Form ACF-696T— a Financial Reporting Form for Tribal Child Care and Development Fund (CCDF) Lead Agencies

Program Instruction

1. Log No: ACF-OCC-PI-2025-05    
2. Issuance Date: March 18, 2025
3. Originating Office: Office of Child Care
4. Key Words:  Child Care and Development Fund (CCDF); ACF-696T; Financial Reporting Form for Indian Tribes

To:

Tribal lead agencies administering child care programs under the Child Care and Development Block Grant (CCDBG) Act (42 U.S.C. § 9857 et seq.), as amended and other interested parties.

Subject:

Form ACF-696T— a Financial Reporting Form for Tribal Child Care and Development Fund (CCDF) Lead Agencies.

References:

The Child Care and Development Block Grant (CCDBG) Act, as amended (42 U.S.C. § 9857 et seq.); Section 418 of the Social Security Act (42 U.S.C. § 618); 45 C.F.R. Parts 98 and 99.

Purpose:

This Program Instruction distributes the revised Form ACF-696T financial reporting form and instructions for the CCDF Tribal lead agencies.  The Office of Management and Budget (OMB) approved the Form ACF-696T under OMB 0970-0510.

Background:

Tribal lead agencies are required to submit financial reports annually as specified by the Administration for Children and Families (ACF; 42 U.S.C. § 9858m(c)(2)(C), 45 C.F.R. § 98.65). Tribal lead agencies are required to use the ACF-696T to report expenditures for all funding issued under CCDF.

Tribal lead agencies must submit separate annual reports for each fiscal year in which CCDF funds were awarded. Therefore, a Tribal lead agency may be submitting as many as five separate ACF-696T reports this year — one for each fiscal year with an open CCDF grant dating to Grant Year (GY) 2020.

Tribal lead agencies that incorporate CCDF into an approved P.L. 102-477 Plan are typically not required to submit the ACF-696T to ACF, rather these Tribal lead agencies submit financial reporting to the Bureau of Indian Affairs. However, Tribal lead agencies that  incorporate a CCDF program into an approved P.L. 102-477 Plan but have active grants that were awarded directly by ACF must continue to submit the ACF-696T until those awards are closed. Active grants may have been issued from GY20 to GY24.

Spending Requirements: The ACF-696T is used to determine compliance with the CCDF spending requirements set forth in 45 C.F.R. Part 98, Subparts F and I.

Tribal lead agencies must meet quality spending requirements that vary depending on the year that funds were awarded:

• For funds awarded in GYs 2020 and 2021, all Tribal lead agencies, regardless of allocation amount, must spend at least 8 percent of expenditures on quality improvement activities.
• For funds awarded in GYs 2022 and later, all Tribal lead agencies, regardless of allocation amount, must spend at least 9 percent of expenditures on quality improvement activities.

Tribal lead agencies may not spend more than 15 percent of their expenditures on administrative activities.

Tribal lead agencies with medium or large CCDF allocations ($250,000 or more based on GY 2016 allocations) must spend at least 3 percent of expenditures on quality improvement activities for infants and toddlers in addition to the quality spending requirement mentioned above.

Tribal lead agencies receiving a medium or large CCDF allocation must expend a significant percentage of the CCDF Discretionary grant to provide direct child care services for children. After withholding the Discretionary base amount, minimum quality (8 percent for GYs 20 and 21 and 9 percent for GY22 and subsequent years) and infant/toddler quality (3 percent) expenses, and the actual administrative costs (up to 15 percent), Tribal lead agencies must expend 70 percent of the remaining Discretionary per-child amount on direct child care services.  

The spending requirements described above do not apply to the Discretionary base amount, and those funds may be used for any allowable CCDF expense, including administrative costs.

Obligation and Liquidation: Typically, Tribal lead agencies must obligate all CCDF Mandatory and Discretionary funding by the end of the second Federal Fiscal Year following the funds being awarded, and liquidate all CCDF Mandatory and Discretionary funding by the end of the third Federal Fiscal Year following the award. However, many Tribal lead agencies have requested and received extraordinary circumstances (fiscal) waivers for their current, individualized obligation and liquidation deadlines. Tribal lead agencies should refer to their most recent extraordinary circumstances waiver approval letter for their current, individualized obligation and liquidation deadlines.

If a Tribal lead agency is unable to obligate the full CCDF Discretionary award within the required time period, the Tribal lead agency must report in a letter to ACF no later than April 1st of the fiscal year in which the funds are due to be obligated with the dollar amount from the grant that the Tribal lead agency will be unable to obligate by the obligation deadline. These unobligated funds may be reallotted to other Tribal lead agencies. Any Tribal lead agency without an ACF-696T report submission by April 1st of each year for the prior grant year will not be eligible to receive reallotted funds.

