Study Points to Progress and Need for Regulation Reforms

The findings of the state's first comprehensive analysis of CT Department of Public Health's inspection reports couldn't have come out at a worse time, admits Judith Meyers, Child Health and Development Institute's president and CEO, with the deficit mitigation plan hitting early care and education in the state hard in November, but the results of the “Impact Study: Ensuring Health and Safety in CT's Early Care and Education Programs” are not meant to place blame or criticize, she said.

“The results will only help us do better by children and families and make them the best they can be,” Meyers said. “There are celebrations in early care and education, but we can also do better.”

To date, 100,000 children are enrolled in 1,650 child care center/group day care homes in Connecticut and 16,000 children are in 2,700 family day care homes in the state. The state's frequency when it comes to routine, unannounced inspections of these facilities is every two years for centers/group day care homes (ranking CT near the bottom of all state frequency of inspections -- #41 our of 50 for centers and #29 out of 39 states for group day care homes) and family day care homes are inspected at a frequency of every three years, ranking CT #31 out of 45 states.

“We need a system that's strong and supports providers and is the underpinning for everything else,” said Shannon Rudisill, the associate director of the Child Care Bureau at the U.S. Department of Health and Human Services.

The study's sample included 676 early care centers (41%) and 746 family child care homes (28%). The highest frequencies within centers for regulation compliance fell within the following categories: child basic health needs (nutrition, rest, space); child supervision, program documentation, educational program, infant/toddler outdoor safety and infant/toddler development. The highest frequencies in centers for non-compliance included record documentation, diaper-changing procedures, playground hazards, the lack of an emergency plan or CPR certified staff. The report noted that licensing specialists varied in their assessments of what was deemed compliant and non-compliant. One licensing specialist found a center non-compliant for playground safety because there was snow on the ground. Another said that playground safety could not be gauged in the winter because of the snow.

In terms of family child care homes, the highest frequencies for regulation compliance were in outdoor safety, indoor health, child basic health (nutrition, diapering, illness), child protection, development, program documentation and parent interaction. The highest frequencies of non-compliance included documentation for child, staff and family, indoor safety, emergency preparedness, medication administration and qualifications of provider.

“The results don't really surprise me,” said Jessica Sager, executive director of New Haven's All Our Kin, Inc., who served as a member of the CHDI panel. “Family providers want to provide the best, but they are isolated. We need to bring resources and training to providers.”

After reviewing the report, Rudisill shared the following insights: 1) She commended CHDI and others for wanting to learn from the data – the goal is continuous improvement, she said; 2) That the public-private partnerships speak volumes for the state; 3) The report is a model for other states and can be shared with other states; 4) There is a sense of balance to the study – the sense is that the goal is to support providers with a system of support.

“You've looked at what things are working and places you have info to make investments to ensure children in Connecticut grow up healthy, happy and successful in school and in life,” said Rudisill.

The report sheds light on the need for uniform inspection criteria by licensing specialists at the Department of Public Health. There are no written guidelines to assess licensing specialists, added Angela Crowley, one of the report's authors and an associate professor at the Yale School of Nursing. The challenges of the report point to weak oversight that includes inconsistent inspections and not enough funding resources that support minimal health and safety, such as medication administration training, a health consultant system and technical assistance and continuing education resources.

“Providers don't mind being inspected, if it's a reliable inspection,” said Rep. Beth Bye (D-West Hartford), who also sat on the CHDI panel.

Linda Smith, executive director of the National Association for Child Care Resource and Referral Agencies (NACCRRA), says the inspection process needs improvement and there needs to be clarity in the regulations. She points to Washington State's regulations, which she calls “provider-friendly.”

“How do we expect compliance when [the regulations] are intentionally vague?” Smith asked.

One audience member noted that the data collection and research from this recent report did not differentiate the severity of violations – for example, an “S” hook on a piece of equipment on a center's playground has begun to rust – does that constitute as a “major” violation? Or a loose floor tile – would that be a serious infraction?

Among the recommendations of the report, program improvement, designating and making available best practices when it comes to a medication administration training program, more frequent inspections and guidelines for specialists in terms of licensing; an electronic data collection system and annual report to the Legislature and the formation of a strategic planning advisory committee that includes members from the Department of Public Health, state agencies, providers, parents, child care health experts and advocates.

The report's conclusion is that non-compliance items should be considered a call to action; that no child is placed at risk and that compliance with continuing education is critical for both strategic planning and on-going monitoring.

“Conversations start with data,” said Rep. Bye. “This will start a conversation. It opened up some questions. We need to make sensible policy and not add to the impoverished field. We need to focus on the most important aspects and look at the money being spent and spend it more wisely.”

“Connecticut has high standards and continues to strive, but in health and safety, one mistake can be costly,” said Iris Rich, director of the Women's League Child Development Center.

“Don't lose sight of the child or you'll fail,” added Smith. “Take the findings and do a strategic plan with the parents at the table.”

This study should be used nationally, Smith said, or replicated around the country to make the case for training and oversight.