DAY-CARE REGULATION IS COUNTERPRODUCTIVE, STUDY SAYS

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP88G00186R000400410024-1
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• Document Page Count: 26
• Document Creation Date: December 22, 2016
• Document Release Date: March 17, 2011
• Sequence Number: 24
• Content Type: REPORT

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DAY-CARE REGULATION IS COUNTERPRODUCTIVE, STUDY SAYS
WASHINGTON, September 25, 1985 -- Day-care regulation has done little to
ensure the health and safety of children, according to a study just
published by the Cato Institute.
Karen Lehrman and Jana Pace write that "day care has been plagued
by the ill-considered directives of well-intentioned bureaucrats. Laws
designed to protect the health and safety of children and guarantee
responsible care have, in many cases, proved to be counterproductive.
By raising the cost of day-care services, would-be providers have been
deterred from the business while others have been driven underground,"
limiting the number of children who can benefit from day care "at a time
when the need has never been greater."
The authors found that "while there are an estimated 10 million day-
care spaces nationwide, there are at least 14 million preschoolers whose
parents work full time." In fact, more than 17 percent of parents seek-
ing day care are unsuccessful. "Such failure does not necessarily mean
that the parents forfeit job or education opportunities; rather, it means
that young children are often left alone for at least part of the day."
Lehrman and Pace discuss a number of detrimental regulations. They
discovered that nearly every state sets guidelines for staff-child
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Cato/Day-Care/2-2-2
ratios. But according to a report commissioned by the Department of
Health, Education, and Welfare, there is only a "slight" correlation
between staff-child ratios and the quality of day care. Although this
guideline has little effect on the quality of care, it is the greatest
barrier to enlarging the supply, as the staff-child ratio determines the
bulk of the day-care providers' costs.
The most detrimental restrictions on day care are local zoning
regulations. "Of all local day-care regulations, however," Lehrman and
Pace write, "zoning statutes have the least relevance to the quality of
care and the safety of the children." Zoning rules often forbid
individuals to care for neighborhood children in their homes or restrict
the number of children who may be cared for in a home, often to as few
as five children.
The authors conclude by stating that it is vital for children to be
cared for by competent people in a safe environment. "But this quality
of care has been achieved through parental concern, not ineffective and
often counterproductive regulations. Without the false sense of security
provided by government standards, parents would take more responsibility
for the well-being of their children."
Karen Lehrman is managing editor and Jana Pace is associate editor
of Consumers' Research magazine. Their study, "Day-Care Regulation:
Serving Children or Bureaucrats?" is part of the Cato Institute's Policy
Analysis series. The Cato Institute is a Washington-based public policy
research organization.
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POLICYANALYSIS
No. 59 September 25, 1985
DAY-CARE REGULATION: SERVING
CHILDREN OR BUREAUCRATS?
by Karen Lehrman and Jana Pace
The regulation of day care is 100 years old this year.[1]
In the past 15 to 20 years, however, day-care regulation has
come to consume $47 million of taxpayers' money.[2] Today, all
50 states and the District of Columbia have some day-care regu-
lations. More significant, day-care facilities are also sub-
ject to a host of local zoning, building, health, fire,. and
safety statutes. These regulations, which vary from state to
state and municipality to municipality, can dictate everything
from the time a facility opens to the width of the exit door.
The intent of these regulations is to ensure minimum health and
safety standards for the children and to guarantee responsible
care by the day-care provider. Unfortunately, many require-
ments do little to achieve these aims, while a major effect of
regulation has been to raise the cost of day-care services,
driving providers underground and limiting the number of chil-
dren who can benefit. Unnecessary regulations are stifling the
supply of day care at a time when the need has never been
greater and shows every sign of continuing to surge.
The Growing Demand for Day Care
Once considered an unfortunate necessity for single moth-
ers, day care has become an American institution, used by peo-
ple of all economic, cultural, and educational backgrounds.
This phenomenon is the inexorable result of social and demo-
graphic changes that over the past 20 years have altered the
life-style and composition of the American family.[3] No
longer are most children raised in traditional, two-parent
households, with a father who works and a mother who stays at
home: in 1984, both parents held jobs in 52 percent of
American families. At the same time, the traditional form of
day care provided by relatives and friends is vanishing; not
only has the increased mobility of American society led to the
disappearance of extended families, but the conventional baby-
sitters have themselves joined the work force.
Karen Lehrman is managing editor and Jana Pace is associate
editor of Consumers' Research magazine.
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Yet the availability of day-care services has not kept
pace with demand. While there are an estimated 10 million
day-care spaces available nationwide, there are at least 14
million preschoolers whose parents work full time, according to
the Institute for Parent/Child Services in Philadelphia. And
that figure is expected to increase 38 percent by the decade's
end. The need for infant care is particularly pressing, since
47 percent of women with children under one year of age are now
in the labor force. According to a day-care referral service
in California, 40 percent of its requests are for children
under two, while only 13.5 percent of the licensed day-care
spaces available locally are for this age group.[4] Another
study found that in 1982 more than 17 percent of parents
searching for day care were not able to find it.[5] Such
failure does not necessarily mean that parents forfeit job or
education opportunities; rather, it means that young children
are often left alone for at least part of the day.[6]
Whether children are better cared for at home by their own
mothers, in others' homes, or in day-care centers is not a pol-
icy question. Day care has become a necessity for most fami-
lies and should thus be regarded as an essential community ser-
vice. The question is whether current policy is working to
cultivate or suffocate this much-needed resource.
