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Reason(s) for non-compliance: • The Lead Agency does not ensure the privacy of the background check results, as required by 98.43(e)(2). (Plan Question 5.7.10) • The Lead Agency background check agency does not coordinate with other agencies in charge of background checks, as required by 98.43(a)(1). (Plan Question 5.7.11vi) • The Lead Agency does not ensure background checks are completed within 45 days of the request, as required by 98.43(e)(1). (Plan Question 5.7.13a) • The Lead Agency does not ensure that child care staff that reside in a different State receive a comprehensive background check, as required by 98.43(e)(1) and 98.43(a)(1). (Plan Question 5.7.13b) • The Lead Agency does not conduct background checks when a provider is separated from employment for more than 180 consecutive days, as required by 98.43(d)(3)(iii). (Plan Question 5.7.17) Overall Target Completion Date: 07/01/2027 Action Step Number Action Step Description Target Completion Date 1 New Check After 180 Days- IDHW child care program staff in partnership with the IDHW Legislative and Regulatory Affairs Office will coordinate an update to the Idaho Administrative Code (IDAPA) to require background checks after 180 days of separation from childcare employment. Rules will be promulgated for presentation to the legislature's germane committees during the 2026 Idaho Legislative Session. 07/01/2026 2 New Check After 180 Days- If the legislature approves the requested updates to IDAPA, and sufficient funding is available, IdahoSTARS staff will coordinate automation development associated to individual users the Idaho child care provider database (RISE). The updates will recognize when users have been separated from childcare employment for more than 180 days and flag the necessity of a new background check when new employment is gained. This is targeted for completion six months after the proposed rules would go into effect. 12/31/2026 3 Completion within 45 Days- Idaho child care staff will participate in requested technical assistance related to the coordination of completed background checks within 45 days, while still protecting children from potential results delayed by the completion of Child Abuse and Neglect registry checks out of state. 06/30/2026 4 Completion within 45 Days- Child care staff will coordinate with staff from the Idaho Background Check Unit to develop updates to the automated background check system and processes, and coordinate the timeline for automation development, testing, and implementation of the updated background check requirements completing the process within 45 days while still protecting children from potential results delayed by the completion of Child Abuse and Neglect registry checks out of state. 09/30/2027 5 Completion within 45 Days- Adding a requirement to complete background checks within 45 days, 07/01/2027 while coordinating with states other than our own, will be a significant undertaking for Idaho. IDHW child care program staff in partnership with the IDHW Legislative and Regulatory Affairs Office and the Idaho Background Check Unit will coordinate any needed update to the Idaho Administrative Code (IDAPA) to require background check completion within 45 days. Due to the complexity of the policy development and coordination, rules and/or statute will be promulgated for presentation to the legislature's germane committees during the 2027 Idaho Legislative Session. 6 Cities- The Lead Agency ensures the privacy of the background check results, coordinates with other agencies in charge of background checks, and ensures that child care staff that reside in a different State receive a comprehensive background check however it was determined that some cities in Idaho who conduct background checks as a component of their licensing programs may not. Child care staff will contact each city conducting their own background checks to determine their current areas of compliance, their challenges with meeting the requirements, and identify any areas of concern for elevation to IDHW and city leadership. 06/30/2026 7 Cities- The Lead Agency ensures the privacy of the background check results, coordinates with other agencies in charge of background checks, and ensures that child care staff that reside in a different State receive a comprehensive background check however it was determined that some cities in Idaho who conduct background checks as a component of their licensing programs may not. For cities that are not able to demonstrate full compliance with all CCDF background check requirements, IDHW child care staff will coordinate with IdahoSTARS staff and inspectors at the Health District to develop a process to require, and inspect for, a Lead Agency 07/01/2027 background check for providers accessing subsidy. 8 Cities- The Lead Agency ensures the privacy of the background check results, coordinates with other agencies in charge of background checks, and ensures that child care staff that reside in a different State receive a comprehensive background check however it was determined that some cities in Idaho who conduct background checks as a component of their licensing programs may not. Child care staff will identify any areas of concern in city processes and policies and coordinate their review with a focus on solution development with IDHW and city leadership. 12/31/2026