ACYF-CB-IM-09-02

ACF Administration for Children and Families	U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES Administration on Children, Youth and Families
	1. Log No.: ACYF-CB-IM-09-02	2. Issuance Date: July 10, 2009
	3. Originating Office: Children's Bureau
	4. Key Words: Indian Tribes; Tribal Organizations; Title IV-E; Fostering Connections to Success and Increasing Adoptions Act of 2008; Automated Child Welfare Information Systems

INFORMATION MEMORANDUM

To: Federally recognized Indian Tribes, Tribal Organizations and Consortia (Tribes)

Subject: NEW LEGISLATION – Fostering Connections to Success and Increasing Adoptions Act of 2008 (Public Law (P.L.) 110-351); automation requirements and options for Tribes operating a title IV-E program pursuant to section 479B of the Social Security Act

Legal and Related References: P.L. 110-351; title IV-E of the Social Security Act (Act) section 479B of the Act; 45 CFR 1355; Program Instruction ACYF-CB-PI-08-05; Information Memorandum ACYF-CB-IM-08-03.

Purpose: This Information Memorandum (IM) provides information to Tribes that are considering operating a title IV-E program pursuant to section 479B of the Act and explores the implementation of an automated child welfare information system as allowed under P.L. 110-351. The IM identifies core components Tribes should consider in a basic child welfare information system supporting Tribal child welfare business practices that are described in a title IV-E Tribal plan. It is intended to provide basic introductory information. As noted later in the IM, more detailed information on child welfare information systems is available on the Children's Bureau (CB) website.

The IM is not intended to: 1) identify all the possible components which encompass a comprehensive child welfare information system; or 2) provide information on how the Statewide Automated Child Welfare Information System (SACWIS)¹. model can be implemented by Tribes.

Information: The President signed P.L. 110-351 into law on October 7, 2008. The law provides Tribes operating a title IV-B subpart 1 program with the option, beginning October 1, 2009, to apply to operate a title IV-E program and seek Federal reimbursement of a share of allowable Tribal expenditures made pursuant to a title IV-E plan approved by the Secretary. Allowable Tribal expenditures include costs of a data collection system to administer child welfare activities under an approved title IV-E plan.

Required data submissions for Tribes with an approved title IV-E plan

Tribes operating a title IV-E program pursuant to an approved title IV-E plan must comply with the Adoption and Foster Care Analysis and Reporting System (AFCARS) reporting requirements.² AFCARS data must be transmitted to CB following prescribed transmission protocols established by the Administration for Children and Families (see ACYF-CB- IM-08-03).

Optional automation for Tribes with an approved title IV-E plan

There are many advantages to supporting child welfare programs with automation. An automated information system can support efficient, economical and effective operations; provide decision support tools; aid workers and supervisors; enable administrators to monitor and manage programs; and serve as a rich data source for program analysis and research. Because of these advantages, CB encourages Tribes to consider automated systems more extensive than that needed to only support required Federal reporting.

When considering automation approaches, CB encourages Tribes to develop and/or select systems appropriate to their needs. To assist Tribes in an evaluation of needed functionality, CB provides the following four categories of child welfare activities commonly supported by current automated child welfare systems.

Note: Tribes are not required to implement any or all of the four categories described below. Tribes may supplement the list with additional activities. The list is offered as a starting point for Tribes to consider as they evaluate alternatives for implementing automated information systems to support their child welfare practice. Because child welfare terminology varies among agencies and organizations, each category includes a brief description of the related activities. These descriptions are provided as examples to clarify the terminology and are not an endorsement of any child welfare practice model. Each description is followed by examples of related child welfare processes currently automated in other jurisdictions.

1. Child abuse and neglect intake/referrals
A report of possible child abuse/neglect is usually the initiating event in a child welfare case. A neighbor, family member, teacher, doctor, or other concerned party will contact the child welfare agency to report observations or an incident of possible abuse/neglect.

Processes frequently automated
Agencies log when the report was received and record information such as the child's demographics and location, the alleged perpetrator's identity, incident details, and the reporter's name and available contact information. Agencies search historical records to determine whether: 1) the child, family, or alleged perpetrator is known to the agency; 2) there have been previous allegations of abuse/neglect; or 3) any of the individuals have been involved in a previous case. The compiled information is evaluated and a determination made as to whether the report merits investigation or assessment. Workers record or the system calculates dates of all activities and decisions to document the expeditious handling of the report.

2. Abuse/neglect investigations and risk assessment
If the agency determines that the allegation(s) of child abuse/neglect merit investigation, an investigator is dispatched to explore the allegation(s). Often the severity and credibility of the intake report will determine how promptly an investigation must begin. Staff will meet with the child, family, and other persons involved in, or with knowledge of, the allegations, evaluate the child's current condition, determine if the child's environment is safe, and assess risks to the child's health, safety, and wellbeing.

