Draft CCWIS IV-E FCMP Eligibility Self-Assessment Tool - Final Draft

CCWIS Self-Assessment Tool Title IV-E Foster Care Maintenance Eligibility

OMB # 0970-0568

Expiration Date: 04/30/2024

Title IV-E Foster Care Maintenance Payment Eligibility

Self-Assessment Tool v1.0

Introduction

Title IV-E of the Social Security Act (the Act) allows states, territories, and tribes to claim partial federal reimbursement for the cost of providing foster care payments on behalf of children who meet federal eligibility criteria. Foster care maintenance payments (FCMPs) are payments to cover the cost of providing food, clothing, shelter, daily supervision, school supplies, a child’s personal incidentals, liability insurance, reasonable travel to the child’s home for visitation, and reasonable travel for the child to remain in the school in which the child is enrolled at the time of placement. With institutional care, payments include the reasonable costs of administration and operation of such institution as are required to provide the items described.¹

Collecting and maintaining FCMP eligibility data in the CCWIS enables the title IV-E agency to efficiently, economically, and effectively make accurate eligibility determinations, service and payment authorizations, and expenditures.² Automating eligibility determinations reduces errors, eliminates the need for duplicate data entry, promotes consistency, and may allow the agency to maximize title IV-E revenue for eligible activities and expenditures.

Title IV-E agencies with a CCWIS must use eligibility data to generate or contribute to required IV-E federal reports and support state or tribal child welfare laws, regulations, policies, practices, reporting requirements, audits, and reviews that support programs and services described in the Act.³ The title IV-E Foster Care Maintenance Eligibility Self-Assessment Tool will help agencies assess whether the CCWIS complies with these requirements to collect, maintain, and report title IV-E FCMP eligibility data and provides useful resources and additional considerations.

Tool Format

This self-assessment tool is divided into sections as outlined on the chart below. Unique Element #s are assigned to every question for reference. Please refer to the instructions in Technical Bulletin #7 or contact your federal analyst if you have questions about the tool or a specific element.

Section	Element #
Overview	F.A.xx
Self-Assessment – Part 1 – Program Goals	F.B1.xx
Self-Assessment – Part 2 – Foundational Requirements	F.B2.xx
Resources and Additional Considerations	F.Cx.xx

A title IV-E agency may use this self-assessment tool to collect information describing the CCWIS’s eligibility functions and the users and external systems associated with these functions. Agencies may cross-reference information if it is already contained in another self-assessment tool, APD, or project artifact. If a question is not applicable to the eligibility function, indicate “NA” and provide the reason it is not applicable.

F.A.01 Date this assessment was completed.

F.A.02 Brief description of the module, its status (such as planning, development, production, operational), and target completion date. If needed, attach or reference artifacts. Examples of artifacts include APDs, project plans, and responses provided in other CCWIS self-assessment tools.

F.A.03 If applicable, list the position(s) of users who enter the title IV-E FCMP eligibility information for youth served by tribal nations and other public entities that have agreements with the state to operate part of the state’s title IV-E program.

F.A.04 Does the CCWIS automate or track title IV-E eligibility for FCMP for youth co-involved with child welfare and juvenile justice?

F.A.05 Are eligibility functions for FCMPs accessed by users who are not employees of the title IV-E agency (or counties in a county-administered system), such as private providers under contract with the title IV-E agency, including Child Welfare Contributing Agencies (CWCAs)? If so, please identify external user groups that have access to this function. Please add more rows, as needed.

User Group	Purpose of Use

F.A.06 Do title IV-E agency staff or external users currently use or plan to use any system(s) external to the CCWIS to collect FCMP eligibility information or identity verification used in this function, such as financial or county-based accounting systems and other state systems such as vital statistics, child support enforcement, Temporary Assistance for Needy Families (TANF), or Supplemental Nutrition Assistance Program (SNAP)? If so, what external systems are used and what data from those systems are shared with the CCWIS? External systems can include commercial off-the-shelf (COTS) products, publicly available portals, and applications for mobile devices. Please add more rows, as needed.

External System	Data Shared

F.A.07 Are there any additional comments you would like to provide as background to this function?

Part 1 – Program Goals

The Program Goals section of this self-assessment tool describes the critical program needs CCWIS must support, as defined at 45 CFR § 1355.52(a) and (b)(1)(ii). These program needs apply whether staff enter data directly into the CCWIS or data are imported through an exchange. Agencies should continually assess changing policy and practice needs to ensure CCWIS aligns with program priorities and remains relevant to support program outcomes. The goals noted below are required by policy or federal law or are common foster care maintenance payment program needs.

