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Nov 21 -- The Labor Department invites comments to OMB by December 21, 2023 regarding data collection for the National Childcare Costs Database.

The Federal Government provides States with funding to offer financial assistance to low-income families to pay for childcare. This funding is provided through the Child Care and Development Fund (CCDF) childcare subsidy program. Subsidy payment rates are determined by States, but payment rates are required to be informed by childcare market prices. States are encouraged, but not required, to set payment rates at the 75th percentile of the market price. To obtain market prices, States are required to conduct a Market Rate Survey (MRS) no more than two years prior to the submission of States' Child Care and Development Fund (CCDF) Plan. The CCDF Plan serves as the mandatory State application to receive Child Care and Development Block Grant (CCDBG) funds. This reinstatement of the National Database of Childcare Prices fills an important gap in data and was first approved for collection by the Office of Management and Budget in August 2019 and made available to the public in September 2022.

The NDCP is the most comprehensive federal source of childcare prices at the county level. The NDCP was first made available to the public in 2022 and it currently provides data for the years 2008 through 2018. The NDCP is based on data collected by each state in their childcare market rate surveys (MRS). State-administered MRS are conducted by state human services or workforce development offices (i.e., Lead Agencies) according to federal regulations to receive Child Care and Development Block Grants (CCDBG). MRS provide market prices of various types of child care (e.g., center-based, home-based) by age of children (e.g., infants, toddlers, preschoolers, school-age children) and by geography. MRS are used to establish reimbursement rates for childcare subsidies. MRS sample eligible centers and care providers in the priced market and obtain the full market price of care. MRS data are a rich source of local childcare price data. However, these data are not reported to the federal government and they are retained by the states. As a result, reporting metrics are not standardized across states and some of the data is not accessible to the public.

MRS are currently collected in three-year cycles. The most current MRS data collection cycle reflects the years 2019 through 2021. Some states may have applied for waivers and conducted data collection or reporting activities in 2022 due to disruptions caused by the COVID–19 pandemic. This information collection would request MRS data for surveys conducted between 2019 and 2022 from all states and the District of Columbia. Data requested would have already been collected by each state to meet federal regulations; no new data collection obligation is created. The Department of Labor would reconcile measures for uniformity across the states and geography would be standardized at the county level to be able to combine these data for analysis with county characteristics that are publicly available from the American Community Survey. The resulting database (NDCP) would be evaluated to protect respondent confidentiality, implementing proper disclosure avoidance techniques in counties with small samples. The database would be made available to the public as a research tool to understand childcare prices at the county level and changes in childcare prices over time.  

Access to affordable childcare is critical to support women’s employment. Because of high childcare prices in the United States and limited government subsidies, childcare access and affordability are issues that affect most working mothers. About 72 percent of mothers of children under the age of 13 are employed. Yet, in areas with high childcare prices, mothers’ employment rates are lower and associated with reduced employment and earnings in the short and long term. However, comprehensive research on the effects of childcare on women’s employment had been limited due to the lack of federal data on childcare prices. The National Database of Childcare Prices, first approved for collection by the Office of Management and Budget in August 2019 and made available to the public in September 2022, fills an important gap in data availability on local childcare prices. No other data source, governmental or private, provides comprehensive county-level childcare price data. Other existing data sources are limited in several ways.

-- Geography. Childcare data collected through federal data sources, including the Survey of Income and Program Participation, the Current Population Survey, and the National Survey of Early Care and Education, are restricted to national- or state-level estimates. These surveys are not large enough to provide sub-state estimates. State-level data underestimate the costs of childcare in urban areas which tend to be significantly more expensive than rural areas. County-to-county variance is also obscured and does not allow for more localized estimates of childcare’s associations with women’s employment. Because parents must choose childcare providers that are in close proximity to their homes or workplaces and prices vary significantly by geographic location within state, state averages are typically not close estimates of the prices parents actually pay which we show using the NDCP. Private sources of childcare data do not have actual county-level data or it is unavailable for most states. The Economic Policy Institute (EPI) derives county-level childcare prices from state-level prices combined with county-level housing rental costs. All families in counties within metro areas are assigned center-based care prices and all families in counties within nonmetro areas are assigned home-based care prices. EPI has conveyed their intent to update their models using the NDCP which provides more accurate county-level data. Child Care Aware of America provides partial county-level data for six states in 2021. Local Child Care Resource and Referral agencies do not make price data publicly available.

-- Universe. The primary federal agency charged with collecting childcare data and reporting on availability and price is the Administration for Children and Families (ACF), Health and Human Services (HHS). However, ACF HHS primarily serves low-income families covered by Child Care and Development Funds (CCDF). As such, HHS tabulations are limited to low-income families. Because childcare is a significant cost for most families, the Women’s Bureau seeks data on childcare prices for all families who pay for care. These data exist. Market Rate Surveys (MRS) conducted by each state assess the price of care in the paid childcare markets of childcare centers and family childcare homes. States must report selected summary MRS results in their triennial CCDF Plan to HHS and use the most recent data to establish subsidy payment rates for low-income families. However, the underlying data used in the CCDF Plan are not reported to the federal government nor consolidated across states. In 2019 and 2020, the Women’s Bureau obtained the already-collected data from 2008 to 2018 from the states and created a consolidated database of childcare prices (NDCP) without income or eligibility restrictions. A new cycle of MRS has been conducted by the states and this ICR seeks data covering 2019 through 2022 to update the NDCP.

-- Comparability. To be able to conduct research on childcare prices throughout the country, the Women’s Bureau requires data that are comparable across states and counties. MRS reports from each state must be harmonized to ensure that variables and definitions are uniform across states. Currently, MRS reports are not aggregated by state and reporting metrics differ across states. Access to the underlying data and tabulations would allow for greater standardization and a higher-quality statistical product.

-- Quality and reliability. Pursuant to the Information Quality Act (Pub.L. 106-554), federal agencies must maximize the quality, objectivity, utility, and integrity of information of disseminated statistics. Prior to the publication of the NDCP, the federal government did not have data on local area childcare prices. In the absence of the NDCP, the government would need to rely on proprietary data from non-governmental entities. Private entities may cease to provide estimates without notice, may modify their methodology, or provide inadequate documentation to certify quality and reliability. Alternatively, the federal government would need to use federal government surveys that were not designed to derive local childcare prices, yielding unacceptable margins of error and unrepresentative coverage.      

NDCP: https://www.dol.gov/agencies/wb/topics/featured-childcare
DOL submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202306-1290-001 Click IC List for information collection instrument, View Supporting Statement for technical documentation. Submit comments through this webpage.
FRN: https://www.federalregister.gov/d/2023-25687

For AEA members wishing to submit comments, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at https://www.aeaweb.org/content/file?id=5806

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