Nov. 6, 2020 —
R 061200 NOV 20
FM COMDT COGARD WASHINGTON DC//CG-11//
TO ALCOAST UNCLAS //N01000//
SUBJ: COVID-19: COAST GUARD CHILD DEVELOPMENT SERVICES OPERATIONS DURING THE COVID-19 PANDEMIC UPDATE 1
A. COMDT COGARD WASHINGTON DC 202115 MAR 20/ALCOAST 099/20
B. Child Development Services Manual, COMDTINST M1754.15 (series)
C. Coronavirus Aid, Relief, and Economic Security Act (CARES Act) Public Law 116-136, March 27, 2020.
D. Coast Guard Non-Appropriated Fund (NAF) Personnel Manual, COMDTINST M12271.1 (series)
1. This ALCOAST cancels REF (A) and establishes updated guidance for the operation of Coast Guard Child Development Centers (CDC) in the current pandemic environment. We will continue to adjust our policies in order to ensure that the Coast Guard remains agile and adaptive to changing circumstances and Commanders have the flexibility necessary to achieve our service’s overall objectives as regional conditions change, state and local mandates fluctuate, and expert guidance evolves.
2. Child Development Centers, Family Child Care (FCC) Homes and Youth Programs (YP) should resume operations at Pre-COVID capacity to the greatest extend possible in support of workforce readiness. These are vital services essential to those who conduct and support our many missions.
3. Coast Guard-operated CDCs and FCC homes within the Child Development Services (CDS) program must implement and maintain the most up-to-date standards and guidance for child care operations from the following sources:
a. Centers for Disease Control and Prevention; b. Current Coast Guard ALCOASTS;
c. Child Development Services Manual, COMDTINST M1754.15 (series); and
d. State Family Child Care Home license requirements.
4. Commands with CDCs and FCC must continue to employ the following practices to maximize resilience and efficiency of our child care services during the COVID-19 pandemic:
a. Provide health and temperature screenings for staff, visitors, parents or guardians and children before allowing them into the program;
b. Follow social distancing strategies: staggered arrival and departures, maintain same group of children and same group of care givers within a room (when possible), practice one-way traffic in hallways, stagger groups on playgrounds, gross motor rooms and cohorting;
c. Increase daily routines for cleaning, sanitizing and disinfecting surfaces to include: room environments, toys, lesson plan materials, furniture, fixtures and equipment; d. Increase daily routine for laundering: sheets, towels, blankets and masks;
e. Ensure hands are frequently cleaned using soap and water, or hand sanitizer if soap and water are not available;
f. Ensure face coverings are properly worn by all adults at all times while in the program, except when eating or hydrating;
g. Ensure face coverings are worn by all children two (2) years old or older while in the program except during snack and meal times, when hydrating, during nap time, and outside when physical distancing measures can be implemented. h. Minimize visitors 5. Coast Guard-operated CDCs and FCC Homes within the CDS programs should return to full services based on facility or home capacity or adjusted COVID-19 maximum capacity. IAW guidance from Centers for Disease Control and Prevention the following activities are not permitted:
a. Group events/celebrations/gathering;
b. Field trips;
c. Family-style dining (staff/provider will plate food for children);
d. Teeth brushing; e. Use of sensory tables;
f. Use of plush toys; g. Use of shared consumables (pencils, crayons, clue, scissors, etc.);
h. Use of volunteers; and i. Closures for in-service training days;
6. The Health, Safety and Work Life, Service Center (HSWL-SC) will resume on-site CDC Quality Assurance Audits (QAA) beginning November 2020. QAA will not be scheduled for any CDC listed on the Centers for Disease Control and Prevention’s High Risk Travel locations. The HSWL-SC will provide the parent command of each CDC a formal notification with the specific dates of the audit 45-60 days prior to the audit. The notification will describe the scope of the audit and will identify CDC specific assistance needed. The annual audit certifies compliance with applicable laws, regulations, policies, and directives (ALCOASTs and instructions). The results of the QAA will determine if the center is issued an annual or provisional certificate to operate. The HSWL-SC Technical Directive 2020-08 addresses the roles and responsibilities, procedures and guidance for the completion of the annual QAA. Technical Directives and additional information and resources pertaining to the CDC QAA process is available at: https://cg.portal.uscg.mil/units/hswlsc/work-life_ division/SitePages/Child%20Development%20Services.aspx.
7. Child Development Services Specialists (CDSSs) will resume onsite inspections of FCC homes located in CG owned or leased housing in accordance with REF (B).
