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Appendix IX

Model Report

(Appropriate State) Title IV-E Foster Care
Eligibility Review
(Date of AFCARS Review Period)

Introduction

During (enter appropriate time frame), Administration for Children and Families' (ACF) staff from the Central and Regional Offices and State of (enter the name of the State) staff conducted an eligibility review of (enter the name of the State)'s title IV E foster care program in (enter the name of the city).

The purpose of the title IV-E foster care eligibility review was (1) to determine if (enter the name of the State) was in compliance with the child and provider eligibility requirements as outlined in 45 CFR §1356.71 and §472 of the Social Security Act; and (2) to validate the basis of (enter the name of the State)'s financial claims to ensure that appropriate payments were made on behalf of eligible children and to eligible homes and institutions.

For a secondary review, the following language is suggested:

This secondary review was conducted because of the findings of the primary review that was completed during the week of (enter date). At that time, (enter State) was determined not to be in substantial compliance with the title IV-E eligibility requirements for the period under review. As required, (enter State) submitted a Program Improvement Plan (PIP) to correct the areas found deficient in its eligibility program for foster care. The ACF's approval of the PIP was based on the State's reports of progress and final implementation of the planned improvements. (A brief synopsis of the PIP goals and activities may be included).

Scope of the Review

The (enter the name of the State) title IV E foster care eligibility review encompassed a sample of all of the title IV E foster care cases that received a foster care maintenance payment during the period of (enter date) to (enter date). A computerized statistical sample of (enter number) cases was drawn from the Adoption and Foster Care Analysis and Reporting System (AFCARS) data submission which was transmitted by the State agency to the ACF for the period under review. The child's case file was reviewed for the determination of title IV E eligibility and the provider's file was reviewed to ensure that the foster home or childcare institution in which the child was placed was licensed or approved for the period of the review.

For a primary review, the following language is suggested:

During the primary review, (enter number) cases were reviewed. (enter number) cases were determined to be in error for either part or all of the review period for reasons that are identified in the Case Record Summary section of this report.

Use the language in either number 1 or 2 below, as appropriate to the review results:

  1. Since the number of error cases was fewer than five, the ACF has determined (enter the name of the State) to be in substantial compliance.

  2. Since the number of error cases exceeded four, the ACF has determined (enter State) not to be in substantial compliance. Pursuant to 45 CFR �1356.71(i), you are required to develop a Program Improvement Plan (PIP) designed to correct those areas determined not to be in substantial compliance. The PIP will be developed by the State, in consultation with ACF Regional Office staff, and must be submitted to the ACF Regional Office by (enter date that is 90 days from date of cover letter). Once the State agency has satisfactorily completed the PIP, a secondary review of a sample of 150 title IV-E foster care cases will be conducted.

For a secondary review, the following language is suggested:

During the secondary review, (enter number) cases were reviewed. (enter number) cases were determined to be in error for either part or all of the review period for reasons that are identified in the Case Record Summary section of this report. The dollar value of the sample was $(enter dollar amount) with the error cases totaling $(enter dollar amount). These data indicate that (enter the name of the State)'s dollar error rate (enter percent) was (enter "less than/equal to" or "greater than") 10 percent and/or the error cases error rate (enter percent) was (enter "less than/equal to" or "greater than") 10 percent. Therefore, (enter the name of the State) is considered (enter "to be in" or "not to be in") substantial compliance.

For non-error cases with ineligible payments discovered during a review, the following language is suggested:

An additional (enter number) cases were identified that contained payments that were claimed improperly. Although these cases are not considered "error cases" for determining substantial compliance, (primary review only) the ineligible maintenance payments and the associated administrative costs are subject to disallowance. A disallowance in the amount of $(enter amount) in maintenance payments and $(enter amount) in administrative costs are assessed for these ineligible payments.

Case Record Summary

The following details the error cases and non-error cases with ineligible payments, reasons for the ineligibility, ineligible payments, and appropriate citations: (List the sample number, describe the errors, and note the citation of the requirement found to be improperly applied for the period of ineligibility. A separate listing of the non-error cases with ineligible payments as well as a separate listing for the underpayments identified should be included below the data listed for the error cases):

Sample number 27: Voluntarily placed child did not have a judicial determination within 180 days of placement. 42 USC §672(e).

