Under the Child Care and Development Block Grant Act (CCDBG), families are eligible for child care subsidies only if their assets do not exceed $1 million, as self-certified by the applicant. However, federal statute or regulations do not further specify which assets should be included or excluded when applying this limit, leaving states to make these determinations. As a result, approaches to defining and assessing countable assets vary widely across states, leading to inconsistency in both policy and implementation.

Current guidance from the Administration for Children and Families (ACF) recommends including assets such as cash, bank accounts, vehicles, investments, and real estate (i.e., properties that can be sold), while excluding a family’s primary residence, primary vehicle, and personal belongings such as furniture (see photo). Because this guidance is not codified in federal statute or regulation, states lack clear and consistent direction on what asset information to collect from families and how to apply it in determining eligibility. In practice, these inconsistencies can lead to requirements that stray from ACF’s guidance. For example, Idaho requires applicants to report all household resources, including homes and vehicles, contrary to ACF recommendations to exclude these assets. Massachusetts requires families to certify that total household assets—including real estate, vehicles, equipment, jewelry, and livestock—do not exceed $1 million, and Rhode Island asks applicants to report details about vehicle ownership.

Transparency for applicants is also uneven. Some states provide detailed explanations of countable assets in subsidy flyers (like Washington), under the eligibility section of their website (like New Jersey), or in publicly accessible program memos (like Vermont). In others, this information is difficult to find in family-facing materials and may appear only in a single application question asking applicants to certify that their assets fall below $1 million, often without clarifying what qualifies as an asset. This lack of clarity can create confusion for families. 

Despite these challenges, recent policy discussions have focused less on clarifying asset definitions and more on lowering the overall asset threshold. In 2026, draft legislation has been shared at the federal level and a bill moved in Idaho (which ultimately failed) that would reduce the asset limit from $1 million to $500,000. Lowering the asset threshold to $500,000 could disproportionately harm low-income families—particularly those in high cost-of-living areas, rural families who own farmland, and those in communities with rising home values—where non-liquid assets, especially housing, may make families appear asset-rich despite having incomes low enough to qualify for child care subsidies. 

This concern is especially relevant given current housing market conditions across the country. According to Redfin Monthly Housing Data from May 2025, there are 16 states with median home prices over $500,000 (listed in the chart below). In these states, families may exceed a lower asset threshold due to home values alone, despite having incomes low enough to qualify for child care subsidies. Similar challenges may arise for families in rural areas who own farmland or for those in rapidly appreciating housing markets. 

This variation underscores the need for clearer federal standards to ensure consistent, transparent, and equitable implementation of asset limits across states. Rather than lowering the asset threshold, policymakers should prioritize codifying clear asset exclusions in federal statute or regulation, such as a family’s primary residence, primary vehicle, and personal belongings, to ensure these assets are not counted toward eligibility limits. Establishing these standards is an easy fix that would promote greater consistency across states and prevent families with non-liquid assets from being inaccurately deemed ineligible for child care subsidies. 

Family Home Prices and Child Care Subsidy Asset Test Questions