Chapter I: Introduction: State Guide to an AFCARS Assessment Review

Chapter I: Introduction

A. Overview

States are required by Federal law and regulation to collect data on children in foster care and those who have been adopted under the auspices of the State child welfare agency. The Federal information system that collects and processes this data is known as the Adoption and Foster Care Analysis and Reporting System (AFCARS). States that fail to meet any of the standards set forth in 45 CFR 1355.40(a-d) are considered not to be in substantial compliance (i.e., are lacking in substantial conformity) with the requirements of the title IV-E State plan, and are subject to penalties¹ .

The Department of Health and Human Services' (HHS) Administration for Children and Families (ACF) provides national leadership and direction in planning, managing, and coordinating the administration and financing of a broad range of comprehensive and supportive programs for children and families, including child welfare programs. These programs are, in large part, carried out by State and local agencies. ACF retains responsibility to monitor and evaluate the programs to ensure that they are being operated as intended by law and regulation. This includes the assessment of the automated information systems operated by State child welfare agencies that support the programs under titles IV-B and IV-E of the Social Security Act, and the collection of relevant data.

The Children's Bureau is committed to assisting States efforts to collect quality adoption and foster care data. To this end, the AFCARS Assessment Review (AAR) was developed to assure the accuracy and reliability of the foster care and adoption data. The State's information system is assessed against the AFCARS requirements in the Federal regulation, policy issuances, and the AFCARS Technical Bulletins. The AAR evaluates a State's information system's capability to collect, extract, and transmit the AFCARS data accurately to the ACF. A second focus of the AAR is to assess the accuracy of the collection and documentation of information related to the foster care and/or adoption case of a child.

The Children's Bureau has produced the State Guide to an AFCARS Assessment Review to provide guidance to State child welfare program and system staff regarding the AAR process. The Children's Bureau continues to evaluate and improve the review process. As such, this is the third edition of the Guide and revisions in it are based on the Children's Bureau's experience conducting AFCARS Assessment Reviews since the Guide was first issued in April 2002. The State Guide to an AFCARS Assessment Review (the Guide) provides information on:

the AFCARS Assessment Review process;
how to request an AFCARS Assessment Review;
how to prepare for the on-site review; and
completing the AFCARS Improvement Plan, if applicable.

Additionally, the Guide ensures that the same criteria are applied equally to all States, that Federal AFCARS Assessment Reviews are conducted in a consistent manner, and that they are well-documented and substantiated.

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B. Audience

The Guide is intended to assist State agency staff to prepare, plan, and participate in the AFCARS Assessment Review. State agency staff that are involved with the assessment review include both systems and program staff. Additionally, individuals that are representing other divisions or agencies during the AAR may also find the information in this Guide helpful.

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C. Background

1. Adoption and Foster Care Analysis and Reporting System (AFCARS)

AFCARS was created, in part, due to concerns raised about the lack of national information available on children in foster care, their families, the types of foster care settings, and adopted children. In 1986, Congress amended title IV E of the Social Security Act (the Act) by adding section 479, which requires the Federal government to institute a foster care and adoption data collection system. In response to the law, requirements for States to report adoption and foster care data to a Federal system were implemented under Federal regulations at 45 CFR 1355.40. The AFCARS collects case level information on all children in foster care for whom the State child welfare agency has responsibility for placement, care, or supervision and on children who are adopted under the auspices of the State's public child welfare agency.

ACF uses AFCARS data for a number of reasons, including:

responding to Congressional requests for current data on children in foster care or those who have been adopted;
responding to questions and requests from other Federal departments and agencies, including the General Accounting Office (GAO), the Office of Management and Budget (OMB), the DHHS Office of Inspector General (OIG), national advocacy organizations, States, and other interested organizations;
short and long-term budget projections;
trend analyses and short and long-term planning;
targeting areas for greater or potential technical assistance efforts, for discretionary service grants, research and evaluation, and regulatory change; and
determining and assessing outcomes for children and families.

Additionally, the AFCARS data are used specifically in the:

Adoption Incentives Program;
Child Welfare Outcomes Report;
Child and Family Services Reviews (CFSR);
Title IV-E Eligibility Reviews; and
Allotment of funds in the Chafee Foster Care Independence Program (CFCIP).

