7 comments
U-LAUNCH: Childhood Development Homes is a Virginia Licensed Home-Based Child Care System operating pursuant to Chapter 14.1 of Title 22.1 of the Code of Virginia and the Virginia Administrative Code. As a licensed system that approves, monitors, and provides centralized administrative services to its approved member homes, U-LAUNCH has direct operational experience implementing the Virginia Child Care Subsidy Program within the licensed system framework. These comments are submitted to promote consistency between the proposed Child Care Subsidy Program Guidance Manual and the existing statutory and regulatory framework governing Licensed Home-Based Child Care Systems.
U-LAUNCH: Childhood Development Homes, a Virginia Licensed Home-Based Child Care System (formerly referred to in the Virginia Administrative Code as a Licensed Family Day System), respectfully requests that the proposed Child Care Subsidy Program Guidance Manual expressly address the role of Licensed Home-Based Child Care Systems in administering Child Care Subsidy Program functions on behalf of their approved member homes.
Virginia's regulatory framework recognizes that a licensed system is more than a collection of independently operating home-based child care providers. Under 8VAC20-770-10, the current regulations define a Family Day System as an entity that approves family day homes as members of its system, refers children to available homes, and, through contractual arrangement, may provide central administrative functions, including, but not limited to, training, technical assistance, consultation, inspection, supervision, monitoring, evaluation, and referrals to health and social services. The use of the phrase "including, but not limited to" demonstrates that the listed administrative functions are illustrative rather than exhaustive.
The same regulation defines an "agent" as a person empowered to act on behalf of an association, partnership, limited liability company, business trust, public agency, or corporation in matters relating to a child day program or Family Day System.
Additionally, the Minimum Standards for Licensed Family Day Systems (8VAC20-810) recognize centralized fiscal administration by requiring licensed systems to maintain financial records, a written schedule of fees charged for services, and a written schedule of payments to member homes specifying the amount, conditions, and frequency of payment. These provisions recognize that licensed systems are intended to provide centralized administrative and financial services to their approved member homes.
Collectively, these regulations establish a framework under which a licensed system may provide centralized administrative and financial functions through written contractual agreements with its approved member homes. However, the proposed Child Care Subsidy Program Guidance Manual does not explain how this existing regulatory authority is intended to operate within the Child Care Subsidy Program.
As a result, Licensed Home-Based Child Care Systems have encountered significant implementation challenges. Although approved member homes may authorize their licensed system through written agreement to provide enrollment management, billing, parent communication, attendance support, compliance assistance, document management, accounting, fee collection, and payment administration, the current subsidy process treats each approved member home as though it operates independently of the licensed system's recognized administrative structure.
Providing guidance on this issue would promote consistency between the Child Care Subsidy Program Guidance Manual and the existing Virginia Administrative Code while supporting the efficient administration of services for families, providers, and local departments of social services.
Accordingly, U-LAUNCH: Childhood Development Homes respectfully requests that the final Guidance Manual include a subsection clarifying the following:
The approved member home may elect to remain the child care provider of record or may designate its legally formed business entity as the provider of record for participation in the Child Care Subsidy Program, consistent with the options available to licensed child day centers. In either case, the provider of record shall remain responsible for compliance with subsidy program requirements, licensing or approval requirements, tax reporting, attendance verification, and program integrity.
A Licensed Home-Based Child Care System (formerly referred to in the Virginia Administrative Code as a Licensed Family Day System) may serve as the authorized administrative agent for an approved member home or its designated business entity pursuant to a written agreement.
When authorized in writing by the provider of record, the licensed system may submit and receive subsidy-related applications, records, notices, authorizations, attendance inquiries, payment information, and other program correspondence on behalf of the provider.
Consistent with the authority recognized under 8VAC20-770 and 8VAC20-810, the licensed system may provide centralized enrollment administration, billing, accounting, fee collection, payment reconciliation, administrative support, and payment-distribution services pursuant to written contractual agreements with its approved member homes.
The provider of record and the licensed system shall maintain complete and auditable records identifying the gross subsidy payment, any authorized contractual administrative fee, and the net amount distributed to the approved member home.
Designation of a licensed system as an administrative agent shall not relieve the provider of record of responsibility for compliance with all applicable Child Care Subsidy Program requirements, licensing or approval requirements, attendance verification, health and safety standards, background check requirements, fraud prevention requirements, or other program integrity obligations.
If the Virginia Department of Education determines that any portion of the administrative-agent functions described above is prohibited by state or federal law, U-LAUNCH: Childhood Development Homes respectfully requests that the final Guidance Manual identify the specific statutory, regulatory, or federal funding authority establishing that limitation.
