Overview of Proposed Revisions to ACF-801

New Data Elements:

• Provider Federal Employee Identification Number (FEIN) or other Provider Unique State ID (Questions 29-32): The Lead Agency will have a choice of which Unique Provider ID they provide.  This ID will allow OCC to connect the current 801 records with the new Provider Record. 

Note: The Provider ID questions are repeated on the new format (once in the Setting Record, and once in the Provider Record).  This duplication is the mechanism that allows the new quality information to be connected to the case-level information.

• Quality Rating and Improvement System (QRIS) Participation and Rating (Questions 33-34): If the Provider is participating in a QRIS, then the Lead Agency would indicate the Provider’s rating using a 3 digit-alphanumeric code.  The Lead Agency would include the key for the alphanumeric code in a footnote.
• Accreditation Status (Question 35): This would include National, State, or other levels of Accreditation.
• State or Local Pre-k Standards (Question 36): We chose “subject to” instead of “meeting” to simplify the data collection process at the State/Territory level.
• Other State Quality Measure (Questions 37): This data element would offer States/Territories that have not yet implemented a QRIS the flexibility to report other quality measures.

Note on Use of Data: While the new data elements will provide valuable quality information, the variability between QRIS systems and other quality measures will limit the ability to make comparisons across States or to generalize at a national level.   The data, however, can be used to track the overall quality of providers within a State over time, and can be used by a State to inform its quality improvement and subsidy management efforts.

Data Collection and Timeline: In order to allow States/Territories the necessary time to make adjustments to their data systems, OCC is proposing a phased-in approach to the implementation of these new revisions.  The general timeline is as follows: 

• Summer 2011: Release for Public Comment
• Late 2011: Release for Second Public Comment and OMB Review
• Spring 2012: Final Approval of New Format
• 10/1/12: Optional Submission (Current and New Formats Accepted)
• 10/1/13: Mandatory Submission  (Only New Format Accepted)

Starting October 2012, OCC will accept both ACF-801 formats (current and new).  This will allow for a transition period as Lead Agencies make the necessary adjustments to their data collection systems.  While submission will not be mandatory until October 2013, States that are able to use the new format are strongly encouraged to do so during the optional submission year. 

FLEXIBLE QUESTION DESIGN: Questions are designed to allow for multiple negative/NA responses so all Lead Agencies will be able to use the new format regardless of the status of their quality system.  The intent is to offer a broad enough range of responses so that all States will be able to report.

For example, the question “Is the Provider Participating in a Quality Rating and Improvement System?” offers the following response options:

Note: While the new quality data elements do offer States a wide range of responses (including the ability to answer “NA” for each question), it is expected that the State will be able to report at least one of the quality data elements for at least a portion of their provider population.

OTHER REVISIONS: In order to improve or refine current data elements, OCC also made the following revisions to the ACF-801:

• New Data Element: A new data element, “Total # of providers that delivered child care services during the report month,” will be added to the Header Record.  This data element is not directly related to quality, but will provide valuable information for States that provide sample data instead of full population data.
• Refined Definition of Licensed/Regulated: The definition of “regulated provider” was clarified to include the provision that “In order to be counted as a regulated provider, the provider must meet State-established health and safety standards and be subject to monitoring (i.e. self-certification by the provider without documentation or verification is not sufficient).”  This clarification was made to ensure that providers listed as regulated are meeting minimum standards.
• Total Hours of Care Provided in Month: Feedback from States indicates that this data element  is not being reported uniformly, with States reporting authorized hours, actual hours, or a combination of the two.  For the time being, OCC will allow States to continue reporting as they have been, but will now require a footnote indicating the type of hours being reported.  We recognize that this approach will result in non-uniform data across the States, so we will consider the pros and cons of moving toward a more uniform approach in the  future.

INVITATION TO COMMENT: The Office of Child Care invites States/Territories to review and comment on the proposed revisions.  While all feedback is welcome, OCC would like to specifically invite comment on the following topics:

• Unique Provider ID: Would your State/Territory be able to provide a Unique Provider ID within the reporting parameters outlined here?
• Range of Responses: Does the range of response options for the new quality questions cover all possible scenarios?  The OCC attempted to develop a comprehensive set of response options to cover all possible scenarios, but if your State would not be able to respond  using the current response options, please note this through public comment.
• Other State-Defined Quality Measure: This open-ended question was included to ensure that States without a robust QRIS would still be able to report the quality measures being implemented.  If your State/Territory would utilize this question, OCC would like to know the nature of the other quality measures that would be reported.