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The Federal Interagency Day Care Requirements
Pages 151-205

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From page 151...
... In particular, the child-staff ratios for preschool children aged three to five were crucial, since this age group constitutes most of the children receiving nonparental care. Child-staff ratios, although not by any means the only significant aspect of child care touched by the FIDCR, are nonetheless the crux of the politics 151
From page 152...
... Labeled the Widows' Pension Movement, this group lobbied successfully for state financial aid to fatherless families -- fatherless by death, that is. Now paid to care for their own children, a few "deserving poor" were channeled away from day care centers and full-time work.
From page 153...
... Child care outside the home revived, however, with the Work Projects Administration's nursery schools. Designed to provide jobs for unemployed teachers and food and care for poor children, these schools did not survive the Work Projects Administration .2 The second tradition of child care, more central to federal programmatic efforts and in that sense more policy-relevant, is employment-oriented day care.
From page 154...
... Thus, contrary to general belief, the steady influx of women into the labor force was not unassisted in terms of federal subsidies for child care. The employment tradition of federal aid to day care continued through this deduction, which was justified as a necessary work expense .4 The third tradition, that of comprehensive psychological development, originated in the nursery schools of the 1920s -- a unique nonparental care effort.
From page 155...
... The legacy of these traditions to the child care programs of the 1960s was, in a word, problematic. Another lineage of out-of-home child care in the 1960s was government regulation.
From page 156...
... Staff directors were to be trained in a broad range of children's needs, including education, psychology, family relations, health, nutrition, and child development. Ideally, a facility would provide proper nutrition and health training and would conform to safety codes.
From page 157...
... Each group "should have a full-time teacher and assistant." As Children's Bureau standards emphasized earlier, children under 3 were not recommended for day care. The staff ratios recommended were roughly the same, but the recommended group size was one third smaller in the Child Welfare League standards.7 Soon after the publication of these standards the Children's Bureau and Women's Bureau sponsored a day care conference, which noted among other things the continued
From page 158...
... After all, women with children had been entering the labor force in significant numbers for well over a decade -- a fact of which the Women's Bureau consistently reminded Congress. Even under the welfare reform rubric, the day care program managed only to extract $800,000 of its $5 million authorization from the conservative appropriations committees in fiscal 1963.
From page 159...
... _ By default, the states retained regulatory power over the expanding day care industry. The developmental tradition of child care also had its heyday.
From page 160...
... To defuse his critics, Shriver formulated a revision to the Equal Opportunity Act, which promised tighter administrative procedures, expanded OEO's support services for welfare recipients seeking work, and proposed employing welfare mothers in child care centers. His revisions first encountered opposition within the administration.
From page 161...
... Finally, the Senate Labor and Public Welfare Committee sought to bring some administrative order to the plethora of social welfare initiatives by mandating a set of interagency regulations to govern the numerous federal day care programs. From the perspective of OEO, HEW, and the Bureau of the Budget, however, day care regulations were not the issue.
From page 162...
... An agency whose program was designed principally to employ the poor sought day care requirements that minimized costs. An agency that operated a child development and care program pushed for more comprehensive requirements.
From page 163...
... His solution to these problems was to draft a set of requirements that, while formally affirming comprehensive developmental child care, were sufficiently ambiguous in content and intention to comprehend the interests of all panel members. The final version of requirements specified child-staff ratios and group and family day care.
From page 164...
... The developmentalist group wanted child-staff ratios akin to those of Head Start, which were lower than those suggested for day care by the Child Welfare League. The employmentoriented group objected to the costs these ratios entailed.
From page 165...
... The panel conducted no cost studies; costs were irrelevant to ideal standards. They relied on their experience with Head Start and their knowledge of child development.
From page 166...
... In 1971, OCD began writing a new set of day care requirements.t 3 After the FAP proposal, Congress evinced continued interest in out-of-home child care. Among the employment
From page 167...
... He was also sufficiently politic to seek advice during its preparation from all interested parties." 4 In 1971, congressional advocates of comprehensive developmental child care added a $2-billion program in this area to an OEO extension bill. Sponsored chiefly by Senator Walter Mondale and Representative John Brademas, S 2007 proposed comprehensive services for children in day care.
From page 168...
