Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JUNE GIBBS BROWN 

Inspector General 

OCTOBER 1998 

OEI-05-98-00010 

TRIBAL CHILD CARE 
OFFICE OF INSPECTOR GENERAL 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, is 

to protect the integrity of the Department of Health and Human Services programs as well as 

the health and welfare of beneficiaries served by them. This statutory mission is carried out 

through a nationwide program of audits, investigations, inspections, sanctions, and fraud alerts. 

The Inspector General informs the Secretary of program and management problems and 

recommends legislative, regulatory, and operational approaches to correct them. 

Office of Evaluation and Inspections 

The Office of Evaluation and Inspections (OEI) is one of several components of the Office of 

Inspector General. It conducts short-term management and program evaluations (called 

inspections) that focus on issues of concern to the Department, the Congress, and the public. 

The inspection reports provide findings and recommendations on the efficiency, vulnerability, 

and effectiveness of departmental programs. 

OEI's Chicago Regional Office prepared this report under the direction of William Moran, 

Regional Inspector General and Natalie Coen, Deputy Inspector General. Principal OEI staff 

included: 

REGION HEADQUARTERS 

John Traczyk, Team Leader Linda Hall, Program Specialist

Nora Leibowitz, Project Leader

Emily Melnick

To obtain copies of this report, please call the Chicago Regional Office at (312) 353-4124. 

Reports are also available on the World Wide Web at our home page address: 

http://www.dhhs.gov/progorg/oei 
EXECUTIVE SUMMARY

PURPOSE 

To examine Tribal Child Care and Development Fund programs, focusing specifically on resource 

utilization and program operation. 

BACKGROUND 

Federal Child Care and Development Fund (CCDF) grants enable Tribes to provide child care 

subsidies to low-income Indian families so they can work, attend training or return to school. In 

fiscal year 1998, Tribes received over $60 million in Federal CCDF grants, more than doubling 

previous Federal child care grant amounts. During discussions with the Administration for 

Children and Families (ACF), questions were raised about how Tribes use and account for these 

grants. 

More than 17,000 Indian children currently receive child care services funded wholly, or in part, 

by CCDF Tribal grants. State CCDF programs also serve Indian children, as dual eligibility 

provisions within the law permit Indians to access the CCDF program through Tribes or the State. 

Tribes in 31 States receive CCDF grants directly from the Federal Government. 

We visited 29 Tribal CCDF programs in Alaska, Arizona, California, New Mexico, Oklahoma, 

Washington and Wisconsin. More than 60 percent of the Tribal CCDF grantees are located in 

these seven States. Tribes in these States receive 80 percent of 1998 Tribal CCDF funding. The 

Tribes we visited account for one-third of the total 1998 CCDF funding to Tribes. We selected 

them based on geographic location, Tribal population, number of children served and CCDF grant 

amounts. We also considered whether Tribes ran their own program or were part of a 

consortium. Our findings are based on information obtained from the 29 Tribes we visited and 

other respondents. 

FINDINGS 

Tribal CCDF grants provide Indian children greater access to child care 

Tribes design their programs to meet community needs, providing child care services through 

center-based programs, certificate programs or both. They often use more expansive eligibility 

criteria than States, allowing more working families and parents in school to use subsidies. Tribal 

programs also improve access by making child care more affordable. 

Lack of Tribal and State coordination adversely impacts child care 

Tribes and States lack knowledge about each others’ programs. This limits access to child care 

services. Lack of coordination also impacts cost, wastes resources and increases the potential for 

fraud. Despite barriers, Tribes and States can collaborate successfully. Many Tribes use child­

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care workgroups to improve coordination and share information with other Tribes and the State. 

Impediments exist in the coordination of Head Start and child care programs 

Many Tribes separately administer their Head Start and CCDF programs. Differing views about 

program functions or absence of leadership often hinder efforts at collaboration. When 

coordination exists, Tribes can improve their use of resources. 

Child care plans, payment systems and reporting are flawed 

Tribal child care plans may not reflect current program operations. Inadequate time sheets and 

poor documentation contribute to provider payment errors and may contribute to the reporting 

discrepancies we found. Tribes that complete the Administration for Children and Families 

Annual Report (ACF-700) state that they have a difficult time making their information fit the 

form’s required categories. The ACF recognizes that Tribes have trouble completing the ACF700 and is in the process of revising the form. Nevertheless, it is unclear to us how much of the 

reported information is used by ACF. 

RECOMMENDATIONS 

To improve access to child care, we recommend that ACF encourage Tribes and States to: 

C Share information about their child care programs and create explicit policies and 

procedures for coordinating these programs. 

C Develop reciprocal licensing agreements, develop shared automated systems and establish 

single points of enrollment for Tribal families. 

We support ACF’s decision to find ways to improve coordination between Head Start and CCDF. 

We recommend that ACF: 

C Hold regional meetings that would enable Tribal Head Start and CCDF personnel to 

discuss common ground, differences and ways to overcome barriers to coordination. 

C Compile and disseminate information about Tribal best practices and model Head 

Start/child care collaborative initiatives. 

To address vulnerabilities we found in Tribal reporting and payments, we recommend that ACF: 

C Compile, develop and disseminate model time sheets and accounting practices. 

C Require Tribes reporting under Public Law 102-477 to certify that their CCDF grants 

were used for appropriate CCDF-related activities. 

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To make the most of resources provided by the technical assistance contractor and regional ACF 

staff, we recommend that ACF: 

C Ensure that the technical assistance contractor works with ACF regional office staff. 

C Encourage the technical assistance contractor to hold individual, on-site meetings with 

Tribal CCDF staff whenever possible. 

C Establish a precedent file. 

AGENCY COMMENTS 

The ACF concurred with the findings and highlighted their ongoing efforts in the areas we 

discussed in this report. Based on ACF’s comments, we made some changes and technical 

corrections to the report. The complete text of these comments can be found in Appendix A. 

The ACF concurred with all of our recommendations. The agency has taken steps to encourage 

States and Tribes to work together, and indicates that it will continue to facilitate such 

cooperation. Through its bureaus, the ACF will continue to facilitate Tribal Child Care-Head 

Start collaborations. The ACF is also taking steps to address Tribal data collection issues. 

Central office staff, regional offices and the technical assistance contractor plan to work together 

to address Tribes’ technical assistance needs. 

We recognize and look forward to ACF’s implementation of efforts to provide technical 

assistance to Tribes and to address the issues presented in the report. 

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TABLE OF CONTENTS

EXECUTIVE SUMMARY PAGE

INTRODUCTION .......................................................... 1

FINDINGS ................................................................ 4

Greater Access ............................................................ 4

Collaboration with States Impacts Care ......................................... 6

Impediments to Head Start Collaboration ........................................ 9

Plan, Payment and Reporting Flaws ........................................... 11

RECOMMENDATIONS ................................................... 15

AGENCY COMMENTS .................................................... 18

APPENDICES

A: USDA Child and Adult Care Food Program ................................. A-1

B: ACF Comments ....................................................... B-1
INTRODUCTION

PURPOSE 

To examine Tribal Child Care and Development Fund programs, focusing specifically on resource 

utilization and program operation. 

BACKGROUND 

The Federal Government has provided child care funding to families over the last 60 years. 