In 2024, OCC published an updated CCDF final rule providing Tribal lead agencies with additional time to liquidate funds that are set aside for construction and major renovation. Generally, Tribal lead agencies must obligate all funds set aside for construction or major renovation by the end of the third fiscal year in which the funds were awarded and liquidate by the end of the fifth fiscal year. As the new rule instituted an obligation deadline for construction funds, OCC offered an extraordinary circumstances waiver to Tribal lead agencies seeking to extend the obligation deadline. Tribal lead agencies with construction set asides should reference their extraordinary circumstances fiscal waiver approval letter for specific extended obligation and liquidation dates for their construction funding.

Revisions:

Utilizing Grants and Contracts to Provide Direct Services

The ACF-696T instructions (attachment B) were revised to provide guidance to Tribal lead agencies regarding the use of CCDF funding to utilize grants or contracts with child care providers to expand direct services to children. Lead agencies may consider any funds paid through grants or contracts directly to child care providers for operational, staff, or other costs related to providing direct services for children receiving CCDF subsidies as direct services when completing the ACF-696T. If a grant or contract provides funds to a provider serving both children participating in CCDF as well as other children, the portion of funding dedicated or reserved for services for children participating in CCDF can be counted as direct services. These expenses should be reported in line 4 in the ACF-696T.  Tribal lead agencies are reminded that if the Tribal lead agency operates a CCDF-funded Tribally operated child care center, all staffing and operational costs associated with providing child care to CCDF-eligible children may be considered a direct service expenditure.

Disaster Relief Funding

The revised ACF-696T includes reporting in Column F for Disaster Relief Funds awarded through the 2023 Consolidated Appropriations Act (Pub. L. No. 117-328), for Tribal lead agencies to address impacts of Hurricanes Ian and Fiona.

Retroactive Requests to Set Aside Funding for Construction and Major Renovations

In June 2024, OCC offered Tribal lead agencies the opportunity to retroactively request to use CCDF funding for construction and/or major renovations. Funds set-aside for construction and major renovations through the retroactive requests retain the obligation and liquidation dates of their originating funding stream, and do not adopt the obligation and liquidation dates of other funds that have been set-aside for construction and major renovation through the typical annual set-aside process. Expenditures for construction and major renovation from these retroactive requests should be reported in line 9 under the column for the originating grant. Obligations for construction and major renovation from these retroactive requests should be reported in line 13a under the column for the originating grant.

Please note, funds cannot be expended for construction and major renovation activities prior to applying for and receiving approval from ACF, with the exception of costs associated with assessing the need for the construction or renovation and/or with preparing the application, such as the development of architectural plans.

The revised ACF-696T instructions clarify that funds retroactively requested and approved for use on construction and major renovation projects may be used for any allowable CCDF expense, and do not require a written request to repurpose the funding because the funds are not transferred to a separate construction account.

Signature Authority

The revised ACF-696T instructions highlight that Tribal lead agencies should have separate individuals entering data into the ACF-696T (the data entry person) and certifying and submitting the data to ACF (the certifier). This allows for the development of stronger internal controls and assures the accuracy of the reporting.

Action Required:

Tribal lead agencies must submit their ACF-696Ts electronically by May 15, 2025, through Online Data Collection (OLDC; see Action Transmittal No. OGM-AT-13-01). OLDC reduces paperwork, allows for quicker processing, automatically completes required calculations, and checks for potential errors. Tribal CCDF lead agencies with OLDC assignments may access the system at https://home.grantsolutions.gov/home/ .  

For CCDF Tribal lead agencies that currently lack access to OLDC, please request access using the OLDC Request Form, which is available (along with OLDC help sheets, user guides, and tutorials) at: https://home.grantsolutions.gov/home/getting-started-request-a-user-account/ .  A completed OLDC Request Form for each staff person who will play a role in using OLDC should be emailed to help@grantsolutions.gov with a copy to your ACF Office of Grants Management contact.  ACF will create a User Identification (ID) based on the information provided on the OLDC Request Form.  An email message is automatically sent to the staff member identified on the Request Form when an OLDC User ID and password is created for that person.  

Submission Of Real Property Form:

CCDF Tribal lead agencies with real property in which the federal government retains an interest (i.e., real property that was constructed or renovated in whole or in part with CCDF dollars) must prepare and submit the SF-429 with Attachment A on an annual basis at the same time as their annual ACF-696T Financial Report is due.  For more information, please see Program Instruction CCDF-ACF-PI-2023-01 on the OCC website.

Non-Reporting Penalties:

Failure to submit the ACF-696T report on or before the due date may be a basis for withholding financial payments, suspension, or termination.

Inquiries:

Inquiries should be made to the appropriate ACF Office of Grants Management staff.

/s/
__________________________
Anne-Marie Twohie
Acting Director
Office of Child Care

Attachments:

A. copy of Form ACF-696T (PDF (PDF)) and (Excel (XLSX))
B.  Instructions for completing Form ACF-696T (PDF)