Arkansas CCDF State Plan Analysis for FY 2019-2021 and FY 2022-2024
1 Arkansas CCDF State Plan Analysis for FY 2019-2021 and FY 2022-2024
By Olivia Gardner
AACF Educaon Policy Director
Introduction
The Child Care and Development Block Grant (CCDBG) Reauthorizaon Act of 2014
requires state-led child care agencies to submit a plan every three years that outlines
their state child care policies and plans for using their Child Care and Development
Fund (CCDF) resources.
1
These state plans, which serve as the state applicaon to the
Administraon for Children and Families (ACF) for appropriated federal CCDF dollars,
also provide data on the variaons in child care policies across states and oer a way for
sharing informaon about eecve policies across states.
2
While state CCDF plans can be amended over the three-year period, community
stakeholders can use the plans’ development as an opportunity to advocate for key policy
changes in areas including parent eligibility, access, and provider payment policies that
can promote equitable access to quality child care.
The nal FY 2022-2024 state plan does include improvements for child care in our state.
For example, there is an increase in voucher reimbursement rates that more closely align
with costs of providing quality child care.
3
This is crucial for compensaon for child care
providers and for building equal access for families. There is also funding for expansion
of the very successful Teacher Educaon and Compensaon Helps (TEACH) Scholarship
program, as well as new funding for quality improvement.
However, there are also parts of the plan that do not fully address the inequies and
challenges that families across the state face when accessing child care. For example,
the co-payments families must make were increased and are sll set at a at rate.
4
This at rate is set regardless of income or family size, and it ulmately limits access to
high-quality and aordable early child care. According to the U.S. Department of Health
and Human Services (HHS), child care is considered aordable when it costs families
no more than 7 percent of their household income.
5
The at rate does not take that
recommendaon in to consideraon.
We also know that the negave eects of the COVID-19 pandemic are being
felt by our early childhood educaon (ECE) workforce and is showing up
in our classrooms; and unfortunately, the plan lacks sucient funding for
the social-emoonal needs of children, sta, and their families. According
to a 2021 UAMS report that surveyed the ECE workforce, nearly half of
parcipants screened were at risk for depression.
6
This is up from the
35 percent reported in the 2017 Workforce Study of Instruconal Sta.
7
2 Arkansas CCDF State Plan Analysis for FY 2019-2021 and FY 2022-2024 www.Aradvocates.org
Such high depression risk could have a devastang impact on the quality of care provided
to children. All children deserve a quality educaonal foundaon that will prepare them to
grow, learn, and succeed, and we know that the key to a properly wired brain is the consistent
presence of responsive adults. Ensuring our children have that strong foundaon will require
addional support to the ECE workforce.
This report also includes a discussion of the proposal submied to the Arkansas State
Legislature by the Division of Child Care and Early Childhood Educaon (DCCECE) for the use
of new federal funding from the American Rescue Plan (ARP).
8
This historic, one-me funding
oers our state the opportunity to expand exisng programs and address inequies that our
children and families are facing in Arkansas.
Contents of the nal FY 2021-2024 state plan
One important update to the FY 2022-2024 state plan is the increase in eligibility limits set by
the state, detailed in Figure 1. The eligibility limits increased roughly 11.6 percent from the FY
2019-2021 state plan.
9
Eligibility Limits for FY 2021-2024
Family
Size
100% of State
Median Income
($/Month)
85% of State Median
Income
($/Month)
[Mulply (a) by 0.85]
1 $3,007.94 $2,556.75
2 $3,933.46 $3,343.44
3 $4,858.98 $4,130.13
4 $5,784.50 $4,916.83
5 $6,710.02 $5,703.52
The co-payments made by families based on income level were also adjusted. Income level
increased by 11.6 percent, and co-payments were increased as well, from $29.61 to $37.80,
regardless of income.
10
Co-payments and income levels for FY 2021-2024
Family
size
Monthly income
level where family
is rst charged a
co-pay
Co-payment for a
family of this size
based on income
Monthly income
before a family is no
longer eligible
1 $1,203.19 $37.80 $2,556.75
2 $1,573.39 $37.80 $3,343.44
3 $1,943.60 $37.80 $4,130.13
4 $2,313.81 $37.80 $4,196.83
5 $2,684.02 $37.80 $5,703.52
3 Arkansas CCDF State Plan Analysis for FY 2019-2021 and FY 2022-2024 www.Aradvocates.org
The state discussed several important partnerships in the FY 2022-2024 state plan. Regarding
services for families experiencing homelessness, DCCECE coordinates with child care providers
and local agencies.
11
DCCECE partners with the Arkansas Out of School Network (AOSN) to
ensure that school days are opmized for successful transion and alignment across mixed
delivery systems.
