The regulations at 45 CFR 1356.60 specify what is considered a training cost and what is considered an administrative expense under title IV-E. Section 1356.60 (c) further explains that the State's cost allocation plan shall identify which costs are allocated and claimed under title IV-E. With regard to costs of educational programs (approved by the State agency) leading to a baccalaureate or graduate degree, the regulations clearly indicate that training to prepare persons who are employed or about to be employed by the State agency administering the title IV-E plan can include such long-term training. Grants to the institution or to the person attending the institution are reimbursable at a Federal matching rate of 75 percent. (See 45 CFR 1356.60 (b)(1)(i), 235.63 (c) and 235.64 (c) for further clarification.)

Under section 474 (a)(3)(B) of the Act, federal financial participation is available at 75 percent "...for the short-term training of current or prospective foster or adoptive parents and the members of the staff of State-licensed or State-approved child care institutions providing care to foster and adopted children receiving assistance under this part, in ways that increase the ability of such current or prospective parents, staff members, and institutions to provide support and assistance to foster and adopted children, whether incurred directly by the State or by contract."

Beginning October 1, 2008, section 474(a)(3)(B) of the Act is expanded to authorize FFP for the short-term training of additional trainees. The additional trainees are: relative guardians (if the title IV-E agency has opted per section 471(a)(28) to offer a guardianship assistance program), members of licensed or approved child welfare agencies providing services to children receiving assistance under title IV-E, members of the staff of abuse and neglect courts, agency attorneys, attorneys representing children or parents, guardians ad litem, or other court-appointed special advocates representing children in the proceedings of such courts in ways that increase their ability to provide support and assistance to title IV-E eligible children. FFP is available for the additional categories of trainees in increasing rates rising to 75% in FY 2013. The specific rates of FFP are 55% in FY2009, 60% in FY2010, 65% in FY2011 and 70% in FY2012.

Costs matchable as training expenditures under this provision may include: (1) travel, per diem, tuition, books and registration fees for trainees; (2) salaries, fringe benefits, travel and per diem for staff development personnel assigned to training functions to the extent time is spent performing such functions; (3) salaries, fringe benefits, travel and per diem for experts outside the agency engaged to develop or conduct training programs; and (4) costs of space, postage, training supplies, and purchase or development of training material. Costs not allowable for trainees under this provision include salaries and fringe benefits.

Federal regulations at 45 CFR 1356.60 (b)(2) require that all training activities and costs funded under title IV-E must be included in the State agency's training plan for title IV-B. States will be reimbursed under title IV-E for such costs only if the activities and costs are described and included in the State's jointly developed and approved title IV-B plan.

All training costs must be allocated to Title IV-E, State foster care and other State/Federal programs in such a manner as to ensure that the cost is charged to the program in accordance with the relative benefits that the program receives from the training. States may determine the manner in which they allocate costs but must do so in accordance with the principles delineated at OMB Circular A-87 (also located at 2 C.F.R. 225).

• Eligibility determinations and re-determinations
• Fair hearings and appeals
• Rate setting
• Referral to services
• Preparation for and participation in judicial determinations
• Placement of the child
• Development of the case plan
• Case reviews
• Case management and supervision
• Recruitment and licensing of foster homes and institutions

Additional examples of allowable administrative activities specifically applicable to the title IV-E adoption assistance program include, but are not limited to:

• Grievance procedures
• Negotiation and review of adoption assistance agreements
• Post-placement management of subsidy payments
• Home studies
• A proportionate share of the development and use of adoption exchanges

There are many training topics that are closely related to these title IV-E allowable activities that the State may train its workers on and claim at the 75 percent rate. The following are some examples:

• Social work practice, such as family centered practice and social work methods including interviewing and assessment.
• Cultural competency related to children and families.
• Title IV-E policies and procedures.
• Child abuse and neglect issues, such as the impact of child abuse and neglect on a child, and general overviews of the issues involved in child abuse and neglect investigations, if the training is not related to how to conduct an investigation of child abuse and neglect.
• Permanency planning including using kinship care as a resource for children involved with the child welfare system.
• General substance abuse, domestic violence, and mental health issues related to children and families in the child welfare system, if the training is not related to providing treatment or services.
• Effects of separation, grief and loss, child development, and visitation.
• Communication skills required to work with children and families.
• Activities designed to preserve, strengthen, and reunify the family, if the training is not related to providing treatment or services.
• Assessments to determine whether a situation requires a child?s removal from the home, if the training is not related directly to conducting a child abuse and neglect investigation. Training on how to conduct specialized assessments such as psychiatric, medical or educational assessments are not permitted.
• Ethics training associated with a title IV-E State plan requirement, such as the confidentiality requirements in section 471(a)(8) of the Act.
• Contract negotiation, monitoring or voucher processing related to the IV-E program.
• Adoption and Foster Care Analysis and Reporting System (AFCARS), Statewide Automated Child Welfare Information System (SACWIS) or other child welfare automated system functionality that is closely related to allowable administrative activities in accordance with 45 CFR 1356.60(d) that the State has chosen to claim as title IV-E training rather than as SACWIS developmental or operational costs (see AT-ACF-OISM-001).
• Independent living and the issues confronting adolescents preparing for independent living consistent with section 477(b)(3)(D) of the Act and the Child Welfare Policy Manual (CWPM), Section 3.1H, Q/A #1.
• Foster care candidate determinations and pre-placement activities directed toward reasonable efforts in 471(a)(15), if the training is not related to providing a service.
• Training on referrals to services, not how to perform the service.