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Disclaimer: On July 23-25, 2008, the Children's Bureau (CB) presented a series of briefings on the National Youth in Transition Database regulation in which State participants submitted the following questions. All additional NYTD questions should be directed to the State's CB Regional Office Specialist.
Question: If a youth receives independent living services paid for or provided by a State CFCIP agency and then moves to another State and receives independent living services from that State’s CFCIP agency during the same reporting period, which State reports on this youth?
Answer: Both. A youth is in the served population if she/he receives an independent living service paid for or provided by the State CFCIP agency during the reporting period. If two States served a particular youth during the same reporting period, they both would report on all the relevant data elements for the particular youth including basic demographics, characteristics, and independent living services received as appropriate. It is possible for a single youth to be in more than one State’s served population.
Question: If one State provides Education and Training Voucher (ETV) funds to a youth and another State provides other Chafee funded independent living services to the same youth, which State reports on the youth?
Answer: Both. A youth is in the served population if she/he receives an independent living service paid for or provided by the State CFCIP agency during the reporting period, including education financial assistance (data element 32) such as ETV. If two States served a particular youth during the same reporting period, they both would report on all the relevant data elements for the particular youth including basic demographics, characteristics, and independent living services received as appropriate. Again, it is possible for a single youth to be in more than one State’s served population.
Question: Do we exclude from our NYTD reporting a youth who exits foster care before age 17, but returns to the agency to request independent living services at age 18?
Answer: Yes, the youth in question would not be a member of the baseline population, because the youth exited foster care before reaching age 17. If the youth is receiving at least one independent living service paid for or provided by the State agency, however, the youth is still in the served population for that reporting period.
Question: Does the youth have to be in foster care when they receive an independent living service?
Answer: No. For NYTD data collection purposes, the served population includes any youth who receives at least one independent living service during a reporting period regardless of foster care status.
Question: How do we determine what age groups should be considered in the served population? Do we determine the served population as those defined as eligible for services under Chafee?
Answer: For NYTD, the State does not determine the served population based on youth age or eligibility for Chafee services. Rather, the served population includes any youth who receives at least one independent living service during a reporting period regardless of any other characteristic. We acknowledge that States may restrict eligibility for independent living services to particular age groups. For the purposes of collecting data on the served population, however, we do not make a distinction between a youth that is eligible or ineligible for a State's Chafee services.
Question: Does a State have to report on a youth who is not eligible to receive independent living services but who is in care at age 17?
Answer: If the youth in question was in foster care at some point during the 45 days after his or her 17th birthday in a year in which baseline data is due, then the youth would be in the baseline population. Whether the youth is eligible to receive services is not relevant to his or her inclusion in the baseline population.
Question: If a youth turns age 17 less than 45 days before the end of a Federal fiscal year (FFY) in which baseline outcomes data must be collected, then do States still report outcomes data? If yes, when does outcomes data need to be obtained?
Answer: Yes, a youth in foster care who turns age 17 before the end of a FFY in which baseline outcomes data must be collected is a member of the baseline population and the State is to collect youth outcomes data within 45 days following the youth's 17th birthday. The State is to report the information in the report period which corresponds with the date of the outcomes data collection (i.e., data element 35).
Question: If a youth enters foster care at age 17 years, six months then they would not be in the baseline or follow-up populations, correct?
Answer: Correct.
Question: If a child turns age 17 on October 2, 2010, is the child reported on in both reporting periods (October 1, 2010 – March 31, 2011 and April 1, 2011 – September 30, 2011)?
Answer: Each State is to submit a single data file to ACF semiannually comprised of data on all youth in the served population, and if applicable, youth in the baseline or follow-up population (45 CFR 1356.82 and 1356.83(a) through (e)). In a year in which data collection is not required on the baseline or follow-up populations, a State must still submit to ACF a data file comprised of youth of any age who are in the served population for a report period. For the served population, as long as a youth is receiving an independent living service that is paid for or provided by the State agency in a six-month report period, then the State is required to report to ACF information on those services (45 CFR 1356.81(a) and 1356.82(a)(1)).
Question: Since age is a primary variable determining the NYTD reporting populations, what is the implication of an incorrect date of birth that, once corrected, would include or exclude a child from one of the reporting populations? How would this impact data element 35?