The Shortage of Supply Services
Why is there a shortage of day-care services? One reason
is general: there is usually a lag in any market before supply
catches up with demand. Another, more specific, reason is that
day care has not proven a particularly lucrative venture, at
least not for the 1.5 million people who provide day care in
their homes. According to the Child Care Law Center in
California, the economic realities of "family" day care are
these:
The average fee per child per month for full time
care in a large family day-care home is $150 to $200
per month. If there are 12 children (and it is rare
for any program to be constantly full due to parents'
vacations, delays in replacing a child, collection
problems, etc.), the total gross annual income would
be $21,000 to $28,000. Out o his amount, two full-
time salaries and benefits must be paid and expenses
must be met, including liability insurance, food for
snacks and lunch, equipment, supplies and so forth.[7]
More typically, a provider cares for only three or four chil-
dren full time, earning less than $6,500 a year.[8] Another
survey estimates that a family day-care provider earns an aver-
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age of $74 a week in profit.[91 For this, most day-care pro-
viders are required to put in an 11-hour day--from 7:00 a.m. to
6:00 p.m.--to accommodate the schedules of working parents.
The other major type of day-care service, the day-care
center, usually serves 20 or more children and is run either as
a commercial enterprise or as a nonprofit activity of a church
or school. Centers charge higher fees, and the commercial ones
can actually be profitable. But they also tend to price them-
selves out of the reach of lower- and middle-income families
who typically spend more than 10 percent of their after-tax
income on day care.[10] Home care remains the most important
for such families, and it is here that the need is greatest.
Of course, home providers do not enter the day-care market
as entrepreneurs seeking to get rich. Most are in the business
because they like children. Many are mothers themselves who
have chosen to stay home with their own children and supplement
their families' incomes (or actually support their families) by
caring for the children of people who work outside the home.
Added expenses or bureaucratic red tape can easily tip the bal-
ance for home providers, turning a marginally profitable but
rewarding endeavor into a frustrating and expensive one.
Clearly, then, if the supply of day care is ever to keep
pace with the rapidly rising demand, it is essential that there
be a favorable climate for its growth. At present there is
not, and the regulatory obstacle course laid out by state and
local officials is in large part why.
State Barriers to the Provision of Day Care
Licensing and Registration
The primary regulation of day care occurs at the state
level, where standards are set and licenses are granted.[11]
All states require day-care centers to be licensed, and more
than half require day-care homes to be licensed as well. In
some states, if a person cares for even one unrelated child in
a private residence other than the child's own, that person is
considered to be operating a day-care facility and is required
to obtain a license.
To monitor compliance, day-care facilities are inspected
by state licensing officials (usually with the department of
social or human services) upon application for a license and,
in most states, again each time a license is renewed. Several
states only conduct spot checks on a random sampling of li-
censed family homes.
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In response to tightening budgets, some states have re-
placed the licensing of day-care homes with "registration,"
generally considered to be a mild form of regulation. Regis-
tration often does not require inspection by the state, empha-
sizing instead the participation of parents in monitoring the
care of their children. In some states, registration is even
voluntary.
Currently, 11 states register family day-care homes, and 3
either license or register them, depending on the number of
children enrolled and the presence of children receiving fed-
eral subsidies. Five states regulate only those homes that re-
ceive federal funds.[121 Home providers caring for fewer than
five children are exempt from regulation in 19 states, while 23
others set more relaxed standards for providers who care for
fewer than six or seven children in their homes. These states
have a separate classification for large family day-care or
"group" care facilities. In states without such a category,
homes where more than five or six children are cared for are
usually defined as day-care "centers" and are therefore subject
to more rigorous standards.
State standards generally govern the number and ages of
children that can be cared for. In a day-care home the most
common maximum number is six, of which no more than two can be
infants. State standards also regulate the amount of indoor
and outdoor space provided, the quality of meals and snacks,
program content, parental involvement, and so on. In addition,
regulations for large family homes and day-care centers usually
include standards on educational requirements for center direc-
tors and teachers and on the ratio of staff to children.
Staff-Child Ratios
Of all the state regulations, staff-child ratios have the
most direct bearing on the supply of day care. Virtually all
states have regulations limiting the number of children one
staff member can care for in a day-care center. The most common
staff-child ratios for preschoolers are 1:10 and 1:15. Since
staff salaries comprise one of the largest components of a cen-
ter's costs--about 75 percent--low staff-child ratios limit the
number of children that can be cared for in centers with lim-
ited budgets. The 1979 National Day-Care Study commissioned by
the Department of Health, Education, and Welfare, the only study
that has examined the effect of state standards on quality of
care, confirmed that the staff-child ratio was the most impor-
tant determinant of Providers' costs. Moreover, the study
found only a "slight' correlation between staff-child ratios
and quality.[13]
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Some states currently require centers to maintain a 1:3
ratio for infant care. Ann Muscari, a spokesperson for Kinder-
Care, by far the largest chain of day-care centers, says that
such a low ratio is not always necessary in a well-equipped
center. It is, in part, such costly regulations that have kept
Kinder-Care--which opened its 1,000th center this summer--out
of 10 states. According to Muscari, in addition to weighing
the demand for day care and the real estate costs in a poten-
tial market, Kinder-Care "tends to go where regulations are
such that [the company] can make a reasonable profit, while
providing affordable and quality child care." The "very, very
stringent" regulation in New York is a principal reason for not
opening a center in that state. The staff-child ratio for
three-year-olds in New York is 1:7.[14]
Strict standards of this nature also limit the number of
children able to benefit from a day-care facility receiving
federal funds for children from low-income families. Fifteen
states have different standards--generally more stringent--for
subsidized care, according to Helen Blank of the Children's
Defense Fund. In seven states, family day-care homes are sub-
ject to a more stringent regulatory process if they accept sub-
sidized children.[15]
Local Barriers to the Expansion of Family Day Care
Zoning Regulations
Although the state's formal permission to operate is the
fundamental requirement for most providers of family day care,
complying with state standards usually does not prove as costly
or complicated as getting past local regulatory obstacles. The
highest hurdle facing family providers is often the first--
obtaining the approval of local zoning officals. Of all local
day-care regulations, however, zoning statutes have the least
relevance to the quality of care and the safety of the chil-
dren. Most city zoning commissions consider day care to be a
small.business and prohibit programs from opening in residen-
tial areas. This prohibition extends even to individuals wish-
ing to use their own homes to care for a few neighborhood chil-
dren.
