NonSub Change Memo - COVID-19 CARES Act

To: Josh Brammer

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Shannon Christian

Office of Child Care

Administration for Children and Families (ACF)

Date: June 26, 2020

Subject: NonSubstantive Change Request – Child Care and Development Fund (CCDF) Annual Aggregate Report (ACF-800) - (OMB #0970-0150)

This memo requests approval of nonsubstantive changes to the approved information collection, CCDF Annual Aggregate Report (ACF-800) (OMB #0970-0150).

Background

The ACF-800 collects annual aggregate data on the children and families receiving direct services under the CCDF from states and territories, as required by the Child Care and Development Block Grant (CCDBG) Act. The form was last renewed in February 2019 and has a current expiration date of February 28, 2022.

In support of the COVID-19 response, the CARES Act was enacted, which included a $3.5 billion increase in the CCDF for States, Territories, and Tribes. The supplemental funding must be used for activities authorized under the CCDBG Act that prevent, prepare for, and respond to COVID-19.

Based on feedback from states and other information, the Office of Child Care (OCC) has determined it would be challenging to establish significant new data reporting requirements at this juncture. Therefore, we are requesting OMB approval of nonsubstantive changes to the current ACF-800. Specifically, we propose to ask States to submit aggregate annual estimates on a few additional key data points —such as number of families and children served whose subsidy was funded with CARES Act dollars. We believe States will be able to report these figures since they are estimates and aggregate numbers (rather than case-level data).

Overview of Requested Changes

This nonsubstantive change request includes the modification of the Comments field (element #15) on the CCDF ACF-800 form to ask States to include:

1. A description of which population of families, children, and providers were reported under questions #1, #2, and #8 of the ACF-800 form (i.e., the extent to which CARES Act funds services are included); and

2. Numerical annual estimates of families, children and providers receiving subsidies for slots only, funded through grants, contracts, or certificates:

• Number of families and children served whose subsidy was partially or fully funded with CARES Act dollars;

• Number of essential worker (e.g., medical workers, first responders, etc.) families and children served because of the COVID-19 crisis (funded with CARES Act and broader CCDF dollars);

• Number of providers that served children of essential workers because of the COVID-19 crisis (funded with CARES Act and broader CCDF dollars); and

• Number of providers that closed for some period of time and received subsidies based on enrollment (funded with CARES Act and broader CCDF dollars)

These proposed changes do not impact the estimated average time to complete the ACF-800. The updated form and instructions are included with this request.

Time Sensitivities

We would like to provide guidance to states by July 13, 2020.

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