RECAP of the December EEC Board Meeting: Revising MA’s Subsidy System Regulations & New Survey Results on the Commonwealth Cares for Children (C3) Operational Grant Program

At Neighborhood Villages, we prioritize keeping up with the policy landscape in the early education and care field, both across the country and in Massachusetts. That includes tuning-in to the monthly meetings of the Massachusetts Board of Early Education and Care (“EEC Board”), to stay apprised of updates and to identify opportunities for how we can work with government and other stakeholders to improve our early education and care system.

This month’s EEC Board meeting highlighted upcoming leadership transitions and provided a preview of the new year:

1. Acting Commissioner Kershaw made opening remarks and provided an End-of-Year Review;

2. Proposed changes to regulations governing the state’s child care subsidy system received an affirmative vote to move to public comment; and 

3. Acting Commissioner Kershaw and her team presented highlights from the recent Commonwealth Cares for Children (C3) survey. 

I. Acting Commissioner Kershaw opened the meeting with updates and provided an End-of-Year review.

The Board meeting, on December 13, 2022, marked the end of Chairwoman Nonie Lesaux’s Board tenure; Lesaux was appointed Chair in 2015 and will be succeeded by Board member Paul Belsito.

In addition to offering words of thanks to outgoing Board members and to outgoing Secretary James Peyser, Acting Commissioner Kershaw noted a few key pieces of information for providers in her opening comments:

• The federal Operation Expanded Testing program, which has distributed COVID tests via Ginkgo Bioworks, will be ending at the end of December 2022. EEC, in partnership with Neighborhood Villages, will continue to provide rapid tests to programs and will continue to offer the Healthline to address questions, through the end of the fiscal year (June of 2023). 

• Providers serving children with subsidies have been given permission to close – without financial penalty – between the week of Christmas and New Year’s. 

• EEC is fleshing out a pilot program to distribute the $10 million allocated in the state budget for the purpose of helping early childhood educators access child care for their own children. EEC is working to ensure the design for the program can be scaled and hope to launch the pilot soon after the new year.

II. Proposed changes to regulations governing the state’s child care subsidy system received an affirmative vote to move to public comment.

At the November meeting of the Board, EEC provided details regarding 41 proposed changes to regulations governing the Massachusetts subsidy system, with particular respect to families seeking access to subsidies. The Acting Commissioner noted that, while traditionally the public comment period is 21 days, EEC is proposing 60 days for this comment period, given the significance of proposed changes and the desire to generate substantial input from stakeholders. The Board voted for preliminary approval of regulatory changes designed to:

• Reduce and eliminate unnecessary and duplicative documentation and reporting requirements that create an undue burden for families.

• Update employment-related definitions and eligibility requirements to reflect the changing nature of work, including more flexibility for hourly wage earners and those working from home.

• Add qualifying service needs for individuals experiencing domestic violence, waive fees for homeless families, and ease and update reporting requirements for individuals with disabilities or participating in treatment for substance abuse.

• Amend the definitions of possible sanctions to clarify the intentional nature of program violations and eliminate the imposition of penalties and loss of assistance where there is no clear intent to defraud.

• Align requirements with associated agencies to streamline processes and reduce administrative burdens.

EEC indicated that they will be working to finalize policies and procedures to accompany these proposed regulatory changes and that, following public comment, they will return to the Board to review that input at the March Board meeting. EEC’s goal is to have these regulatory changes go into effect by July 1, 2023. The Board voted to proceed to the public comment period.

III. Acting Commissioner Kershaw Presented Highlights from the Recent Commonwealth Cares for Children (C3) Survey. 

The Commonwealth Cares for Children (C3) Stabilization Grant Program has funding to continue through part of May 2023 and preliminary survey findings show that the program has positively impacted providers. 

Acting Commissioner Kershaw and her team presented preliminary findings from a recent survey of the Commonwealth Cares for Children (C3) grant recipients. EEC noted that funding from the C3 program:

• Helped to narrow the gap most programs face between their revenue and the cost to operate.

• Helped providers maintain capacity and avoid raising tuition.

• Has been effective in targeting resources to vulnerable parts of the state’s child care system.

• Has provided new insight and data about the early education and care sector and strengthened relationships between EEC and providers.

Some of the key findings from the survey – which launched in September 2022 and yielded 6,010 responses – include:

• 83% of Group and School Age (GSA) providers and 41% of Family Child Care (FCC) providers report that C3 funds have allowed them to increase salaries for existing staff;

• 61% of GSA providers and 50% of FCC providers report that they would have to increase tuition rates if C3 were no longer available;

• 9% of GSA providers and 14% of FCC providers (comprising 751 providers and 15,078 licensed seats) report that they would have to close if C3 funds were no longer available;

• To date, providers have spent almost 60% of C3 funds awarded on: existing payroll and benefits; past costs; and other operational expenses (compared to 24% on new investments);

• 81% of GSA providers and 52% of FCCs report that they would increase educator salaries and increase their own/their assistant’s compensation – respectively – if the C3 grant were extended.

In addition to the impact of the C3 funds, the survey also collected information on provider recipients’ current capacity, staffing, and compensation. The survey revealed that:

• More than one-third of GSA providers are currently unable to serve their full license capacity because they are not fully staffed;

• Among the GSA programs hiring for open educator positions, the average program is hiring for 3.6 positions;

• About one-third of educator positions have turned over in the past year;

• The most common reason programs observed as the reason for educator turnover was that staff left for a position in another sector outside of the licensed early education and care system;

• The most frequently cited recruitment strategy has been to offer more competitive salaries, while the most frequently cited retention strategy has been to increase salaries;

• The median educator hourly pay remains below 50% of Massachusetts’ State Median Income and it is lower in programs that serve more subsidized children;

• About one-quarter of FCC providers report earning between $15,000 and $30,000 per year.

These findings paint a picture of the critical value C3 funding has provided to the Massachusetts early education and care sector. If the state does not take action, funding for C3 is due to expire in mid-May of 2023.