Currently, the impetus for providing Federal support for child care stems from increased emphasis 

on transitioning welfare recipients to work and enabling low-income working families to remain in 

the workforce. 

Obtaining affordable and safe child care is widely recognized as a major barrier that keeps families 

on welfare and out of the workforce. Parents are more likely to obtain work and remain in the 

workforce if child care is affordable, stable, conveniently located and of good quality. Child care 

helps parents reach and maintain economic self-sufficiency. 

The newly established Child Care and Development Fund (CCDF), as authorized by the Personal 

Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), assists low-income 

families and those transitioning off welfare to obtain child care so they can work or attend 

training/education. 

The CCDF brings together four Federal child care subsidy programs and allows States and Tribes 

to design a comprehensive, integrated service delivery system to meet the needs of low-income 

working families. The Child Care and Development Block Grant Act (CCDBG), as amended by 

PRWORA, now permits Tribal grantees to directly administer child care funds related to the now 

repealed Title IV-A programs (At-Risk, Transitional and AFDC child care), in addition to 

operating CCDBG programs. The amended CCDBG Act also permits Tribal grantees to use 

funds for construction and renovation purposes. 

The CCDF helps low-income families, families receiving temporary public assistance and those 

transitioning from public assistance obtain child care so they can work, attend training or return to 

school. The Administration for Children and Families (ACF) Child Care Bureau is responsible for 

oversight of the CCDF. Total funding authorized for the CCDF is $22 billion over a 7 year 

period, of which 2 percent is earmarked for Tribal child care programs. In fiscal year (FY) 1998, 

Tribes received over $60 million from the CCDF, more than doubling previous Federal grant 

amounts to Tribes for child care. 

Child Care Funding for Tribes 

Federally recognized Tribes can apply for a CCDF grant if they have at least 50 children under 

age 13. Tribes with fewer than 50 children may join with other Tribes to form a consortium. The 

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consortium can then apply for a CCDF grant. Unlike States, Tribes do not apply for or receive 

matching CCDF grants. They can apply for Mandatory and Discretionary Funds and must 

integrate the two programs and administer them through the same lead agency. 

Grants from Discretionary Funds include a base amount of $20,000 plus a per child amount 

(approximately $19 per child in FY 1998) for each Tribe with a minimum of 50 children. Tribal 

consortia receive a base amount dependent on the number of children in each of the participating 

Tribes.1 Grants from Tribal Mandatory Funds are calculated solely on a per child basis 

(approximately $81 per child in FY 1998). 

Tribal grantees must spend 63.75 percent of their total CCDF per child amount on direct child 

care services. The remaining 36.25 percent may be used to pay for child care services, 

administrative costs or activities to improve the availability and quality of child care. The base 

amount may be used for any purpose consistent with the objectives of the CCDF program. 

Fiscal year 1998 Tribal grants range from less than $22,000 to more than $8.8 million. Currently, 

243 grantees, including 27 Tribal consortia, receive CCDF grants to provide child care services to 

525 Tribes. Tribes operate centers, certificate programs or both. 

More than 17,000 Indian children currently receive child care services funded wholly, or in part, 

by CCDF Tribal grants. State CCDF programs also serve Indian children. Dual eligibility 

provisions within the law permit Indian families to access the CCDF program through Tribes or 

the State. Tribes in 31 States receive CCDF grants. 

Indian children can access child care from their own Tribes, other Tribes or from a consortium. 

Tribal CCDF programs serve Indians living in self-defined service areas. A few Tribes only serve 

members living on the reservation, but most Tribal service areas include areas off reservations. 

Some Tribes will serve any Indian child. The eligibility of Indian families for a Tribal CCDF 

subsidy does not affect their eligibility for a child care subsidy under the State CCDF program. 

Furthermore, States cannot categorically refuse to provide child care service to Indian children. 

Under the Indian Employment, Training and Related Services Demonstration Act of 1992 (Public 

Law 102-477), Tribes may elect to consolidate their CCDF funds with other employment and 

training funding. These Tribes report grant use information to the Bureau of Indian Affairs. In 

FY 1998, 15 of the 234 Tribal CCDF grantees ran child care programs as part of a consolidated 

funding plan approved under P.L. 102-477. 

1 For each participating Tribe, the consortium receives a sum equal to the fraction of $20,000 

proportional to the number of children as a fraction of 50 children. For example, a consortium consisting of 

four Tribes in which each Tribe had 25 children would receive a base amount of $40,000 ($10,000 for each of 

the four Tribes with 25 children). 

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METHODOLOGY 

We visited 29 Tribal child care programs in Alaska, Arizona, California, Oklahoma, New Mexico, 

Washington and Wisconsin.2 More than 60 percent of the Tribal CCDF grantees are located in 

these seven States. Tribes in these States receive 80 percent of 1998 Tribal CCDF funding. The 

Tribes we visited account for one-third of the total 1998 CCDF funding to Tribes. Sites were 

selected based on geographic location, Tribal population, number of children served and CCDF 

grant amounts. We also considered whether Tribes ran their own program or were part of a 

consortium, their approach to serving children and the purported relationship between the State 

government and the Tribe. In addition, we chose two sites that include CCDF funds in their 

consolidation of employment and training funds under Public Law 102-477. 

Tribal child care administrators and other Tribal employees responsible for the CCDF program 

were interviewed. We also interviewed State child care representatives in each State where we 

interviewed Tribes. We also spoke with staff from four ACF regional offices and several child 

care and Tribal interest groups. 

Tribes provided information about their CCDF programs and discussed their processes for 

enrolling children and providers. Of the 29 Tribes we visited, 9 only operate centers, 11 only use 

certificates and 9 offer both. All Tribes were asked to provide program expenditure information. 

Sixteen of the 20 grantees running certificate programs were also asked to provide canceled 

provider payment checks and copies of the underlying documents information used to derive the 

payments. We analyzed 28 checks and supporting documentation for accuracy of payment, 

adequacy of supporting documentation and potential processes vulnerabilities. We did not 

examine whether CCDF grants were appropriately spent by Tribes operating child care centers. 

We did not conduct a financial audit of the Tribal child care programs or perform a full-scale, indepth review of Tribal programs or systems. 

In addition to systems and processes, our interviews focused on coordination efforts between 

Tribal CCDF programs and other programs such as Head Start and the State CCDF programs. 

We also asked Tribal CCDF grantees about their experiences applying for grants and accounting 

for grant expenditures. 

We conducted our review in accordance with the Quality Standards for Inspections issued by the 

President’s Council on Integrity and Efficiency. 

2 We visited 24 Tribes and 5 consortia. The 5 consortia represent 10 Tribes and 22 villages. 

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FINDINGS

Tribal CCDF Grants Provide Indian Children Greater Access To Child Care 

Federal CCDF grants made directly to Tribes help Indian families to overcome barriers in 

accessing child care. In many areas, geographic isolation and transportation difficulties restrict 

Indian families’ access to State offices. Prejudice, fear, and lack of knowledge about available 

resources also keep Indian families from accessing child care through the State. Historic tensions 

between Tribes and States also impede Indian families’ access to child care. Some Tribes may not 

want to work with States due to past disputes over child custody, fishing rights, timber rights and 

sovereignty issues. State and Tribal respondents reported that Indian families are often shuttled 

back and forth between Tribal and State child care offices as they attempt to access services. 