Processes frequently automated
Staff document findings of the reported allegation(s). During the investigation if previously unreported incidents of abuse/neglect are discovered, they are documented. Workers document all investigation contacts, interviews, and the dates these activities occurred. The initial intake report is supplemented with the information gathered in the course of the investigation. In addition, other agency (ices) records (and other records, such as law enforcement databases) are searched for information having a bearing on the investigation.

Child welfare agencies often automate risk assessment tools or processes to support the assessment of the child and family on a range of risk factors. The computer will either present the information in an organized manner, or tally the results and report if the child is at low/medium/high risk of abuse or neglect. Usually, the automated child welfare information system also collects the information gathered during the investigation in a narrative format.

The investigator's conclusions/decisions can also be documented in the automated system. Conclusions can range broadly across a continuum that includes unfounded or unsubstantiated allegations, substantiated allegations, the child is safe, the child/family require services in the home, and the child's health, safety, and well-being necessitate removal from the home.

3. Child welfare case management
The findings arising from the abuse/neglect investigation and risk assessment process often determine if a child welfare case is opened. Workers managing a case will develop case plans and establish goals for the child and family members based on investigation/assessment results, the expressed needs and desires of the child and family, court directives, and other agency assessments. Case plans will be developed for services provided to children maintained in their own home, in foster care, being considered for adoption, receiving independent living services, or transferred to another jurisdiction. Services (which may include out of home placement) will be offered to address needs and to help children and families reach defined goals. Workers, supervisors, case reviewers, and courts will monitor children, families and services and review/modify case plans as needed to meet changing circumstances and goals.

Processes frequently automated
Workers document the details of the case plan, such as participants, needs, services, and goals. Workers record contacts with children, families, and other parties. Workers recommend services that are approved/authorized by supervisors, or the workers may directly authorize services. Service provision is tracked. Details on children, including out of home placement, health, special needs and education, are documented. The case plan is periodically reviewed and updated to reflect case activities and changing circumstances, goals or objectives, new assessments, and service strategies.

A Tribe that is considering implementing a system should remember that case documentation is sometimes used to inform court proceedings and may need to meet certain legal standards of admissibility for this purpose. For example, in order for a case note to meet legal standards of admissibility, it may be necessary to include an audit trail of any modifications made to the original note.

4. Financial management
The child welfare budget must be monitored and controlled. All costs must be managed so that the child welfare agency can ensure continuous, needed operations and that staff and resources are available and allocated as intended in order to provide adequate, timely, and appropriate services to vulnerable children and families.

Processes frequently automated
All financial transactions arising from serving children and families are tracked including placements, on-going services, and special one-time payments made on behalf of children. Budgets must be established. Payments are authorized and funds disbursed from the correct funding sources (e.g., various Federal funding sources, local funding sources, grants, etc.) and placement and service contracts managed. Title IV-E eligibility determination may be calculated or recorded. Payment histories (including information on payees and clients, approvals, costs, and transaction numbers) may be maintained and audited. Accounting and financial controls should be in place. Documentation should support CB review of title IV-E claiming, including reports, history and an audit trail f title IV-E eligibility and reimbursement determinations.

Evaluating if automation is beneficial
CB encourages Tribes to evaluate the benefits of automating child welfare activities beyond what is needed to submit required Federal reports. Tribes may consider automating some or all of the activities listed above. Tribes may also consider automating other activities not listed above.³

When evaluating automation strategies, Tribes should analyze multiple alternatives, determine the feasibility of each approach, and conduct a cost/benefit analysis of the feasible alternatives before undertaking an automation project.

Inquiries: HHS – Director, Division of State Systems, Children's Bureau, Administration for Children, Youth and Families, Administration for Children and Families

/s/

Maiso L. Bryant
Acting Commissioner
Adminstration on Children, Youth and Families

¹45 CFR 1355.53 provides the regulatory definition of a SACWIS. back
²Federal reporting requirements not discussed in the IM include the Quarterly Report of Expenditures and Estimates (Form ACF-IV-E-1), other title IV-E and IV-B formula grant reports, and the title IV-B Child and Family Services Plan including the Annual Progress and Services Report. back
³Please see Action Transmittal (AT) ACF-OISM-001, Issued February 24, 1995, "Part IV - SACWIS Functional Requirements and General Program and Systems" for a listing of functions that comprise a comprehensive child welfare case management system. The AT is available at the CB website at http://www.acf.hhs.gov/programs/cb/laws_policies/policy/at/at9501.htm. back