Child Trends is a highly respected, nonpartisan research organization focused exclusively on improving the lives and prospects of children, youth, and their families. For nearly 40 years, decision makers have relied on our rigorous research, unbiased analyses, and clear communication to improve public policies and interventions that serve children and families. Pursuant to the notice published in the Federal Register on April 19, 2019 (84 FR 16572), Child Trends submits these comments to request that the agency withdraw the proposed rule and fully implement the AFCARS Final Rule issued in 2016.