Key Roles in the Implementation of CCDF

While state grantees have flexibility in the implementation of their child care programs, some key responsibilities are defined. States identify a Lead Agency with the authority to administer the program and a CCDF Administrator as the primary child care contact within the state. Both of these roles are identified in the form ACF-118, also known as the CCDF Plan.

New options regarding the designation of a Lead Agency are included in the Act. These include designating an appropriate collaborative agency or establishment of a joint interagency office, in addition to the identification of a state department as Lead Agency. It should be noted that CCDF administration may be conducted jointly across several agencies. For example, child care provider licensing and monitoring for compliance can be conducted by a different agency than the Lead Agency.

The role of the CCDF Administrator varies across Lead Agencies. It is a complex and engaging role that requires extensive coordination and collaboration within the Lead Agency and across agencies, as well as with stakeholders, providers, and the general public. Some of the tasks commonly reported by CCDF Administrators include the following:

  • Interaction with Office of Child Care (OCC) staff through calls or attending national and regional meetings
  • Convening information technology staff to review and discuss data reporting
  • Working with financial staff to ensure the accurate reporting of quality funds expended
  • Engaging stakeholders through the early childhood State Advisory Council, or comparable entity, about changes in policy or spending
  • Working with staff from the state's education department regarding prekindergarten programs, developing and aligning early learning and development guidelines, and coordinating with services provided under the Individuals with Disabilities Education Act (IDEA) Part B and C, for children with special needs, collaborating related to coordinating services through the Every Student Succeeds Act (ESSA), and with 21st Century initiatives that focus on school-age care
  • Managing the implementation of CCDF services (such as licensing, a quality rating and improvement system, subsidy, and professional and workforce development)

More detailed information on the responsibilities of the Lead Agency can be found in the following box.

Responsibilities of CCDF Lead Agencies [1]

Under CCDF, Lead Agencies have considerable flexibility in administering and implementing a child care program that meets the needs of families in their state. The following list includes some of the basic responsibilities of a Lead Agency as found in statute and regulation.

A Lead Agency is designated by the chief executive of a state (often, this is the governor), or by the appropriate tribal leader or applicant. This may be one agency (which may be an appropriate collaborative agency) or a joint interagency office.

The Lead Agency has broad responsibility and authority to do the following:

  • Administer and implement the CCDF program, directly or indirectly, through governmental, nongovernmental, or other public or private local agencies as long as it retains overall responsibility for the administration of the program. If the Lead Agency administers or implements the CCDF program indirectly, it must have written agreements with such agencies that specify mutual roles and responsibilities.
  • Maintain its overall responsibility for child care programs. The Lead Agency determines the basic use of CCDF funds and the priorities for spending CCDF funds, and does the following:
    1. Promulgates the rules governing overall administration
    2. Submits all reports required by the Secretary of Health and Human Services (the Secretary)
    3. Assures program compliance with the approved CCDF Plan and all federal requirements
    4. Oversees the spending of funds by subgrantees and contractors
    5. Monitors programs and services
    6. Fulfills the responsibilities of any subgrantee that does not comply with the following:
      1. Fiscal management
      2. Program implementation
      3. Monitoring
      4. Responding to complaints
    7. Serves as the single point of contact for issues involving the CCDF program
    8. Develops the CCDF Plan at the time and in the manner specified by the Secretary

The CCDF Plan (ACF-118), which the Lead Agency must submit to the Secretary for funding, identifies the following:

  • Lead Agency
  • Entity designated to receive private donated funds
  • Purposes for which the funds will be expended
  • Amount of funds requested, as prescribed by the Secretary
  • Other information specified by the Secretary

In developing the CCDF Plan, the Lead Agency must do the following:

  • Consult with the appropriate representatives of local government
  • Coordinate the provision of child care services with other federal, state, and local child care and early childhood development programs (including programs for the benefit of American Indian and Alaska Native children, infants and toddlers, children with disabilities, children experiencing homelessness, and children in foster care) to expand accessibility and continuity of care as well as full-day services
  • Coordinate the provision of services with the state agencies responsible for specified early childhood–related programs
  • Hold at least one public hearing
  • Conduct a market rate survey (or ACF pre-approved alternative methodology) no earlier than 2 years before the effective date of the currently approved CCDF Plan

The CCDF Plan must include assurances of the following:

  • The Lead Agency will comply with all the requirements of the CCDBG Act and the regulations
  • CCDF funds will not be used for lobbying
  • The Lead Agency provides a drug-free workplace
  • No principals have been disbarred
  • The Lead Agency enforces applicable provisions regarding nondiscrimination
  • The Lead Agency complies with the Pro-Children Act of 1994, regarding prohibitions on smoking

Upon approval of the Plan, the Lead Agency will have in place a child care program that:

  • Complies with the provisions of the Plan
  • Is administered in accordance with the CCDBG Act of 1990, as amended; section 418 of the Social Security Act; and all other applicable laws and regulations

Other Lead Agency responsibilities include the following:

  • Lead Agencies must have an audit conducted after the close of each program period and ensure that subgrantees are audited in accordance with appropriate audit requirements
  • Lead Agencies must submit fiscal and program reports as prescribed by the U.S. Department of Health and Human Services
  • Lead Agencies must submit Plan amendments within 60 days of the effective date of substantial change in the program


[1] CCDBG Act of 2014 658D; Child Care and Development Fund, 45 C.F.R. § 98.10 (2016).