The National Association for Family Child Care (NAFCC) is concerned about the impact the Child Care Development Fund (CCDF) Final Rule will have on family child care educators, the families they serve, and the long-term stability of the child care system. While we welcome opportunities for the Department of Health and Human Services to provide states with flexibility and support family choice—particularly when those efforts strengthen inclusion across all child care settings, especially home-based family child care—these changes roll back important advancements that strengthened the stability and accessibility of our child care subsidy systems. As a result, families may face fewer child care options that meet their needs, and the already fragile early childhood workforce could experience further strain and instability.
The final rule removes several federal policy provisions that were intended to create greater consistency and stability within child care subsidy systems. Specifically, the rule rescinds provisions related to enrollment-based payments, prospective payments, and the use of grants and contracts to sustain and expand child care supply in underserved communities. This new rule also reverses the federal cap on family copayments, making child care less affordable for low-income families.
With federal guidance rescinded by the new rule, states will determine whether and how to implement payment practices such as enrollment-based reimbursement, prospective payments, and supply-building strategies through their individual CCDF state plans. As a result, access to stable payment policies and affordable child care assistance will vary significantly from state to state.
For family child care educators, these policy changes carry serious implications. Predictable payment practices are often the difference between remaining open and closing their doors. Family child care educators continue to pay rent or mortgages, utilities, food costs, insurance, staffing, and supplies regardless of whether a child is absent on a given day. Attendance-based reimbursement systems shift financial risk onto educators who are already subsidizing the child care system with their own labor and personal resources.
NAFCC’s 2025–2026 Annual Survey revealed an unsustainable situation: 35% of family child care educators reported earning less than $10 an hour despite 71% working 50 or more hours per week. Family child care educators ranked access to benefits, including retirement, paid time off, and healthcare, as the top three personal and business challenges, whereas managing paperwork ranked sixth. Reducing unnecessary administrative burden can provide some relief, but streamlining paperwork alone does not address the larger challenges threatening the sustainability of the field: inadequate compensation, unstable payment practices, and limited access to benefits and economic support.
NAFCC encourages states to continue prioritizing policies that strengthen payment stability, sustain child care supply, and support the economic viability of family child care programs. Administrative efficiency should strengthen the child care system, not weaken the financial foundation of the workforce holding it together. Family child care educators and advocates can find resources for state-level advocacy on these policies here.
Family child care educators are essential infrastructure for working families and communities across the country. They provide care during nontraditional hours, serve rural, underserved, and native communities, care for infants and toddlers, and offer culturally responsive environments that many families rely on because other options are unavailable or inaccessible.
Any efforts to promote flexibility within the child care system must also prioritize increased and sustained investment in child care, the long-term stability of the workforce, and the protection of access to care for the families who rely on it every day.
About the National Association for Family Child Care
The National Association for Family Child Care is the leading national membership organization dedicated to promoting high-quality early learning through home-based child care. NAFCC advocates for family child care educators and works to strengthen the profession through policy, professional development, and accreditation.
