Submit the Tribal CCDF Plan for the CCDF Program Fiscal Year (FFY) 2026-2028

Tribal Child Care and Development Fund (CCDF) Plan Program Instruction 

1. Log No: ACF-OCC-CCDF-PI-2025-03
2. Issuance Date: 01/13/2025
3. Originating Office: Office of Child Care (OCC)
4. Key Words: Child Care and Development Fund (CCDF) Fiscal Year 2026 Funding; Fiscal Year 2026-2028 Tribal CCDF Plan and Plan Preprint; Indian Tribes and Tribal Consortia

To

Federally Recognized Tribes, Tribal Consortia, and Tribal Lead Agencies administering child care programs under the Child Care and Development Fund (CCDF) program, as amended, and other interested parties.

Purpose

This Program Instruction (PI) provides guidance to Tribes, Tribal Organizations, and Tribal Lead Agencies for using the Tribal CCDF Plan template (ACF-118A) to complete and submit the Tribal CCDF Plan (Plan) for the CCDF program Fiscal Year (FFY) 2026-2028.

This PI also provides guidance on the submission of Plan amendments for approval to reflect any significant changes in the administration of the CCDF program, and clarification and guidance on certain areas of the Plan.

References

The CCDBG Act of 1990 (42 U.S.C. § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186); Section 418 of the Social Security Act (42 U.S.C. § 618); and 45 CFR Parts 98 and 99.

Submission Deadlines and Plan Effective Dates

The deadline for the submission of the FFY 2026-2028 Plan is July 1, 2025. OCC will review Plan submissions from July through September 2025. As part of the review process, Tribal Lead Agencies should expect to respond to requests for clarifications from OCC. OCC will send an approval letter to Tribal Lead Agencies in October that will address approved activities and any requirement(s) not fully implemented in compliance with CCDF. Once approved, Plans will be effective from October 1, 2025, through September 30, 2028.

Guidance

The Plan, including the child count declaration and Tribal Lead Agency assurances, serves as the Tribal Lead Agency’s application for CCDF funds by providing a description of its child care program and services available to eligible families (42 U.S.C. 9858m(c)(4); 45 CFR 98.81 (b)(4)). The Plan provides information about aspects of the Tribal Lead Agency’s CCDF program such as: the overall management of CCDF services, eligibility guidelines, provider payment rates, service priorities, parental rights and responsibilities, program integrity and accountability, and quality improvement activities. The Plan also presents an opportunity for Tribal Lead Agencies to describe the activities and services they are providing to meet the needs of children and families in its service area.

The Plan template must be used by direct-funded Tribal CCDF lead agencies and new applicants to ensure the Plan submission addresses all applicable requirements necessary to authorize CCDF funds. Tribes that have consolidated their CCDF funds under the Indian Employment, Training and Related Services Consolidation Act of 2017 (commonly known as Pub. L. 102-477) should review the Public Law 102-477 Section below.

Tribal Eligibility for CCDF Funds

Pursuant to 45 CFR 98.80, a Tribe is eligible to apply for and receive CCDF funds if the Tribe is federally recognized and the Tribal population includes at least 50 children under age 13 within the approved CCDF service area.

A Tribe with fewer than 50 children under age 13 may participate in a consortium of eligible Tribes. To be eligible to receive CCDF funds on behalf of its member Tribes, a consortium must:

• Consist of Tribes that meet the eligibility requirements for the CCDF program if the Tribe had at least 50 children under age 13;
• Demonstrate it has current authorization from each participating Tribe to receive CCDF funds on behalf of the Tribe. Each consortium member must provide a demonstration every three years for the consortium Lead Agency to include with the plan submission—this is included as part of the child count; and
• Demonstrate its current service delivery capability, including skills, personnel, resources, community support, and other necessary components to satisfactorily carry out the proposed program.

Consortium Membership Changes

It is the responsibility of a Tribal Lead Agency consortium to notify OCC of any changes in its membership for CCDF funding purposes during the approved Plan period. For example, if the consortium adds a new Tribe during the Plan effective period, or if a current Tribal Lead Agency consortium member elects to leave that Tribal consortium, these changes must be conveyed to OCC in writing by the Tribal Lead Agency consortium through an amendment to the CCDF Plan. The Tribe electing to the leave a consortium can also notify OCC of that change.