12
Addionally, DCCECE collaborates with the Temporary Assistance for Needy
Families (TANF)-funded iniave, “100 Families.”
13
This program assists families experiencing
homelessness and other signicant risk factors to ensure a successful transion into
employment and/or educaonal programs. DCCECE also discussed their public-private contract
established with Save the Children, which provides programming for at-risk families with a
focus on language and literacy development in the home and in preschool classrooms.
14
Comparison of the FY 2019-2021 and FY 2022-2024 state plans
Overall, the preprint dra and the nal FY 2021-2024 state plan saw minor updates from the
FY 2019-2021 version. As previously menoned, increases were made in eligibility limits and
co-payment costs for families. Addionally, several important denions were updated and
strengthened. This cycle also saw the expansion of Secon four: Equal Access by ACF, therefore
new details related to equity are available in the nal plan.
The state expanded on their previous strategies ulized to provide outreach and services to
eligible families for whom English is not their rst language.
15
The nal FY 2021-2024 state plan
includes new services like applicaon and informaonal materials in non-English languages,
website in non-English languages, accepng applicaons at local community-based locaons,
bilingual caseworkers or translators and outreach workers available, and partnerships with
community-based organizaons.
16
The state also expanded on their previous strategies to provide outreach and services to
eligible families with a person(s) with a disability. The nal FY 2021-2024 state plan includes
new services like:
17
• Ensuring accessibility of environments and acvies for all children
• Partnerships with state and local programs and associaons
focused on disability related topics and issues
• Partnerships with parent associaons, support groups, and parent-to-
parent support groups, including the Individuals with Disabilies Educaon
Act (IDEA) federally funded Parent Training and Informaon Centers
• Partnerships with state and local IDEA Part B, Secon
619 and Part C providers and agencies
• Availability and/or access to specialized services (e.g., mental health,
behavioral specialists, therapists) to address the needs of all children
4 Arkansas CCDF State Plan Analysis for FY 2019-2021 and FY 2022-2024 www.Aradvocates.org
The FY 2021-2024 state plan changed how the state denes children with special needs,
signicantly expanding its denion from the FY 2019-2021 state plan.
18
“A child whose physical condion has lasted or is expected to last at least two (2)
years as diagnosed by a licensed medical or psychological praconer, a child
determined eligible for special services under the Individuals with Disabilies
Act (IDEA) for whom a current IFSP or IEP exists, and/or a child with an emoonal
and/or behavioral disturbance dened by IDEA and reviewed by a team of
Behavior Specialists cered in Early Childhood Mental Health Consultaon
(designated by the DCCECE) as experiencing one or more of the following: an
inability to learn that cannot be explained by intellectual, sensory, or health
factors, an inability to build or maintain sasfactory interpersonal relaonships
with peers and teachers, inappropriate types of behavior or feelings under
normal circumstances, a general pervasive mood of unhappiness or depression,
and/or a tendency to develop physical symptoms or fears associated with
personal or school problems.” A child whose physical condion has lasted or
is expected to last at least two (2) years as diagnosed by a licensed medical
or psychological praconer, a child determined eligible for special services
under the Individuals with Disabilies Act (IDEA) for whom a current IFSP or
IEP exists, and/or a child with an emoonal and/or behavioral disturbance
dened by IDEA and reviewed by a team of Behavior Specialists cered in
Early Childhood Mental Health Consultaon (designated by the DCCECE) as
experiencing one or more of the following: an inability to learn that cannot
be explained by intellectual, sensory, or health factors, an inability to build
or maintain sasfactory interpersonal relaonships with peers and teachers,
inappropriate types of behavior or feelings under normal circumstances, a
general pervasive mood of unhappiness or depression, and/or a tendency to
develop physical symptoms or fears associated with personal or school problems.”
5 Arkansas CCDF State Plan Analysis for FY 2019-2021 and FY 2022-2024 www.Aradvocates.org
In the secon on equal access, the state discussed how they will increase the supply and
quality of child care programs. Figure 2, outlines which groups will see those changes.
19
Child Care Programs that Serve Increase
the supply
of care
Increase the
quality of
care
Children with disabilies x
Infants and toddlers x
x
School-age children x
x
Children needing non-tradional
hour care
x
x
Children experiencing
homelessness
x
Children with diverse linguisc or
cultural
backgrounds
x
Children in underserved areas x
x
Children in urban areas x
Children in rural areas x
x
The state went on to say that pending state and federal approval, DCCECE plans to ulize ARP
stabilizaon funds to 1) support the expansion of exisng programs, with an emphasis on rural
areas for infant/toddler and school-age care; and 2) assist exisng providers in reaching higher
quality levels.
20
Policy Recommendations:
The FY 2022-2024 state plan increases the base payments rates and percenles over the FY
2019-2021 state plan.