Answer: A State that reports an incorrect date of birth for a youth risks committing errors in the State's data file submission and, consequently, could be subject to penalties for noncompliance.
Question: If youth that are deceased, incapacitated, or incarcerated are excluded from calculation of outcomes survey participation rate, then can the State remove these youth from the NYTD data file prior to submission to ACF?
Answer: No. The State cannot remove records for youth that are deceased, incapacitated, or incarcerated from the NYTD data file before submitting the file to ACF. For these particular subgroups, the State would report "Youth incapacitated", "Incarcerated", or "Death" as appropriate for data element 34 (outcomes reporting status) and these youth would be excluded by ACF from the calculation determining the State's compliance with the foster care youth participation rate and discharged youth participation rate standards. The State is still required to provide the youth's record to properly account for the experience of youth reported as in the baseline population.
Question: Youth that have runaway and remain missing for over six months are generally discharged from foster care. Do States still need to report on these youth and their outcomes?
Answer: It depends. If a youth on runaway status has been discharged from foster care before reaching his/her 17th birthday during a Federal fiscal year in which baseline outcomes data is due, then the State is not responsible for administering the youth outcomes survey. Youth who are age 17 in the applicable fiscal year but who have run away are considered to be part of the baseline population if they are still under the placement and care responsibility of the State title IV-B/IV-E agency. If the youth is on runaway status at the time(s) that the State attempts outcomes data collection, the State will report the youth as having runaway in the outcomes reporting status element (45 CFR 1356.83(g)(34)) to explain why that youth's information was not collected. The State would also be responsible for collecting information on the data elements relevant to a member of the served population if the youth received at least one independent living service during a reporting period.
Question: How would a State report on youth who move from their home State after being counted in the home State's baseline population?
Answer: The home State is responsible for administering the youth outcomes survey to youth in the follow-up population regardless of where the youth resides. We anticipate offering technical assistance on strategies States may employ to assist in locating youth after they leave foster care.
Question: Which State reports outcomes data for an ICPC youth in the baseline or follow-up populations, the sending State or the receiving State?
Answer: The "sending" State. A youth that is included in a State's baseline population remains in that State's baseline population for the purposes of follow-up outcomes data collection. States are responsible for administering the youth outcomes survey to youth in the follow-up population regardless of where the youth resides. We anticipate offering technical assistance on strategies States may employ to assist in locating youth after they leave foster care.
Question: Can you elaborate on the type of youth that will be waived from participation in the served population and the baseline population? For example, is a youth with a disability waived from the NYTD data collection requirements and/or do States have the responsibility to complete the information for them?
Answer: The term "waive" is not applicable to the NYTD. No youth may be excluded from the served population if the State pays for or provides an independent living service to that youth during a reporting period. For a youth with a disability, a State has the discretion to choose the methods, if any, by which it determines that a youth in the baseline population is unable to participate in the outcomes data collection due to an incapacitating permanent or temporary mental condition (45 CFR 1356.82(a)(2) and 1356.83(g)(34)(iv)). A State may select the method for administering the youth outcomes survey, including providing assistance in recording youth responses (i.e. filling out a survey for a youth with a disability as the youth provides responses to the survey questions). A State, however, may not supply responses to the survey questions from any source other than the youth. If a State determines that a youth is unable to participate in outcomes data collection due to an incapacitating condition, the State would report "youth incapacitated" for data element 34 and would not be responsible for reporting further outcomes information on the youth.
Question: How severe must a youth's disability be to exclude them from the baseline or follow-up populations?
Answer: A State has the discretion to determine whether a youth in the baseline population is unable to participate in the outcomes data collection due to an incapacitating permanent or temporary mental condition (45 CFR 1356.82(a)(2) and 1356.83(g)(34)(iv)). If a State determines that a youth is unable to participate in outcomes data collection due to an incapacitating condition, the State would report "youth incapacitated" for data element 34 and would not be responsible for reporting further outcomes information on the youth as a member of the baseline population. Because the youth did not participate in outcomes data collection as a member of the baseline population, the youth is not a member of the follow-up population.
Question: If the State surveys a youth in the follow-up population in a subsequent reporting period following the reporting period in which the youth turned age 19 or 21, should the State still submit the outcomes data?
