THE SUPPORTING STATEMENT
Specific Instructions
A. Justification
Circumstances Making the Collection of Information Necessary
Section 658K of the Child Care and Development Block Grant (CCDBG) Act (42 U.S.C. 9858, as amended by Public Law 113-186) requires that States and Territories submit
monthly case-level data on the children and families receiving direct services under the Child Care and Development Fund (CCDF). The implementing regulations for the statutorily required reporting are at 45 CFR 98.70 and 98.71. Case-level reports, submitted quarterly or monthly (at grantee option), include monthly sample or full population case-level data. The data elements to be included in these reports are represented in the ACF-801. ACF uses disaggregate data to determine program and participant characteristics as well as costs and levels of child care services provided. This provides ACF with the information necessary to make reports to Congress, address national child care needs, offer technical assistance to grantees, meet performance measures, and conduct research.
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Purpose and Use of the Information Collection
The case-level administrative information received through this collection provides the means to analyze and evaluate the CCDF program and the extent to which States and Territories are assisting families in addressing child care needs. This collection will provide ACF with the information necessary to make reports to Congress (available at https://www.acf.hhs.gov/occ/resource/reports-to-congress), address national child care needs, offer technical assistance to grantees, meet performance measures, and conduct research.
Use of Improved Information Technology and Burden Reduction
ACF has made arrangements with the National Institutes of Health for secure electronic file transfer using either CyberFusion or by using Secure File Transfer Protocol (SFTP). These methods of transmission ensure that case identifiers remain secure in the transmission. States that cannot transmit the ACF-801 data via one of the above methods may submit using an encrypted and/or password protected diskette/CD via registered mail. ACF provides technical assistance to Grantees in the use of secure electronic file transfers toward improved data accuracy and reliability.
Efforts to Identify Duplication and Use of Similar Information
This data collection is required by section 658K of the Child Care and Development Block Grant (CCDBG) Act (42 U.S.C. 9858, as amended by Public Law 113-186) and does not duplicate any other reporting or record-keeping requirements. The implementing regulations for the statutorily required reporting are at 45 CFR 98.70 and 98.71.
No similar information is being collected on CCDF program participants and related child care services that can be used to respond to the issues identified in section 658K. Collection of the information specified on the ACF-801 is necessary to comply with the Federal statute and regulations, and to ensure the availability of data to respond to inquiries regarding the progress of the CCDF program and related issues.
Impact on Small Businesses or Other Small Entities
This data collection effort does not involve small business or other small entities.
Consequences of Collecting the Information Less Frequently
Section 658K of the statute requires States and Territories to transmit information collected on a quarterly basis (or monthly at State/Territory option). The data are submitted no later than 60 days after the end of each quarter. In the case of a State/Territory who is submitting a sample, the sample includes a minimum of 200 records for each of the three months of the quarter (October through December, January through March, April through May, and July through September, as appropriate). States and Territories have the option of submitting full population or sample data.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
The collection of this information is conducted in accordance with 5 CFR 1320.6.
Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency
A 60-day notice in the Federal Register was published on April 13, 2018 (Vol 83, pg 16104). In this notice, ACF solicited public comment on the extension of this data collection with changes. With this extension, ACF was proposing to add two new data elements (data element numbers 30a and 41) to the existing reporting requirements in accordance with the CCDF final rule at 45 CFR 98.71(a)(11). These proposed revisions to the ACF–801 would allow ACF to collect the amount charged per child by those providers who charge the family more than the required copayment in instances where the provider’s price exceeds the subsidy payment.
We received comments from five State CCDF Lead Agencies—all of which objected to the proposed new data elements. Hawaii, Minnesota, New York, and Utah indicated that the elements would create a reporting burden for families and/or providers, and that it would challenging to collect and report accurate data. New Jersey indicated that it has legacy systems that would be unable to calculate or report this data. New York argued that the new elements were duplicative of information that States are required to report in their CCDF Plans, and would involve significant costs given that the State is county-administered. Utah recommended that this information be collected through a different mechanism and less frequently (rather than monthly on the ACF-801).
