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Office of Child Care briefs tribes on triennial child-count rules, CARS submissions and service-area limits
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Summary
The Office of Child Care told tribal lead agencies a July 1, 2025 self-certified child count is required to set CCDF allocations for the next three federal fiscal years, explained Indian‑child and service‑area definitions, described conferring and non-duplication requirements, and walked participants through the CARS submission and recent CCDF rule changes.
The Office of Child Care (OCC) told tribal lead agencies in a webinar that a self-certified child count due July 1, 2025, will set each tribe’s Child Care and Development Fund (CCDF) allocation for the next three federal fiscal years and detailed how to prepare and submit that count through the Child Care Automated Reporting System (CARS).
"This is the number that we use to determine your CCDF funding," said Mike Colbita, a program specialist in OCC’s policy, data and planning division, stressing that the child count must be unduplicated and based on the tribe’s stated definition of "Indian child" and its CCDF service area. Dawn Ramsburg, division director for program operations in OCC’s Office of Child Care, opened the webinar and outlined the application components tribes must upload or certify in CARS.
Why it matters: OCC allocates a limited tribal set-aside of CCDF money proportionally by per-child counts. Colbita illustrated that if a tribe expands its Indian-child definition and reports more children, its share of a fixed set-aside increases and other tribes’ per-child allocations fall, a result he said underscores the importance of complete, accurate counts.
What tribes must submit: OCC said the CARS submission should include a declaration requesting CCDF funds, an assurance tied to any approved Public Law 01/2477 consolidated plan, and the approved 01/2477 plan or, for tribes integrating CCDF into an in-process 01/2477 plan, the draft plan and related assurances. OCC staff noted these elements may be combined into a single document.
Definitions and limits: Colbita described flexibility in the "Indian child" definition — from enrolled-members-only to broader ancestry-based definitions — but emphasized federal CCDF funds are limited to children affiliated with federally recognized tribes. He also said a tribe’s CCDF service area must be on or near a reservation or, for tribes without a reservation, within close geographic proximity to where tribal populations reside. "ACF cannot approve an entire state as a tribe service area," he said.
Methodology and non-duplication: Presenters urged tribes to pick data sources that match their definitions and to keep written policies documenting methodology, non-duplication checks and conferring with neighboring lead agencies. Borofsky said tribes do not have to submit underlying data sources to OCC but should keep records for their own files and future audits.
Consortia and Alaska exception: OCC explained consortia must submit a child count for each member tribe as well as a signed declaration (sample Appendix 1A). In an Alaska-specific exchange, Colbita said mandatory CCDF funding rules tied to the Social Security Act can require counts for member tribes even if a member receives separate discretionary funds; CARS provides boxes to distinguish mandatory and discretionary counts.
CARS and account access: OCC opened the CARS portal for submissions and encouraged tribes to create accounts, add the child-count module, and attend a repeat CARS webinar. Presenters reviewed account rules — multi-factor authentication, logging in at least every 60 days, password rotation, and role-based access where only an authorized tribal signatory can certify and submit the final declaration.
Recent rule changes and plan amendments: OCC staff summarized 2024 regulatory updates that removed the sliding-fee-scale requirement (March 2024) and removed mandatory family‑income consideration for eligibility (November 2024). Both changes are optional and tribes that adopt them may need to file 01/2477 plan amendments; OCC said it will coordinate plan reviews with the Bureau of Indian Affairs (BIA) and tribes should work with their AOTR to request technical assistance.
Next steps: OCC staff recommended logging into CARS well before late June to avoid access problems, answering conferring questions early, and contacting the CARS help team or OCC AOTRs for timely assistance. Carrie McMillan of the BIA Division of Workforce Development offered to help tribes find their AOTR contacts.
The webinar closed with presenters reminding tribes that the child count submitted in CARS is fixed for the three-year funding cycle (except for certain consortium membership changes) and that accuracy and documented methodology are important both for funding fairness and for future plan cycles.