In the absence of such authority, the final Guidance Manual should recognize and provide guidance on the existing administrative and contractual authority granted to Licensed Home-Based Child Care Systems under 8VAC20-770 and 8VAC20-810, thereby promoting consistent implementation of Virginia law, improving administrative efficiency, reducing confusion among providers and local departments, and recognizing the centralized administrative role that Licensed Home-Based Child Care Systems were established to perform under Virginia's regulatory framework.
Owner, Kesha's Care LLC
Former Approved Childhood Development Home
U-LAUNCH: Childhood Development Homes
I appreciate the opportunity to comment on the proposed Child Care Subsidy Program Guidance Manual.
I was an Approved Childhood Development Home operating within U-LAUNCH: Childhood Development Homes, a Virginia Licensed Home-Based Child Care System. I respectfully request that the Department clarify the administrative role of Licensed Home-Based Child Care Systems within the Child Care Subsidy Program.
When I decided to become a Child Care Subsidy provider, I worked with U-LAUNCH, which was authorized to assist me with the administrative aspects of the enrollment process. As a new provider, I relied on the licensed system to help me navigate the requirements, communicate with the Department, and prepare the necessary documentation.
Unfortunately, the enrollment process took longer than I anticipated. During that time, a family that had been waiting to enroll their child in my program was unable to continue waiting and ultimately secured child care elsewhere. As a new provider, losing that enrollment opportunity had a significant impact on my ability to launch my business successfully.
Ultimately, I made the difficult decision not to continue operating as an Approved Childhood Development Home. While there were several factors involved in my decision, my experience highlighted the importance of a clear and efficient administrative process for new providers seeking to participate in the Child Care Subsidy Program.
I believe the Guidance Manual should clearly explain the role of Licensed Home-Based Child Care Systems in assisting approved member homes with subsidy enrollment and administration. These systems were established to provide centralized administrative support, and clear guidance would help reduce confusion, improve communication, and allow new providers to begin serving families more efficiently.
I respectfully request that the Department revise the Guidance Manual to clarify:
I support efforts to make the Child Care Subsidy Program more accessible and efficient for both providers and families. Clear guidance regarding the role of Licensed Home-Based Child Care Systems would benefit new providers, reduce administrative uncertainty, and help families access child care more quickly.
Thank you for considering my comments.
Respectfully submitted,
Waukesha Walker
Owner, Kesha's Care LLC
Former Approved Childhood Development Home
U-LAUNCH: Childhood Development Homes
I am submitting these comments to share my experience with the Child Care Subsidy Program and to offer recommendations that I hope will improve the process for future providers.
I previously operated as an Approved Childhood Development Home within U-LAUNCH: Childhood Development Homes, a Virginia Licensed Home-Based Child Care System. My goal was to become a Child Care Subsidy provider so that I could expand my business while providing quality child care to families who rely on subsidy assistance.
Although I was approved to participate in the Child Care Subsidy Program, I soon discovered that approval was only one step in the process. I experienced challenges obtaining the information and access needed to begin participating in the program. As a new provider, it was often unclear what steps remained, who I should contact for assistance, and when I would be able to begin serving subsidy families.
Fortunately, I had the support of U-LAUNCH to help me communicate with the appropriate offices, understand the process, and follow up on outstanding administrative matters. Without that support, navigating the onboarding process would have been much more difficult. My experience demonstrated the important role that Licensed Home-Based Child Care Systems play in helping new providers successfully enter the Child Care Subsidy Program.
I also believe my experience highlighted an opportunity for improvement. The Guidance Manual does not clearly explain how Licensed Home-Based Child Care Systems may assist their approved member homes during provider enrollment and onboarding. Greater clarity would help reduce confusion, improve communication, and create a more efficient process for both providers and the Department.
Although I am no longer an Approved Childhood Development Home, I hope my experience can help improve the process for those who choose to participate in the future.
I respectfully encourage the Department to consider the following:
Virginia continues to need qualified child care providers. Creating a clearer and more efficient onboarding process will help providers begin serving families sooner while strengthening access to child care across the Commonwealth.
Thank you for considering my comments.
Clarifying the Administrative Role of Licensed Home-Based Child Care Systems in the Child Care Subsidy Program
I am submitting this comment based on my experience as the Founder and Director of Operations of U-LAUNCH: Childhood Development Homes, a Virginia Licensed Home-Based Child Care System. My comments are not based on my experience as a child care provider, but rather on my responsibility for administering one of only two licensed home-based child care systems in the Commonwealth of Virginia and assisting approved member homes in navigating the Child Care Subsidy Program.