The illogic of this restrictive zoning policy was pointed
out by one frustrated would-be provider before the Washington,
D.C., Board of Zoning Adjustment: "You're telling us that we
cannot operate a day-care facility in a residentially zoned,
middle-class neighborhood with a large number of working
mothers, but we can operate a center in a commercial zone be-
tween two topless bars."[161
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In most cases providers can apply for a zoning variance or
a conditional-use permit, but the process is generally neither
cheap nor easy--nor is it always successful. Fees to process
an ap lication for a variance or a use permit typically range
from p$100 to $1,000, although zoning commissions that are par-
ticularly vehement in their desire to keep day care out of
residential areas have been known to levy fees as high as
$3,000.[17] Before a use permit is granted, some communities
also require complex, formal hearings in which applicants may
need legal counsel, a further--and not inconsequential--
expense. An applicant may also be required to send a written
notice of the hearing to neighbors as well as to pay for a
public notice in the local newspaper.[18]
The detrimental effects of zoning regulations can be il-
lustrated easily. Mary Andrews of Ridley Township, Pennsylvania,
tried to claim exemption from the local zoning code on the grounds
that her day-care service was a "home occupation." But the
zoning board ruled that her home was in violation of the local
ordinance because she had an additional part-time employee and
took her business outside the home when she let the children
play in her yard or took them on walks. At a later hearing,
she testified that the employee had resigned and that the chil-
dren would remain inside in the future.[19] Rather than promot-
ing quality or ensuring safety, the effect of the local ruling
was to reduce the amount of adult supervision and deny children
outdoor exercise.
Five prospective day-care providers in Richland County,
South Carolina, were denied outright the conditional-use per-
mits necessary to provide day care in their homes. The appli-
cants were participants in the state's Family Day-Care Home
Demonstration Project, a government-funded program to train
AFDC recipients to provide day care. Each had passed a pre-
liminary screening by the state's Department of Social Services
and had completed a three-month training program. According to
Lillian Crosby of the Management Services Corporation, the pri-
vate organization that runs the program jointly with the state,
zoning had not been a problem in other counties. In Richland,
however, because neighbors and members of the zoning board of
adjustment were opposed to day care, the requisite permits were
withheld and there was little to no chance of successful
appeal.[20]
In one exceptional case of zoning trouble in Birmingham,
Michigan, a provider was arrested for caring for too many chil-
dren in her home. Although Renee Cuchetti had a license from
the state to care for up to twelve children, under Birmingham's
zoning ordinance she could accept only six. Cuchetti had
previously complied with this limit, but in 1982 when her
husband became unemployed, she began caring for one or two
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additional children with his help. Her problems began when a
neighbor, who had tried to have Cuchetti day-care business closed
down once before, enlisted the aid of two other neighbors to
count the cars arriving at the Cuchetti home each day. Based on
this "triple hearsay," says Patrick Keenan, Cuchetti's lawyer
and a professor at the University of Detroit Law School, the
city issued an arrest warrant for the errant day-care provider.
The case was ultimately dismissed by embarrassed local
officials, and Cuchetti continues to provide day care. She
says she will not try to get the local zoning policy brought
into line with state policy, even though in 1980 she had led
the successful. fight to change the city's zoning law to permit
care for up to six children per day-care home in residential
areas. The court battle had taken over a year and had cost the
Cuchettis $3,000 to $4,000 in legal fees.[21]
Opposition from neighbors is frequently the point of origin
for the problems home providers encounter with local zoning au-
thorities. Much of the resistance to day care, explains Abby
Cohen, a lawyer with the Child Care Law Center, comes from re-
tired senior citizens who fear that a day-care home would mean
traffic congestion and an influx of noisy children into their
quiet residential streets. While some additional traffic in the
morning and evening is likely, she argues that the level is usu-
ally not high enough to justify prohibiting family day care.
The Child Care Law Center advises prospective providers to arm
themselves with these arguments when appearing at zoning hearings:
Even a home caring for 12 children will probably gen-
erate little increase in traffic because most fami-
lies select day-care homes in their own neighborhoods
and many school-age children walk from school to day
care. Those parents who do drive won't all arrive at
the same time, so parking shouldn't be a problem.
The children in family day care are well-super-
vised. . They are less noisy than unattended
neighborhood children, and their outdoor activities
can be scheduled and controlled by the provider so
that they do not create problems for neighbors.[22]
From attending numerous zoning-board hearings, Cohen has also
found that a conviction that mothers should not work, but stay
home to care for their children, is another source of neighbor-
hood resistance to day care.
Local zoning commissions do not always act as fair, objec-
tive arbiters in such instances. Zoning hearings sometimes turn
into forums for the airing of neighborhood tensions unrelated
to the issue of child care, and, says Cohen, such neighborhood
squabbling has often led to arbitrary zoning decisions.[23]
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A case in point is Jorgenson v. Salt Lake City, now before
the Utah Supreme Court, in which a day-care provider who was
ordered to close down has charged the city's zoning board of
adjustment with "arbitrary, capricious, and abusive" use of
discretion. The zoning board allegedly made no attempt to dis-
criminate among the neighbors who complained, assigning as much
weight to complaints from neighbors living across the street
and several houses away as to complaints from the neighbors
whose property abuts the provider's. Moreover, the opinion of
the lower court, which upheld the board's decision, was written
in language suggesting that "if anyone in the city complained
[about a day-care home], the zoning board would recognize that
complaint" and deny the day-care home permission to operate,
according to a lawyer involved in the case.[24]
While preparing a profile on day care for the American
Enterprise Institute in 1982, Sean Scott talked to four pro-
prietors of small day-care homes in Washington, D.C., who said
they would not risk the $100 fee to participate in what the?
perceived to be an "arbitrary, inconsistent review process,'
and thus chose to remain unlicensed.[25]
The District of Columbia modified its zoning ordinance in
1982 to allow family day care to operate in residential areas
as a matter of right. However, because the city defines family
day care as a program serving five or fewer children, a home in
which even six children are cared for (including the provider's
own) is considered to be a "center" and is therefore denied
this right.
