The National Indian Child Care Association (NICCA) has submitted comments to the Administration for Children and Families in response to proposed changes in the Child Care and Development Fund (CCDF) regulations. These changes seek to grant Tribal Lead Agencies more flexibility in determining family income eligibility for child care services, an adjustment that aligns with the needs and sovereignty of Tribal Nations.
Supporting Tribal Sovereignty and Flexibility
NICCA fully supports the proposed rule change that would allow all Tribal CCDF Lead Agencies to serve Indian children, as defined by the Tribal Lead Agency, regardless of family income or assets. Under current regulations, Tribes with larger CCDF allocations are subject to federal income eligibility standards, which often limit their ability to serve their communities effectively. The proposed change would extend the flexibility currently afforded to smaller Tribes to all Tribal Nations, empowering them to design child care programs that better meet their unique needs.
Aligning with Executive Order 14112
The proposed changes align with Executive Order 14112, which calls for increasing the accessibility, equity, flexibility, and utility of Federal funding for Tribal Nations. By allowing Tribes to exercise categorical eligibility, the proposed rule enhances Tribal sovereignty and promotes more tailored, community-based solutions for child care. This is an essential step in ensuring that federal programs can be effectively utilized to support the well-being of Indian children and families.
Reducing Administrative Burdens and Aligning with Tribal Head Start
NICCA also emphasizes the importance of aligning CCDF eligibility rules with those of the Tribal Head Start program, which recently eliminated family income requirements. This alignment will reduce administrative burdens for Tribal Lead Agencies and create a more coherent system for delivering early childhood services. Such consistency is crucial for streamlining access to high-quality early education and care across Tribal communities.
Key Benefits of the Proposed Rule Change
The proposed regulatory changes offer several key benefits:
Self-Determination:Â Supporting Tribal sovereignty by allowing Tribes to define eligibility criteria based on their specific needs.
Increased Access:Â Removing income eligibility requirements will broaden access to CCDF services, especially for families facing financial hardship.
Alignment with Head Start:Â Aligning CCDF with Tribal Head Start rules reduces administrative complexities and enhances program coherence.
Community-Based Solutions:Â Tribal Nations are best positioned to understand and address their communities' needs. This rule provides them with the flexibility to do so.
NICCA's Commitment
NICCA urged the Administration to finalize this proposed rule promptly, as it is a critical step toward empowering Tribes and improving the lives of Indian children and families. This proposal not only upholds Tribal sovereignty but also promotes accessible, equitable, and high-quality early childhood care and education across Indian Country.
By advocating for these changes, NICCA continues to work toward a future where all Indian children have the support they need to thrive. We look forward to continued collaboration with the Administration to build a robust and effective system that serves the best interests of our children, families, and communities.
Comments