Connecticut Title IV-E Foster Care Eligibility Review

Connecticut Title IV-E Foster Care Eligibility Review
Review Period 10/1/2005 - 3/31/2006

Introduction

During the week of June 5, 2006, staff from the Regional and Central Offices of the Administration for Children and Families (ACF) and Connecticut's Department of Children and Families (DCF) conducted a subsequent primary eligibility review of the State's title IV E Federal foster care program. The review was carried out at the central office of the Department of Children and Families located in Hartford, Connecticut.

The purpose of the title IV-E foster care eligibility review was (1) to determine if Connecticut 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 Connecticut's financial claims to ensure that appropriate payments were made on behalf of eligible children and to eligible homes and institutions.

Scope of the Review

The Connecticut 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 October 1, 2005 through March 31, 2006. A computerized statistical sample of 80 cases and an over-sample of 20 cases were 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 had undergone the required criminal records and/or safety checks and was fully licensed or approved for the period under the review (PUR).

During this subsequent primary review, 80 cases were reviewed. Four cases were determined to be in error for either part or all of the review period and five cases were determined to be non-error cases with improper payments. An error case is defined as a case which received a title IV-E payment during a period of ineligibility found during the PUR. A non-error case is defined as an otherwise eligible case which received a title IV-E payment during a period of ineligibility found outside of the PUR. As noted in the Case Record Summary section of this report, the total Maintenance and Administrative costs recommended for disallowance for these nine cases is $214,655 (FFP). However, only error cases are considered in determining whether a State exceeds the threshold set for subsequent primary reviews. Because the number of error cases in Connecticut was fewer than the threshold of five, the ACF has determined the State to be in substantial compliance with the title IV-E Federal foster care program eligibility requirements. Thus, the next primary review will not be conducted until Federal Fiscal Year 2009.

Strengths and Model Practices

Overall, DCF and the Courts have significantly improved the content and timeliness of the court order sanctioning the removal of the child from his/her home. All of the cases reviewed were found to have the required judicial determinations of "Contrary to the Welfare of the Child" to remain at home, "Reasonable Efforts to Prevent Placement," and "Reasonable Efforts to Finalize the Permanency Plan."
As required for title IV-E eligibility determinations of children removed from home and placed into foster care, the State has continued to strengthen their system for determining and documenting financial need and deprivation of parental support according to the State's July 16, 1996 guidelines for Aid to Dependent Children (AFDC). However, DCF still uses a labor intensive, manual process for determining AFDC eligibility. We understand that the State is making efforts to automate this process and encourage the State to continue to do so.
The criminal records check requirements for Connecticut have been strengthened to include finger printing and NCIC clearance in addition to State and local clearances. However, the lack of timeliness in obtaining the results of these checks may be putting some children at risk and/or delaying the claiming of otherwise title IV-E eligible children.

Areas in Need of Improvement

Six cases had issues with the lack of and/or untimely criminal records/safety checks (one error case and five non-error cases with improper claiming.) As noted above, the primary factor contributing to these issues is the amount of time required to fingerprint a prospective foster parent(s) and to receive a response from NCIC. In one case, we noted that this process took over a year to complete.

It is our understanding that the State is considering the purchase of portable fingerprinting apparatus that would allow foster and pre-adoptive parents to be fingerprinted in local child welfare offices near their home. In addition, this system has the capability to electronically send and expeditiously receive the results of the NCIC criminal records checks.

We encourage Connecticut DCF to pursue this approach to not only better ensure the safety of children placed in out-of-home care but to also to ensure timely claiming of FFP for otherwise eligible title IV-E children.

Case Record Summary

The following details the error cases and non-error cases with improper payments, reasons for ineligibility, ineligible periods and amount for each ineligible claim. The FMAP rate for determining the disallowance is 50% for all fiscal years.

Error Cases
Sample #	Case ID	Reason*	Period	Disallowance Main.	(FFP) Admin.
8	174894	1	10/1/05-3/31/06	$3,020	$531
28	182607	2	9/8/95-3/31/06	$126,812	$34,163
30	178759	3	3/30/04-3/31/06	$10,204	$11,367
71	314049	1	9/1/05-11/30/05	$404	$0
Sub-Total				$140,440	$46,061

Non-Error Cases
Sample #	Case ID	Reason*	Period	Disallowance Main.	(FFP) Admin.
27	205778	3	8/4/05-8/30/05	$1,901	$531
34	1188626	3	12/22/04-7/31/05	$4,029	$3,610
41	1081315	3	10/6/04-10/31/04	$336	$516
42	1318479	1 & 3	6/29/04-9/30/05	$7,723	$7,715
76	701310	3	6/30/05-8/30/05	$762	$1,031
Sub-Total				$14,751	$13,403
Total				$155,191	$59,464

* Ineligible Codes for Error and Non-Error Cases

Provider not fully licensed according to requirements found at 45CFR1355.20 (a)(2).
Child not living with and removed from same "Specified Relative" according to the requirements found at 45CFR1356.21(k) and (l).
Criminal Records Checks and/or safety checks of provider not completed according to requirements found at 45CFR1356.30.

Disallowances

Pursuant to 45 CFR §1356.71(j), a total disallowance in the amount of $214,655 in Federal Financial Participation (FFP) is assessed for ineligible payments claimed for error and non-error cases.

The erroneous maintenance payments and administrative costs associated with the four error cases ($186,501 FFP) include all payments claimed on behalf of the child for the entire period of time that each case was determined ineligible for title IV-E payments. No future claims should be submitted on these error cases until it has been determined that all eligibility requirements are met.

An additional five cases were identified that contained payments that were claimed improperly. Although these cases are not considered "error cases" for determining substantial compliance, the ineligible maintenance payments and associated administrative costs ($28,154 FFP) are also subject to disallowance.