... The legislation cost $1 billion less than the earlier vetoed version and modified the objectionable provisions regarding legal services. There was also an expansion of Head Start, which the administration opposed, intended to offset the loss of the comprehensive child care program.
From page 169...
... In the crucial area of child-staff ratios the requirements increased the child-adult ratios but specified that only care givers, not clerical or janitorial staff, could count in the ratios. Although the 1968 FIDCR mandated lower ratios, it allowed any adult volunteer or older child present in the center to count in that overall ratio.
From page 170...
... commit the federal government to determining directly the nature of child care, (2) raise care in the centers to "approximately" the same quality as that of Head Start, (3)
From page 171...
... From the viewpoint of the Child Welfare League, the Children's Defense Fund, and others, HEW and the administration had entered an insidious conspiracy to undermine the quality of federally funded day care. The revised FIDCR, they believed, eviscerated the impeccable standards of 1968.
From page 172...
... In one respect, the history of Title XX began in 1972. At that time federal welfare funds were distributed in categorical fashion to states under an 80 percent matching formula.
From page 173...
... Their draft bill gave the secretary authority to prescribe maximum permissible child-staff ratios for children over 5 provided that those ratios did not exceed 13:1 for children ages 5-9 and 20:1 for children over 9. The bill also included a request to the secretary to prepare a report on the overall appropriateness of the day care requirements.
From page 174...
... The conference report passed both chambers by voice vote.25 HEW approved of the enrolled bill. HEW Secretary Casper Weinberger wrote Ash that the higher child-staff ratios were "an improvement over our proposal in this ~ Apparently they had overestimated the political regard." _ muscle of the comprehensive care advocates.
From page 175...
... A 1974 HEW audit of day care centers in nine states indicated that three fourths of them were not in compliance with one or more health or safety requirement. problem was staff ratios.
From page 176...
... They responded with calls and letters to Congress. The AFL-CIO and Child Welfare League threatened to sue HEW if the requirements were not enforced.
From page 177...
... The lower child-staff ratios would enlist support from advocates of comprehensive day care. The welfare provisions would attract conservative votes.
From page 178...
... However, the bill also made the employment tax credit refundable to encourage nonprofit centers to hire welfare recipients. This credit, in conjunction with direct federal funding, would have defrayed up to $5,000 of the cost of employing a welfare recipient in a day care center.
From page 179...
... In large part the hierarchy of HEW believed this approach to be the only politically viable one in light of Congress's determination to continue federal enforcement of the day care requirements. It was not that HEW opposed the administration's position that requirements were a state responsibility, but that they recognized the political difficulty of effecting that position.
From page 180...
... 9803. Suspending the staff ratios for 17 months while retaining the additional day care funds, the bill allowed the states and centers to have their carrot while standing more or less still.
From page 181...
... HEW recommended approval. The bill, they observed, suspended staff ratios and was backed by a veto-proof majority.
From page 182...
... Of these 5.2 million children, 1.3 million are cared for by relatives in the relative's home, 960,000 by relatives in the child's home, 620,000 by nonrelatives in the child's home, 1.2 million by nonrelatives in "family" day care facilities, and a little over 1.1 million in centers including day care centers, nurseries, cooperatives, and Head Start.38 Approximately $10 billion is spent on child care annually. Individual payments account for roughly 60 percent, direct federal payments 18 percent, federal tax credit 8 percent, and state and local payments the remaining 14 percent.
From page 183...
... Moreover, states might not raise their subsidy share or, worse, they might revise licensing codes to require staff ratios consistent with those of the FIDCR. The latter move was a more disconcerting possibility to non-FFP proprietary centers for it would increase costs without providing any offset through subsidies.4i The staff ratios, however, do not have the same import for nonprofit centers.
From page 184...
... On the other side of the staffing issue stand the many nonprofit centers, the comprehensive developmentalist advocates, such as the Child Welfare League and the Children's Defense Fund, and the American Federation of Teachers of the AFL-CIO. For reasons already mentioned, many nonprofit centers prefer lower child-staff ratios.
From page 185...
... is the primary standard-setting body for children, a legacy from the Children's Bureau. Like its predecessor, OCD, ACYF does not administer day care funds other than those for Head Start.
From page 186...
... Although they were receptive to changes in staff ratios, the executive staff worried about "mere custodial warehousing of children" and "franchise operations .
