The first step in conducting a Market Rate Survey is to identify the market area. The market area is the geographical area in which the child care providers are located who will be surveyed. Due to the differences among Tribes, the varying regulations regarding child care providers on reservations, and the different geographical configurations of tribal grantees, deciding the market area will be critical. Consequently, in identifying the child care market area for the survey, general questions to be answered by the Tribe are:

• Did the State Market Rate survey include geographical areas in which our Indian families select child care?

• Is that geographical area the eligible tribal families use for child care the same as the service area described in the CCDF plan? If not, in what additional areas does the Tribe need to collect data?

By deciding the answer to the above question, Tribes can begin to focus on the child care market area to be surveyed. The following discussion describes specific areas of thought for grantees on reservations, in tribal consortia, or in the states of Alaska, California, and Oklahoma.

Tribes on Reservations: Some families living on reservations will choose child care services from providers who also live on the reservation. Other families will select child care providers who live off the reservation, but close to work or school locations. The Tribe must decide if the Market Rate Survey will include providers on and off the reservation. It is important to consider the relationship between the service area described in the CCDF plan and the geographical area of the Market Rate Survey. A possible decision determining the Market Rate Survey area could be to survey the providers in the area where Indians living on the reservation work. Therefore, if persons traveled 20 miles off the reservation to work, the child care providers on the reservation plus those providers in a 20 mile perimeter around the reservation might be the population to be surveyed. In this case, the State may be asked to supply the information for those providers off the reservation. The Tribe may survey only those providers on the reservation, if they were not included in the State Market Rate Survey. Then the Tribe would combine the information to determine their Market Rate Survey.

If the Tribe plans to provide subsidies for child care services only on the reservation, the Market Rate Survey would be conducted only with the providers on the reservation. A call to the State Agency administering the State's CCDF monies should indicate whether or not any of the State's data is useful for the Tribe. A list of the State CCDF Agencies and Contact Persons is included in Appendix B.

Some Tribes on reservations combine the use of State CCDF funds with Tribal CCDF funds. Tribal families, with dual eligibility for both State and tribal funding, apply for the State's subsidized child care services. In this case, the State pays the child care provider the State's determined reimbursement rate. The Tribe may pay the child care provider the family's co-payment or use the tribal grantee funding for other child care purposes. Conducting a Market Rate Survey in situations such as these would obviously be a collaborative effort between the State and the Tribe.

Tribal Consortia: In order to receive CCDF funds, Tribes participating in a consortia must be within geographic proximity to each other or have an existing consortium arrangement already in place. The concept of a Market Rate Survey becomes even more complex when the market may be small geographical areas spread across a state or multi-state area. The Consortium conducting the survey may wish to contact the State Agency or States administering the CCDF funding and inquire about their data. If the State(s) can break down their data into zip code areas, the Consortium may be able to use this data as their Market Rate Survey. Again, it is important to know whether or not the State included data from providers (regulated and unregulated) that provide child care services to both tribal and non-tribal families.

Alaska, California and Oklahoma: The CCDF funds for Tribal and Alaska Native entities are used to serve Indian children living on or near reservations except in the states of Alaska, California, and Oklahoma. Due to the demographics of American Indian and Alaska Native groups in these states, the service areas defined by the grantees are different. Tribal grantees may have overlapping service areas, areas spread across large underpopulated spaces, service areas which combine metropolitan and rural populations, or combinations of other factors.

Tribal or Alaska Native grantees in these states may contact the State CCDF Agency to find out how the State conducted their Market Rate Survey. Again, it is important to know whether or not the State included providers (regulated and unregulated) who provide child care services to tribal families. In areas where another tribal grantee or a consortium may also be receiving CCDF funding, all Tribes may need to collaborate on identifying the market area and on using similar data for the survey. Tribal grantees with overlapping service areas are encouraged to collaborate in establishing their subsidized rates.

102-477 Tribal Grantees: Program Instruction (PI) ACYF-PI-CC-99-01, dated January 19, 1999 states that Tribes consolidating their funds in a 102-477 plan may meet the § 98.43 (a) statutory requirement by certifying that payment rates for child care services are sufficient for families to access equal services compared to those families not supported by CCDF or other Federal, State, or Tribal program assistance. Therefore, a Market Rate Survey is not required for 102-477 tribal grantees.

Child Care Providers

Once the decision is made on the geographical area to be used in the Market Rate Survey, the Tribe needs to identify which child care providers will be surveyed. It is often difficult to identify child care providers within a certain geographical area. Identifying the child care providers for a Tribe can be even more complex. In some cases, it is impossible to identify all the home care providers in the market area, especially those who are unregulated by the Tribe or State. For some Tribes, the number of Child care providers in a particular category, such as the number of centers on a reservation, will be so small that it is impossible to calculate market rates based on the sample. For some Tribes, the federal subsidies plus the family fees are the only rates charged in the area so this is the market rate. Some general questions to be answered by the Tribe are:

• For what categories of child care do we need to know the market rate?
  • child care centers
  • family and/or group child care homes
  • in - home providers (relative care and non-relative)
  • preschools
  • all categories in one location
  • other - such as out-of-school care

• Is only regulated care going to be included in the survey? Or, is all the child care provided to Indian families unregulated? Or, will the survey include both regulated and unregulated child care?

• How does the Tribe know who the unregulated child care providers are?

• Will Head Start, public or BIA preschool programs or tribally subsidized programs be included in the survey? Generally, these providers do not charge any rates and are excluded from market rate surveys. However, if CCDF funds are used for combining services with these providers, they may be included. A separate survey instrument probably will be needed to collect specific information.

In areas where there are many child care providers, some Tribes may need to consider sampling the child care provider population. This can be a complicated research technique that may require some additional assistance.

Having investigated whether the State's survey area applies to the Tribe's population, determined the child care market area for CCDF -assisted Indian families, and decided which categories of child care providers need to be included in data collection, the Tribe now proceeds with gathering available information.

The next chapter explores the possibilities of getting data from other agencies and describes possible resources.

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