Last week, the Office of Child Care (OCC) within the Administration for Children and Families (ACF) published an update to their COVID-19 FAQs resource to address questions related to subsidized care of school-aged children. In response to questions about COVID-19 and its impacts for children, their families, and child care providers, ACF created a website with resources for Child Care and Development Fund (CCDF) Lead Agencies in March, including the FAQ resource, and has been publishing new guidance on the site since then.
The revised FAQ addresses the following topics:
- Can lead agencies use CCDF program funds to pay for subsidies for school-age children who participate in remote, virtual, or online school work while in child care? and
- Can lead agencies pay full-time payment rates for these school-age children on remote learning days?
The short answer to both questions is yes, however, OCC provides further explanation. On the first issue, Lead Agencies may use subsidies under these circumstances if it interprets federal regulations prohibiting the use of CCDF for school-age children during the regular school day to apply only when a child is physically at school. The resource clarifies that Lead Agencies are not required to adopt this interpretation.
Further, federal law and regulations that prohibit use of CCDF for either regular education services for which students receive academic credit toward graduation or instructional services that supplant or duplicate the academic program of any school stand. Consequently, under no circumstances may CCDF be used to fund any instruction or services associated with academic credit or a school’s program. Given that CCDF funding is limited, OCC encourages Lead Agencies to set parameters that restrict the use of CCDF for child care services during times when schools are open and children are able to attend safely in person.
Similarly, on the second issue, Lead Agencies may pay full-time subsidy payment rates for school-age child care as long as it is not paying for time when a child is physically attending school and is not paying for any regular education services. Lead Agencies may define full-time and part-time rates.
The OCC will continue to update its COVID-19 Resources page as more information becomes available. ACF also hosts a national consumer education website, ChildCare.gov, which provides state-level information to help families and child care providers stay informed on issues such as: state issued child care guidance, information about child care financial assistance in light of COVID-19, and assistance in finding emergency child care for families who are part of the essential workforce.