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

Federal Title IV-E Reviews Periodic and systematic review of title IV-E foster care programs are conducted by the Children’s Bureau. Ensure federal funds are expended for intended purposes Recover improper expenditures Reviews are conducted by a team of federal and state agency representatives. Reviews provide a snapshot of decisions about a child’s foster care episode and, thus, the agency’s child welfare practice and fiscal accountability.

Federal Title IV-E Reviews Reviews monitor substantial compliance with requirements pertaining to: Judicial determinations regarding reasonable efforts and contrary to the welfare Voluntary placement agreements Responsibility for placement and care vested with the State. Children's’ eligibility AFDC Child’s placement in a licensed foster home or child care institution Safety requirements are met IV-E expenditures

Primary Review Process On-site review during a 5 day period Review team examines case records including: Placement history Payment history Court orders Provider licensing Safety documentation Review team completes a Title IV-E Foster Care Eligibility On-Site Review Instruments for each case.

Period Under Review (PUR) 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. 80 cases will be randomly selected from the PUR to be reviewed during the on-site primary review. 20 additional cases are pulled as oversamples

Substantial Compliance During the primary review, out of the 80 cases reviewed the State is allowed up to four federal case errors. A federal case error is a finding of a case to not be IV-E eligible or a finding of an ineligible IV-E payment made during the PUR If one case has multiple errors, it still counts as only 1 federal case error. A finding of four or fewer federal case errors means that the State is found in substantial compliance. If found in substantial compliance, the next review will be in three years.

Not in Substantial Compliance If five or more federal case errors are found during the primary review, the State will not be in substantial compliance Beyond payment back any ineligible payments found during the review, the state could also face a larger financial disallowance State must develop a Program Improvement Plan (PIP) Correct areas of noncompliance Improve performance on future reviews Strengthen overall operation 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.

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 Each agency has an equal chance to have a case selected

2019 Review Preparation Effective July 1, 2018, the error rate for shared fiscal accountability for title IV-E foster care was reduced to 0%. QAA consultants continue to conduct quarterly reviews for all new funding cases validations as well as completing a 100% review of all ongoing IV-E foster care cases. QAA team will conduct thorough reviews on all 80 cases selected for the review. Case files needed at the time of review include: Eligibility File Services File Resource Home File

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

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

Ongoing Review Reporting Thorough breakdown of ongoing reviews for FY 18 was published on Fusion “4th Quarter and FY 2018 IV-E State and Local Outcomes” Broken down by State, Region, and Agency Report Details: Types of errors found on the report Number of each type of error Total number of errors found Total number of cases with an error Federal error percentage

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

Federal Error Percentage Number of cases with an error (Federal Case Error) divided by the total number of cases reviewed Provides a percentage of cases which had at least one error found on the ongoing reviews

Ongoing Review Errors Ineligible IV-E Expenditures Most common error found during ongoing reviews 11.11% of all cases reviewed had an ineligible IV-E expenditure Pro rating the maintenance payment based on placement dates Untimely VEMAT Missing documentation for clothing expenditures Missing documentation for transportation expenses No longer accepting corrections on site Agency can provide any missing documentation while on site but the finding will remain on the report as an error. While this is the highest occurring error, this is the easiest error that can be addressed within the agency.

Ongoing Review Errors Safety Requirements 1.62% 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 Background checks are able to kept in the eligibility file Good working relationship between resource home unit and eligibility unit Tracking each resource home to know when background checks are due

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

CWCR Reporting Quarterly Reporting Continuous Quality Improvement Posted to the Fusion website Shows the number of cases reviews and total number of errors found for each region. Continuous Quality Improvement Mirror the ongoing report Provide more extensive breakdown of the errors found Provide the Federal Case Error rate Identify trends and areas needing improvement for correct determinations of IV-E eligibility

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

Common Findings: Agency Practice and OASIS OASIS Documentation Missing or incorrect funding determination Incorrect placement dates Missing or incorrect court information Agency Practice Missing Notice of Action Missing placement agreements File not maintained based on the Standard File Format “IV-E Case File Sections” available on Fusion

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

Title IV-E Training New IV-E Training is offered every month except for May and November Each region conducts two trainings a year 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

Title IV-E Training Schedule October 2018 - Northern November 2018 - Empty December 2018 - Eastern January 2019: Piedmont February 2019: Central March 2019: Western April 2019: Northern

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 Dawn Burtner – QAA Program Supervisor Dawn.keister1@dss.Virginia.gov 804-418-9175