NonSub Change Memo - ACF 696 Form CRRSA Funds Updates

To: Jordan Cohen

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Ellen Wheatley, PhD

Office of Child Care

Administration for Children and Families (ACF)

Date: February 17, 2021

Subject: NonSubstantive Change Request – Child Care and Development Fund (CCDF) ACF-696 Financial Report for States and Territories (OMB #0970-0510)

This memo requests approval of NonSubstantive changes to the approved generic information collection (GenIC), Child Care and Development Fund (CCDF) ACF-696 Financial Report for States and Territories (OMB #0970-0510; Generic Clearance for Financial Reports).

Background

On December 27, 2020 the Consolidated Appropriations Act, 2021 and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSA), 2021, P.L. 116-260, was signed into law. The CRRSA provided $10 Billion to the Child Care and Development Block Grant (CCDBG).

The ACF-696 is currently approved under OMB Control Number 0970-0510 through May 31, 2021. A full request to extend approval of this form is currently underway. At this time, ACF is seeking approval for NonSubstantive changes to the form and form completion instructions.

Currently, States, the District of Columbia, and five U.S. Territories that receive CCDF funding (American Samoa, Commonwealth of Northern Mariana Islands, Guam, Puerto Rico, and Virgin Islands) submit quarterly ACF-696 Financial Reports. The frequency will remain the same with additional reporting capabilities for CRRSA, since there is no financial reporting mechanism for the CRRSA supplemental CCDBG funds at this time.

Overview of Requested Changes

ACF proposes the following updates to the current form and instructions

1. Inclusion of reporting on CRRSA supplemental CCDBG funds made available by the supplemental appropriations for Coronavirus relief (P.L.116-260). This includes adding an additional reporting column to the ACF-696, but no additional cost categories

2. Addition of descriptive language in the form completion instructions concerning requirements and allowable uses of CRRSA funds

3. Minor updates and revisions to the form completion instructions necessary to improve clarity in areas where the grantee population has provided feedback.

We consider the above changes to be NonSubstantive in nature while providing improved simplicity and clarity for users of the ACF-696. As a result of the proposed changes, we have updated estimated average burden per response from 5 to 6 hours.

Time Sensitivities

The next ACF-696 Financial Report, quarter-end 3/31/21, has a due date of April 30, 2021. Since CARES Act funds were awarded during the quarter, it is important that grant recipients have a mechanism to report CRRSA expenditures. Further, it takes a significant amount of staff hours to program updates to financial reporting forms in ACF’s grant reporting system. Therefore, a prompt approval is desired to ensure timely reporting can be achieved by the state and territory CCDF grantee population.