Empire Justice Center writes to comment on the proposed regulations which appeared in the June 15, 2016 New York State Register regarding Child Care for Children Experiencing Homelessness.  Empire Justice Center is a non-profit civil legal aid organization with offices throughout New York State in Albany, Rochester, Westchester and on Long Island.  Our mission is to protect and strengthen the legal rights of people in New York State who are poor, disabled or disenfranchised through systems change advocacy, training and support to other advocates and organizations, and high quality direct civil legal representation.  We focus on a number of issues affecting low income individuals and families such as public benefits, including SNAP, cash assistance and child care issues.  We closely follow state law and policy regarding child care, because affordable quality child care is critical to the ability of low income working families to succeed and escape poverty.

The federal Child Care Development Block Grant of 2014 requires states to place a strong emphasis on serving homeless families and children.  Specifically, the federal law requires that after establishing initial eligibility, states must allow a grace period for homeless children to provide documentation, particularly with respect to immunizations; provide training to child care providers regarding services and supports for homeless children; and to conduct outreach to homeless families.  42 USC 9858c(c)(2)(I)(i)(l);(c)(2)(O)(i);(c)(3)(B)(i).

Click here to read our comments.