BILL ANALYSIS                                                                                                                                                                                                    �




                                                                  AB 2125
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          Date of Hearing:   April 23, 2014

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Joan Buchanan, Chair
                AB 2125 (Ridley-Thomas) - As Amended:  April 10, 2014
           
          SUBJECT  :   Child care: standard reimbursement rates

           SUMMARY  :   Replaces the standard reimbursement rate (SRR) with a  
          reimbursement rate for child development programs to reflect the  
          actual current cost of care in each region per unit of average  
          daily enrollment for a 250-day year.  Specifically,  this bill  :  

          1)Requires the Superintendent of Public Instruction (SPI) to  
            implement a plan that establishes reasonable standards and  
            assigned reimbursement rates through a single reimbursement  
            system which vary with the length of the program year and the  
            hours of service.

          2)Eliminates the SRR at $3,523 per unit of average daily  
            enrollment for a 250-day year, increased by the cost-of-living  
            adjustment granted by the Legislature beginning July 1, 1980,  
            or as adjusted to provide adequate compensation for education  
            and training, and instead establishes a reimbursement rate  
            that reflects the actual current cost of care in each region  
            per unit of average daily enrollment for a 250-day year.  

          3)Strikes provisions that specify the following:

             a)   The plan shall require agencies having an assigned  
               reimbursement rate above the current year SRR to reduce  
               costs on an incremental basis to achieve the SRR. 

             b)   The plan shall provide for adjusting reimbursement on a  
               case-by-case basis, in order to maintain service levels for  
               agencies currently at a rate less than the SRR.  Assigned  
               reimbursement rates shall be increased only on the basis of  
               one or more of the following:

               i)     Loss of program resources from other sources.
               ii)    Need of an agency to pay the same child care rates  
                 as those prevailing in the local community.
               iii)   Increased costs directly attributable to new or  
                 different regulations.
               iv)    Documented increased costs necessary to maintain the  









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                 prior year's level of service and ensure the continuation  
                 of threatened programs.
               v)     Child care agencies funded at the lowest rates shall  
                 be given first priority for increases.

          4)Specifies that the adjustment factors for infants; toddlers;  
            children with exceptional needs; severely disabled children; a  
            child at risk of neglect, abuse, or exploitation; and  
            limited-English-speaking and non-English-speaking children  
            shall apply without regard to whether the programs are at or  
            below the SRR and without regard to whether the reimbursement  
            rate exceeds the adjusted SRR.

          5)Strikes the provision specifying that programs above the SRR  
            may be considered on a case-by-case basis for rate adjustments  
            due to documented increases in insurance costs.

          6)Strikes the provision specifying that in no event shall the  
            assigned reimbursement rate exceed the SRR.

          7)Strikes the provision excluding the schoolage community child  
            care services programs from being adjusted by specified  
            reimbursement factors.  

          8)Adjusts the regional market rate (RMR) ceiling established at  
            the 85th percentile of the 2005 RMR survey for that region to  
            the 85th percentile of the current RMR survey for that region.  
             

           EXISTING LAW :

          1)Establishes eligibility for child care services and child  
            development programs administered by the California Department  
            of Education (CDE) and requires the SPI to adopt rules and  
            regulations on eligibility, enrollment and priority of  
            services needed for implementation (Education Code (EC)  
            Section 8263).

          2)Requires the SPI to implement a plan that establishes  
            reasonable standards and assigned reimbursement rates, which  
            vary with the length of the program year and the hours of  
            service.  Requires the SRR to be $3,523 per unit of average  
            daily enrollment for a 250-day year, increased by a  
            cost-of-living adjustment granted by the Legislature beginning  
            July 1, 1980.  (EC Section 8265)









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          3)Requires the cost of child care services provided for CalWORKs  
            recipients to be governed by the RMR.  Specifies that  
            recipients of child care services shall be allowed to choose  
            the child care services of licensed child care providers or  
            child care providers who are, by law, not required to be  
            licensed, and the cost of that child care shall be reimbursed  
            by counties or agencies that contract with the CDE if the cost  
            is within the RMR.  (EC Section 8357)

