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During the week of August 28, 2000 - September 1, 2000, Administration for Children and Families' (ACF) staff from the Regional and Central Offices and State Federal Policy Unit staff conducted an eligibility review of Arizona's Title IV-E foster care program.
The purpose of the Title IV-E eligibility review was to validate the accuracy of Arizona's financial claims to assure that appropriate payments were made on behalf of eligible children, to eligible homes and institutions, at allowable rates.
The Arizona Title IV-E foster care review, which was conducted in Phoenix, encompassed all Title IV-E foster care cases during the period from October 1, 1999 to March 31, 2000. A computerized statistical sample of 88 cases (80 cases and 8 over sample cases) was drawn from the Adoption and Foster Care Analysis and Reporting System (AFCARS) data which was transmitted by the State Agency to ACF. The sampling frame consisted of cases of individual children who received at least one Title IV-E foster care maintenance payment during the six -month period noted above. For each case, the child's case file was reviewed for the determination of Title IV-E eligibility and to ensure that the foster home in which the child was placed was licensed for the period of the review.
During this initial primary review, 80 cases were reviewed. The team determined that 74 cases were eligible for Title IV-E and six (6) cases were ineligible for Title IV-E. For a State to be determined to be in substantial conformity on an initial primary review, no more than eight (8) cases can be found in error. As a result, Arizona has been determined to be in substantial conformity for the initial primary review. Therefore, no secondary review will be required and the only financial penalty to be taken will be for the payments on the six (6) ineligible cases amounting to the total value of $186,062 and the Federal Financial Participation (FFP) is $122,171.
Below is a brief summary of the findings for each of the six (6) ineligible cases.
Sample number 14: Child was placed by juvenile justice. Temporary order did not provide a judicial determination that the continuation in the home would be contrary to the child's welfare and reasonable efforts were provided to prevent removal or to reunify child and family (sections 472(a)(1) and 471(a)(15)(B)(i) of the Social Security Act).
Sample number 20: Child was placed with an unlicensed provider (sections 471(a)(10) 472(a)(3), (b) and (c) of the Social Security Act).
Sample number 49: Child was placed by juvenile justice. There was no judicial determination that the continuation in the home would be contrary to the child's welfare (section 472(a)(1) of the Social Security Act).
Sample number 60: Child is over age 18 and is not in a secondary school or its equivalent (section 402(a)(2)(A) & (B) of the Social Security Act).
Sample number 61: No documentation that the provider was licensed for the entire time of the child's placement (sections 471(a)(10) 472(a)(3), (b) and (c) of the Social Security Act).
Sample number 72: AFDC eligibility cannot be made on an illegal alien child (section 472(a)(4) of the Social Security Act).
There are several areas that we saw as strengths and/or as best practices. They are as follow:
Judicial determinations that the State Agency provided reasonable efforts to prevent removal or reunify the child with the family were completed in less than 60 days in the cases reviewed and individualized efforts were reflected in the court orders (checklist element number 13).
In some of the cases reviewed, the State is already meeting the new requirement regarding judicial determinations be made on the reasonable efforts of the State Agency in achieving the permanency plan within 12 months of the date the child is considered to have entered foster care, effective March 27, 2000 (checklist element numbers 17 and 18).
The State's 90-day time frame on voluntary placement agreements reflects Arizona's efforts to expedite permanency for children in out-of-home care in a timely manner. The Federal standard for a voluntary placement agreement is no more than 180 calendar days and if it is still in the best interest of the child to remain in foster care, there must be a judicial determination before the 181st day (checklist element number 16).
The State has written procedures and a system in place to ensure that institutions are meeting the safety requirements (checklist element number 36).
In the area of AFDC eligibility determinations (checklist numbers 19 - 25), there was a yellow form number 230A used to document eligibility, but unfortunately its use has been discontinued. This form was useful because it documented financial resources and deprivation factors used to determine eligibility. Perhaps a screen providing similar information can be incorporated into the CHILDS system.
Four main areas were identified for improvement and these were discussed during the exit conference.
1. AFDC Linkage
2. Licensing and Safety
3. Court Orders
4. Voluntary Placements
The review included a sample of 80 cases. It was determined that 74 cases were eligible for Title IV-E and six (6) cases were ineligible. The financial penalty for the six (6) ineligible case payments amounts to the total value of $186,062. The Federal Financial Participation (FFP) is $122,171. See attachment 1 for the financial details on the six (6) ineligible cases.
Based upon the results of the review, Arizona did not exceed the 10 percent error rate. Arizona has been determined to be in substantial conformity and will undergo another primary review in three years.