Comment to ODJFS and DCY on proposed amendments to SUTQ rules

Family Child Care (FCC) providers and child care centers serve foundational roles in their communities but are once again being asked to provide more for less. The Ohio Department of Children and Youth (DCY) and the Ohio Department of Job and Family Services (ODJFS) have proposed a rule that would change the Step Up to Quality (SUTQ) system from a five-star system to bronze, silver, and gold (a three-tier system). Through this process, one- and two-star providers would be grouped into a new bronze tier, three-star providers would become silver, and four- and five-star providers would become gold.

Ohio child care providers are not fooled and know that this will result in more administrative work and less funding, but parents might be. The proposed collapse to a three-tier system also flattens opportunities to earn higher enhancement rates. That’s why, even apart from the direct loss of revenue from enhancements, taking away quality rating indicators that providers have worked hard to earn will result not only in a loss of morale among providers, but also tangible losses in pay and lost investment in earning a specific SUTQ tier. Providers take pride in their work and contribution to their communities, but this move undercuts that commitment by providers.

Step Up to Quality’s long-established rating system is familiar to families and aligned with best practices under professional child care governing bodies including the National Association for the Education of Young Children, National Association for Family Child Care, and others. Family child care providers display these ratings to reassure families that they are entrusting their child to a top quality provider. By collapsing the five-tier SUTQ program into a nebulous three-tier system, Ohio would lose those quality indicators now clearly mapped out in the profession and knock programs down in their rating that parents see.

In addition to changing the tier system, the new rules increase the burden on providers with no corresponding increase in funding or support. Providers will need to do a needs assessment within thirty days of enrollment and then annually, and they will be required to refer families to services within 30 days. Those providers maintaining gold ratings will have to follow up with families after the referral to determine if needs are being met for services and document these efforts. Under the proposed rule, gold-rated providers will have to plan and host more annual educational trainings, workshops, or events for families. Providers will also be required to do more professional development annually, at a time when finding trainings that meet the SUTQ requirements and the providers’ schedules is already a challenge.

Providers have invested work and resources into earning their Step Up to Quality stars. The state of Ohio has an obligation to do right by their providers and early childhood educators by ensuring that they can care for themselves, their families, and communities.

Lawmakers must add money to Department of Children and Youth (DCY) and Publicly Funded Child Care (PFCC) budgets for higher provider reimbursement rates. Without adequate funding, Ohio’s child care system will remain in crisis with early childhood educators, parents, and kids left to deal with the consequences.

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