NICCA Submits Feedback on the Native Children’s Commission Implementation Act of 2025

The National Indian Child Care Association (NICCA) is committed to ensuring that Native children and families have access to high-quality, culturally grounded care and education. This week, NICCA submitted formal feedback to the Senate Committee on Indian Affairs on the Native Children’s Commission Implementation Act of 2025, an important bill that lays out new structures, resources, and opportunities for Tribes.

Our comments affirm the strong direction of the legislation and recommend specific improvements to make it more responsive to the needs of Tribal communities.

What We Support

NICCA strongly supports the bill’s provisions that:

• Create an Office on Native Children and a National Clearinghouse on Native Children to coordinate data and programs across agencies.

• Increase Tribal funding in the Child Care and Development Block Grant (CCDBG) from 2% to 5%.

• Authorize Tribal nutrition pilots under the Child and Adult Care Food Program (CACFP) and school meal programs, with reimbursement at a State-like level.

• Strengthen the 102-477 program, reducing fragmentation and expanding flexibility for Tribes to integrate child care, workforce, health, and nutrition programs.

What We Recommended

To make the bill even stronger, NICCA recommended that Congress:

Unlock existing data now

While the Clearinghouse is being built, federal agencies already hold critical Tribal child care and workforce data—such as Tribal CCDF plans, ACF-700 reports, and 102-477 reports—that are not currently accessible to Tribes or Tribal organizations. NICCA urged Congress to require federal agencies to make these datasets available immediately, with proper privacy protections.

Ensure Tribal sovereignty in CACFP

Tribal governments cannot serve directly as sponsoring agencies in CACFP, forcing them to work through States or third parties. NICCA recommended permanent language authorizing Tribes to contract directly with USDA as sponsoring agencies, with State-like reimbursement and authority, and urged support for including traditional foods and streamlining procurement for Tribal sponsors.

Fund Tribal child care without penalizing States

NICCA supports raising the CCDBG Tribal set-aside to 5%, but urged Congress to ensure this increase does not reduce State allocations. We recommended:

• Funding the increase through overall increases or supplemental add-ons;

• Commissioning a Tribal “true cost of care” study to guide equitable rates; and

• Extending Tribal CCDF plan cycles from 3 years to 5 years for more flexibility and stability.

Strengthen 102-477 for early childhood integration

NICCA recommended explicitly clarifying that CCDF, Head Start/EHS, maternal-child health, and nutrition pilots are eligible for inclusion in 477 plans. We also called for aligned data standards and minimal reporting requirements that would reduce duplication while still capturing important information on children and families served.

Additional improvements

Finally, NICCA recommended that the bill:

• Codify that evaluations incorporate Indigenous methodologies and practice-based evidence;

• Mandate that interagency committees, especially the Early Childhood Tribal Advisory Committee, work to dismantle cross-agency barriers to child care and early learning; and

• Ensure that Tribal organizations, such as NICCA, are formally included in advisory bodies.

Why This Matters

Taken together, these recommendations would:

1. Unlock data that is already available but hidden from Tribal use,

2. Empower Tribes to exercise full sovereignty in administering CACFP,

3. Increase Tribal child care funding without creating losses for States,

4. Maximize the flexibility of 102-477 integration for holistic, community-driven systems, and

5. Ensure that all aspects of implementation reflect Indigenous knowledge and Tribal leadership.

   
   

Read the Full Submission

You can download NICCA’s full feedback submission to the Senate Committee on Indian Affairs.

Download NICCA's Feedback

NICCA will continue to advocate for policies that strengthen Tribal sovereignty, ensure equitable funding, and affirm the identities and well-being of Native children.

📬 How to Submit Your Own Feedback

The Committee is accepting feedback on the Native Children’s Commission Implementation Act through September 12, 2025. We encourage all Tribal leaders, child care providers, and advocates to share their perspectives.

Please submit your comments by email to: Murkowski_Outreach@Indian.Senate.Gov.