Answer: Yes. States are encouraged to submit outcomes data collected from youth in the follow-up population in a subsequent reporting period in order to maintain the continuity and completeness of the data available for current and future use. Failing to administer the youth outcomes survey to a member of the follow-up population during the reporting period in which the youth turns age 19 or 21 is out of compliance with the NYTD data collection schedule and may result in a penalty.
Question: What do "Py" and "Pn" actually stand for in the calculation for determining sample size for the follow-up population?
Answer: "Py" is the estimated proportion in the population with the characteristic of interest and "Pn" is (1 - Py). If Py = 0.5, then Pn = 1 - 0.5 = 0.5. A value of 0.5 for Py maximizes the sample size and (Py)(Pn) = 0.5(0.5) = 0.25.
Question: Why do we have to use a Z coefficient of 1.645?
Answer: For the purpose of sampling, ACF has determined that a 90 percent confidence interval provides a balance between larger and smaller sample sizes for NYTD data reporting. When a 90 percent confidence level is desired, the coefficient from a standard normal probability distribution (a Z-value) is 1.645.
Question: Is a single sample drawn from the baseline population for the entire FFY or from each of the two reporting periods during the FFY?
Answer: The State is to draw the sample from the entire FFY's baseline population that has participated in the outcomes data collection (see 73 FR 10345) and not separately for each reporting period.
Question: Were the data elements vetted by disproportionality experts to ensure that there are no hidden dangers in the language and definitions in order to promote proportionate outcomes and reporting?
Answer: In developing the rule we engaged in an extensive consultation process on the information that would comprise the NYTD. Our consultation included national discussion groups with child welfare agency administrators and independent living coordinators at the State, Tribal, and local levels; public and private agency youth service providers; technical assistance providers; child welfare advocates; group home staff and administrators; and current and former foster youth and foster parents. We also conducted a pilot test of the draft data elements in seven States and one Indian Tribe and formed a work group of national associations, resource centers and State and Tribal representatives to analyze the results of the pilot test. Experts, advocates, and other representatives from the child welfare field provided public comment to the proposed rule and we incorporated some of these suggestions into the final NYTD Final regulation.
Question: If a foster parent provides some type of transitioning service (i.e., dishwashing or opening a checking account) whether or not the youth was in the Independent Living Program, do these services "count" for data elements relating to independent living services (data elements 20-33) even if they are not paid for with Chafee funds?
Answer: Data elements 20-33 collect information on independent living services "paid for or provided by the State CFCIP agency" during the reporting period regardless of whether these services are paid for with Chafee funds. If a foster parent provides training or other services described in the independent living services data elements (data elements 20-33), regardless of whether the youth receiving these services is considered part of or eligible for the State's Independent Living Program, then the State may consider that a service provided by the State CFCIP agency.
Question: Our State provides transportation assistance for employment for three months. Without transportation assistance, youth would not be able to access their jobs. Do any of the NYTD data elements capture information on this service?
Answer: Yes. If a State CFCIP agency pays for or provides financial assistance to a youth for transportation, a State may capture this information in data element 33 (other financial assistance).
Question: We could not locate an ILP service type where transportation costs would fit-is there a data element or data elements that specifically capture information on these costs?
Answer: It depends. If a State CFCIP agency pays for or provides financial assistance to a youth for transportation, a State may capture this information in data element 33 (other financial assistance).
Question: The AFCARS data elements for race and Hispanic/Latino ethnicity include "unable to determine" as a valid response option. Would we expand the possible race/ethnicities to include both "unknown" (for AFCARS purposes) and "declined" (for NYTD purposes) then map them to "unable to determine" for AFCARS and map them singularly for NYTD?
Answer: The NYTD definition of "unknown" encompasses two situations in which it can be used. One situation would be mapped to AFCARS and the other would not. In order to make the response option of "unknown" more meaningful to the worker, the State may want to consider alternate terminology. One example might be "incapacitated" and "multi-racial-other race not known." These would then map in NYTD to "unknown." For AFCARS reporting purposes:
Current AFCARS reporting allows for States to report "unable to determine" when an individual declines to provide either their race or ethnic origin. Many States have changed the values that workers have to select from "unable to determine" to both "abandoned" and "declined." These options then map to the AFCARS value of "unable to determine."
Question: Regarding data element 15 (local agency), if a youth is in foster care but receives services from a "centralized unit", what is meant by "centralized unit"? Does a centralized unit have a FIPS code?
