Appendix A. Comments Received on 60-Day Federal Register Notice

Appendix A
Comments Received on 60-Day Federal Register Notice

June 18, 2021
Submitted via email ([email protected]).
Attn: OPRE Reports Clearance Officer
Administration for Children and Families
U.S. Department of Health & Human Services
330 C Street, S.W.
Washington, D.C. 20201
Re: Proposed Information Collection Activity; Early Head Start-Child Care Partnerships Sustainability
Study (86 FR 20699)
To Whom It May Concern:
Start Early and the Educare Learning Network appreciate the opportunity to offer a joint comment to
the U.S. Department of Health & Human Services regarding the Early Head Start-Child Care Partnerships
(EHS-CCP) Sustainability Study. With our mission of giving children in poverty the best chance for
success in school and in life, Start Early advocates for the highest quality care and education for children
from birth to age five. Thousands of young children, parents, and members of the early childhood
workforce are reached each year through our programs, training, evaluation, and advocacy efforts.
Start Early serves as the backbone for the Educare Learning Network (ELN), a national network of 25
birth-through-age 5 schools that aims to improve access to high-quality early education across the
country. The Network builds strong public-private partnerships to create strong schools and longtime
champions who will amplify our call for change. Below, Start Early and ELN offer additional
considerations for EHS-CCP evaluators, informed largely by a community of practice of the 12 Educare
operating organizations that have participated in EHS-CCP. In alignment with our commitment to
centering and amplifying early childhood practitioner voice, in each section below, we offer direct
quotes from the EHS-CCP grantees surveyed in addition to a summary of our comments and
recommendations.

Study Importance & Use of Data
VOICES FROM THE EDUCARE LEARNING NETWORK:
The EHS-CCP grantees
“My hope would be that we would be able to show how
consulted for this comment
powerful and impactful the work that we do in EHS-CCP is in
offer that the data collected
being able to level the playing field when it comes to
by ACF in this study should
supporting the overall development and education of the
be used to demonstrate the
children and families we serve. My hope is that we would be
value that the partnerships
able to show that the approach that we use in our work sets up
add to child care programs
each and every child and their family for future school success
and improving family and
in a most equitable and respectful way. My hope is the data
validates our approach and would be a springboard to partner
child development and
with as many providers as possible to continue the work that
outcomes. Further, they
we do.” -Jami Pollis, Early Childhood Education Coach, Educare
offer that the data should
Central Maine/Kennebec Valley Community Action Program
be used for asset mapping
and creating best practices for programs participating in EHS-CCP grants. The data collected should be
analyzed for regional similarities and differences, trends in gaps and strengths, and asset mapping that
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can be used to support programs in areas of specific need. This would allow ACF to leverage the deep
knowledge base that has been built up by current grantees to strengthen and sustain current and future
EHS-CCP grants and enhance their impact on child and family outcomes.
In particular, programs would benefit from best practices for data collection and sharing among
partners. The EHS-CCP grantees engaged in this commenting process reported a wide range of
experiences in regard to what partner data they readily have access to and who they share it with (e.g.
internal school leaders, Head Start Policy Council, staff, governing boards, state government). Given the
importance of program data for continuous quality improvement, we recommend that the data
collected for ACF’s evaluation be used to develop best practices and exemplars in this area, among
others. As ACF uses data from this sustainability study to determine what technical assistance EHS-CCP
grantees need, we encourage the agency to consider establishing a EHS-CCP Training and Technical
Assistance Center as needed. As ACF uses data from the sustainability study to determine the technical
assistance needs of grantees, we encourage the agency to consider establishing a EHS-CCP Training and
Technical Assistance Center if needed.

Suggested Changes to Collection Instruments
The EHS-CCP grantees consulted for this comment indicated that the following topics are of critical
importance to the partnerships and should be explored in ACF’s surveys and interviews:
Workforce development and support, e.g. access to professional development and higher
education attainment during the partnership and growth from coaching. We appreciate ACF
including workforce development factors in its draft surveys and interview protocols, and
recommend including questions on the timing of credentials received to identify whether higher
education attainment increased during the period of partnership and whether child care
providers were able to provide various types of professional development to their staff
members prior to their participation in EHS-CCP. Additionally, ACF’s questions regarding
professional growth and development focus primarily on the attainment of formal credentials.
We recommend broadening these
VOICES FROM THE EDUCARE LEARNING
questions to include staff and leaders
NETWORK:
growth from peer-to-peer coaching as
“Partners enjoy the collaboration, the technical
well as alternative, competency-based
assistance support and the financial support that
workforce development pathways that
our grant offers. We have heard from multiple
build the knowledge, skills, and practice
partners over the past year that without our
support, their programs might have had to close.
expertise.
For many of our partners, just having someone to
•
COVID-19 impacts and
talk through things with is incredibly helpful.” resiliency factors, e.g. what specific
Jami Pollis, Early Childhood Education Coach,
supports allowed programs to remain
Educare Central Maine/Kennebec Valley
operational during COVID, partners’
Community Action Program
lessons learned from the pandemic,
strategies that were implemented due to the pandemic and will be continued. We appreciate
ACF’s draft questions related to how COVID-19 affected vacant slots, providing infant/toddler
care, home-visiting opportunities, and more. Grantees surveyed for this comment emphasized
the need for information around how COVID-19 affected: the stability of programs’ funding
sources, workforce retention, what types of support child care partners requested from their
•