Greater flexibility increases access to child care 

Many Tribes reported that the CCDF program allows them to determine and meet the needs of 

their members. Locally designed programs allow Tribes to offer child care services which best fit 

their community needs. Tribal CCDF child care programs include center-based programs, 

certificate systems, and a combination of the two. Some certificates are valid only for Tribal 

providers or certain types of care, while other certificate systems allow parents to choose any 

available provider in the larger community. A few Tribes reported that they will subcontract for 

care in any State licensed center. 

Tribes vary in their use of resources to serve children. The number of children Tribes can serve 

with their CCDF allocation varies significantly depending on the type of system they choose to 

administer. Some administer certificate programs that maximize the number of children served by 

paying low rates to providers. Others spend all of their resources on a center-based program 

where families can only use Tribal CCDF funds for center enrollment. For example, one Tribe 

reported that they spent $237,000 and were able to serve 125 children by operating a certificate 

program. In contrast, another grantee with a $224,000 CCDF allocation could only serve 32 kids 

in their center-based program. 

Allowing families to use certificates can improve access to services if they exist in the community. 

However, respondents from Tribes, States and ACF regional offices reported a lack of centers 

and non-relative providers in many Tribal areas. Twelve of 29 Tribes reported that they are using 

CCDF construction money to build child care centers to improve Indian families’ access to centerbased care in the future. Some Tribes have allocated Tribal funds to supplement CCDF funds set 

aside for construction and renovation. Tribes setting aside some portion of their grant for 

construction are required to maintain their service level from the previous year. Some Tribes 

want to concentrate their funding on construction without maintaining their current service level. 

They feel this would increase access to formal child care settings and improve the overall quality 

of care. 

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Some Tribes make a concerted effort to maximize the number of children served by referring 

families to the State’s CCDF program. In this way, grantees can use their CCDF allocation to 

provide child care assistance to families determined ineligible for the State CCDF. Tribes also use 

their CCDF grant to fund programs such as odd hour, infant or after-school care or other services 

that may not be available through State CCDF.3 However, sovereignty may play a role in Indian 

families’ accessing child care. Some Tribes felt it was their exclusive role to provide child care 

subsidies. In one State, where most Tribes refer families to the State for subsidies, other Tribes 

do not because they want to be able to serve their own families and do not want them to rely on 

State funds. One Tribal program did not make referrals to the State even though their centerbased program had a waiting list and there were no additional funds to serve children. 

Eligibility criteria are often more expansive than State criteria 

State CCDF eligibility criteria are often more restrictive than Tribal CCDF criteria. While States 

serve children in families earning up to 85 percent of the State median income, Tribes have the 

option basing eligibility on 85 percent of either the State or Tribal median income. Unlike States, 

many Tribal programs encourage parents’ attainment of a post-secondary education as a means of 

becoming self-sufficient. Most State CCDF programs require that parents work at least 20 hours 

per week to be eligible for child care subsidies. Under State programs, parents who work and 

attend school may only be eligible to receive child care services during their working hours. At 

least five of the Tribes we visited allow full-time students to access CCDF subsidized child care or 

will pay for full-time child care for students working part-time. 

Tribal programs often have policies that improve access to continuous care for seasonal workers 

or families receiving a Tribal dividend. In some State programs, families receiving lump sum 

payments may be ineligible for child care in the months when they receive the bulk of their 

income. Some Tribal programs recognize that these families need affordable continuous care 

even in months when they have higher than average income. Flexibility to annualize income or 

count income on a month to month basis allows Tribal programs to meet the needs of their 

members who must stretch their resources over the entire year. 

Tribal child care may be more affordable 

To improve access, Tribes attempt to make child care affordable. Experts recognize that 

affordable rates are critical to ensuring access to child care. Nationally, Indians have the highest 

poverty rate of any census group. Tribes report that State copayments are too high for many 

Indian families. The ability of Tribes to set their own rates improves access to child care for 

Tribal members. More than 70 percent of the Tribes we visited had copayment rates below the 

State copayment level. Furthermore, Tribes often share the cost of child care with States by using 

3 Indian families are eligible for child care subsidies under both their State’s and Tribe’s CCDF 

programs. However, Tribes may set their own eligibility criteria, and often set criteria that are more expansive 

than the State’s rules in order to cover their families’ needs. Families who may be ineligible for the State 

program due to income level or school attendance rather than work participation may therefore still be eligible 

for the Tribe program. 

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their Tribal CCDF funds to cover all or part of the State copayment. They may also calculate 

family income differently than the States. Some Tribes deduct a flat amount from a parent’s gross 

income before determining their copayment. 

Tribal programs are more culturally sensitive 

Most Tribes report that many families prefer to have relatives and neighbors care for their 

children. Indian families that prefer to use relatives for child care are often unable to obtain State 

child care subsidies. State policies often require that informal child care providers be regulated by 

the State to receive State funds. Many Indian families feel uncomfortable with State regulation 

and most informal Tribal providers do not want to be monitored or regulated by the State. Rather 

than submitting to these requirements, families often choose to pay for relative providers with 

personal or Tribal CCDF subsidies. Tribal certificate programs may enable families to use the 

type of child care provider they prefer. 

Lack Of Tribal And State Coordination Adversely Impacts Child Care 

Coordination between State and Tribal CCDF programs appears to improve Indian families’ 

access to child care, increase affordability and expand service options. Lack of coordination 

exacerbates the difficulties Tribal families have accessing child care. Poor collaborative efforts 

further exacerbate problems presented by geographic barriers, lack of eligible providers and 

mutual distrust between State and Tribal governments. Despite barriers, many Tribes and States 

collaborate successfully. 

Lack of information sharing impedes access 

Lack of knowledge about each other’s CCDF programs impedes service for Indian families. We 

found some Indian families and providers have been misinformed about the CCDF program from 

both Tribal and State employees. For example, one State field office erroneously told Tribal 

providers that they need to be licensed in order to access the State child care funds. 

When States and Tribes are not well informed about each other’s CCDF programs, Indian families 

are often referred back and forth between State offices, Tribal offices and, in some cases, 

consortia offices. This is particularly problematic when a Tribal program is set up to subsidize the 

copayment for Indian children enrolled in the State program. 

Tribal and State administrators’ lack of knowledge about one anothers’ program requirements 

may stem from lack of communication, staff turnover or inexperience. When Tribe and State 

administrators do not have an established pattern of communication, information sharing may be 

difficult. Staff turnovers in Tribal programs may make it difficult to maintain relationships 

between programs. While somewhat unusual, one Tribal CCDF administrator we interviewed did 

not know that the State ran a CCDF program. A Tribal administrator did not know whether 

Tribal providers could access the State Child and Adult Care Food program. 

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6 
The absence of coordination negatively affects Indian families’ ability to access both State and 

Tribal CCDF programs. In some areas, historic tensions have made both parties wary of working 

with one another. Tribes mentioned that some families are nervous about accessing State 

subsidies. Previous policies that allowed State child welfare workers to remove Indian children 

from their parents keep some families from approaching the State for social services. 

