Webinar #5: Draft 2019-2021 CCDF Plan Preprint


>>THERESA CAMPISI: Good afternoon, everyone. This is Theresa Campisi from the National
Subsidy Center. And thank you for taking the time to attend
and participate in our fifth webinar on the National Criminal Background Check Requirement. This webinar is being recorded, so as long
as you are registered, then you should receive an email notification a couple days from now
with a link of the recording. So, today, presenting, we have Rachel Demma,
the Child Care Program Specialist at the Office of Child Care; also Dawn Ramsburg, a Child
Care Special Program Specialist at the Office of Child Care; Brad Kramer, a Senior Business
Analyst at the National Center on Subsidy Innovation and Accountability; and then me,
Theresa Campisi, a TA Specialist. So at this time I’m actually going to turn
it over to Dawn and Rachel, just to introduce themselves and say a quick hello.>>DAWN RAMSBURG: Hi, everyone. This is Dawn Ramsburg with the Office of Child
Care, and hopefully this is partially a sound check as well as an introduction. So hopefully everyone can hear us here, and
there’s not too much background noise. But we’re excited to be able to talk to you
today about background checks.>>RACHEL DEMMA: Thanks, Theresa and Dawn. This is Rachel Demma in the Office of Child
Care. I just wanted to say hello to everyone, and
let everyone know that, with the departure of Mary from the Office, that I will be taking
over as a point person for this issue area. So, I look forward to working with you all. Back to you, Theresa.>>THERESA CAMPISI: Great, thank you. So, we’re just going to go ahead and move
on. And before we officially get started today,
I’d like to go over a few housekeeping items. We have about 120 people attending this webinar,
so everyone will be on mute. And we ask that if you have any questions
or comments, you type them in your questions box, and we’ll try to address them on today’s
webinar. You may also utilize the hand-raising feature,
and one of our organizers will unmute you, so that if you want to actually speak to the
group, that’s okay, too. As a reminder, this is a webinar series of
different webinars, so we hope to answer different questions or review different clarifications
on each webinar. The new clarifications we review partly depend
on your responses to the polls at the end of the webinar, so please don’t forget to
hang on the line and take the polls. And just one more reminder to utilize the
question box for questions and comments. So, our agenda looks like today we’ve got
a couple of policy clarifications, like we usually do. But the majority of the time will be spent
on the draft 2019–2021 CCDF Plan Preprint. And, as always, we have opportunities throughout
the webinar for questions. So, I’ll go over a couple of, like I said,
brief clarifications, and then Brad’s going to take over the Preprint section. So, the first clarification we have is, “Who
is responsible for paying the background check fees?” States, territories, and tribes have the flexibility
to determine who pays for background checks. So, for example, the Lead Agency, the provider,
or the applicant may be responsible for the fees. Fees that a state, territory, or tribe may
charge for the cost of processing applications and administering a criminal background check,
shall not exceed the actual cost for the processing and administration. And at a Lead Agency’s discretion, CCDF funds
may be used to pay the cost of background checks including legally exempt and family
child care providers, and their household members. The next clarification is on privacy of results. So, the question is, “Who can make a determination
that a prospective staff member is eligible to work?” The Lead Agency is required to make determinations
regarding a child care staff member’s eligibility for employment. The Lead Agency must provide a response for
the background check to the child care provider in a statement that indicates only whether
the prospective staff member is eligible or ineligible, without revealing specific, disqualifying
information or other information regarding the individual. If the staff member is ineligible, the Lead
Agency must provide information about each specific disqualifying crime to the prospective
staff member, as well as information on how to appeal the results of the background check
to challenge the accuracy and completeness. So, this is an exception to who the results
can be shared with. So, the question is, “Can detailed results
be shared with provider or the prospective employer?” So, most Lead Agency currently use Public
Law 92-544 or the National Child Care Protection Act/Volunteers for Children Act, NCPA/VCA,
as the authority to conduct FBI background checks. The NCPA/VCA requires dissemination of the
results to a governmental agency, unless the state has implemented a Volunteer and Employee
Criminal History System program. Through the NCPA/VCA VECHS program, Lead Agencies
may share an individual’s specific background check results with the child care provider,
provided the individual has given consent. And Lead Agencies have the flexibility to
continue to use these statutes as authority to complete the FBI fingerprint check, as
long as the employment determination process required by the Act is followed. So, this is the first opportunity that we
