NonSub Change - % Chg CCDF Pooling Reasoning

To: Kelsi Feltz

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Helen Papadopoulos

Office of Child Care (OCC)

Administration for Children and Families (ACF)

Date: October 24, 2023

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

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

Background

The ACF-800 form is an approved collection with an expiration date of March 31, 2025. 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 annual aggregate data on the children and families receiving direct services under the CCDF.  The implementing regulations for the statutorily required reporting are at 45 CFR 98.70 and 98.71.

The ACF-800 collects information on the number and characteristics of families and children served, and the providers that serve them, including information on the funds used to provide the child care services. States who pool the funds to provide child care services report a pooling factor on the ACF-800 (data element #13), which indicates the percent of CCDF funds that make up the pool. If the percent is less than 100%, the state is pooling its funds to provide child care services and is reporting all families and children served. OCC uses the pooling factor to calculate the families and children served funded with CCDF dollars. OCC provides technical assistance to states to ensure that they accurately report the pooling factor. As currently reported, OCC can see if funds are pooled and how the percentages change from year to year but does not have an understanding for why there is fluctuation from year to year. To that end, OCC is interested in asking states to describe the reason when there is a change greater than or equal to five percent (>= +/- 5%) to the pooling factor as compared to last year. This information will assist OCC in understanding why pooled funding fluctuates from year to year and identifying states who may need further technical assistance when calculating the pooling factor. This follow-up question will allow OCC to fulfill the uses of the data collection as already approved (See supporting statement A for described purposes and uses of the data collected).

Overview of Requested Changes

OCC is requesting to add a follow-up question associated with the reporting of data element # 13, pooling factor. After answering data element #13 (percent of pooled funds that are CCDF funds), the percent change from the previous year will be calculated automatically. If that change is an increase or decrease of 5% or more, states will be asked to provide an explanation. Specifically, for the states who pool funds to provide child care services, the follow-up question to #13 would read:

13a. If this year's pooling factor has changed more than +/- 5% since last year, please

explain what led to the change

Time Sensitivities

OCC is interested in implementing this follow-up question for the FY2023 ACF-800 report, which is due by December 31, 2023. Once approved, OCC will update the Child Care Automated Reporting System (CARS), which is the web-based system states use to report the ACF-800 data, to incorporate this follow-up question.