Implementation Deadline

The statute required that states had in place by September 30, 2017 policies and procedures that met the background check requirements. There was one exception to this deadline for the National Crime Information Center’s (NCIC) National Sex Offender Registry (NSOR) check. States had to be in compliance with the NSOR check by September 30, 2018. States described compliance in the submission of the FY 2019-2021 CCDF Plan.

In recognition of the challenges to implementing the CCDF background check requirements, all states applied for and received extensions through September 30, 2018. The Office of Child Care (OCC)/Administration for Children and Families (ACF/HHS) may grant additional waivers of up to 2 years, in one year increments (i.e., potentially through September 30, 2020) if significant milestones for background check requirements were met.

  • To receive these time-limited waivers, states and territories had to demonstrate that the milestones were met via the CCDF Preprint and a time-limited waiver request.
  • These waivers were considered “transitional and legislative waivers” to provide transitional relief from conflicting or duplicative requirements preventing implementation, or an extended period of time in order for the state legislature to enact legislation to implement the provisions.
  • These waivers were limited to a one-year period and were extended for at most one additional year from the date of initial approval.

For any questions regarding waivers, states should contact the Regional Office Program Manager and/or Program Specialist.

For any year that a state fails to substantially comply, 5 percent of the state’s CCDF funds will be withheld.

Consult the OCC website for the most current Program Instructions, Policy Interpretation Questions, FAQs, information on the FBI’s NFF, and implementation guidelines.

See the Program Instruction on CCDF Reauthorization Effective Dates (CCDF-ACF-PI-2015-02) and its attachment for effective dates of the background check requirements. In addition, see the Program Instruction for Guidance on Implementing the National Crime Information Center National Sex Offender Registry Background Check Requirement in the Child Care Block Grant (CCDBG) Act (CCDF-ACF-PI-2017-03)

Resources: Monitoring and Enforcement


[1] CDBG Act 658H(d), (j).