How State-level Child Care Development Fund Policies May Shape Access and Utilization among Hispanic Families
Publication number: 2019-3
Author(s): Lisa Gennetian; Julia L. Mendez; Zoelene Hill
Publication date: Jan 2019
Doc type: Brief
The Child Care and Development Fund (CCDF)a is a federal and state partnership that provides financial assistance to low-income families to obtain child care in order to support work or attend training or education programs. A portion of CCDF funds are also set aside to support and improve the quality of child care.1,2 CCDF helps fund child care for a monthly average of 1.4 million children under age 13.3 Use of the program among Hispanicb families, however, remains relatively low. The GAO estimates that only 20 percent of the population served by CCDF is Hispanic,c although Hispanic children make up an estimated 35 percent of the eligible population.4
This research brief draws on a newly developed framework to understand how state policy context may contribute to racial/ethnic disparities in the use of CCDF subsidies—especially the low use by eligible Hispanic families. The research findings featured in this brief stem from an exploratory analysis of state-level variation in policy and practice that may shape access to and utilization of CCDF subsidies among Hispanic families.d Specifically, we considered state-level variation in the following policy/practice dimensions that are particularly salient for Hispanic families: eligibility requirements around English as a Second Language (ESL) classes and work hours; household and work documentation requirements; prioritization of Temporary Assistance for Needy Family (TANF) recipients; and the availability of program information and/or application online in Spanish.
We focused our analysis on the 13 statese that are home to over 80 percent of all Hispanic children living in low-income households in the United States (households with income under 200 percent of the federal poverty levelf). To better understand the varying demographics within Hispanic families, we also conducted a complementary review of CCDF policies and practices by the proportion of the Hispanic population in the 13 states that is foreign-born (as citizenship status may affect real or perceived eligibility), and whether the state is host to an emerging or established Hispanic population (as states with established Hispanic communities may be more responsive to eligible Hispanic families).
As of July 2018, the 13 reviewed states show considerable variation in state-level policies and practices related to CCDF across the four domains examined: eligibility requirements, household and work documentation requirements, prioritization of TANF recipients, and availability of program information online in Spanish.
- Six of the 13 states approve ESL classes for program eligibility. If these classes are accessible to Latino parents with limited English proficiency and count for program eligibility, they may help Hispanic families—especially recent immigrants—access and use CCDF.
- Seven states have requirements for minimum weekly work hours that may impose a higher burden on Hispanic families, who are more likely than their peers to work informal or seasonal jobs.5 Two of these seven states have work hour requirements for two-parent households that may also place a higher burden on Hispanic families, who are more likely to have two resident parents.6
- Seven of the 13 states have documentation requirements for household members. All 12 states or local entities within states that make CCDF applications available online also request Social Security numbers (SSNs) on the forms for at least some household members. Seven of the 12 explicitly specify SSN documentation as optional. Requesting SSNs without explanation, or lacking specificity about the optional status of this request, may impose a burden on Hispanic parents who have fears about revealing their own, or a household member’s, immigration or citizenship status.
- Almost all states, except California, give TANF-affiliated families priority in their distribution of CCDF funding. This may impose barriers to CCDF-eligible Hispanic families for two reasons. First, TANF tends to have more stringent eligibility and documentation requirements. Second, many other services and programs use one gateway portal for eligibility and rely on TANF eligibility and documentation.
- Six states do not provide their application online in Spanish, and three do not provide program information online in Spanish.
In examining states by selected characteristics of their Hispanic population, we find that:
- States with a lower proportion of foreign-born Hispanics (under 25 percent) are more likely to have policies that facilitate access to CCDF subsidies than states with higher proportions.
- CCDF state policies that can facilitate or limit Hispanic families’ access to CCDF subsidies differ little by whether the state is home to an emerging or established Hispanic population.
A Theoretical Framework: How Policy and Practice Can Shape CCDF Utilization
A combination of individual-, household-, and community-level factors shape whether families use nonparental child care and, if so, which type they use.7-9 Program policies and administrative practices also influence the use and choice of child care, particularly subsidized child care. Because many social service programs operate on a tight budget, states employ strategies to ration or prioritize their services or benefits. These strategies may affect who gains access to the program and who is excluded. This process, called “administrative exclusion,” provides a useful framework to examine how the costs imposed by a program’s policies and administrative practices may limit access for some families while facilitating it for others.10
In the administrative exclusion framework, barriers (or costs) exist—or are created when families seek access to programs—that influence the actual experience of attempting to access or use a program’s services.11 These barriers include learning costs (a lack of knowledge of a program and a lack of information about personal eligibility), psychological costs (stigma or negative social perceptions), and compliance factors (burden on the applicant to produce documentation).