A nationwide study conducted in 1984 by the Children's
Foundation found that zoning problems for day-care homes have
increased in recent years as more providers have entered the
market. At the same time, progress has been made in eliminat-
ing restrictive zoning codes in six states, which have passed
preemption statutes to exempt family day-care homes from local
zoning ordinances. In these states, as in Washington, D.C.,
day care is treated as a "customary home occupancy" in the same
way that doctors' and architects' offices are treated. Efforts
to pass similar legislation in Massachusetts failed last year,
and a preemptive statute that made it through the Georgia
legislature was subsequently. judged unconstitutional under
state law.
Building, Fire, and Health Regulations
Like zoning codes, building, fire, and health codes ap-
plied to day care are administered primarily on the local level
and vary widely from community to community. In cases where
state licensing regulations conflict with local codes, the more
restrictive provisions generally apply.
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When interviewed, many providers say that a house or
apartment deemed safe enough for a family should be considered
suitable for the care of five or fewer unrelated children.[26]
Yet this belief is rarely shared by local officials. A home
judged safe by building and fire inspectors for private resi-
dents must usually meet a host of additional requirements if it
is used for day care.
To comply with these codes, providers sometimes spend thou-
sands of dollars to renovate their homes.[27] In some cases,
the required renovations are either prohibitively expensive or,
says Abby Cohen, actually impossible to implement. Cohen cites
cases in which family day-care homes in California were required
to install sprinkler systems and fire-retardant walls to comply
with local fire codes. One family day-care provider was ordered
to install fire-safe wallboard to separate the area used for
day care from the rest of the house.[28]
California's preemptive day-care statute, adopted in 1983,
has since freed small family day-care providers from such infea-
sible regulations. However, the statewide fire code for day
care, which has replaced the local codes, still restricts day-
care activities to the ground floor in homes caring for seven
to twelve children unless automatic sprinkler systems are in-
stalled. Although a number of alternatives are allowed under
the state regulation, "all are expensive," says the Child Care
Law Center's Carole Stevenson. The regulation thus prevents
many homes from expanding to provide group care.[29]
In other states as well, building and fire codes effec-
tively prohibit family providers from increasing enrollment in
their homes. In some cases, there is ample room to question
whether the added safety provided by required renovations would
be enough to justify the cost.
Sylvia Thorpe of Potomac, Maryland, for example, decided
she could not afford to care for more children after the fire
marshall told her she would need to replace her four smoke de-
tectors with a five-detector, interconnecting system. The cost
of installing the system was estimated at $2,000.[30] Susan
Suddath, a family day-care provider for nearly 20 years in Damas-
cus, Maryland, was told the ceiling in her basement was too
low. Almost six feet tall herself, Suddath assured the inspec-
tor that she would be the tallest person in the room and did
not need to stoop to stand there. Despite this, regulations,
she was told, could not be bent.[31] A San Benito County, Cal-
ifornia, woman learned that she would have to install separate
toilet facilities for boys and girls if she wanted to increase
enrollment in her six-child day-care home. Moreover, the bath-
rooms would have to be accessible to wheelchairs. The woman
withdrew her application.[32]
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Regulations such as that stipulating separate toilet fa-
cilities have, in many cases, been borrowed from codes designed
for institutions: schools serving larger numbers of children,
or hospitals and orphanages providing round-the-clock care.
"Because child care has only recently begun to be acknowledged
as a necessary community service for all families," explains
Carole Stevenson, "the laws that govern it . . . often do not
contemplate its unique nature. In many instances, child care
has been regulated by fitting it into a preexisting statutory
scheme."[33]
According to David Beard, director of day-care licensing
in Texas, "Legislators found it all too convenient to jam day-
care licensing into existing residential child-care licensing
laws, regardless of lack of fit."[34] In Texas, Beard adds,
health departments often apply restaurant standards to day-care
facilities because food is served. Family day-care providers
can be required to install three separate stainless steel sinks
and a vent over the stove.[35]
In Bloomington, Minnesota, health officials currently
apply to large day-care homes the National Food Code provisions
regarding the separation of public and private foods. Thus, in
order to serve hot meals, these homes must be equipped with
separate storage facilities (including refrigerators and freez-
ers), separate food preparation areas, and a separate sink for
hand washing where food is prepared.[36] Joy Prentice, a day-
care provider in Bloomington, was also directed to obtain dish-
sanitation equipment. Because she cares for more than five
children, she is classified as a nursery school--requiring a
fully commercial kitchen--under Bloomington's regulatory stat-
utes. As a result, Prentice and most other group-home providers
in Bloomington do not serve hot lunches; instead, they ask parents
to provide brown-bag lunches. Providers who pay a $25 "snack
fee" to the city, however, are permitted to serve cold snacks
during the day. This is in addition to the $50 licensing fee
that is levied by the city on group day-care homes.[37] Char
Thomasson, executive director of the Family Day-Care Association
in Hennepin County, Minnesota, claims that these costly require-
ments are a violation of the state's preemptive statute for day
care, which covers both family and group day care.
When stringent standards are imposed on residences used
for day care, providers are discouraged from applying for a
state license and identifying themselves to local authorities.
It is estimated that 90 percent of home day-care providers
operate without a license, even where it is illegal to do so.
Ten percent of the larger, more visible day-care centers are
unlicensed.[38] The most frequently cited reason for "going
underground" is the complex and costly maze of requirements
that must be met before obtaining state sanction. For parents
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seeking day care, this vast underground market can present a
problem. When providers choose not to register or apply for a
license, they do not appear on public or private information
and referral lists. Even more visible (and uncountable) than
the providers who go underground, however, are the potential
providers who are deterred by state and local regulations from
entering the day-care market at all.
