Title IV-E

Quality Assurance and Accountability (QAA) QAA Team: Program Manager 2 Program Supervisors 5 Regional Teams Central – 5 Program Consultants Piedmont – 5 Program Consultants Northern – 5 Program Consultants Eastern – 4 Program Consultants Western – 4 Program Consultants

QAA Reviews The QAA team conducts two types of agency reviews to ensure proper use of IV-E funding Child Welfare Case Reviews Quarterly review of every agency Reviews all new foster care funding cases to ensure proper IV-E eligibility determination IV-E Ongoing Reviews Once a year for every agency Reviews all ongoing IV-E eligible youth for the agency Verifies proper use of IV-E funds for services provided

Child Welfare Case Reviews (CWCR) 10 CPS Referrals, 5 CPS Ongoing, 5 Foster Care Cases Eligibility Determination requirements: Required Judicial Language Contrary to the Welfare Reasonable Efforts to Prevent Removal AFDC Relatedness Income/Resources/Assistance Unit Removed from a Specified Relative Deprivation Citizenship or Qualified Alien Status Age

Ongoing Reviews IV-E Ongoing Requirements: Age Approved Placement SSI Payments Judicial Requirements: Annual Judicial Reviews Voluntary Placement Language Proper completion and documentation of IV-E payments Clothing Allowance VEMAT Child Care Transportation

OASIS Documentation and Agency Practice Child Information Eligibility Determination: IV-E vs CSA Placement Information Court Information Maintenance Rates Agency Practice Eligibility File All documentation is in file All documentation is in the correct section of the file

3rd Quarter FY IV-E CWCR Error Rates

FY20 Quarter Comparison

3rd Quarter FY IV-E Ongoing Error Rates

Total Errors vs Cases with an Error Total number of errors found State level, regional level, and agency level Number of cases with an error Federal Case Error Number of cases which had an error regardless of the amount of errors for that case Example: One case had three errors found: 2 ineligible payments and 1 safety requirement finding 3 total errors but only 1 Federal Case Error

2019 Federal Review On-side Review – September 23rd through the 27th, 2019 Period Under Review – October 1, 2018 through March 31, 2019. 80 cases randomly selected (20 oversample) The cases that are determined for the review are selected from the Adoption and Foster Care Analysis and Reporting System (AFCARS). Any case that had at least one IV-E foster care maintenance payment made during the PUR is eligible to be reviewed.

Substantial vs Non-Substantial Compliance During the primary review, out of the 80 cases reviewed the State is allowed up to four federal case errors. If five or more federal case errors are found during the primary review, the State will not be in substantial compliance State must develop a Program Improvement Plan (PIP) State will undergo a secondary review following the completion of the PIP.

Secondary Review 150 cases are pulled from a new Period Under Review State must not exceed the compliance threshold of more than 10 percent in both the federal case error rate and the dollar error rate. If not in compliance with a secondary review, a disallowance is assessed on the basis of the agency’s total foster care population for the 6 month PUR.

QAA Preparation for IV-E Review Meetings with federal government have begun Determine readers for the review Prepare and share all policy related to IV-E Final Sample List Immediately notify the agencies – request SPR information Coordinate a time for our QAA consultants to review case All cases will end up at CRO for the week of the review

Agency Preparation for Upcoming IV-E Every agency provided a list of their IV-E eligible youth during the PUR AFCARS Report for 10/01/18 – 03/31/19 OASIS based – IV-E eligibility indicator Completed internal IV-E review of cases Provided a review tool Fill out and return a certification that the agency read the cases Make necessary adjustments to any ineligible IV-E payments found Key areas of focus

Safety Requirements 4.10% of all cases were found to have a safety requirement error Checklist for provider approval and re-approval dates Inconsistent or inaccurate Pulling two resource home files during the review Verifying that the checks were completed and in the file Verifying the dates match the dates on the checklist Proper documentation for LCPA homes in eligibility file LCPA license Certificate of Approval of the home State Form Letter – CRC and Registry Checks

Emergency Approvals Youth can be temporality placed for up to 60 days. IV-E can begin the first day of the month in which all federal safety requirements are met: Fingerprint background results Central Registry verifications All requirements have to be met within the 60 day and the license of approval issued. Example: 60 day emergency approval 09/23/18 – 11/22/18 License of Approval begin date: 11/27/18 – 11/27/21 IV-E cannot pay from 11/23/18 – 11/26/18

