1 Introduction

1.1 Purpose

The purpose of this document is to provide guidance to Federal and State personnel on conducting Statewide Automated Child Welfare Information System (SACWIS) Assessment Reviews.

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1.2 Background

The Department of Health and Human Services' (DHHS) Administration for Children and Families (ACF) provides national leadership and direction in planning, managing, and coordinating the administration and financing of a broad range of comprehensive and supportive programs for vulnerable children and families. These programs are, in large part, administered by public and private State and local agencies and are designed to promote stability, economic security, responsibility, and self-sufficiency.

For many years, concerns have been raised about the lack of information available on children in foster care and their families. To address some of these concerns, Congress amended title IV-E of the Social Security Act in 1986 by adding section 479 which requires the Federal government to institute a foster care and adoption data collection system. Federal regulations at 45 CFR 1355.40 (Code of Federal Regulations) set forth the requirements for the Adoption and Foster Care Analysis and Reporting System (AFCARS).

The Omnibus Budget Reconciliation Act of 1993 (OBRA 93) provided enhanced Federal financial participation (FFP) at the 75 percent rate (beginning October 1, 1993) for development of SACWIS systems to carry out the States' programs under title IV-E of the Social Security Act. In response, requirements for SACWIS were implemented under regulations at 45 CFR 1355.50. The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 extended the period of eligibility for the enhanced rate to September 30, 1997. Under these laws, enhanced funding was made available for the planning, design, development, and installation of statewide systems that meet the following standards.

1. The systems must meet the requirements imposed by regulations promulgated pursuant to section 479(b)(2) (AFCARS) of the Social Security Act.

2. The systems must, to the extent practicable, interface with the State data collection system that collects information relating to child abuse and neglect.

3. The systems must, to the extent practicable, interface with, and retrieve information from, the State data collection system that collects information relating to the eligibility of individuals under the title IV-A program.

4. The systems must be determined by the Secretary to improve program management and be likely to provide more efficient, economical, and effective administration of the programs carried out under a State's plans approved under title IV-B or IV-E of the Act.

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1.3 Reviews

States are encouraged to develop SACWIS systems. States electing to develop such systems with Federal financial participation (FFP) come under the existing Federal review and approval processes, initiated and updated by Advance Planning Documents (APDs) submitted to ACF. ACF has established the following types of reviews.

MONITORING REVIEWS: 45 CFR 95.621 requires that ACF continually review, assess, and inspect the planning, design, and operation of SACWIS systems to determine how such systems meet and continue to meet the requirements imposed in the law, regulations, and guidelines.

These reviews, conducted on an as-needed basis, assess the State's progress in developing the comprehensive statewide system described in the approved APD. During planning, development, and installation, these reviews are generally concerned with the overall progress, work performance, expenditure reports, system deliverables, security, and supporting documentation. ACF assesses the State's overall conformance with the approved APD and provides technical assistance and information sharing from other State projects.

ASSESSMENT REVIEWS: There are no specific certification requirements for SACWIS. Once a system is operational, ACF will conduct and report the results of a SACWIS Assessment Review (SAR). The purpose of these reviews is to ensure that all aspects of the project, as described in the approved APD, have been adequately completed, and conform to applicable regulations and policies. Either the State or ACF may initiate these reviews. However, ACF reserves the right to initiate a SACWIS Assessment Review at anytime in the life cycle of a system.

A SACWIS Assessment Review (SAR) is based on the requirements of law, implementing regulations, the SACWIS Action Transmittals (AT) and Program Instructions (PI), the State's approved APD, State contract documents, and any additional policy guidance or conditions provided to the State. Every effort will be made to reach mutually acceptable solutions to any identified issue. However, if this is not possible, the State may be subject to the remedies described at CFR 45 1355.56.

The timing and manner in which SACWIS reviews are conducted is based on available staff and resources; not all SARs will be conducted on-site nor will they necessarily be conducted at the time the system becomes operational. Therefore, States that use contractor assistance in the development of their system should not link final acceptance or payment to an ACF review. Instead, States are encouraged to base contractor payments on task-specific deliverables and system acceptance on demonstrations and system acceptance tests.

In preparation for a SAR, every effort will be made by ACF (considering resource availability) to conduct a technical assistance consultation with the State. This discussion should occur during or immediately after pilot implementation. The State and ACF will use this technical assistance consultation as an opportunity to estimate system conformance with SACWIS requirements, specify a time frame for resolution of obvious (i.e., highly visible) issues (if needed) and discuss when the SAR should be conducted.

Generally, ACF will not conduct the Assessment Review until, at a minimum, the following conditions are met:

30 percent of the total foster care and adoption caseloads (State and Federal) have been converted to, and are maintained under the fully functional SACWIS system; and

One (1) or more county/district offices are fully operational.

States should note that they MAY provide the information requested in the SACWIS Assessment Review Guide in an alternative form to the extent that the State already has it available.