Answer: "Centralized unit" was provided as a response option in data element 15 to indicate that a youth who is not in foster care receives services from a centralized unit, rather than a county agency. If a State reports that a youth was served by a centralized unit, there is no FIPS code to report.
Question: For a youth in the served population, if a youth was an adjudicated delinquent (data element 17) during the reporting period but not at the time the data was captured, is that youth classified as delinquent?
Answer: Yes. States report in data element 17 whether or not a youth in the served population has ever been adjudicated delinquent by a State or Federal court of competent jurisdiction.
Question: For the adjudicated delinquents in the served population, are they counted as such if they were ever adjudicated delinquent (data element 17) or if they were only adjudicated delinquent during the reporting period?
Answer: Data element 17 captures information on whether or not a youth in the served population was ever adjudicated as a delinquent by a State or Federal court of competent jurisdiction.
Question: If a youth drops out of school after completing 10th grade and at age 19 he is working on completion of his GED during a reporting period, then what does the State report for data element 18 (education level) and data element 46 (highest education certification received)?
Answer: If the youth in question received at least one independent living service paid for or provided by the State CFCIP agency during the reporting period, the State would report "10th grade" for data element 18 because this is the highest educational level completed by the youth. If the youth in question was a member of the follow-up population, then the State would report the youth's response to the survey question relevant to data element 46.
Question: If at age 21 the same youth has received his GED and is at the end of his second year of this Associate's degree program during a reporting period, then what does the State report for data element 18 (education level) and data element 46 (highest education certification received)?
Answer: If the youth in question received at least one independent living service paid for or provided by the State CFCIP agency during the reporting period, then the State would report "college" for data element 18 because this is the highest educational level completed by the youth. Data element 18 defines the response option "college" as completing at least one semester of study at a college or university. If the youth in question was a member of the follow-up population, then the State would report the youth's response to the survey question relevant to data element 46.
Question: If a youth received special education services such as tutoring from the State CFCIP agency and not from the youth's school, would the State report "yes" for data element 19 (special education status)?
Answer: No. Data element 19 (special education status) refers to whether a youth in the served population is receiving specifically designed instruction, at no costs to the parents, to meet the unique needs of a child with a disability. This data element does not refer to a specific independent living service paid for or provided by the State CFCIP agency, but rather is meant to provide information on a particular characteristic of youth.
Question: For data element 21 (academic support), does it count as a "service" every time a foster parent helps a youth with homework?
Answer: Yes. If a foster parent provides academic support as described in data element 21 to assist a youth in completing high school or obtaining a General Equivalency Degree (GED) during the reporting period, a State may indicate "yes" for data element 21.
Question: If a caseworker talks to a youth about college, does this count as the independent living service "post-secondary education support" (data element 22)?
Answer: It depends. Post-secondary educational support as defined at 45 CFR 1356.83(g)(22) must involve a service aimed at assisting a youth to enter or complete college. To the extent that a caseworker's conversation with a youth involves assisting that youth to enter or complete college, a State may indicate "yes" for data element 22.
Question: Regarding data element 24 (employment programs or vocational training), I understand that we are only to report on the job programs that the State agency places/finds for a youth, but doesn't this preclude any data on those youth who find work on their own? Without also tracking this, we cannot relate their positive outcomes to these jobs.
Answer: Data element 24—employment programs and vocational training—captures information on the State agency's efforts to build a youth's skills for a specific trade, vocation, or career through classes or on-site training. This includes employment programs a State identifies for the youth such as apprenticeships, internships, or summer employment programs. Jobs secured by the youth alone are not included in the data element definition because they are not part of a service provided by the State agency. The youth outcomes survey, however, does capture information on a youth's employment status (data elements 37 and 38) regardless of whether the State agency has assisted the youth in preparing for or securing employment.
Question: If State CFCIP agency staff offer budgeting and financial management coaching as part of regular case management, does this cover the independent living service described in data element 25 (budget and financial management)?
Answer: Yes. If State CFCIP agency staff provided the service, then the State would report "yes" for data element 25 (budget and financial management).
Question: Our State has a partnership with the cooperative extension program that offers budgeting and financial management training to youth in foster care. We are going to use Chafee funding to provide food for the youth attending this training as well as to provide an incentive for youth to attend the classes. The agency will also ensure the youth are transported to the classes by foster parents, residential staff or paid transportation providers. Does this count as providing the independent living service "budgeting and financial management" (data element 25)?
