Child Welfare Policy Manual

November 29, 2014

3.1H  INDEPENDENT LIVING, Certifications and Requirements, Training

1. Question: What funds under section 477(b)(3)(D) of the Social Security Act (the Act) will be used for training the individuals listed there and whose responsibility is it to train them?

Answer: The certification at section 477(b)(3)(D) of the Act requires the State or Tribe receiving Chafee funds to train the categories of people enumerated therein and to utilize the funds that are available for this purpose. The funds specified at section 474(a)(3) of the Act are the administrative dollars which can be claimed for such training. Under that section of the Act, the cost of training certain individuals is reimbursable from title IV-E administrative funds at the rate of up to 75 percent Federal Financial Participation (FFP). If the State/Tribe with an approved title IVE plan contracts with private entities to perform case management functions, it may claim the percent reimbursement permitted by statute for training the contractor's staff to perform the contracted functions. The certification for training in the CFCIP law simply adds independent living training to the pool of allowable title IV-E training activities; it has no general impact on the FFP match for training costs. In addition, regulations at 45 CFR 1356.60 (b)(2) require that all training activities and costs funded under title IV-E shall be included in the title IV-E agency's training plan for title IV-B. The certification at section 477(b)(3)(D) of the Act also encourages such training to be coordinated with the Chafee Foster Care Independence Program training conducted for youth participants.

2. Question: Does the law permit training to be directly charged to title IV-E or must the training costs be cost allocated?

Answer: States and Tribes receiving Chafee funds should treat independent living training for foster parents, adoptive parents, case managers and workers in group homes on independent living issues like any other training costs under title IV-E and allocate appropriately.

3. Question: May States claim the costs of training foster parents under their CFCIP funds?

Answer: No. The certification at 477(b)(3)(D) specifies that States "will use training funds provided under the program of Federal payments for foster care and adoption assistance" to provide training to help foster parents, adoptive parents, workers in group homes, and case managers understand and address issues confronting adolescents. Since the statute expressly directs that title IV-E administrative funds be used for training, Chafee funds are not permitted for this use.

  • Source/Date: 7/25/02
  • Legal and Related References: Social Security Act - section 477(b)(3)(D)