          4)Defines "RMR" as care costing no more than 1.5 market standard  
            deviations above the mean cost of care for that region.   
            Establishes the RMR ceilings at the 85th percentile of the  
            2005 RMR survey for that region.  Requires the CDE to contract  
            to conduct and complete a RMR Survey no more frequently than  
            once every two years, consistent with the federal regulations,  
            with the a goal of completion by March 1.  (EC Sections 8357  
            and 8447)  

           FISCAL EFFECT  :  Unknown

           COMMENTS  :  According to supporters, this bill is intended to  
          establish a single reimbursement rate system for child care and  
          development programs and increase payments to providers.  

           Background on child care and development programs  .  The CDE  
          administers a child care and development system, maintaining  
          1,401 service contracts with approximately 758 public and  
          private agencies supporting and providing services to children  
          from birth through 12 years of age. Contractors include school  
          districts, county offices of education, cities, colleges, other  
          public entities, community-based organizations, and private  
          agencies.  In fiscal year (FY) 2013-14, $2.1 billion was  
          provided for child care and development programs from state and  
          federal funds, enrolling an estimated 340,000 children.  This is  
          down from $2.669 billion initially provided in the FY 2010-11  
          budget (prior to midyear trigger cuts) with almost 416,000  
          slots.  According to the Legislative Analyst's Office, overall  
          funding for the child care and development program has decreased  
          by almost $1 billion since 2008-09, with the elimination of  
          110,000 slots.  The Governor's proposed FY 2014-15 budget  
          provides an increase of $66 million over FY 2013-14 funds for a  
          total of $2.2 billion for child care and development programs to  
          provide an estimated 343,000 child care and preschool slots. 










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           Eligibility  .  State and federal subsidized child care is  
          provided through two ways:  1) eligibility for CalWORKs, or 2)  
          based on income and need for child care services.  CalWORKs is a  
          temporary cash aid program for families with children.  The  
          child care program is administered in three stages to help a  
          family transition from immediate, short-term child care needs to  
          stable, long-term child care as a family becomes stable and is  
          no longer reliant on CalWORKs aid.  Subsidized child care  
          services are intended to assist recipients in engaging in work  
          or education/training required for receiving aid.  

          Non-CalWORKs families and former CalWORKs recipients can receive  
          subsidized child care if they meet income eligibility of 70% of  
          state median income ($46,896 for a family of four) or if they  
          are recipients of child protective services and if they can show  
          need for child care services.


           Payment system  .  The state uses two different methodologies for  
          determining the rates for child care and development program  
          payments.

            
           1)RMR  .  The CDE administers a voucher program that enables  
            eligible families to choose their providers, which may be a  
            licensed center, licensed family child care homes, or  
            license-exempt care (e.g., care by a relative).  The voucher  
            program is administered by Alternative Payment Programs (APPs)  
            selected by the CDE.  Child care licensed providers must  
            comply with Title 22 regulations (health and safety standards)  
            developed by the California Department of Social Services and  
            receive reimbursements of up to the 85th percentile of child  
            care rates charged by private providers in the area.  

            The rates are determined by the RMR survey and vary depending  
            on the geographical location of the provider.  The RMR is  
            based on a survey of licensed centers and family child care  
            homes measuring child care rates of similar socioeconomic  
            conditions, rather than geographic proximity, creating ''price  
            profiles" of similar zip codes.  Ceilings are established for  
            each county according to estimates of the 85th percentile of  
            child care rates for groups of centers and family child care  
            homes.  These county market rate ceilings are differentiated  
            by the age of the child (infant/preschool/school age),  
            full-time or part-time care, and frequency of care.  The rate  









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            is intended to enable access to 85 percent of all licensed  
            providers in a county and represents the maximum amount the  
            state will pay for services.  Providers that charge at or  
            below the RMR will receive the actual costs.  If a family  
            chooses a provider that charges above the RMR, the family pays  
            the additional amount.  State and federal law requires the  
            survey to be updated every two years.  However, due to  
            budgetary reasons, the current RMR is based on the 2005  
            survey.     