As a result of the comments received, ACF has determined not to move forward with implementing the additional data elements (data element numbers 30a and 41) at this time. These elements would be burdensome to the States to report. States would be dependent on parents and providers to collect and report this information, which will be unreasonably difficult as (a) the burden of collection would be shifted to parents and providers, and (b) currently States do not have mechanisms in place to collect these data. Furthermore, the quality of the data would be questionable as there would not be mechanisms in place to validate the information.
ACF allows the CCDF Lead Agencies the flexibility to permit providers to charge parents an additional amount when the child care provider’s price exceeds the subsidy payment. In the CCDF State Plan, the Lead Agencies are required to demonstrate how such a policy promotes access and affordability, and provide supporting data and analysis of these additional amounts as related to the required co-payments and subsidy rates. Also, ACF plans to evaluate potential research approaches, including the feasibility of adding questions to the National Survey of Early Care and Education, to obtain information related to amounts parents pay, beyond the required copayment, in instances where the provider’s price exceeds the subsidy payment.
Explanation of Any Payment or Gift to Respondents
Not applicable.
Assurance of Confidentiality Provided to Respondents
Section 658K(a)(1)(E) of the CCDBG Act now prohibits the ACF-801 report from containing personally identifiable information. As a result, ACF is not collecting Social Security Numbers (SSNs). The form requires a unique identifying number, other than the SSN, that is assigned by the State for each family. ACF has made arrangements with the National Institutes of Health for secure electronic file transfer using either CyberFusion or by using Secure File Transfer Protocol (SFTP). These methods of transmission ensure that case identifiers, i.e., unique identifying numbers, remain secure in the transmission. States that cannot transmit the ACF-801 data via one of the above methods may submit using a diskette/CD via registered mail. ACF provides technical assistance to Grantees in the use of the electronic system toward improved data accuracy and reliability.
Justification for Sensitive Questions
This data collection does not involve asking questions of a sensitive nature.
Estimates of Annualized Burden Hours and Costs
All States and Territories are required to participate and report case-level data for the CCDF program. The burden of collecting the information is estimated as follows:
Number of Respondents: 56
Number of Responses per Respondent: 4
Average Burden Hours per Response: 25
Total Burden Hours per Year: 5600
We estimate that the time required to assemble and transmit the data file will take approximately 25 hours per transmission at an estimated $46 per hour which totals $4,600 per State and Territory. This estimate is based on BLS wage data, specifically two times the hourly rate for a government-employed computer operator—which accounts for overhead/indirect costs. The estimated annual labor cost for all States and Territories (56) is $257,600.
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
Operational costs for systems software computer time will average about $4,500 a year per State and Territory, for a total of $252,000 for all States and Territories (56).
The estimated total annual cost, including burden hours, for all States and Territories (56) is $509,600 (i.e., $257,600 plus $252,000).
Annualized Cost to the Federal Government
The estimated annual Federal cost is $513,600. This includes staff costs of program analysts who review the information to ensure consistency and contact grantees as necessary when information is incomplete or questionable. It also includes systems costs, including data base maintenance, associated with the electronic system that performs audit checks and provides feedback to the States and Territories.
Explanation for Program Changes or Adjustments
No changes are proposed.
Plans for Tabulation and Publication and Project Time Schedule
Fiscal Year 1998 through 2016 data from the ACF-801 has been processed and reported in a variety of places. Specifically, data has been incorporated into the Office of Child Care (OCC) Report to Congress, used by ACF to respond to requests from Congress, track ACF's performance under the Government Performance and Results Act, and respond to inquiries regarding the progress and effectiveness of the CCDF program as well as posted on the OCC website.
Reason(s) Display of OMB Expiration Date is Inappropriate
The expiration date is currently displayed at the top right corner of the ACF-801 Form.
Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions to this form.
| File Type | application/msword |
| File Title | ACF-801 Supporting Statement |
| Author | ACF |
| Last Modified By | SYSTEM |
| File Modified | 2019-02-06 |
| File Created | 2019-02-06 |