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out of state checks, there is just an inconsistency in requested length from divisions. All CCDF/Subsidy license-exempt providers, license-exempt in-home providers, License Family Child Care Home I/II (household members and staff) and Child Care Center Directors (not including their staff) are in compliance with this. The population that we are needing to obtain additional years of interstate criminal registry checks are for non- CCDF/Subsidy License Family Child Care Home I/II (household members and staff) and Child Care Center directors/staff. The checks that are currently completed do provide assurances of the persons character for employment and to be around children.

Appendix A.12: Interstate child abuse and neglect registry check for existing staff. (See related question at 5.4.8 (b)) Describe the provision from which the state/territory seeks relief. Nebraska is requesting a waiver to seek relief for interstate child abuse and neglect registry checks checks for existing staff, specific to ensuring privacy for the individual and 5 years requested from the other state(s). Child Care Licensing and CCDF/Subsidy currently require the individual to be responsible for obtaining their own back ground check from the previous state(s) the lived in. For Child Care Licensing, only the past 12 months is requested. For CCDF/Subsidy providers, the past 5 years is requested.

Describe how a waiver of the provision will, by itself, improve the delivery of child care services for children The Department of Health and Human Services (Lead Agency) administer both Child Care Licensing Services and CCDF/Subsidy, but in different divisions. Requirements for Child Care Licensing are either in state statue or in a regulatory section administered by the Division of Public Health. Requirements for CCDF/Subsidy are in a regulatory section administered by the Division of Children and Family Services. Both divisions have been a part of process improvement project for a few different topics related to streamlining the programs and sharing information. Both divisions are currently working on a project related to background checks. Additional time will allow this work to continue, regulatory changes to be made (both division have a draft in various pending status), and the legislative bill proposal for the upcoming 2019 legislative session to be introduced (for a second time), reviewed, and hopefully passed.

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