Building Futures
Through Education
Public Comments on Maryland’s Child Care Development Fund Plan for FFY 2014-2015
Presented by: Francine K. Hahn, Esq., At-Large Board Member of NAEHCY,
fhahn1229@gmail.com, 443-756-7451 (cell)
The future for a young homeless child is not bright. She is four times more likely to have a
developmental delay, twice as likely to have a learning disability and the effects of toxic stress
exposure can be life-long.i Place this same child in a stable, nurturing environment with access
to stimulating early play and early learning experiences and a different outcome is possible.ii
Homeless families cannot afford quality early childhood experiences for their child without child
care subsidies.
A few revisions in the CCDF Plan will bring down barriers currently faced by homeless families
when trying to access child care. The barriers to child care access faced by homeless families
are above and beyond other families in poverty, including high rates of mobility; little, if any,
income to apply towards child care subsidy co-pays; and challenges accessing the documents
required to enroll in child care. As a result, mothers who have experienced homelessness are
less likely than their housed peers to receive child care subsidies, and more likely to have
employment problems due to lack of child care. And since the only entre to early education for
many infants, toddlers and preschoolers is through subsidized child care, limited access
increases the likelihood that young children who are homeless will enter kindergarten behind
their peers both academically and socially thus ill-equipped for school success.
The numbers are staggering. In America, 1.6 million children are experiencing homelessness
and 42% of these children are between the ages of 0-5 years old. iii In Maryland, our child
homelessness population is 22,686iv and approximately 9,500 of these children are between the
ages of 0-5. Family homelessness is the fastest growing segment of the homeless population
across the country and Maryland is not shielded from this trend.
[Paragraph about your program and barriers homeless families in your community experience
accessing child care.]
1. McKinney-Vento education definition of homelessness be included as an eligible
population and be a priority category.
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The inclusion of the education subtitle of the McKinney-Vento Homeless Assistance Act’sv
definition of homelessness in the CCDF Plan and regulations will bring the Child Care Subsidy
(CCS) program in alignment with other federally funded education programs such as, special
education, child food and nutrition programs, Head Start and public schools.vi Prioritizing
homeless children for CCS services is encouraged by the Dept. of Health and Human Services,
Administration for Children and Families (ACF); it is required for Head Start programs.vii Under
McKinney-Vento, a child is homeless if she lacks a fixed, regular, and adequate nighttime
residence and is living in one of the following situations: sharing the housing of other persons
due to loss of housing, economic hardship, or a similar reason; living in motels, hotels, trailer
parks, or camping grounds due to the lack of alternative accommodations; living in emergency
or transitional shelters; abandoned in hospitals; or awaiting foster care placement.viii Lack of
shelter means that homeless families are forced into temporary, unstable, and sometimes
unsafe living arrangements.
Identifying and serving homeless children and families under the McKinney-Vento education
definition has been done by CCS partners within the [your State’s agencies that have M-V
policies in place] for many years so CCS has blueprints of regulation, policy and procedure to
use as a foundation for its own program. [If helpful, you may list more specifically the
department(s), division(s) & contact person(s)] Collaboration with these partners will
streamline programs that serve many of the same families and more efficiently deliver child
care services to homeless families.
It is recommended that the McKinney-Vento education definition of “homelessness” found at
43 U.S.C.A. § 11434a(2) be added to § 2.5.3 of the CCDF Plan and in [suggest edits to state
regulations, policies].
2. Homeless children be immediately enrolled while awaiting documentation
It is challenging for homeless families to maintain critical documents throughout the family’s
homelessness because belongings are lost during a sudden eviction, fleeing domestic violence,
or stolen at a shelter or when doubled-up with a friend or family member. ACF urges CCDF
programs to “[e]xamine the documentation required to enroll in an ECE program and, where
appropriate, provide “grace periods” to give families sufficient opportunity to gather required
documents…..”ix A grace period to submit documents such as birth certificates and
immunization records is extended to homeless families in Head Start and the public schools.
Adoption of ACF’s policy suggestion will place the CCS program in parity with other programs
who serve the same children, such as Head Start and public schools. Further, ACF encourages
Head Start and CCS to work together to align child care licensing policy and establish a grace
period for documents, including immunization records.x
It is recommended that § 3.1.1 in the CCDF State Plan state that homeless children may be
enrolled in and attend child care programs immediately and a grace period [of ___ days] is
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provided to applicants who are homeless to gather and submit enrollment documents. The CCS
case manager will provide assistance to the family in obtaining documents. In addition,
[suggest edits to state regulations, policies].
