COVID-19 has placed additional pressure on already overloaded child welfare systems, including the difficulties of managing remote casework, increased service and funding needs, and administrative challenges. Given current staffing reassignments and shortages during this crisis, several child welfare agencies have asked whether the federal government will allow any streamlining in IV-E claiming, the process states use to request federal reimbursement for eligible children.
While HHS does not have the authority to waive any of the statutory requirements for determining and claiming federal reimbursement to states under the federal Title IV-E program, the Children’s Bureau has temporarily suspended IV-E Eligibility Reviews to allow child welfare agencies to focus on mission critical work during the difficult period.
Title IV-E, which refers to a specific title of the Social Security Act, is the largest source of federal child welfare funding to the states. To ensure that states are claiming proper levels of reimbursement for IV-E, the Children’s Bureau of the federal Department of Health and Human Services (HHS) conducts periodic IV-E Eligibility Reviews to ensure state compliance with federal law. These on-site accountability reviews are time-consuming for both states and the federal government, requiring a systematic evaluation that includes a representative sampling of case records for children and the accompanying provider and payment documentation.
Title IV-E eligibility standards are statutory requirements and cannot be waived unless Congress decides to change current law. That means that, even in times of crisis, child welfare agencies are required to document allowable expenses and keep careful records on each case. The federal government does, however, have the authority to suspend on-site Title IV-E eligibility reviews to free-up critical agency personnel who would otherwise be preparing for and staffing the review process.
The Children’s Bureau recently released guidance to the states that it will be postponing all IV-E Eligibility Reviews and related preparation activities for the “foreseeable future” to protect the health and well-being of prospective reviewers and to “ensure that the resources of child welfare agencies remain focused on mission critical work serving children and families.” The guidance further specified that the Children’s Bureau will continue to monitor health conditions and reschedule the reviews when it is safe to do so and will provide states with sufficient notice to prepare for the rescheduled reviews.
Title IV-E Foster Care Eligibility Reviews Fact Sheet (Children’s Bureau, March 2012)
Title IV-E Foster Care Eligibility Review Guide (Children’s Bureau, December 2012)
Child Welfare: A Detailed Overview of Program Eligibility (Congressional Research Service, October 2012)
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