States are required to submit AFCARS data semi-annually to ACF in accordance with 45 CFR 1355.40² . These data submissions are subject to a minimal number of edit checks, as listed in Appendix E of 45 CFR 1355. These edit checks are only able to determine substantial compliance for:

the timely submission of the data files;
the timeliness of data entry of certain data elements; and
whether the data meets a 90% level of tolerance for missing data and internal consistency.

As such, these edit checks are an important first step to ensuring the collection of quality data. However, substantial compliance with these edit checks neither informs ACF as to whether or not a State's information system satisfies all Federal regulatory requirements, nor demonstrates the State is submitting accurate and reliable data to ACF. This explains why in the past a State may have been penalty free yet still needed to improve its AFCARS data for accuracy, reliability, and quality. For example, the edit checks cannot assess the AFCARS data files to determine whether the State submitted data on the correct foster care population for the correct time period required by the regulations. Also, the edit checks cannot determine if the State has correctly collected the necessary data and mapped it to the appropriate AFCARS values.

2. Statewide Automated Child Welfare Information System (SACWIS)

In December 1993, ACF published regulations at 45 CFR 1355.50-56 implementing section 474(a)(3)(C) and (D) (42 U.S.C. 674(a)(3)(C) and (D)) of title IV-E of the Act. Section 474(a)(3)(C) (now revised) provided enhanced Federal financial participation (FFP) at the 75 percent match rate for Federal fiscal years (FFY) 1994 1996³ for planning, design, development, or installation of SACWIS to support the States' programs under titles IV-B and IV-E of the Act. Additionally, section 474(c) (42 USC 674(c)) of the Act indicates that States do not have to allocate expenditures between title IV-E and non-title IV-E clients for SACWIS-related costs.

The Federal regulations at 45 CFR 1355.53 provide the conditions for approval of funding for a SACWIS. As a condition of funding, the SACWIS must be designed, developed (or an existing system enhanced), and when implemented, produce a comprehensive, effective, and efficient system to improve the program management and administration of the State plans for titles IV-B and IV-E. At a minimum, the system must provide for effective management, tracking, and reporting by providing automated procedures and processes to, among other things, meet the adoption and foster care reporting requirements through the collection, maintenance, integrity checking, and electronic transmission of the data elements specified by the AFCARS requirements mandated under section 479(b) of the Act and 45 CFR 1355.40. As a result, States that receive FFP to develop a SACWIS must not collect and maintain the AFCARS data in a separate automated information system after the SACWIS is operational. A State found out of compliance with 45 CFR 1355.53(b)(1) by the use, or continued use, of an external system in addition to the use of SACWIS can lead to a final finding of non-compliance with the SACWIS functional requirements, and may result in a disallowance of some of the Federal incentive funds used by the State to develop its SACWIS.

Since SACWIS is intended to support a variety of child welfare programmatic purposes, it should be considered to serve as the official case file and as such, contain all the same type of information that would have been generated by the agency and kept in the paper record. This does not mean that documents that are generated by agencies outside of the child welfare agency must be stored in the SACWIS. These documents will be part of a hard copy record. However, information that is entered over time by caseworkers should be maintained in the system and not overwritten by new occurrences. This allows the State to evaluate the status of a case at any point in time based on information that was known at that time.

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D. Information System Reviews

The Children's Bureau conducts separate assessment reviews to evaluate the development, implementation, and operations of SACWIS and AFCARS.

The SACWIS Assessment Review (SAR), conducted by the Children's Bureau's Division of State Systems (DSS), focuses solely on operational statewide automated child welfare systems for which States have received SACWIS-level FFP. DSS assesses a State agency's SACWIS for its compliance with Federal statutory and regulatory requirements, as well as functional, technical, and operational specifications approved in a State's Advance Planning Document (APD).

As part of this review, DSS identifies whether or not the State is using the SACWIS to collect and submit the AFCARS data. Once a State has an operational automated system identified as a SACWIS, or its case management module is operational, ACF expects that the State's system be used to collect and submit the AFCARS data. If an AFCARS data file has not been submitted by the time of the review, DSS assesses the State's system's capability to submit it. Additionally, DSS transmits any on-site State questions and findings regarding AFCARS to the Children's Bureau's AFCARS project leader who will follow up with the State.