Answer: No. Because the budgeting and financial management training described in the example above is provided by a partnership and is not actually paid for or provided by the State CFCIP agency, we do not consider it a service for NYTD reporting purposes.
Question: In our State, we have arranged for volunteers to provide free budget and financial literacy classes. The State CFCIP agency provides the site, transportation, food, materials and equipment using Chafee funds. Does this meet the definition of an independent living service?
Answer: We do not have sufficient information to answer this question. We are interested in a State collecting and reporting information on youth who receive an independent living service due to the State agency's commitment of funds or resources to provide the service. Independent living services that are arranged or brokered by the State agency are too far removed from the statutory mandate to collect data on youth served under the CFCIP.
Question: If the State CFCIP agency pays for or provides screened and trained mentors to youth but they do not meet face-to-face (interaction through a monitored portal via the internet), then would the State be able to report "yes" for data element 29 (mentoring)?
Answer: Yes. If the mentoring service otherwise meets the definition of "mentoring" as described in 45 CFR 1356.83(g)(29), then mentoring meetings conducted via the internet are acceptable.
Question: Our State contracts and pays transitional living programs that provide minimal supervision 24 hours a day, seven days a week for our youth but they also provide youth with opportunities for increased responsibilities. Would the transitional living programs we contract with count as a "supervised independent living" (data element 30)?
Answer: It depends. Supervised independent living, as defined in data element 30, means that a youth is not supervised 24-hours a day by an adult. Transitional living programs vary in their service delivery as well as level of supervision provided to the youth. However, as we understand transitional living programs, they offer a supervised living arrangement with less than 24-hour a day supervision by an adult and increased youth responsibilities. If this is the case here, then the State could count the transitional living program as supervised independent living. Further, we clarified in the preamble to the final rule (73 FR 10349) that the State would report "yes" for youth participating in the Federal transitional living program as long as the youth's participation in the program is paid for or provided by the State agency and is otherwise consistent with the regulatory description.
Question: How would a State respond to data element 34 (outcomes reporting status) if a caseworker fails to survey a 19- or 21-year-old youth in the follow-up population?
Answer: If the State fails to survey a youth in the follow-up population during the six month reporting period in which a youth turns age 19 or 21, then the State would report "unable to locate/invite" for data element 34.
Question: If the State reports data element 34 (outcomes reporting status) as "youth declined", then what is reported for data element 35 (date of outcome data collection)?
Answer: Nothing. If a youth declines to participate in the outcomes survey, then the State would leave data element 35 blank because reporting the date of outcome data collection only applies when the youth responds to the outcomes survey questions (data elements 38-56).
Question: Why only collect data on full- and part-time employment (data elements 37 and 38)? What if a youth makes a livable wage working part-time?
Answer: In drafting the proposed rule and after considering public comments on data elements 37 and 38, we concluded that more detailed data on employment status is not central to the purposes of the NYTD. Even though we are not requiring more detailed employment data such as hours worked or wages earned, States may report information in other elements that may provide additional context on a youth's financial self-sufficiency (data elements 39-45).
Question: Allowing States to count a previous caseworker as a "connection to an adult" (data element 48) may misrepresent whether the youth has a long lasting connection to an adult who will be there for the youth after they are no longer employed to do so. If States are allowed discretion in determining whether a youth's connection to a caseworker counts as "yes" to data element 48, then there will be inconsistencies.
Answer: Like all of the NYTD youth outcomes survey questions, it is up to the youth to determine whether he or she has positive connection to a former helping professional. The State does not have discretion to make this determination on the youth's behalf. While current caseworkers are excluded from the data element description for "connection to an adult", a youth who reports a connection (as described in data element definition) to a former caseworker could report "yes" for data element 48.
Question: Would a current Chafee-funded outreach worker be considered allowable as a "connection to an adult" (data element 48) if the outreach worker is not the youth's caseworker?
Answer: No, not if the Chafee-funded outreach worker is a current State agency employee (45 CFR 1356.83(g)(48)).
Question: If a youth in the follow-up population indicates having been homeless (data element 49-homelessness), would there be a need to know if they received public assistance while homeless?