3. Parent fees and copayments be waived for homeless families
The cost of securing permanent housing is expensive. The costs include a security deposit, first
month’s rent, moving costs and basic household items. Even if a homeless family is earning
income above the poverty line, money must be saved to rehouse the family as quickly as
possible and not spent on copayments or fees for child care. This recommendation is
consistent with ACF which clearly states there is flexibility in the policy to target a subset of
families living in poverty, such as homeless families.xi
It is recommended that § 2.4.4 of the CCDF State Plan state copayments and fees will be waived
for homeless families. In addition, [suggest edits to state regulations, policies].
4. Case management be individualized to meet the unique needs of homeless families
Homeless families have unique needs compared to other low-income housed families.
Homeless families and children experience traumatic stressxii and the largest cause of family
homelessness is domestic violence. Consequently, homeless children have three times the rate
of emotional and behavioral problems, such as anxiety, depression, sleep problems,
withdrawal, and aggression.xiii Homeless mothers experience depression at 4 to 5 times the
rate of women in the general population.xiv Clearly, homeless families have many more
challenges that require an individualized case management approach.
It is recommended that § 2.2.6 of the CCDF State Plan include a description of how case
management will be individualized to address the unique needs of homeless families for
immediate enrollment, ongoing attendance and continuity of care thereby creating alignment
with other federal programs.
Adoption of the above recommendations will improve homeless families’ access to child care by
prioritizing homeless children for access to child care; allowing for a homeless child to
immediately enroll in care while documentation is obtained; ensuring that co-pay requirements
are not a barrier; and requiring states to describe in their state child care plan how they will
meet the needs of homeless families through individualized case management services.
Without an education, today’s homeless child is all too likely to become tomorrow’s homeless
adult. Without child care, homeless parents find themselves unable to quickly obtain
permanent housing, look for work, maintain employment, focus on the needs of the family
resulting from the trauma of homelessness; thus, keeping their family mired in homelessness.
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i
See, Ellen Bassuk, MD, Christina Murphy, Natalie Thompson Coupe, Rachael R. Kenney & Corey Anne Beach, State
Report Card on Child Homelessness: America’s Youngest Outcast 2010, 10 (2011) (available at
<http://www.homelesschildrenamerica.org/media/NCFH_AmericaOutcast2010_web_032812.pdf).
ii
Id. at 11.
iii
See, America’s Youngest Outcast pp. 86-87 (describes research methodology).
iv
See, America’s Youngest Outcast, 45.
v
See, 42 U.S.C.A. § 11434a(2).
vi
See, 20 U.S.C. 1401, 1411-1419 and 34 CFR Part 300(special education), Pub. L. 108-265 The Child Nutrition and
WIC Reauthorization Act of 2004, § 107 (2004), Improving Head Start for School Readiness Act of 2007, 42 U.S.C.A.
§ 9832(19).
vii
Dept. of Health & Human Servs., Policies and Procedures to Increase Access to ECE Services for Homeless
Children& Families, 1 (January 2013) (available at
https://www.acf.hhs.gov/sites/default/files/ecd/acf_homeless_policies_and_procedures.pdf) (hereinafter “ACF
Memo”).
viii
The entire definition is as follows:
The term “homeless children and youth”—
(A) means individuals who lack a fixed, regular, and adequate nighttime residence …; and
(B) includes—
(i) children and youths who are sharing the housing of other persons due to loss of housing, economic
hardship, or a similar reason; are living in motels, hotels, trailer parks, or camping grounds due to the lack
of alternative accommodations; are living in emergency or transitional shelters; are abandoned in
hospitals; or are awaiting foster care placement;
(ii) children and youths who have a primary nighttime residence that is a public or private place not designed
for or ordinarily used as a regular sleeping accommodation for human beings …
(iii) children and youths who are living in cars, parks, public spaces, abandoned buildings, substandard
housing, bus or train stations, or similar settings; and
(iv) migratory children who qualify as homeless for the purposes of this subtitle because the children are living in
circumstances described in clauses (i) through (iii). 42 U.S.C.A. § 11434a(2).
ix
ACF Memo at 2.
x
Id.
xi
ACF Memo at 4.
xii
See, America’s Youngest Outcast at 10.
xiii
Id. citing, The National Center on Family Homelessness, America’s youngest outcasts: State report card on child
homelessness (2009).
xiv
Id. citing, Knitzer, J., Theberge, S., & Johnson, K., Reducing maternal depression and its impact on young children:
Toward a responsive early childhood policy framework, New York, New York: National Center for Children in
Poverty (2008).
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