           2)SRR  .  In addition to Title 22 regulations, child development  
            programs and preschools that contract directly with CDE  
            through the General Child Care, Migrant and Handicapped child  
            care, and California State Preschool Programs must comply with  
            higher standards (teacher qualifications, child development)  
            under Title 5 regulations developed by the CDE and receive the  
            SRR.  The SRR is a specified rate established in statute and  
            adjusted through the budget act.  The current SRR, which was  
            last adjusted in 2007-08, is at $34.38 per day for full-day  
            care (or $8,595 annually) and $21.22 per day per child for  
            part-day (or $3,714 annually).  The monthly rate for full day  
            care for a four-year-old is $716.


          Annual Rates for Subsidized Early Education and Support Services  
          in California
          

                -------------------------------------------------- 
               |Counties    |Standard   |Regional    |Regional    |
               |            |Reimburseme|Market Rate |Market Rate |
               |            |nt Rate<1> |Ceiling     |Ceiling     |





          ---------------------------

          <1> The standard reimbursement rate (SRR) is $34.38 per child  
          day of enrollment (CDE) or $8,595 per annum based on 250 days of  
          operation (Education Code Section 8265 (B) and State Budget Act  
          of 2012, item 6110-194-0001, provision 7). 
















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               |            |           |2005<2>     |2012<3>     |
               |            |           |CURRENT     |            |
               |------------+-----------+------------+------------|
               |Alameda     |     $8,595|    $10,308 |     $14,540|
               |------------+-----------+------------+------------|
               |Humboldt    |     $8,595|     $8,176 |     $10,887|
               |------------+-----------+------------+------------|
               |Kern        |     $8,595|      $8,088|      $8,229|
               |------------+-----------+------------+------------|
               |Los Angeles |     $8,595|      $8,925|     $13,542|
               |------------+-----------+------------+------------|
               |Mendocino   |     $8,595|      $7,908|     $11,001|
               |------------+-----------+------------+------------|
               |Orange      |     $8,595|      $9,984|     $15,071|
               |------------+-----------+------------+------------|
               |Riverside   |     $8,595|      $8,204|     $13,131|
               |------------+-----------+------------+------------|
               |Sacramento  |     $8,595|      $8,231|     $11,563|
               |------------+-----------+------------+------------|
               |San Diego   |     $8,595|      $9,058|     $14,577|
               |------------+-----------+------------+------------|
               |San         |     $8,595|     $11,809|     $14,590|
               |Francisco   |           |            |            |
               |------------+-----------+------------+------------|
               |Sonoma      |     $8,595|      $9,094|     $14,485|
               |------------+-----------+------------+------------|
               |Ventura     |     $8,595|      $9,064|$15,060     |
                -------------------------------------------------- 

               Source:  California Department of Education

             
           The Governor has attempted to reduce RMR and the SRR rates.  The  
          Governor's FY 2012-13 budget proposed to reduce the RMR to the  
          ---------------------------
          <2> Assembly Bill 1497, which was signed into law on June 27,  
          2012, maintains the Regional Market Rate ceilings at the 85th  
          percentile of the 2005 Regional Market Rate Survey and the  
          licensed-exempted child care providers ceilings at 60 percent of  
          the Family Child Care Home ceilings effective July 1, 2012.   
          Number shown represents the maximum reimbursement full-time  
          monthly rate for children aged 2-5 years in child care centers,  
          multiplied by 12 to obtain the annual rate.
          <3> 2012 Regional Market Rate (RMR) Survey of California Child  
          Care Providers. Number shown represents the maximum  
          reimbursement at 85% for full-time monthly rate for children  
          aged 2-5 years in child care centers, multiplied by 12 to obtain  
          the annual rate.