have for questions. So, it doesn’t look like we have any questions
in the questions box, Brad. So, I will go ahead and move on unless you
have anything else to add.>>BRAD KRAMER: Okay. Thank you, Theresa. So, now that we’ve got a couple of policy
clarifications out of the way, I just wanted to take a look at this first slide, the Background
Check Requirements Highlights. And most of the webinars, as Theresa said,
in this series have been focused on the criminal background check requirements. And now that we have the Preprint available,
we wanted to bring that to this group to sort of link the two together and allow some Preprint
specific questions as they relate to criminal background checks. And as we go through some of this information
moving forward today, we do have Dawn available, as we heard earlier, to answer some of your
specific questions about the Preprint. But I’m going to try to do my best to convey
the information that we have here in the presentation for you. And just to note for those of you who may
not remember, or who could be here for the first time, we do have a handout section in
the webinar, and it does include a copy of the PowerPoint version—I’m sorry, the PDF
version of today’s presentation. So, you will have some of this documentation
available to you, along with a few other resources that we have included there. But moving into the content, the Background
Check Requirements Highlights. If you’ve been attending this series of webinars,
you’ve seen this presentation a number of times. But I wanted to just throw it up here one
more time, because it does encapsulate, at a high level, the eight specific background
check related requirements regarding qualifying for employment. The eight I’m referring to are the two federal
checks; a national FBI fingerprint criminal history check; the NCIC National Sex Offender
Registry check, sometimes that’s referred to as the NSOR N-S-O-R; and then for the current
state of residence, the in-state criminal history, the in-state sex offender registry,
and the in-state child abuse and neglect. So, there are those five, plus three when
there is a previous state of residence within the past five years. And, as you all hopefully know by now, these
requirements are applicable not only to prospective staff who are seeking employment but those
who are already employed as well. And we’re going to talk about how the waiver
is affected by those in a little bit. So, without going any deeper into the detail
of the background checks, because we’ve done that so many times, we’re going to move focus
to the Preprint and how they apply. And the first thing that we wanted to start
off with by mentioning, is that just yesterday—literally yesterday—the public comment period closed
on the Preprint. And rather than wait for any changes that
may come about as a result of that, we wanted to get you the information as soon as possible. And so here we are, right after the holidays,
getting this on the books, because we knew we would have the Preprint. We also knew we would not yet have all of
the public comment feedback or any changes that may come from that, so I mention this
just to reiterate and stress that what we’re covering today is based on the Preprint as
it stands as of today. We are not forecasting any changes that may
come based on the public comments period. Just letting you know we’re getting you information
as quickly as we can and being as transparent about it as possible. So, thank you for that understanding, hopefully,
as we move forward with the information here today. So, let’s talk about what information we do
have available of today. So—and I’m not going to read all of these
slides word-for-word. Again, you can download these and take them
with you, if you choose, but the bottom line here is that it goes without saying that there
were some challenges to implementing the CCDF background check requirements. And all states, as a result of that, did apply
for and received extensions through September 30th of 2018. Going further than that, OCC, in the Administration
of Children and Families, is committed to granting an additional two years of waivers
in one-year increments. However, those are not just going to be blanket
waivers. You are going to have to apply to receive
the limited time waivers, and in order to qualify for the additional waivers, you will
have to demonstrate progress by meeting some clearly defined milestones. And we’re going to talk about those on the
next slide. Before I get into the details of the milestones,
I do want to let you know that I will be pausing for questions once I get to the end of this
segment. If you have questions that you want to start
entering into the questions chat box, feel free to do so. I may be actually answering your question
as we go, so if you want to wait, that’s fine. The same goes for anyone who may want to raise
their hand and ask a question. We will pause and give you the opportunity
to say so. I didn’t want you to think that I was just
going to talk for the next 20 or 30 minutes and not give you the opportunity to be heard. Before we hit a question-and-answer session,
though, I do want to cover a little bit more information. And that is specifically what the milestone
prerequisites are, in order to meet the milestone for applying the waiver. By September 30th of this year—that’s the
