Implications of Child Care and Development Block Grant Reauthorization for State Policies: Changes to Job Search Policies

Brief

Implications of Child Care and Development Block Grant Reauthorization for State Policies: Changes to Job Search Policies

Abstract

The 2014 reauthorization of the Child Care and Development Block Grant will change how states and territories provide child care subsidies to low-income families. Before reauthorization, most states and territories provided some level of job search eligibility. Now, states and territories that didn’t allow this type of eligibility will have to add it, and states and territories that allowed some eligibility for job search may have to make changes to comply with the new law. This brief describes state and territory policies for job search before reauthorization and how those policies will have to change in the coming years.

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Implications of Child Care and Development Block Grant Reauthorization for State Policies: Changes to Job Search Policies

The recent reauthorization of the Child Care and Development Block Grant (CCDBG) Act will create some major changes in how States and Territories provide child care subsidies to low-income families. This brief focuses on just one change, the extent to which subsidies are available to parents who are looking for work. Before the reauthorization, most but not all
States/Territories provided some level of job search eligibility. Now, the States/Territories that have not allowed this type of eligibility may have to add it, and even States/Territories that already allow some eligibility for job search may have to make changes in their policies to comply with the new law.

 

Background

 

The Child Care and Development Fund (CCDF) provides funding from the CCDBG to the States, Territories, and Tribes to administer child care subsidy programs for low-income families.1 States/Territories must comply with broad federal guidelines, including but not limited to establishing income eligibility limits at or below 85 percent of state median income (SMI);
setting the maximum age for children at or below 12 years, or at or below 18 years if children have special needs; and defining what activities qualify for assistance (work, education, training, etc.). Within the broad federal guidelines, States/Territories are given discretion to establish many of the detailed policies used to operate their CCDF programs, including job search policies.

 

The CCDBG Act of 2014 is the first reauthorization of the federal grant since 1996. The reauthorization of CCDBG emphasizes family-friendly eligibility policies, increased quality of care, more explicit health and safety requirements for child care providers, and transparent and accessible information about providers to help parents make informed decisions.2 One key requirement affects working parents who become unemployed while receiving CCDF-funded subsidies. States/Territories must continue providing child care subsidies to families during the eligibility period even if they experience a temporary disruption in their employment, education, or training status (such as maternity or medical leave, a change in seasonal work schedule, or a break between school semesters). For families who have a permanent change in their employment status (such as losing a job or finishing a training or education program), States/Territories can continue assistance until the end of the minimum 12-month eligibility period. If they choose to terminate assistance, the State/Territory must provide child care subsidies for at least 3 months to allow the parent to engage in a job search and resume work or to resume attendance at a job training or educational program.3 (For more information on the revised eligibility period, see the companion brief “Reauthorization of the Child Care and Development Block Grant: Changes to Requirements for Ongoing Eligibility.”) While this requirement will also apply to parents who stop attending education or training programs, in this brief we focus on the implications for state policies affecting parents who lose their jobs. While many of the new policies went into effect when the law was signed on November 19, 2014, some policies have later implementation dates. For requirements without specified dates, the Office of Child Care set September 30, 2016 as the implementation date. Additional guidance is provided to the States/Territories through the CCDF Plan Preprint and program instruction memorandums from the Office of Child Care.4

 

In this brief, we look at current State/Territory policies for job search as an approved activity as they are addressed in the new legislation in order to understand what State/Territories are currently doing and how those policies might have to change. We provide an overview of the policy, a snapshot of State/Territory policies prior to CCDBG reauthorization, and a description of how the policies will have to change to align with the new requirements. Finally, we provide information about additional resources for understanding State/Territory policies and CCDBG reauthorization.

 

The policies discussed in this brief are drawn from several resources. We use the CCDF Policies Database to understand current State/Territory policies, and the CCDBG legislation, as well as the CCDF Plan Preprint, to describe the federal policy requirements. The U.S. Department of Health and Human Services (HHS) has issued proposed regulations based on the new law. In addition to providing information on how to implement the law, the regulations may include additional requirements, within the CCDBG legislation, for States’/Territories’ child care subsidy policies.

