Use of Tribal Child Care and Development Fund Resources to Support Early Childhood Systems Building

Publication Date: April 1, 2022
Current as of:
  1. Log No: CCDF-ACF-IM-2022-01
  2. Issuance Date: 04-01-2022
  3. Originating Office: Office of Child Care
  4. Key Words: Child Care and Development Fund, CCDF, Tribal Lead Agencies

To

Tribal Lead Agencies administering the Child Care and Development Fund (CCDF) program, as amended, and other interested parties

Subject

Use of Tribal Child Care and Development Fund (CCDF) Funds by Tribal Lead Agencies to Support Early Childhood Systems Building and a Tribal Early Learning Initiative

References

The Child Care and Development Block Grant (CCDBG) Act (42 U.S.C. 9857 et seq.); 45 CFR Parts 98 and 99; The American Rescue Plan (ARP) Act of 2021 (Public Law 117-2).

Purpose

To assist Tribal CCDF Lead Agencies considering how to leverage Tribal CCDF funding to implement their vision for a stronger system of high-quality early care and education at the tribal community level.

Background

The Office of Child Care (OCC) within the Administration for Children and Families (ACF) supports low-income working families by improving access to affordable, high-quality early care and afterschool programs.OCC administers the Child Care and Development Fund (CCDF) - a block grant to state, territory, and tribal governments that provides support for children and their families with paying for child care that will fit their needs and that will prepare children to succeed in school. Two hundred sixty-five Tribal Lead Agencies operate Tribal CCDF programs in more than 530 tribal communities. Forty-five of these tribes consolidate their CCDF funds into an employment, training, and related services plan under Pub. L. 102-477.

CCDF also improves the quality of care across the early care and education system to promote children’s healthy development and learning by supporting a range of quality improvement activities, such as implementation of health and safety standards, purchase of supplies and equipment, and training and education for child care workers.

The recent large investments in the Tribal CCDF program through the Coronavirus Aid, Relief, and Economic Security Act (CARES) Act (Pub. L. 116-136), Coronavirus Response and Relief Supplemental Appropriations(CRRSA) Act (Pub. L. 116-260), and American Rescue Plan (ARP) Act(Pub. L. 117-2) present an opportunity for tribes to enhance their early childhood systems to meet their goals, promote child development, and support working parents.The significantly increased funds offer tribes a chance to invest broadly in their child care and early childhood infrastructure to support higher program quality and improved child and family outcomes. One creative use of increased Tribal CCDF funds could be to invest in the broader system of child care to support young children and families, in collaboration with partners at the tribal and federal level.

Guidance

This Information Memorandum provides an overview of how Tribal Lead Agencies can use existing CCDF funds, including supplemental funds provided through the ARP Act, to implement their tribe’s vision for a stronger system of high-quality early care and education at the tribal community level. It offers examples of activities that Tribal Lead Agencies may implement that are allowable under the Child Care and Development Block Grant (CCDBG) Act and the CCDF regulations. Later in the memorandum, we discuss opportunities for Tribal Lead Agencies to participate in a Tribal Early Learning Initiative effort as they implement early childhood systems building activities.

Overview

In recent years, there has been growing recognition of the need to support more coordinated early childhood programs and systems in American Indian and Alaska Native (AI/AN) communities. Tribal early childhood development programs that serve young children and their families, including Head Start/Early Head Start, CCDF, and home visiting, have historically been developed in “patchwork” fashion in response to specific needs. They frequently have separate funding sources, standards, regulations, and governance structures. Over time, discrete programs have developed, sometimes with conflicting policies, inconsistent quality and accountability, and uneven investment. In a well-aligned system, programs are more seamlessly aligned and integrated.

