Supporting Statement.CCDF Reauthorization NPRM

SUPPORTING STATEMENT

JUSTIFICATION FOR INFORMATION COLLECTION

Child Care and Development Fund (CCDF) Reauthorization Notice of Proposed Rulemaking

A. JUSTIFICATION

1. Circumstances Making the Collection of Information Necessary

The Administration for Children and Families proposes to amend the Child Care and Development Fund (CCDF) regulations at 45 CFR Part 98 to reflect the reauthorization of the Child Care and Development Block Grant Act in 2014. The proposed rule makes changes to: protect the health and safety of children in child care; help parents make informed consumer choices and access information to support child development; provide equal access to stable, high quality child care for low-income families; and enhance the quality of child care and the early childhood workforce. The proposed rule includes two new information collections—(1) a requirement that States establish a consumer education website; and (2) a provision that States, Territories and Tribes require child care providers providing CCDF services to report serious injuries or deaths of children to a designated State, territorial or tribal entity. These collections do not involve Federal forms. All other information collections referred to in the proposed rule are covered by existing OMB-approved collections.

2. Purpose of Information Collection

Consumer Education Website: Section 45 CFR 98.33 of the proposed rule requires State and Territory Lead Agencies administering the CCDF program to provide consumer education information through a consumer-friendly and easily accessible website. The website must include provider-specific information related to health and safety (including results of monitoring and inspection reports), and quality (if available for the provider). This information will help parents choose a safe, quality child care provider that meets their needs. This website requirement applies to the 50 States, District of Columbia, and five Territories that receive CCDF grants.

Reporting of Serious Injuries and Deaths in Child Care: Section 45 CFR 98.42 of the proposed rule requires Lead Agencies administering the CCDF program to establish procedures that require child care providers that care for children receiving CCDF subsidies to report to a designated State, territorial, or tribal entity any serious injuries or deaths of children occurring in child care. This is necessary in order for States to make this information available to the public, and to be able to examine the circumstances leading to serious injury or death of children in child care, and, if necessary, make changes to health and safety requirements and enforcement of those requirements in order to prevent any future tragedies. The requirement would potentially apply to the nearly 400,000 child care providers who serve children receiving CCDF subsidies, but only a portion of these providers would need to report, since our burden estimate assumes that no report is required in the absence of serious injury or death. Using currently available aggregate data on child deaths and injuries, we estimated the average number of provider respondents would be approximately 10,000 annually.

3. Use of Improved Information Technology and Burden Reduction

Consumer Education Website: The requirement for a website ensures that the information will be readily available to parents. Approximately 35 States already have a website in place that meets at least some of the proposed requirements by giving provider-specific health and safety information. States will have some flexibility regarding how to implement this provision and each State will determine its own tailored approach based on existing practices, available resources, and other circumstances.

Reporting of Serious Injuries and Deaths: More than half the States already have reporting requirements in place as part of their licensing procedures for child care providers. States, Territories and Tribes have flexibility in specifying the particular reporting requirements, such as timeframes and which serious injuries must be reported. While the reporting procedures will vary by jurisdiction, we anticipate that most providers will need to complete a form or otherwise provide written information. We encourage States to use information technology, such as electronic transmission, to ease the reporting burden.

4. Efforts to Identify Duplication and Use of Similar Information

Consumer Education Website: States may use existing websites that meet the requirements.

Reporting of Serious Injuries and Deaths: States may use existing reporting procedures, if any, that meet the requirements.

5. Impact on Small Businesses or Other Small Entities

Neither of these information collections will have a significant economic impact on a substantial number of small entities. The information being required has been held to the absolute minimum required for intended use.

6. Consequences of Collecting the Information Less Frequently

Consumer Education Website: This information collection will be ongoing. States and Territories will need to periodically update their websites to ensure that the information is current and accurate. Without these websites, parents would lack critical health and safety information that they need to make informed child care choices.

