Q1: May States get a Y2K extension for filing the first caseload reduction credit report?
A: Every State should make a concerted effort to submit its FY 2000 caseload reduction credit report on time (i.e., by 12/31/99). However, if a State experiences extraordinary circumstances, related to Y2K, that impede its ability to submit the report on time, we will consider granting it an extension of the report deadline. Any State in this situation needs to request an extension.
Q2: May States have at least until December 31 to file the annual report? What about allowing 45 days more? What are the implications if a State fails to submit the annual report in a timely manner?
A: Although we said that the annual report is due at the same time as the fourth-quarter data report, i.e., November 15th of each year, since the statute and regulations both hold States harmless from a reporting penalty if they submit the required quarterly reports by December 31, we have decided to allow the same latitude on the submission of the annual report. Thus, a State could have until December 31 to file the annual report required under ยง265.9 of the final rules.
We would not allow a later submission because the annual report contains two pieces of information that could trigger a penalty against the State for failure to file complete, accurate, and timely data. Also, in a couple of instances (i.e., the MOE program information and information on domestic violence strategies and waivers), the annual report may provide information needed to determine whether a State is penalty-liable.
Finally, these annual reports will provide valuable information about the different ways that States are using their resources to help families attain and maintain self-sufficiency. We intend to synthesize the information provided in the State annual reports when we discuss program characteristics in our annual report to Congress. We also will use the information in responding to Congressional and public inquiries on how TANF programs are evolving. Thus, it is very important that States submit the information required in these reports in a complete, accurate, and timely manner.
