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Empire Justice Comments on Public Assistance and Child Care Laws

July 18, 2008

 

Public Information Office

New York State Office of Children and Family Services
52 Washington Street
Rensselaer, NY 12144

Dear Sir or Madam:

Thank you for the opportunity to share our thoughts and concerns with you regarding the proposed child care subsidy regulations. These comments are submitted on behalf of the Greater Upstate Law Project and the New York State Child Care Coordinating Council, and have been prepared with the assistance of Amy Schwartz, Esq. a Greater Upstate Law Project attorney who specializes in Domestic Violence issues.

The Greater Upstate Law Project, Inc.

The Greater Upstate Law Project is a support center for legal aid and legal services organizations across New York State. We have offices in Rochester, Albany and White Plains, and provide training, litigation support, and information clearinghouse services to 20 legal aid offices from Long Island to Chautauqua County. In addition, we assist hundreds of community groups that serve low income clients, and we represent low income clients who are referred to us. Finally, we engage in policy analysis and legal research on issues affecting poor New Yorkers.

Our office has been involved the particular concerns of low income parents who use child care, as well as providers of child care, who are also often low income. We frequently provide training on child care issues and have issued a number of reports regarding child care, including Child Care in New York State: A Patchwork of Policies: A County by County Review of Subsidy Administration (November, 2002). We are currently working on a report regarding child care providers and access to health and liability insurance. Additionally, the Greater Upstate Law Project has worked on a number of legislative initiatives that benefit low-income parents and providers.

The New York State Child Care Coordinating Council

The New York State Child Care Coordinating Council is a statewide, non-for-profit membership organization that aims to promote excellence in early care and education. The NYSCCCC does this in partnership with a strong network of community-based organizations that provide Child Care Resource and Referral Services. A primary goal of the New York State Child Care Coordinating Council is to ensure affordable, accessible, quality child care for all children needing care.

We have outlined our areas of support and concern below. For ease of understanding, we have set forth our areas of support and concern within each subject area.

I.              Budgeting Rules/Financial Eligibility

A.    The Child Care Services Unit [415.1(l), 415.1(h)]

We support the clear budgeting rules which establish a “Child Care Services Unit” to define whose income in the household will be considered for the purpose of determining a family’s eligibility for child care services. We particularly support the rule which provides that children who reside with individuals who are not the children’s parents, stepparents, adoptive parent, or legal guardian with financial responsibility for the children, comprise a child care services unit separate from the adult who is not legally responsible for the child. This means that most grandparent and other kinship relative caregivers will not have their income counted when determining child care eligibility.

We also support the rule that provides that individuals who are temporarily absent will be counted as part of the child care services unit unless they are away from home as a result of foster care placement

B.    Treatment of 18, 19 and 20 Year Olds [415.1(l)]

The Social Services district has the option to include 18, 19 or 20 year old individuals in the same child care services unit as their parent(s) by indicating such option in its consolidated services plan (CSP) or integrated county plan (ICP). Districts have the options to include all  8, 19, or 20 year olds or to include only those 18, 19 and 20 year olds who inclusion in the child care services unit would benefit the family.

The inclusion of an 18, 19 or 20 year old individual in the unit could either help or hurt low income families. By including them in the unit, he household size increases, as does the financial eligibility level. However, if the 18, 19 or 20 year old has income, the inclusion could be detrimental to the household because that income is counted towards eligibility.

  • Concern: Allowing local districts to make this determination creates an inconsistent patchwork of eligibility rules across the state. The OCFS recognizes in its regulatory impact statement that many older teenagers live at home so that they can take advantage of educational opportunities and minimize expenses.  As a practical matter these teenagers rarely, if ever, contribute to their household’s income.

Recommendation: Rather than leave it to county option, there should be one uniform statewide rule, which requires that 18, 19 or 20 year olds only be included in the child care services unit when it would benefit the family.

II.             Child Support Cooperation Requirement [415.3(c), (d), (e)]

These regulations would impose a new eligibility requirement upon child care recipients, requiring them to “actively pursue” child support from the non-custodial parent. The parent could either pursue support through the district’s child support enforcement program or through other legal means.

Low-income parents should be encouraged and given every opportunity to obtain child support to benefit their children. We would fully support any proposal that made access to family court easier for working parents. However, we can not support this proposal, which lacks statutory authority, and for that reason alone, should be withdrawn.

