Additionally, such requirements limit the extent to which the significant proportion of the low-income
labor force that works part-time can get help paying for child care (if the minimum is set high).
Eliminating or reducing minimum hour requirements for eligibility can reduce access barriers and allow
for maximum eligibility for low-income working parents.
Job Schedules and Hours
There is no federal requirement that agencies document or verify parents’ job schedules or hours.
States vary in their policies on the collection of job hours and schedule information. In practice, states
gather information on the number of work hours for multiple reasons. They may use the information to
restrict eligibility (as in the case of minimum hour requirements) or they may use the information to
determine how much care they will authorize (for example, part-time or full-time or a specified number of
hours). It’s possible to ask clients the number of hours worked (or an average number of hours) to
determine authorization for child care without restricting eligibility.
In addition to hours, some states require clients to document actual job schedules or verify schedules with
employers. Others allow families to report the hours worked if necessary and to establish a child care
schedule that meets their needs. Job schedule verification is difficult on multiple fronts. Unpredictable
and fluctuating schedules, or working multiple jobs, can make verification challenging. If parents are
required to resubmit work schedules every time their schedule changes, retaining child care assistance
becomes untenable. Depending on employers to submit or verify work schedules can also contribute to
processing delays even for workers with stable schedules.
Overall, this single verification requirement can result in significant administrative burden and processing
delays—both in trying to verify job schedules, and in dealing with changes in work once the family is
receiving subsidies. Rhode Island, for example, identified the collection of job schedules as a primary
requirement contributing to churn in the child care subsidy system. Job schedules were difficult for clients
to provide and the absence of a job schedule resulted in denials and delayed authorizations for otherwise
eligible families. While Rhode Island still requires parents to self-report job schedules, it was able to
significantly improve subsidy processing times by removing its verification requirement for job
schedules, and improving its business processes.
States should eliminate job schedule verification requirements, allowing families to self-report hours
worked if necessary. States that maintain job schedule verification requirements should consider how
parents with volatile schedules access child care subsidies and ensure caseworkers are instructed on
appropriate methods for authorizing care for these parents.
Matching Work Hours to Child Care Hours
There is no federal requirement that parents’ work hours match the number of child care hours
authorized, or that parents’ work hours match children’s hours in child care. Some states require a
precise match between the hours of child care authorized and the parents’ hours of work. The federal
Office of Child Care has clarified that states are not restricted to limiting authorized child care based on
the work, training, or educational schedule of the parent.
Moreover, the updated CCDBG law encourages
states to support the fixed costs of care and generally accepted payment practices for providers. While this