The Multi-Ethic Placement Act of 1994 (MEPA), as amended by the Interethnic Adoption Provisions of 1996 (MEPA-IEP), applies to any state or other entity that receives funds from the federal government and is involved in some aspect of adoptive or foster care placements. All state and county child welfare agencies involved in placements that receive federal Title IV-E and Title IV-B funds are subject to MEPA-IEP. The Act also applies to other public or private agencies involved in placements that receive federal funds from any source, whether they receive the funds directly or through a sub-grant from a state, county, or another agency.  Even if agencies do not claim Title IV-E but do receive federal funding through the Child Abuse Prevention and Training Act, Title IV-B and/or other federal dollars, MEPA – IEP regulations apply. 

MEPA violations could cause states to be penalized by up to five percent of the total Title IV-E funding received in a fiscal year.  The funding includes Title IV-E foster care payments, adoption assistance, administration and training claims, as well as Chafee Independent Living Grant funds. Key points to understand:

• While no specific criteria exist, violations will be determined on a case-by-case basis when an agency has delayed or denied a child’s adoptive or foster parent based on race, color, or national origin.
• Violations are restricted to a specific fiscal year. However, the lack of compliance in a subsequent year may continue the penalty for each year that the violation has not been resolved.
• Because a private international adoption agency does not receive Title IV-E funds,  MEPA regulations do not apply.  Private agencies must still meet requirements of Title VI of the Civil Rights Act of 1964, including provisions for delaying a foster care or adoption placement due to race, color, or national origin.

About Kay Casey

Kay Casey has over 20 years of experience in federal and state child welfare policy and programs, having worked for the federal Administration for Children and Families (ACF) and the Florida Department of Children and Families prior to joining PCG. She is responsible for the review and assessment of fiscal processing systems that impact a state’s ability to identify, document, and report expenditures for federal reporting purposes accompanied with the programmatic impact on the state’s system of care. Among her projects since joining PCG, Kay has managed fiscal monitoring of Florida’s privatization of child welfare services for allowability and compliance with federal guidelines,; served as Technical Advisor and Policy Reviewer for a Pennsylvania (PA) statewide quality control administration for Title IV-E compliance services for 67 PA counties; served as Business Project Manager for a PA SACWIS feasibility study; and provided ongoing technical assistance on federal policy changes as they impact the Commonwealth of Massachusetts, Department of Children and Families,and State of Indiana Department of Children Services.

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