In this section, the title IV-E agency may document components, factors, and design elements of the function(s) or exchanges that support the program goals of the FCMP eligibility function. We encourage agencies to simplify their responses by referencing submitted documentation, such as APDs, or attach screenshots, system documentation, training materials, survey data, self-assessment tools, and agency policy or procedures. To ensure the CCWIS is supporting program goals, engagement with end users during all stages of the system development life cycle is critical. Likewise, continuous user feedback is often important to ensure the system responds to program changes after implementation.

In the Evidence the Module & Exchanges Support the Program Goal column, include information such as:

• how the CCWIS supports agency policies and practices;

• feedback from end users;

• how the module was designed to be user friendly and streamline work;

• data CCWIS maintains to support the goal;

• reports CCWIS provides; and

• components, factors, and design elements of the function(s), or exchanges, that support the goal.

If the title IV-E agency has additional program goals, please include them below and add new rows, as needed.

If a question is not applicable to the eligibility function, indicate “NA” and explain why it is not applicable. For example, other functions in the CCWIS may address the program goals.

#	Program Goal	Evidence the Module & Exchanges Support the Program Goal
F.B1.01	Provide consistent, timely, and accurate information to support the agency’s title IV-E FCMP eligibility determinations and related business practice and policy.
F.B1.02	Ensure title IV-E FCMP eligibility information is accurately collected and maintained.
F.B1.03	Support the issuance of foster care maintenance payments made on behalf of an eligible child.
F.B1.04	Ensure information on the ongoing title IV-E FCMP eligibility requirements is accurately collected and maintained. Such information may include timely judicial determinations, placement changes, or other circumstances that impact a child’s eligibility for FCMP.
F.B1.05	Ensure other modules are integrated with the title IV-E FCMP eligibility module. For example, ensure the CCWIS automatically updates title IV-E FCMP eligibility status to reflect changes to placement, provider, and/or caretaker information. This may also include ICPC, adoption support, and/or kinship guardianship functions.
F.B1.06	Link the child’s historical title IV-E FCMP data to the child’s current case and provide an audit trail of activities to determine the child’s eligibility for FCMP.

Part 2 – Foundational Requirements

Foundational requirements identify the conditions that must be met to comply with CCWIS project, data, and reporting requirements at 45 CFR § 1355.52. These apply whether staff enter data directly into the CCWIS or data are imported through an exchange.

In this section, the title IV-E agency may document components, factors, and design elements of the function(s) or exchange(s) that support CCWIS foundational requirements. We encourage agencies to simplify their responses by referencing submitted documentation, such as APDs, or attach screenshots, system documentation, training materials, survey data, self-assessment tools, and agency policy or procedures.

In the Evidence the Module & Exchanges Support the Foundational Requirement column, include information such as:

• feedback from end users;

• how the module was designed to be user-friendly and streamline work;

• data the CCWIS maintains;

• reports the CCWIS generates or contributes to;

• user-interface features; and

• automated processes and other design features.

If a question is not applicable to the eligibility function, indicate “NA” and explain why it is not applicable. For example, other functions in the CCWIS may address the relevant foundational requirements.

#	Foundational Requirement	Evidence the Module & Exchanges Support the Foundational Requirement
F.B2.01	Include all data elements necessary to support an agency’s determination of a child’s title IV-E eligibility and ongoing FCMP eligibility requirements.
F.B2.02	The CCWIS is used to determine a child’s title IV-E FCMP eligibility for accurate federal reimbursement.
F.B2.03	Data to support state and federal audits, plans, reviews, reports, and other monitoring activities, including title IV-E FCMP eligibility reviews is maintained in the CCWIS.
F.B2.04	Data, such as title IV-E FCMP eligibility determination, is not created by default or inappropriately assigned.
F.B2.05	Appropriate users can review, validate, and correct title IV-E FCMP eligibility data. See the Administration and Security Self-Assessment Tools for goals related to access and security controls.
F.B2.06	Automation exists to ensure that title IV-E FCMP eligibility calculations, including related Aid to Families with Dependent Children (AFDC) calculations, are consistently and accurately applied in every eligibility determination.
F.B2.07	State only: The same automated function or the same group of unduplicated automated functions are used for all title IV-E FCMP eligibility determinations. Tribal only: To the extent practicable, the same automated function or the same group of unduplicated automated functions are used for all title IV-E FCMP eligibility determinations.
F.B2.08	The CCWIS supports automated FCMP eligibility determinations for young adults age 18-21 returning to foster care, if allowed by the title IV-E agency.
F.B2.09	Data must be exchanged and maintained according to confidentiality requirements in section 471(a)(8) of the Social Security Act (the Act), 45 CFR 205.50, and 42 U.S.C. 5106a(b)(2)(B)(viii) through (x) of CAPTA, if applicable, and other applicable federal and state or tribal laws.