Emergency Approvals Best Practice Emergency Approval for title IV-E Reporting Available on the Fusion IV-E website Needs to be completed and put in eligibility file

ICPC Foster Homes Forms 100 A and B should be in eligibility file These forms do not have information regarding background checks Home Study is not required to be in the eligibility file Should have the information regarding background checks QAA consultant will ask to see Home Study to verify checks If checks are not in the Home Study Agency will need to work with ICPC and the other state to get documentation of background checks

Safety Requirements Best Practice Good working relationship between resource home unit and eligibility unit Tracking each resource home to know when background checks are due Spreadsheets Shared Calendar Sharing these tracking tools with resource and eligibility staff creates another layer of internal quality control

Ongoing Review Errors Ineligible IV-E Expenditures Most common error found during ongoing reviews 18.74% of all cases reviewed had an ineligible IV-E expenditure No longer accepting corrections on site While this is the highest occurring error, this is the easiest error that can be addressed within the agency.

Supplemental Clothing Allowance Most common issue is the lack of documentation to support the purchase of clothing. Receipts need to be in eligibility file to support payment Shipping and handling is a non-reimbursable cost Shall not exceed the designated rate Regardless of IV-E, CSA, or combination of the two It should be used by May 31st of each year The date the bill is paid determines the fiscal year in which the payment is counted when it comes to fiscal year end

Supplemental Clothing Allowance Best Practice IV-E Quick Reference Guide: Internal Clothing Tracking Tool Ensure the agency does not go over Track which youth still has money available at the end of the fiscal year

December DYK - Definitions and Details: Title IV-E Allowable Costs Available on the Fusion IV-E website

Prorating Foster Care Rates Common errors when prorating: Paying the entire month or incorrect amount of days Rounding the daily rate to the incorrect amount Payments begin = date the child is placed in the home Payments end = date prior to the removal date of that home

Prorated Foster Care Rates IV-E Quick Reference Guide Available on the Fusion IV-E website under resources

January DYK – VEMAT Scores of 36 Common and costly VEMAT scores 28 or above must be reassessed every 3 months VEMAT score of 36 due solely to severe medical and physical needs can be assessed annually Physicians statement Detailing the child’s condition Statement that the condition is unlikely to improve Obtained within three months of the initial VEMAT Assessment score of 36 New statement must be obtained along with the next annual VEMAT Assessment

January DYK – VEMAT Scores of 36 If the agency does not receive the physician’s statement prior to the expiration date of the first VEMAT with the score of 36, then title IV-E funds should cease beginning the first day of the following month. Example: VEMAT effective 02/01/18 – 04/30/18 Physicians statement not obtained prior to 04/30/18 IV-E funds cannot be used beginning 05/01/18 If the agency receives a physician’s statement after the expiration of the VEMAT, title IV-E funds can be used again beginning the first day of the month following receipt of the statement for the remainder of the year of approval

VEMAT Broadcast and Form “VEMAT Administration with a Physician's Statement” 05/13/19 Broadcast

VEMAT Best Practice Excel spreadsheet of all VEMATs and due dates Shared calendar with all VEMAT due dates Eligibility workers can serve as a secondary level of internal quality assurance. Any questions on the quality of the physician’s statement should be sent to regional permanency consultant

Best Practice of Local Agencies Internal Reviews Benefit Specialist to conduct quarterly reviews of eligibility file and OASIS Identify areas in need of improvement and implement reviews Technical Assistance QAA Consultants Agency to agency collaboration Communication within the agency Services, benefits, finance, and resource home staff

Role of Finance Staff in IV-E Knowing which youth are IV-E eligible Access to OASIS Easily accessible database of IV-E eligible youth Knowing which payments can be paid from IV-E Knowing IV-E rules surrounding eligible payments Tracking of clothing allowances Communication Notice of Action

Updated IV-E Application/Evaluation Updated IV-E Application and Evaluation has been posted to Fusion An e-mail went out via our DYK distribution list with the application and description of changes

Title IV-E Training New IV-E Training is offered every month Each training should be posted to the Learning Center six months prior to training taking place Online IV-E modules are available on Learning Center and are prerequisites for the in class training

Contact Information Morgan Nelson – QAA Program Manager Morgan.nelson1@dss.Virginia.gov 804-726-7521 Matthew Lafrinere – QAA Program Supervisor Matthew.lafrinere@dss.Virginia.gov 804-351-6203