Barriers and Solutions to Implementing CCDBG Act Interstate Background Check Requirements

Publication Date:

September 2, 2022

The 2014 Reauthorization of the Child Care and Development Block Grant (CCDBG) Act includes new background check requirements for child care and early education (CCEE) staff. A research study1 found that these requirements—and particularly requirements to conduct interstate background checks—have been challenging to implement because they require new partnerships and infrastructures within and across states. Other complicating factors include checks not previously used for CCEE employment purposes, the large number of staff who must be checked, and the quick timing required to conduct checks.

Under the CCDBG Act of 2014, background checks must be conducted for CCEE providers who are licensed, regulated, or registered under state law or who receive CCDF program funds.a In addition to federal and in-state checks, three different registries must be checked in all relevant states if a staff member lived in another state in the previous five years: state criminal history repository, state sex offender registry, and state child abuse and neglect registries. In 2019, only 20 percent of states reported completing 95 percent of background checks that had an interstate component within 45 days of the request (Figure 1).


Figure 1. Do states complete over 95 percent of background checks within 45 days?

Figure 1. Do states complete over 95 percent of background checks within 45 days?

Note: Adapted from “States’ status of and identified barriers to implementation of the CCDBG Act of 2014 out-of-state background check requirements”, B. Cunningham & N. Ravishankar, 2021, OPRE Report #2021-15, p.12. Copyright 2021 by Office of Planning, Research, and Evaluation, Administration for Children and Families, U.S. Department of Health and Human Services. Adapted with permission.


This brief is part of the Child Care and Early Education Policy and Research Analysis (CCEEPRA) project. CCEEPRA supports policy and program planning and decision-making with rigorous, research-based information.


Footnote and Reference

a The requirements apply to anyone employed by a child care provider for compensation; contracted employees and self-employed individuals; any adult living in a family child care home; and anyone who cares for, supervises, or has unsupervised access to children in care.

1 Adams, G., & Pratt, E. (September 2021). Assessing child care subsidies through an equity lens: A review of policies and practices in the Child Care and Development Fund. Urban Institute. https://www.urban.org/research/publication/assessing-child-care-subsidies-through-equity-lens-review-policies-and-practices-child-care-and-development-fund