 

Policies Related to Eligibility during Periods of Job Search

 

In order to qualify for subsidies under the CCDF program, parents or guardians must participate in an approved activity that demonstrates a need for child care. These activities have typically focused on work, education, or training, with some states also approving care for job search activities. Parents searching for a job may need child care so that they can attend interviews, work on resumes, or submit job applications. Policies related to job search periods can greatly impact a family’s ability to keep subsidized child care, and in turn the continuity of care for the children.

 

Federal policy has typically allowed, but not required, States/Territories to provide CCDF subsidies for parents seeking work. As of October 1, 2014, the month prior to reauthorization, 16 States/Territories did not provide any CCDF-subsidized child care to support job search (figure 1 and appendix table 1). Among the 40 States/Territories that considered job search to be a qualifying activity for CCDF subsidies, the specifics of these policies varied widely. Some States/Territories approved this type of eligibility only for parents who became unemployed while already participating in the child care subsidy program. This is referred to as job search for continuing eligibility only, and 19 programs used this approach. Other States/Territories also approved subsidies for parents who were not working and were actively looking for employment when they entered the program (referred to as job search for initial eligibility). Twenty-one States/Territories considered job search a qualifying activity for both initial and continuing eligibility.5

Figure 1. State and Territory Job Search Policies (2014)

States/Territories have also varied on the maximum length of time that unemployed parents can receive child care subsidies. As of October 1, 2014, the amount of time allowed for job search activities ranged from 2 to 13 weeks per year in 14 States/Territories, from one to two months per six-month period in five States/Territories, and from 30 days to six months per job loss occurrence in 18 States/Territories. The remaining three States/Territories that allowed for job search activities used slightly different methods for establishing the amount of time approved. In Connecticut and Oregon, job search activities were approved through the end of the month following the month in which employment ended, regardless of what day of the current month employment ended. In the Northern Mariana Islands, job search activities were approved for 30 days (with no specification of how many job search periods a family can have in a given time period). Appendix table 1 provides the States’/Territories’ detailed job search policies, including time limits, for October 2014.

 

Now, some States/Territories will have to change existing policies to meet the new federal law regarding eligibility during periods of unemployment. Whereas States/Territories previously had the discretion to terminate a parent’s child care subsidy if he or she lost a job or stopped attending a training or education program, CCDBG reauthorization now requires States/Territories to continue providing the subsidy to the family for the remainder of the 12-month minimum eligibility period or provide a job search period of at least three months if they choose to terminate the subsidy prior to the end of the 12-month eligibility period. For example, in a State/Territory that decides to terminate subsidies prior to the end of the eligibility period due to a permanent job loss, if a parent loses his or her job after 10 months of receiving child care subsidies, he or she must receive at least 3 more months of eligibility. In a State/Territory that decides to continue subsidies for the full eligibility period regardless of a loss of employment, if a parent loses his or her job after 6 months of receiving child care subsidies, he or she must receive subsidies for the remainder of the 12-month minimum eligibility period, so in this case for at least 6 more months. The new legislation intends for policies to allow sufficient time for families in every State/Territory to find work or re-enroll in education or job training without losing their child care subsidy in the interim. This may also allow for greater continuity of care for children.

 

To meet the requirements of the law, the 16 States/Territories that did not allow care for job search for continuing eligibility must either allow families to receive subsidies for at least 12 months, regardless of permanent changes in employment or attendance at an education and training program, or continue providing subsidies for at least three months. The other 40 States/Territories already partially or fully meet the new requirements by providing job search for at least continuing eligibility, but they will need to provide at least three months of subsidies for job search or provide subsidies for the full eligibility period for parents who become unemployed while receiving subsidies. Of the 40 States/Territories that authorized subsidies for job search, only five States/Territories had job search time limits of at least three months (in a year or per job loss occurrence). The remaining 35 States/Territories will need to extend their job search time limit to at least three months or provide care for the full eligibility period.

