States have the option of using differential monitoring strategies, provided that monitoring visits are still representative of the full complement of licensing and CCDF health and safety standards. Many states use differential monitoring approaches, which are intentionally designed so that although not every licensing standard is specifically checked for compliance, the monitoring visit is indicative of the full range of the licensing requirements. Differential monitoring often involves monitoring programs using a subset of requirements to determine compliance. There are two methods that states have used to identify these critical rules:

• Key indicators: An approach that focuses on identifying and monitoring rules that statistically predict compliance with all the rules. The key-indicators approach is often used to determine which rules to include in an abbreviated inspection form or checklist.
• Risk assessment: An approach that focuses on identifying and monitoring rules that place children at greater risk of mortality or morbidity if violations or citations occur. A risk assessment approach is most often tied to classifying or categorizing rule violations and can be used to identify rules where violations pose a greater risk to children, distinguish levels of regulatory compliance, or determine enforcement actions based on categories of violations.

Note: Monitoring strategies that rely on sampling only some providers or allow for a frequency of less than once a year for providers that meet certain criteria are not allowable. The law clearly states that each child care provider serving a child receiving CCDF assistance shall receive an inspection annually.

[1] Office of Child Care. (2016). Child Care and Development Fund final rule frequently asked questions. U.S. Department of Health and Human Services, Administration for Children and Families. https://www.acf.hhs.gov/occ/faq/child-care-and-development-fund-final-rule-frequently-asked-questions