end of the initial waiver period that everyone has asked for and was granted—states, territories,
and tribes must have requirements, policies, and procedures for four of those eight components
that we just talked about, for new prospective child care staff. I’m stressing that because remember the requirements
actually apply to new and current staff, but the milestone for the waiver is that you must
have the policies, procedures in place for the four green checkmark requirements for
new staff. We’ll talk about existing staff in a little
bit. Those four milestones are the National Fingerprint
Criminal History Check and then all three of the in-state checks. All three of those for existing staff must
be in place by September 30th of this year to meet the milestone. The other four with the X’s, those do not
have to be in place. They’re not required for the milestone. They can be included as part of the waiver
requests going forward, but if you’ve already made progress on those, by all means, please
continue to keep it up. So let’s move on then to slide 12 and look
at what exactly the time-limited waiver allows. So, if those milestone prerequisites are met,
again, for new hires those for background check components, then the additional time
waivers may be requested for the other components as outlined in the proceeding table. That waiver allows for conducting the background
checks on the backlogs of current staff only. So, if you can do these four on existing—I
apologize, if you can do these four for prospective new hires, then you can get a waiver for doing
these four on all of the backlog staff that’s currently employed. The next slide discusses the other items that
are also allowed and what those non-milestone components are. If the milestone prerequisites are met, then
additional time limited waivers may be requested for these other components: The National Sex
Offender Registry check and the out-of-state checks for Criminal History Sex Offender Registry
and Child Abuse and Neglect Registry. But, again, you must meet those requirements
as milestones first in the preceding slide. If you’ve done that, then you can apply to
have a waiver for establishing requirements and procedures and/or conducting the background
checks on all new prospective child care staff for these components and/or conducting background
check on the backlog of current staff for all components. And just to note, states may request multiple
waivers and for different reasons. Moving on to slide 14, this talks about what
some of the deadlines are for the waiver. Starting October 1st, which is the end of
the current waiver period, you can apply as part of the submission for the Plan. There is no separate letter required. In order to receive the time-limited waivers,
states and territories must demonstrate, again, that those milestones are met, and they can
do so by responding to a series of questions included in the Preprint. If that is approved, states and territories
will have the option to renew the waivers for one additional year, so long as progress
is demonstrated during the initial waiver period. To request the renewal, that would be done
through a Plan amendment. The next slide here just gives a little bit
more of a breakdown of what some of the deadline dates are. We have the original deadline for implementation,
which was September 30th, 2017. As we discussed, all states applied for and
were given the one-year extension. That deadline is coming up in this September
30th. For the two new one-year additional waivers,
we see both of those deadlines here, as well. But, again, you must be meeting the milestones
for the first one. You have to show progress for the second one. And full compliance for all eight background
check components for prospective staff and existing staff is required by September 30th,
2020. So that is a lot of information I just threw
out there at you, and I’m sure you have a lot of questions. We have taken two questions that we’ve seen
previously and are of a topic that has come up more than once. And, so we tried to formulate a combined question
in response here, so that you had at least something to go on for some frequently asked
questions, and then we will open it up to the group. So, the first question here, relating to the
Preprint, is regarding the criminal background check requirements five through eight. When I say five through eight, I mean those
four red X requirements, the ones that aren’t part of the milestones. “Can the waiver request vary depending on
the requirement? For example, can the state request a waiver
to have time to establish procedures for NSOR at the same time they request a waiver to
conduct the inter-state background checks?” So, the short response is yes. And, as we mentioned earlier, you can have
the requests for multiple reasons. But you can request multiple waivers for any
applicable components for different purposes. So as the example says here, you can have
a waiver for time to establish a procedure for one, while requesting time to conduct
another one. So the next FAQ question and response here,
“Is it correct to understand that if a state needs a one-year waiver to establish procedures
for one or more of the checks, their ability their ability to get a second year waiver
to have time to conduct the checks is contingent on meeting the milestone of finalizing and