Local Barriers to the Expansion of Day-Care Centers
Local regulations also present great obstacles to day-care
centers. Some city zoning commissions do not define day care
as a commercial activity and therefore prohibit facilities from
locating in commercial areas. As a result, businesses may not
be able to offer day care as an employee benefit on or near
their premises without obtaining special approval.[39]
Under many zoning codes, churches are defined as essential
community services permitted to locate anywhere. But when
churches provide services other than worship--such as day care--
they must often obtain a zoning variance or a special excep-
tion.[40] Some local governments also subject churches to ad-
ditional requirements when their facilities are used for day
care. In the District of Columbia, churches are required to
have 60 square feet of playground space per child and reserved
parking spaces for day-care staff. It is estimated that such
requirements add $50 to $100 per child per month to tuition
cost.[41] Across the District's border in Montgomery County,
Maryland, the building code requires all day-care centers to
have 1,000 square feet of playground space per child! Mary-
land's state licensing law stipulates only that "ample space"
be provided.
Many building codes are predicated on the assumption that
facilities have been newly constructed for the express purpose
of providing day care. But that is rarely the case. Most day-
care centers and virtually all day-care homes are located in
structures formerly used for some other purpose. One director
in Washington, D.C., wanted to open a center in a building that
had a 36-inch-wide door. But the city required that doors in
day-care centers be at least 38 inches wide. In order to com-
ply, a wall had to be knocked out. In terms of actual inches
and added safety, the difference between a 36-inch door and a
38-inch door is minimal. In terms of expense, it is not.[42]
The District of Columbia's regulations require centers to
have one toilet for every 10 persons, including staff. More-
over, adult bathroom facilities must be separate from those of
children. To meet this requirement, probably another holdover
from regulations governing the care of children in orphanages,
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hospitals, and other residential institutions, centers must
either restrict enrollment or increase tuition. A less strin-
gent ratio would be adequate to meet the sanitary requirements
of children in day care.[43]
Regulation to Prevent Child Abuse
Investigations and arrests in New York, California, New
Jersey, Illinois, Alabama, and Tennessee have focused national
attention on the potential problems of sexual abuse in day-care
settings. Concern, of course, is well justified. However, not
only could a flood of new state legislation prove inadequate in
preventing child abuse, it could deter dedicated and caring
individuals from entering the day-care market. Added to these
risks are the costs to day-care providers in time and money,
and the potential threat to civil liberties.
Currently, the federal government is putting pressure on
the states to pass child-abuse legislation. As part of the
Continuing Appropriations Act for fiscal year 1985, Congress
made available to the states $25 million for training child-
care workers to prevent child abuse in licensed and registered
day-care facilities. Use of these funds is contingent on a
state's establishment of laws or regulations providing for em-
ployment-history checks, background checks, and nationwide
criminal-record checks for all day-care employees. Previously,
state laws regarding the confidentiality of criminal-record
files prohibited day-care center directors from making criminal-
background checks of potential employees. Any state that does
not have the required legislation in place by September 30,
1985, must return half the allotted funds. At the time the
federal act took effect, only three states had approved statutes
requiring national criminal-record checks of day-care personnel,
and fewer than half had regulations requiring screening through
statewide criminal-record files.[44]
As part of the same act, Congress directed the Department
of Health and Human Services (HHS) to provide the states with
guidelines for minimum licensing and registration standards.
Along with the guidelines, which were promulgated in January,
1985, HHS issued a statement on the potential effectiveness of
screening:
Experience to date indicates that criminal record
checks for licensing and employment purposes in vari-
ous occupational categories yield a positive identi-
fication rate (i.e., the person being checked has a
criminal record) of only five to eight percent of the
persons screened. Because child sexual abuse so fre-
quently goes undetected and because the conviction
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rate for sexual abuse crimes is so low, it is esti-
mated that only one to 15 percent of sexual abusers
have criminal records. In addition, while approxi-
mately 95 percent of child-care workers are female,
it is males who constitute 80 to 85 percent of the
criminal record cases and 78 to 92 percent of child
sexual abuse cases. It is estimated that only seven
to eight percent of reported child sexual abuse is
committed by someone other than a relative. It ap-
pears likely, therefore, that only a small number of
child sexual abusers will be identified in this type
of screening of child-care workers.[45]
HHS also noted that while the increase in the reporting of
child abuse is a legitimate cause for concern, it may not mean
that sexual abuse in day-care facilities is actually on the
rise.[46] It is plausible that increased attention may have
led to increased reporting.
In May 1985, HHS released a report on child neglect and
abuse that stated that in almost 98 percent of known cases,
children are abused in the home by close relatives, family
friends, or neighbors. The single largest group of abusers,
comprising 77 percent of the total, is parents [47]. A 1982
survey by the American Humane Association supports these find-
ings. The survey found that in 56,000 cases of reported child
abuse, the vast majority--82 percent--involved abuse by family
members. Day-care workers and babysitters were involved in
only 1.5 percent.[48]
In the wake of a much-publicized child-abuse scandal in a
Bronx day-care center, New York City passed legislation in 1984
requiring all day-care workers to be fingerprinted. Of the
more than 6,000 workers screened, not one was found to have a
record of sexual or other child abuse. Only 3.8 percent had
records of criminal convictions, and less than half of one per-
cent had records of felonies. Nevertheless, 36 workers with
criminal records were dismissed or suspended, even though many
had been charged only with very old or drug-related offenses.
This action was even harsher than it might seem, for in many
cases police records report only the original charge, with no
indication of whether an arrest was followed by dismissal, ac-
quittal, or conviction.[49]
The costs of criminal-record checks may not be insignifi-
cant for day-care operators, and the processing time may be
more than providers can afford. The FBI charges $12 for each
fingerprint card submitted for nationwide screening. The
state and local fees vary; for example, Nebraska charges $5,
California charges $15.50, and New York City charges $17. A
report by the inspector general's office of HHS estimates that
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a nationwide criminal-record check of both state and FBI files
using two fingerprint cards costs about $25 per person. The
FBI estimates that it takes an average of 14 days for a finger-
print check to be processed, while state checks can take as
much as six to eight weeks. These are long delays for day-care
facilities, especially since the day-care industry suffers from
a staff turnover rate of 40 percent and must be able to make
replacements quickly both to assure adequate care and to meet
state staff-child ratio requirements. In addition, while
criminal checks can deter job applications by potential abusers,
they can also discourage perfectly acceptable individuals from
entering the day-care market, particularly when the checks re-
quire long delays before employment. "Ultimately," states the
HHS report, "the costs of regulating will be borne by the con-
sumer or the taxpayer."[50]
Another counterproductive effect of regulation to discour-
age child abuse in day-care centers is the false sense of se-
curity it can give parents. Most state agencies do not have
the money or manpower to ensure that day-care regulations are
being complied with, let alone to test their effectiveness in
bringing about quality and safety. On the average, states have
only one inspector for every 70 day-care centers; Ohio has one
inspector for every 100 centers.[51] Because of these limited
resources, states inspect homes only once a year or less. In
California, day-care centers and homes are now being visited
only once every three years. Some states inspect only a random
10 or 20 percent sample each year.[52] Family day-care homes
are especially difficult to monitor, since only 140,000 of the
estimated 1.5 to 2 million homes are licensed or registered.
