On behalf of the more than 5,000 NC licensed child care/early education providers, the NCLCCA respectfully requests the following changes to the Build Back Better Act:
| Universal Preschool Program|
Commit to a “Mixed-Delivery” model that fully utilizes current licensed private provider infrastructure (child care centers, family child care homes and faith-based programs) before building new infrastructure. The current bill requires full utilization of Head Start slots before building new infrastructure but fails to include a comparable requirement for utilization of existing community-based private provider slots.
Align program requirements and standards across all provider types, including Local Education Agencies. The bill continues to impose different standards on licensing for Local Education Agencies (LEAs) versus all other provider types.
Birth through Five Program
Fix “cost estimation model” to ensure reimbursements align with true costs of care, including variations in fixed costs and annual rate increases. The current bill misses several items that could result in an incomplete cost-of-care model on the state level. The cost estimation model should include variations in fixed costs, such as average rent/mortgage payments, hours worked by staff, and hours of operation, as well as annual cost-of-living increases for reimbursement rates, especially since there is a requirement in the bill for annual COLA increases for employee wages.
Ensure that states actually reimburse providers at rates that cover the full cost of care based on the cost estimation model. Payment rates and practices are not clearly specified in the bill, particularly with regard to whether providers are required to be paid at a rate that reimburses them for the full cost of care provided. If/when providers are under-reimbursed, they will be disincentivized or unable to participate in the program.
Increase funding for Local Grants. In states that do not “opt in” to the new federal child care/early education programs, the full amount of funding designated for North Carolina should be used for Grants to Localities to ensure funding is robust enough for the programs to work for providers and families in these communities.
Put the Child Care and Dependent Care Tax Credit (CDCTC) back in the bill. The expanded CDCTC is needed to make child care more affordable for families – at least for the first year of the new 0-5 program wherein the income eligibility for the program includes far fewer families. (The expanded Child Tax Credit, or CTC, which is still included in the bill is often used by families for other urgent needs, such as food, shelter and health care, and will not necessarily help families afford child care/early education so they can return to work.)