CHILD CARE DEVELOPMENT FUND OVERVIEW

The Child Care and Development Fund (CCDF), also known as Child Care and Development Block Grant (CCDBG), is the main source of funding for child care across the country, including Indian Country. 263 grantees, representing over 500 Tribes and Tribal organizations received Child Care and Development Block Grant (CCDBG) funds in FY 2013, with Tribal allocations totaling approximately $102 million. Recent reauthorization of CCDBG amended the Tribal set-aside language from stating that Tribes would receive between 1% and 2% of the amount allocated to CCDF to state that Tribes would receive no less than 2%. Historically, Tribes have received 2% of the allocated CCDF funding which is divided into mandatory and discretionary money. The final Tribal allocation is to be determined by the Secretary.

 

Scroll down for more information on the CCDF.

NICCA POLICY RECOMMENDATIONS

The following recommendations have been made by NICCA and Tribal leaders and program staff are encouraged to use these recommendations in their own conversations with other government leaders. 

 

For a printable version of the NICCA policy recommendations, click here.

Policy Revisions
  • Maintain Family-Friendly Policies

  • ​Implement 12 month eligibility re-determination periods 

  • Determine priority for homeless families 

 

Child Care Workforce
  • Allow for cultural skills and knowledge to be incorporated in building the knowledge and skills of the child care workforce 

  • Require States to communicate, coordinate, and collaborate with any Tribe in their jurisdiction for training opportunities and professional development

  • Consider Tribal cultures, traditions, and customs in providing training and progression to improve the knowledge of providers

 

Funding
  • Increase the Tribal CCDF funding set aside to 5% 

 

Tribal Data
  • Support data collection for Tribes and Tribal programs

  • Allow for site visits to all CCDF providers

  • Enter the Plan PrePrint into a database by each CCDF grantee to allow information to be utilized to outline the services that Tribes are providing for their children and families

  • Support Tribal participation in data collection 

  • Promote data accessibility and dissemination

 

Health & Safety
  • Impelement standards & monitoring processes to ensure the health and safety of child care

  • Update OCC’s Tribal Health and Safety Standards and establish health and safety requirements only in consultation with Tribes, acknowledging Tribal customs

  • Provide Tribes access to criminal background check databases 

 

Child Development
  • Allow the methodology in promotion of social-emotional health and development of children to be self-determined by Tribes 

 

Reporting
  • Develop a reporting mechanism that can be entered into a database and be accessible and searchable for Tribes

  • Consider in CCDF reporting the type of programs being operated and how the CCDF funds might be utilized in a Tribal Center versus a voucher program

 

Quality Enhancements
  • Provide supports for continuous quality improvement for Tribal child care

  • Provide training and funds for any new mandates 

 

Consumer Knowledge & Parental Access
  • Develop tools to assist information dissemination on the full range of child care services 

  • Allow parental access to provider-specific information on monitoring reports 

 

Training & Technical Assistance
  • Establish comprehensive strategy for providing training and technical assistance to all CCDF providers

  • Allow for site visits to all CCDF providers

  • Support Regional OCC staff to provide technical assistance to CCDF providers

 

Other Areas
  • Include grievance or appeal processes if there are penalties in the proposed late/non-reporting protocol  

  • Remove exempt/non-exempt threshold requirements for small Tribes

 

Tribal CCDF Plan Redesign
  • Redesign the Tribal Plan PrePrint to be completed online and stored in a database that will capture the information in a format where it can be used to provide relevant information regarding Tribal child care

  • Work with small Tribes for Tribal Plan revision in consultation with the Tribes 

 

 

Overview of CCDF

Mandatory funding is allocated through the reauthorization process and is effective until the CCDBG is reauthorized and the long-term funding determined. The discretionary funding is subject to the annual budget process. For 18 years NICCA has advocated for a set-aside increase of 5%. With no substantial increase in new funding for CCDF for the past 14 years, an increase to the set-aside would have cut funding to states and territories and was not a popular theme with policy makers. This past year saw a very small increase to CCDBG with the reauthorization. The Tribal set-aside for discretionary CCDF was increased to 2.5%.

 

Federally recognized Tribal governments that apply for CCDF receive funding if they have 50 or more children under the age of 13 years or if they are in a consortium with a combined total of 50 or more children under the age of 13. Since implementation of the CCDF in 1996, more Tribes have applied for funding, which means that more Tribal children have access to CCDF but also means that the 2% set-aside gets smaller and smaller as it is divided into more and more pieces.