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partner EHS programs, and what types of supports families requested and received from
programs.
Supports for children with developmental delays or disabilities. We appreciate ACF’s
questions regarding the availability of developmental screenings and who provides and receives
them. We also recommend asking specifically about the longer-term success of children who
receive these screenings (e.g. the number of children with IEPs who no longer need them at age
five) and what role EHS-CCPs played in
VOICES FROM THE EDUCARE LEARNING
increasing access to screenings and use of
NETWORK:
screening data to inform services and
“The ability to keep partners viable is
instruction.
understated. It’s not in most people’s nature
to put a spotlight on the fact that without
The EHS-CCP grantees we surveyed
these supports ‘they may have had to close
emphasized the importance of using
doors’ as many feels this makes them look
narratives and anecdotes in addition to data,
unstable or financially unreliable. However, in
and appreciate ACF’s use of both interviews
truth, many only were able to stay open or
and surveys, as well as the many
close for Covid concerns, because of the
opportunities the surveys offer to provide
partnership and the stability we provide.” alternative responses (“other, please
Andrew Bourassa, Supervisor and Educational
specify”). We are also excited that many of
Coach for MSAD 54 and KVCAP Pre-K
the
questions speak specifically to unique
Programs at Educare Central Maine/Kennebec
challenges and successes experienced in
Community Action Program
serving infants and toddlers and hope that
the data can inform how providers can enhance and expand these critical services.
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Additionally, we recommend that in question 16 of the Sustained Partner Interview Protocol, ACF
change “maternity leave” to “parental leave” to be inclusive of providers and parents of all genders and
all types of parental leave policies offered by early
VOICES FROM THE EDUCARE LEARNING
childhood programs.
NETWORK:
“I feel we do a good job of capturing the data
Data Collection Considerations
but it is hard to quantify some things we do.
Given the many demands placed on early childhood
The stories are what people care about and
program leaders, we recommend that ACF consider
sometimes those are not quantifiable.” leveraging programs’ existing, readily accessible
Melissa Manning, Training & Professional
data to help inform EHS-CCP program planning,
Development Coordinator, Educare
technical assistance, and research. Table 1 below is
Oklahoma City/Sunbeam Family Services
a summary of the partner data that is accessible to
the EHS-CCP program leaders surveyed for this
“[What is not being captured about the impact we
comment:
are making is] [w]hat is truly needed to support
infants, toddlers and families in small group size and
pay staff a livable wage.” – Lori Pittman,
Governmental Affairs Advisor Educare Seattle, Puget
Sound ESD and Co-Chair, Educare Policy Workgroup

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Table 1: Partner data availability
Collects and can access OR could easily access:
•
•
•
•
•
•

•
•

•

QRS statistcs
Infant CLASS
observations
Pre-K CLASS
observations
ITERS-3 observations
Child assessment EHSCCP data using TSG
Provider statistics (# of
providers in your
state/community over
the past few years)
Provider feedback
about the partnerships
EHS-CCP data on
supports you are
providing to each
partner (i.e. coaching,
mentoring, renovation
funds, etc.)
Family
surveys/interviews

•

Does not collect/no plans to collect:

Family outcomes:
o Families as lifelong
educators (reading
together, college
savings, etc.)
o Families as learners
(education, etc.)
o Family connections
to peers and
community (social
supports,
community
connections, etc.)
o Positive parentchild relationships
(family time,
guidance/discipline,
etc.)
o Parents as
advocates and
leaders (civic
process, parent
advocacy, etc.)
o Family well-being
(housing,
transportation,
childcare,
employment, etc.)

•
•
•

FCCERS-3 observations
Child assessment EHS-CCP
data using DRDP
Child assessment EHS-CCP
data using COR

We also encourage OPRE to consider compensating survey and interview participants for their time.
The EHS-CCP grantees consulted for this comment indicated that participating in interviews may be a
challenge particularly for family or home-based child care providers, who often rely on a small, core
group of staff and may find it difficult to find coverage for their child care duties during interview
participation.

Considerations for Future Studies

The EHS-CCP grantees we spoke with for this comment indicated that they are eager for an opportunity
to evaluate the community-wide impact of the partnerships. Child care partners serve many children
and families who are not directly involved in the partnership work, but may benefit indirectly from the
peer learning, professional development, and program assessment and continuous quality improvement
that takes place through EHS-CCP. Though outside of the scope of the sustainability study proposed by
ACF, we recommend that these potential indirect benefits of the partnerships be explored in future
studies.
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VOICES FROM THE EDUCARE LEARNING NETWORK:
“I'm not sure that we have found an effective way to collect data on the community impact of
our partnerships. We often focus on child outcomes and specific family outcomes for those
children and families enrolled in our slots. With that being said, many of our partners have a
significant part of their enrollment not directly involved in our partnership. Those staff, children,
and families are indirectly impacted and that is the data I believe could help round out our story.
How many programs have increased enrollment, staff retention, etc. as a direct result of our
involvement?” -Jami Pollis, Early Childhood Education Coach, Educare Central Maine/Kennebec
Valley Community Action Program
Thank you for consideration of the above comments. For any additional information, please contact
Nadia Gronkowski, Program Manager of Advocacy and Policy at Start Early, 33 W. Monroe Street, Suite
1200, Chicago, Illinois 60603, [email protected].
Sincerely,

Diana Mendley Rauner, Ph.D.
President, Start Early

Cynthia D. Jackson
Executive Director, Educare Learning Network

Lori Pittman
Governmental Affairs Advisor Educare Seattle,
Puget Sound ESD
Co-Chair, Educare Policy Workgroup

Keith Liederman
Chief Executive Officer
Educare New Orleans, Kingsley House
Co-Chair, Educare Policy Workgroup

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