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          50th percentile using the 2009 survey.  The Legislative  
          Analyst's Office (LAO) estimated the proposal to reduce rates by  
          12 to 14 percent, on average.  The FY 2012-13 budget also  
          proposed to reduce the SRR by 10 percent, dropping the per-child  
          rate for full-day services to $30.94 and the preschool rate to  
          $19.10.  The LAO recommended rejection of the reduction.  The  
          budget that was ultimately adopted did not include the  
          reductions.  

           This bill  adjusts both the SRR and the RMR.  The RMR is adjusted  
          by updating the survey used to determine rates.  The current  
          rate based on the 85th percentile of the 2005 RMR survey is  
          updated to the current survey.  For now, the most current is the  
          2012 survey.  The contractor retained by CDE to conduct the 2014  
          survey is in the process of collecting information.  

          The change to the SRR is significant.  The bill proposes to  
          eliminate the rate specified in statute and instead establish a  
          reimbursement rate based on the actual current cost of care in  
          each region.  It is unclear how the current cost of care is  
          calculated.  According to the author's office, the intent of the  
          bill is to base the reimbursement rate on the RMR at the 100th  
          percentile.  Staff recommends an amendment to replace "actual  
          current cost of care" with the RMR at the 100th percentile.  

           Need for adjustment  .  The SRR has been the same since FY  
          2007-08, while the state Legislature has placed greater emphasis  
          on increasing the quality of early childhood and development  
          programs.  The low SRR reimbursement has caused contractors to  
          cease the provision of services to low-income families.   
          According to the LAO, in a report titled, "Restructuring  
          California's Child Care and Development System," the RMR is  
          higher than the SRR in 19 counties.  Consequently, 224 providers  
          have terminated contracts with the CDE over the last few years,  
          typically due to insufficient funding.  The availability and  
          access to quality subsidized early education services are  
          reduced in a community if the CDE is unable to locate another  
          provider to take the slots.  Wages of child care providers are  
          low.  Based on information provided by the CDE, the Employment  
          Development Department reports that during the first quarter of  
          2011, the average wage of those employed by child care centers  
          was $11.64 per hour and $15.23 per hour for preschool teachers.   
              

           How much would the SRR increase  ?  If the SRR were raised to the  









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          RMR at the 85th percentile using the 2012 RMR survey, with the  
          exception of one county, which experiences a minor decrease, the  
          other counties identified in the chart above would receive  
          between a 25 percent to a 75 percent increase.  The increases  
          are higher at 100th percentile.  The RMR survey does not  
          currently measure costs at the 100 percentile.  If this bill is  
          enacted, the RMR survey would have to be updated in order to get  
          the payment levels specified by this bill.  

           Should there be a hold harmless provision  ?  The SRR is higher  
          than the RMR in some areas.  Using the RMR in those areas may  
          cause hardship on those providers.  Staff recommends adding an  
          amendment to continue the current rate for contractors whose  
          rate would be reduced under the new reimbursement system until  
          the new reimbursement rate reaches the most current RMR level  
          for that region.  

           Infant/toddler adjustments  .  Current law authorizes an  
          adjustment increase in the SRR, recognizing that there are  
          higher costs to serve certain populations, including  
          infants/toddlers; children with exceptional needs (0 to 21  
          years); severely disabled children (0 - 21 years); children at  
          risk of neglect, abuse, or exploitation (0 - 14); and  
          limited-English-speaking (2 - kindergarten).  The RMR survey  
          already takes into consideration higher costs for serving  
          infant/toddlers.  As such, it is not necessary to continue an  
          adjustment factor for infants/toddlers.  Staff recommends  
          striking the adjustment factors for infants and toddlers.  