State approaches toward coordinating with Tribal CCDF programs need to consider the diversity 

of Tribes. Even if a State has a standard plan for working with Tribes, differences in Tribal size, 

location, level of infrastructure and governmental structure can impede efforts to work together. 

Geographically isolated Tribes face additional barriers to coordination with the State. Long 

distances between reservations and State offices further complicates collaboration in all site visit 

States. 

Working together, many Tribes and States have taken action to improve Indian families’ access to 

child care. Efforts to coordinate their CCDF programs include informing their employees about 

each other’s eligibility standards and services offered. They share information on copayment 

rates, eligibility, licensing requirements, forms, policies and procedures at regularly scheduled 

conferences and meetings. They fax information to each other and share program newsletters. 

Reacting to problems Indian families have accessing child care, several States remind their intake 

workers about Indian children’s dual eligibility. This minimizes the likelihood that the State 

would send Indian families back to their Tribe for services without first checking their State 

eligibility. One State has hired a private agency to provide technical assistance to Tribes on how 

to access the State child care program. Another State uses CCDF quality-improvement money to 

fund an intertribal council’s child care coordination efforts. Several other States employ Tribal 

liaisons whose responsibility it is to work with Tribes to coordinate State and Tribal CCDF 

programs. 

Lack of coordination wastes resources 

Reciprocal licensing agreements benefit both Tribes and States. They enable families to pay 

Tribal child care providers with State CCDF subsidies. Five States have agreements with Tribes 

that allow Tribally-certified providers to receive State CCDF. Other States have reciprocal 

agreements with Tribes that allow both parties to act as agents for one another in the licensing 

and certification of child care providers. This avoids duplication of effort and the cost incurred 

when both parties inspect the same location. 

Allowing Tribes to license or certify providers for the State program may enable Indian families in 

rural areas to access State child care subsidies. States may lack staff, money and other resources 

to conduct inspections in rural areas. Allowing Tribal licensure or certification to substitute for 

State licensure and inspection allows rural Indian families to use State CCDF 

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7 
subsidies. Reciprocal licensing agreements may also pave the way for rural Tribal providers to 

access their State’s Child and Adult Care Food Program.4 

Tribal and State collaborative efforts to establish a single point of entry to State and Tribal CCDF 

programs appear to improve access for Indian families. A single point of entry allows Tribes and 

States to maximize their resources and reduce administrative overhead. One State we visited 

permits Tribes to act as their agent for a number of welfare and employment programs, thus 

improving access for Indian families and satisfying the preference of some Indians to interact with 

Tribal agencies. Tribal points of entry also allow Tribes to identify and potentially serve families 

ineligible for the State program. 

Placing State employees on the reservation or having State employees regularly visit the 

reservation also improves Indian families access to child care and other programs. In two States, 

State human services employees visit Tribes regularly. They help Indian families learn about State 

programs and assist Tribal families in completing applications for the State CCDF subsidies and 

other State programs. In some areas the State subcontracts with Tribes and consortia for these 

services. 

Lack of coordination opens up the potential for duplicate payments 

Most States and Tribes report that they have no way of determining whether Indian families 

receive child care subsidies from both Tribal and State programs. In every State the potential for 

duplicate payments exists. Very few of the 29 grantees we visited had established a method for 

sharing information on their CCDF clients with the State. Both State and Tribal respondents 

were more concerned about ensuring access to child care services than the potential for illegally 

obtaining duplicate payments from the Tribal and State CCDF programs. 

Sharing information reduces the risk of duplicate payments. Currently, Tribes and States do very 

little to reduce the risk of duplicate payments. Periodic exchange of information about families 

entitled to State and Tribal child care subsidies helps ensure that providers do not receive 

duplicate payments for child care services. One Tribe sends all families to the State first, 

specifically to avoid duplicate payments. They require that families get written approval or denial 

from the State program, and then follow up by telephone to verify cases with the State office. In 

another State, the day care center director meets regularly with State employees to discuss the 

families they both serve. The State can also check a list of Indian families using Tribal CCDF 

against their own records. 

Tribal workgroups improve coordination 

Tribal child care workgroups exist in all seven States we visited. They facilitate cooperation and 

the exchange of information among Tribes and between Tribes and the State. Some workgroups 

are formal with well-defined purposes, responsibilities and policies. In some States, workgroups 

4 For more information about the U. S. Department of Agriculture’s Child and Adult Care Food 

Program, see Appendix A. 

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make recommendations to their State legislature on issues affecting Indians’ use of child care. 

The groups act as forums for the Tribes to provide input on legislation and other child care issues. 

Tribal workgroups give participating grantees the opportunity to discuss child-care problems and 

exchange program development ideas. They also function as a mechanism by which Tribes 

advocate for quality child care for Indian children in the State. They distribute information to 

Tribes, promote the provision of coordinated services and facilitate networking with Tribal and 

non-Tribal child care programs. Respondents report that workgroups heighten awareness about 

Tribal and State programs and improve the relationship between the State and Tribal child care 

agencies. Collaboration has led to one State adopting Tribal processes for ensuring that families 

pay their copayments and several Tribal health and safety practices. 

Impediments Exist In The Coordination Of Head Start And Child Care 

Programs 

Head Start and CCDF are both low-income child care programs administered by ACF. Many 

preschool-aged children enrolled in CCDF programs are also eligible for Head Start. Tribes often 

run both programs, and some preschool-age children participate in both programs. Coordinated 

programs improve resource utilization and help create a cohesive program for providing care for 

children. 

Despite an overlap in eligible service populations, coordinating the programs may be difficult. 

The ACF manages the Tribal CCDF program at the regional office level, while Tribal Head Start 

is administered through ACF's headquarters in Washington, D.C. Tribes and ACF often see the 

two programs as performing different functions. Tribes frequently run Head Start from their 

education department and CCDF from a social services department. 

Tribal CCDF programs provide child care subsidies for low income families engaged in work, 

training or education. Head Start programs provide “developmental services” for low-income, 

preschool children and social services for their families. Head Start services for children include 

education, socio-emotional development, physical and mental health care, and nutrition. Unlike 

CCDF, Head Start has specific rules regarding program content and stringent requirements for 

staff education. Head Start traditionally runs a half-day program, while CCDF pays for needed 

hours of care. Head Start and CCDF program administrators frequently disagree on the role each 

program plays in child care and child development. 

Lack of leadership and conflicting views impede coordination efforts 

Several Tribal CCDF directors indicated that the support of their Tribal councils for child care 

was key to running a successful program. One administrator operating a Head Start wrap-around 

program said that “Leadership is the key to collaboration.” In a Tribe that recently improved 

collaboration between the two programs, the Chief made it clear that the important thing is 

serving Indian children without worrying about whether they are Head Start or child care kids. 

This Tribe’s social services department follows this philosophy to enhance overall services to 

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children. 

Tribal ability to coordinate programs may improve with a unitary vision about serving children. 

One administrator stressed that CCDF and Head Start staff must be “on the same page, their 

hearts in the same place.” To facilitate a unitary vision about serving children, Tribes sometime 

hire a single person to be the CCDF administrator and Head Start director. Almost all Tribal 

CCDF staff said they collaborate or would like to collaborate with Head Start to provide the best 

possible services to children. 

