On December 9, 2011, the Administration for Children and Families (ACF) released Program Instructions (ACYF-CB-PI-11-09) on changes to the Title IV-E state plan as part of Public Law 112-34. The Child and Family Services Improvement and Innovation Act of 2011 amends case plan and case review system requirements and the Adoption Assistance Program reinvestment requirements and requires Title IV-E state plan changes. States were provided with a state plan pre-print that must be completed by January 31, 2012, but the changes have an effective date back to October 1, 2011.
The case plan and case review system requires that child welfare agencies must now meet the educational stability case plan requirement each time a child's placement changes, not just at the initial placement into foster care. The educational stability plan was the original requirement under the Fostering Connections to Success and Increase Adoptions Act of 2008, which required the plan only at the time of placement. This revision will be an onerous requirement when children move from one placement to another frequently.
An additional requirement for case plans and case reviews is credit reports for youth in foster care. Public Law 112-34 calls for each child 16 years of age and older in the state's foster care system be provided a consumer credit report each year until discharged from foster care. The law requires that each report be interpreted to the child to identify and correct any discrepancies.
Title IV-E agencies and youth in foster care may find helpful information about understanding credit reports on the Federal Trade Commission webpage here.
The Program Instruction also addressed the requirement for documentation of any savings generated from switching general revenue funded adoption assistance subsidies to Title IV-E Adoption Assistance related to the delinking of eligibility of children in adoption assistance from the 1996 Aid to Families with Dependent Children (AFDC) policy and financial needs standards. As a result of Public Law 110-351 - "Fostering Connections to Success and Increase Adoptions Act of 2008" child protection agencies must spend savings generated on child welfare services that may be provided under Titles IV-B and IV-E. Under a prior policy instruction (ACYF-CB-PI-09-08) state agencies are required to provide a certification that this requirement is met in the Title IV-E state plan. In ACYF-CB-PI-10-11, ACF clarified that the title IV-E agency has flexibility to determine the methodology for calculating savings.
