BCDI-Ohio’s Public Comment on Proposed Federal Rule “Restoring Flexibility in the Child Care and Development Fund (CCDF)”

RE: Docket number ACF-2026-0001 / RIN number 0970-AD20

Dear Secretary Kennedy:

Thank you for the opportunity to submit comments on the proposed rule Restoring Flexibility in the Child Care and Development Fund (CCDF). We oppose the proposed rule because of its potential impact on families, providers, and communities.

Child care plays a central role in children’s development, family economic stability, and community well-being. For children, stable early care environments support social, emotional, and cognitive development and provide consistent relationships with caregivers during critical years of growth.

For families, access to affordable and reliable child care enables workforce participation, educational attainment, and financial stability. For communities, child care supports local economies and workforce systems and contributes to long-term educational and health outcomes.

Through our community engagement work at BCDI-Ohio, families and providers consistently identify access to affordable, high-quality child care as a critical need.

In Ohio, families continue to face challenges related to the cost, availability, and stability of child care. Providers face persistent workforce shortages and financial constraints that affect their ability to sustain operations and meet demand. These conditions are especially pronounced in rural communities and in programs serving infants and toddlers.

In Ohio, many child care programs operate with limited financial margins. Payment systems that rely on daily attendance or delayed reimbursement can create cash flow challenges that affect staffing and enrollment capacity. These pressures can contribute to classroom closures and reduced access to care, particularly for infants, toddlers, and families in underserved areas. When child care becomes less affordable or less stable, children experience more disruptions in care and fewer consistent relationships with caregivers, which affects their development and sense of security.

The proposed rule would remove requirements related to limiting family co-payments, providing some direct services through grants or contracts, and to enrollment-based and prospective provider payments. These provisions were intended to improve stability for both families and child care programs. Removing them risks shifting financial uncertainty back onto families and providers at a time when stability is most needed. This instability will directly impact the viability of business infrastructure which is a focus in our State as well at the Federal level.

Child care is critical infrastructure. It supports the workforce, family stability, and children’s development at the same time. Policy decisions about CCDF shape how that infrastructure functions at the ground level.

While state flexibility is important, it should be balanced with federal expectations that protect affordability and stability. I urge the Department to maintain meaningful standards related to family cost burden and provider payment practices, even while allowing states flexibility in how those standards are implemented.

Thank you for the opportunity to comment. I urge careful consideration of how this rule will affect real families and real child care programs across states like Ohio.

Respectfully Submitted,

Dr. Jasmine Moses

Policy Manager

Black Child Development Institute of Ohio