Help Shape Federal Child Care Policy — Deadline Feb. 4
The U.S. Department of Health and Human Services is considering changes to federal Child Care and Development Fund (CCDF) rules that could directly affect family copayments, provider payment stability, and support for infant, toddler, rural, and special needs care.
The NPRM proposes to remove or modify some of the mandatory provisions included in the 2024 CCDF Final Rule:
The NPRM proposes to remove or modify some of the mandatory provisions included in the 2024 CCDF Final Rule:
- Rescinds the requirement for states to cap family copayments at 7%. The NPRM proposes to return to the 2016 language, which simply requires states to ensure that family copayments are not a barrier for families receiving subsidy. The NPRM also includes a conforming change to remove the requirement that Lead Agencies describe in their CCDF Plans how copayments do not exceed 7%.
- Rescinds the requirement that states use some grants or contracts for direct services for infants and toddlers, children with disabilities, and children in underserved geographic areas. The NPRM proposes to revert to the 2016 language that state CCDF Plans must include strategies to increase the supply and improve the quality of child care services in underserved areas, infants and toddlers, children with disabilities, and children who receive nontraditional hour care, including whether the Lead Agency plans to use grants and contracts, among other strategies.
- Rescinds the requirement that states pay child care providers based on a child’s enrollment, rather than attendance. The NPRM proposes to return to the 2016 language that allows Lead Agencies to meet the requirement to delink provider payments from occasional absences through multiple options, including: paying providers based on enrollment; paying a full payment to providers as long as the child attends for 85% of the time; provide full payment to providers as long as a child is absent for five or fewer days in a month; or establishing an alternative approach in its CCDF Plan.
- Rescinds the requirements that states pay child care providers prospectively. The NPRM proposes to return to the 2016 language that gives Lead Agencies the option to pay prospectively or pay providers within 21 calendar days.
- Removes language clarifying the total payment to providers. While not a requirement under the 2024 CCDF Final Rule, but included as a clarification, the NPRM also proposes to remove language that requires Lead Agencies to demonstrate in their CCDF Plans that the total payment to a provider would not decrease due to lower family copayments. It argues that since the NPRM proposes to remove the 7% copayment cap language, this clarification would be no longer relevant.
- Timely payments: HHS notes that some providers continue to express concerns about not receiving payments for long periods of time after services are rendered, which sometimes impacts their decisions to participate in CCDF. HHS is seeking comments on whether instead of requiring payment within 21 days of services, if a different deadline (i.e., 7 or 14 days after receiving a completed invoice) would better support provider stability.
- Delinking payments from absences: HHS is seeking comments on whether a different number of paid absences (i.e., providing full payment as long as a child is absent 10 days or fewer instead of 5 days in a month) or a different attendance rate (i.e., 75% instead of 85% of authorized time) would increase child care provider participation in CCDF.
It is important that people comment sharing how these proposed changes could affect:
- The families you serve
- Your program’s financial stability
- Your ability to remain open and staffed
Commenters do not need to be a policy expert. Your lived experience matters.
PACCA has created several optional tools — use whichever fits your time and comfort level:
Comments are due by February 4, 2026.Federal officials often say: “We need to hear from the field.” This is that moment. Your voice helps ensure that child care policy reflects the real costs, realities, and responsibilitiesof providing care in Pennsylvania.