Allocation Sizes

Tribal Lead Agencies are subject to different CCDF requirements depending on the size of their FFY 2016 CCDF allocation amounts (45 CFR 98.83(e)-(f)). Allocation sizes for new Tribal Lead Agencies since FFY 2016 will be determined based on what their first annual allocation amount would have been in FFY 2016 based on their first submitted child count.

• Tribal Lead Agencies with small allocations (allocations of less than $250,000 in FFY 2016) are not subject to the majority of the CCDF requirements. These Tribal Lead Agencies are still expected to spend their funds in alignment with CCDF goals and purposes.
• Tribal Lead Agencies with medium allocations ($250,000 to $1,000,000 in FFY 2016) are not required to operate a certificate program.
• Tribal Lead Agencies with large allocations (over $1,000,000 in FFY 2016) are required to operate a certificate program.

Plan Structure

The Plan is structured to align with the flexibilities Tribal Lead Agencies have based on their allocation size. All Tribal Lead Agencies must complete Part I of the Plan. Tribal Lead Agencies with small allocations must also complete Part II and Tribal Lead Agencies with medium and large allocations must also complete Part III.

Part I (For Tribal Lead Agencies with small, medium, and large allocations)

• CCDF program administration
• Health and safety of child care settings
• Quality improvement

Part II (For Tribal Lead Agencies with small allocations only)

• Direct services information

Part III (For Tribal Lead Agencies with medium and large allocations only)

• Child and family eligibility, enrollment, and continuity of care
• Equal access to high quality child care
• Family outreach and consumer education

Tips for Your CCDF Plan Responses

• Some questions that previously requested narrative responses or required citations may now simply ask the Lead Agency to certify it is meeting CCDF requirements. In those cases, check “yes” if fully meeting the requirement or check “no.” If “no,” use the “Explain” text box provided to briefly describe the Lead Agency current implementation status.
• Some questions that previously requested narrative responses now offer multiple choices. Lead Agencies may select the appropriate choice(s) and/or select “other” and provide additional information where requested. Please follow instructions carefully to assess whether the question allows for multiple selections or whether the question requires selection of one option.
• In responding to questions, Tribal Lead Agencies are asked to follow all instructions, and for narrative responses provide brief, specific summaries and/or bullet points only with specific language that responds to the question. Do not use tables or copy and paste charts, add attachments, or paste manuals into the Plan.

Review of the Plan

In completing the FFY 2026-2028 Tribal Plan, each Tribal Lead Agency should consider all the policies and program activities that will be in effect as of October 1, 2025, the start of the FFY 2026-2028 Tribal CCDF Plan period. This includes the policies and activities related to direct services to families receiving child care assistance through CCDF as well as broader activities to support child care supply-building and quality improvement activities for child care programs for all children. Lead Agencies must include and describe all relevant policies and activities funded by CCDF.

OCC will review each Plan for:

• Completeness — have all required components of the question been answered (e.g., have all requirements been described for all CCDF provider categories)?
• Responsiveness — do the responses address the information requested in the question?
• Clarity — does the response provide a clear understanding of the Lead Agency’s CCDF requirement?
• Compliance — is the response allowable and does it fully meet the requirements of CCDF?
• Consistency within the Plan — is response consistent with similar/related areas of the Plan?

In some cases, Tribal Lead Agencies are reliant on partnerships with states or use of state systems for implementation of their CCDF Program. The Tribal Plan template does not ask Tribal Lead Agencies for information on or report on the status of a state system that they do not have the authority to change. Tribal Lead Agencies will not be determined non-compliant for partnering with a state or using a state system that OCC has determined is non-compliant with CCDF requirements. State policies that are non-compliant with CCDF can be found on the OCC website. Please contact the appropriate OCC Regional Office for help locating that information.