8. Child care and virtual public education requirements around the nation, specifically for children twelve (12) years old and younger, continues to be a challenge for our families. Despite the lack of child care and in-person school, all CG-sponsored child care must be approved and conducted in accordance with the policy set forth in REF (B). Ensuring that our children are cared for in a safe, healthy, and quality child care environment is our highest priority. REF (B) does not apply to cooperative babysitting services. However, any command who is considering allowing a cooperative babysitting service to operate on its installation should consult with their servicing legal office to understand the associated risks. Commanding Officers in concert with their Morale, Well-Being, and Recreation (MWR) Directors, CDSSs, Family Resources Specialists (FRS), CDC and Youth Center Directors can assist with the following options:
a. CDSSs may recruit and train CG adult family members who reside in government-owned or leased housing to serve as Family Child Care Home Providers and operate a certificated child care home for children 6 weeks to 12 years old, which may include non-traditional care to facilitate virtual school support or irregular shifts;
b. Provide families with information on how to establish and maintain a Parent CO-OP for infant to pre-school, elementary school, middle school, or high school-age children to facilitate virtual school days;
c. Provide families with information on hiring a family helper (middle-school to college-age child) to assist with child care or virtual school days when they are not attending school while the parent teleworks; and
d. Provide families with national, regional and local resources that offer programs and services to military families. These resources include Coast Guard Mutual Assistance (CGMA) grants and loans for: school supplies, tutoring, child care, specials needs, and lost wages. For additional information find your local CGMA Representative at: https://www.cgmahq.org/locations.html.
9. The first priority of all CDCs is to maximize child care capabilities to support CG missions. It is essential that CDCs retain or increase their non-appropriated fund (NAF) workforce to maintain and expand operations to support local units. REF (C) which provides the authority to use FY20 appropriated funds (APF) to support NAF supported programs ends on 11 December 2020. This act provided the NAF supported programs (for example, Coast Guard Exchange, MWR and CDC programs) the authority to use APF to support their NAF employees' payroll and benefits as those NAF programs suffered losses as a result of their reduction in revenues based on mandated closures and services limited to mission essential personnel. While the CG is working to extend this authorization, CDCs must generate sufficient NAF income to cover their NAF payroll, benefits and consumable expenses. Mandated leave concluded on 3 October 2020 and standard payroll and time and attendance, per REF (D), will resume. Child care programs are extremely labor-intensive and payroll is the primary expense that must be monitored and controlled in CDCs. Any furloughs or Reduction in Force (RIF) of CDC personnel must be approved by DCMS. Commanding Officers in concert with their MWR Director and CDC Directors should consider the following options for managing their CDC programs:
a. Infant, pre-toddler and toddler rooms should be filled daily with two (2) ratio groups per room. Fill pre-school rooms daily with one (1) ratio group, and add a second ratio group if the room can be divided into two spaces. If a center has open rooms, they may offer school-aged care for children in kindergarten through 6th grade to support new virtual school schedules. Consider increasing center hours to cover evening and weekend options to accommodate workforces’ child care needs due to virtual school day sessions;
b. When NAF revenue funds have been exhausted, NAF consumable materials may be purchased with appropriated funds. Food, when used as part of an educational lesson, may be purchased with appropriated funds. If NAF payroll and benefits expenses do not exceed the NAF revenue then appropriated funds are not authorized for consumable materials;
c. Consider reducing hours within a given worker category; and d. Consider the ability of local unit NAFI revenue to support temporary shortfalls within CDCs.
10. Any reduction of services that substantially impacts support to members performing mission essential functions, to include the closure of any CDC, must be approved by the Base or unit commander after consultation with the COMDT (CG-1112) CDS program, Senior Medical Executives and Community Services Command via the facility closure process facilitated by the DCMS Watch.
11. Family Child Care providers are considered private business owners and, as such, will determine when it is appropriate to operate their programs, or suspend services. All FCC providers must report closures of their program to their servicing CDSS or HSWL-Regional Practice.
12. The CG Fee Assistance (FA) Program offsets the cost of child care for eligible members with dependents ages six (6) weeks to twelve (12) years old/sixth grade. The assistance is paid to the provider after the sponsor pays the total monthly child care fee, and is not paid in advance. The FA program offsets the cost and does not pay for the sponsor’s portion of the payment, as detailed in the Frequently Asked Questions on the FA Program web site. To find out more information, or to enroll in the FA Program, visit: https://elibrary.cnic-n9portal.net/familyenrollment/community-programs/.
13. Personnel who meet DoD military eligibility criteria for child care may apply for, and request child care through MilitaryChildCare.com (MCC) to access all DOD operated child care as of 1 September 2020. The DOD installations will utilize MCC to manage child care spaces, active care options, accepting or declining care, and waitlist management. Priority for care is administered by MCC based on the eligibility requirements. For additional information on how to create an account go to: https://militarychildcare.com/. To review the new DOD guidance on eligibility requirements, go to: https://public.militarychildcare.csd.disa.mil/mccu/ui/#/priority.
14. Point of contact is Renee L. Podolec, Child Development Services, Program Manager, at (202) 475-5160, Renee.L.Podolec@uscg.mil.
15. RADM P. F. Thomas, Deputy for Personnel Readiness, sends.
16. Internet release is authorized.