The Functional Process Factors and Additional Considerations below are examples, not an exhaustive list of functional requirements, that title IV-E agencies may consider in developing a title IV-E FCMP function. Title IV-E agencies are encouraged to collect data required to support child welfare program outcomes, needs of respective users, and CCWIS and program regulations. If the agency is including these functional process factors and additional considerations in the CCWIS, please write “Yes” in the “Included in Agency’s CCWIS?” column.

Resource 1 – Functional Process Factors

Resource 2 – Additional Considerations

Resource 1 – Functional Process Factors

Functional process factors identify useful processes to achieve an efficient, economical, and effective CCWIS, as defined at 45 CFR § 1355.52. The regulations do not require a title IV-E agency to have all the functional process factors listed below in the CCWIS. Function descriptions are based on historical perspectives and typical program needs gathered from previous reviews to promote the successful execution of eligibility program goals. The functional process factors will evolve, and title IV-E agencies may, as needed, include additional factors. Title IV-E agencies are encouraged to assess local program needs, federal and agency policies, and user-centric design as they develop, maintain, and enhance the CCWIS eligibility functions to support positive program outcomes.

#	Included in Agency’s CCWIS?	Functional Process Factors
F.C1.01		The system automatically generates alerts, notifications, and reports of key eligibility milestones and missing information.
F.C1.02		The system contains limits for edits and data overrides. Internal system controls are in place to allow auditable edits and overrides when necessary and supported by agency policy.
F.C1.03		Using the data retrieved from an automated exchange with courts, the system notifies the appropriate users of upcoming court dates to ensure that ongoing IV-E FCMP eligibility timeframes are met.
F.C1.04		The system carries data forward to other functions to support: Licensing and background safety checks Placement Financial reconciliation and payments
F.C1.05		The system automates the sharing and collection of information from external systems to help determine IV-E eligibility (e.g., title IV-D, title XIX, TANF, labor, vital statistics).

Resource 2 – Additional Considerations

The Additional Considerations section describes useful features agencies may wish to incorporate into the CCWIS design/features.

#	Included in Agency’s CCWIS?	Additional Consideration
F.C2.01		The system automatically assesses ongoing FCMP eligibility at regular intervals to support the judicial determination of reasonable efforts to finalize the permanency plan.
F.C2.02		The system tracks both title IV-E and non-federal FCMP.
F.C2.03		A search results filter provides quick access to history to support FCMP eligibility determinations and federal, state, or tribal title IV-E reviews.
F.C2.04		A data exchange with the juvenile justice agency supports dually involved youth to meet eligibility requirements when a title IV-E eligible youth enters or leaves a detention facility.
F.C2.05		A data exchange with tribal agencies serving title IV-E eligible children exists through a title IV-E agreement with the state.
F.C2.06		The system collects information to create and maintain voluntary placement agreements.

We encourage agencies to add examples of additional considerations from their eligibility function they wish to highlight.

#	Agency-Submitted Additional Considerations

1 Section 475(4) of the Act.

2 45 CFR § 1355.52(b)(1)(ii).

3 45 CFR § 1355.52(c).

PAPERWORK REDUCTION ACT OF 1995 (Pub. L. 104-13) STATEMENT OF PUBLIC BURDEN: Through this information collection, the Administration for Children and Families (ACF) is collecting information to document that title IV-E agencies have planned and developed their system’s conformity to federal CCWIS and Advance Planning Document requirements. Public reporting burden for this collection of information is estimated to average 10 hours per title IV-E agency choosing to develop and implement a CCWIS system, including the time for reviewing instructions, gathering and maintaining the data needed, and reviewing the collection of information. This is a voluntary collection of information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information subject to the requirements of the Paperwork Reduction Act of 1995, unless it displays a currently valid OMB control number. The OMB # is 0970-0568 and the expiration date is 04/30/2024.