Blind Spots in Tribal 477 Plans

Consolidating the Child Care and Development (CCDF) and other federal formula programs into 477 Plans has helped parents living on tribal lands receive the child care assistance they need, but the merger has created significant blind spots in how tribes serve children from low-income families and how they support child care providers.

Simplifying reporting requirements is one of the main flexibilities of 477 Plans. Those tribes only need to provide administrative data regarding the total number of children served, according to provider type, and the total number of families served.

However, tribal CCDF grantees are required to submit information under the ACF-700 form, which is the primary method HHS uses to capture data on the use of federal child care assistance on tribal lands. Those tribes must submit data on:

• the number of families receiving services;
• the number of children receiving services, according to the type of provider;
• the number of children receiving services, according to age bands (e.g. three to four years);
• the reasons children received assistance;
• how long, on average, children received services per month;
• the average monthly amount paid for child care services; and
• the number of children served by payment type (i.e., grant or contract).

The Bureau of Indian Affairs and HHS should work together to create a system of reporting and accountability that both based around achieving outcomes relating to employment and training for low-income families and early childhood development. These recommendations are reflected in the Bipartisan Policy Center’s recent report Righting a Wrong: Advancing Equity in Child Care Funding for American Indian & Alaska Native Families.