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:

• Recognize the centralized administrative 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 and the Standards for Licensed Home-Based Child Care Systems (8VAC20-810).
• Clarify that an approved member home may authorize its Licensed Home-Based Child Care System, through a written agreement, to perform designated administrative functions on its behalf, including provider enrollment, onboarding, administrative communications, recordkeeping, billing support, and other centralized administrative services, while the approved provider remains responsible for compliance with all Child Care Subsidy Program requirements.
• Clarify the administrative procedures for payment administration when an approved member home has contractually authorized its Licensed Home-Based Child Care System to provide centralized fiscal and administrative services. This should include guidance regarding the submission of W-9 information, banking information, and other documentation necessary to administer Child Care Subsidy Program payments on behalf of approved member homes, or identify any statutory or regulatory authority that limits or prohibits such arrangements.
• Establish clear communication protocols between the Department and Licensed Home-Based Child Care Systems when the system has been authorized by an approved member home to serve as its administrative representative.
• Provide clear guidance regarding provider enrollment, onboarding, and ongoing administrative procedures involving Licensed Home-Based Child Care Systems and their approved member homes to ensure consistent implementation across the Commonwealth.

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