21
Arkansas already dierenates payment rates based on certain factors,
such as the provider’s locaon, the child’s age, or the quality of care. For example, states oen
have higher rates for care for providers in high-cost areas; serving younger children; oering
higher-quality care; and oering care during evenings, overnight, and weekends.
While these dierenang rates can serve important purposes, it is essenal to set adequate
base rates. If base rates are low, even a small, unexpected expense could leave providers
without the resources they need to oer high-quality early learning experiences for the
children in their care and without an incenve to serve families receiving assistance.
22
Now is a crically important moment to decide on a path forward for the ECE sector, and that
includes paying all subsidy providers by enrollment and not aendance. This change would
stabilize budgets for providers and contribute to connuous quality improvement. It will also
encourage those currently not parcipang in the voucher program to begin. This is both a
compensaon strategy and a supply-building strategy, where we can encourage more child
6 Arkansas CCDF State Plan Analysis for FY 2019-2021 and FY 2022-2024 www.Aradvocates.org
care providers to either join or stay a part of the subsidy program. This policy change would
need to apply to centers and as well as family child care homes.
Under the new rates and policy, the denions of part-me and full-me were amended.
Under the new state plan, full-me is dened as a minimum of eight hours per day.
23
Part-me
is anything less than eight hours and is calculated at 50 percent of the full-me rate.
24
This is a
change from the previous state plan, which stated that full-me was at least ve hours and up
to 10 hours.
25
This shi is problemac for a few reasons: 1) We know that fee-based families are not receiving
a discounted rate because the cost of care remains consistent regardless of the number of
hours a child may aend in the day. It is not a sound business pracce for the state to have a
separate, and substanally lower rate, for subsidy-based families. 2) Most programs will not
be able to accommodate families needing part-me care because the costs remain while the
reimbursement is reduced by 50 percent. We expect that this policy shi will greatly reduce
access to care for families who do not require eight hours. 3) Due to this limited access for
part-me child care, we fear this policy will inadvertently encourage families to use care more
oen than they may need to. We do not believe this was the state’s intenon, however, it does
disincenvize families from maximizing me with their young children.
Discussion of the AR Department of Human Services American Rescue Plan
child care spending recommendations
DCCECE recently released their proposal for the use of ARP funds, and this proposal was
approved by the Arkansas Legislave Counsel on September 17, 2021.
26
The topline funding
levels included in the proposal are listed below along with an analysis.
1. Stabilizaon Funds
a. Subgrant Payments: $258 million
i. Operaonal
ii. Quality Improvement
iii. Child Care Expansion
b. Supply Building: $25 million
2. Supplemental Discreonary Funds
a. Essenal Worker Child Care: $130 million
b. TEACH Scholarship Program: $40 million
3. Administrave
a. Stabilizaon: $3 million
b. Supplemental Discreonary: $8 million
Total Funding: $464 million
7 Arkansas CCDF State Plan Analysis for FY 2019-2021 and FY 2022-2024 www.Aradvocates.org
Stabilization Funds
Cing three Arkansas-specic COVID-19 child care studies, the state notes that early care and
educaon program sta are experiencing high levels of stress, sta onboarding and retenon
issues, lost revenue, and diculty maintaining health and safety standards.
27
Therefore, the
state claims operaonal payments for programs are necessary to stabilize the sector and
minimize the number of permanent closures.
28
Regarding quality improvement, the state discussed the movement toward creang a ered
quality rang improvement system. The state proposes to use stabilizaon subgrant funding
to support exisng early childhood educaon programs in obtaining a higher level of Arkansas
Beer Beginnings by funding the operaons and resources necessary to do so.
29
Arkansas set
a previously established goal of July 2020 for all programs receiving CCDF voucher funding
to become level two or higher; however, due to the COVID-19 pandemic, this goal was
ulmately pushed back to July 2022.
30
The state acknowledged that facilies did not have the
me, funding, or resources necessary to move forward in achieving quality as a direct result
of COVID-19. Therefore, DCCECE proposes to remove the funding and resource barriers by
allowing programs to submit subgrant applicaons for the amount necessary to obtain a higher
level of Beer Beginnings.
31
Lastly, to address “child care deserts” that exist across Arkansas, DCCECE proposes providing
subgrants to support the expansion of currently licensed programs with an emphasis on rural
areas to build and expand capacity for high-quality infant/toddler and school-aged care.
32
Supplemental Discretionary Funds
DCCECE plans increase the supply of child care services available to the essenal workforce
and low-income families, nong that these families are integral to Arkansas’s recovery from
the pandemic and that they oen need child care outside of regular business hours.
33
The state
also proposes extending the Essenal Worker Child Care program (including new applicaons)
through September 30, 2024, or unl funding has been exhausted.
