NonSub Change Request - CARES Act

To: Jordan Cohen

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: October 22, 2020

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 March 27, 2020 the Coronavirus Aid, Relief and Economic Security Act (CARES Act), P.L. 116-136, was signed into law. The CARES Act provided $3.5 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. At this time, ACF is seeking approval for nonsubstanive 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 CARES Act, since there is no financial reporting mechanism for CARES Act CCDBG funds at this time.

Overview of Requested Changes

Updates were made to the previously approved form to: (1) include reporting on CARES Act CCDBG funds made available by the supplemental appropriations for Coronavirus relief (P.L.116-136) – this includes additional reporting columns to the ACF-696T, but not additional cost categories; (2) add descriptive language in the form completion instructions concerning requirements and allowable uses of CARES Act funds; (3) make 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

As previously noted, Tribal CCDF grantees submit annual ACF-696T Financial Reports. The frequency will remain the same with additional reporting for CARES Act funds.

The next ACF-696T Financial Report, quarter-end September 30, 2020, has a due date of December 29, 2020. Since CARES Act funds were awarded during Federal Fiscal Year 2020, it is important that grant recipients have a mechanism to report CARES Act expenditures. Therefore, a prompt approval is desired.