implementing procedures during the first waiver period?” So, it’s—that’s not necessarily true. What we mentioned and what the requirements
state is that you must demonstrate some progress in the initial waiver period. So, it doesn’t necessarily specify what the
project is, and there will be some additional guidance on that later regarding the timeline
and criteria for requesting the renewal. So hopefully that helps hit off a couple questions. Again, I apologize for going through this
so quickly, but we really anticipated that much of the time of this hour would be spent
with some verbal discussion on questions that folks want to ask, not only in the chat, but
also via raising their hands and allowing us to unmute you. So, without further ado, I am going to turn
it over to Dawn, who is monitoring the question chat box and Theresa, who is monitoring the
hand raises, and open the lines up for questions now. So, if you hear some silence, it may be because
we are scrolling through the questions to sort them out and determine the best order
to in which to provide responses. So, without further ado, Dawn and Theresa
and Rachel, feel free to take it away.>>RACHEL DEMMA: Hi, Theresa. This is Rachel. Did you want me to just go ahead and start
addressing the questions that have come in through our question box?>>THERESA CAMPISI: Yes, that sounds good. If you just want to read the question first,
and then answer it.>>RACHEL DEMMA: Sure. So, the first question is, “I thought CCDBG
required we not share specific—” Oh, it just moved. I’m sorry. It just went away.>>THERESA CAMPISI: I can read it.>>RACHEL DEMMA: That’s weird. Why does it move?>>DAWN RAMSBURG: Because someone else added
something.>>RACHEL DEMMA: Oh. Okay. [LAUGHTER]>>THERESA CAMPISI: So the question was—>>RACHEL DEMMA: Would you mind reading question,
Theresa? Thank you.>>THERESA CAMPISI: Sure, no problem. “I thought CCDBG required we not share specific
results with the program just the applicant.”>>RACHEL DEMMA: Right. And, so to speak to that, I think it’s important
to first make the distinction between the use of the words program, provider, and applicant. And when we—in earlier slides in this presentation
and past presentations—speak about providers, I think that’s synonymous with programs
and then the applicant is referred to in our slides here and previous slides, we’d use
as the individual. So, as we did clarify in the privacy of results
section of the presentation on today’s webinar, yes, the Lead Agency is required to provide
a response for the background check that’s been conducted that indicates only whether
the prospective staff member, or applicant, is eligible or ineligible without revealing
the specific disqualifying information or any other information regarding that individual
applicant. There is clarifying language, in addition,
in our preamble to the Act, which we also touched on on slide 6 in today’s presentation,
which clarifies that the flexibility to share individual specific background check results
with the child care provider directly, provided that that individual has given consent, is
allowable under the National Child Protection Act Volunteers for Children Act, the NCPA/VCA,
and that states have flexibility to utilize that range of response allowed under that
Act. So, unless there’s additional questions on
that, which will come in hopefully through the question box, we’ll jump to the second
question, the tribal question. Theresa, would you mind reading that one?>>THERESA CAMPISI: Sure. “Is it necessary, or maybe suggested, to
also include a tribal background check?”>>RACHEL DEMMA: So, under the Act, all tribes
are required to conduct background check requirements. Whether or not they conduct a check on their
tribal criminal records repository separately, is not required because not all tribes have
these repositories. So, if that is what the question is asking,
we wanted to clarify that. If the tribe does have such a repository,
it makes sense for them to go ahead and try to execute that as part of the requirement,
but that is not part of the required activity under the Act.>>THERESA CAMPISI: Okay. So, do you want to keep going with the questions?>>RACHEL DEMMA: Yes. I believe the next question—Oh, I think
we’re going to skip Shelly’s question as more of a statement of clarification, but, if you
wanted to go ahead and read that out loud, that’s great. And I think we were going to move to the NSOR
question.>>THERESA CAMPISI: Yeah. Okay. Yeah, I’ll move on to the next question, which
is, “Does the in-state sex offender check have to be name and date of birth like the
NSOR, the National Sex Offender Registry, or is a fingerprint-based check of an in-state
sex offender registry sufficient?”>>RACHEL DEMMA: So the in-state sex offender
registry check may be conducted by a fingerprint, and that is up to the state Lead Agency determination.>>THERESA CAMPISI: Okay. The next question is, “Is a background check,
the background checks the CCDF is required to pay for providers or is it an obligation?” I’m sorry. I don’t think I’m reading that correctly. “The background checks with CCDF is required
to pay for providers or is it an obligation?” So, I think the question is are states requiring,
are they required to pay for the background checks for the providers? And if I’m not actually reading that question
correctly, if you can just type in another question and clarify what I was saying, that
