On January 7, the Administration for Children and Families (ACF) issued (ACYF-CB-PI-11-01), providing states and Indian Tribes with direction on requirements for integrating policy changes with the Title IV-E program into Statewide Automated Child Welfare Information Systems (SACWIS) systems. The document outlines the areas that a state must address prior to its SACWIS Assessment Review (SAR) to ensure ongoing SACWIS compliance. In the last two years, significant changes have been made in child welfare policy and financing. Through the passing of Fostering Connections to Success and Increasing Adoptions Act legislation in October 2008, states have had to explore how differently their systems of care for the child protection system might be. The legislation brought about changes such as the age a youth ages 19-21 can be claimed to Title IV-E, creating an entirely new entitlement program for guardians who care for Title IV-E eligible children, and the de-linking of Adoption Assistance and the former AFDC program. In addition, on April 6, 2010 the Children’s Bureau (CB) issued changes to the Child Welfare Policy Manual eliminating the federal requirements for re-determination of a child’s AFDC eligibility after the child is determined to be eligible at removal.
States responses to these changes have been mixed. Some states have jumped at the opportunity of extending the age limit for Title IV-E, while other states have backed away due to significant budget reductions and losses. Still other states continue to try and sort it through and obtain state legislative approval, if needed. The same is true of the kinship guardianship assistance program. Many states lobbied for years to have this included in Title IV-E reimbursability, yet have found it difficult to free up additional general revenue for match when the population is often funded through 100 percent federal dollars of TANF. There have been states that have moved forward with submitting state plan amendments and obtaining the authority from ACF to begin claiming Title IV-E for the guardianship assistance payments as soon as possible.
When CB eliminated the requirement for agencies to re-determine a child’s AFDC eligibility at specified intervals, states saw this as work reduction and welcomed it. Tracking and ensuring that children retained their Title IV-E eligibility related to a continuation of deprivation after the original removal was difficult for many states to achieve. This exclusion was recognized as a positive.
The Program Instruction reminding states of all these changes highlights that as states make these changes to the child welfare program, changes and modifications to the SACWIS are also critical. The essence of the document stresses that whatever policy changes the states incorporate into the state’s Title IV-E program, they must ensure that the SACWIS system is adapted to the policy changes. In 45 CFR 1355.53(b)(5) &(7) it describes as a key component of any federal SAR an evaluation of how well the state’s system has automated completion of federal requirements, as demonstrated in the agency’s policies.
Whether or not a state may claim funding for revisions and updates to the systems depends largely on what costs of development and operation were outlined and approved in the Advance Planning Document (APD). Costs for development for the system revisions are not automatically eligible. While states are required to develop functionality to support all the changes in policy and integrated into the system of care, without advance approval or an APD Update, states may have to assume full financial responsibility.
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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