Tribal CCDF administrators report that conflicting views of CCDF and Head Start hinders 

collaboration. Despite the benefits, Tribes often face difficulties coordinating these programs. 

Head Start administrators may see their programs as “child development” and CCDF programs as 

“baby-sitting.” While a Tribe can shape its CCDF program to meet a variety of community needs, 

Head Start is structured to meet national standards. This makes Head Start inflexible, according 

to some CCDF directors. Head Start’s concern that coordination with child care will reduce 

overall quality of care hinders some Tribes’ attempts at coordination. 

Individual Tribes often operate Head Start from their education department while CCDF is under 

the social services department. Administering the two programs from different departments 

suggests that Tribes view them as serving different functions. Separate administration may 

exacerbate turf issues. Program administrators may fear losing staff or functions if the two 

programs share resources when they work together. Consequently, both programs are often 

hesitant to share resources. 

Lack of coordination wastes resources 

Sharing a center may maximize its use by providing additional services and expanded care. 

Seventeen of the 29 Tribes we visited ran both CCDF and Head Start programs. Several operate 

combined child care-Head Start centers. Co-located programs can share resources, including 

administration, support staff and other resources. Combined resources may also augment training 

opportunities for both providers and parents. Full day care allows families to work full time, 

which is harder to do in traditional, part day Head Start. 

Coordination between Head Start and CCDF helps programs use their funds more efficiently. 

One Tribe used a CCDF grant to construct a combined center. Head Start will pay for all 

operating costs until they have paid an amount equal to the CCDF outlay. After that, the two 

programs will share center operating costs equally. 

Head Start and CCDF programs that do not share space can still collaborate to serve children. 

One Tribe with a smaller CCDF grant decided to maximize its resources by putting its money into 

a center. The child care center serves more than 60 children during a day by working with Head 

Start and the State’s early education program. Thirty children spend the morning at the child care 

center before moving to the Head Start center in the afternoon. They switch with the morning 

Head Start children, who move to the child care center in the afternoon. Half day programs 

allow the children of working parents to attend Head Start, and increase the number of children a 

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child care center can serve during a day. 

Child Care Plans, Payment Systems And Reporting Are Often Flawed 

To obtain a CCDF grant, Tribes must develop a child care plan and submit a grant application to 

their regional ACF office. Tribes then update and submit child care plans to ACF every other 

year. Grant applications must be submitted annually. Each grant is tracked using a unique grant 

number. Tribes have 2 years to obligate grant funds and 3 years to spend them. 

Child care plans may not accurately reflect program operation 

Concern exists that some Tribal child care plans may bear little resemblance to the program Tribes 

operate. Some Tribes said that they have submitted essentially the same plan each year since they 

began receiving child care funds. Several told us that a Tribal grant writer developed their CCDF 

plan and grant application. In some cases, this occurred without any input from staff involved in 

running the child care program. All ACF regional office respondents reported that the plans 

submitted by Tribes are essentially the same year after year. They felt that some plans may not 

accurately reflect the child care programs operated by Tribal grantees. 

Methods used to pay providers may generate inaccurate payments 

We found potential vulnerabilities in the systems Tribes use to pay child care providers. 

Reconstructing how they derived provider payment amounts was difficult or not possible. In 

some Tribes, linkages between provider payment checks and the specific children for whom 

payments were made were not readily apparent. Tribes can usually reconstruct how provider 

payments were derived using information in their provider or family enrollment files. However, 

there were a few cases where staff knowledge of families and providers was needed to locate all 

of the information. Reliance on information contained in multiple files increases the risk of 

payment error and makes it difficult for an outside party to verify the accuracy of payments. 

When staff turnovers occur, subsequent staff and administrators may not be able to reconstruct 

how their predecessors derived payments to some child care providers. 

Many payment errors appear related to deficiencies in time sheets. Time sheets used to calculate 

payments to providers often had missing information that appeared to affect payment accuracy. 

Most Tribes manually calculate payments to providers. Most of these calculations are done on 

the time sheets submitted by the child care provider. Unfortunately, many time sheets did not 

contain information about the child’s age, authorized hours of care, rate of payment and 

copayment information. The absence of this information may contribute to mathematical errors in 

payment calculations. 

We found model time sheets that contain sufficient information to determine payment. They not 

only provide space to record hours of care, but also show the hours of authorized care, payment 

rate and parent copayment amounts. These model practices reduce the risk of payment error and 

provide a better audit trail. They do not rely on staff memory or information contained in multiple 

))))))))))) 11 
locations. They simplified Tribal checks and balances by providing all information necessary to 

figure out payment. 

Good accounting practices used by Tribes ensure that providers, families and third parties clearly 

understand how provider payments were derived. Some Tribes use letters and others use check 

vouchers to establish easy to follow audit trails. These letters/vouchers identify the children 

served by name and age, provide information about the number of hours the provider billed per 

child and the provider’s charges. They also provide information about authorized hours, Tribal 

payment and parent copayment. They also included explanations for any adjustments affecting 

payment. 

Current reports may not be reliable or useful 

Tribes that receive CCDF grants are required to submit an Administration for Children and 

Families Annual Report (ACF-700) each year. The ACF-700 provides program and financial 

information about a Tribe’s child care program. Tribes are also required to submit an annual 

Standard Form 269 (SF-269). The SF-269 provides yearly expenditure information for each 

CCDF grant a Tribe received. 

Child care program statistics reported by Tribes on the ACF-700 may not provide reliable 

information. Nearly all Tribes indicted that they had some problem completing at least some 

portion of the ACF-700. Some grantees told us that some information is an estimate or best 

guess. For example, the ACF-700 asks for numbers of families and children receiving services. 

Tribes have trouble completing this item because families and children are added and dropped 

from the program throughout the year. Uncertainty exists as to what numbers are appropriate. 

Tribes that do not pay child care providers on an hourly rate report that they have a difficult time 

determining the “average number of hours of child care . . . provided per child, per week.” 

Deriving the average hourly rate of pay may be even more difficult for grantees that use all of 

their grant money to support the operations of their child care center. Likewise, Tribes that pay 

daily, half day, full time and part time rates do not always have information on the actual number 

of hours of child care provided. 

Some program instructions are unclear. Program instructions do not sufficiently clarify at what 

point in time Tribes should determine a child’s age or a family’s annual income. Some Tribes also 

find instructions on how to determine the number of similar size families at or below the poverty 

thresholds confusing. Tribes complain that program instructions on how to complete the ACF700 change too frequently. These changes may not always filter down to the people within the 

Tribe who will need to implement them. Problems are exacerbated when Tribes get conflicting 

answers to the same question from several sources. 

To simplify collection of child care reporting data, a few Tribes have developed and financed their 

own management information systems. Many Tribes, including those with automated systems, 

describe completion of the ACF-700 as a difficult and time-consuming task that requires at least 

some manual review of their program data and files. Most Tribes rely on manual systems to 

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collect some or all of the ACF-700 information and data. The task of putting together program 

and financial information is often shared by different people and departments; consequently, 

information about program expenditures on the ACF-700 may differ from information reported on 

the SF-269. 

