Tribes and States Working Together: A Guide to Tribal-State Child Care Coordination
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A Comparison of State and Tribal CCDF Programs
| "We have benefited from our collaborations with the Tribes...[they have] allowed us to provide access to resources and share information on the child care subsidy and quality programs."
- Laura Saterfield |
The purposes and goals of Federal CCDF funding are the same for States, Territories, and Tribes: to increase the availability, affordability, and quality of child care services. Further commonality is found in the CCDF Act provision that Indian children have what is known as “dual eligibility.” This means that parents of eligible Indian children may apply for and receive child care assistance from either the Tribe or the State. However, in order to receive services under a State or Tribal program, the child must still meet the other specific eligibility criteria of that program.
There are some differences between the CCDF requirements for Tribes and those for States and the Territories. These unique Tribal requirements are primarily found in Subpart I of the CCDF final regulations (45 CFR Parts 98 and 99). Highlights of these Tribal differences are described below.
- Within their CCDF plans, Tribes must define their CCDF service areas. Many include communities located both on and near reservations. It should be noted that most Tribes in Alaska, California, and Oklahoma do not live on reservations and, therefore, are encouraged to work together to ensure that their service areas are not overlapping.
- Tribes must provide a definition of “Indian Child” in their CCDF plans.
- Tribal CCDF funding is based on an annual certified child count of all children under the age of 13 who reside within the Tribe’s designated service area and meet the Tribe’s definition of “Indian Child.”
- Federally recognized Tribes with fewer than 50 children under the age of 13 may apply for CCDF funds as part of a consortium arrangement. For example, four Federally recognized Tribes elect to receive CCDF services as members of the South Puget Inter-Tribal Planning Agency of Shelton, Washington.
- In determining CCDF eligibility guidelines, Tribes may use the State or Tribal median income.
- Tribes may use their State’s market rate surveys, sliding fee schedules, and provider payment rates or develop their own.
- Tribes have the option of using Tribal, State, or local child care licensing requirements. Federal Minimum Standards for Tribal Family Child Care Homes and Minimum Standards for Tribal Child Care Centers are available to Tribes as guidance.
- Upon approval by their ACF Regional Offices, Tribes may use some of their CCDF funds for the construction and renovation of child care facilities. However, they must ensure that they will not decrease the level of services to families if they plan construction or major renovation efforts.
| "It's all about dialogue. We're not doing anything fancy, just respecting each other and realizing that we are all working on the same [child care] things. Lots of State folks don't realize how little [CCDF] fund some tribes receive...." |
Another important Tribal CCDF distinction is that Tribes that receive a fiscal year CCDF allocation equal to or greater than $500,000 are considered “non-exempt” grantees. This distinction means that (1) the Tribe must expend no less than four percent of the aggregate CCDF funds in a fiscal year on quality activities, and (2) the Tribe must operate a certificate program that offers parental choice from a full range of providers (i.e., center-based, group home, family child care, and in-home care), including sectarian (“faith-based”) providers. Tribes that receive less than an annual $500,000—which is less than the smallest state allocation—are considered “exempt” and may chose to spend their child care funds all on direct services within Tribal child care centers, all on certificates, or a combination of services. “Exempt” Tribal CCDF grantees are not held to the four percent quality expenditures requirement.
The Indian Employment, Training and Related Services Demonstration Act of 1992 (PL 102-477), as amended, permits Tribes to consolidate CCDF with a number of Federal employment, training, and related services programs into a single, coordinated, comprehensive plan. The Office of Self-Governance and Self-Determination, U.S. Department of the Interior, serves as the Lead Agency for all PL 102-477 plans. Currently 31 of the 265 Tribal CCDF grantees operate their child care services through approved PL 102-477 plans.
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