Making child support cooperation a condition of eligibility for the receipt of child care is an unnecessary “stick,” that creates more problems than it solves. It will cause low income parents, with low wage jobs that may not provide them with vacation or personal time, to miss work in order to comply with this new mandate. Despite its well intentioned “good cause” language, it will result in many low income parents leaving the system, unless sufficient financial resources are devoted to universal notification for applicants and training to the child care workers who will be making good cause determinations for the first time. It will cause collection confusion for providers, and most likely result in providers not receiving payment in the event of a default by a non-custodial parent. We therefore, for the reasons set forth more fully below, urge OCFS to withdraw this section of the proposed regulations.

This proposal was first made in 99 ADM-5 four years ago, but the effective date was delayed until OCFS had the regulatory authority to impose such a requirement. 99 ADM-5, p. 47. As long as OCFS intends to implement this policy as set forth in that 1999 ADM and a follow up 2000 Informational Letter, this proposal provides little benefit to low-income families. This child support cooperation requirement is primarily a cost recovery mechanism, which primarily benefits local social services districts, and which will cause administrative headaches for providers when collecting fees.

  • Concern: Although these regulations create regulatory authority to impose a child support cooperation requirement, OCFS does not have the statutory authority to impose such a requirement. Cooperation requirements for Temporary Assistance, Medicaid and Foster Care are explicitly set forth in statute. For Temporary  Assistance, the requirement to cooperate in establishing paternity and obtaining support is in Social Services Law 349-b(1)(b) and the penalty for non-cooperation ( a 25% grant reduction) is set forth at Social Services Law 131(16). For Medicaid, the requirement is in Social Services Law 366(4)(h)(2). For foster care, the requirements are set forth at Social Services Law 398(5)(b), (d). There is no similar statutory authorization to require cooperation for child care in the statute governing New York’s child care block grant, Title 5-c of the Social Services Law (See sections 410-u, et. seq), or lsewhere.
  • Concern: The cooperation requirement creates a host of administrative and legal problems that are not addressed in this proposed regulation. These problems need to be firmly resolved before any child support cooperation requirement is imposed. If the State insists on pursuing this regulatory change, we raise  the following concerns and make the following recommendations:

1.     Parents pursuing child support are not entitled to assigned counsel. Family Court Act §262. Nevertheless 99 ADM-5 at page 21 requires that an applicant for or recipient of child care services who is not a client of the Support Collection Unit must demonstrate that he or she is pursuing child support by presenting a letter from a representing firm or organization which attests to a laundry list of information. Many petitioners in family court support proceedings proceed pro se. Most child support enforcement units do not provide legal representation without charging a fee to non-public assistance recipients. The verification requirements are difficult for some and impossible for non-represented persons, and have the potential to delay applications for child care services and thus disrupt employment.

Recommendation: All petitioners, but particularly pro se petitioners , must be permitted to provide a self-attestation to verify cooperation (date petition filed, return date, etc.). This should be made explicit in the regulations.

Recommendation: The regulation should clearly state that no application for child care shall be delayed pending verification of child support cooperation.

2.     The Administrative Directive makes clear that a person with a child support order must cooperate in modifying the order to address child care costs. 99 ADM-5 at page 18. The Family Court Act permits an “add-on” for child care costs. Family Court Act §413 (l)(c)(4).

  • Concern: A parent who is required to pursue an add-on for child care costs may likely incur expenses for legal representation that do not ultimately benefit her but instead benefit the social services district.  In 2000, when these regulations were contemplated but not proposed, OCFS issued an informational letter indicating that the child care add-on provided to a recipient of child care services would not go to defray the custodial parent’s cost of child care but instead would reduce the subsidy paid by the Social Services District.1 Additionally, when a non-custodial parent ceases to pay the child care add-on, it is the custodial parent who must pay the non-custodial parent’s share to retain her slot (an amount that was formerly paid by subsidy), until there has been one month of non-payment and the custodial parent has gone to family court and filed a violation petition against the non-custodial parent. [1] In 1999 OCFS indicated that districts would not have to resume paying the noncustodial parent’s share until a violation petition had been filed by the custodial parent.[2] Once that petition is filed, OFCS has not made clear who is liable for the non-custodial parent’s share which accrued between the default and the filing of the petition.
  • Concern: This proposal creates an accounting nightmare for providers who will have to collect from three sources: the custodial parent, the noncustodial parent and the county. When the non-custodial parent defaults, providers become the collector of first resort (instead of the child support enforcement unit) for the unpaid child care add-on.