The erroneous maintenance payments (Main.) and administrative costs (Admin.) associated with the (enter number of cases) error cases were calculated as follows, and include all payments claimed on behalf of the child for the entire period of the error. (Indicate the error case(s), all payments claimed for the entire period of the error for each case, Federal Medical Assistance Payment [FMAP] rate, and Federal Financial Participation [FFP]. Note that a State's FMAP rate may vary annually and, therefore, needs to be obtained for each year that a case is found to be in error.)

Sample # XX XY XZ Total Main. FMAP FFP Main. FFP Admin. Total Disallow.
FFY 94     1,635.71 1,635.71 70.92% 1,160.05 1,411.05 2,571.10
FFY 95     3,224.95 3,224.95 70.14% 2,261.98 1,261.98 3,523.96
FFY 96 2,378.88   3,067.01 5,445.89 68.78% 3,745.68 1,745.68 5,491.36
FFY 97 5,450.00   3,975.73 9,425.73 67.97% 6,406.67 3,406.67 9,813.34
FFY 98 5,324.00   4,326.36 9,650.36 69.59% 6,715.69 5,715.69 12,431.38
FFY 99 2,868.00 32,915.29 3,557.87 39,341.16 69.85% 27,479.80 17,479.80 44,959.60
FFY 00 3,182.67 11,336.69 3,263.55 17,782.91 70.15% 12,474.71 9,474.711 21,949.42
Total 19,203.55 44,251.98 23,051.18 86,506.71   60,244.58 40,495.58 100,740.16


Areas in Need of Improvement

Describe the areas of weakness or deficiency that need to be addressed in the PIP.

Strengths and Model Practices

Describe strengths or model practices discovered during the review.

Disallowances (if necessary)

Use language appropriate to the type of review and disallowance criteria pursuant to 45 CFR §1356.71(j).

For the primary review, the following language is suggested:

The review included a sample of (enter number) cases. The sample was drawn from a universe of cases that received at least one title IV-E foster care maintenance payment during the 6-month AFCARS period of (enter date) to (enter date). Based upon the results of the review, the State of (enter name) has been determined (enter "to be" or "to be not") in substantial compliance. (The report should end here if no cases were determined to be in error.) (enter number) cases were determined not to be eligible for funding under title IV-E foster care. Therefore, a disallowance in the amount of $(enter dollar amount) in Federal Financial Participation (FFP) is assessed for the entire period of time that these cases were determined to be in error.

For the secondary review, use the suggested language in either 1 or 2 below, as appropriate to the review results:

  1. State in substantial compliance: The review included a sample of (enter number) cases with a total dollar value of $(enter dollar amount). The sample was drawn from a universe of cases that received at least one title IV-E foster care maintenance payment during the 6-month AFCARS period of (enter date) to (enter date). Based on the results of the review, the State of (enter the name of the State) has been found to be in substantial compliance; (the report should end here if no cases were determined to be in error) however, (enter number) cases were determined to be in error and are not eligible for funding under title IV-E foster care. Therefore, a disallowance in the amount of $(enter dollar amount) in Federal financial participation (FFP) is assessed for the entire period of time that these cases were determined to be in error.

  2. State not in substantial compliance: The review included a sample of (enter number) cases with a total dollar value of $(enter dollar amount). The sample was drawn from a universe of cases that received at least one title IV-E foster care maintenance payment during the 6-month AFCARS period of (enter date) to (enter date). Based upon the results of the review, the State of (name) has been found not to be in substantial compliance since (enter number) cases were not eligible for funding under title IV-E foster care and the case and dollar error rates both exceeded 10 percent. We have projected the results of the review over the universe from which the sample was drawn and have determined that $(enter dollar amount) in title IV-E funds were inappropriately claimed as foster care maintenance payments. In addition, the related share of administrative dollars of $(enter dollar amount) is disallowed. Therefore, the total disallowance is $(enter dollar amount) in Federal financial participation (FFP).