The CCDBG Act of 2014 added provisions stating that the purposes of the CCDBG include assisting lead agencies “in delivering high-quality, coordinated early childhood care and education services to maximize parents’ options.” (Sec. 658A(b)(4); 42 U.S.C. 9857(b)(4)) The 2016 CCDF final rule preamble notes that “CCDF also funds quality improvements for settings beyond those that serve children receiving subsidies.CCDF has helped lay the groundwork for development of State early learning systems.… Child care is a core early learning and care program and plays an important role within a broad spectrum of early childhood programs supporting young children”; as noted in the preamble to the CCDF final rule, we have “consistently sought to support State, Territory and Tribal efforts to improve the coordination and alignment of early childhood programs.” (81 FR 67442-43) Section 45 CFR 98.53(a) of the CCDF regulations states that a percentage of “funds must be used to carry out…quality activities to improve the quality of child care services for all children, regardless of CCDF receipt.” All of these provisions provide support for the use of Tribal CCDF funds to support early childhood systems building activities that both support child development and meet the needs of working parents.

An ideal tribal early childhood system is a tribally driven, culturally informed system of whole family, holistic, trauma-informed approaches that work across different programs with early childhood as the focal and starting point.This system would be designed to both promote optimal child development and support parents engaged in work, job training, and education activities.The system would include education, child development, and physical and mental health, and be seamless, from prenatal to kindergarten entry and beyond, including aligned intake and referral, data collection and reporting, screening, assessment, and treatment.Services would be affordable, safe, high-quality, sufficiently funded, and available at times of day needed to support working parents and would take place in appropriate facilities.The system and its services would be developed and implemented in partnership with parents, families, tribal leaders, elders, and community stakeholders.Finally, the system would fully utilize the cultural and linguistic strengths of the community, with Native language and culture incorporated across the entire early childhood system as determined by the tribe.

Allowable Activities

The activities outlined below meet the CCDF programmatic purposes for quality activities as outlined in the CCDBG Act and the CCDF regulations.In order to use Tribal CCDF quality funds for these purposes without cost allocation with other entities or programs, Tribal Lead Agencies must ensure that the activities do not provide a “direct” benefit to other entities or programs.If the activity provides a direct benefit to separate entities or programs, then the costs must be allocated according to the proportionate benefit to each entity or program.To expend CCDF funds for the benefit of individuals who are not Indian children, as defined by the grantee tribe, or for the benefit of a separate program like Head Start would violate the purpose of Tribal CCDF and the award conditions.However, other entities or programs may be “indirect” beneficiaries of the activities or might use the completed work to build upon and improve their own services.When implementing any of these activities, Tribal Lead Agencies should work in close collaboration with other tribal early childhood program and system partners to identify ways to leverage resources of all partners in the system.

The following is not meant to be a checklist of required activities or investments, but rather a set of options that the Tribal Lead Agency may consider implementing to support more coordinated and high-quality systems and services in their communities.Tribal Lead Agencies have the option to use Tribal CCDF program funds, including supplemental funds provided through the ARP Act, to support the following.In all activities, Tribal Lead Agencies should work closely with partners throughout the early childhood system to ensure the effectiveness of the system building effort.

