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Providers press DCYF workgroup over experience waivers and verification under HB 1648
Summary
The HB 1648 staff‑qualifications workgroup debated how to count and verify experience for waiver eligibility, whether Merit or licensors will verify, and whether family input should inform qualifications. Providers raised appeals process, equity and documentation concerns.
DCYF staff and providers spent a substantial portion of a March 25 provider‑supports meeting on implementation details of HB 1648 and the staff‑qualifications workgroup.
Susie Campbell, staff‑qualifications coordinator, summarized workgroup progress: members favor broadening how experience is recognized, are weighing flexibility and transferability, and plan later sessions on education and training. Campbell said Merit will be enhanced to calculate the five‑year experience threshold and include leadership roles; the system will not require waivers to be sent to Cultivate for manual determinations.
Providers pressed for clarity on who verifies experience and how appeals will work. One attendee asked if Merit alone should determine eligibility; Campbell said the workgroup is still deciding nuances, but Merit is the official employment record and automation is the likely path. Several providers warned that automated denials require a meaningful appeal process. ‘‘We’re going to need a pretty hefty appeal process if it’s an auto‑deny because the computer calculated something,’’ one provider said.
Participants also disputed whether to solicit parent/family feedback about qualifications. Some providers objected that families often lack technical knowledge about staff qualifications and that parent input can be ‘‘weaponized’’ against providers; others suggested anonymous surveys after licensing visits as a lower‑risk way to surface family perspectives.
DCYF and the workgroup said further deliberations will continue, including guest speakers from other states in March and discussion of long‑range issues through 2030. The agency will return with more detailed guidance and noted that some communication to licensing staff remains in draft form to avoid premature confusion.
Next steps: the workgroup will continue defining experience and awarding pathways; DCYF expects to bring clearer verification and communication plans back to provider groups.
