For millions of families across the country, home-based child care is not a backup option… It is the care that makes work possible. More than 12 million children are cared for in homes by trusted providers, including family child care educators and family, friend, and neighbor (FFN) caregivers, who offer flexible schedules, cultural and linguistic connection, and deep relationships that families depend on. Yet despite their essential role, these providers continue to face low compensation, unstable income, and systemic barriers to fully participating in public child care programs.
As federal policymakers consider changes to the Child Care and Development Fund (CCDF) through the U.S. Department of Health and Human Services’ 2026 Notice of Proposed Rulemaking, Restoring Flexibility in the CCDF, the stakes for families and providers could not be higher. The proposed rule would roll back important 2024 reforms that were specifically enacted to stabilize provider payments, strengthen financial sustainability, and improve the economic well-being of child care providers. In response, Home Grown submitted public comments urging the Administration to ensure that any changes build on, rather than dismantle, these recent gains, and that they strengthen, rather than weaken, access to child care and the stability of the home-based workforce. Our recommendations center the lived experiences of providers and families and focus on protecting affordability, access, and long-term sustainability.
Two Core Issues About Payments and Reimbursements
The proposed rule would roll back key protections established in the 2024 CCDF final rule, specifically designed to bring greater stability to a chronically underfunded sector. The 2024 rule required states to move toward enrollment-based and prospective payments to give providers predictable, timely compensation. The 2026 proposal would instead allow states to revert to attendance-based payments and reimbursement models, once again shifting financial risk onto providers. For home-based providers with fixed monthly expenses, these changes would mean unpredictable income and renewed threats to program sustainability.
That is why preserving the 2024 reforms is not simply a technical policy decision, it is a matter of economic survival for providers and access for families. Home Grown strongly urges the Administration to maintain prospective, enrollment-based payments and ensure reimbursements are issued within seven days of a completed invoice. Providers should be paid for maintaining available slots, not penalized for child absences beyond their control. Predictable, timely payments are fundamental to keeping providers in the field and ensuring families can rely on a stable child care system.
Grants and Contracts Expand Access for Underserved Communities
The Notice of Proposed Rulemaking also eliminates the requirement that states use grants or contracts to deliver direct services for children in underserved areas, including infants and toddlers, children with disabilities, and families in rural communities. Grants and contracts are a proven strategy for stabilizing provider revenue, encouraging supply growth, and expanding parent choice where care is scarce.
Home Grown urges HHS to retain the 2024 requirement for grants and contracts and to fully fund CCDF so states can continue using these tools to address child care deserts and better meet community needs.
Keeping Child Care Affordable for Families
The proposed rule also removes the 7% cap on family copayments established in the 2024 final rule. This change risks increasing out-of-pocket costs for families already struggling with the high price of child care and could discourage participation in CCDF altogether. Families with multiple children receiving subsidies would be particularly harmed.
Maintaining the 7% cap is critical to ensuring CCDF remains an effective tool for supporting working families while preventing providers from absorbing the cost of reduced family payments.
A Call to Protect Home-Based Child Care
Home Grown envisions a child care system that values home-based child care as a high-quality, essential option for families and communities. We urge policymakers to preserve the strongest elements of the 2024 CCDF final rule, center the experiences of providers and families, and fully fund CCDF to support meaningful implementation. These decisions will determine whether CCDF strengthens child care access — or further destabilizes a workforce and system already under strain.
