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June 8, 2001

WYOMING TITLE IV-E
FOSTER CARE ELIGIBILITY REVIEW
April 1, 2000 - September 30, 2000

I. INTRODUCTION

During the week of May 7 through May 9, 2001, the Administration for Children and Families' (ACF) staff from the Regional and Central Offices and State of Wyoming staff conducted an eligibility review of Wyoming's Title IV-E foster care program in Cheyenne, Wyoming.

The purpose of the title IV-E foster care eligibility review was:

1. To determine if Wyoming was in compliance with the child and provider eligibility requirements as outlined in CFR 1356.71 and Section 472 of the Act.
2. To validate the bases of Wyoming's financial claims to assure that appropriate payments were made on behalf of eligible children and to eligible homes and institutions.

II. SCOPE OF THE REVIEW

The Wyoming Title IV-E foster care review encompassed a sample of all the title IV-E foster care cases that received a foster care maintenance payment during the period of April 1, 2000 to September 30, 2000. A computerized statistical sample of 80 cases was drawn from the Adoption and Foster Care Analysis and Reporting System (AFCARS) data, which was transmitted by the State agency to the Administration for Children and Families(ACF). Each child's case file was reviewed for the determination of title IV-E eligibility and each provider's file was reviewed to ensure that the foster home in which the child was placed was licensed for the period of the review. Eight cases were designated as over-sample cases to be used in the review if one of the initial sample cases did not receive a foster care maintenance payment.

The review results determined four cases 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. Since the number of error cases were less than nine, Wyoming is considered to be in substantial compliance.

The review team was made up of eighteen individuals: ACF Regional Office Staff included: Oneida Little, Marilyn Kennerson, Eric Busch, Gloria Montgomery. Lucille McCluney, Jennifer Butler Hembree and Christie Craig represented the ACF Central Office. The State team members included: Rick Robb, Jim Palmer, Stan Franek, Steve Vajda, Pauline Carpenter, Jo Lee Schuler, Heather Babbitt, Maureen Clifton, Dana Shireberg, Nicky Anderson and Sandra Stokes.

III. Case Record Summary

The following details the error cases and reasons for the error, erroneous dollars, and appropriate citations:

Case #1
Sample #3
Year - FFY 00
County - Carbon County
Error - Lapsed Provider license
Erroneous dollars (disallowance): $1,819.35
Citation: Section 472(c) (1) & (2)- Foster care payments are made for care of children in foster family homes, private child care institutions or public child care institutions accommodating no more than 25 children, which are licensed by the State in which they are situated or have been approved by the agency in such State having the responsibility for licensing or approving foster family homes or child care institutions.
Practice: Practices should be reviewed regarding lapses in foster home licensure and the foster care/adoption transition for the proper execution of adoption subsidy payments.

Case #2
Sample #29
County - Laramie
Error - Locked Residential Facility
Erroneous dollars (disallowance): $16,692.00
Citation: Section 472(c)(1) & (2) - Federal reimbursement is not available for children who are in detention facilities, forestry camps, training schools or any other facility operated primarily for the detention of delinquent children.
Practice: Practice should be reviewed regarding placement of children in locked facilities.

Case #3
Sample #10
County - Carbon County
Error - No Court Order to authorize foster care placement after adoption placement failed.
Erroneous dollars (disallowance): $ 8,667.13
Citation: Section 472(a)(1)- Payments are provided for each child- the removal from home was the result of a judicial determination to the effect that continuation therein would be contrary to the welfare of such child and that reasonable efforts have been made prior to the placement of each child in foster care, to prevent or eliminate the need for removal of the child from the home, and to make it possible for the child to return to his home.
Practice: Practice should reviewed regarding issuance of Court Orders authorizing foster placement when adoptions fail.

Case #4
Sample #11
County - Carbon
Error - No Court Order to authorize foster care placement after adoption placement failed.
Erroneous dollars (disallowance): $ 8,309.86
Citation: Section 472(a)(1)- Payments are provided for each child- the removal from home was the result of a judicial determination to the effect that continuation therein would be contrary to the welfare of such child and that reasonable efforts have been made prior to the placement of each child in foster care, to prevent or eliminate the need for removal of the child from the home, and to make it possible for the child to return to his home.
Practice: Practice should reviewed regarding issuance of Court Orders authorizing foster placement when adoptions fail.

IV. AREAS IN NEED OF IMPROVEMENT

Since Wyoming is in substantial compliance, these are observations and recommendations and therefore need not to be addressed in a Program Improvement Plan (PIP).

• It was noted that there should be no practice of joint custody between the State Agency and the placement agency. Court Order language should always state clearly that the State Agency has sole custody of the child.
• There should not be significant lapses in time between custody order and the placement of the child.
• Court Order language should be "child specific". Court Order documentation should also reflect the date of entry into foster care.
• All items for IV-E eligibility should be in place before certification is completed.
• Records should be organized in State's standardized format and provide clear documentation of the movement of children throughout placement. The lack of organization could result in child safety issues.
• New tabs need to be designed for foster care records.
• The State should review practices of claiming for title IV-E when placing juveniles in shelter care prior to foster care placement.

V. STRENGTHS AND MODEL PRACTICES

• The pre-conference discussions assisted in making the process clear for the state and for the Federal Review Team.
• The state is to be commended for its outstanding organization, which made the review process flow very smoothly.
• There was an attitude of "partnership" among the state and the federal workers. This provided for the sharing of varied expertise and a less intimidating experience for the state.
• Cheyenne County did a great job of organizing cases and should be modeled throughout the state.

VI. DISALLOWANCES

A disallowance is assessed for the total Federal Financial Participation (FFP) amount for the entire period of time that these cases were determined to be in error. Therefore, the total disallowance for the four error cases is $35,488.34.