 

Tribes apply for CCDF through a process called the Plan Pre-Print which is completed every other year and is the blueprint for implementing the Tribe’s child care services. The plans include lists of questions and are completed by the Tribe and submitted to regional offices via an electronic file such as Word. The Tribal CCDF Plans are not compiled in any kind of a data gathering system that can generate information about Tribal child care programs throughout Indian Country.

Full Policy Recommendations

The following provides additional information and context around the policy recommendations above.  Click print to get a printable version. 

 
Policy Revisions

 

Maintaining Family-Friendly Policies

  • NICCA recommends that there should be included hardship waivers to allow for care in the child’s home under certain circumstances or for multiple children

 

Implementing 12 month eligibility re-determination periods

  • NICCA recommends continued flexibility for self-determination of definition of income. NICCA also recommends that Tribes have flexibility in implementing eligibility and re-determination periods. Having a set 12 month eligibility period is not realistic for all Tribes. This may create a hardship for smaller grantees who cannot afford to maintain a waitlist for eligible families, when a parent who may no longer meet eligibility remains on the program for 12 months. Many families have several children who enter care and while we support the importance of continuity of care, it isn’t always reasonable, or fiscally responsible, to continue to subsidize parents who do not remain employed for a long period of time, but may bounce in and out of employment until they find stability in the workforce. Especially if there is a waitlist of eligible parents, this can be a hardship for Tribal Grantees to justify keeping families who are not working or attending school in the program for 12 months. As many as 58% of Tribal Grantees currently maintain a waitlist.

 

Priority for homeless families

  • NICCA recommends that Tribes should self-determine or define “homeless”, allowances for informal custody of family members i.e. grandmother taking care of grandchildren without court guardianship documents.

NICCA continues to be concerned about:

 

  • The inadequate funding levels for Tribal child care;

  • The failure of legislation and policy to fully address the rights and abilities of Tribes to participate in Federal domestic assistance programs; and

  • Inconsistent relationships between Tribes and States that have hampered Tribes’ abilities to fully implement needed services for children and families.

 
Health & Safety

 

Standards & Monitoring Processes to Ensure the Health and Safety of Child Care

  • NICCA recommends that Tribes should have standards & monitoring processes to ensure health and safety of child care in place. If Tribal Grantees should require additional support for standards of monitoring, there will be efforts made to provide T/TA and the ability to incorporate tribal culture, customs and traditional care.

 

Updating OCC’s Tribal Health and Safety Standards

  • NICCA recommends that the OCC’s Tribal Health and Safety Standards (Orange Book) should not be updated without consultations with Tribes and the ability to incorporate tribal culture, customs and traditional care

 

Establishing health and safety requirements in 10 topic areas

  • NICCA recommends that when establishing health and safety requirements in 10 topic areas that should be established in consultation with Tribes and allow for the flexibility of incorporating tribal customs and traditions for care, as well as consider the type of care and size of each program when setting requirements for Tribal Grantees

 

Conducting comprehensive criminal background checks on all child care staff

  • NICCA asserts that the length of time it takes to get comprehensive criminal background check results can be a barrier. Tribes need access to criminal background check databases or one should be established for Tribes. Often child care providers are needed with little to no notice

 
Quality Enhancements

 

Supporting Continuous Quality Improvement

  • NICCA recommends that there be supports for continuous quality improvement for Tribal Child Care, and take into consideration that in supporting continuous quality improvement for Tribes, there must be flexibility and willingness to allow for tribal customs and traditions for care

 

Introducing the Tribal Quality Framework

  • NICCA recommends that training and funds should be provided for any new mandates as well as Tribal Consultation

 
Child Care Workforce

 

Building Knowledge and Skills of Child Care Workforce

  • NICCA recommends that Building Knowledge and Skills of Child Care Workforce - Should allow for cultural skills and knowledge to be incorporated in any requirements.

 

Accessing State training and professional development

  • NICCA recommends that States should be required to communicate, coordinate and collaborate with any Tribe in their jurisdiction for training opportunities and professional development. States should be required to show documentation of communication with each Tribe in their jurisdiction. States should fund participation as much as possible.

 

Providing ongoing annual training and progression to improve knowledge of providers

  • NICCA recommends that when providing ongoing annual training and progression to improve the knowledge of providers Tribal culture, traditions, customs should be taken into consideration. NICCA also recommends that an annual Regional CCDF training be provided in every Region in order to best meet the diverse needs of each Region and to accommodate the grantees access to training.

 

Enhancing health and safety training

  • NICCA recommends that Tribal culture, traditions and customs should be taken into consideration; best practices should be shared. When enhancing health and safety, there should be ongoing supports and T/TA that meets the needs of the Tribal Grantees

 
Child Development

 

Promoting the social-emotional health and development of children

  • NICCA recommends that the methodology in promotion of social-emotional health and development of children should be self-determined by Tribes. Tribal culture, traditions and customs should be taken into consideration; tools should be developed to assist caregivers and parents to understand behavioral health and child/brain development.