  • Hiring a coordinator whose role it is to bring together all programs serving young children and families in the community (including child care, Head Start/Early Head Start, home visiting, health, mental health, nutrition, family support, and employment and training) and manage the overall effort.This individual serves as a “backbone” to support systems building efforts, including providing coordination, facilitation, and administrative support to the effort.Such a position (part time or full time) is essential to an early childhood system building initiative, given that all system partners are focused on implementation of their own individual programs and may not be able to invest significant time into coordinating and aligning their efforts. This type of position is seen as having indirect benefit to other programs and supporting the overall early childhood system.
  • Forming a local advisory committee to guide the effort and develop a vision for an early childhood system that best meets the needs of children and parents.Local advisory committees are created to ensure that the overall effort is in touch with the community's needs and incorporates the community's perspective in all activities.Committees meet on a regular basis and perform a number of valuable functions, including helping to shape the tribe’s vision, goals, objectives around an early childhood system and shaping and overseeing the core functions and activities of the early childhood systems building effort.This type of local advisory committee is seen as having indirect benefit to other programs and supporting the overall early childhood system. Tribal Lead Agencies may also choose to use some CCDF funds to partially support an existing community group that could be used for these purposes.
  • Conducting a community needs assessment and planning process.Tribal early childhood needs assessments may examine community characteristics, the current availability and quality of early childhood services in the community, existing barriers to coordination and collaboration across early childhood programs, gaps in services to meet the needs of families (including those with working parents), and needs for early childhood programming and investments.Based on the findings of needs assessments and in collaboration with partners, Tribal Lead Agencies may support strategic planning efforts to identify goals, objectives, and activities that build toward a stronger early childhood system. This type of activity is seen as having indirect benefit to other programs.
  • Investing in a coordinated data system that allows for collection, housing, and sharing of data across early childhood programs to support improved services to families.While tribal programs collect a lot of information about young children and their families, data collection across early childhood programs is often uncoordinated or inconsistent, which can hinder the quality of services available to families.Programs may be collecting the same information from families, conducting duplicative assessments or screenings, and missing opportunities to coordinate services for an individual family.When investing in coordinated data systems, Tribal Lead Agencies must closely consider the need for cost allocation, as the systems are likely to have direct benefits to participating programs.Tribal CCDF funds could be used for data system planning, design, and infrastructure building activities, recognizing that other partners will need to invest their own resources to fully participate in the system.
  • Supporting coordinated professional development and workforce support activities.There are many skills and competencies needed by providers in the early childhood system regardless of program.These include awareness of trauma-informed practices, strategies for engaging families, and integration of culture and language into programming.There are also supports that would be helpful to the entire early childhood workforce, such as infant and early childhood mental health consultation.Funds could be used to support training, professional development, and supports for staff from multiple programs.Depending on how the trainings or other supports are set up (i.e., if there a cost per participant), Tribal Lead Agencies may need to consider the need for cost allocation with participating programs that are directly benefiting from the opportunities.
  • Developing a community resource directory or website to support families’ access to high-quality early childhood services.A comprehensive resource directory is of direct benefit to CCDF program participants, ensuring they are aware of all community resources and supports.This activity is seen as having indirect benefit to other programs in the community and supporting the overall early childhood system.
  • Building coordinated intake systems that allow families to access early childhood services in a less confusing and burdensome way and make it easier for working parents to access services that meet their needs.The use of common intake and assessment forms and coordinated referral strategies across multiple programs in a community can improve the experience of CCDF program participants when accessing other services and reduce administrative burden for the individual programs that are part of the early childhood system (an indirect benefit to all programs).
  • Carrying out family engagement activities to bring together all families with young children in the community for information sharing, education, activities supporting children’s development, cultural enrichment, etc.Though early childhood programs often work in silos, the families they work with have similar needs, strengths, and interests and may benefit from common community-wide activities for all families with young children.Depending on how the activities are set up (i.e., if there a cost per participant), Tribal Lead Agencies may need to consider the need for cost allocation with participating programs that are directly benefiting from the opportunities.

Tribal Early Learning Initiative Opportunity

In 2022, Tribal Lead Agencies will have an opportunity to participate in a Tribal Early Learning Initiative (TELI), building on lessons learned from past ACF TELI efforts (see appendix), to support their early childhood system building efforts.Tribal Lead Agencies interested in participating in the TELI will have an opportunity to participate in one of two groups differing in terms of the commitments needed from tribes and the supports provided by ACF: 1) TELI Collaborative and 2) TELI Network.Regardless of the group a Tribal Lead Agency is part of, ACF is committed to tribal sovereignty and self-determination and engaged partnership with tribal communities.

