Frequently Asked Questions: New Elements in the ACF-801 Report
FOCUS ON QUALITY: NEW ELEMENTS IN THE ACF-801 REPORT
FREQUENTLY ASKED QUESTIONS
Updated May 2013
The Office of Child Care (OCC) has made changes to the required ACF-801 monthly data report. The changes, focused on quality-related information, will allow OCC and Lead Agencies to capture child-level data on provider quality for each child receiving a child care subsidy. The OCC will be able to use the data to track the overall quality of the providers within a State or Territory over time. This is a key component of the Administration’s efforts to help more children in low-income families access high quality care. Working with grantees to track this information will provide a key indicator on the progress being made toward that goal and will help inform both quality investments and subsidy policies to create continuous improvement over time.
The OCC has been introducing the new elements to key stakeholders – Federal staff in both the Central and Regional Offices, State System Specialists and other CCTAN partners, and CCDF grantees responsible for submitting the report. During these discussions, a number of questions have been raised that required further guidance and clarifications. These questions and OCC’s responses are presented below.
QUESTIONS ABOUT ACF-801 QUALITY ELEMENTS
Q1: What are the exact dates by which these new elements must be included in the ACF-801 monthly report?
A1: There are different types of changes, some requiring only clarifications to the submitted information, and some requiring actual changes to the content and format of the report. Based on the type of change, there are different implementation dates:
- Footnotes on the type of hours reported are required beginning October 2012.
- Grantees are encouraged to begin reporting the new quality information beginning with the October 2012 report.
- New quality elements (including unique provider IDs) are required to be included on the ACF-801 report beginning with the October 2013 report. The State must report quality data (at least one of the quality data elements) for at least a portion of the provider population.
- Provider counts must be included in the header record when the grantee begins reporting the new provider and quality information. Provider counts are not required prior to the inclusion of provider and quality information.
Q2: The instructions indicate that States must report at least one of the quality data elements 33-37 (for at least a portion of the provider population). What does this mean? Can a State answer NA for every provider? Can a State satisfy the requirement by reporting only item 33 (QRIS participation status)?
A2: The addition of the new quality data elements allows both OCC and States to track what kind of care children with CCDF subsidies receive. This data will be used to continually improve the quality of care and to target CCDF investments. OCC understands that this will be an incremental process for States without well-developed quality measurement systems, so the new quality data elements were chosen and designed to allow all Lead Agencies to use the new format regardless of the status of their quality system. This offers a broad enough range of questions and responses so that all States, including those without QRIS, will be able to report program-level quality information. It is important to note that no individual quality element (questions 33-37) is required. If a State does not find a particular quality element useful, and would prefer to report using one of the other questions, the State may report “NA.” However, it is expected that the State will be able to, at minimum, report one of the quality data elements for at least a portion of their provider population.
It is not acceptable to answer “NA” for all quality data elements (33-37) for all providers. This means that for at least one of the quality data elements, the State must provide a response other than “NA” for at least a portion of the provider population. (Note: Since data elements 33 and 34 are both about QRIS, if the State chooses to report on QRIS, it must report on both elements.)
Q3: The instructions indicate that the State/Territory must be able to report quality data for at least a portion of the provider population. What minimum proportion of the provider population must be reported?
A3: OCC has not established a specific threshold at this point. The goal is for grantee reporting to be as comprehensive as possible and the expectation is that grantees will be able to report on at least one of the quality data elements for at least a portion of their provider population. OCC will monitor the situation once reporting begins.
Q4: Given that this is monthly reporting, how often does the provider-related quality information need to be updated?
A4: The quality elements (33-37) ideally will reflect the quality rating or indicator that is in place at the time of service in the month reported on the ACF-801. However, OCC recognizes that each State has different assessment and monitoring schedules and understands that there will be variation in how often the quality measures are validated. Taking this variation into account, the State should report the most recently available data for the report month. If a provider’s quality rating (e.g., QRIS level) changes, this should be revised in the provider record as soon as possible.
Q5: Do grantees reporting sample data need to report provider records (i.e., unique provider IDs and quality information) for all providers serving CCDF children in the State/Territory, or only providers associated with children in the current month’s sample?
A5: Grantees reporting sample data are only required to include provider information records (i.e., unique provider IDs and quality information) for those providers associated with children in the current month’s sample. The provider count included in the header record should include all providers, not just those in the sample.