AFCARS REVIEWS: The purpose of the AFCARS review is to assess States' information system's capability to accurately collect, extract and transmit the AFCARS data to ACF. The AFCARS review also assesses the State child welfare staff's ability to accurately collect and document the AFCARS information related to the foster care and/or adoption case of a child. The review process goes beyond the edit checks that must be met in order to pass the AFCARS compliance error standards. The review focuses on ascertaining a State's degree of compliance with all of the AFCARS requirements and the quality of its data. Therefore, AFCARS reviews have a separate and distinct purpose from SACWIS reviews and may be conducted before, during, or after a SAR.

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1.4 Authority and References

Title IV-E SARs are conducted under the authority of 45 CFR 1355.55, which requires that DHHS evaluate SACWIS system projects.

The following regulations and guidelines apply to the SAR process or are of related interest:

• Conditions for approval of funding in 45 CFR 1355.53;

• Action Transmittal (AT), ACF-OISM-001, Issued February -24, 1995 (referred to as the "SACWIS AT 001");

• Action Transmittal (AT), ACF-OSS-05, Issued August 21, 1998;

• AFCARS Regulations (45 CFR 1355.40), Policy Information Questions, Technical Bulletins and other policy guidance;

• Office of Management and Budget (OMB) Circular A-87, Cost Principles for State and Local Governments;

• Automated data processing services and acquisition procedures and requirements of 45 CFR Part 95, Subpart F;

• ACF's Information Systems Review Guide, Cost/Benefit Guide, and Companion Guide 2: Cost/Benefit Analysis Illustrated for Child Welfare Systems;

• SACWIS Conceptual Design, SACWIS Data Element Dictionary, SACWIS Integrated Data Set, and SACWIS Functional Requirements;

• NCANDS Detailed Case Data Component Guidelines and Procedures;

• ACF's review guides for programs that interface with SACWIS systems (e.g., the Automated Systems for Child Support Enforcement: A Guide for States); and

• Federal statues and regulations applicable to the programs administered through the State's SACWIS.

To obtain relevant policy documents, interested parties may access the information at the Children's Bureau's web page.

Information about SACWIS, AFCARS, and NCANDS is available at http://www.acf.hhs.gov/programs/cb/stats_research/index.htm#afcars

To obtain other relevant SACWIS related Action Transmittals, interested parties may contact the Division of State Systems in ACF's Children's Bureau or visit the Division of State Systems' Homepage at http://www.acf.hhs.gov/programs/cb/stats_research/index.htm#sacwis

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1.5 Assessment Review Process Summary

This Guide describes the SAR process and provides guidance and examples on completing the questions in appendices A, B, and C. A major component of the SACWIS review process is the self-assessment conducted by the State. As a result of its self-assessment, the State will be in a position to describe fully and accurately its system through its responses in the Guide. The Guide can be broken out by section or even by question, so that the responsibility for completing the Guide may be separated into smaller components and sent to the appropriate staff for completion.

The Guide sets forth the specific areas of the review and is divided into three parts, which can be found in Appendices A, B, & C. The three parts of the Guide are the Overview, Process, and New Initiatives Sections.

The Overview Section describes the general characteristics of the SACWIS system, including the objectives, applications, and architecture. It provides general identifying information that will help other States and ACF understand the overall size, cost, and programmatic functionality of the system.

The Process Section describes the SACWIS system's conformance with mandatory program requirements derived from statute and regulation. The questions in this section are derived from the SACWIS Action Transmittal (AT) No. ACF-OISM-001, dated February 24, 1995. The Section numbering conforms to the AT. Sequential numbering has been added to the Guide for ease of use. ACF relies on the sequential numbering to reference areas of the document in discussions with the State.

The New Initiatives Section describes how the system supports new Federal and State initiatives. SACWIS systems are expected to be comprehensive child welfare case management tools and need to be enhanced as program requirements change.

The review is normally initiated when a State submits an electronic copy of the Guide and supporting documentation to the ACF Central and Regional Offices. An electronic version of the Guide serves as the means of documenting the review, providing the State with the Federal review team's findings and producing a final report. ACF is able to provide an electronic copy of the original document in the following formats: Microsoft (MS) Word, or as an electronic rich text file (*.rtf). ACF prefers to receive the completed document as an MS Word file. If this format is not available, the document may be returned to ACF as an electronic rich text file.

After the documentation is evaluated, ACF will conduct the review either on-site (at the State offices) or off-site (by telephone conference calls). The State completed Guide is used by ACF to record comments, issues, resolution dates and negotiated action plans. Based on these comments, the State may update the Guide before finalization of the report.

The SAR Process is described in Chapter 2, while Chapter 3 provides instructions for completing the different parts of the Guide. Additional guidance may be requested from ACF's Central and Regional Offices, ACF systems staff will be available to work with the State through the entire review process.

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