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Empire Justice Center Comments on the Early Childhood Advisory Committee’s Strategic Report and Plan

May 25, 2010


Thank you for the opportunity to comment on the ECAC strategic report and plan for conducting activities.  Promoting strong and healthy families by building a comprehensive early childhood system is a strong and vital investment in the future of New York State’s children.  The objectives cited by ECAC for which federal funds are requested, however, do not go far enough.  Entirely missing from the ECAC report is a plan to address the inequities that currently exist in our county administered child care subsidy system.  Until these inequities are addressed, the ECAC’s commendable goal of optimizing services to under-served families will never truly be achieved.

Despite the fact that the child care subsidy system is a federally funded program with nearly $1 billion in federal funds spent annually in New York State, the system has different eligibility rules, established county by county, which result in similarly situated families being treated very differently, just because of where they live. The disparities and inequities among counties in the implementation of child care subsidy administration are best illustrated by the significant county by county differences in child care copayments. There are no uniform state standards based on ability to pay. Counties are permitted to pick a copayment multiplier of between 10% and 35%, which is applied against the family’s income over the poverty level.  Counties are provided with no criteria for picking this multiplier.
For example, a family of three with an annual income at 200% of the poverty level ($36,620) that lives in Oswego County pays 10% of their income over the poverty level for a child care subsidy, which means they pay $1,831/year or $35/week, amounting to 5% of their gross income.  In contrast, a family living in Orange County, must pay 35% of their income over the poverty level for a child care subsidy, which is $6,408/year, or $123/week and constitutes 17.5% of the household’s gross income.   To give a more broad overview, in six counties, parents pay 10% of their income over the poverty level; in one county, parents pay 15%; in one county, parents pay 17.5%; in thirteen counties, parents pay 20%; in sixteen counties, parents pay 25%; in two counties, parents pay 30%; and in eighteen counties, parents pay 35% of their income over poverty as their child care copayment.   For a one page analysis of these differences, click here.  These differences in copayments are imposed on parents on an arbitrary basis that is in no way correlated to a family’s actual ability to pay. 
The Empire Justice Center has examined various factors such as per capita income, consumer price levels, and the cost, availability and accessibility of child care among the various counties, and none of these factors correlate to the differing amounts that parents pay.  This analysis is in a report entitled Mending the Patchwork, which explores the county-by-county inequities in child care subsidy administration in New York State. Click here to read the full report.   The report examines other county by county variations in eligibility rules as well, such as whether low income parents who are looking for work are eligible for child care, whether the county counts the income of 18-21 year olds when determining the parent’s eligibility for child care for a younger sibling, or whether parents who need child care to attend post-secondary education are eligible for a subsidy. These arbitrary variations compromise notions of equal access to quality child care, which should be the bedrock of New York’s child care subsidy system.
The goals of the ECAC – the alignment and extension of existing programs, the identification of families in need of additional support, and the improvement of accountability and program quality, ring hollow if no effort is made to solve the problems of equal access created by our standardless system.  This opportunity for funding should be used to do the hard work necessary to create a system that provides equitable access to child care programs and services.  Please amend your application so that you can use these funds to mend the patchwork. 

For a copy of the Early Childhood Advisory Committee’s Strategic Report, click here.

For more information, please contact:

Susan C. Antos

Empire Justice Center
119 Washington Avenue
Albany, NY  12210 

(518) 462-6831
(518) 935-2852