the centers do not receive other public funding (at any level, Federal, State, County, municipal) they must fall under the Federal standards. They, therefore, would place owners in a position of possibly refusing care to a battered or protective services child who was paid for by a county or local agency. On the other hand, within a 4 or 5 year period, in order to maintain its ABC eligibility, each State will have to certify to the Federal Administrator of Child Care (undoubtedly soon to be a "czar") that all centers in their State are licensed and monitored, and then, that all such licensed child care ascribes to the minimal and irreducible Federal standards. Otherwise, the State is decertified and can no longer receive ABC money.

What about the large and growing number of religiously sponsored centers, especially in the 12 States where, by statute, they are exempt from licensing and regulation, and which strongly oppose being regulated by secular/public authorities on religious grounds? Are they to be discriminated against because of their beliefs? Might they not bring legal suit also, again delaying implementation and hurting thereby the poor and their children? The ABC supporters have been caught in a religious labyrinth from which there is no escape.

These bills are so flawed and unjust that they appear, as you read them, more and more like Swiss cheese. They do not respect State and local rights to decide how to regulate, monitor and improve the quality of a wide variety of child care options and will result, at the least, in a two-tier system of center care. They violate the well-accepted "principle of subsidiarity."

(2) These bills are blatantly anti-small business.

Speaking also of prejudice and unfair exclusion, both these bills are deliberately biased against proprietary centers, putting us at a severe competitive disadvantage, and even out of business. We are deliberately and unjustly excluded from the ABC grant and loan provisions for care environment improvements, from technical assistance and teacher improvement grants, from demonstration program grants for business-center partnerships, and so forth. The supporters of these legislative affronts to fairness have repeatedly heard the proprietary small businesses cry out for fairness in this regard, and resolutely chosen not to compromise in any way. Mr. Chairman, it's tough enough competing in a marketplace where non-profit centers pay no taxes, receive subsidized food, obtain operating grant monies, charge rates equal to or higher than proprietors, and refuse to accept subsidized children. Our tax-paying centers are faced with an evergrowing unfair competitive challenge from tax-exempt providers.

Our tax-paying centers already are faced with an evergrowing unfair competitive, challenge from tax-exempt providers. Recall, if you will, that IRS designation as a 501(c)(3) charitable organization triggers a plethora of advantages, such as exemption from Federal, State and local income, sales, and property taxes, favorable postal rates, favorable contract arrangements with public bodies such as public school systems and the so-called "halo image." It is no wonder that recently a YMCA national official was quoted as declaring that now YMCAs have more child care centers than even KinderKare!

(3) These bills are deceptive about child participation and raise false expectations for parents and the public.

It boggles the mind that the eligible population under the ABC Bill, if fully funded at $2.5 billion annually, is estimated by the Child Welfare League at 18 million youngsters, aged infant to 15, but only 1 million would be served. One can only express bewilderment that the ABC Bill is so unrealistically all-encompassing, attempting to solve latch-key children problems in a pre-K bill. Moreover, the average direct subsidy to all eligible parents would be only $97, if the Bill were fully funded; or a much smaller parent group could receive a larger subsidy. (Consider that under S. 412, the Moynihan/Packwood tax credit/Title XX Bill, the maximum credit per child would be $960 and could be refundable).

(4) These bills will unjustly redirect the family rearing policies and preferences in the United States for future generations.

Finally, and perhaps more devastatingly for the future course of family life in the U.S., testimony presented last week before the House Republican Study Committee strongly indicates that the ultimate purpose or effect intended by the core leadership of those groups fervently pushing the ABC approach as the only way to go, is to impose a Swedish family model on the unsuspecting U.S. In that system, the main role of both parents after a child is born, is to go back to work as soon as possible and "leave the driving to us," the early childhood elite establishment and valueneutral or free, public education system. This is a perversion of the American way of life and flies in the face of every known child psychology study about the need for parent bonding and nurturing with their child, and an affront to parent choice in child rearing.

Now, let me emphasize the positive. What are we for-what approach to the national child care policy does the NCCA and other major organizations espouse as a reasonable alternative to the dangerously flawed approaches I have just discussed. At the outset, let it be heard loud and clear: we, too, care about youngsters. The ABC coalition has no monopoly on concern for the safety and health of young children, for their parents' involvement, and for teacher and program improvements on all levels.

We support the basic thrust of S. 412, the "Expanded Child Care Opportunities Act" introduced by Senators Moynihan and Packwood and many of your colleagues on this Committee on Finance. Our reasons for this support can be related to the three objectives or issues-availability, affordability and quality, around which the national child care policy debate has been framed.