Furthermore, inmost states inspections of centers and
homes are announced. Not only do scheduled visits rarely, if
ever, detect cases of child abuse, but according to a 1985
Children's Defense Fund study, "Day-care centers that bend or
break regulations have time to make the necessary improvements
to be in compliance for the visitation. . . . The illegal prac-
tices often resume after the inspector leaves. [53] Scheduled
inspection visits are more efficient for day-care licensing
offices than unscheduled visits, however: since there are so
few inspectors but so many facilities to visit, inspectors want
to assure access to all important personnel and records.[54]
If licensing is to guarantee quality and safety, according
to Joan Maxwell, senior associate with the Greater Washington
Research Center, inspections must be much more frequent, even
weekly--"a level of in-home supervision few providers would
tolerate and few, if any, governments could afford.
Parents vest that licensing process with powers far beyond its
merits. Most parents are unaware how rarely officials come
into contact with licensed providers. The fact that a home--or
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center--is licensed lulls many parents into a false sense of
security. We have certainly seen evidence of this in the recent
newspaper accounts of long-term child abuse by day-care providers,
all of whom were licensed."[55]
Toward Deregulation of Child Care
Registration and Parental Supervision
By increasing providers' costs, day-care regulations limit
the supply of a much-needed service. Many regulations, espe-
cially local zoning and building codes, do little to promote
quality or ensure safety. Even in cases where regulations might
benefit the child's welfare, limited enforcement minimizes any
positive effect. For these reasons, states should replace li-
censing laws with a system of registration for both homes and
centers. Registration requirements should include only those
that have a proven effect on quality of care and on health and
safety and are not so costly that they would cause providers
not to operate or to operate illegally. At the same time,
states and child-advocacy groups should continually reassess
standards to determine which ones serve children best in the
context of providers and parents' willingness and ability to
pay.
Unlike licensing, registration would give parents the ul-
timate responsibility for the quality of their children's day
care. This is appropriate: since they come into contact with
the day-care staff and observe the facility at least twice a
day, parents are in the best position to monitor day-care homes
and centers effectively. Complaints by parents can then form
the basis for official action, including unannounced inspections
by state and local authorities. In some states, day-care provid-
ers are permitted to restrict parental visitation; this, obvi-
ously must be changed.
So far, states have done little to educate parents to be
informed consumers of day-care services.[56] "The traditional
licensing approach seems to take the family out of family day
care," says David Beard, who has been in the business for nearly
20 years. He says parents can do a good job of overseeing family
day care if they know what to look for.[57] According to
Greater Washington Research Center associate Joan Maxwell, li-
censing officials perceive parents as either not knowing or not
caring about the potential dangers that arise when children are
placed in day care.[58] Such might indeed be the case. A 1983
study found that "parents tend to inquire about costs and form
a general impression from the appearance of the center; few ask
about the program and teacher qualifications."[59] If parental
monitoring is to work, parents must take the trouble to learn
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what good-quality day care is and, especially, how to recognize
signs of child abuse and neglect. Until they do, regulations--
especially those with only indirect bearing on day-care quality--
can do little to ensure good day care. Parents often get a
false sense of security from the mere existence of government
standards regulating day care--even if those standards are not
enforced through frequent inspections. When this happens, regu-
lations not only fail to promote the welfare of children; they
jeopardize it.
In the past decade, information and referral services have
appeared across the country, partly filling the gap in parental
education. These services, provided by state and local agencies,
community oranizations, employers, and nonprofit groups, increase
parents' ability to choose the appropriate care for their children.
Many provide information, training, and coordination of available
child-care services; many refer parents to subsidized care and
explain eligibility requirements; many identify providers who
speak languages other than English, who accept infants, who
offer evening or night care, and so on. Some even follow up on
referrals to see if parents have found satisfactory child care,
a service that helps identify geographic areas where additional
providers are needed. Some information and referral services
also screen day-care programs for quality and safety before
adding them to resource lists.
Dismantling Local Regulatory Barriers
Another part of the deregulation process should address
the barriers presented by local zoning, building, health, and
safety codes. With working-women and single-parent households
now an indisputable fact of American life, family day care has
become an essential community service and should be viewed as
such by local governments. The concerns of neighborhood groups
need not result in expensive zoning variance procedures; rather,
neighbors' rights can be addressed through reasonable compro-
mises or, if necessary, through legal action against individual
providers.
State preemption codes, which exempt day-care homes from
restrictive zoning, building, and fire regulations, should be
adopted more widely. States also need to address the concerns
of group day-care homes. Statewide safety standards should
take into account the fact that day-care programs are usually
established in existing buildings. Alterations of existing
structures should be required only when they are deemed so es-
sential to child health and safety that their cost is justi-
fiable. A home that local inspectors consider safe for a family
should not have to meet any additional requirements to be con-
sidered safe for six or fewer unrelated children.
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Private Alternatives to State Oversight
A number of private-sector services have taken on the ac-
creditation of day-care facilities and the certification of
day-care providers and their staffs. Although most of these
initiatives are still in their infancy, it is conceivable that
an expanded private role in setting standards and monitoring
day-care services could eventually take the place of state
oversight of day care. Since private certification and accred-
itation of individual day-care programs would give parents the
greatest degree of choice in selecting day care, the growth of
such agencies is desirable.
