THE SUPPORTING STATEMENT
The Office of Management and Budget (OMB) requires that for approval under the Paperwork Reduction Act a Supporting Statement must be prepared in the format specified below. Information in the Supporting Statement should be provided in a manner that is responsive to the OMB instructions, and each item must be identified using the numbering system given by OMB. If the Supporting Statement exceeds 10 single-spaced pages in length, there should be a summary not exceeding one page in length which precedes it.
Every effort should be made to keep the Supporting Statement to a length of 10-12 pages. When possible, detailed information should be placed in an attachment, which is then referenced in an appropriate place in the Supporting Statement so that interested reviewers can peruse it. Each attachment should be referenced in the text, so that a reviewer knows why it has been included and which portions may be of particular interest. Brevity and clarity with respect to both the text of the Supporting Statement and any attachments are highly desirable; only the information requested by the OMB outline and needed to understand the project should be included.
This annotated electronic version of the OMB outline for a Supporting Statement has been prepared by the ACF, Office of Planning, Research and Evaluation (OPRE), to assist in the preparation of a request for clearance of an information collection. This template can be downloaded from the PRA E-Office information collection web site.
General Instructions
A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must be entered in worksheet I. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. OMB reserves the right to require the submission of additional information with respect to any request for approval.
THE SUPPORTING STATEMENT
Specific Instructions
A. Justification
Circumstances Making the Collection of Information Necessary
The authorization to require the submittal of a Block Grant Plan by the Lead Agency in the State or Territory administering a Child Care and Development Fund (CCDF) program is contained in the Child Care and Development Block Grant Act of 1990 (CCDBG Act), 42 U.S.C 9858 as amended by the Child Care and Development Block Grant Act of 2014, Public Law 113-186. To be eligible to receive funds under this program, Section 658E of the CCDBG Act, 42 U.S.C. 9858c, a State or Territory shall prepare and submit to the Secretary an application at such time, in such manner, and containing such information as the Secretary shall require by rule, including a CCDF Plan that meets the requirements of Section 658E(c) of the CCDBG Act, 42 U.S.C. 9858c(c).
The CCDF Plan Preprint for States and Territories (ACF Form 118) is currently approved through 12/31/2018 (OMB Approval Number 0970-0114). A revision of the current information collection is being requested.
The Office of Child Care (OCC) has revised the FY 2019-2021 CCDF Plan Preprint to align with the CCDF Final Rule published on September 30, 2016. The Plan, submitted via the ACF-118, is required triennially, and will remain in effect for three years.
Due to unanticipated events, including challenges faced by States and Territories in implementing portions of the comprehensive and unprecedented background check requirements, the OCC has re-examined the implementation deadline to give States and Territories an opportunity to apply for additional time (up to two years, in one year increments) to meet the most challenging parts of the background check requirements as long as specific milestones were met. These developments required OCC to delay submission of the PRA CCDF Plan Preprint because the process and criteria for requesting additional time will be carried out as part of the Plan submission process.
Purpose and Use of the Information Collection
The primary purpose of the information contained in the CCDF Plan is to determine whether the Lead Agency can be approved to receive Block Grant funding, as required in Section 658E(d) of the Child Care and Development Block Grant (CCDBG) Act of 2014 (42 U.S.C. 9858c and 9858m), as amended. The Office of Child Care (OCC) reviews the Plan information to determine if the Lead Agency is operating in accordance with its approved plan. In addition, the information contained in the State and Territory Plans helps the OCC identify trends, best practices, areas that need improvement and to determine if the States and Territories are administering the program in accordance with the CCDBG Act and amended regulations. Based on a review of the plans, the OCC designs technical assistance strategies that will be responsive to the needs of the Lead Agencies.
The Administration for Children and Families (ACF) has found the CCDF Plan Preprint useful in guiding Lead Agencies in the development and submission of their Plans. The standardized, “Preprinted” format provides complete program information necessary to complete the CCDF Plan, ease the burden on States and Territories, especially with the inclusion of check boxes, and expedites timely reviews by ACF staff. Because the CCDF Plan Preprint reflects the CCDBG statute and amended regulations, it serves as a framework, or blueprint for Lead Agencies in developing and implementing their CCDF programs.
The public takes considerable interest in the way States and Territories administer their CCDF funds. With the focus on transparency, the Plan Preprint allows Lead Agencies to provide the public an opportunity to comment on the provision of child care services under the Plan. The OCC also makes Plan information available to many users including members of Congress, Congressional Committees, State, and local child care administrators, advocacy groups, researchers and the public.
Use of Improved Information Technology and Burden Reduction
Lead Agencies submit their Plans electronically through a web-based on-line submission tool designed by OCC for Lead Agencies. OCC continues to work with Lead Agencies on the usability of this on-line submission. Some of the revisions to the Preprint (e.g. use of checkboxes) were designed and formatted to make the Plan suitable for an electronic submission process.