Recommendation: A parent with a child support order should not be required to seek a child care add-on as a condition of eligibility.  However, if the Office of Children and Family Services is intent on requiring parents to seek a child care add-on they should:

a)     Guarantee counsel at no cost to such parents (who are by definition low income);

b)    Provide that the add-on defray the parent share of the subsidy for the custodial parent;

c)     Make the non-custodial parent invisible in the subsidy payment process. Regardless of whether the add-on is applied against the parent share or the county share of the subsidy, require that the child care add-on be paid to the child support collection unit and be transmitted directly from the child support collection unit to the county. For those receiving subsidies, the county then  becomes the guarantor of payment, just as they are for those receiving public assistance;

d)    Make the child support enforcement unit the enforcer in the event of a default (this may require that the custodial parent assign her rights to the add on to the county).

Example: Cost of child care is $100 per week. Subsidy is $50 per week and parent share is $50 per week. Child care add on is $25 per week.

A.    If the add on defrays the county subsidy: Parent continues to pay $50 per week and county pays $50 per week. Non-custodial parent pays add on directly to the county, reimbursing the county for the county share, and effectively reducing the county share to $25. If non-custodial parent defaults, neither the provider nor the parent suffers harm. The IV-D unit then pursues the non-custodial for a violation of the support order.

B.    If the add on defrays the parent share: Parent pays $25 per week and county pays $75 per week(county share plus non-custodial share). Noncustodial parent pays add on directly to the county, reimbursing the county for part of the custodial parent share. If non custodial parent defaults, neither the provider or the parent suffers harm. If statutory authority were provided, the IV-D unit could then pursue the non-custodial for a violation of the support order.

  • Concern: Courts often order that a percentage of the cost of child care be paid by the non-custodial parent. To the extent that the custodial parent’s child care needs vary from week to week, this will create a nightmare of enforceability.

Recommendation: This is another reason for the county IV-D Unit to supervise collection. The Day Care Unit could transmit the cost of care to the IV-D Unit which could log in the amount incurred and bill the non-custodial parent in such cases.

  • Concern: In response to inquires from Legal Services programs when the rule was first proposed in 1999, the OCFS answered a number of questions with respect to the interface between child support collection and child care.

First, OCFS indicated that the child support cooperation requirements would not apply for those receiving preventative or protective day care.[3] 

Recommendation: If this is still the case it should be made clear in the regulations.

  • Concern: This is a harsher penalty than the one applied in the Family Assistance program, which imposes a 25% sanction in such cases. Social Services Law §131(16).

Recommendation: If OCFS insists on imposing a penalty, it should not be harsher than the penalty imposed upon public assistance recipients. The parent should lose a percentage of her subsidy, not all of it.

  • Concern: If a recipient of child care services has two children with different fathers and mom cooperates in establishing paternity for one but not the other, neither child is eligible for child care assistance.[4]  It makes no sense that when an absent parent is paying support, that child is not eligible for a subsidy, simply because the mother does not cooperate in pursuing support for another child, with a different father in the household.

Recommendation: No penalty should be imposed against a child whose mother has cooperated in providing child support.

  • Concern: In 1999 OCFS indicated that they would apply the child support cooperation requirement to grandparents unless they had good cause.[5]6 This makes no sense in light of the fact that their income is not counted in determining the eligibility for children in their care. Proposed regulation 415.1(l)(1)(iv). Additionally, it will require grandparents to be suing their own children, which may fracture an already fragile family dynamic.

Recommendation: The regulations should expressly exclude the non-legally responsible caregivers from the cooperation requirement.

C.    Good cause and Domestic Violence.

Without doubt, victims of domestic violence will be applying for child care assistance.  As a result, these proposed regulations must provide these clients with the ability to receive much-needed benefits without having to compromise their own safety, as well as that of their children.

We support the good cause exemption definition, which, as currently written, adequately offers victims of domestic violence and their children the opportunity to be exempted from this cooperation requirement. Therefore, the good cause exception should continue to be incorporated into the proposed regulation.

