How will ACF determine compliance?

ACF will determine compliance with requirements in the new law through submission and approval of the FY 2016-2018 CCDF Plans and other appropriate means, including site visits to States.  Submission and approval of the Plan is the primary mechanism by which ACF works with Lead Agencies to ensure State and Territory programs meet federal requirements.  Reauthorization of CCDF brings about a number of changes, some of which are straightforward to implement, and others that are more complex and will take time to put in place.  The level of effort needed for implementation will vary depending on the number of changes a State needs to make.  Some States and Territories will need time to enact changes through their State legislatures or rulemaking processes.

Therefore, if a State or Territory provides justification for why it cannot certify compliance with one or more of the new requirements at the time of submission of its FY 2016-2018 CCDF Plan, ACF may allow the Lead Agency to submit a State-specific timeline for achieving compliance with such provision(s).  The timeline must provide sufficient information to support approval of the Plan for funding.  ACF expects the need for additional time would be limited to provisions that require significant policy revisions or implementation efforts by the Lead Agency.  For all provisions that do not otherwise have a statutorily-specified effective date (i.e., provisions in the bulleted list above) the timeline for implementation may not go beyond September 30, 2016.