Efforts to Identify Duplication and Use of Similar Information
The information collected by the ACF-118 is not available from any other source.
Impact on Small Businesses or Other Small Entities
The data collection effort does not involve small businesses or other small entities.
Consequences of Collecting the Information Less Frequently
In accordance with 45 CFR 98.13, Lead Agencies are required to provide a Plan that describes the entire child care program in detail triennially (every three years).
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
The collection of information will be conducted in accordance with 5 CFR 1320.6.
Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency
FRN Vol. 82, No. 235 page 57986 published on 12/08/2017
The Office of Child Care’s (OCC) notice soliciting comments on this information collection was published in the Federal Register Vol. 82, No. 235 on December 8, 2017. OCC sent an email message to State and Territory Lead Agencies and a separate message to a large email list of external stakeholders notifying them of the federal register notice, including sending electronic copies of the draft CCDF Plan Preprint. During the 30 day comment period, the OCC held a national conference calls with all State and Territory Lead Agencies to review the proposed changes. In addition. The ACF regional Offices convened their states and territories via conference call. Finally, the Federal Register Notice and the proposed Plan Preprint were posted on the OCC website to make it available to a wide audience.
The OCC received comments on the CCDF Plan Preprint for the States/Territories from 33 entities along with feedback from the Office of General Counsel and OMB. The comments received were positive and extremely helpful and represented a wide range of stakeholders. The OCC reviewed and discussed all comments through a series of internal and external meetings and made changes accordingly.
The major themes of the comments in addition to comments identifying formatting or edits were:
Requests to revise some questions to include checklists (e.g., sections 2.1.2, 3.1.6, 3.1.8, 3.2.2, 3.3.4, 4.1.3b).
Recommendation to add some guidance and additional language/information for clarity purposes to sections 2.3.2, 2.3.7, 2.4, 3.1.7, and 3.4.6.
Request to give states the option to acknowledge implementation challenges and action steps planned to reach full compliance.
Recommendation for consistencies related to federal regulation citations for each question.
In addition to these major themes, there were specific concerns for different sections of the Preprint document. Below are the comments and corresponding actions taken by OCC.
Section 1 - Define CCDF Leadership and Coordination with Relevant Systems: Several Afterschool alliances recommended we include school aged afterschool and summer camp programs to the language in 1.7.
We made this change throughout the Preprint as applicable.
Section 2 – Promote Family Engagement through Outreach and Consumer Education: In this section, several states requested clarifications regarding the posting of monitoring and inspection reports on the consumer education website and the national hotline. Several entities also recommended adding a specific box for school aged standards in 2.3.6 and revising the language in 2.3.6a.
We added checkboxes in section 2.3.5 to provide examples of what might be included. In section 2.3.7 we provided clarification related to monitoring and inspection reports. In response to comments regarding clarification on how to respond about the National Website and Hotline, we deleted section 2.4.
Section 3 – Provide Stable Child Care Financial Assistance to Families: In this section, recommendations were made about reinstating language from FY 2016-2018 Plan Preprint to ensure states do not misinterpret the language in 3.1.9; and separate the questions in 3.2.1. Commenters also recommended asking states/territories to report on their requirements for redetermination and whether they intend to change their income eligibility limits.
We added clarifications to 3.1 regarding initial eligibility and redetermination. We also included additional examples and clarifications for 3.2 and 3.3. To assist us in better understanding responses to 3.4.1, we requested a location name for the “most populous area of the state”. We moved 3.4.5 and 3.4.6 into section 4 because of their relevance to equal access.
Section 4- Ensure Equal Access to Child Care for Low-Income Children: In this section, states requested the Plan clearly communicates that the use of quality indicators in conducting the Market Rate Study or establishing payment rates only applies to states that have quality rating and improvement system; there was also a recommendation for OCC to clarify there’s no requirement for states to pay at the 75th percentile.
Revisions to this section consisted of general edits and clarifying information to further explain the requirements. We added a request to identify the “most populous area” used to complete responses for 4.3.1.
Section 5- Establish Standards and Monitoring Processes to Ensure the Health and Safety of Child Care Settings: In this section, requests were made to revise the components pertaining to waiver request procedure; ask states/territories to describe the qualifications for licensed center based child care directors in 5.2.1; explain the differences by age category in 5.2.3 and 5.2.5 and clarify the option to develop alternate monitoring requirements for care provided in a child’s home in 5.3.