For smaller Tribal grantees collecting information for the ACF-700 is particulary onerous. Tribes 

claim CCDF reporting requirements require more time and effort on their part than many larger 

grants they receive from other government programs. In fact, the paperwork involved in 

obtaining Tribal funds and accounting for them was derived from processes developed for States. 

In addition to the burdensome process for collecting required report data, respondents question 

the reliability of data that is not uniformly derived and reported. For example, to arrive at “... the 

average number of hours of care per child per week,” Tribes can average actual hours over a 52 

week period, average actual hours in representative weeks or weight an average of actual hours in 

representative weeks. Instructions caution Tribes not to use “the annualized average number of 

hours of child care service per week.” 

Problems completing the ACF-700 and the appearance that the information is not used for 

constructive program improvement may account for some Tribal reluctance to comply with 

reporting requirements. Of the 27 Tribes in our sample required to file an ACF-700, we were 

only able to locate reports for 23 Tribes. Four Tribes have not yet filed this required report 

for 1997. The ACF recognizes the low compliance rate with Tribal ACF-700 and has taken steps 

to improve compliance. The ACF is also in the process of revising the ACF-700 to improve data 

reliability. Nevertheless, it is unclear to us how much of the reported information is actually used 

by ACF. 

Annual reporting does not ensure that Tribes operate the child care programs described in their 

plans. Tribes often do not know what information ACF is trying to obtain from the reports they 

file, or how that information will be used to improve their programs. Moreover, the current 

reporting forms do not provide sufficient information about the child care programs Tribes run. 

While the current reporting does provide some fiscal accountability, it appears to provide little 

information that would help ACF improve the programs Tribes operate. 

Some Tribes are not required to file ACF-700s. These Tribes provide information about their 

child care program under an alternative reporting mechanism provided by Public Law 102-477. 

The Tribes in our sample using this method like the alternative process better. The information 

they are required to provide is less extensive and easier to retrieve from Tribal records than the 

information required on the ACF-700. 

The CCDF child care program may be vulnerable when Tribes report expenditures under Public 

Law 102-477. This alternative to the ACF-700 does not ensure that Tribal CCDF grants are used 

in accordance with the requirements of the law. We found no evidence to suggest that Tribes are 

not using CCDF grants to operate child care programs as intended by the Congress. However, 

the risk of misuse of child care funds is greater when Tribes report under Public Law 102-477 

because Tribes can combine their Federal grant funds. The alternate reporting provides little 

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assurance that Tribes understand CCDF program requirements and are abiding by them. 

Technical assistance with child care plans, payment systems and reporting is difficult to 

obtain 

The regional office staff play many roles in the Tribal CCDF program. They have primary 

responsibility for overseeing Tribal use of Federal CCDF grant money. They also provide 

technical assistance and policy guidance to a large and diverse group of Tribes. The ACF regional 

office staff frequently receive calls from the Tribes regarding the CCDF program, payment 

systems and financial reporting forms. Regional office staff have developed strong working 

relationships with Tribal program administrators. All of the Tribes we spoke with reported that 

ACF regional staff had consistently helped them solve problems as they arose. 

Tribes want one-on-one assistance and report they would benefit from regional office visits. 

Problems posed by Tribal grantees are often complex and not easily resolved over the telephone. 

Tribes believe that onsite visits would help ACF better understand the systems, processes and 

infra-structure Tribes use to operate their CCDF programs. When Tribes need assistance, they 

turn to the regional offices for guidance. Tribes also expressed concern that in recent years they 

have not received the individual attention ACF staff used to provide during their onsite visits. 

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RECOMMENDATIONS

Tribal and State Coordination 

To improve Indian Families’ access to child care, we recommend that ACF: 

C actively encourage and facilitate the development of Tribe-State reciprocal licensing 

agreements. 

Reciprocal licensing agreements increase the number of licensed child care providers without

increasing costs or duplicating State or Tribal efforts. Tribal families would have improved access

to State child care subsidies. Tribal CCDF programs could shift resources to families not eligible

for the State’s program or to meet specific Tribal needs such as odd hour care. Reciprocal

licensing agreements would enable Tribes to license and inspect Tribal child care providers. This

would maintain Tribal child care provider autonomy from State oversight while enabling Tribal

families and providers to access the State program; thus, increasing the number of State licensed

child care providers available to Indian families. A State’s recognition of Tribally licensed child

care providers will remove a major obstacle to provider 

participation in the Department of Agriculture’s Child and Adult Care Food Program. 

To improve Indian Families’ access to child care, increase affordability and expand service

options, we further recommend that ACF encourage States and Tribes to:

C Share information about their child care programs’ eligibility criteria, provider 

qualifications and co-payments. 

C Work together to create explicit policies and procedures for coordinating their child care 

programs. These procedures should address information sharing and referral procedures. 

C  Participate in Tribal/State child-care workgroups. 

C  Agree to outstation State child care staff on Tribal lands. 

Furthermore, we recommend that ACF encourage Tribes to refer their families to the State when 

appropriate. This would enable Tribes to serve families ineligible for State programs or meet 

community needs such as odd hour care. 

To reduce the risk of duplicate payments, we recommend that ACF encourage Tribes and States 

to: 

C Develop shared automated systems or regularly exchange information on families using 

CCDF subsidies. 

C  Establish single points of enrollment for Tribal families 

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Child Care and Head Start 

The ACF has an initiative designed to look at Head Start and CCDF coordination. We support 

the efforts of this workgroup and recommend that ACF: 

C Hold regional meetings that would enable Tribal Head Start and CCDF personnel to 

discuss common ground, differences and ways to overcome barriers to coordination. 

C Compile and disseminate information about Tribal best practices and model Head Start 

and child care collaborative initiatives. 

Tribal Payment and Reporting Systems 

The ACF is also in the process of modifying the ACF-700 and SF-269 reporting forms to improve 

the reliability of data. To improve accountability, we recommend that ACF: 

C Examine the use of the data elements on the new ACF-700 to determine why the 

information is being collected, who will use the information and for what purpose. 

C  Compile, develop and disseminate model time sheets and accounting practices. 

C Require Tribes reporting under Public Law 102-477 to certify that their CCDF grants 

were used for appropriate CCDF-related activities. 

C Set aside funds for Tribal management information systems. These systems could be used 

to enroll children, to generate payments to providers and to produce statistics for ACF and 

Tribes. 

Technical Assistance 

Regional Child Care Bureau office staff are responsible for overseeing Tribal CCDF grants. They 

provide technical assistance and guidance to Tribes on how to prepare their child care plans. 

They provide information to Tribes on how to run their programs and help complete required 

reporting forms. Regional staff communicate regularly with Tribes and have established 

relationships with them. Their role in assisting Tribes makes them best suited to identify 

individual Tribal needs and to develop solutions for those needs. The ACF has hired a technical 

assistance contractor to provide information to Tribes. However, regional offices should not be 

left out of the process. To improve the quality of the assistance Tribes receive, we recommend 

that ACF: 

C Ensure that the technical assistance contractor is in close communication with ACF’s 

regional office staff. This will help provide continuity of service for Tribes requiring 

technical assistance. It is particularly important that the contractor and regional ACF staff 

are providing consistent responses to Tribes’ questions. Frequent communication between 

the two groups will facilitate this consistency. 