The AFCARS Assessment Review (AAR) is a comprehensive evaluation of the State's automated information system which collects, extracts, and submits AFCARS data, and assesses the accuracy of data collected in accordance with the definitions of the data elements. This is done by verifying the State information system's capability to collect, extract, and transmit the AFCARS data accurately to ACF. Additionally, the AAR provides assurance to the Children's Bureau that the data being collected are reliable and consistent across all States. The AAR process goes beyond the edit checks that must be met in order to pass the AFCARS compliance error standards. The AAR assesses the extent to which a State is meeting all of the AFCARS requirements and the quality of its data.

AFCARS Assessment Reviews will be conducted in every State, regardless of whether a State operates a SACWIS. Also, an AAR will be conducted on those States that participated in the pilot AFCARS reviews. For States with an operational SACWIS, an AAR may occur either prior to or following a SAR. It is possible for AFCARS and SACWIS reviews to be conducted concurrently. States that have not developed a SACWIS, and are not planning to do so, are considered ready for an AFCARS Assessment Review. To be considered ready for an AAR, States that have developed, or have not completed the full implementation of, a SACWIS must be:

operating all modules related to the collection of AFCARS data;
operating these components statewide; and,
collecting, extracting, and submitting both the foster care and the adoption files from the SACWIS.

The Children's Bureau's SACWIS and AFCARS review teams share the results and documentation of their reviews with each other as well as with the CFSR teams.

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E. Authority

The statutory basis for AFCARS and SACWIS is the Social Security Act (the Act). The following lists the specific requirements that govern information systems, data collection, and ACF's review of the AFCARS requirements:

Section 422(b)(10)(B)(i) of the Act: Requires States to have an operating "statewide information system that, at a minimum, can readily identify the status, demographic characteristics, location, and goals for the placement of every child who is (or within the immediately preceding 12 months, has been) in foster care."
Sections 471(a)(6) and 476(a) of the Act: Establishes ACF's responsibility to verify the correctness and reliability of State reports and to exercise oversight of foster care and adoption data.
Section 479 of the Act: Requires HHS to implement a national data collection system to collect information with respect to the foster care and adoption population.
Section 474(a)(3)(C) and (D) of the Act: Provides enhanced Federal financial participation (FFP) to States for the planning, design, development, or installation of statewide mechanized data collection and information retrieval systems that, among other things, support the collection of foster care and adoption data under section 479 of the Act and lead to a more efficient, economical, and effective administration of the programs under a state plan approved under titles IV-B and IV-E.
45 CFR Parts 1355, 1356 and 1357: Sets forth the requirements implementing programs under titles IV-B and IV-E of the Act.
45 CFR Parts 1355.40 and Appendices to 45 CFR 1355: Sets forth the requirements for the AFCARS data system.
45 CFR 1355.50-57: Sets forth the requirements for developing and implementing a SACWIS.

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F. Structure Of The Guide

The Guide is organized into six chapters. Chapters I through III provide a general overview and background of the AAR and the review teams. Chapters IV and V describe the activities involved in an AFCARS Assessment Review. Chapter VI addresses the activities that occur after the site visit and provides information on the AFCARS improvement plan.

Information regarding AFCARS and SACWIS can be found on The Federal and State Reporting Systems page at http://www.acf.hhs.gov/programs/cb/systems/index.htm. Information about other program-related guidance, is available from the Children's Bureau web page at http://www.acf.hhs.gov/programs/cb.

This Guide may undergo periodic updates and/or revisions. To ensure you have the latest version of the Guide, check the Children's Bureau's AFCARS web page at http://www.acf.hhs.gov/programs/cb/systems/afcars/review.htm once an AFCARS Assessment Review has been scheduled.

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Continue to Chapter II: Overview of AFCARS Assessment Reviews

Attachments:

ACYF-CB-IM-02-05

State Guide to an AFCARS Assessment Review HTML or PDF(332 KB)

Footnotes:

¹ The Administration for Children and Families is not assessing AFCARS penalties at this time (see ACYF-CB-IM-02-03) and will not take penalties until new, final AFCARS regulations are issued implementing P.L.108-145 (The Adoption Promotion Act of 2003). Back to top
² AFCARS report periods are based on the Federal fiscal year. Report periods are October 1 - March 31 (data are due by May 15) and April 1 - September 30 (data are due by November 14). Back to top
³ The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (Public Law 104-193) extended enhanced funding through FFY 1997. Back to top