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Release of CCDF Plans to Office of Child Care (OCC) Website Frequently Asked Questions (FAQs)

Published: June 30, 2016
Categories:
Child Care Development Fund (CCDF) Reporting
Topics:
States/Territories
Types:
Q&As

Why is the OCC releasing the FY 2016-2018 Child Care and Development Fund (CCDF) Plans?

OCC is releasing these documents to provide transparent information about the direction and activities of Lead Agencies and the CCDF Plans. These CCDF Plans reflect state and territory intentions for implementing the Child Care and Development Block Grant (CCDBG) Act of 2014 at a particular point in time. Many stakeholders have expressed interest in understanding the progress towards the implementation of all new requirements of the CCDBG Act of 2014. 

What items are included in the FY 2016-2018 CCDF Plans?

The following two documents are included in the PDF:

2016-2018 Child Care and Development Fund (CCDF) Plan Conditional Approval Letter – OCC issued a letter with the conditions of approval for each State and Territory regarding their CCDF Plans, and response to any waiver/extension requests. In reviewing plans and waiver/extension requests, OCC gave careful consideration to the statutory conditions outlined in the Act, as well as the length of time requested, with the goal of having all provisions related to the Act fully implemented by October 1, 2018 corresponding to the start of the FY2019-2021 CCDF Plan period. The approval letter covers the CCDF Plan for the period of June 1, 2016, through September 30, 2018.

2016-2018 Child Care and Development Fund (CCDF) Plan - The Plan describes the CCDF program to be administered by the State/Territory  for the period 6/1/2016 – 9/30/2018 as conditionally approved by OCC. The Plan serves as the application for CCDF funds by providing a description of, and assurance about, the grantee’s child care program and all services available to eligible families. As provided for in the applicable statutes and regulations, the Lead Agency has the flexibility to modify this program at any time, including amending the options selected or described. For purposes of simplicity and clarity, the specific provisions of applicable laws printed therein are sometimes paraphrases of, or excerpts and incomplete quotations from, the full text.

How is the CCDF Plan organized?

The CCDF Plan is organized into 8 sections that correspond with key opportunities in the CCDBG Act to develop an integrated system of high quality care for low-income working families. These are:

  • Define CCDF Leadership and Coordination with Relevant Systems
  • Promote Family Engagement through Outreach and Consumer Education
  • Provide Stable Child Care Financial Assistance to Families
  • Ensure Equal Access to High Quality Child Care for Low-Income Children
  • Establish Standards and Monitoring Processes to Ensure the Health and Safety of Child Care Settings
  • Recruit and Retain a Qualified and Effective Child Care Workforce
  • Support Continuous Quality Improvements
  • Ensure Grantee Accountability

What does conditional approval mean?

A “conditionally approved” plan is a fully approved plan with conditions to be met based on waiver requests, if applicable, and implementation and corrective action plans for unmet requirements. The conditions will be deemed fully met once all provisions in the Child Care and Development Block Grant (CCDBG) Act of 2014 are fully implemented.

What are waiver requests?

In the CCDBG Act, Congress gave the Secretary of HHS the option to waive (extend the effective date) new statutory provisions or penalties for States and Territories up to 3 years to allow time to come into compliance or in cases of extraordinary circumstances.  OCC determined that if a State or Territory is not going to be in compliance with one or more provisions by the deadline required in the Act, then the State/Territory must request a temporary extension/waiver as well as complete an implementation plan.  The Act requires that State and Territories submit waiver requests to ACF in writing.  The written request must:

  • detail each sanction or provision that the State seeks relief from;
  • describe how a waiver from that sanction or provision will, by itself, improve the delivery of child care services for children in the State/Territory;
  • certify that the health, safety, and well-being of children served through assistance received through CCDF will not be compromised as a result of the waiver; and
  • describe one or more conflicting or duplicative requirement(s) preventing the effective delivery of child care services to justify the waiver; extraordinary circumstances, such as a natural disaster or financial crisis; or an extended period of time for a State legislature to enact legislation to implement the provision of the Act.

Current waiver requests reviewed by ACF were addressed in the State/Territory conditional approval letter. The OCC expects additional requests to be submitted as States/Territories move forward with implementation. Waiver requests to ACF must be submitted by the designated official authorized to act on behalf of the Lead Agency.  ACF must respond to the State/Territory within 90 days after the receipt of the request.

What was OCC’s approach to reviewing waiver requests?

In reviewing plans and waiver/extension requests, OCC gave careful consideration to the statutory conditions outlined in the Act, as well as the length of time requested, with the goal of having all provisions related to the Act fully implemented by October 1, 2018 corresponding to the start of the FY2019-2021 CCDF Plan period.  Given that one of the statutory requirements was that applicants for waivers certify that the health, safety, and well-being of children served through assistance received through CCDF will not be compromised as a result of the waiver, no waiver requests for Health and Safety Training for CCDF providers were approved.  Those States were placed under a Corrective Action Plan for 1 year to provide time needed to meet the requirement.  Background Check provisions have not yet been considered under this waiver implementation process because the Act provided for a separate extension process for those States and Territories unable to comply by the statutory deadline of September 30, 2017.

Why does the conditional approval of the Plan not constitute a final determination regarding payment rates and equal access?

A top priority of the CCDBG Act is to ensure equal access for eligible families to child care services comparable to those provided to families not eligible to receive CCDF assistance.  In addition, States/Territories were required to take into consideration the cost of providing higher quality child care services than were provided prior to the enactment of the new law in November 2014.  OCC continues to be concerned about payment rates and have plans to conduct a more extensive review and analysis as part of onsite monitoring visits to States and Territories.  OCC recognizes that some states currently have rates in place sufficient to meet the equal access requirement.  Including a focus on payment rates in the conditional approval letter was not to undermine those States but to encourage continued focus on those efforts.

What are the deadlines for implementing the new provisions in the CCDBG Act of 2014?

Those specified in the Act are:

  • November 19, 2016 – Inspection Requirements (inspections for licensed and exempt providers, qualifications, ratio of inspectors)
  • September 30, 2017 –Background Check Requirements
  • November 19, 2017 – Posting the Results of Monitoring on the Consumer Education Website

For all other provisions, the OCC issued guidance that they be in effect by September 30, 2016.

Will OCC continually update these documents to reflect ongoing progress in implementation?

After this initial posting, OCC does not currently have plans to post any changes made to individual State/Territory conditionally approved Plans to the website.  Lead Agencies have the flexibility to amend their program at any time.  All amendments must be submitted to OCC for approval within 60 days of the effective of the change.  We strongly encourage States/Territories to update the public when changes occur to their Plan.

Has a Final Rule been issued to implement the CCDBG Act?

No, the Final Rule is still pending. In the meantime, states and territories were asked to complete their plans using a reasonable interpretation of the statute. Details on the CCDF 2015 Notice of Proposed Rulemaking (NPRM) can be found online.

Who should be contacted if we have questions about the CCDF Plan?

Questions about state plans should be directed to CCDF Lead Agency. Contact information can be found on the CCDF Grantee State and Territory Contacts page.

 

 

 

Last Reviewed: July 12, 2016