One of the more important of the private initiatives, the
Child Development Associate (CDA) National Credentialing Pro-
gram, provides training in child care at more than 350 colleges
and universities nationwide. Since 1971, nearly 13,000 child-
care providers have received CDA certification. An increasing
number of states have begun using these credentials to assess
day-care staff qualifications. (The CDA program is not entirely
private, however; it receives half of its funding from a federal
grant.)
Another private initiative starting up in some areas is
the "satellite system," which recruits and trains home provid-
ers, sets standards for care, and closely supervises programs.
At present, satellite day-care systems must be licensed by state
authorities and must operate according to state standards, though
some develop their own standards as well. At least five states--
California, Florida, Michigan, Texas, and Virginia--now have
provisions for satellite systems.
My Other Mother's (MOM's), Inc., one such private non-
profit system, operates in Alexandria, Virginia, on a fee-for-
service basis. MOM's oversees four family homes and operates
.two centers. The director of the organization, whose educa-
tional background is early childhood development, inspects fa-
cilities in the system at least once a month and often once a
week. Providers are required to give parents monthly child-
development reports.
A similar program in Clermont County, Ohio, is operated by
the local YWCA. Family day-care homes are screened for quality
and safety before being listed with the program's information
and referral service. In addition, each provider must agree to
regular, unannounced visits from the county welfare department
and must attend training classes on nutrition, child develop-
ment, and child abuse. Providers are also given meal and snack
guidelines and are required to keep a record of their weekly
menus. Incentives to join the YWCA program include liability
insurance, unemployment insurance, Social Security, and two
weeks of paid vacation after one year's employment.[60]
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It is conceivable that such day-care programs as those
sponsored by MOM's and the YWCA could operate effectively in
the absence of a state licensing system. Money now spent by
states on licensing could be better spent on the education of
parents through information and referral services. In addi-
tion, a private program to certify day-care providers could be
established on the model of the American Bar Association and
funded through membership fees. However, certification from
such an association should be optional, and parents should be
able to choose whether or not to place their children in homes
or centers with certified day-care providers.
As with many services, day care has been plagued by the
ill-considered directives of well-intentioned bureaucrats.
Laws designed to protect the health and safety of children and
guarantee responsible care have, in many cases, proved to be
counterproductive. By raising the cost of day-care services,
would-be providers have been deterred from the business while
others have been driven underground. This is aside from the
fact that many of the requirements do little, if anything, for
the welfare of children.
Indeed, it is vital that children be cared for by compe-
tent, dedicated professionals in a safe environment. But this
quality of care has been achieved through parental concern, not
ineffective and often counterproductive regulations. Without
the false sense of security provided by government standards,
parents would take more responsibility for the well-being of
their children. Moreover, through unregulated competition,
day-care facilities and services can supply parents with
something even more fundamental--freedom of choice.
[1] David Beard, "Regulation in Day Care: Overview and Alter-
natives," paper presented at conference "Child Care in the
United States: Toward a National Consensus," sponsored by the
National Center for Neighborhood Enterprise (Washington, Sep-
tember 1984), p. 3. In 1985, the Pennsylvania legislature
passed what is generally considered to be the first complete
child-care statute.
[2] Diane Adams, "Family Day Care Regulations: State Policies
in Transition, 11 Day Care Journal (Summer 1982): 13. A survey
by Adams of state licensing agencies found an average estimated
budget of $833,000 per state for day-care regulation and an
estimated total of $47 million nationwide.
[3] Three major demographic changes account for the increased
demand. First, the number of working mothers with preschool
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children has more than doubled since 1960. In that year, 20
percent of all women with children aged six and under were in
the work force; by 1984, the figure had soared to 52 percent.
Second, the number of single-parent families has doubled in the
past decade. One-parent families now account for 26 percent of
all families with children under 18, compared with 13 percent
in 1970. Third, the number of children under age 10 is growing
for the first time in 30 years as the baby-boom generation be-
gins raising families of its own. Between-1980 and 1990 the
number of children under 10 is expected to increase 17 percent.
Data obtained from Perspectives on Working Women: A Data Book,
Bureau of Labor Statistics Bulletin no. 2080 (Washington: De-
partment of Labor, 1980), table 26; Working Women and Public
Policy, Bureau of Labor Statistics Report no. 710 (Washington:
Department of Labor, August 1984), table 2; Household and
Famil Characteristics, Current Population Reports series P-20,
no. 398 (Washington: Bureau of the Census, April 1985), table
D. Families and Child Care: Improving the Options, House Select
Committee on Children, Youth, and Families, 98t Cong., 2d
sess., H. Rept. 39-1460, 1984, p. iv.
[4] Futures: Families, Community, and the Workplace 1, no. 1
(Pasadena: Child Care Information Service, January 1985), p. 3.
[5] Ibid. However, the National Association of Child Care
Management (NACCM), a trade association representing some 300
day-care centers nationwide, reports that most members have
spaces available, with occupancy rates averaging 70-75 percent.
The discrepancy in these reports might be explained by cost
constraints on parents looking for day care. In testimony be-
fore the House Select Committee on Children, Youth, and Fami-
lies on April 4, 1984, Rachel Thompkins, executive director of
the Children's Defense Fund, estimated the cost of care in a
group home or center at $2,200 to $3,200 per year for a three-
to five-year-old. Care for children under age three can run an
additional $1,000 per year. The average cost for family day
care, however, was estimated at $1,200 to $2,200 yearly. While
a report by Gregory L. Rhodes and Mark Real of the Children's
Defense Fund of Ohio (Day Care: Investing in Ohio's Children,
Washington, 1985, p. 46) found that most families spend-more
than 10 percent of their gross incomes on day care, Edward
Overstreet of the Michigan Association of Children's Alliances
testified before the congressional committee on March 5, 1984,
that families earning less than the Bureau of Labor Statistics
intermediate budget could not afford to pay more than 5 percent
of their incomes for day care. In 1981 the BLS intermediate
budget was $25,407 for a family of four. Some parents also
prefer the convenience and home-like atmosphere provided by
family day-care homes to the more institutional atmosphere in
centers, which serve an average of 94 children, according to
NACCM figures.
