NonSub Change Memo - ACF 696T 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 16, 2021

Subject: NonSubstantive Change Request – Child Care and Development Fund (CCDF) ACF-696T 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-696T Financial Report for Tribal grantees (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-696T is currently approved under the Generic Clearance for Financial Reports (OMB # 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, Tribal CCDF grantees submit annual ACF-696T 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-696T, 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-696T.

Time Sensitivities

The next ACF-696T Financial Report, quarter-end September 30, 2021, has a due date of December 29, 2021. Since CRRSA funds were awarded during Federal Fiscal Year 2021, it is important that grant recipients have a mechanism to report CARES Act expenditures. Further, it takes aa 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 tribal CCDF grantee population.