would be great.>>ANDREW WILLIAMS: So, this is Andrew Williams
in the Office of Child Care. And that would be a state’s decision. Some states pay for the background checks
for the providers and others charge fees to providers. So that’s the state’s decision, if we’re
understanding the question correctly.>>RACHEL DEMMA: And this is Rachel. Just to piggyback on that, the cost of the
fee charged by the Lead Agency cannot exceed the cost of the check itself that the agency
is performing.>>THERESA CAMPISI: Okay. “What if your state does not have a child
abuse and neglect registry?”>>DAWN RAMSBURG: So, Theresa, we’re going
to move to the question, the Plan question, that came in. This is Dawn.>>RACHEL DEMMA: Did we want to answer that
first?>>THERESA CAMPISI: Sure, no problem. Do you want me to read it or I—>>DAWN RAMSBURG: No, I can. I can. I keep having this sense of, like, not being
heard since we had a bad experience in this room right before this call. So there was a question that asked about,
in a review of the Plan and the final rule, it shows that there are 15 background check
requirements for states to be in full compliance, and then it asked if there will be a comprehensive
matrix or grid developed for the states to consult. And so, while it is true that there are more
requirements that are listed in the Plan and included in the milestone, we organized it
in—the milestone is based on, like, getting the requirements set up. And then some of the additional requirements
around background checks, such as, like, the 45 days to conduct and some of the other things,
are also part of the requirements. But the milestone and the reason why we limited
it to those eight, is those are getting your requirements and your processes in place to
be able to conduct background checks. And so, we don’t plan to include all 15 requirements
as part of the milestone. The milestone is about the eight components
of a comprehensive background check. And so, then the other requirements will need
to be there, but they’re part of the broader process. But the first step is getting the capacity
to conduct a check initially. And the eight components is focused on the
elements of what a comprehensive background check must be. So, if that does not make sense and more clarification
is needed, I’m happy to talk about that. But that’s the way that the Plan is set up
is, first about what the eight required background check components are, and that’s where you
can have more time. And those other the other elements that are
part of it, such as the 45 days and some of the other things, are not a background check
in and of themselves. They’re part of the process of conducting.>>BRAD KRAMER: This is Brad. While you focus on locating the next Preprint
question, I’m going to ask Theresa if we can go back to slide 12. I just wanted to make sure I clarify something
that I believe I may have misspoken on. It is correct on the slide, but I think I
may have mentioned it incorrectly so for the group just to review, and this is regarding
the milestone component—the milestone components being those four checks for new hires—the
waiver would then allow for those same four checks on existing staff. In other words, you start doing it for everybody
who’s looking to work, and then you can get a waiver for the folks who are already working. And then on slide 13, there’s a combination
of things that the waiver is allowed for, which also may include some elements for prospective
and existing staff for those four components you see there. So hopefully I did not confuse anyone. There was a comment that I think I said something
incorrectly, so I wanted to go back to show those two slides again and just reiterate
what it is supposed to be. So, thank you for that, and I apologize for
any confusion I may have caused. I’m going to send it back to Dawn now to see
if we have any other Preprint questions. Thank you.>>THERESA CAMPISI: Dawn, did you want us
to go over some of the resources while you all are reviewing some of the questions that
you plan on answering?>>ANDREW WILLIAMS: Yes.>>THERESA CAMPIS: Okay.>>DAWN RAMSBURG: Yeah that would be great.>>THERESA CAMPISI: Okay. Great. So, this is the resources page, which, if
you participated in the previous webinars, you know we have been kind of showing these
resources. There is in the—in your panel here, there
should be a handouts section that you can actually download a PDF of the PowerPoint
that we’re reviewing today. And within that PowerPoint, these links are
live links, so you should be able to just click right on the link and go directly to
these pages. So, some of the resources are the Background
Check Requirements Highlights, which Brad went over. And we tend to go over that during every webinar,
because it’s a nice, comprehensive, high-level document. We have the Criminal Background Check Requirements:
CCDBG Act Background Check Requirements. And that is basically a PowerPoint of all
of the webinars that we’ve gone over. So, it’s one document where you can kind of
go through and find your question and answer, hopefully. And then the Child Care Subsidy Criminal Background
Check Contact List. I just want to throw out a reminder to state
administrators and anyone who is the point of contact for the contact list, that I will
be updating the contact list in February. So right now, I think it was last updated