This framework also details how barriers or costs might differ for eligible families by racial/ethnic group. English language barriers, lack of knowledge about programs, and the real and perceived risks of interacting with government programs as noncitizens may shape the likelihood that eligible Hispanic parents will apply for and receive CCDF subsidies more so than for eligible non-Hispanic parents. This is because Hispanic families are more likely than some of their income-eligible peers to not be English proficient or to be residing with a non-U.S. citizen (as two examples). Hill, Gennetian, and Mendez (2018) provide a more detailed description of this theoretical framework and its complementary expansion to existing models (e.g., Weber, 2011).12,13
Data Sources and Definitions
We used three sources of publicly available information for our review of state CCDF policies and practices. The CCDF Policies Database14 provided a general overview of state-level CCDF eligibility policies. Publicly available CCDF grantee state plans for federal fiscal years 2016–2018, submitted by state lead agencies to the ACF Office of Child Care, provided detailed information about the policy dimensions under consideration.15 We relied on the information from CCDF grantee state policy manuals if it conflicted with information documented in the CCDF Policies Database. The state plans were submitted in March 2016 and may reflect state progress in implementing changes to federal policies included in the 2014 reauthorization of the Child Care and Development Block Grant (CCDBG) Act. The FY 2016–2018 CCDF state plans were approved prior to the publication of the CCDF final rule in September 2016; therefore, states completed the plans based on their reasonable interpretation of the law, although not all details may be available in public documents.g Finally, from winter 2017 to spring 2018, we performed a qualitative review of the online applicant experience to examine how policies are enacted in practice and communicated to potential CCDF applicants. Specifically, we accessed the lead agency website for each state or local administrating office to locate information about the state subsidy program and application forms, and to determine the ease of Spanish translation availability.
Eligibility. If a state policy manual affirmatively indicated that participation in ESL is an acceptable form of program eligibility that contributes to minimum hours requirements, then the measure was coded as ‘yes’; otherwise, it was coded as ‘no.’ If state policy manuals did not specify a required minimum number of weekly work hours, this situation was coded as ‘no minimum.’ Otherwise, we coded the information on the minimum hours specified in the policy manual and, as appropriate, separately for single- versus two-parent households.
Household and work documentation requirements. State policy manuals vary by the types of documentation acceptable to verify household membership, including birth certificates, baptismal records, census records, tax records, marriage records, divorce or death certificates, Social Security records, Veterans Administration records, medical or school records, and statements from a landlord. State manuals that require any type of documentation verification of household members were coded as ‘yes,’ while states that do not require any documentation of household members were coded as ‘no.’ Federal policy does not require families to provide SSNs in order to receive assistanceh; however, states may elect to (voluntarily) ask applicants for SSNs for data merging or other reasons. States with application forms that request the SSN of the applicant or any household member(s) were coded as ‘yes’ (ACF, 2000).16 States with applications that explicitly describe the provision of the SSN as optional were also coded as ‘yes (optional)’; states with applications that do not ask for the SSN are coded as ‘no.’ Four states (California, North Carolina, New York, and Texas) have a decentralized CCDF application system, and local entities in these states have the authority to use different application forms.i If an application form of any one local entity requests an SSN per the criteria above, then the state was coded as ‘yes.’
States may also vary in the types and number of forms of documentation acceptable to verify weekly work hours, including pay stubs, signed letters from employers, work schedules, income tax forms, and CCDF administrators’ review of online employment verification systems or direct contact with employers. If a state policy manual specifies that verification of weekly work hours is required, then it was coded as ‘yes.’
Prioritization. State manuals that indicate prioritization of CCDF receipt for TANF recipient families were coded as ‘yes’; otherwise, they were coded as ‘no.’
Spanish-language availability. We reviewed the websites of state or local administrating agencies to determine (1) whether program information was available in Spanish and (2) whether the CCDF application form was available in Spanish. States whose CCDF application is posted online in Spanish were coded as ‘yes’; otherwise, they were coded as ‘no.’ In four of the 13 states, local entities may have different application forms than the state. If all counties have an application posted online in Spanish, the state was coded as ‘yes’; otherwise, it was coded as ‘no.’ States that provide an online link to Spanish translation or an equivalent document in Spanish with program information were coded ‘yes’; otherwise, states were coded as ‘no.’