Q6: In the ACF-801 provider record, what is the difference between FEIN, SSN, and Unique State ID, and how is each one used?
A6: OCC believes that it is critical for States to have unique provider IDs for child care providers—whether the FEIN, a State-specific number, or other identifier. The unique provider identifier will allow both the State and OCC to link any given child receiving CCDF with the new ACF-801 provider record containing information on the quality of care. It also helps provide a mechanism for linking the provider to other State systems (such as licensing, State pre-K, etc) to promote integrated data that provides a comprehensive picture of early care and education services. It can also support State efforts to ensure compliance with health and safety requirements (by linking the provider to licensing), as well as fraud detection and improper payment efforts (for example, by seeing if a provider is submitting payment requests to multiple counties in a county-administered State). By including the unique provider identifier as part of the ACF-801 case record, OCC will be able to generate an accurate, unduplicated count of providers participating in the CCDF program for full population States. In addition, this data can be used to support important analyses—such as tracking the duration and spells of care by specific providers (since continuity of care is critical to children’s development and learning).
In order to be able to identify and track providers over time, a unique identification number must be included for each provider (and, in the case of providers who operate in multiple locations, for each location). Grantees will provide this unique identification in both the Setting Information section of each family record (Elements #29 and/or #30), and in the Provider Information record (Elements #31 and/or #32). Identifiers that are reported must be consistent across reporting periods so that activities of each single provider can be tracked over time.
Element #29 and #31 (FEIN) – If a provider has a FEIN that identifies them for tax and other recordkeeping purposes, it must be entered in this field.
This identifying FEIN should be “location specific.” That is, if a provider offers child care services only in one location (e.g. one single Center, or one Family Home), this number will inherently identify that location. If a provider operates in multiple locations (e.g. a corporation with multiple Centers), and the FEIN is for the corporate entity, then this number would not be considered “location specific” because it does not identify which of the multiple centers provided care to each child. In this case, elements #30 and #32 also must be completed.
Element #30 and #32 (Unique State Provider ID) – In the absence of a “location specific” FEIN, a grantee-defined unique identification number is required. This may be a Social Security Number, if the State chooses. The unique ID must be location specific. OCC encourages, but does not require, grantees to use unique identification numbers that can be linked with other early care and education programs to support data integration and service coordination.
Q7: In Element #33, are all rated providers considered participating in the QRIS? For example, if a State automatically assigns all licensed providers a Level 1 rating, does that mean that they are participating?
A7: Yes, all providers who have a rating are considered participating in the QRIS. Even if providers have been automatically assigned a rating without applying or receiving support through the QRIS system, they are considered participating and should be reported on the ACF-801.
Q8: Is a provider considered participating in the QRIS if they have decided to be rated but have not yet been assigned a rating?
A8: Yes, providers who have agreed to be rated but have not yet been issued a rating are also considered to be participating in the QRIS. For example, some states provide quality improvement supports for a number of months before the program is rated. Programs receiving these pre-rating supports are considered QRIS participants.
The state would still need to answer Element #34, using a 3 digit code to reflect that the provider has not yet been rated. OCC recommends that all grantees use the standard code “888” to reflect a provider that has agreed to participate in your QRIS but has not yet been rated.
Q9: In Element #34, where can one find this 3 digit QRIS rating code?
A9: This is a code that the Lead Agency develops itself, based on the State’s QRIS rating system. The Lead Agency can create up to a 3 digit code for each rating level. For example, GOL = Gold, SIL = Silver, BRO = Bronze, or 1 = 1 Star, 2 = 2 Stars, 3 = 3 Stars, 4 = 4 Stars, 5 = 5 Stars. The Lead Agency can determine whatever code works best for its QRIS. The Lead Agency must include a footnote to indicate the level of quality each code represents. The footnote does not have to include detailed information or descriptions on what quality indicators or criteria are associated with each level of quality.
Q10: The State would like to report on Accreditation, but very few providers in the State participate. How should the State report on this data element?
A10: For participating providers, the State should indicate the appropriate level of Accreditation: National, State, Other, or Unavailable. For providers who do not participate, it is acceptable for the State to answer “No.” This answer would still be a measure of quality.
States must report on at least one quality data element for a portion of their provider population. Accreditation status is one of several options available to States, and if it is not a useful measure, States may report “NA” for this element and report on another quality data element instead.
Q11: In Element #36, what does OCC specifically mean by Pre-K standards? Would these be standards determined by the State/Territory?