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[6] A report prepared for the governor of Maine by the Child
Care Task Force revealed that 500 Maine children aged five or
under spent time during a typical week caring for themselves.
Another 2,500 children under age three and 1,000 children aged
three to five were sometimes left at home alone, with only a
neighbor or friend occasionally looking in on them. Helen
White, Child Care: The States' Response (Washington: Children's
Defense Fund, 1984), p. 10.
[7] Kathleen A. Murray, Summary of San Francisco and State
Building Code Impediments to Licensure of Large Day Care Homes
(San Francisco: Child Care Law Center, 1981), p. 2.
[8] Rhodes and Real, p. 46.
[9] Andree Brooks, "Child-Care Homes Divide Communities," New
York Times, July 19, 1984, p. C8.
[10] Rhodes and Real, p. 46.
[11] From 1968 to 1982, the federal government regulated day
care in facilities serving low-income, subsidized children.
When funding was cut in the Omnibus Budget Reconciliation Act
of 1981, responsibility for regulation passed to the state
level. However, a bill introduced in the Senate in January
1985, the National Child Protection Act (S.142), would once
again involve the federal government in setting standards for
day-care programs. The bill would amend Title XX of the Social
Security Act to require all states receiving Title XX funds to
license and monitor day-care services according to standards to
be established by the secretary.of health and human services.
[12] 1983-84 Family Day Care Licensing Study (Washington: Chil-
dren's oun ation, 1985), pp. 6-8.
[13] Children at the Center: Summary Findings and Policy Im-
plications of the Nationa -Day Care Stu (Cambridge, Mass.:
Abt Associates, 1979), p. 3. At the time of the study, the
prevalent staff-child ratios were 1:5 and 1:10. Since then,
the majority of states have relaxed staff-child ratio require-
ments somewhat.
[14] Ann Muscari, phone interview, May 24, 1985.
[15] Helen Blank, phone interview, March 15, 1985.
[16] Robert L. Woodson, "The Importance of Neighborhood Organ-
izations in Meeting Human Needs," in Meeting Human Needs: To-
ward a New Public Philosophy, ed. Jac A. Meyer (Washington:
American Enterprise Institute, 1982), p. 142.
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[17] Abby Cohen, phone interview, March 20, 1985.
[18] Lujuana Wolfe Treadwell, Zoning Laws and Family Day Care
(San Francisco: Child Care Law Center, , p,
[19] Virginia Inman, "Day Care Laws Limit Private-Home Centers
That Parents Like," Wall Street Journal, October 16, 1982, p.
18.
[20] Lillian Crosby, phone interview, April 30,
1985.
[21] Renee Cuchetti, phone interview, April 30,
Keenan, phone interview, May 24, 1985.
1985; Patrick
[22] Treadwell, p. 8.
[23] Cohen.
[24] Michael Murphy, phone interview, May 1, 1985.
[25] Sean M. Scott, Regulatory Barriers to Neighborhood De-
velopment: The Re ulation of Day Care (Washington: American
Enterprise Institute, ), p.
[26] Ibid., p. 10.
[27] According to Sean Scott, one day-care expert explained the
added requirements placed on homes used for day care by noting
that "most trained inspectors do not agree that the average
home is safe for children. Few building inspectors are satis-
fied with the safety of those codes, but we could not afford
the safety they would want to bring us. Therefore, when we
give them a special responsibility to protect children in fam-
ily day care, they could not sleep at night if they did not add
on things that we do not have in our regular homes." Scott,
pp. 10-11. Other individuals interviewed by the writers ex-
plained the stringent codes in similar ways.
[28] Cohen.
[29] Carole Stevenson, phone interview, April 29, 1985.
[30] Inman, p. 18.
[31] Ibid., p. 1.
[32] Ibid.
[33] Beard, p. 21.
[34] Woodson, p. 143.
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[35] David Beard, phone interview, March 20, 1985.
[36] Char Thomasson, phone interview, May 2, 1985.
[37] Joy Prentice,. phone interview, May 24, 1985.
[38] Adams, p. 9.
[39] Scott, p. 4.
[40] Ibid., p. 6.
[41] Robert L. Woodson, "Day Care," in This Way U : The Local
Official's Handbook for Privatization and Contracting ut, -e.
Raymond Armington and William Ellis (Chic-ago: Regnery
Gateway, 1984), p. 159.
[42] Scott, p. 10.
[43] Ibid.
[44] Model Child Care Standards Act--Guidance to States to Pre-
vent Child Abuse in Day Care Facilities (Washington: Department
of Health an Human Services, 1985), p. 27.
[45] Ibid., p. 33.
[46] Ibid., p. 5.
[47] Parade, May 26, 1985, p. 16.
[48] Rhodes and Real, p. 76.
[49] Diana R. Gordon, "No Child Abuse, No Adult Abuse," New
York Times, March 2, 1985.
[50] Model Child Care Standards Act, pp. 31-33.
[51] Rhodes and Real, p. 71.
[52] 1983-84 Family Day Care Licensing Study, pp. 15-17.
[53] Rhodes and Real, p. 71.
[54] Ibid.
[55] Joan Maxwell, "Paid-For Love: The Regulation of Small
Family Day Care," paper presented at conference "Child Care in
the United States: Toward a National Consensus," sponsored by
the National Center for Neighborhood Enterprise (Washington,
September 1984), p. 8.
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[56] 1983-84 Family Day Care Licensing Study, p. 4.
[57] Inman, p. 18.
[58] Maxwell, p. 7.
[59] Susan Rose-Ackerman, "Unintended Consequences: Regulating
the Quality of Subsidized Care," Journal of Policy Analysis and
Management 3, no. 1 (1983): 24.
[60] Rhodes and Real, p. 12.
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