in November. So, if you can get those updates to me within
the next week or two, that would be great. And then it’ll be in the next contact list. A couple people have already emailed me, so
thank you for that, and I will be sure to include those. And then we’ve got the National Criminal Background
Check Webinar Series, numbers one, two, and three. We had some technical difficulties on number
four, so that was not recorded. We apologize for the inconvenience. And then, on the Administration for Children
and Families webpage, there is the PI for Implementing the NCIC NSOR Background Check
Requirement, and the PIQ for Clarification on CCDBG Act Background Check Requirements
and Health and Safety Training Requirements. So, those are really good links to have and
really good resources to, kind of, make sure that you’re in the know. And I’m going to just go ahead and launch
the poll, because this will take only a second. And, so the poll is, “What topics would
you like to discuss on the next webinar?” Is it inter-state background checks? Fingerprint vendors, and what other states
are using, and how they’ve worked with those fingerprint vendors? Building relationships with criminal background
check partners? Do you need more information on the NCIC NSOR? Or other? And if you do have an “Other,” then please
feel free to type that into the questions box, and, you know, we will pull that report
at the end of the webinar. Or at the end of the webinar, please feel
free to send me an email, and just let me know what you would like to have discussed
on the next webinar. So, it looks like we have about 35 percent
that have voted, so I’ll give it another like 10 seconds. Okay I’m going to close that. I’m going to share that. So, it looks like 47 percent said, “Inter-state
background checks.” Fourteen percent said, “Fingerprint vendors.” Nineteen percent said, “Building relationships
with criminal background check partners.” Eighteen percent said, “NCIC NSOR.” And 1 percent said, “Other.” So, we definitely take those things into consideration. Thank you. And then I’m going to turn it back over to
Central Office to address any more questions that, you know, they’re comfortable with at
this time.>>ANDREW WILLIAMS: Hi. This is Andrew Williams. We’re going to do a tag team here and pass
the microphone around here. So one question that came in is, “Can a
person begin working prior to an eligibility decision being made, as long as they are under
a supervision of another staff person who has gone through the comprehensive background
check process, and then be determined eligible?” And the answer to that is no. Under the rules of CCDF regulation, in order
for someone to begin employment, they have to have been completed and been cleared by
either their FBI fingerprint check or their in-state fingerprint check of the criminal
repository. Once they are cleared by one of those two
checks, they can begin working provisionally, under supervision, while the remaining results
come in. And now I’m going to turn it to Rachel.>>RACHEL DEMMA: Thanks Andrew. The next question reads, “The state currently
has a name search database for state sex offender registry. Will this suffice in meeting the requirement?” And the answer to that is yes. That is not required to be fingerprint-based. The next question reads, “On the background
checks, is the tribal CCDF required to pay for all providers? Are we obligated to pay?” The answer to that is yes. The same rules apply to the tribes, to the
states in that scenario. We just covered the payment rule. And the next question reads, “What about
family relative care providers that are not required/exempt from the background check
process?” And we have a question back to the questioner,
because under the current rule and Act, family and relative care providers are exempt. So, can you help us understand exactly what
you’re asking?>>ANDREW WILLIAMS: The relative provider
is, but not family child care provider.>>RACHEL DEMMA: But not family provider,
right. And I believe—am I turning this over to
Kathy? Okay.>>KATHY GATTIN: Good afternoon. This is Kathy Gattin with Central Office. The next question was, “What if your state
does not have a child abuse and neglect registry?” We did the 56 TA calls with WRMA, and the
only—we had one state, I’ll put it that way, that didn’t have a child abuse and neglect
registry. Most do, is our understanding. So, if we’re talking about this one state,
or if you know of another one that doesn’t, there has to be probably another process taking
place that’s investigating this type of situation. So, we would encourage you to talk to the
Regional Office, because possibly some other office is doing this. They may not have the registry out there,
but the investigations may be taking place. So, again, we’re only aware of one state that
didn’t have a CAN registry when we were doing those calls. And, Theresa, correct me if you can remember
if there was another one, but I know that we ran into that situation only once in my
limited memory. [LAUGHTER]>>THERESA CAMPISI: Yeah, I think you’re right. I don’t remember offhand which state it was,
but I think, for the most part, most states had some type of registry. Yeah.>>ANDREW WILLIAMS: So, there was a question
about states that do not give information to out-of-their state requesters, I think
to out-of-state requesters. Theresa, did you want to talk a little bit