  • Concern: Staff and Training issues: There are procedural concerns which have not been adequately addressed by this proposed regulation. The Administrative Directive, 99 ADM-5, pages 35 et, seq., states that child care workers would be making the determination as to whether or not family violence circumstances meet the good cause exemption requirements. Under the new regulation, will the child care workers still make good cause determinations for both Public Assistance and non-PA families? Will these workers be trained with regard to domestic violence screening and assessment issues and, if so, who will provide this training? Will domestic violence liaisons have any role and, if so, how will this role be defined? Will referrals or other services be offered to domestic violence victims?
  • Concern: Notice and screening: Under the universal screening and notification provisions contained within 98 ADM 3 (The Family Violence Option), all temporary assistance applicants and recipients must be screened for the existence of domestic violence and be notified that they may have the potential to be exempted from certain requirements such as paternity establishment and child support cooperation. Will any similar such notice requirement be instituted for child care applicants and recipients? If not, how will applicants for child care be notified about the potential good cause exemption?
  • Concern: Confidentiality: We also have several concerns regarding the confidentiality of records in cases of domestic violence. For Temporary Assistance applicants, current Social Services Law Section 349-a(7), 18 NYCRR 357.3(i), and 98 ADM 3 (page 15 and 16), all address the privacy and confidentiality of records and client information when domestic violence is at issue. In order to provide additional safety protections for the domestic violence victim and his/her family, the domestic violence liaison’s records are to be kept separate and apart from other case records and information contained within this file may be released to persons both inside and outside of the Department only on very limited bases.

In contrast, under the current child care regulation, no similar safety and confidentiality measures are being proposed for applicants and recipients who disclose the presence of domestic violence. The proposed regulation and 99 ADM-5, page 40 state that the determination about good cause and the basis upon which the determination was made shall be documented in the case record.  As a result, ironically the very same domestic violence information that is being fiercely protected by one division of the department, is at the same time rendered much more easily accessible in another. Accordingly, we propose a strong standardized policy regarding the privacy and confidentiality of domestic violence victim’s records, regardless of the point of entry for services.

III.            Application Issues

A.    Funding Set Asides, Waiting Lists and Denial of Services [415.2(d)(2)(2), (3)]

The regulations make clear that local social services districts may set aside portions of their child care block grant allocations or their Title XX allocations to serve particular priority populations. These funding set asides must be described in the district’s CSP or ICP along with a rationale for the set aside. These amounts may be adjusted up or down by 10% without the prior written approval of the OCFS provided that such adjustments are reported to OCFS within 30 days of adjustment. Prior approval is needed for adjustments in excess of 10%.

In the event that the district has set aside funds to serve one or more priority populations and all the available funds that are not set aside are projected to be needed for open child care cases, a district may choose to deny services to a family that does not fall with in the priority population for the set asides. In the alternative, the district may place the family on a waiting list for subsidies. A district that has not established set asides but otherwise has available funds committed to open child care cases may deny services to a family which is not eligible for a child care guarantee or place the family on a waiting list for subsidies.

Recommendation: The regulations should make clear that a family denied child care services for lack of funding must receive a denial notice in writing.

Recommendation: If child care need is to be accurately assessed, the social services district should be required to report the number of these denials accrued in each calendar year, as well as data regarding the numbers of children on waiting lists, to OCFS.

B.    Transitional Child Care [415.2(a)(1)(iv)(d)]

We strongly support this provision in the regulations which makes clear that transitional child care eligibility may be requested in any month during the twelve month period after the family leaves the assistance. The regulations specifically state that the start date for eligibility may precede the date services were requested and cover any period during the twelve months of the guarantee.

C.    Parent Fee/Family Share [415.4(f)]

The Parent Fee provisions are now called “Family Share”. The regulations make clear that a family share may now include an overpayment amount for child care services.

  • Concern: Logistically this seems somewhat confusing in as much as part of the family share would then go to the provider and part to the social services district. In a meeting with OCFS on July 11, 2003, we asked how this would work and were advised that district could choose to have the parent pay the overpayment to the social services district, or if the parent fee is paid to the provider, the county would adjust (lower) the amount of the subsidy going to the provider. This raises a host of other problems. If the parent defaults in payment, is there a subsidy adjustment to the provider? Will the provider get advance notice that the parent share is being adjusted and that will mean that their county subsidy will also get adjusted downward?

Recommendation: These issues should be explicitly addressed in regulation. Failure to timely pay the family share can result in the termination or suspension of child care services.

  • Concern: What does “timely pay” mean?

Recommendation: The definition of timely payment should appear in the regulations. .