Availability. The issue of availability is a red-herring. There is no massive and critical shortage of child care now, or for the foreseeable future. Rather, as our current NCCA National Center Vacancy Study is expected to find, (as preliminary results did last September), there are actual vacancies ranging on a State by State basis from 14 to 30 percent in center care. This is in accord with the April 1988 report of the Labor Department that identified pockets of shortages, skewered by age (infants, for example) and location, and highly sensitive to the current national and local economy. And presumably, there will be an ample supply of both paid and unpaid, family home care providers.

Affordability. To address this need in a constitutionally appropriate way, the NCCA endorses increased-percentage child care tax credits, targeted towards the poor, and refundable for the most needy. We would also propose a targeted, nondiscriminatory use of child-care certificates for the truly poor to use for the child arrangement of their choice, provided by the States from their Title XX Social Service Block Grant funding.

In this way, the percentage of family income dedicated to child care by poorer parents can be reduced form approximately 20-25%, and more closely approximate middle income family percentages, as well as increase parental choice options.

Quality. But tax credits alone (absent a massive improvement in parent/consumer education and critical questioning and awareness) will not do enough for qualitative improvements in child care.

These block grant funds also should be used to address the issue of quality, as determined and decided, with wide local input, by those closest to the scene, the States and localities. Federal standards and a brand new Federal oversight establishment is not needed. We desire improvements in State licensing and monitoring of all types of paid child care, especially for the estimated 90% of paid family home care providers who currently are not regulated. (These are not grandparents, other relatives or trusted neighbors, but those who provide care for 5 or more children to whom they are not related, and for pay in their homes.) They, above all, need remedial assistance to improve their care environments (family rooms, or basements), and to upgrade their pedagogical skills, through continuing education programs from a variety of sources, such as at local community colleges. And this is true for all types of center providers, as well.

Many other issues should be addressed in a truly pre-K, child care legislative agenda-appropriate participation of senior citizens without jeopardizing their Social Security benefits; creative business/child care center partnerships and a cafeteria plan of child care benefits for employees; vast improvement in resource and referral services; increased parent consumer education (the ultimate quality assurance guide); and liability insurance reforms for care providers.

Mr. Chairman, the time has come for a fair and equitable national child care policy, targeted towards lower income parents and their pre-K children, and for children of special needs, funded through a combination of tax credits and social service block grants. The ultimate quality of provision responsibility should be determined by the States and localities, in dialogue and partnership with needy parents, and other knowledgeable participants.

We join the voices of many advocates who contend that most State licensing departments are in dire need of additional resources, and we believe it is an appropriate role of the Federal government to provide incentives and assistance to those departments to assure adequate monitoring of non-familial, out-of-home, paid child care, especially unlicensed family care providers. Until this country improves, upgrades and assures all children of the equal enforcement of health and safety standards in its current system, it seems ludicrous to impose even stronger Federal standards on the very segment of the industry that is already highly regulated, and willingly accepts state regulations, or their voluntary equivalent, for the protection of the children for whom we care.

This is the only constitutional, focused and effective pre-K program for the Federal government. It's not as simple, therefore, as ABC.

The quality issue in child care is nebulous at best. Quality means different things to different people, and it is that broad spectrum of parental demands and expectations that has afforded this nation its diverse child care system. And it is the protection of this diversity that we, as an industry, feel is important to the working parents of America. We across the country, I assume we, as an industry, must be doing something right. I know I speak for thousands of child care professionals who are extremely proud of the job they do.

While I am extremely grateful to the Committee for allowing testimony from the National Child Care Association, I must encourage you to continue seeking input from all sources. What I have to say, as a practitioner and provider of child care is very different from what you might hear from the theorists, social scientists and even insurance underwriters. However, we are the ones implementing child care policy and actually providing the service. With an estimated three million children in licensed child care across the country, I assume we, as an industry must be doing something right. I know I speak for thousands of child care providers who are extremely proud of the job they do. We suggest that the federal government play a role in providing resources for state licensing departments to license more completely and consistently all non-family, out-of-home, paid child care, as well as center based care. We also encourage the federal government to help us to improve the quality of child care by increased training of child care professionals and increased consumer education, and upgraded resource and referral centers.

In conclusion, I want to thank you again for this opportunity to present testimony before the Committee on Finance. I have tried to present an accurate picture of both my industry and my profession and our goals and concerns for the children of America. We are a new industry, we are developing, and we are professionalizing at an incredible pace. We need your help to continue both our commitment to private enterprise and to children. I urge you to consider carefully the impact of your legislative action on our future.

Enclosure.

RSD

Building Futures

The Newsletter from Rochester School for the Deaf

1545 St. Paul Street, Rochester, NY 14621

(716) 544-1240

Issue No. 39, 1989

New Day Care Center Provides Model Program