Reporting of Serious Injuries and Deaths: This information collection will occur after the serious injury or death of a child that occurs in a child care setting. The information must be reported in a timely manner, as determined by the State, to ensure that any appropriate corrective action is taken to ensure children’s safety.

7. Special Circumstances

None of the special circumstances apply to these information collections.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

The proposed rule is available for public comment. The proposed rule includes a section on information collections under the Paperwork Reduction Act, and includes instructions for submitting comments on the burden estimates.

9. Explanation of Any Payment or Provided to Respondents

No payments or gifts are provided to respondents.

10. Assurance of Confidentiality Provided to Respondents

There is nothing of a confidential nature on the websites. No assurances of confidentiality will be provided.

11. Justification for Sensitive Questions

There are no questions of a sensitive nature.

12. Estimates of Annualized Burden Hours and Costs

Consumer Education Website: The public reporting burden for this collection of information is estimated to be 300 hours per response. In estimating the burden estimate, we considered the fact that many States already have existing websites. Even in States without an existing website, much of the information will be readily available from licensing agencies, quality rating and improvement systems, and other sources. The burden hour estimate below reflects an average estimate, recognizing that there will be State variation. The estimate is annualized to encompass initial data entry as well as updates to the website over time.

Reporting of Serious Injuries and Deaths: The public reporting burden for this collection of information is estimated to 1 hour per response. The requirement would potentially apply to the nearly 400,000 child care providers who serve children receiving CCDF subsidies, but only a portion of these providers would need to report, since our burden estimate assumes that no report is required in the absence of serious injury or death. Using currently available aggregate data on child deaths and injuries, we estimated the average number of provider respondents would be approximately 10,000 annually.

The estimate of the burden for these two new information collections is:

INSTRUMENT	NUMBER OF RESPONDENTS	NUMBER OF RESPONSES PER RESPONDENT	HOURS PER RESPONSE	RESPONSE BURDEN
Consumer Education Website	56 States/Territories	1	300	16,800
Reporting of Serious Injuries and Death	10,000 child care providers	1	1	10,000

Estimated Total Annual Burden Hours: 26,800

The total estimated dollar cost associated with the burden hours for the Consumer Education Website is $7500 per State/Territory. This equates to a total of $420,000 for all grantees.

The total estimated dollar cost associated with the burden hours for Reporting Serious Deaths and Injuries is $25 per child care provider. This equates to a total of $250,000 for all respondents.

The combined estimated dollar cost associated with the burden hours for both new information collections is $670,000.

13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

Consumer Education Website: Approximately 35 States have existing websites that already meet at least portions of this requirement. The remaining 21 States and Territories will face capital and start-up costs (e.g, the purchase of any hardware and equipment) needed to launch the website. In the regulatory impact analysis for the proposed rule, we estimated an average annual cost of $12.8 million for building and maintenance of the websites over the first five years.

Reporting of Serious Injuries and Deaths: There are no additional costs other than those reflected in item 12.

14. Annualized Cost to the Federal Government

There is no cost to the Federal government.

15. Explanations for Program Changes or Adjustment

Not applicable. This is a new collection.

16. Plans for Tabulation and Publication and Project Time Schedule

Consumer Education Website: States will disseminate their web addresses to the public.

Reporting of Serious Injuries and Deaths: The Office of Child Care does not plan to tabulate or publish this data, which will be reported to a designated State, Territorial, or Tribal entity (not the Federal government).

17. Reason(s) Display of OMB Expiration Date Inappropriate

Not applicable.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification.

2. STATISTICAL METHODS (USED FOR COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS)

1. Respondent Universe and Sampling Methods

(Not Applicable)

2. Procedures for the Collection of Information

(Not Applicable)

3. Methods to Maximize Response Rates and Deal with Nonresponse

(Not Applicable)

4. Test of Procedures or Methods to be Undertaken

(Not Applicable)

5. Individuals consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data

(Not Applicable)

The information collection does not employ the use of statistical methods.