D.    Interdistrict Moves [415.4(d)]

The proposed child care regulations would adopt a rule similar to the rule for interdistrict moves in public assistance cases. When a recipient of child care services moves from one district to another, the former social services district is obliged to continue to pay for child care services during the month that the family moves from one district to the other and the following full month. The new social services district of residence is responsible for child care thereafter. This provision does not apply in situations where the former social services district has continuing responsibility for providing public assistance such as when the parent or caretaker relative is required to attend a substance abuse program, nor does it apply in foster care situations.

We support the creation of a rule that clearly outlines areas of responsibility in the situation of an interdistrict move.

  • Concern: Unfortunately, this provision only applies to families in receipt of public assistance and transitional child care.

Recommendation: This regulation should be expanded to include families who receive income eligible child care to allow for a smooth transition to the new district of residence. The Office of Children and Family Services should request that a small amount of money be set aside in next year’s state budget for people who move to new districts of residence to assure that their child care may continue despite their move.  Local districts could then claim against this amount so they would not disrupt their projected spending patterns. Child care, like food stamps and Medicaid is a federally funded benefit; it should be administered as a statewide program; the fact that a person moves from one district to another within the state should not affect eligibility.

E.    Child Care Provided Outside the District [415.9(k)]

We strongly support this provision which provides that when a social services district pays for child care services provided by a provider located in another district, the applicable market rate is the rate for the district in which the child care provider is located.

IV.           Programmatic Rules

A.    Child Care for Sleeping Parents [415.4(c)(3)]

The regulations make clear that up to eight hours of child care services may be provided to enable an employed caretaker who works a second or third shift to sleep.

We support this provision which is particularly helpful for parents who work the night shift and who are unable to sleep during the day because their young children are not yet in school.

  • Concern: Unfortunately this is a county option.

Recommendation: The regulations should make this a requirement for all parents regardless of county of residence, who need such care.  Parents who work the night shift with children who are too young to be in school have no time to sleep without endangering their children. This danger is real regardless of county residence and should not be a county option.

B.    24-Hour Care [415.1(a)(1) thru (3)]

The regulations as they currently exist provide that child care services cannot be provided for more than a 24-hour period.

We support this proposed new regulation which would allow exceptions to this prohibition in certain circumstances such as when services are provided on a short term emergency basis or when the caretaker’s approved activity necessitates care for 24 hours on a limited basis, so long as the social services district chooses this as an option in their consolidated services plan or integrated county plan.

  • Concern: Programmatic eligibility rules should be the same across the state for similarly situated persons.

Recommendation: The exception should be uniform and should not be a county option.

C.    Breaks in Activity [415.2(c)]

The Seamless Funding Bill (Ch. 569 of the Laws of 2001) amended Social Services Law § 410-w(5), to make it mandatory for social services districts to provide child care for families on public assistance who were between breaks in activity, and for families in work activities or community service. Such interim care could be for a period of up to two weeks and renewed for a period of up to one month total if child care arrangements would be lost if the services were not continued. These regulations make clear that social services districts have the option to provide such interim care for non-public assistance families.

We strongly support the expansion of this rule to non-public assistance families.

  • Concern: Programmatic eligibility rules should be the same across the state for similarly situated persons.

Recommendation: OCFS should seek legislation to provide this protection for all recipients of child care subsidies.

V.            Provider Issues

A.    Legally Exempt Providers [415.4(f)(7) ]

Two new requirements are being imposed upon legally exempt providers, also known as “informal” child care providers. Such providers must answer two questions. First, whether or not they have ever been denied a license or registration to operate a day care program or group or family day care home or had such a license or registration suspended or revoked. Additionally, legally exempt providers must attest to whether or not they have ever had their parental rights terminated or had a child removed from their care pursuant to Article 10 of the Family Court Act. If either of these questions are answered in the affirmative, the social services district may choose to enroll or refuse to enroll such a caregiver as a legally exempt child care provider.

We support the addition of these standards which will help assure that state dollars pay for quality child care.

  • Concern: Whether the district chooses to enroll or refuse to enroll a legally exempt caregiver should be guided by standards that should be set forth in regulation. Additionally, the regulations should state that a provider who is denied enrollment should have the right to a fair hearing.

B.    Absences - [415.6(e)(4),(5)]

The regulations make several important changes with respect to payments for absences. The requirement that payments for absences be made only to contracted providers is now abolished. The districts must now adopt their absence policies in their consolidated services plan. Social services districts may choose to continue to only allow contracted providers to be paid for absences. Alternatively, they may provide them to all subsided child care services except for informal or legally exempt child care providers. Payment for absences is not allowed to providers who are paid on daily or part-time rate.