This section has the most substantial edits. In 5.1.1 and 5.1.2, we reorganized the questions so 5.1 focused on licensing requirements and 5.1.2 focused on providers exempt from licensing. In 5.2, we added clarifications regarding citations for licensed and license-exempt providers and to indicate that training must be completed by caregivers, teachers and directors. In 5.3, we inserted instructions to skip questions if applicable and eliminated duplicative questions which altered the numbering pattern.
In 5.4 the introduction was revised to clarify the requirements and explain the waiver milestones and process. The waiver request process was moved to Appendix A: Background Check Waiver Request Form to address comments about waiver process. Revisions now request responses for each component of the background check for new staff and existing staff, and describe requirements for provisional employment of prospective staff. Numbering was also corrected and headers were provided for in-state background check requirements, national background check requirements and inter-state background check requirements.
Section 6- Recruit and Retain a Qualified and Effective Child Care Workforce: In this section, commenters suggested OCC includes a question regarding the essential role of parents when establishing effective training for child care workers, so they are equipped to treat parents as partners. There was also a recommendation to split 6.2.3 into two items, asking states/territories to describe their outreach to providers with limited English proficiency separately from their outreach to providers with disabilities.
Revisions mainly consisted of adding clarifying language related to several questions. Question 6.2.4 was eliminated resulting in numbering changes for the rest of the section.
Section 7 - Support Continuous Quality Improvement: Request for a “Not Applicable” option be added to 7.4.2; recommend the descriptions at 7.8.1 and 7.8.2 include specificity about tools and strategies in child care centers and in family child care homes, drawing a distinction and asking states/territories to report on efforts for different settings. There was also a recommendation to enhance the checklist in 7.9 to ensure states can provide the information that reflects their effort.
Minor edits were made to clarify intent of question, mainly in relation to age groups covered by the questions.
Section 8 - Ensure Grantee Program Integrity and Accountability: No comments received.
In 8.1.4, we reorganized the question to address fraud (a), unintentional program violations (b), and agency errors (c). In 8.1.5 the question was revised to identify recovery of misspent funds due to fraud (a), unintentional program violations (b), and agency errors (c). Language was added to focus on the results of program integrity efforts.
Explanation of Any Payment or Gift to Respondents
No payments or gifts are provided to respondents.
Assurance of Confidentiality Provided to Respondents
The information collection is nothing of a confidential nature, therefore does not require any assurance of confidentiality.
Justification for Sensitive Questions
There are no questions of a sensitive nature.
Estimates of Annualized Burden Hours and Costs
The annual public reporting burden for this information collection is estimated to average 200 hours per response. This includes the time for reviewing instructions, gathering and maintaining the data needed, and completing the CCDF Plan Preprint every three years. Total cost is projected to be approximately $147,840 (3,696 * $40/hour).
Instrument
|
Number of Respondents
|
Number of Responses Per Respondent |
Hours Per Response |
Response Burden
|
CCDF Plan Preprint |
56 |
.33 |
200 |
3,696 |
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
There are no direct monetary costs to Lead Agencies other than the time to complete the ACF-118.
Annualized Cost to the Federal Government
The annual costs to the Federal Government are projected as follows:
Task Estimated Hours Estimated Rate Total
Preprint Design 160 $30.58 $ 4,892.80
State/Territory
Plan Review 40 * 56 Plans = 2,240 $30.58 $68,499.20
Total $73,392
NOTE: Plans are submitted triennially.
Explanation for Program Changes or Adjustments
The Office of Child Care (OCC) has revised the FY 2019-2021 Plan to align with the program requirements made under the CCDBG Act of 2014, which was signed into law on November 19, 2014 and the CCDF Final Rule, which was issued on September 30, 2016. In making the revisions, consideration was given to minimize the burden of the collection on respondents. Consistent with previous formats, the Preprint includes a combination of check boxes, certifications, and requests for descriptive information. No adjustments were made to #13 and #14.
Plans for Tabulation and Publication and Project Time Schedule
Not applicable.
Reason(s) Display of OMB Expiration Date is Inappropriate
Not applicable.
Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions.
B. Statistical Methods (used for collection of information employing statistical methods)
The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When item 16 is checked "Yes," the following documentation should be included in the supporting statement to the extent that it applies to the methods proposed:
Not applicable. The information collected by the ACF-118 is not the type of information that may be collected by statistical methods. Statute requires States and Territories to prepare and submit to the Secretary a CCDF Plan that meets the requirements of Section 658E(c) of the CCDBG Act, 42 U.S.C. 9858c(c).
Respondent Universe and Sampling Methods
Procedures for the Collection of Information
Methods to Maximize Response Rates and Deal with Nonresponse
Test of Procedures or Methods to be Undertaken
Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data
| File Type | application/msword |
| Author | ACF |
| Last Modified By | SYSTEM |
| File Modified | 2018-05-24 |
| File Created | 2018-05-24 |