ACF-801 Supporting Statements_22Feb2022_final

ACF-801: Child Care and Development Fund (CCDF) Quarterly Case-Level Report

OMB Information Collection Request

0970 - 0167

Supporting Statement Part A - Justification

February 2022

Submitted By:

Office of Child Care

Administration for Children and Families

U.S. Department of Health and Human Services

1. Circumstances Making the Collection of Information Necessary

Section 658K of the Child Care and Development Block Grant (CCDBG) Act (42 U.S.C. 9858, as amended by Public Law 113-186) requires that states and territories submit

monthly case-level data on the children and families receiving direct services under the Child Care and Development Fund (CCDF). The implementing regulations for the statutorily required reporting are at 45 CFR 98.70 and 98.71. Case-level reports, submitted quarterly or monthly (at grantee option), include monthly sample or full population case-level data. The data elements to be included in these reports are represented in the ACF-801. The Office of Child Care (OCC), Administration for Children and Families (ACF) uses disaggregate data to determine program and participant characteristics as well as costs and levels of child care services provided.

2. Purpose and Use of the Information Collection

The case-level administrative information received through this collection provides the means to analyze and evaluate the CCDF program and the extent to which states and territories are assisting families in addressing child care needs. This collection will provide OCC with the information necessary to make reports to Congress (available at https://www.acf.hhs.gov/occ/resource/reports-to-congress), address national child care needs, offer technical assistance to grantees, meet performance measures, and conduct trend analysis.

3. Use of Improved Information Technology and Burden Reduction

ACF has made arrangements with the National Institutes of Health for secure electronic file transfer using either CyberFusion or by using Secure File Transfer Protocol (SFTP). Starting in October 2022, OCC plans to transition the ACF-801 data collection to the Child Care Automated Reporting System (CARS), similar to the collection of the ACF-901 form (OMB #0970-0584). CARS is a web-based data collection system through a secure internet web site. System edit checks provide immediate feedback concerning the accuracy of the submitted data. ACF provides technical assistance to states and territories in the use of the secure electronic system toward improved data accuracy and reliability.

4. Efforts to Identify Duplication and Use of Similar Information

This data collection is required by section 658K of CCDBG Act (42 U.S.C. 9858, as amended by Public Law 113-186) and does not duplicate any other reporting or record-keeping requirements. The implementing regulations for the statutorily required reporting are at 45 CFR 98.70 and 98.71. No similar information is being collected on CCDF program participants and related child care services that can be used to respond to the issues identified in section 658K. Collection of the information specified on the ACF-801 is necessary to comply with the Federal statute and regulations, and to ensure the availability of data to respond to inquiries regarding the progress of the CCDF program and related issues.

5. Impact on Small Businesses or Other Small Entities

This data collection effort does not involve small business or other small entities.

6. Consequences of Collecting the Information Less Frequently

Section 658K of the statute requires states and territories to transmit information collected on a quarterly basis (or monthly at state/territory option). The data are submitted no later than 60 days after the end of each quarter. In the case of a state/territory who is submitting a sample, the sample includes a minimum of 200 records for each of the three months of the quarter (October through December, January through March, April through May, and July through September, as appropriate). States and territories have the option of submitting full population or sample data.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

The collection of this information is conducted in accordance with 5 CFR 1320.6.

8. 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 December 3, 2021, Volume 86, page 68671, and provided a sixty-day period for public comment.

During the notice and comment period, one (1) comment was received, which is attached. The comment was regarding a proposed change specifically for a child’s gender (data element #24) to include “Gender X” as a third gender option. Currently, the data element provides for gender the responses “male” and “female”. OCC added a “no response” category. We will consider other changes in the future based on the commenter’s suggestion and the outcomes of work that is currently underway to inform federal guidance on gender markers, but are not taking additional steps at this time.

9. Explanation of Any Payment or Gift to Respondents

Not applicable.

10. Assurance of Confidentiality Provided to Respondents

Section 658K(a)(1)(E) of the CCDBG Act prohibits the ACF-801 report from containing personally identifiable information. The form requires a unique identifying number, other than the SSN, that is assigned by the state for each family. ACF provides technical assistance to states and territories in the use of the electronic system toward improved data accuracy and reliability.

11. Justification for Sensitive Questions

This data collection does not involve asking questions of a sensitive nature.

12. Estimates of Annualized Burden Hours and Costs

Information Collection Title	Total Number of Respondents	Annual Number of Responses Per Respondent	Average Burden Hours Per Response	Annual Burden Hours	Average Hourly Wage	Total Annual Cost
ACF-801: Child Care and Development Fund (CCDF) Quarterly Case-Level Report	56	4	25	5600	$36.76	$205,856
Estimated Annual Burden Total:				5600	Estimated Annual Cost Total:	$205,856

Fifty-six (56) states and territories respond quarterly, and based on experience and feedback, we estimate the average time per response to be 25 hours. The cost to respondents was calculated using the Bureau of Labor Statistics (BLS) job code for Social and Human Services Assistants [21-1093] and wage data from May 2020, which is $18.38 per hour. To account for fringe benefits and overhead the rate was multiplied by two which is $36.76. The estimate of annualized cost for all states and territories (56) is $205,856.

https://www.bls.gov/oes/current/oes_stru.htm

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

Operational costs for systems software computer time will average about $4,500 a year per state and territory, for a total of $252,000 for all states and territories (56).

14. Annualized Cost to the Federal Government

The estimated annual Federal cost is $513,600. This includes staff costs of program analysts who review the information to ensure consistency and contact grantees as necessary when information is incomplete or questionable. It also includes systems costs, including data base maintenance, associated with the electronic system that performs audit checks and provides feedback to the states and territories.

15. Explanation for Program Changes or Adjustments

The ACF-801 provides monthly case-level data on the children and families receiving direct child care services under CCDF. OCC added “no response” categories under the following three data elements: Child's gender, ethnicity, and race.

16. Plans for Tabulation and Publication and Project Time Schedule

Fiscal Year 1998 through 2019 data from the ACF-801 has been processed and reported in a variety of places. Specifically, data has been incorporated into the OCC’s Report to Congress, used by ACF to respond to requests from Congress, track ACF's performance under the Government Performance and Results Act, and respond to inquiries regarding the progress and effectiveness of the CCDF program as well as posted on the OCC website.

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

The expiration date is currently and will continue to be displayed at the top right corner of the ACF-801 Form.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to this form.