In
order to address the larger child care issues (see Chapter 6) and improve the
licensing function, the Department is entering into a process to reorganize the
licensing and quality functions which may require additional staff.
FINDING
2: Inequitable Workload Distribution Impacts
Primary Mission of Unit
Recommendation: The licensing unit needs to develop appropriate standards for
caseload and workload.
Response: Partially agree.
Licensing activities, travel, meetings, training and mentoring have not been
ignored in workload distribution.
However, without established standards for caseload and workload, it is
difficult to assess the success of current practice. And as indicated in the report, established workloads are
difficult to assess with the amount of turnover the program has experienced.
While
creation of the resource manual was time intensive for licensing staff, it was
developed to address specific issues around licensed child care and to address
provider turnover and retention. The
resource manual will be used in the delivery of provider orientation.
The
LSO report states “One professional organization states that technical support
is not part of the official job description of child care inspectors, and if
carried too far, could detract from their fundamental regulatory mission.” The Department of Family Services
disagrees. The National Association for
Regulatory Administration (NARA) considers provider support services to be an
essential part of licensing. So much
so, that it is included as an entire module by NARA in their Licensing
Curriculum. They state, “For strong and
consistent compliance to occur, the provider himself must understand the rules,
their intent, and ways to meet them. He
must develop the internalized motivation to comply. It follows that licensing staff must be strongly prepared to
offer skillful assistance to licensees and to prospective licensees at each
stage of the licensing process.” NARA
considers technical assistance to be the most common form of provider support
licensing staff can offer.
The
Department is currently researching assessment and auditing procedures of other
states that can be adapted for use to assess current workloads and establish
clear means of workload distribution. Until staff turnover is adequately
addressed, any attempt to implement this recommendation may be undermined by
the need to cover areas of the state where vacancies exist.
Chapter 3 – Management
Information and the Licensing Function
FINDING
3: Without Program-Level Data, the Unit Cannot
Make Strategic Decisions
Recommendation: The licensing unit should develop performance measures and
collect data that gauge program effectiveness.
Response: Agree. The lack of
performance measures and data does make it difficult to identify successes and
deficiencies within the program. Focus has been on staffing, training,
structure and communication systems due to staffing changes and turnover of
staff. Development of performance
measures for the child care licensing program will begin immediately so that
development of the new computer system targeted for completion in February
2002, will include capture of essential data for management of the program.
The
planned inclusion of provider data such as inspection and compliance history
will enable collection and analysis of data to guide development of key
indicators of compliance and streamline the inspection process.
While
information sharing does occur between DFS field staff and licensing field
staff in areas of subsidies and Social Services, the Department continues to
develop linkages between programs and databases.
Chapter 4 – Ensuring
Compliance with Licensing Requirements
FINDING
4: Illegally Operating Providers Undermine
Licensing System
Recommendation: DFS needs to take the lead in developing a workable process for
enforcement of licensure.
Response: Agree. The licensing
program will continue to actively assess enforcement issues. This will include examining current practice
to determine if enforcement can be improved through policy development. The new rules begin to address this issue by
affording new opportunities for licensing staff to work with uncertified
providers more effectively.
Policy
will also include clear reporting of illegally operating providers to
prosecuting attorneys.
The
Department has investigative access to exempt providers who receive subsidy
payments from DFS. This authority,
through the CCDF subsidy program, can be used to ensure that exempt providers
receiving subsidy payments are meeting exemption criteria. Increased human resources will be necessary
to actively investigate and document the operation of uncertified providers.
The
Department will continue to include all stakeholders on a community level to
work toward addressing illegal, uncertified care.
FINDING
5: Inconsistencies mean Children in Licensed
Care May Not Be Uniformly Protected
Recommendation: The licensing unit should develop a policies and procedures
manual.
Response: Agree. The child care
licensing program recognizes and concurs with the importance of developing a
policy and procedures manual. The
Department will proceed immediately.
The manual will be completed by July 1, 2002 as recommended.
Chapter 5 – Other Entities
Regulate Childcare Providers
FINDING
6: Childcare Facilities are Inspected by
Additional Regulatory Entities
Recommendation: The different entities currently involved in inspecting child
care facilities should continue to conduct separate inspections.
Response: Agree. The Department is
coordinating the separate inspections by other agencies involved in the
regulation of child care facilities under the newly adopted licensing
rules. We concur that coordination to
avoid duplication is essential and that ongoing communication between agencies
is necessary to accommodate inspection of all child care facilities. The Department hopes to continue dialogue
with the other agencies to facilitate linkage of data systems.