From page 187...
... As his staff explained, the criticisms were "probably an inescapable cost to be incurred for the benefit of keeping all major policy choices open to debate in the course of developing the new regulations. "4 Ill feelings toward the appropriateness report were not limited to the child care community.
From page 188...
... In other words, the report recommended that the revised FIDCR be appropriate to child care in Americas Whether it successfully fulfilled its stated purpose of informing the public debate remains to a great extent in the eye of the beholder. TOWARD THE FINAL REGULATIONS Once ASPE had issued the appropriateness report the task of drafting new regulations on day care fell to the Office of Human Development Services, the administering agency.
From page 189...
... Abt's four-year study involved 1,800 preschool children, 1,100 parents, and 120 classroom groups from 57 day care centers in Atlanta, Detroit, and Seattle. The study dealt with three basic questions: (1)
From page 190...
... Abt used a combination of test scores and observations to assess the effects of different staff ratios, group sizes, and care giver qualifications on the child. These measurements included reflection/innovation, cooperation, noninvolvement, aimless wandering, and performance on the Preschool Inventory Peabody Vocabulary tests.s 3 The potential relevance of the Abt study to the FIDCR policy debate was as much a matter of coincidence as deliberation.
From page 191...
... Staff ratios, however, were not unimportant. The Abt study concluded that they were "the most important determinant of difference in costs." In cost-benefit terms the ultimate conclusion became obvious.
From page 192...
... If HEW chose the high-quality option, 72 percent of FFP centers would be in compliance with the recommended staff ratios and 77 percent with the recommended group size. If HEW chose the minimum-quality option (i.e., all centers reaching the average quality of current care)
From page 193...
... It also sat well with APS. Since the study recommended staff ratios higher than those in the 1968 and 1972 requirements, APS's clients -- the states and their day care centers -- would be relatively unaffected by requirements based on these recommendations.
From page 194...
... Generally, the new FIDCR proposed the staff ratios recommended by the Abt study, though a range of options was offered. Neither the states nor the FFP centers desired requirements that might result in punitive sanctions against them.
From page 195...
... To this end they distributed anti-FIDCR postcards to parents who used their child care facilities, newspapers, members of Congress, and HEW. The message was simple: the new FIDCR will close the day care centers or raise costs or both and we oppose them.
From page 196...
... Armed now with White House support, proponents of the stricter FIDCR managed to overcome their opponents' objections based on costs and promote staff ratios as strict as (or stricter than) those recommended in Abt's Policy A option.
From page 197...
... . 9 Federal Interagency Day Care Requirements (HEW Publication #(OHDS)
From page 198...
... , RG 51, NEOB. 38 These statistics are drawn from UNCO's, National Child Care Consumer Study: 1975 (HE W-OCD, 1975)
From page 199...
... , June 21, 1978, File CY-1-3, HEW:OS. Tithe Appropriateness of The Federal Interagency Day Care Requirements (FIDCR)
From page 200...
... 5-10 7. 5-10 10-12 .5 Head Start 1965 -- -- ~~ 4 5 5 ~~ FIDCR 1968 NR NR NR NR 5 7 7 Child Welfare League 1969 NR NR NR NR 6 - 7 .5 7.
From page 201...
... 6 7-8 9 10 11 12 13-14 Objective 10-12.15 10-12 .5 10-12 .5 10-12.5 10-12 .5 10-12 .5 10 10 10 10 10-12.15 10-12.5 10-12.5 10-12.5 10-12.5 10-12.5 __ __ __ 12 13 __ G __ R 10 10 R __ G S 13 16 16 20 20 R 12 16 16 16 16 20 20 S 15 15 15 15 20 20 20 R 15 15 15 15 20 20 20 R 18.8 18.8 18.
From page 202...
... A o Ail Ail r~ al m c' X ,1 s ~C)
From page 204...
... % No. In Own Home by Relative 10-29 hours per week3 245,900 30+ hours per week3 239,900 In Own Home by Nonrelative 20-29 hours per week3 30+ hours per week Relative's Home 10-29 hours per week4 30+ hours per week3 Nonrelative's Home (Family Day Care)
From page 205...
... Kamerman and Alf red J Kahn, Child Care, Family Benef its and Working Parents (1980)


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