34
The proposal also includes plans to expand the previously established TEACH Arkansas
Scholarship Program and allow up to 4,000 full-me early childhood teachers the opportunity
to obtain a credenal, degree, or cercate.
35
The state acknowledged that due to the
COVID-19 pandemic, many educators had to suspend their eorts to obtain college credits
in early childhood educaon due to nancial hardships, safety, or other burdens. DCCECE
proposes to assist the early childhood educaon workforce to move forward in pursuing higher
educaon following the pandemic.
36
Administrative
DCCECE also alloed funds to cover the costs associated with implemenng these funding
proposals. These funds can cover usual administrave costs like, salaries, personnel,
equipment, facilies, and travel.
37
8 Arkansas CCDF State Plan Analysis for FY 2019-2021 and FY 2022-2024 www.Aradvocates.org
Discussion of the Public Comments
Of the comments made during the public comment period for the FY 2022-2024 CCDF state
plan, the comments with specic language changes were most likely to be accepted. On at
least three occasions, very specic language changes were made to the nal FY 2022-2024
state plan. It is hard to determine if comments that were more general in nature, or anecdotal,
were factored into any of the changes made, but that does not seem to be the case.
Many of the comments that were not included in the nal FY 2021-2024 state plan have been
addressed in the state’s proposal for the use of ARP funds. Here are some of the suggesons
made in the public comment period that were addressed in either the nal FY 2022-2024 CCDF
state plan or the ARP spending proposal:
• Expansion of the Essenal Worker Child Care voucher program
• Expansion of the TEACH Scholarship program
• Addional funding for quality improvement
• Addional funding for operaonal costs
A set of recommendaons were submied by the Arkansas Early Childhood Associaon (AECA)
during the public comment period.
38
Two notable omissions in both the nal FY 2022-2024
CCDF state plan and the ARP spending proposal include seng the subsidy payment rates
based on aendance rather than enrollment which is problemac for the reasons discussed
above; as well as a recommendaon about the social-emoonal learning support for children,
sta, and families.
The ARP allows for a program to use their “operaonal subgrant” for mental health services;
however, both AACF and AECA would have preferred a more coordinated approach to the
issue. We are concerned that in some locaons that even if a program chooses to spend these
funds on mental health, they are likely to have diculty accessing these services. Ulmately,
when programs are forced to choose between using the funds for mental health services or
for air puriers, personal protecve equipment, or covering past losses associated with the
pandemic, the immediate physical health and nancial needs are more likely to be placed
ahead of mental health needs.
Arkansas Advocates for Children and Families
1400 West Markham, Suite 306
Little Rock, AR 72201
(501) 371-9678
Northwest Arkansas Ofce
614 East Emma Avenue, Suite 235
Springdale, AR 72764
(479) 927-9800
facebook.com/aradvocates @aacf @aradvocates
1 hps://www.acf.hhs.gov/occ/fact-sheet
2 hps://www.clasp.org/sites/default/les/publicaons/2021/01/2021_State%20CCDF%20Planning%20Process%20brief.pdf
3 2022 state plan details
4 2022 state plan details
5 hps://www.govinfo.gov/content/pkg/FR-2016-09-30/pdf/2016-22986.pdf
6 hps://medicine.uams.edu/familymedicine/wp-content/uploads/sites/7/2021/07/Summary-of-AR-ECCE-Covid-19-Surveys_
Final-1.pdf
7 hps://medicine.uams.edu/familymedicine/wp-content/uploads/sites/7/2021/07/Summary-of-AR-ECCE-Covid-19-Surveys_
Final-1.pdf
8 hps://humanservices.arkansas.gov/wp-content/uploads/DCCECE-American-Rescue-Plan-Proposal-One-Pager.pdf
9 2022 state plan details
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20 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
21 2022 state plan details
22 hps://www.clasp.org/sites/default/les/publicaons/2021/01/2021_State%20CCDF%20Planning%20Process%20brief.pdf
23 2022 state plan details
24 2022 state plan details
25 hps://humanservices.arkansas.gov/wp-content/uploads/stplan_pdf_2019_nal_approved.pdf
26 hps://humanservices.arkansas.gov/wp-content/uploads/DCCECE-American-Rescue-Plan-Proposal-One-Pager.pdf
27 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
28 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
29 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
30 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
31 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
32 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
33 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
34 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
35 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
36 hps://www.arkleg.state.ar.us/Calendars/Aachment?commiee=020&agenda=4741&le=Supplemental+Agenda.pdf
37 hps://humanservices.arkansas.gov/wp-content/uploads/DCCECE-American-Rescue-Plan-Proposal-One-Pager.pdf
38 hps://arkansasearlychildhood.org/wp-content/uploads/2021/06/Federal-Funds-Recommendaon.pdf
Endnotes
