Overview
Title
Submission for Office of Management and Budget (OMB) Review; Child Care Improper Payments Data Collection Instructions (OMB #0970-0323)
Agencies
ELI5 AI
The Administration for Children and Families wants to make some updates to how they collect information about mistakes in child care payments and wants to keep these updates going for another three years. They are asking people to tell them if these changes will help make it easier to spot mistakes and report them correctly.
Summary AI
The Administration for Children and Families (ACF) is requesting public comments on proposed revisions to the Child Care Improper Payments Data Collection Instructions and is seeking a 3-year extension for these revisions. This involves updates to the data collection instructions and forms, particularly revising estimated burden hours and standardizing error causes to improve the clarity and accuracy of data submissions. Comments must be submitted by March 7, 2025, and are crucial for ensuring that these changes effectively reduce the reporting burden on States while maintaining accurate data on improper payments. The feedback, in particular, will help refine the proposed standardized list of error causes included in the data collection forms.
Abstract
The Administration for Children and Families is proposing revisions to an approved information collection, the Child Care Improper Payments Data Collection Instructions (OMB #0970-0323, expiration 1/31/2025). In addition to the proposed changes, we are requesting a 3-year extension.
Keywords AI
Sources
AnalysisAI
Summary of the Document
The document is a formal notice from the Administration for Children and Families (ACF), part of the U.S. Department of Health and Human Services. It seeks public comments on proposed changes to the Child Care Improper Payments Data Collection Instructions. The current authorization for this data collection, under the Office of Management and Budget (OMB) #0970-0323, expires on January 31, 2025, and a three-year extension is proposed. This effort aims to refine the instructions and forms used by states in reporting improper payments, including adjustments to how the data is collected and reported. Key updates include revising the estimated burden hours and standardizing how errors are reported, which are intended to improve data consistency and reduce workload. Stakeholders have until March 7, 2025, to submit their feedback on these proposed changes.
Significant Issues and Concerns
Several issues and concerns arise from the document.
Survey Representation: The decision to revise estimated burden hours is primarily based on a survey that had a 56 percent response rate. This may not fully represent all Child Care and Development Fund (CCDF) Lead Agencies, potentially leading to skewed or incomplete understanding of actual burdens.
Standardization Impact: While standardizing error cause categories in reporting might enhance consistency, the document does not provide a detailed analysis of how this change could impact data quality or the unique needs of various states.
Financial Implications and Monitoring: There's a notable absence of a discussion about the financial implications of these changes or how the proposed reductions in burden hours will be monitored for effectiveness in reducing improper payments.
Complexity and Clarity: The language used is highly technical, assuming familiarity with CCDF-related policies, which could hinder accessibility and understanding for some stakeholders.
Impact on the Public
The proposed changes are likely to have a broad impact in terms of reducing the administrative burden on states that report improper payments in child care programs. By potentially streamlining processes and standardizing certain reporting elements, these changes could lead to more reliable and quicker data submissions. This may ultimately benefit federally-funded child care programs by ensuring accountability and improving the efficiency of public spending.
Impact on Specific Stakeholders
States and CCDF Grantees: For CCDF grantees, which include states, the District of Columbia, and Puerto Rico, the changes in reporting requirements could mean less manual work. However, despite possible reductions in the time spent on data submission, the modifications could initially require adjustments in processes, and some states might find that standardization does not necessarily align with their individual needs.
Federal Agencies: For federal agencies overseeing these programs, the benefit might come in the form of more standardized and potentially more reliable data, enabling better assessment and policy decisions regarding improper payments.
Child Care Providers and Families: Indirectly, the overarching goal of improving the integrity of child care payments can lead to more effective program funding, benefiting child care providers and the families they serve.
Overall, while the proposed revisions aim to improve efficiency and data accuracy, careful consideration and transparency in handling potential concerns and impacts are crucial for the successful implementation of these changes.
Issues
• The document lacks a detailed breakdown of financial implications related to the proposed changes and adjustments in burden hours.
• The justification for the proposed changes in estimated burden hours relies on a survey with a response rate of 56 percent, which may not be representative of all CCDF Lead Agencies.
• The potential impact of standardizing the root causes of error in the ACF-404 Report on data consistency and quality is not clearly detailed, despite the mention of benefits and potential ease of report preparation.
• The description of the survey and its methodology, including possible biases and limitations, is not fully transparent, which could affect the credibility of the proposed changes.
• The language used in the document is technical and assumes familiarity with the Child Care and Development Fund (CCDF) and related Acts, potentially limiting accessibility for stakeholders less familiar with these programs.
• There is a potential risk of not addressing the unique reporting needs of individual states by pushing for standardized reporting for errors, which is not elaborated upon.
• There is no discussion on how the proposed reduction in burden hours will be monitored or evaluated for effectiveness in reducing improper payments.