 

Understanding State and Territory Policy Changes Going Forward

 

Over the next several years, State/Territory CCDF policies will change significantly as a result of the reauthorization of the CCDBG Act. The policy change that requires States/Territories to continue a subsidy for at least three months after a parent loses a job or provide subsidies for the full eligibility period could result in changes in the number of families and children eligible for child care subsidies at a given point in time. For example, low-income families, who are more likely to experience periods of unemployment, might have previously lost their child care subsidies when they lost their job. Based on an analysis of the Current Population Survey (CPS), 6.9 million children in families with income below 200 percent of the Federal Poverty Level had a parent who was unemployed some time during 2012.6 Among these children, about one-third had parents who were out of work for at least six months.7 Families receiving subsidies will now be able to either stay on the program during the full eligibility period even if they lose their job or continue to receive their subsidies for at least three months.

 

While the new policies could result in significant changes in the length of time some families will receive CCDF assistance, it is unclear at this time how the actual caseloads will change as States/Territories make decisions about how to implement the new requirements and how other related policies might change. States/Territories will face decisions about how to implement the new requirements, and how to fund the changes, as the new law did not guarantee higher federal funding.8 Over the next several years, as States/Territories revise their policies to come into alignment with the new law, additional information about CCDBG reauthorization and guidance for States/Territories, how and when State/Territory policies change, and how caseloads change, will be available through several public resources.

  • Resources from the CCDF Policies Database: The CCDF policies shown here are taken from the CCDF Policies Database. The CCDF Policies Database tracks State/Territory policies over time, with hundreds of variables tracking policies related to family eligibility, application and wait list procedures, family copayments, provider reimbursement rates, and other provider policies. The Database is maintained by the Urban Institute and funded by the Office of Planning, Research and Evaluation within the Administration for Children and Families, U.S. Department of Health and Human Services. The data are available for public use through annual published reports and access to the full Database detail.9 This brief is one in a series of briefs on the implications of CCDBG reauthorization on state child care subsidy policies. The other two briefs describe the changes to ongoing eligibility requirements and the changes to requirements for legally unregulated child care providers. Additionally, policy changes resulting from CCDBG reauthorization will be picked up as part of future updates to the Database, with the data made available for public use.
  • Resources from the Office of Child Care: Information on CCDBG reauthorization, as well as information on CCDF caseloads and spending, can be obtained from the Office of Child Care (OCC), within the Administration for Children and Families, U.S. Department of Health and Human Services.
    • CCDBG Reauthorization: OCC provides the statutory language of the Act, guidance for States/Territories provided in the CCDF Plan Preprint, details on the timeline for implementing the new requirements, and additional resources.10
    • CCDF Statistics: OCC provides CCDF Statistics, including information on the number and characteristics of children and families served, the types of provider settings used, and State/Territory expenditures.11
  • Resources from the Child Care Administrative Data Center (CCADAC): CCADAC, a project run by Child Trends and funded by OPRE, supports the use of administrative data to address policy-relevant early care and education research questions for state child care administrators and their research partners.12 State/Territory leaders and researchers may be interested in analyzing data to understand the effects of changes to requirements for eligibility during periods of job search. Analysis of administrative data is a cost-effective means of assessing the intended and unintended outcomes of policies and administrative procedures. Box 1, with information provided by CCADAC, provides examples of questions that can be answered with administrative data and next steps that States/Territories can take now to capture relevant information in their administrative records.

Box 1. Using Administrative Data to Understand Policy Changes Going Forward

Appendix Table 1. State and Territory Job Search Policies (2014)

 

Notes

 