 
Consumer Knowledge & Parental Access

 

Disseminating information on the full range of child care services

  • NICCA recommends that tools/templates should be developed to assist dissemination of information. Allowance for tribal language should be taken into consideration.

 

Parental access to provider-specific information on monitoring reports

  • NICCA recommends that parents should participate or have a role in monitoring their providers.

 
Funding

 

Tribal CCDF Funding

  • NICCA recommends that the Tribal CCDF Funding set aside is increased to 5%. 

 
Reporting

 

CCDF Reporting

  • NICCA recommends that Tribal CCDF programs should have a reporting mechanism that can be entered into a database and be accessible and searchable for Tribes. The information captured should reflect all CCDF services provided by the Tribes, not just a piece of what Tribal CCDF programs accomplish

  • NICCA recommends that CCDF reporting take into consideration the type of programs being operated and how the CCDF funds might be utilized in a Tribal Center vs a voucher program. Reporting should make sense for smaller grantees that may have additional funding supports from their Tribe, as well as larger Tribal grantees that offer multiple services with their CCDF.

 
Training & Technical Assistance

 

Providing training and technical assistance to Tribes

  • In addition to mandatory Tribal Grantee standards and monitoring processes to ensure health and safety of child care, the Office of Child Care (OCC) has a responsibility to provide training and technical assistance (T/TA) to Tribes to ensure the new regulations set forth by the CCDF laws are followed.

  • NICCA recommends OCC establish annual site visits and TA of ALL CCDF providers: NICCA is in support of all tribes receiving site visits and guidance from OCC, including smaller tribes that receive less funding. NICCA suggests that ACF/OCC Regional staff take on a role and have an increased travel allowance to support the T/TA needed for those Tribal Grantees who need it the most. The OCC Regional Staff should know their Tribal Grantees best, and have the relationship with the Tribal Grantee to support as deemed necessary and as a priority. T/TA funding should be made available so this can take place. Furthermore, we acknowledge the burden that such an undertaking would be, however we recommend a variety of methods to address the need to ensure the overall safety of children while in care. The goal and intention is to bring the standard of care to the highest reasonable quality for ALL children regardless of family income. In order to meet this goal, there must be a system that takes into consideration the diversity within communities providing Tribal Child Care.

  • Although smaller tribes may have fewer resources, all tribes should make an effort to adhere to the new health & safety regulations. Exceptions could be made for smaller tribes with limited resources. In this instance, the tribe could request a waiver for that regulation and present a plan as to how they would address the issue without compromising the health and safety of the children in care.

  • Peer monitoring is a suggested option in how this could address the issue without comprising the health or safety of the children in care. Utilizing the established Tribal leaders in our field to support the efforts to ensure each Tribal Grantee has an annual monitoring review, with supportive measures to reach all Tribal Grantees, regardless of size or funding amount.

  • NICCA does not support less T/TA for smaller Tribes, as they often have the least funding and resources available to support higher quality child care, quality enhancements, more stringent health and safety regulations, less staff supports, and the means to engage families who may live in remote locations with limited means of reaching the families being served, or who might be served.

 
Tribal Data

 

Support the Tribal data collection

  • NICCA is concerned about the continued lack of Tribal data. Tribes need data similar to states.

  • NICCA recommends that the Plan PrePrint be entered into a database by each CCDF grantee similar in style of the state’s so that the information from the Tribes’ Plan PrePrints can be utilized to outline the services that Tribes are providing for their children and families

  • 102-477 Tribes should contribute to child care data; data should be accessible and disseminated annually.

 
Tribal CCDF Plan Redesign

 

Re-designing the Tribal CCDF Plan

  • NICCA recommends that the Tribal Plan PrePrint be re-designed to be completed online by the Tribes in a database that will capture the information from Tribes in a format where the information entered can be assimilated to provide relevant information regarding Tribal Child Care (as the state and territory plans are currently entered into a database and assimilated) . No data currently exists that is relevant to Tribal CCDF programming.

  • NICCA recommends that if the smaller Tribal Grantees have a revised Plan, that this is done in consultation with Tribes. A modified Plan should be flexible to meet the diverse needs of Tribes and continue to maintain best practices with flexibility of the diversity of the Tribal Grantees. 

Other Areas

 

Proposed late/non-reporting protocol

  • NICCA recommends that the proposed late/non-reporting protocol should include grievance or appeal process if there are penalties

 

Requirements that should not apply to small Tribes

  • Exempt/Non-exempt threshold

 

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