Access subsidized child care, child development and community service advocates, eligibility agencies, one university and local government. the comments submitted by the pennsylvania child care campaign pccc ; included support for the rulemaking by 32 child development, provider and community service advocacy organizations, such as united way agencies, pennsylvania association of child care agencies, community legal services, community justice project, pennsylvania partnerships for children and success against all odds, that joined together to show their collective support. although the letter from pccc was one comment letter, the letter represents 45% of the commentators on this rulemaking. discussion of major comments and major changes following is a summary of the major comments received within the public comment period following publication of proposed rulemaking and the department's response to the comments. a summary of the major changes from the proposed rulemaking is also included. general--costs to eligibility agencies the independent regulatory review commission irrc ; noted that the proposed rulemaking may increase the administrative duties of eligibility agencies and the costs of operating the subsidized child care program, based on recordkeeping and verification. should administrative expenses increase, irrc questioned how the eligibility agencies will be reimbursed. response the simplification of the verification process will reduce paperwork and permit time now spent in administrative tasks to be redirected to support more focused counseling and time with families, such as assisting families with verification. in addition, the department will be implementing a new enhancement of the ccmis. the enhancement will automate additional steps of the eligibility determination process including producing written notices to families, producing automated forms for the redetermination process, making provisions to automatically track the dates for eligibility agencies when information is due from parents and calculating income for families. general--funding several commentators and irrc questioned if additional funding is needed to serve the children currently enrolled in the subsidized child care program and how these costs will be funded. response the department is budgeting sufficient carry forward funds for fy 2005-2006 to serve the same number of children as served during the previous year. general--promoting family self-sufficiency and impact on the waiting list several commentators and irrc questioned the goal of promoting family self-sufficiency and how access to care will increase if waiting lists are expanded. response allowing families to include education and training in their hours of work promotes self-sufficiency. adults with higher levels of education have greater earning potential and long-term job security. this final-form rulemaking provides families with incentives to continue to make progress in achieving economic independence. the past practice of permitting families with income up to 200% of the federal poverty income guidelines fpig ; to enter.
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