I appreciate the Department’s efforts to revise the Child Care Subsidy Program Guidance Manual to improve clarity, update administrative processes, and address gaps in existing guidance. Based on my experience administering a licensed home-based child care system, I believe there remains an important opportunity to clarify how Licensed Home-Based Child Care Systems interact with the Child Care Subsidy Program.
Licensed Home-Based Child Care Systems are established under Article 3 of Chapter 14.1 of Title 22.1 of the Code of Virginia (§§ 22.1-289.010 through 22.1-289.019) and are regulated by the Standards for Licensed Home-Based Child Care Systems (8VAC20-810). Pursuant to 8VAC20-810-40, licensed systems are responsible for approving homes, monitoring compliance, providing technical assistance, maintaining records, and performing ongoing administrative oversight of approved member homes. These responsibilities distinguish licensed systems from individual child care providers by establishing them as centralized administrative entities within Virginia’s early childhood system.
As Director of Operations, one of my primary responsibilities is carrying out these statutory and regulatory duties while assisting approved member homes through the administrative requirements of the Child Care Subsidy Program. In performing those responsibilities, I encountered significant administrative challenges because the Guidance Manual does not clearly define the role of a Licensed Home-Based Child Care System within the subsidy program. Although Virginia law and regulations recognize licensed systems as centralized administrative entities, the Guidance Manual provides little direction regarding how licensed systems may communicate with the Department, assist approved member homes with provider enrollment and onboarding, perform administrative functions on behalf of approved member homes, or participate in payment administration when authorized by contract.
As a result, I frequently had to identify the appropriate Department contacts, seek clarification regarding administrative procedures, coordinate communications between approved member homes and the Department, and navigate processes that were not clearly addressed in the Guidance Manual. These uncertainties created unnecessary administrative burdens for both the licensed system and the providers we support, delayed provider onboarding, and, in some cases, delayed families’ access to child care services.
Because the stated purpose of this revision is to clarify expectations, improve administrative processes, and address gaps in existing guidance, I respectfully encourage the Department to further clarify the role of Licensed Home-Based Child Care Systems within the Child Care Subsidy Program. Specifically, I recommend that the Guidance Manual:
Clarifying these areas would not create new authority for Licensed Home-Based Child Care Systems. Rather, it would provide guidance for implementing responsibilities that already exist under Article 3 of Chapter 14.1 of Title 22.1 of the Code of Virginia and 8VAC20-810. Clear guidance would promote consistent statewide implementation, improve administrative efficiency, reduce unnecessary delays and confusion for providers and Department staff, and strengthen Virginia’s ability to expand access to quality home-based child care through its licensed system model.
I appreciate the Department’s commitment to strengthening the Child Care Subsidy Program and respectfully request that these recommendations be considered as part of the final Guidance Manual. Thank you for the opportunity to submit these comments.
Respectfully submitted,
Nicole Ahmad, M.S.
Founder & Director of Operations
U-LAUNCH: Childhood Development Homes
Virginia Licensed Home-Based Child Care System
Recognizing the Role of Licensed Home-Based Child Care Systems in Supporting Approved Providers
My name is Tantania Brown, and I am the owner and Childcare Educator Operator (CEO) of Heartfelt Nesting LLC, an Approved Childhood Development Home operating within U-LAUNCH: Childhood Development Homes, a Virginia Licensed Home-Based Child Care System.
I appreciate the Virginia Department of Education’s efforts to revise the Child Care Subsidy Program Guidance Manual to improve clarity and strengthen administrative processes. As an approved provider operating within a Licensed Home-Based Child Care System, I would like to share my perspective on an area that I believe would benefit from additional clarification.
One of the reasons I chose to become an Approved Childhood Development Home within a Licensed Home-Based Child Care System was the centralized administrative support available to providers. While I am responsible for operating my child care program and complying with all Child Care Subsidy Program requirements, I rely on my licensed system to provide guidance, technical assistance, administrative support, and help navigating complex state processes.
Throughout my experience, I have observed that the Guidance Manual does not clearly recognize the role that Licensed Home-Based Child Care Systems play in supporting approved providers. This lack of clarity can create uncertainty regarding communication with the Department, provider enrollment, administrative processes, and other functions that licensed systems are already responsible for under Virginia law and regulation.
Licensed Home-Based Child Care Systems are established under Article 3 of Chapter 14.1 of Title 22.1 of the Code of Virginia (§§ 22.1-289.010 through 22.1-289.019) and regulated by the Standards for Licensed Home-Based Child Care Systems (8VAC20-810). These systems exist to provide centralized oversight and administrative support to approved member homes. Recognizing that role within the Child Care Subsidy Program Guidance Manual would better align the guidance with Virginia’s existing statutory and regulatory framework.
