image Visit coronavirus.govVisit disclaimer page for the latest Coronavirus Disease (COVID-19) updates.
View ACF COVID-19 Responses and Resources
< Back to Search

Letter regarding IM-ACF-OA-2020-01

Published: May 14, 2020
Categories:
Program Administration
Topics:
Current Guidance
Types:
Guidance

Dear CCDF Lead Agencies:

Attached for your awareness is Information Memorandum IM-ACF-OA-2020-01 issued by the Administration for Children and Families (ACF) on grant flexibilities for human service activities related to, or affected by, COVID-19. This Information Memorandum provides short term relief for administrative, financial management, and audit requirements under 45 CFR Part 75 (the HHS implementation of the Office of Management and Budget’s (OMB’s) 2 CFR Part 200), Uniform Administrative Requirements, Cost principles and Audit Requirements for Federal Awards).

Only certain parts of 45 CFR Part 75 apply to the Child Care and Development Fund (CCDF) program (see Program Instruction CCDF-ACF-PI-2015-01). Specifically:

  • Subpart A, “Acronyms and Definitions,” is applicable.
  • Subpart B, “General Provisions,” is applicable.
  • Subpart C, “Pre-Award Requirements,” is not applicable except 45 CFR 75.202 (2 CFR 200.202) is applicable.
  • Subpart D, “Post-Award Requirements,” is not applicable except 45 CFR 75.351, 75.352 and 75.353 (2 CFR 200.330, 2 CFR 200.331, and 2 CFR 200.332) are applicable.
  • Subpart E, “Cost Principles,” is not applicable in its entirety.
  • Subpart F, “Audit Requirements,” is applicable (replaces the provisions of OMB Circular A-133).

With this in mind, below is a summary of how Information Memorandum IM-ACF-OA-2020-01 applies to the CCDF program.

Grant Flexibility from Information Memorandum IM-ACF-OA-2020-01

Applicability to CCDF

1. Flexibility with SAM registration.

CCDF Lead Agencies should already be registered with SAM. Current registrants in SAM with active registration expiring before May 16, 2020, are afforded a one-time extension of 60 days to renew their registration.

2. Flexibility with application deadlines.

At this time, the Office of Child Care is not providing any extension to the deadline for submittal of CCDF Plans.

3. No-cost extensions on expiring awards.

Not applicable. CCDF does not have no-cost extension requirements. Under CCDF law and regulations, CCDF Lead Agencies may request a waiver for extraordinary circumstances related to CCDF obligation and liquidation deadlines.

4. Abbreviated non-competitive continuation requests.

Not applicable. CCDF does not have non-competitive continuation requirements.

5. Allowability of salaries and other project activities.

Not applicable. CCDF Lead Agencies should expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds (45 CFR 98.67(a)). While guidance in Information Memorandum IM-ACF-OA-2020-01 on the allowability of costs is not binding on CCDF, the Information Memorandum provides flexibility to certain other ACF programs related to the charging of salaries and benefits and other costs. CCDF Lead Agencies may want to take this guidance into account when assessing how to expend and account for CCDF funds in accordance with their own laws and procedures. Child care providers who receive ACF grants may not use grant funds for costs that are reimbursed or compensated by other federal or state programs that provide for such benefits, including but not limited to the Small Business Administration’s Paycheck Protection Program, the Public Health and Social Services Emergency Fund, or unemployment compensation.

6. Allowability of Costs not Normally Chargeable to Awards.

Not applicable. CCDF Lead Agencies should expend and account for CCDF funds in accordance with their own laws and procedures for expending and accounting for their own funds (45 CFR 98.67(a)). While guidance in Information Memorandum IM-ACF-OA-2020-01 on the allowability of costs is not binding on CCDF, the Information Memorandum provides flexibility to certain other ACF programs regarding the charging of costs related to the cancellation of events, travel, and other activities due to the public health emergency. CCDF Lead Agencies may want to take this guidance into account when assessing how to expend and account for CCDF funds in accordance with their own laws and procedures.

7. Prior approval requirement waivers.

Not applicable. CCDF does not have requirements related to prior approval of allowable costs, with the exception of prior approval for construction and major renovation for Tribal Lead Agencies, and for Supplemental Disaster Relief funds (unrelated to COVID-19). The Office of Child Care does not intend to waive the pre-approval requirement for construction and major renovation.

8. Exemption of certain procurement requirements.

Not applicable.

9. Extension of financial, performance, and other reporting.

The Office of Child Care will allow State and Territory CCDF Lead Agencies to delay submission, for up to three months beyond the normal due date, of (1) quarterly expenditure reports for States and Territories (ACF-696) for the quarters ending March 31 and June 30, 2020 and (2) monthly case-level administrative data reports for States and Territories (ACF-801) for months through June 2020. See Figure 1. CCDF Lead Agencies do not need to seek approval for this extension, but should maintain documentation of the reason for the delayed filing. At this time, OCC does not believe an extension is needed for the State/Territory annual aggregate administrative data report (ACF-800), Quality Progress Report (ACF-218), Tribal Annual Report (ACF-700), or Tribal Expenditure Report (ACF-696T) since those reports are not due until the end of the calendar year.

10. Extension of currently approved indirect cost rates.

Not applicable. CCDF does not require indirect cost rates to be approved by HHS. Under 45 CFR 98.57, the CCDF Lead Agency and subgrantees shall keep on file indirect cost agreements, as appropriate. Approval of the indirect cost agreements is not specifically required, but the agreements are subject to review.

11. Extension of closeout.

Not applicable. Uniform closeout procedures do not apply to CCDF.

12. Extension of Single Audit submission.

ACF is allowing CCDF Lead Agencies and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse and that have fiscal years with ending dates through June 30, 2020, to delay the completion and submission of the Single Audit reporting package to six months beyond the normal due date. CCDF Lead Agencies and subrecipients do not need to seek approval for this extension, but should maintain documentation of the reason for the delayed filing.

 

Figure 1: Data Reporting Extensions

Report Frequency

ACF-696 Expenditure Report - Quarterly

ACF-801 Case Level Report - Monthly or Quarterly (Lead Agency’s Choice)

Reporting Periods

1.Oct 1 – Dec 31

2.Jan 1 – Mar 31

3.Apr 1 – Jun 30

4.Jul 1 – Sep 30

Every month or quarter

Regular Due Date

30 days after end of quarter

For monthly reporting: 90 days after end of month

For quarterly reporting: 60 days after end of quarter

Revised Due Date with Extension

Jan 1-Mar 31 quarterly report will be due July 31

Apr 1 – Jun 30 quarterly report will be due Oct 30

Monthly ACF-801 Submission:

Feb 2020 will be due 8/30/2020

Mar 2020 will be due 9/30/2020

Apr 2020 will be due 10/30/2020

May 2020 will be due 11/30/2020

Jun 2020 will be due 12/30/2020

Quarterly ACF-801 Submission:

Jan-Mar 2020 will be due 8/30/2020

Apr-Jun 2020 will be due 11/30/2020

Sincerely,
/s/
Shannon Christian
Director
Office of Child Care

Last Reviewed: May 27, 2020