ResultsView Table 1
Of the policy dimensions reviewed, most of the 13 states had policies or practices that may impose burdens on Hispanic families and likely create barriers to access. However, many also had policies that may facilitate access for Hispanic families (see Table 1).
Eligibility. For six of the 13 states (Arizona, Colorado, New Mexico, New York, Pennsylvania, and Washington), the policy manuals specify that ESL participation is acceptable for CCDF eligibility. Policy manuals for seven states (Florida, Georgia, New Jersey, New Mexico, Pennsylvania, Texas, and Washington) specify that at least one parent must work a minimum number of hours per week—ranging from five to 30—for the family to be eligible for the program. In two states, the policy manuals specify minimum weekly work hours for two-parent households: In Florida, each parent must work 20 hours per week, and in Texas, each parent must work 25 hours per week. This requirement may present unique conflicts for low-income Hispanic families, who overall tend to have high rates of employment, but who also report limited notification of work schedules and high rates of nonstandard hours of employment.6,17 Nonstandard schedules, especially those with unpredictable hours and limited worker input, can reduce the likelihood that parents can easily document eligibility and may limit parents’ ability to find available child care that meets their needs.
Household and work documentation requirements. The policy manuals of all 13 states require some type of verification of work hours, even in states with no minimum weekly hour requirement. The policy manuals of eight states (California, Florida, Illinois, New Jersey, New Mexico, New York, Pennsylvania, and Washington) specify that some type of documentation is required to verify household membership. The CCDF online application forms in all states, or the local administrating entities within states (with the exception of Florida), request the SSN for the applicant or household members. In only seven states is the provision of SSN explicitly noted on the application as optional.
Prioritization. The policy manuals of nearly all of the 13 states (with the exception of California) identify TANF-involved families as a population that has priority for receiving CCDF subsidies.
Spanish language availability. CCDF administrating agencies in seven states (Arizona, Colorado, Illinois, New Jersey, New Mexico, Pennsylvania, and Washington) provide the CCDF application form online in Spanish. In 10 states (Arizona, California, Colorado, Florida, Illinois, New Jersey, New Mexico, New York, Texas, and Washington), the administrating agencies provide program information in multiple languages, including Spanish.
Variation in CCDF policies and practices by state-level demographics
The U.S. Hispanic population is heterogeneous across several characteristics. We assessed whether patterns in the reviewed CCDF state policies and practices in the 13 states varied by the proportion of the state’s Hispanic population that is foreign-born, and whether the state is host to an emerging or established Hispanic population.
Proportion of the Hispanic population that is foreign-born. In three states (New Mexico, Colorado, and Pennsylvania), the proportion of Hispanics who are foreign born is low (i.e., less than 25 percent), at 17 percent, 24 percent, and 23 percent, respectively. In the other 10 states, the proportion of Hispanics who are foreign born is over 28 percent, with the highest in Florida at 48 percent.
- ESL is approved as an eligible CCDF activity in the three states in which less than 25 percent of the Hispanic population is foreign born; ESL is not approved in the seven of the 10 states with a higher proportion of foreign-born Hispanics.
- Four of the 10 states with a high foreign-born Hispanic population request some type of verification of at least some household members, compared to one in three states with a low foreign-born Hispanic population.
- The CCDF application in Spanish is commonly available in the low foreign-born Hispanic states, while less than half of the 10 states with a high foreign-born Hispanic population provide the application in Spanish.
Emerging or established Hispanic population. New or emerging communities describe communities that have experienced an influx of Hispanics since the 1990s, as compared to communities with more established Hispanic populations. In some cases, emerging communities can also occur within large cities that have established Hispanic populations. For the purposes of this brief, we distinguish between the five states that are home to emerging populations (Colorado, Georgia, North Carolina, Pennsylvania, and Washington) and those that are more established (Arizona, California, Florida, Illinois, New Jersey, New Mexico, New York, and Texas).18-20
- In the domain of CCDF eligibility, three of the eight states with established Hispanic populations specify ESL as an approved activity for eligibility, compared to three of the five states with emerging Hispanic populations.
- Six of eight states with established Hispanic populations require some type of household verification, only slightly higher proportionally than the two of five states with emerging Hispanic populations.