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C Encourage the technical assistance contractor to hold individual on site meetings with 

Tribal CCDF staff whenever possible. Tribal queries are often complex and require 

extended discussion of individual programs. These discussions are best undertaken 

through in-person meetings. Whenever appropriate, the contractor should include 

regional office staff in the process. 

C Establish precedent files containing questions Tribes have asked and the responses ACF 

and the technical assistance contractor have provided. 

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AGENCY COMMENTS 

We would like to thank ACF for commenting on the draft of this report. The full text of ACF’s 

comments can be found in Appendix B. 

The ACF concurred with all of our recommendations. The agency has taken steps to encourage 

States and Tribes to work together, and indicates that it will continue to facilitate such 

cooperation. Through its bureaus, the ACF will continue to facilitate Tribal Child Care-Head 

Start collaborations. The ACF is also taking steps to address Tribal data collection issues. 

Central office staff, regional offices and the technical assistance contractor plan to work together 

to address Tribes’ technical assistance needs. 

Based on ACF’s comments, we have made changes and corrections to the report. We corrected 

references to applicable laws and made other corrections ACF suggested. We would like to 

point out that our study was not intended to investigate “quality of care” issues. 

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APPENDIX A

USDA Child and Adult Care Food Program 

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The Child and Adult Care Food Program funds meals that child and adult day care facilities 

provide to their clients. The U.S. Department of Agriculture (USDA), through the States, 

reimburses participating licensed child care operators for meal costs. Twenty of the Tribal Child 

Care and Development Fund (CCDF) grantees we visited indicated that some Tribal providers 

participate in this program. 

Child care centers participating in the food program may do so as independent centers or through 

a sponsoring organization. However, family home care providers must have a sponsoring 

organization to participate. All child care providers must be licensed by the State to participate in 

the program. Providers must serve meals that meet Federal nutrition guidelines and must agree to 

monitoring by the State or their sponsoring organization. 

Tribal CCDF programs may become sponsors for child care providers wishing to join the food 

program. Several Tribes in our sample act as sponsors and administrative agents for their child 

care providers. To become an administrative agent for family home providers, a Tribe or 

consortium applies to the State to become a sponsoring organization for the food program. 

Alternatively, a Tribe or consortium that wishes to administer all of the USDA’s Food and 

Nutrition Service programs may apply to the Department of Agriculture to become a State 

agency. 

Some Indian child care providers are uncomfortable with State monitoring. A Tribe or 

consortium acting as the sponsoring organization or a State agency may be the most acceptable 

option for these providers. 

The food program provides additional revenue to Tribal child care providers and to Tribes. The 

program would reimburse Tribal providers for food expenses they already incur. Consequently, 

start up costs for providers entering the food program are minimal. The added income the food 

program provides may be an incentive for some child care providers to join the CCDF program. 

This may be particularly helpful in recruiting providers in under served areas. 

Tribes and consortia running CCDF programs can also benefit from the USDA food program. 

Organizations that sponsor family home providers receive per-provider reimbursement to help 

defray administrative costs. This added income can help Tribal CCDF programs pay for staff 

needed to monitor providers participating in child care and food programs. 

Indian providers’ entry into the food program is facilitated when Tribal and State CCDF programs 

establish reciprocal licensing agreements. Such agreements allow child care monitors working for 

Tribal programs to license or regulate CCDF providers for the State. Reciprocal agreements 

would enable more Tribal child care providers to participate in the USDA food program. 

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APPENDIX B

Administration for Children and Families 

Comments on the Draft Report 

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COMMENTS OF THE ADMINISTRATION FOR CHILDREN AND FAMILIES ON 

THE OFFICE OF INSPECTOR GENERAL’S DRAFT REPORT “TRIBAL CHILD 

CARE," OEI-O5-98-00010) 

General Comments 

The Administration for Children and Families (ACF) is pleased to have this opportunity to provide 

official comments on the draft OIG report "Tribal Child Care" (OEI-05-98-00010) . 

In recognition of the specialized needs of our tribal Child Care and Development Fund (CCDF) 

grantees, in January 1998, ACF's Child Care Bureau awarded a contract to establish a Tribal 

Child Care Technical Assistance Center (TriTAC). This contract is one of seven separate projects 

that comprise the Child Care Bureau’s new Child Care Technical Assistance Network (CCTAN). 

Through this network, the Child Care Bureau is providing increased technical assistance to our 

child care partners, which includes States, Territories, Tribes and local communities. The seven 

projects are providing assistance in the following areas: tribal child care; public-private 

partnerships; healthy child care (including tribal health and safety standards); inclusion for children 

with disabilities; state automated reporting systems; logistical support for Regional Office 

conferences; and a clearinghouse for child care information. 

In early 1998, one of the partners in the CCTAN performed on-site visits at 29 tribal child care 

grantees as a way of assessing the technical assistance needs of tribal grantees. The current and 

planned activities under the tribal contract address many of the recommendations which have been 

presented in the draft OIG report, as well as the on-site visit report findings. One of the major 

tasks under this new tribal contract is to build a cadre of consultants who will be available to 

assist tribal CCDF grantees through cluster trainings, ACF regional meetings, and in some cases, 

targeted on-site technical assistance. Through an intensive week-long "Train-the-Trainer" 

meeting in October 1998, over twenty consultants will receive training on the CCDF program. 

All of the topic areas in the Recommendations section of the draft OIG report will be addressed at 

this training. 

Before addressing the specific recommendations in the report, we would like to offer a few 

general comments about the overall content of the report. First, it is important to be mindful that 

the CCDF is a block grant program. Thus, grantees have tremendous flexibility in program design 

and implementation. Furthermore, unlike most ACF competitive funding grant programs, there is 

no statutory mandate to conduct on-site monitoring visits to CCDF programs, nor is there a 

specific monitoring instrument for this purpose. While Regional Office staff across nine HHS 

regions communicate frequently with tribal CCDF grantees, few tribal programs are visited on-site 

due to a lack of ACF travel funds. However, Regional Office staff track grantee progress and 

accomplishments through their review and approval of the CCDF plan preprint, plan amendments, 

the ACF-700 data reporting form and the SF-269 expenditure form. 

We have some concerns that the draft report addresses only a few CCDF-funded quality activities 

(i.e., resource and referral), but does not address larger ''quality of care" issues. In addition, while 

a section of the draft report addresses Head Start/Child Care collaborations, there is little 

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C

discussion of collaboration or coordination with other ACF programs (e.g., Temporary Assistance 

for Needy Families, Native Employment Works, Child Support Enforcement and Child Welfare 

Services). We feel that a statement addressing the quality of child care and linkages with other 

ACF programs would enhance the overall report. Although tribal health and safety standards 

were not a primary focus of the study, it would also enhance the report to note some of the 

findings around this important issue (i.e., Tribal CCDF programs that are exceeding state 

requirements). 

The following comments address the draft report recommendations: 

OIG Recommendation: Tribal and State Coordination 

To improve Indian Families' access to child care, we recommend that ACF actively encourage and 

facilitate the development of Tribe-State reciprocal licensing agreements. 

