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Comments on Proposed Child Care and Development Block Grant Regulations: 78 Fed. Reg. 29442

August 7, 2013

 

Docket # ACF-2013-0001
Submitted August 5, 2013


Introduction
   
The Empire Justice Center is a not for profit law firm that provides training, litigation support and policy analysis to legal aid and legal services offices across New York State.  In addition, we assist hundreds of community groups that serve low income clients, and also represent low income clients in individual matters as well as class action litigation. We have offices in Rochester, Albany, White Plains and Central Islip.
 
Our work focuses on a wide range of civil issues facing low income New Yorkers. In the public benefits area a large part of our work is devoted to subsidized child care. We have written many reports on the state of child care in New York State, the most recent of which, Mending the Patchwork, outlines the broad county by county variations in the administration of child care across the state.  In addition, in conjunction with the National Center for Law and Economic Justice, we obtained class relief in a case called Torres v. Blass (USDC EDNY 12-cv-3603(JS)(WDW)), resulting in clear and comprehensive notices for recipients of child care subsidies when social services districts lower eligibility levels. In Williams v. Carrion, we represent a statewide class of low income working parents in New York who pay more than 10% of their income as a parent copayment, challenging New York’s inequitable parent share regulation as a violation of state law and equal protection.

The Child Care Council of Suffolk and the Child Care Council of Nassau are not for profit agencies on Long Island that work with parents, providers and businesses so that every child can be in a quality child care program.  They provide child care counseling and referrals to families, professional development and technical assistance to active and potential providers, and services to employers interested in the child care needs of employee’s families. The Councils also serve as an informational resource and public voice for child care issues facing Long Island’s diverse communities.

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