Technical Bulletin 14r-v3: Child Care and Development Fund Reporting Clarifications for Tribally Operated Centers

Answer: Tribal grantees use their CCDF grant dollars in different ways to provide child care services to eligible families and children. Those grantees that use CCDF funds to operate a center-based child care business are said to have a Tribally Operated Center (TOC). The Tribe oversees all operations of the program: paying facility costs (e.g., rent and utilities), hiring and managing staff, purchasing equipment and supplies, and screening families for eligibility.

Answer: The ACF-700 report no longer distinguishes between licensed or legally operating/non-licensed care types. There are now just five different care type categories in the ACF-700, and the previous distinction between licensed and legally operating care has been removed, leaving one Center category. The five new reporting categories for type of care are:

1. Relative Care in a Child’s Home: Care provided by a caregiver in the child’s own home by a grandparent, great-grandparent, aunt or uncle, or sibling living outside the child’s home.
2. Non-relative Care in a Child’s home: Care provided by a caregiver in the child’s own home by someone who is NOT the child’s grandparent, great-grandparent, aunt or uncle, or sibling living outside the child’s home.
3. Relative Care in a Family Home: Care provided in the family home of the provider (i.e., care provided by an individual in their own private residence) by someone who is the child’s grandparent, great-grandparent, aunt or uncle, or sibling living outside the child’s home. Generally, family home care is provided only to a limited number of children at any one time (e.g. 3-5).
4. Non-Relative Care in a Family Home: Care provided in the family home of the provider (i.e., care provided by an individual in their own private residence) by someone who is NOT the child’s grandparent, great-grandparent, aunt or uncle, or sibling living outside the child’s home. Generally, family home care is provided only to a limited number of children at any one time (e.g. 3-5).
5. Care in a Center: Care provided in a center-based setting, including programs in schools or churches.

Answer: No. In your Tribal CCDF Plan, you may define the various types of providers you are going to use for your CCDF program, and these definitions will guide your program operations. As long as you adhere to the criteria in your approved CCDF Plan and to the CCDF care type definitions, you may use as many different providers and types of providers as your program requires.

Answer: Direct service expenditures include CCDF payments for child care services received by CCDF-eligible children, including slots purchased through contracts/grants with child care providers, services provided through certificates/vouchers, and services provided in a TOC.

In the case of a TOC, direct service expenditures also include CCDF dollars used to operate the center and provide services to CCDF-eligible children, including the following payments: wages, salaries, and benefits for child care staff and support staff (e.g., cooks, custodians); facility costs (e.g. rent, maintenance); and classroom materials, equipment, food, and supplies.

The following are not considered direct expenditures:

• Administration of the CCDF program (i.e. developing the biennial Tribal Plan, preparing required reports, evaluating program results);
• Quality improvement activities such as professional development and consumer education;
• Eligibility determinations and re-determinations;
• Preparation and participation in judicial hearings;
• Recruitment, licensing, inspection, reviews, and supervision of child care providers;
• Training of child care staff; or
• Maintenance of computerized child care information systems.

On the ACF-700 you should report on the CCDF eligible families and children associated with the direct service costs that are reported on the ACF-696T.

Answer: A subsidy is an amount of money paid by the CCDF Lead Agency on the family’s behalf, allowing the family to receive child care services they might otherwise not be able to afford. In this case, the CCDF subsidy is the dollar amount used to support the child care costs for an eligible family’s children.

The most common subsidy is the payment a CCDF grantee makes to a provider for child care services delivered. For a TOC, the subsidy represents the amount spent on direct services, as defined in Question 3 above.

The co-payment is the dollar amount the Lead Agency determines the family should pay each month towards the cost of care. Lead Agencies are required to calculate the assessed co-payment amount based, at a minimum, on the family’s income and size.

Answer: Amounts spent on the provision of direct child care service in the TOC should be included in the average monthly subsidy per child (data element # 6a on the ACF- 700). Tribes that operate their own center can estimate the average monthly subsidy per child using the figures reported on their recent ACF-696T report.

1. STEPS for calculating the estimated average monthly subsidy per child in your TOC when you provide child care services only in your own TOC:
   1. Step 1: Add the expenditures from Tribal Mandatory, Discretionary, and Discretionary Funds (including expenditures from the CARES Act, the CRRSA Act, and Discretionary ARP Act) . that your Tribe reported on Line 4 of the ACF-696T — Expenditures for Child Care Services. Do not include expenditures for construction and renovation. During the Federal fiscal year, if you expended funds from more than one grant year, you must add the appropriate expenditures from each of the reports submitted regardless of the year that the grant was awarded.
   2. Step 2: Divide the above total by the number of months that you provided services during the year (ranging from 1 to 12 months), to get an overall monthly subsidy amount.
   3. Step 3: Divide the monthly subsidy amount by the average number of children served per month (data element #2) to estimate the average monthly subsidy per child in your center. (See Questions #7-11 for more information regarding which families and children to include in your report.)

Answer: The ACF-700 report was modified beginning with FY2020. Therefore, reporting of the average subsidy (#6a) is no longer required.

Answer: No. On the ACF-700, you should report only those children who meet CCDF eligibility requirements and whose direct services are fully or partially paid for with CCDF funds. Because a TOC’s direct service expenditures include center operating costs, all families and children who meet your CCDF defined eligibility criteria and receive services in your center may be included in the ACF-700 report as long as their care is at least partially paid for by CCDF. If a family pays the full private pay rate and the child’s care is not at least partially funded by CCDF, the family/child should NOT be counted in the ACF-700 report. (See Question #3 above for more information about direct and non- direct services/expenditures.)

Answer: No. You should count only those children whose families are determined to be eligible to receive a CCDF subsidy and whose care is partially or fully paid for by CCDF. (See Question #3 above for more information about direct and non-direct services/expenditures.)

Note: You will have to obtain sufficient information about the eligible families and children participating in the drop-in program to be able to accurately complete the annual ACF-700 report.

Answer: No. All of the children involved in quality activities should not necessarily be included on the ACF-700 report. Children should be included on the ACF-700 report only if you also used CCDF funds to pay for some or all the direct child care services. They should not be counted if they only received the benefits of CCDF-supported quality activities (e.g., providing professional development for staff). In these cases, the grant did not pay for the direct child care service. (See Question #3 above for more information about direct and non-direct services/expenditures.)

Answer: Children whose child care is fully funded by the State should not be counted on the ACF-700 report. However, you should count these children on the ACF-700 if their direct services are at least partially funded by Tribal CCDF dollars. (See Question #3 above for more information about direct service expenditures.) For example, the TOC may use Tribal CCDF dollars to pay remaining costs of services if the State subsidy is insufficient to cover all service costs. (Note: A State has the authority to waive the co- payment for families living below the poverty line or for children in protective services; however, the Tribe has no authority to use CCDF funds to independently pay the family’s co-payment if the State is funding the subsidy.) Eligible children in a TOC whose services are partially funded by the State and partially by the Tribe may be reported both by the State (on the ACF-801) and by the Tribe (on the ACF-700). The Tribal grantee should determine the number or percentage of children being served in the TOC that are being subsidized with both Tribal CCDF and State dollars and indicate in the Introduction Section of the ACF-700 Report.

Answer: OCC is interested in learning about the co-payments for all CCDF-eligible families served in the TOC and whose services are paid for, at least partially, by your CCDF grant. Therefore, you should include in your ACF-700 report the assessed co-payment amount, regardless of whether it is defined by the State or by the Tribe.