To improve Indian Families' access to child care, increase affordability and expand service 

options, we further recommend that ACF encourage States and Tribes to: 

C Share information about their child care programs' eligibility criteria, provider qualifications 

and co-payments. 

C Work together to create explicit policies and procedures for coordinating their child care 

programs. These procedures should address information sharing and referral procedures. 

C Participate in Tribal/State child care workgroups. 

C Agree to outstation State child care staff on Tribal lands. 

We recommend that ACF encourage Tribes to refer their families to the State when appropriate. 

To reduce the risk of duplicate payments, we recommend that ACF encourage Tribes and States 

to: 

@ Develop shared automated systems or regularly exchange information on families using 

CCDF subsidies. 

C Establish single points of enrollment for Tribal families. 

ACF Response: 

We agree that it benefits States and Tribes to work closely together to provide services to eligible 

Indian children. Following the passage of the welfare reform law (P.L. 104-193), ACF published 

a Program Interpretation Question (PIQ) which addresses the dual eligibility of Indian children 

under the amended Child Care and Development Block Grant (CCDBG) Act. The PIQ 

encourages States and Tribes to work closely together in coordinating child care services to 

ensure the availability of adequate child care for eligible Indian children. The Bureau has and will 

continue to sponsor workshops around State/Tribal collaboration at our annual American Indian 

and Alaska Native Child Care Conference, State Child Care Administrators' Conference, and ACF 

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C

Regional Office events. Further, the Bureau will continue to bring State and Tribal Issues Work 

Groups together to strengthen collaboration. 

OIG Recommendation: Child Care and Head Start 

The ACF has an initiative designed to look at Head Start and CCDF coordination. We support 

the efforts of this workgroup and recommend that ACF: 

C Hold regional meetings that would enable Tribal Head Start and CCDF personnel to discuss 

common ground, differences and ways to overcome barriers to coordination. 

C Compile and disseminate information about Tribal best practices and model Head Start and 

child care collaborative initiatives. 

ACF Response: 

The Child Care Bureau and the Head Start Bureau are continuing to provide direction and 

leadership to tribal child care programs on the issue of collaboration. We intend to highlight 

model collaborations in future issues of the Tribal Child Care Bulletin, a biannual newsletter. 

Each year, presentations are made on collaboration efforts at the annual American Indian and 

Alaska Native Child Care Conference, as well as at Regional Office meetings. 

OIG Recommendation: Tribal Payment and Reporting Systems 

The ACF is also in the process of modifying the ACF-700 and ACF-269 reporting forms to 

improve the reliability of data. To improve accountability, we recommend that ACF: 

@ Examine the use of the data elements on the new ACF-700 to determine why the information 

is being collected, who will use the information and for what purpose. 

C Compile, develop and disseminate model time sheets and accounting practices. 

C Require Tribes reporting under Public Law 102-477 to certify that their CCDF grants were 

used for appropriate CCDF-related activities. 

C Set aside funds for Tribal management information systems. 

ACF Response: 

We agree that the program data collected on the ACF-700 reporting form need to be examined. 

We will be consulting with members of the Child Care Bureau Tribal Work Group regarding the 

types of data that are meaningful for tribal programs in their program planning needs. Yet, we 

must also meet ACF's need to have basic data on the numbers of children and families served, 

similar to State collected data, to ensure that ACF can make useful comparisons and conduct 

meaningful analysis across all CCDF programs. 

To ensure financial integrity for Tribes consolidating CCDF funds through a P.L. 102-477 plan, 

we have requested that the Bureau of Indian Affairs (BIA) include as an attachment to its 

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modified SF-269 expenditure report, the following statement. "We certify that CCDF funds

under an approved P.L. 102-477 plan will be used for appropriate CCDF-related activities." The

BIA is currently working with the Office of Management and Budget to revise and renew this

expenditure form.

While Tribes can use their grant funds to purchase automated systems, the CCDBG Act does not

authorize ACF to set aside program funds for this purpose. However, the Child Care Bureau is

using its technical assistance resources for help in developing systems and reporting. The TriTAC

is consulting with the Child Care Bureau’s Tribal Work Group about the 

development of a software package to assist tribal CCDF grantees with program and fiscal data

collection.

With this group, we are also discussing the types of materials which would be useful in a manual

for new tribal CCDF administrators (i.e, sample time sheets, CCDF regulations and reporting

forms). This effort is an extension of the new administrators training offered annually at the

American Indian and Alaska Native Child Care Conference, which addresses many data and fiscal

reporting requirements.

OIG Recommendation: Technical Assistance 

To improve the quality of the assistance Tribes receive, we recommend that ACF: 

C Ensure that the technical assistance contractor is in close communication with ACF's regional 

office staff. 

C Encourage the technical assistance contractor to hold individual onsite meetings with Tribal 

CCDF staff whenever possible. 

C Establish precedent files containing questions Tribes have asked and the responses ACF and 

the technical assistance contractor have provided. 

ACF Response: 

It is critical that the Child Care Bureau, Regional Office staff and the technical assistance 

contractor (TriTAC) work together to ensure program consistency. In this regard, through 

regular conference calls, the Child Care Bureau is working in partnership with ACF Regional 

Offices and TriTAC in the development of its tribal technical assistance activities. The TriTAC 

project also attends and makes presentations at a number of the ACF Regional office conferences. 

Through these functions, the project director has established and maintains positive and 

productive working relationships with Regional Office staff. 

Over the three year contract period, TriTAC will be providing technical assistance to tribal 

grantees primarily through cluster trainings at several locations throughout the country. 

Individual on-site meetings will be held, when feasible. While we fully agree with the draft OIG 

report recommendation that individual meetings with tribal CCDF staff are most effective, we 

believe that the contractor must be prudent in allocating funds for specific on-site purposes. The 

Child Care Bureau, ACF Regional Offices, and TriTAC are working together to develop a 

))))))))))) B - 5 
judicious process to assess individual on-site technical assistance requests. 

Technical Comments 

Page 2, second full paragraph. The Background section of the report states that 63.75 percent of 

the total CCDF per child amount must be spent on direct child care activities during an interim 

period "until new regulations are published.” This statement is no longer correct since new 

regulations were published on July 24, 1998. These rules amend the 1992 CCDBG rules to 

follow the amendments to the CCDBG Act of 1990 that were made by P.L. 104-193. 

Page 2, last paragraph. An incorrect reference is made to P.L. 102-477. The correct name of this 

law is the “Indian Employment, Training and Related Services Demonstration Act of 1992.” 

Page 4, last paragraph, fifth sentence. Under the discussion about grantee flexibility, the draft 

report states that all Tribes are required to maintain their service level from the previous year. 

This is not correct. Although we encourage tribal grantees to maintain or exceed their level of 

service from the preceding year, the statutory language provides that this requirement only applies 

to those Tribes that submit applications for construction or major renovation of child care 

facilities. 

Page 11, first paragraph. Under the section "Child Care Plans, Payment Systems and Reporting 

Are Often Flawed," it is incorrect to state that "Tribes must file separate applications for 

Mandatory and Discretionary Funds." Tribes only have to file one application. 

The draft report refers to the "ACF-269" as the form which collects expenditure information. The 

correct citation for this form is Standard Form 269 (SF-269). 

)))))))))))

B - 6