           LAO proposal  .  The LAO recently issued a report recommending a  
          restructure of the child care and development system.  Among  
          other recommendations, the LAO proposes the following:

                 Limit CalWORKs eligibility for child care to 6-8 years,  
               which will increase access to 35,000 more families. There  
               is no data on how long families get child care currently.

                 Provide benefits (except for the State Preschool  
               Programs) through vouchers.  State Preschool will continue  
               as direct contract, but providers would be restricted to  
               only local educational agencies.

                 Require higher developmental standards for 0-3  
               providers.  CDE would be required to develop the standards  
               and monitor the providers to ensure compliance.  









                                                                  AB 2125
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                 Change the fee structure so that they are more uniform  
               by high, medium or low-cost counties based on the 70th  
               percentile of the 2012 RMR survey.  Establish rates for  
               infants, preschool, and school-age for each type of cost  
               counties.  
          

          
                     ----------------------------------------- 
                    |Rate Structure Proposed by the |         |
                    |              LAO              |         |
                    |-------------------------------+---------|
                    |                    2014-15    |Annually |
                    |               Ratea           |         |
                    |                               |$16,104  |
                    |High-Cost Counties             |  10,824 |
                    |Infants             $1,342     |         |
                    |Preschool                902   |7,212    |
                    |School-age               601   |         |
                    |-------------------------------+---------|
                    |Medium-Cost Counties           |         |
                    |Infants             $1,077     |$12,924  |
                    |Preschool               719    |         |
                    |School-age              479    |8,628    |
                    |                               |         |
                    |                               |5,748    |
                    |-------------------------------+---------|
                    |Low-Cost Counties              |         |
                    |Infants             $ 836      |$10,032  |
                    |Preschool              594     |         |
                    |School-age             396     |7,128    |
                    |                               |         |
                    |a Reflects reimbursement per   |4,752    |
                    |month for full-time child care |         |
                    |(based on the 70th percentile  |         |
                    |of the 2012 RMR survey)        |         |
                     ----------------------------------------- 
                    
                    Source:  Legislative Analyst's Office

          The author may wish to consider whether the rate structure  
          proposed by the LAO may be easier for implementation purposes.   
          Under this bill, the CDE would have to broadly structure 58  
          different contracts for the cost differences in each region.   









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          Each contract in each region will also vary according to the age  
          of the children and the amount of time served.  This could  
          increase the CDE's administration duties substantially.  The  
          author may wish to consider the benefits of the LAO's regional  
          rate structure, using the 100th percentile of the most recent  
          survey.  

           Technical amendment  .  This bill updates the 2005 RMR to the  
          "current" RMR survey.   Staff recommends changing "current" to  
          "most recent".  "Current" is used to describe the survey in  
          effect, but the survey currently being used is not the most  
          recent survey.  

           Arguments in support  .  The author states, "This legislation  
          proposes that the base reimbursement level be set to correspond  
          to the latest regional market survey, so that it increases to  
          match the current cost of living in every region of the state.   
          Aligning and increasing these rates, will allow ECE [early  
          childhood education] providers to improve the pay of the ECE  
          workforce, which responded to 8 years of increasing quality  
          standards by attaining higher levels of workforce training and  
          education."

           Prior related legislation  . AB 2286 (Bonilla), held in the  
                               Assembly Appropriations Committee suspense file in 2012,  
          increases the rates for subsidized child care services for  
          infant and toddler care as follows: 1) Increases the adjustment  
          factor for infants 0 to 18 months of age served in a child day  
          care center from 1.7 to 2.3; and 2) Increases the adjustment  
          factor for toddlers who are 18 to 36 months of age served in a  
          child day care center from 1.4 to 1.8.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Child Development Administrators Association
          California Child Care Resource and Referral Network
          Child Care Alliance of Los Angeles
          Northern Director's Group

           Opposition 
           
          None on file
           









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          Analysis Prepared by  :    Sophia Kwong Kim / ED. / (916) 319-2087