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General Requirement StandardsThere were two problems with the foster care reporting population. The State is incorrectly including Tribal children for whom it or the county does not have responsibility for care and placement, but for whom the county provides funds to the Tribe for the placement of the child. The State needs to exclude these records from the AFCARS reporting population. The second problem relates to the reporting of youth who have reached the age of majority. In Minnesota, the age of majority is 18. The State does claim title IV-E funds for youth up to their 19th birthday if the individual meets the title IV-E requirements, and is correctly including them in the AFCARS report. The State also provides services to youth through a voluntary arrangement after the age of 18, regardless of eligibility for title IV-E funds. The State incorrectly includes these youth in AFCARS. Once a child reaches 18, or 19, if appropriate, the State must report these individuals as discharged. The reason for discharge would be “emancipation,” unless there is another appropriate outcome reason. The State staff made changes to the discharge date and discharge reason elements in the extraction code. However, the change for the date of discharge is incorrect and the Federal review team and the State need to discuss this section further. In regard to the reporting of adoptions in which there is State agency involvement, AFCARS requires States to report “(b) all special needs children, whether or not they were in the public foster care system prior to their adoption and for whom non-recurring expenses were reimbursed. c) Children adopted for whom an adoption assistance payment or service is being provided based on arrangements with the State agency.” (45 CFR 1355 Appendix B, Section II). The State has adoption agreements with, and provides subsidies to, families that adopted a special needs child through a private agency. The State is not including these adoptions in AFCARS, and must begin doing so immediately. The State should note that these adoptions count towards the number used to determine a States’ adoption bonus.
The AFCARS review team identified a significant problem with the method the State uses to create its record numbers. This problem also has implications for the creation of an AFCARS annual file, which is used for the data profiles in the Child and Family Services Reviews and the annual report to Congress. The AFCARS regulation states that if a State uses a unique (encrypted) record number, it must follow the child as long as he or she is in foster care. In certain situations, the State is not using the same record number for a child each time it submits its AFCARS data. This occurs for children that are new to the state agency for foster care services. When a county first receives information on an individual they check if the person is already known to them and if there is a previous case record. If the individual is new to the agency, the county assigns a county number that must be cleared to the State. This ensures that the individual is not already known to another agency in the State. Once the number is cleared to the State, a statewide number is assigned to the individual. This number becomes the permanent person identifier number. The problem arises if at the time the AFCARS file is created and sent to ACF the State identifier number has not yet been assigned. In this case, the AFCARS extraction code will encrypt the county number but in succeeding submissions the State identifier number is assigned and this becomes the new encrypted record number. Because the State sometimes submits an encrypted county number followed by a different encrypted State number, there is not a single record number that follows the child while he/she is in foster care. In addition to this method not being consistent with the regulations, it prevents the Children’s Bureau from matching records of the same child for the first two report periods of a child’s AFCARS records, thereby resulting in a significant number of records being dropped between the two report periods. The State must submit only one record number for a child for every AFCARS report period for the child’s complete history with the child welfare agency.
In the case file review there were a significant number of errors found in the dates of first removal, the dates of latest removal, and the number of removal episodes. The majority of the errors were due to the reviewers finding earlier dates of removal than what were reported in the AFCARS data. There were also more removal episodes than what were reported, which also caused errors in the date of discharge from the previous removal episode. There was one technical issue in the program code regarding the extracting of dates of first removal, and the State has corrected this problem. The system has a “removal and adoption history” screen. The purpose of this screen is to collect certain historical information on the child. This screen has two fields, one for the county to enter the date of first removal recorded in the county and a field to record an earlier removal date, if known. There appears to be a problem with workers not getting and/or entering the information for the second field, especially if the child’s foster care episode was in another county(ies). Additionally, there is a problem with the program code. It does not check the “removal history, earlier removal date” field on this screen. The State is required to report the date of a child’s first-ever removal from home and the total number of times a child has entered foster care. This is regardless of which county had responsibility for the case or who now has responsibility. The data is to reflect the child’s experience, not a county’s experience with the child. The State needs to review and clean up data regarding a child’s prior experience with the foster care system.
The State is not including all types of placements. The State excludes hospital stays exceeding 30 days (the State’s definition of an acute care stay), boarding school, intermediate care facility for mental retardation, and juvenile correctional facility (locked) as placements. In addition, when the placement reason is “consequences - 30 days or more” or “behavioral consequences less than 30 days” the setting is not considered a placement. All of these situations must be considered placements and included in the number of placement settings (foster care element #24). The case file review findings indicate that there are more placement moves than are being reported in AFCARS. There are elements in which the quality of the data needs to improve. There were 33 foster care elements that require additional training and supervisory oversight for the timeliness and accuracy of data entry. Two significant areas that appear to be underreported are the circumstances associated with a child’s removal from home and whether a child has been diagnosed with a disability. There are some technical corrections to mapping and the program code for the disabilities that need to be addressed, but there is also an issue with workers not entering or updating the information in both areas. There were several elements that needed technical corrections; the State made these corrections and submitted them to ACF. These data elements have been given a rating factor of “3.” The State will now need to implement additional measures to ensure the accuracy of data entry and improve the quality of the data. In some instances this involves data clean-up, additional training, and/or supervisory oversight to ensure timeliness of data entry. |