Tribal Lead Agencies with a strong commitment and clear vision to support a tribal early childhood system by leveraging Tribal CCDF and other funds will have an opportunity to participate in the TELI Collaborative.Tribes will commit to working in partnership with ACF to develop and carry out TELI plans and learn from one another in a collaborative to maximize opportunities to implement strong early childhood systems.Tribes will also demonstrate a commitment to involving tribal leaders and partners from key tribal early childhood programs — including (where applicable) AI/AN Head Start/Early Head Start, Tribal CCDF, and Tribal Maternal, Infant, and Early Childhood Home Visiting (MIECHV) — in the TELI work.Finally, tribes will commit to developing their systems in partnership with community members, parents, elders, and families.There will be up to eight TELI Collaborative participants, and these tribes will receive intensive support over a 3-year period, including:

  • Ongoing technical assistance (TA) as part of a peer learning network/learning collaborative.TA and resources will be provided to the group as well as to the individual tribes.
  • Direct support from federal staff and decision makers across key tribal early childhood programs (as applicable), as well as other relevant federal partners.ACF is committed to ensuring that federal program specialists collaborate across offices and provide guidance to help remove barriers and reduce administrative burden, funding restrictions, and other impediments to creative early childhood systems building.
  • Annual meetings to establish and maintain the learning collaborative, support ongoing peer learning and sharing, and receive TA and guidance.
  • A joint site visit (as feasible and appropriate) to each tribe from ACF staff from the relevant programs, along with TA providers, to explore opportunities for collaboration and identify and address barriers to coordination and systems building.

Tribal Lead Agencies, including those that consolidate CCDF funds into an employment, training, and related services plan under Pub. L. 102-477, will have an opportunity to indicate interest in being part of the TELI Collaborative in early 2022, with official launch of the collaborative anticipated in late summer 2022.

The TELI Network opportunity will be available to any of the 265 Tribal CCDF grantees, including those that consolidate CCDF funds into an employment, training, and related services plan under Pub. L. 102-477, that are interested in using their Tribal CCDF funds to support a TELI in their own community, but less interested in intensive supports and partnership with ACF.TELI Network tribes will have an opportunity to stay informed of the work occurring in the TELI Collaborative and apply emerging best practice and knowledge.TELI Network tribes will receive universal TA related to early childhood systems building, including access to resources and tools developed for the TELI Collaborative, and will also have access to existing supports and guidance from federal staff and TA providers.

ACF will provide more information about both TELI opportunities in the coming months.

Questions

Please direct inquiries to the Child Program Manager in the appropriate Office of Child Care Regional Office. Contact information for Regional Offices can be found at https://www.acf.hhs.gov/occ/resource/regional-child-care-program-managers.

Ruth Friedman, Ph.D.
Director
Office of Child Care

Appendix: Background on Past Tribal Early Learning Initiative Efforts

The original Tribal Early Learning Initiative ran from 2012 to 2017 and was a partnership between ACF and eight AI/AN tribal grantees with Head Start/Early Head Start, CCDF, and Tribal MIECHV programs.The purposes of the TELI were to:

  • Support tribes to coordinate tribal early learning and development programs
  • Create and support seamless, high-quality, early childhood systems
  • Raise the quality of services to children and families across the pregnancy-to-kindergarten-entry continuum
  • Identify and break down barriers to collaboration and systems improvement

The TELI included small incentive grants ($30,000-$100,000, via supplements to Tribal MIECHV grants) to tribal grantees, along with technical assistance provided collaboratively across Office of Head Start, Office of Child Care, and Tribal MIECHV federal staff and contracted technical assistance providers.TELI grantees across two cohorts made major strides in improving their early childhood systems and services, starting with building strong relationships across programs.Funds were used by grantees to hire a TELI coordinator and to enhance the early childhood system and improve the quality of services across existing programs, rather than to provide new services.Grantees had a great deal of flexibility to set local priorities and goals and develop individualized work plans and activities, with ACF’s support and guidance.

TELI grantee activities included creating a single tribal early learning program enrollment form, reviewing and agreeing upon common assessment tools, holding joint professional development opportunities and trainings for staff, jointly creating a community resource directory, allocating costs across early childhood program grants to provide more efficient and responsive services, and investing in data systems to allow for better coordination and sharing of relevant child and family data across programs.

More information can be found on the ACF TELI website.

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