When reauthorizing the Child Care and Development Block Grant (CCDBG) Act of 2014, Congress required Child Care and Development Fund (CCDF) Lead Agencies to develop and implement strategies to increase the supply and improve the quality of child care services for targeted groups, including infants and toddlers and homeless families.

The CCDF Final Rule has made children experiencing homelessness a priority category, which means that Lead Agencies shall give such children priority for services (45 C.F.R. § 98.46, 2016). The CCDF Final Rule also defines “child experiencing homelessness,” adopting the definition in section 725 of Subtitle VII-B of the McKinney-Vento Act (42 U.S.C. 11434a), which aligns with other Federal early childhood programs, including Head Start.

This definition of homelessness means those lacking “a fixed, regular, and adequate nighttime residence” and includes but is not limited to children:

• “Sharing the housing of other persons due to loss of housing, economic hardship, or a similar reason”
• “Living in motels, hotels, trailer parks, or camping grounds due to the lack of alternative adequate accommodations”
• Who “are abandoned in hospitals, or are awaiting foster care placement"
• “Who have a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings”
• “Migratory children who qualify as homeless for the purposes of this subtitle because the children are living in circumstances described above.”

For more information about this definition, visit the U.S. Department of Education’s website.

According to the new CCDBG Act and the CCDF Final Rule, Lead Agencies are required to use CCDF funds to improve access to quality child care services, including the following (45 C.F.R. § 98.51, 2016):

Lead Agencies shall give priority for services to families experiencing homelessness. Lead Agencies must have procedures to permit enrollment of children experiencing homelessness prior to completion of all documentation (including grace periods for compliance with immunization and other health and safety requirements). When establishing the length of the grace period, Lead Agencies must do so in consultation with appropriate health agency. Additionally, the Lead Agency must coordinate with licensing agencies and other relevant state, territorial, tribal, and local agencies to provide referrals and help families comply with immunization and other health and safety requirements;

• Provide training and technical assistance to child care providers and appropriate Lead Agency (or designated entity) staff on identifying and serving children and families experiencing homelessness
• Conduct specific outreach to families experiencing homelessness

Why Is It So Important to Serve Homeless Families With Infants and Toddlers?

Young children need consistent, stable environments that offer safety and security to support their optimal development and learning (National Research Council and Institute of Medicine, 2000). Infants and toddlers are especially vulnerable given their rapid brain development and the influence that early experiences have on their neural pathway formation and future learning. Adverse experiences, such as homelessness and poverty, create an environment of chronic stressors that can impact and alter the developing brain (Center on the Developing Child, 2007; De Bellis & Zisk, 2014). Prolonged periods of an unstable environment, absence of a primary caregiver, domestic conflicts, compromised mental health of a parent or caregiver, and exposure to household substance abuse are chronic stressors that may impair young children’s development. Young children who have experienced chronic stressors may have inhibited self-regulation skills, impaired neural pathway development, emotional and behavioral issues, and in some cases, physical disabilities and developmental delays (Buckner, 2008). Adverse experiences of homelessness during infancy and toddlerhood may lead to a lower aptitude and lack of skills needed to succeed in school compared to peers who did not experience homelessness (Perlman & Fanuzzo, 2010). This remains consistent even after controlling for poverty.

Access to child care that offers a consistent, predictable, nurturing, and safe environment supports young children’s development and learning and can buffer the challenges and stressors associated with homelessness (Center on the Developing Child, 2007). Child care settings that support individualized care and primary care relationships are important for all young children, but are essential for infants and toddlers experiencing homelessness (Office of Child Care, 2016).

Strategies and Recommendations for States and Territories to Serve Families Experiencing Homelessness Through CCDF

The Administration for Children and Families (ACF) provides States with the flexibility to develop policies that increase access to services for the homeless population (ACF, 2013). This list of policy options includes the following:

• Exempt Housing Assistance from Countable Income: States/Territories have the flexibility to exclude the value of housing assistance when determining income eligibility for CCDF. This means that homeless families do not have to worry about losing their child care subsidy if they accept housing assistance. (p. 4)
• Waive Co-payments for Low-Income Families: States have the flexibility to waive co-payments for families if they are living below the poverty line. This provision would eliminate the financial contribution usually required for accessing a child care subsidy. States also have the flexibility to target this policy to a subset of families living in poverty, such as homeless families. (p. 4)

The Policy Statement on Meeting the Needs of Families With Young Children Experiencing and at Risk of Homelessness (USDHHS, U.S. Department of Housing and Urban Development, U.S. Department of Education, 2016) provides the following recommendations for consideration to support the unique needs of families with young children who are experiencing homelessness or who are at risk of experiencing homelessness.

