ACYF-CB-IM-01-11 - Title IV-E Foster Care Eligibility Review Guide

Chapter 5 Final Report

Purpose of the Final Report

The basic purpose of the final report is to document for the State the determination of substantial compliance or noncompliance. It also provides a listing of each error case with an explanation of the error, a listing of each non-error case with an improper payment with an explanation of the ineligible payment, an explanation of payments that were eligible for claiming, but were not claimed, and a compilation of the agency's strengths and areas in need of improvement. The State agency should use the information in the final report to develop a PIP, if necessary, and to enhance the effectiveness of its title IV-E eligibility program.

Preparation of the Final Report

The ACF Regional Office, in consultation with the ACF Central Office review representative and team leader for eligibility monitoring, will develop the cover letter and final report to be signed and disseminated by the ACF Regional Administrator. See "Sample Transmittal Letter Including Notice of Disallowance," Appendix VIII; and "Model Report Title IV-E Foster Care Eligibility Review," Appendix IX. The ACF Regional Office will analyze the results of the cases reviewed and make a determination about substantial compliance. Issues addressed in the report should be relevant to the scope of the eligibility review and the determination of substantial compliance or noncompliance. Any other issues revealed during the review should be addressed in the report as comments or observations. Observations or comments about the State child and family services program should be limited to those issues that directly impact the efficient and proper administration of the State title IV-E eligibility program for foster care.

The completed final report to the State should include:

A Transmittal Letter that accompanies the report and includes a statement about substantial compliance; the notification of the disallowance, if applicable; and the notification of the timeframe in which the PIP must be submitted to the ACF Regional Office, if applicable. (See "Sample Transmittal Letter Including Notice of Disallowance," Appendix VIII.)
An Introduction that provides an overview of the background and purposes of the review; the type of review (primary or secondary); and location, dates, and descriptions of the review activities, including the AFCARS reporting period under review and review team representatives. If the review type was secondary, include the reason a secondary review was necessary and a brief synopsis of the findings of the primary review that required the conduct of a secondary review.
A Scope of the Review that describes the manner in which the review was conducted and provides a summary of the review findings, including the number of case records and oversample case records reviewed, the number of records in error, the case error rate and/or dollar error rate, the number of non-error cases with ineligible payments, the disallowance amount, the number of cases with underpayment and the underpayment amount.
The Case Record Summary that provides a summary of the results of the review, including the sample size, oversample size, the number of eligible cases, the number of error cases, and the amount of maintenance dollars and amount of administrative costs associated with each error case. When applicable, a subsection of the case record summary will be included that summarizes the number of eligible cases in which an ineligible payment was claimed, the number of sample cases in which an allowable activity or cost was not claimed, but could have been claimed, and the amount of maintenance dollars and administrative costs associated with each eligible case with ineligible payments and with each sample case with underpayments. An analysis of the sample cases with payment issues also should be included in the Case Record Summary that identifies each case by sample number, along with an explanation of the payment issue and duration, and the statutory/regulatory citation that supports the determination that the case was ineligible or that an underpayment took place. The sample case name or other personal case identifiers should be excluded from the summary and other documents that may be made available for public review.
A section on Areas in Need of Improvement that describes weaknesses or deficiencies discovered about the title IV-E foster care program during the review. Observations about program performance made in this area should be related primarily to needed program improvements and focus on areas of noncompliance resulting from the title IV-E foster care eligibility review.
A section on Strengths and Model Practices discovered during the review that describes strengths or model practices that contributed to the efficient and proper administration of the State title IV-E program and may be replicated by other State eligibility programs. An example is an automated process for title IV-E eligibility determination that the ACF Office of State Systems determined to be compliant with the requirements of SACWIS (Statewide Automated Child Welfare Information System).
A Disallowance section that indicates if a disallowance is warranted. The disallowance will consist of all ineligible maintenance dollars and administrative costs that occurred beginning with the first month of ineligibility and continuing through the date that is the earlier of the end of the service month that immediately precedes the month of the on-site review or when the ineligibility ceases for the most recent foster care episode. If funds are to be disallowed, the disallowance notification, with instructions for State appeals (45 CFR Part 16), will be a part of the transmittal letter of the report. The State agency must be advised that it will be liable for interest on the amount of funds disallowed by the Department, in accordance with the provisions of 45 CFR §30.13.
An Underpayments section that indicates the total amount of maintenance dollars and administrative costs associated with the underpayments, if an underpayment is observed. The notification of underpayment, with instructions for claiming, will be included in the transmittal letter of the final report.
A section on Next Steps that indicates the activities the ACF Regional Office and the State agency should undertake to complete the current phase of the review and begin the next phase of the review cycle. This includes information concerning repayment of disallowances, further claim adjustments, timeframe for PIP development and completion, and subsequent review.

Dissemination of the Final Report

The ACF Regional Office will provide the final report with transmittal letter to the appropriate officials at the State agency, with copies to the State review coordinator and the Children's Bureau Associate Commissioner, and an electronic copy to the ACF Central Office team leader for eligibility monitoring within 30 calendar days of completing the on-site review. The final report should be transmitted to the State agency through the use of registered or certified mail with a request for a return receipt to establish the date.

If the ACF Regional Office receives additional documentation subsequent to issuing the final report and the documentation results in a change to the review compliance or payment disallowance, the ACF Regional Office will provide the State with written notification of the revised finding. The subsequent notification should be signed and issued by the Regional Administrator and an electronic copy forwarded to the ACF Central Office team leader for eligibility monitoring. The ACF Central Office will post on the Children's Bureau Internet Web site the final reports and other pertinent information pertaining to the title IV-E foster care eligibility reviews.