APHSA and NASCCA comment on the proposed CCDF rule “Restoring Flexibility”

APHSA and NASCCA comment on the proposed CCDF rule “Restoring Flexibility,” expressing support for affordability, access to quality care, and provider stability while emphasizing the operational realities states face. We support the rescission of several 2024 final rule requirements because states warned those mandates—without added funding—could reduce access for families and create implementation challenges. In this letter, we argue that flexibility must come with clarity and respect for state policy choices, while encouraging continued partnership to strengthen CCDF without creating unintended burdens that could reduce the number of families served.