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8.2B.7  TITLE IV-E, Adoption Assistance Program, Eligibility, Judicial determinations

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Question 1.  
We believe that the lack of a "reasonable efforts" determination in accordance with section 472 (a)(1) of the Social Security Act (the Act) cannot result in ineligibility for title IV-E adoption assistance. Is this correct?
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Question 2.  
Do the "contrary to the welfare" requirements at 45 CFR 1356.21(c) and (d) apply to the adoption assistance program?
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