Answer: No. Data element 49 relates to the youth's experiences with homelessness. For the purposes of reporting on data element 49 for a youth in the follow-up population, a youth is considered to have experienced homelessness if the youth had no regular or adequate place to live in the past two years. Whether or not the youth received public assistance during his or her experiences with homelessness is beyond the scope of this data element. The youth's receipt of public assistance is captured in separate outcome data elements (42-44).
Question: Regarding data element 49 and the definition of homelessness, what is an "adequate" place to live?
Answer: We define "homeless" as having "no regular or adequate place to live." This definition includes situations where the youth is living in a car, on the street, or staying in a homeless shelter.
Question: For data element 51 (incarceration) should we ask if the youth was ever convicted?
Answer: No. Data element 51 indicates whether the youth in the baseline population has ever been confined in a jail, prison, correctional facility, or juvenile or community detention facility in connection with allegedly committing a misdemeanor or felony regardless of conviction. For a youth in the follow-up population, data element 51 indicates whether the youth has been confined to a jail, prison, correctional facility, or juvenile or community detention facility in connection with allegedly committing a misdemeanor or felony regardless of conviction in the past two years. The youth's conviction is beyond the scope of this data collection.
Question: As written, data element 51 does not ask about the youth's experience. If the intent of data element 51 (incarceration) is to capture the "trauma" related to incarceration, can the question be reworded to reflect that?
Answer: The survey question collecting information on data element 51 (incarceration) cannot be reworded. Data element 51 addresses the statutory requirement to develop outcome measures pertaining to incarceration and high-risk behaviors.
Question: What do States report for data element 52 (children) if a youth indicates that he doesn't know whether or not he has fathered a child?
Answer: The State should direct the youth to answer the question with one of the valid response options for data element 52, which are "yes", "no" or "declined" as "do not know" is not a valid response. If a youth is not declining to respond, then the only choices remaining are "yes" or "no." Regardless, it is the youth's response that the State must report.
Question: If a youth in the baseline or follow-up populations has children by more than one father but is married to one of them, then what does the State report for data element 53 (marriage at child's birth)?
Answer: It depends. Data element 53 asks whether the youth was married to the child's other parent at the time of the child's birth. So, if the youth was married to either of her child's fathers when either of the children was born, then the youth could report "yes." Regardless, the State should direct the youth to answer the question with one of the valid response options for data element 53 (marriage at child's birth).
Question: How do States survey youth in the baseline population?
Answer: A State has the discretion to choose the method(s) it will use to administer the outcomes survey to youth (e.g., in person, via the internet or over the phone) provided that the survey is administered to youth directly. We anticipate providing technical assistance to States in devising effective methods of administering the youth outcomes survey.
Question: Can we alter the survey verbiage in Appendix B to make the survey more "youth friendly" or must we use the language listed in the regulation?
Answer: No. We choose to regulate the survey questions to ensure that each youth is provided with standard questions and response options so we can allow for consistency of the data collection nationwide. States must collect information on the youth outcome survey data elements using the survey questions in appendix B of the NYTD regulation and may not alter these questions in any way. It is allowable, however, for a State to use "youth friendly" language in explaining the survey questions if the youth indicates they are unclear. We anticipate providing technical assistance and further guidance on how States may best administer the survey to youth to minimize non-response bias and measurement error.
Question: If a youth in the baseline or follow-up populations indicates in the outcomes survey that he/she is not receiving a particular service or benefit (data elements 37-58), can the State consult other administrative data systems to confirm whether the youth is in fact receiving a benefit or service (i.e. food stamps, Medicaid, etc.)?
Answer: No, not for the purposes of NYTD. States must administer the survey to youth directly and may not provide information on outcomes data elements from any other source including administrative databases, such as TANF, Social Security or employment records (73 FR 10350).
Question: If a SACWIS State has an interface with the Medicaid database, should data element 54 (Medicaid) be reported from the information received through the Medicaid database or through the youth's self-report?
Answer: No. The outcomes data for this element must be based on the youth's self-report. Again, States must administer the survey to youth directly and may not provide information on outcomes data elements from any other source including the State's Medicaid data system (73 FR 10350). We also added a response option of ‘‘don't know'' to data elements 54 through 58 to permit the youth to identify the types of health insurance that he or she knows and does not know about.
Question: If the youth indicates in the outcomes survey that he is still in foster care, is under age 19, and does not have Medicaid but the State knows he does have Medicaid, should the answer to survey question be "yes" or "no"?
