providers as we reestablish the market

2. As with licensing regulations, a temporary subset of SUTQ expectations should be implemented with the expectation of returning to the full SUTQ guidelines somewhere in the future once the market has re-stabilized. SUTQ domains should be reevaluated for short-term and long-term focus priorities and adjusted accordingly.

 

OACCP has identified potential ways of supporting SUTQ continuation while focusing short term SUTQ expectation on only those that are essential to the current marketplace.

 

Supply Chain

Essential operational materials must be available in the traditional or an alternative supply chain in order for programs to open safely. Support from the State in resourcing items such as Infrared thermometers, masks, gloves, protective eye covering, smocks/lab coats and hand sanitizer will be critical.

 

1. CARES Act funds should be considered to source and bulk purchase newly needed in-demand items. These items could be distributed through the CCRR system.

2. Programs such as the Child and Adult Care Food Program should be investigated to evaluate opportunities to offset additional costs such as sanitizing wipes, hand sanitizer and additional cleaning supplies in order to maintain a healthy environment.

 

Workforce Development & Supports

The early childhood workforce is the engine of the child care industry. These industry employees are historically underpaid mission driven individuals. While they deal with everyday germs that come with working with young children, they are not accustomed to putting their life or the life of a loved one on the line in order to do their job. We must find ways to support these critical employees with wages, benefits and wrap around services in order to have these critically important individuals do their jobs. There is much concern about if we will be able to recall the lion share workers that have been laid off in our industry due to the financial incentive of the federal unemployment compensation or personal health concerns. We respectfully ask:

 

1. When a vaccine or antibody testing developed, prioritize child care providers and offer free vaccine/testing for all child care staff members

2. Maintain the pandemic guideline allowing new hires to be considered in ratio but not alone with children prior to receiving the JFS 01176 form.

3. Allow for flexibility in opportunities for meeting and extending required training hours.

4. Support their personal needs by making it possible for their employers to extend paid time off, sick time, and/or substitute pay through policies such as payment by enrollment and appropriate reimbursement which covers the cost of care.

5. Provide Mental Health services for these front line workers who will need support for their own mental health and training on trauma informed care to support the mental health of the children in their care.

6. Consider tax incentives for early childhood workers to help offset the low industry wages and encourage individuals to come back to working in the early childhood field.

Monitoring Systems and Communications

Crisis management calls for over communication of clear and consistent messaging. It will be challenging to entice workers and customers back to group child care after necessary, but repeated messaging in the initial days of COVID-19 that it was not a safe environment. To this end, we respectfully ask for consideration of:

 

1. A continued heightened alert of COVID-19 which will be necessary for some time. A process of monitoring incidence and infection specifically within the child care environment will help inform necessary changes to program practice.

2. Creation of a dynamic tracking system of child care programs closures and those that have slots available will be necessary as supply and demand changes will be variable and dynamic for some time.

The CCRR system and child care eligibility and payment systems must have the ability to adapt to the changing needs in a community that will likely take some time to stabilize.

3. It is important that center based child care is not defined by this crisis for years to come. Broad stroke thoughtful messaging regarding the importance of high quality childcare meeting the safety and educational needs of children will be necessary from the Governor and his administration in order for families and staff to feel safe returning to these environments. Marshalling advocacy partners to help share these high level consistent messages will further support program recovery.

4. Communication to stakeholders must be consistent and repetitive to families and providers from ODJFS & the CDJFS’s as the market is rebooted.

5. Make every effort to support the mental health needs of children, families and providers must be made to ensure a successful transition of students and staff back to the child care setting.

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