Child Care and Development Fund (CCDF) State Monitoring Compliance Demonstration Packet
OMB Information Collection Request
0970 - New Collection
Supporting Statement Part A - Justification
May 2019
Submitted By:
Office of Child Care
Administration for Children and Families
U.S. Department of Health and Human Services
SUPPORTING STATEMENT A – JUSTIFICATION
Summary
Circumstances Making the Collection of Information Necessary
The Administration for Children and Families (ACF) Office of Child Care (OCC) is requesting approval for this collection of information to support a new onsite monitoring process developed to monitor states for compliance with federal regulations. The Child Care and Development Fund (CCDF) State Monitoring Compliance Demonstration Packet (Attachment A) will be the instrument used to collect the necessary information from state lead agencies.
Section 658I of the Child Care and Development Block Grant Act and Subpart J of 45 CFR, Part 98 of the Child Care and Development Fund requires the monitoring of programs funded under the CCDF for compliance with:
(1) The CCDBG Act;
(2) CCDF Regulations; and
(3) State/Territory CCDF approved Plan.
The new proposed data collection form is designed as part of the evidence collection process of the Monitoring system and provides states with an opportunity to propose how they, as block-grant recipients, will choose to demonstrate compliance. This process was designed to protect state flexibility in the implementation and administration of their program, and to ensure an efficient and effective design to the monitoring process.
Purpose and Use of the Information Collection
The information provided through this instrument will be used by OCC to monitor State CCDF Lead Agencies to determine and validate compliance with CCDF regulations and the State Plan. States have flexibility in administering the CCDF block grant and this information will establish consistency in how the monitoring team approaches the evidence collection and analysis of the state lead agency compliance.
The data collection for the first 3-years will focus on 11 topical areas: 1) Disaster Preparedness, Response and Recovery; 2) Consumer Education: Dissemination of Information to Parents, Providers, and General Public (Monitoring Reports and Annual Aggregate Data); 3) Twelve-Month Eligibility; 4) Child:Staff Ratios and Group Sizes; 5) Health and Safety Requirements for Providers (11 Health and Safety Topics); 6) Pre-Service/Orientation and Ongoing Training Requirements for Providers; 7) Inspections for CCDF Licensed Providers; 8) Inspections for License-Exempt CCDF Providers; 9) Ratios for Licensing Inspectors; 10) Child Abuse and Neglect Reporting; and 11) Program Integrity.
Use of Improved Information Technology and Burden Reduction
The States and Territories may use any available information technology to reduce the burden of information and data collection in support of the monitoring requirements prescribed in the Statute. ACF will accept the CCDF State Monitoring Compliance Demonstration Packet, and any supporting documentation, initially via email, and later in Fiscal Year 2019 via a secure web submission site referred to as the Office of Child Care Monitoring System (OCCMS). System virus checks will provide immediate feedback concerning the acceptability of the submitted documents. ACF provides technical assistance to States and Territories in the use of the web submission site (OCCMS) toward improved data submission. In addition, program analysts will review the information to ensure consistency and contact States and Territories as necessary when information is incomplete or questionable.
Efforts to Identify Duplication and Use of Similar Information
The CCDF State Monitoring Compliance Demonstration Packet does not require respondents to send any information or documentation that is accessible to OCC through other Data Collection Tools or information requests. An inventory of available reports and data was conducted to ensure that there was not a duplication of effort on the part of the respondents in providing OCC with information relevant to determining their compliance during a monitoring visit.
Impact on Small Businesses or Other Small Entities
N/A
Consequences of Collecting the Information Less Frequently
CCDF Lead Agencies will participate in monitoring based on a 3-year cohort cycle. If this information is not collected, the monitoring of State CCDF Lead Agencies and assessing compliance may be inaccurate or misrepresent the state’s implementation of the program. Ultimately, OCC will be unable to ensure compliance with CCDF requirements.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
N/A
Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency
In accordance with the Paperwork Reduction Act of 1995 (Pub. L. 104-13) and Office of Management and Budget (OMB) regulations at 5 CFR Part 1320 (60 FR 44978, August 29, 1995), ACF published a notice in the Federal Register announcing the agency’s intention to request an OMB review of this information collection activity. This notice was published on October 29, 2018, and provided a sixty-day period for public comment. During the notice and comment period, two comments were received, which are attached. (See Attachments B and C)
OCC received general comments from KinderCare Education in support of OCC’s monitoring system and the information collection documents.