  1. “States/Territories” is used throughout the brief to refer to the 50 States, the District of Columbia, American Samoa, the Commonwealth of the Northern Mariana Islands, Guam, Puerto Rico, and the Virgin Islands. While not covered in this brief, the CCDF program also provides funding for the Tribes.
  2. For more information about the new child care provisions and the full law, see the Office of Child Care’s CCDF reauthorization resources webpage at http://www.acf.hhs.gov/programs/occ/ccdf-reauthorization.
  3. These policies apply to most families receiving child care subsidies. States/Territories may establish different policies for subgroups of families (including families receiving TANF, families with children in protective services, etc.).
  4. The CCDF Plan serves as a State’s/Territory’s application for funds by providing a description of the program and policies and must be submitted every three years.
  5. The policies described here are the general requirements in each State/Territory. States/Territories often establish different policies for TANF families participating in job search activities.
  6. Isaacs, Julia and Olivia Healy. 2014. “Public Supports When Parents Lose Work.” The Urban Institute.
  7. These figures are for low-income families in general. Only a small percentage of these families receive CCDF subsidies.
  8. The law does include a 16 percent increase in authorized discretionary funds over six years, but this increase must be allocated by Congress each year. For more information about the funding for CCDBG, see the guide to reauthorization prepared by the Center for Law and Social Policy and the National Women’s Law Center at http://www.clasp.org/resources-and-publications/publication-1/ccdbg-guide-for-states-final.pdf.
  9. For more information about the CCDF Policies Database and access to the Database products, see http://www.acf.hhs.gov/programs/opre/research/project/child-care-and-development-fund-ccdf-policies-database-2008-2013 and http://www.urban.org/policy-centers/income-and-benefits-policy-center/projects/ccdf-policies-database.
  10. For more CCDBG reauthorization information from the Office of Child Care, see http://www.acf.hhs.gov/programs/occ/ccdf-reauthorization.
  11. CCDF statistics are available from OCC at http://www.acf.hhs.gov/programs/occ/resource/ccdf-statistics. CCDF expenditure data are available from OCC at http://www.acf.hhs.gov/programs/occ/resource/ccdf-expenditure-data-all-years.
  12. For more resources on working with administrative data from CCADAC, see http://www.researchconnections.org/content/childcare/understand/administrative-data.html.

 

About the Authors

 

Kathryn Stevens is a research associate in the Income and Benefits Policy Center at the Urban Institute. Her work focuses on child care subsidy policies, tax policy, and government programs that serve low-income families. She serves as project manager for the CCDF Policies Database.

 

Sarah Minton is a research associate in the Income and Benefits Policy Center at the Urban Institute. Her research focuses on child care subsidy policies and other government programs that serve low-income families. She serves as co-project director for the CCDF Policies Database.

 

Lorraine Blatt is a research assistant in the Income and Benefits Policy Center at the Urban Institute. She works primarily on child care subsidy policies and education and training initiatives.

 

Acknowledgments

 

This brief was funded by the Office of Planning, Research and Evaluation (OPRE). The authors would like to thank Linda Giannarelli (the Urban Institute) and Kathleen Dwyer (OPRE) for their insight during the drafting of the brief and their review of various drafts. The authors would also like to thank Gina Adams and Monica Rohacek of the Urban Institute for reviewing and providing feedback on the brief, as well as for their ongoing guidance on the project. Particular thanks are owed to the CCADAC team—Kelly Maxwell, Van-Kim Lin, Nicole Forry, and Carlise King—for their insight on using administrative data, for providing the supplemental material included in Box 1 of the brief, and for reviewing the draft brief. Finally, the authors would like to thank Rachel Schumacher (Director of OCC), Dawn Ramsburg (OCC), Minh Le (OCC), Amanda Clincy (OPRE), and Elizabeth Shuey (OPRE) for reviewing the draft brief, and Andrew Williams (OCC) for providing input on the overall plan and policy topics for the brief.

 

The views expressed in this publication do not necessarily reflect the views or policies of the Office of Planning, Research and Evaluation, the Administration for Children and Families, the U.S. Department of Health and Human Services, the Urban Institute, or the Urban Institute’s trustees or funders.

 

Submitted to:
Kathleen Dwyer, Project Officer
Office of Planning, Research and Evaluation
Administration for Children and Families
U.S. Department of Health and Human Services
Contract Number: HHSP23320095654WC

 

Project Director:
Linda Giannarelli
The Urban Institute
2100 M Street NW
Washington, DC 20037

 

This brief is in the public domain. Permission to reproduce is not necessary. Suggested citation: Stevens, Kathryn, Sarah Minton, and Lorraine Blatt (2016). Implications of Child Care and Development Block Grant Reauthorization for State Policies: Changes to Job Search Policies. OPRE Report 2016-21, Washington, DC: Office of Planning, Research and Evaluation, Administration for Children and Families, U.S. Department of Health and Human Services.

 

This report and other reports sponsored by the Office of Planning, Research and Evaluation are available at http://www.acf.hhs.gov/programs/opre/index.html.

Copyright May 2016. OPRE and Urban Institute


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