FINDING
7: Childcare Facilities Are Subject to Local
Regulation
Recommendation: The Legislature should consider options to eliminate barriers to
childcare supply.
Response: Agree. During the
revision of child care licensing rules, attempts were made to engage local
authorities in the dialogue. There is no
doubt that local restrictions impact the availability of childcare and need
attention. The debate over local vs.
state control makes this situation highly controversial.
Through
the new computer system, the Department will begin tracking local regulatory
requirements on providers. The data may
facilitate discussion of the impact of local regulation on availability of
quality child care. Also, the
Department will have an economic impact study conducted to assess variables,
including local regulation, that impact the availability and affordability of
child care.
Chapter 6 – Larger Childcare
Issues
Page
56: “At present, the state lacks a function
dedicated to considering larger childcare issues, one that could establish
policy on how to improve childcare quality, affordability, and availability.”
Response: The Child Care & Development Fund requires expenditures to
improve the quality of child care in Wyoming.
The Child Care program has a Quality Initiatives Committee that assists
the Department in establishing goals and strategies to address these issues. The committee is comprised of members from
other state agencies, child care facilities (both licensed and legally exempt),
parents, employers, Head Start, Developmental Preschools, early childhood
professional organizations and state policy makers. See attached Wyoming Childcare & Development Fund State Plan.
On
a broader level, Governor Geringer established through Executive Order, the
Wyoming Early Childhood Development Council.
This Council serves in a policy recommending capacity for enhancing
early childhood development opportunities for Wyoming’s children. Issues of childcare quality, affordability,
and availability represent a single component of their mission to advocate for
healthy growth and development of Wyoming’s children. Please see the attached for members of the Wyoming Early
Childhood Development Council.
Page
60: “To increase the availability of care, some
states require all providers who receive reimbursement funds to be licensed, an
incentive that may help expand licensed supply.”
Response: 45 CFR § 98.30 requires states to allow parents to enroll the
child with an eligible childcare provider.
Eligible providers include relative care. This requirement would mandate the licensing of all relatives
caring for children. Legally exempt
providers also meet the need for care during non-traditional hours, which few
licensed facilities provide.
The
Department is creating a Childcare Provider Forum to continue dialogue with
these professionals. In addition to
this forum, the Department plans to conduct a visioning process to develop long
term goals and strategies for the Child Care & Development Fund. This process should be completed by January
1, 2002.
Recommendation: The Legislature should consider authorizing a task force to begin
addressing larger childcare issues.
Response: Agree. The Department has
already begun identifying partners and developing plans to conduct a formal
visioning process to address larger childcare issues. Any task force must include representation from the Early
Childhood Development Council.
Quality
projects to address issues surrounding the availability, accessibility and
affordability of child care are currently managed through the Child Care &
Development Fund to meet federal requirements.
The Department is actively involved in projects to improve the quality
and availability of child care.
Currently, the following projects and programs are in place:
·
Increased
training for providers through WestEd Infant training and the statewide
childcare conference.
·
Improved
training evaluation and resources with the Statewide Training and Resource
System (STARS).
·
Statewide
child care resource and referral services (Child Care Finder) to assist parents
in finding childcare and information on what quality child care is and what to
look for. Child Care Finder also
provides resources to providers such as training and a statewide training
calendar.
·
Expansion
of Head Start/Child Care collaborations to increase the availability of full
day, full year programs to address this issue at the community level.
·
An
Infant/Toddler Credential to certify the demonstrate competency of caregivers
for these children. The credential was
created in collaboration with the University of Wyoming and Casper College.
·
The
provider resource manual to provide technical assistance for new
providers. This resource manual was
created in collaboration with the Licensing Program.
The
state plan for the Child Care & Development Fund which was submitted to the
Administration for Children and Families (ACF) for implementation on October 1,
2001 outlined the following quality activities:
·
Partnerships
with local governments, businesses and child care facilities to expand the
availability of care at the local level.
Work to develop these partnerships has begun and will be
prioritized. Campbell and Natrona
counties currently are working to identify partners, access needs and convene
meetings of stakeholders.
·
Comprehensive
consumer education to educate the public about quality child care.
·
Training
grants to providers to improve accessibility to quality training in early
childhood.
·
Statewide
delivery of the Mother Goose Asks “Why” program. This program will be delivered in
partnership with the Wyoming State Library to address literacy and the
importance of reading in early childhood programs.
·
Implementation
of a career ladder and professional development system for early childhood
professionals. This system will provide
a vehicle to address compensation and retention issues in the early childhood
profession.
Sincerely,
Susan E. Lehman
Director
cc: Barbara Rogers
Dan Stackis
Les Pozsgi
Glennda Lacey
Sue Bacon
