Will States with a 6 month eligibility re-determination period have to change to 12 months?

Yes, all States and Territories will be required to certify in their FY 2016-2018 CCDF Plan that they have a 12-month re-determination period for CCDF families.  Establishing a 12 month eligibility period is one of the most significant areas of change made by Congress and is a priority for ACF.  For States that cannot certify compliance with this requirement by the time Plans become effective, ACF may allow the State to submit a justification for why they are not in compliance with the policy (e.g., need to get approval of the State legislature or engage in rulemaking process) and to submit a State-specific timeline for when they will have the policy fully implemented which may not go beyond September 30, 2016.  However, ACF expects States and Territories to take steps to expedite implementation of this important policy change as quickly as possible.

(Reference: CCDF-ACF-PI-2015-02; Section 658E(c)(2)(N))