I respectfully recommend that the Guidance Manual:
Providing this clarification would reduce confusion for providers, improve administrative efficiency, and allow approved homes like mine to spend less time navigating administrative uncertainty and more time providing high-quality care to Virginia’s children and families.
Thank you for the opportunity to submit these comments and for your consideration of these recommendations.
Respectfully submitted,
Tantania Brown
Childcare Educator Operator (CEO)
Heartfelt Nesting LLC
Approved Childhood Development Home
Member of U-LAUNCH: Childhood Development Homes, a Virginia Licensed Home-Based Child Care System
Supporting Administrative Partnerships Between Approved Homes and Licensed Home-Based Child Care Systems
My name is Anderia Knight, and I am the owner and Childcare Educator Operator (CEO) of an Approved Childhood Development Home operating within U-LAUNCH: Childhood Development Homes, a Virginia Licensed Home-Based Child Care System.
I appreciate the opportunity to provide comments on the proposed Child Care Subsidy Program Guidance Manual.
As an approved provider participating in a Licensed Home-Based Child Care System, I have experienced firsthand the value of having centralized administrative support available to help navigate state requirements and administrative processes. While I remain responsible for operating my child care program and complying with Child Care Subsidy Program requirements, I depend on my licensed system for technical assistance, guidance, and administrative support so that I can focus on providing high-quality care for children and families.
In reviewing the proposed Guidance Manual, I believe it would be beneficial to more clearly recognize the role of Licensed Home-Based Child Care Systems established under Article 3 of Chapter 14.1 of Title 22.1 of the Code of Virginia (§§ 22.1-289.010 through 22.1-289.019) and regulated under 8VAC20-810. Licensed systems provide ongoing oversight and centralized administrative services to approved member homes, yet the Guidance Manual provides very little information about how these systems interact with the Child Care Subsidy Program.
Greater clarity would benefit providers by reducing uncertainty regarding communication with the Department, provider enrollment, administrative procedures, and other processes where licensed systems routinely provide assistance.
I respectfully recommend that the Department:
Clarifying these areas would strengthen the partnership between approved providers and Licensed Home-Based Child Care Systems, improve administrative efficiency, reduce confusion, and allow providers to spend more time serving children and families instead of navigating administrative uncertainty.
Thank you for considering my comments and for your continued efforts to strengthen Virginia’s Child Care Subsidy Program.
Respectfully submitted,
Anderia Knight
Childcare Educator Operator (CEO)
Approved Childhood Development Home
Member of U-LAUNCH: Childhood Development Homes
Virginia Licensed Home-Based Child Care System
Supporting a Clear Pathway for Future Approved Child Care Providers
My name is Tanaisa Biggs, and I am the owner of Mars Childcare LLC. I am currently working toward becoming an Approved Childhood Development Home through U-LAUNCH: Childhood Development Homes, a Virginia Licensed Home-Based Child Care System.
As someone preparing to enter Virginia’s child care profession, I appreciate the opportunity to provide comments on the proposed Child Care Subsidy Program Guidance Manual.
One of the reasons I chose to pursue approval through a Licensed Home-Based Child Care System is the guidance, technical assistance, and administrative support the system provides to new providers. As someone starting a child care business, navigating state requirements, provider enrollment, and administrative processes can be overwhelming. Having access to a licensed system that provides oversight and ongoing support gives me confidence that I will be able to successfully serve children and families while meeting Virginia’s requirements.
As I prepare to become an approved provider, I believe the Guidance Manual should more clearly recognize the role of Licensed Home-Based Child Care Systems established under Article 3 of Chapter 14.1 of Title 22.1 of the Code of Virginia (§§ 22.1-289.010 through 22.1-289.019) and regulated by 8VAC20-810. These systems play an important role in helping providers understand state requirements, complete administrative processes, and maintain compliance after approval.
I respectfully recommend that the Department:
As Virginia continues working to expand access to quality child care, I believe Licensed Home-Based Child Care Systems can play an important role in helping new providers successfully enter the profession. Clear guidance recognizing that role will reduce confusion, improve consistency, and make it easier for future providers like me to navigate the approval and subsidy processes.
Thank you for the opportunity to submit these comments and for your consideration of these recommendations.
Respectfully submitted,
Tanaisa Biggs
Owner
Mars Childcare LLC
Candidate for Approval through U-LAUNCH: Childhood Development Homes
Virginia Licensed Home-Based Child Care System