Triennial Child Count Declaration

All Tribal Lead Agencies who intend to receive CCDF funding for FFY 2026-2028, regardless of whether they currently receive CCDF funds, including those that have consolidated their CCDF program into an approved P.L. 102-477 Plan, must submit the triennial child count declaration by July 1, 2025. The child count reflects the number of children under age 13 who reside in the Tribal Lead Agency’s defined service area and is the basis for Tribal funding allocations to reflect the needs and population of each Tribal Nation and community. The child count questions are included in the Plan template in Section 1. Tribal Lead Agency consortia will need to submit child count declarations/demonstrations of their member tribes. Examples of these are included as Appendix 1 and 1-A in the Plan template. Guidance on developing your child count declaration is provided in the OCC PI CCDF-ACF-PI-2024-04.

Submitting the Tribal Plan

Tribal Lead Agencies will complete and submit their complete Plan for the FFY 2026-2028 triennial plan cycle including all appendices and attachments to the Child Care Automated Reporting System (CARS) at https://cars.acf.hhs.gov .

CARS is a password-protected web-based system. Use of the paperless Internet data entry site streamlines submission processing and improves data quality. Tribes should not submit a plan separate from the CARS system.

For access to CARS, contact the CARS team at cars@acf.hhs.gov or toll-free at 1-877-249-9117.

Plan Amendments

Any substantial change to the CCDF program during the Plan effective period requires an amendment to the approved Plan (45 CFR 98.18(b)).

Determining whether a change is “substantial” (and therefore requires a Plan amendment) requires examination of the specific circumstances as well as the content of the existing approved Plan. However, substantial changes in a Tribal Lead Agency’s Plan generally include instances when the Tribal Lead Agency:

• Adds a significant additional program activity;
• Eliminates a significant program activity;
• Changes its basic Plan for the use of funds, including payment rates, eligibility thresholds, family co-payment, or quality initiatives; or
• Changes the Lead Agency responsible for administering the program.

Tribal Lead Agencies are not required to submit Plan Amendments for basic "edits" or revisions to Plan questions that do not constitute a CCDF program change. Whenever you are unsure if you are making a substantial change, please consult with your Regional Office staff.

To amend a Plan, Tribal Lead Agencies will enter amendment information into CARS within 60 days of the effective date of the change.

Public Law 102-477

All Tribes, including those who have consolidated their CCDF funds under the Indian Employment, Training and Related Services Consolidation Act of 2017 (commonly known as Pub. L. 102-477), must submit their request for CCDF program funding and triennial child count declaration by the July 1, 2025.

For Tribes with approved Pub. L. 102-477 Plans, the request for CCDF program funding must include the following attachments with the child count declaration in CARS:

• A request to apply for CCDF program funding;
• The Tribe’s approved 477 Plan attached;
• An assurance that the Tribe “intends to continue providing services under the CCDF program pursuant to the Tribe’s approved Pub. L. 102-477 Plan during FFY 2026-2028 CCDF funding cycle;” and
• If applicable, any proposed changes from the approved Pub. L. 102-477 plan related to the CCDF program funding requirements (please note that changes may require an amendment to the Pub. L. 102-477 plan).

The child count submission for Tribes and Tribal organizations that consolidate CCDF funds under Pub. L. 102-477 also includes one question regarding the acceptance of reallotted funds in the event they are available.

The effective dates for the CCDF funding request and child count will be October 1, 2025 through September 30, 2028.

Additional information on the child count can be found in the child count PI, CCDF-ACF-PI-2024-04.

Audits

Audits must be conducted in accordance with 2 CFR Part 200 Subpart F and 45 CFR Part 75 Subpart F, Audit Requirements.

Guidance for New Tribal Lead Agencies

This Program Instruction only includes information on the Tribal CCDF Plan, submission and review considerations, and amendments. It does not include information on all requirements for Tribal Lead Agencies on other areas such as spending requirements or construction and major renovation. New Tribal CCDF Administrators and/or Tribes applying for CCDF funds for the first time are encouraged to reach out to the appropriate regional office for more information on other Tribal CCDF Lead Agency responsibilities and activities

Inquiries

Reach out to the Office of Child Care with any questions or for more information.

Attachments

Federal Fiscal Years 2026—2028 Child Care and Development Fund (CCDF) Plan for Tribes (PDF)

/s/ 
Ruth J. Friedman
Director
Office of Child Care