The regulations also permit licensed, registered or legally exempt group programs to claim an additional 5 days of reimbursement in the case of natural disasters, severe weather and closures due to state, federal or nationally recognized holidays.

We strongly support the abolition of the requirement that payments for absences be made only to contracted providers, as well as the allowance of 5 days for closures for the enumerated reasons set forth above.

  • Concern: Provider reimbursement rules should be the same across the state for similarly situated providers.

Recommendation: In order for parents with subsidies to truly obtain equal access to child care providers, payment for absences and holidays should be required whenever it is required for private pay parents.

VI.           Miscellaneous Issues

A.    Multi-Year Consolidated Services Plan/Integrated County Plans/ Implementation Reports - [415.4(e)(6)]

The regulations make clear that each social services district must submit a multi-year consolidated services plan or an integrated county plan and any implementation reports as required by OCFS.

Recommendation: The regulations do not state how these plans are made available to the public. The regulations should require that all current plans be made available either upon request to the local services district, or to the Office of Children and Family Services, within 5 business days after the request. Additionally, these plans should be available on line on the OCFS website as well as the county or local district website.  Easy access to these plans are critical due to the multitude of characteristics that are particular on a county by county basis. In order for parents to clearly understand their rights, or if they are attempting to enforce them through the fair hearing process, it is important that these plans be readily available.

B.    Recovery of Overpayments - [415.7(i),(j)]

The regulations make clear that an overpayment may only be recovered from a caretaker relative or provider who is responsible for such overpayments, whether the result of acts of omission or commission. A parent who promptly reports a change in circumstances but is overpaid as a result of the district’s failure to act promptly, shall not be required to repay said overpayment. In such case neither federal nor state reimbursement can be claimed for such an overpayment.

Applicants who have not repaid past overpayments for previous child care services must agree to and comply with a plan to make full payment of such overpayments as a condition of being eligible for new child care services. Recipients who fail to agree to such plans will have their child care benefits suspended or terminated. A recipient or former recipient of child care services who has voluntarily admitted to  fraudulently receiving child care services will not be eligible for a period of time in accordance in the penalties under the intentional program violation rules in 18 NYCRR 359.9. This penalty will be suspended if the recipient is being required to participate in activity for which child care services are necessary.

Overpayments for child care services which result from aid continuing for a caretaker who loses a fair hearing, will be recovered in the same manner as other overpayments.

We support the provision that bars repayment for overpayments caused by the agency’s failure to promptly budget changes.

C.    Case Closings for Lack of Funds [415.2(d)(4)]

When districts run out of money, social services districts are permitted to discontinue funding to families that are not eligible for a child care guarantee. The regulations state that the length of time used to close cases may be based on either the shortest or longest time a family has received child care services, but must be consistent for all families with in the district. The county option must be specified in the local district’s consolidated services plan or integrated county plan.

  • Concern: Programmatic eligibility rules should be the same across the state for similarly situated persons.

Recommendation: The state should develop one consistent rule for the use of this primarily federal funding stream so that all residents of the State of New York are treated equally.

Thank you for the opportunity to comment on these regulations. We hope you will consider our specific comments regarding improvements and alternatives before you proceed, and repromulgate the regulations with the changes we suggested, particularly the omission of the child support cooperation requirement.

Very truly yours,

 

Susan C. Antos
Staff Attorney, Greater Upstate Law Project

and

Chair, Legislative Committee
New York State Child Care Coordinating Council

 

cc: Lee Prochera, Esq.
Suzanne Sennett,
Director BECS
Anne Ball
Mark Kissinger, Executive Chamber
Jaqui Greene, Assembly Program and Counsel
Senate Committee on Children and Families
Assembly Committee on Children and Families
Eileen Stack, Esq.



[1] Id., Question 44.

[2] Id.

[3] Memorandum from Anne Ball to Suzanne Zafonte Sennette and Lee Prochera (11/1/99),

Question 1, attached.

[4] Id. Question 5.

[5] Id. , Question 3.

For more information, please contact:


Susan C. Antos

Empire Justice Center
119 Washington Avenue
Albany, NY  12210 


(518) 462-6831
(518) 935-2852
santos@empirejustice.org