Appendix F. Federal Register Comment

October 21, 2022
Office of Planning, Research, and Evaluation
Administration for Children and Families
330 C Street, S.W.
Washington, DC 20201
Re: Proposed Information Collection Activity; The Role of Licensing in Early Care and Education
(#2022-18154)
To Whom It May Concern:
On behalf of Learning Care Group (LCG), I am grateful for the opportunity to comment on the Office of
Planning, Research, and Evaluation’s (“Office”) Proposed Information Collection Activity; The Role of
Licensing in Early Care and Education, specifically with respect to the potential survey of licensed child
care providers.
Learning Care Group is the second largest for-profit early care and education provider in North America,
headquartered in Novi, Michigan. LCG is a leader with 50 years of experience in providing high-quality
child care and early education programs for children ages six weeks to 12 years. With 1,056 schools in 39
states and the District of Columbia, LCG has approximately 23,000 employees and the capacity to serve
more than 160,000 children. Approximately one-third of children served in our schools receive some
financial support (i.e., Child Care and Development Block Grant) to afford high-quality early education
and care. We also play a critical role for ensuring food security for vulnerable children, serving
approximately 22 million meals annually to young children through the Child and Adult Care Food
Program. LCG is known through its 11 family brands: AppleTree & Gilden Woods Early Care and
Preschool, The Children’s Courtyard, Childtime Learning Centers, Creative Kids Learning Center,
Everbrook Academy, La Petite Academy, Montessori Unlimited, Pathways Learning Academy, Tutor Time
Learning Centers, U-GRO Learning Centres, and the Young School.
As a leader in early childhood education, LCG is deeply invested in improving the industry. Our halfcentury of providing high-quality child care and early education programming has taught us that
implementing meaningful improvements requires considerable gathering information. We view the
Office of Planning, Research, and Evaluation’s efforts to survey the early education industry as an early
step to helping providers like LCG better serve American families. The company is committed to evolving
in tandem with the changing needs of the children in its care, and we commend the Office for similarly
reflecting on the growth of the early care and education industry.
We hope the Office will consider the following logistical recommendations as the Office drafts the
survey to be circulated among licensed providers. First, we urge the Office to draft a survey that is as
user-friendly as possible. An Internet-based survey that lends itself to easy completion using multiple-

choice questions where appropriate and can be submitted immediately is more likely to be completed
by child care providers, who increasingly find themselves pressed for time amid staffing shortages and
high demand for care. Second, the Office should expand the pool of center-based providers to be
surveyed. Center-based providers include corporate providers, nonprofit providers, and faith-based
providers, among others. The Office currently proposes to capture that wide range of perspectives by
surveying only 1,000 respondents nationally. We worry that such a small sample size will fail to
accurately reflect the diversity of the industry, compromising the overall effectiveness of the survey.
Third, we encourage the Office to add an additional cohort of survey respondents: former providers who
permanently closed their child care centers during the pandemic. Responses from this cohort will shed
light on the extent to which state licensing requirements contributed to the discontinuation of their
operations. The pandemic exposed the cracks in the child care landscape, so this information is essential
to developing a more complete understanding of state licensing regimes.
Additionally, we encourage the Office to incorporate the following five substantive considerations into
the survey. First, the survey should seek to uncover the vast differences between state licensing
requirements that occasionally lead to drastic differences in how states interpret and enforce similar
rules. Second, we similarly suggest the survey press respondents to explain how states collaborate with
stakeholders to develop licensing requirements. Third, we recommend asking providers about the
extent to which states differentiate between violations that risk the health and safety of children and
less serious violations when labeling a provider noncompliant. Fourth, the survey should probe the
extent to which state licensing regimes discourage technological adaptation, including in the
maintenance of inspection, violation, and staffing records. Finally, the survey should solicit feedback
from providers on training mandates, which often present logistical challenges to providers. For
example, some states may provide training less frequently than a region of providers demands. These
inquiries will provide crucial insight into the barriers providers face in navigating state licensing
requirements to the benefit of the Office’s larger goal.
We appreciate the Office’s attention to this issue and leadership in helping children and families. LCG
looks forward to ultimately learning from the licensed child care provider survey results. Please do not
hesitate to reach out if LCG can be helpful to the Office as the survey progresses.
Sincerely,

Johnna L. Weller, Ed.D.
Chief Academic Officer
Learning Care Group