- For online communication of program information, all eight states with established Hispanic populations provide CCDF program information in Spanish, compared to two of five states with emerging Hispanic populations.
Discussion and Implications
Public investments in the Child Care and Development Fund (CCDF) aim to make nonparental care for eligible working families more affordable, and in nonparental care settings that support children’s development. The program itself and the population it serves have changed over time, as Hispanic families make up a growing proportion of low-income working families. However, eligible Hispanic families use child care subsidies at lower rates than their peers.4 Lower use of social assistance generally—and subsidized early care and education more specifically—have conventionally been attributed to differences in social norms and familial support (e.g., a preference for child care by family members). This brief has described how policy and practice might also contribute to differences in CCDF use by race or ethnicity.
States seek to be responsive to the needs of their populations. However, they also face a variety of budgetary and political tradeoffs in determining how policies are carried out, and how quickly. Notably, states’ racial or ethnic demographic composition can often evolve more quickly than policy change, which may disproportionately hinder access to services for some income-eligible populations.
The findings in this brief suggest that policymakers’ review of certain policies and administrative practices for CCDF (and related social services) might uncover factors that (perhaps inadvertently) create barriers for eligible Hispanic families’ access to CCDF benefits. This knowledge can be used to inform adjustments to policy or practice. In states where Hispanics are underserved by CCDF, these changes could include revising applications to remove certain documentation requirements, offering clearer explanations or alternative options for voluntarily reporting SSNs, translating existing program websites into Spanish (and other languages), and providing applications in Spanish. States may also deploy alternative options for Hispanic (and other) families with low literacy to complete CCDF applications by phone, or to have information voice-translated online.21 Notably, it is not just Hispanic families that may be disproportionately impacted by policies and practices, although these families are the focus of this brief. Any group characterized by a high proportion of immigrants or limited English language proficiency, for example, may also be impacted.
The findings might also inform implementation of the reauthorized Child Care and Development Block Grant (CCDBG) Act. At the last reauthorization in 2014, sweeping statutory changes were made to CCDF in response to 1) research showing the impact of stable, high-quality care on child development, and 2) the challenges that CCDF programs face in subsidizing stable, high-quality care. Enacted changes for some states included longer eligibility periods—for example, from 3 to 6 months, or up to 12 months, as well as continued provision of assistance to families that may have lost jobs or left training or education programs. These changes reduce the redetermination and reporting burden on parents, and support stability for children in child care. Policies may not, however, be neutral across important characteristics that are highly associated with race and ethnicity. Our hope is that this brief stimulates a deeper investigation into whether the implementation and practice of state-level policies may disrupt or support use of CCDF subsidies, even in the context of limited government resources.
a CCDF consists of two separate funding streams: 1) Discretionary funding authorized by the Child Care and Development Block Grant (CCDBG) Act, subject to annual appropriation; and 2) an entitlement portion of Mandatory and Matching funds made available under Section 418 of the Social Security Act.
b We use “Hispanic” and “Latino” interchangeably throughout the brief. Consistent with the U.S. Census definition, this includes individuals having origins in Mexico, Puerto Rico, and Cuba, as well as other “Hispanic, Latino, or Spanish” origins.
c Note that the OCC estimate is 23 percent, as of 2016, according to https://www.acf.hhs.gov/occ/resource/y-2016-preliminary-data-table-12.
d This brief draws on Hill, Z., L. Gennetian, & J. Mendez (2018). A descriptive profile of state Child Care and Development Fund policies in states with high populations of low income Hispanic children. Early Childhood Research Quarterly. https://www.sciencedirect.com/science/article/pii/S0885200618301182
e The 13 states are Arizona, California, Colorado, Florida, Georgia, Illinois, New Jersey, New York, New Mexico, North Carolina, Pennsylvania, Texas, and Washington.
f The Annie E. Casey Foundation. (2016). KIDS COUNT data center. Retrieved from: https://datacenter.kidscount.org/
g The state plans for 2019–2021 should reflect policy based on the final rule, which might require policy changes in states.
h Administration on Children, Youth and Families, U.S. Department of Health and Human Services. (2000). Clarifying Policy Regarding the Use of Social Security Numbers Under the CCDF and Privacy Act of 1974. Downloaded August 28, 2018: https://www.acf.hhs.gov/occ/resource/pi-cc-00-04
i We describe a decentralized application system as distinct from more general decentralized CCDF administrative authority—i.e., some states with county or related local CCDF administration may not have a decentralized application system.
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