A11: Like all new ACF-801 data elements on the quality of care (e.g., QRIS level, State-Defined Quality Measure, etc) this element is State-defined. Because there are no Federally-mandated program-level quality standards for child care programs, each State will report using its own standards. Similarly, since Pre-K standards vary by State, there is no standard definition; each State will determine how to define and use this data element. The element provides an opportunity to document whether or not a given provider is subject to Pre-K standards established by the State or locality. This element was included to provide States, particularly States without QRIS, an alternative approach for reporting program-level quality information. If a State does not find the element useful, and would prefer to report using one of the other quality data elements, the State may report “NA” for this element.
Q12: What are some examples of a “State-defined Quality Measure?”
A12: This field is available for States to report any State-defined quality measures other than QRIS, accreditation, or Pre-K standards. For example, if a State conducts reviews using environmental rating scales, it may report “Yes” for providers scoring above a State-established threshold and “No” for providers scoring below that threshold. As another example, if a State establishes certain structural quality indicators (e.g., staff/child ratio, group size, workforce training/education), the State may report “Yes” for providers meeting the indicators and “No” for providers not meeting the indicators. Beyond these two examples, States may have other approaches.
Q13: Will the Child Care Data Viewer software be updated to include these new quality elements?
A13: Yes, the Data Viewer will be updated and a new version will be distributed in early FFY 2013 to coincide with the optional submission period for the new provider and quality elements.
Q14: Does the Lead Agency report the provider IDs, provider quality information, and provider counts in the header record for providers that received a payment during the report month, or that delivered services during the report month?
A14: These elements should be reported for child care providers that delivered services during the report month--i.e., providers paid with CCDF funds (or expected to be paid) for care of the child that occurred during the report month.
Q15: Are States subject to penalties/sanctions for failure to report the new data elements after October 1, 2013?
A15: Yes, the law provides that the Secretary of Health and Human Services may impose sanctions on a Lead Agency for non-compliance with any requirement of the CCDF program. These sanctions may include a penalty of not more than four percent of the discretionary funds for a fiscal year. Lead Agencies failing to provide reports may be subject to this penalty or other sanctions (see 45 CFR 98.92).
Although there are sanctions in place, OCC wants to ensure that all Lead Agencies have the support and capacity to report on the new data elements starting October 1, 2013. More than half the States have implemented statewide QRIS, and many others have alternate ways of measuring quality. There are numerous TA resources available to assist. States and Territories are encouraged to contact their Regional Program Managers with any questions or concerns.
QUESTIONS ABOUT OTHER REPORTING CLARIFICATIONS AND REQUIREMENTS
Q16: The newly released guidance also includes clarification of requirements for reporting hours of care, and includes a required footnote to describe the way the grantee is capturing and reporting hours. By what date does this footnote have to be included in the monthly report?
A16: Grantees may begin including the footnote immediately, and it must be included beginning with the October 2012 report.
Q17: Regarding the licensing clarifications, what constitutes monitoring? Some grantees have providers who are subject to differing sub-sets of inspections (e.g. Fire Marshall inspections and background checks which are documented by the State/Territory). Would these activities be considered monitoring and thus put these providers in the category of being licensed/regulated?
A17: No, these activities would not be sufficient to be considered monitoring because of their narrow scope. CCDF regulations (45 CFR 98.41) include a more comprehensive set of health and safety requirements, which incorporate elements such as, the prevention and control of infectious diseases. The purpose of the clarifying new language in the ACF-801 instructions was to ensure that providers reported as being licensed/regulated meet state-established health and safety standards and are subject to monitoring. Previous reporting instructions provided little guidance on the definition of “Licensed/regulated,” which raised questions about how data reported by States should be interpreted, particularly given wide variation in State licensing/regulatory terminology and process. The goal of this clarification is to provide a minimum baseline that ensures a basic level of cross-state consistency in how the term is defined for data reporting purposes.
OCC has not defined “monitoring” for purposes of reporting on the ACF-801. At a minimum, there must be some type of documentation or verification of the state-established health and safety standards, beyond self-certification by the provider.
If you have other questions about the program and policy guidance related to the quality elements, contact your OCC Regional Program Managers: http://www.acf.hhs.gov/programs/occ/resource/regional-child-care-program....
If you need technical support as you prepare your system to include the new data elements, contact the National Center on Child Care Data and Technology (NCDT) (firstname.lastname@example.org).