about the list that’s on the website that you all put together and any plans to update
that?>>THERESA CAMPISI: Was it the contact list?>>ANDREW WILLIAMS: Yes, the contact list. I believe they’re asking about state information. If I understand the question correctly, they’re
asking about getting contact information for other states.>>KATHY GATTIN: They’re asking—I’m sorry. I think someone might be asking about states
that don’t give information to other states, because there are several of those. They will not share right now, but what we
have always said, as far as OCC, is best effort you can. You would not be penalized for making that
effort and not being able to get that information from another state. That’s the way we’ve approached it, as far
as those situations, in the past.>>THERESA CAMPISI: But, Andrew, if you wanted
me to address the contact list again, there is a contact list online, and it was on the
resources page. So, feel free to go on there. And if you see something that’s incorrect
about the contact list from your state, please feel free to reach out to me and let me know,
and I will certainly fix that. But it will be updated in February.>>KATHY GATTIN: This is Kathy. On this question about if only one fingerprint
is allowed, I think there maybe within five years, or in the last five years of this person’s
employment. It says, “How can we have the NCIC check
done on the already enrolled providers who’ve had fingerprints done in the past five years?” There’s no NCIC, you know, decision that I’ve
ever read that says you can only have one fingerprint in any five-year period. I mean, people have fingerprints done for
various reasons, and they all go through NCIC. So that may be a state decision in this situation. I’m not aware of this from the FBI saying
that, and, like I said, it may be an agency like a state police or a state decision. And providers who’ve already had their fingerprints
done, are going to have to be, even if it’s been done inside the last five years, with
my understanding, they would have to have them done again for this purpose, because
this is a more comprehensive check. And so, that’s the answer to this. This is a more comprehensive check. Even if you’ve checked your individual within
the last five years, they still would need this check done, and it’s good for 180 days. And if they change providers, and it’s been
more than that period of time, they are going to have to be rechecked.>>ANDREW WILLIAMS: So, there was a question
about tribes and the deadlines for tribes. I’m not sure if we’re understanding the question
exactly, but the tribes have to comply with the regulation by October 1st, 2019. And so that is currently the deadline when
tribes would be in compliance with the background check requirements. There is a provision in the rule that allows
tribes additional flexibility and proposing an alternative approach to background checks,
but we don’t anticipate that that would be used to circumvent the requirements entirely.>>THERESA CAMPISI: We do have someone with
their hand raised, and I think I accidentally put it down, but are you okay with me unmuting
someone to ask a question?>>RACHEL DEMMA: We are. We wanted to circle back and just clarify
the response to the question regarding exemptions under the law for criminal background checks,
and clarify that relative providers are exempt and family child care home providers are not. If that was confusing, apologies on this end. And, Theresa, we’re happy to go ahead and
take a question.>>THERESA CAMPISI: Okay. Actually she hasn’t entered her PIN number,
which is fine. But she did send me the question privately,
and it says, “Once we receive background checks, what is allowable on background checks
and is there a statute of limitations?” Let me see if she’s entered her PIN, and if
she has, she could clarify her question. I have not received an update on that, so
I guess you could move on to the next question.>>RACHEL DEMMA: Theresa, this is Rachel. I’m just going to jump in with an additional
clarification to our response on exemptions, because, as was just rightly pointed out—we
were having some discussion here—relative care providers, in order to be classified
as relative care providers, are related to all of the children in care. So just to make sure that that’s clear in
terms of the definitions under the Act. And we can move on to the next question.>>THERESA CAMPISI: Were you all going to
review them, the questions, and then read it out loud?>>RACHEL DEMMA: Theresa, I think we’re feeling
that we’re almost out of time here on our end. And so, if there are additional questions
that we haven’t gotten to, if folks could submit those by email for us to answer.>>THERESA CAMPISI: Okay. That works. So, my email address is on this screen. So, if you do have follow-up questions that
maybe were not answered today, please feel free to email them to me, and then I can make
sure to submit them to OCC Central Office. And do you have any closing remarks? Central Office? Rachel? Dawn?>>RACHEL DEMMA: I think that’s it from our
end. And thank you to everyone, including our hosts
at the Subsidy Center. And I think, yeah, that’s it from our end
this afternoon. So, thank you.>>THERESA CAMPISI: Okay. Thanks, everyone. Have a good afternoon.>>BRAD KRAMER: Thank you, everyone.

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