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OCC offers step-by-step guidance for CCDF guided case file reviews, stresses PII protections
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Summary
The Office of Childcare trained state and local staff on guided case file reviews for CCDF monitoring, emphasizing collaboration ("monitoring is not a gotcha"), an increased FY25–27 focus on file reviews, expectations for documentation and procedures for safeguarding PII.
The federal Office of Childcare (OCC) held a training session for state and local staff on conducting guided case file reviews during Child Care and Development Fund (CCDF) monitoring visits, stressing that monitoring is collaborative rather than punitive. "It's important to remember that OCC monitoring is not a gotcha," the session host said, urging staff to treat the visit as a conversation about how CCDF policies play out locally.
The training outlined objectives for federal fiscal years 2025–2027, including an increased emphasis on guided case file reviews and interviews with subsidy and regulatory staff to better assess implementation at the local level. OCC staff said on-site monitoring typically lasts about three days and that the number of case files reviewed for each state is determined by that state's CCDF administrative structure and pre-visit planning.
A mock case file review demonstrated what inspectors and presenters should expect during an in-person visit. Jessica Sellers, identified in the session as a licensing inspector from Wauchagon, walked through a type 1 early care center case. She said she conducted a prelicensure inspection on 02/04/2022, used a prelicensure monitoring checklist, found the provider compliant in all areas and issued the license the same day. For annual inspections, she said the team uses a checklist alongside the licensing policy manual and records provider contact information, inspection dates and child demographic data in the inspection report.
On specific monitoring topics, presenters and mock inspectors addressed common points of inquiry. Concerning medication administration, the training explained that regulations require medications to be locked, unexpired, and accompanied by documentation of date, time and dosage when administered; staff must hold the required administering-medication training and that training certificate should be present in staff records. On emergency preparedness, Jessica described required components of an emergency plan — evacuation, relocation, shelter, lockdown, accommodations for infants, toddlers and children with disabilities — and said centers must conduct practice drills and maintain appropriate emergency supplies.
The presenters clarified several procedural matters state and local staff frequently ask about. Annual inspections cited in the example were described as unannounced; when asked, Jessica confirmed "All of our annual inspections are unannounced." She also confirmed that volunteers are treated as staff for the purpose of required drills and trainings and therefore should be included in practice drills and recorded training data.
The training emphasized documentation and transparency during the guided case file review. Inspectors were advised to bring rosters of staff and children, use separate worksheets to document child-to-staff ratios and group sizes by age, and include those worksheets in the inspection packet. OCC encouraged presenters to project the monitoring checklist from their data system, speak clearly for note takers, and identify acronyms on first use.
On data privacy, Sandra and the OCC team advised that personally identifiable information (PII) in case files may be shared on-site or via screen sharing during a virtual review but must remain secure: "The OCC monitoring team will not leave with any information containing PII nor will the OCC monitoring team document PII in their notes," the host said. If documents are requested after the visit, OCC asked states to provide redacted or blank templates without PII and to consult their CCDF administrator with any concerns.
The OCC also recommended optional guided case file review office hours for local staff as practice sessions to clarify expectations and technical steps prior to the on-site visit. The session closed with a reminder to contact the state CCDF administrator for state-specific checklists and further instructions.
The training did not result in any formal actions or policy changes; it was presented as guidance and a procedural walkthrough. OCC said follow-up and any requests for documents will be tracked as part of the monitoring visit process.