The Tennessee Department of Human Services (TDHS), also submitted comments in support of the data collection, and requested additional clarification regarding the burden hours and submission of the information. ACF-OCC’s responses to comments received by TDHS, when applicable, are included as Attachment D.
In developing the Onsite Monitoring System, OCC convened a workgroup of state lead agency representatives to provide feedback and input on the design of the Onsite Monitoring System. As part of the workgroup discussions, states emphasized the need for individualized monitoring because of the complexity of each state's CCDF structure and variance in implementation strategies. As a response, OCC developed the Compliance Demonstration Packet that offers states the opportunity to propose their approach to demonstrating compliance based on how their CCDF program is administered. OCC also convened a Peer Advisory Group to consult with other federal programs and monitoring experts on the Onsite Monitoring System's development and incorporated their feedback regarding the efficiency and efficacy of the proposed process. During the development of the Onsite Monitoring System, OCC conducted pilots in a number of States (the same question was not asked of more than nine people during the pilot phase). Feedback received from pilot States and the pilot results were used to enhance the monitoring process and data collection method. Burden estimates are based on an analysis of data collected through all of the pilot visits while accounting for variance in state documentation.
Explanation of Any Payment or Gift to Respondents
N/A
Assurance of Confidentiality Provided to Respondents
N/A
Justification for Sensitive Questions
N/A
Estimates of Annualized Burden Hours and Costs
State grantees and the District of Columbia will be required to complete and submit the two instruments in the Compliance Demonstration Packet. First the Compliance Demonstration Chart will be submitted and reviewed by ACF-OCC. For this chart, OCC is looking for a high-level description of how the state proposes to demonstrate compliance. No additional materials should be submitted with this chart. After review by OCC, any changes or edits to the chart will be finalized in collaboration with the State. Once the final Compliance Demonstration Chart is submitted, the State will have 4-6 weeks to complete the Document Submission Chart and provide the associated materials.
Information Collection Title |
Total Number of Respondents |
Total Number of Responses Per Respondent |
Average Burden Hours Per Response |
Total Annual Burden Hours |
Average Hourly Wage |
Total Annual Cost |
Compliance Demonstration Chart |
17 |
1 |
16 |
272 |
$38.04 |
$10,346.88 |
Document Submission Chart |
17 |
1 |
80 |
1360 |
$38.04 |
$51,734.40 |
Totals: |
|
1632 |
|
$62,081.28 |
||
Description of cost calculations:
Job Code - NAICS 999200 - State Government, excluding schools and hospitals (OES Designation)
Wage Data as of 2017: $19.02 Hourly
Therefore to account for fringe benefits and overhead the rate is multiplied by two which is $38.04. The estimate of annualized cost to respondents for hour burden is $38.04 times 1,632 or $62,081.28.
https://www.bls.gov/oes/current/naics4_999200.htm
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
N/A
Annualized Cost to the Federal Government
The estimated annual Federal cost is $9,592.53. This includes labor costs of analysts who developed the tool and review the information submitted by grantees and contact grantees as necessary when information is incomplete or questionable. It also includes Amazon Web Services (AWS) hosting environment costs where the data submitted by the grantees is stored.
Explanation for Program Changes or Adjustments
This is a new information collection request.
Plans for Tabulation and Publication and Project Time Schedule
This data collection will be used as an intermediate step to understanding the state’s implementation of the CCDF program and ultimately assessing compliance with the federal regulations. The OCC will use this data to shape the onsite monitoring visit and determine additional validation methods that are required on the ground to confirm the state’s compliance with the federal regulations. The data collected through this instrument will not be used as a standalone source of evidence for state compliance, and therefore the results of this specific data collection will not be published.
Reason(s) Display of OMB Expiration Date is Inappropriate
N/A
Exceptions to Certification for Paperwork Reduction Act Submissions
N/A
| File Type | application/msword |
| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |