In the release of the Office of the Inspector General’s (OIG) work plan for FY2011, the focus on human services programs includes one audit for the Administration of Aging, and some 22 audits of Administration for Children and Families (ACF) programs. As American Recovery and Reinvestment Act (ARRA) funds are expiring, a renewed focus on many ACF programs appears to be emerging.  Many of the 2011 audits are new, while others are continuing. The OIG will continue with audits concerning: 1) Foster care and Adoption Assistance Training Costs and Administration Costs, 2) Adoption Assistance Subsidies, 2) Foster Care Claims for the Placement of Delinquent Children, 3) Foster Children Over 19 Years Old, 4) Licensing Standards and Health and Safety Monitoring at Child Care Facilities, and 5) Head Start Grantees’ Progress Toward Meeting New Teacher Credentialing Requirements.   Each of these areas under review has been part of the OIG’s work plans in 2009 and 2010 and the OIG cites ongoing work due to problems found in reporting and claiming of federal reimbursement.

For the Federal Fiscal Year 2011, the OIG is undertaking a broader and more focused look at many of the Title IV-E funding areas that will impact many of our clients.  The new areas to be reviewed include:

1. Oversight of System Design of Statewide Automated Child Welfare Information Systems -  audit will review the level of ACF oversight and guidance to states provided, as well as the costs appropriately claimed by states at the 50 percent FFP.
2. Administrative Costs Charged to the Foster Care Program by One County Probation Department and 
3. Training Costs Charged to the Foster Care Program by One County Probation Department – will examine the costs collected and reported as allowable costs of a State’s county probation department.  Preliminary work in this area has identified unallowable costs claimed as Title IV-E that did not correlate with the federal regulations identified in 45 CFR 1356.60 (c ) (2) and (b) (1).
4. Foster Care Per Diem Rates - the intention of this review will be to determine the costs included in a per diem rate set by a state agency to ensure that it is consistent with Title IV-E regulations   as well as the administrative costs that might be associated with the per diem. 
5. Costs Billed by Child Placing Agencies, Group Home and Foster Family Agency Rate Classification – the OIG intends to examine one State’s foster care payments for group homes and /or foster family agency treatment programs.  45 CFR 1356.60 (a) (1) (i) requires that states must review the payments to ensure continued appropriateness. The review will examine whether the state established the rate by classifying each group home program and applying the standardized schedule of rates. 
6. Foster Care Placement Candidacy Costs – the work plan calls for a review in several states to ensure that States are appropriately claiming administrative costs for allowable pre-placement activities, and that a determination of the child as a candidate for foster care has been documented.
7. Foster Care Program Collection and Reporting of Child Support Payments – 45 CFR 302.52 requires that State’s collections of child support payments for children in foster care be used to offset foster care program costs.  State agencies are required to report identifying information for children in foster care to CSE agencies.  The OIG plans to determine if prompt and accurate reporting is occurring, if reconciliation occurs between reports and offsets, and identify the causes of discrepancies.
8. Monitoring the Health and Safety of Foster Children --  The review will include examining foster children case files to ensure that workers are monitoring foster care placements to ensure the health and safety of children.  Every child in out of home care are required to have case plan and for it to be reviewed no less than every 6 months.  This review will focus on a state’s timely review of foster children’s case plan. The degree to which OIG will be successful in fulfilling the 2011 work plan is questionable, as it is extremely expansive.  However, the areas identified that relate to a state’s Title IV-E funding have been issues that have emerged recently through state audits and ongoing reviews by ACF. OIG’s 2011 work plan is hitting many of the topics that PCG has already been discussing with states.

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.

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