• Two-Generation Approach: Local and State providers are encouraged to support positive early experiences of young children and work to achieve stability and promote well-being for the whole family by creating and strengthening partnerships across housing and early childhood programs (p. 3).
• Coordinated Entry: Support integration of early childhood programs and local homeless assistance systems to ensure immediate and ongoing assessment to address housing needs of families (p. 3).
• Share Data on Early Childhood Homelessness: Build upon evidence-based practices and research to better serve families experiencing or at risk of experiencing homelessness (p. 3).

Building Supply of Child Care Through Grants and Contracts

ACF (2001) indicates that using grants and contracts can increase the capacity to serve vulnerable populations while providing increased financial support for child care providers. Many States use grants and contracts to supplement the delivery of child care services. CCDF Lead Agencies can use grants and contracts to build a more targeted capacity of available child care to serve families experiencing homelessness, particularly those with infants and toddlers.

Ensuring the early learning and development of our country’s youngest and most vulnerable children is essential to ACF’s work. Clearly, the reauthorized CCDBG Act and CCDF Final Rule place an emphasis on serving homeless children and families. Supporting the well-being of young children and families experiencing homelessness is an urgent task. It is critical to improving the long-term educational outcomes of children nationwide. These families face many difficult and unique challenges. Ensuring families experiencing homelessness have consistent access to high-quality child care can help them overcome some challenges and provide tremendous benefits to their children, particularly infants and toddlers.

Administration for Children and Families, U.S. Department of Health and Human Services. (2013, January 4).Policies and procedures to increase access to ECE services for homeless children and families. Retrieved January 11, 2017, from https://www.acf.hhs.gov/ecd/interagency-projects/ece-services-homeless-children/policies

Buckner, J. C. (2008). Understanding the impact of homelessness on children. American Behavioral Scientist, 51(6)721–736. doi: 10.1177/0002764207311984

Center on the Developing Child, Harvard University. (2007).The impact of early adversity on children’s development (InBrief). Retrieved December 7, 2016, from http://46y5eh11fhgw3ve3ytpwxt9r.wpengine.netdna-cdn.com/wp-content/uploads/2015/05/inbrief-adversity-1.pdf

Child Care and Development Fund (CCDF) Program, 81 Fed. Reg. 67438 (September 30, 2016) (codified at 45 C.F.R. Part 98). Retrieved January 4, 2017, from https://www.gpo.gov/fdsys/pkg/FR-2016-09-30/pdf/2016-22986.pdf

Child Care and Development Fund (CCDF) Program, Federal Register, 81 Fed. Reg. 67438-67595 (September 30, 2016) (codified at 45 C.F.R Part 190). Retrieved December 7, 2016, from https://www.federalregister.gov/d/2016-22986/p-130

Child Care and Development Fund (CCDF) Program, 81 Fed. Reg. 67438 (September 30, 2016) (codified at 45 C.F.R. Part 98). Child Care and Development Fund (CCDF) Program, 81 Fed. Reg. 67438 (September 30, 2016) (codified at 45 C.F.R. Part 98). Retrieved January 4, 2017, https://www.gpo.gov/fdsys/pkg/FR-2016-09-30/pdf/2016-22986.pdf

Child Care and Development Fund (CCDF) Program, 81 Fed. Reg. 67438 (September 30, 2016) (codified at 45 C.F.R. Part 98). Retrieved January 4, 2017, https://www.federalregister.gov/d/2016-22986/p-130

De Bellis, M. D., & Zisk, A. (2014). The biological effects of childhood trauma Child and Adolescent Psychiatric Clinics of North America23(2), 185–222. Definitions of Homelessness for Federal Program Serving Children, Youth, and Families. (n.d.). Retrieved January 9, 2017, from https://www.acf.hhs.gov/sites/default/files/documents/ecd/homelessness_definition.pdf

National Research Council and Institute of Medicine. (2000). From neurons to neighborhoods: The science of early childhood development. Committee on Integrating the Science of Early Childhood Development. Jack P. Shonkoff and Deborah A. Phillips, eds. Board on Children, Youth, and Families, Commission on Behavioral and Social Sciences and Education. Washington, DC: National Academy Press.

Office of Child Care, Administration for Children and Families, U.S. Department of Health and Human Services. (2016, December, 14). Child Care and Development Fund Final Rule frequently asked questions Retrieved January, 9, 2017, from https://www.acf.hhs.gov/occ/resource/ccdf-final-rule-faq

Perlman, S., & Fanuzzo, J. (2010). Timing and influence of early experiences of child maltreatment and homelessness on children’s educational well-being. Children and Youth Services Review, 32 874–883.

U.S. Department of Health and Human Services (USDHHS), U.S. Department of Housing and Urban Development, & U.S. Department of Education. (2016, October, 31). Policy statement on meeting the needs of families with young children experiencing and at risk of homelessness. Retrieved January 9, 2017, from https://www.acf.hhs.gov/sites/default/files/documents/ecd/echomelessnesspolicystatement.pdf