Answer: States must administer the survey to youth directly and may not provide information on outcomes data elements from any other source including the State's Medicaid data system (73 FR 10350). A State must report the answer provided by the youth. Also, a State is responsible for determining and reporting whether a youth in the baseline or follow-up population is in foster care. Please note that while there is a foster care status data element for the baseline and follow-up populations, there is not a survey question related to foster care status.
Question: What about verification of youth responses for youths who are not truthful?
Answer: The goal of the youth outcome survey is to collect information that represents the youth's understanding of his or her own circumstances and experiences as a whole. To achieve this goal and to preserve the integrity of the survey and data, States must administer the survey to youth directly and may not provide information on outcomes data elements from any other source including administrative databases, such as TANF, Social Security or employment records (73 FR 10350). Also, States may not correct a youth's response if they have alternative knowledge about a youth's outcomes. It is, however, allowable for a State to develop a system of prompts to help the State verify whether a youth meant to provide a particular answer (73 FR 10350).
Question: What about youth who may need assistance in responding to the youth outcomes survey due to a disability?
Answer: A State may select the method for administering the youth outcomes survey, including providing assistance in recording youth responses (i.e. filling out a survey for a youth with a disability as the youth provides responses to the survey questions). A State, however, may not consult any source other than the youth when administering the youth outcomes survey. A State also has the discretion to choose the methods, if any, by which it determines that a youth is unable to participate in the outcomes data collection due to an incapacitating permanent or temporary mental condition (45 CFR 1356.82(a)(2) and 1356.83(g)(34)(iv)).
Question: May the data that is provided to ACF be sent in the same format as is allowed for AFCARS reporting or does ACF expect the State's SACWIS to produce the NYTD reports directly?
Answer: We have not made any final decisions about file formatting and transmission procedures for the NYTD. We are working diligently with our contractor to make this information available to States as soon as possible in 2009. States will be afforded the opportunity to submit test files prior to the actual submission of NYTD data in order to ensure proper file format and transmission, and to make any necessary modifications.
In regard to the information system used to collect NYTD data, if a State developed a SACWIS, then the State must incorporate the collection of information required for NYTD into its SACWIS in order to remain SACWIS-compliant.
Question: Should a State's SACWIS system have the functionality to record responses to the outcome survey questions?
Answer: States that have elected to build a SACWIS must incorporate NYTD information collection and reporting activities, including outcomes, related to children in foster care into their SACWIS system (73 FR 10361).
Question: If a State creates an external data base (outside the SACWIS system) for recording and maintaining data and survey information associated with follow up populations will this data also be required to be added to the SACWIS data base? Can separate data reports come from SACWIS and from the external data bases?
Answer: Regarding the first question, no, these data are not required to be added to SACWIS, but if they are not included with the SACWIS, then the developmental costs cannot be allocated to title IV-E. (Operational costs for the follow-up population would not be allocable to title IV-E regardless whether included with the SACWIS or a separate database). Regarding the second question, the State cannot submit separate reports/files for each of the populations. NYTD data must be submitted as a single data file.
Question: In an electronic survey, a State could code the internal consistency checks, however, in a paper survey it is likely there will be instances where a youth would mistakenly answer "no" for data element 52 (children) and "yes" for data element 53 (marriage at child's birth). How would States handle this situation?
Answer: This is a matter at a State's discretion. States should evaluate carefully their survey methods for the potential for response errors as a result of using a particular methodology. We anticipate providing technical assistance to States in devising effective methods of administering the youth outcomes survey.
Question: Will a youth's refusal to participate (or parent's refusal to allow participation) in the outcomes survey effort be considered as missing data and therefore counted as an error on data elements 35 - 41 and 45 -58?
Answer: No. We define missing data as any element that has a blank response, when a blank response is not a valid response option as described in the data element descriptions in section 1356.83(g). If a youth declines to participate in the outcomes survey (or a youth's parent declines participation in outcomes data collection as a member of the baseline population), then the State should report "youth declined" or "parent declined" as appropriate for data element 34 and leave the outcome survey data elements (37-58) blank. In this case, "blank" is a valid response option for data elements 37-58.
Question: For the follow-up populations, the number of youth that are incapacitated, incarcerated, and deceased is excluded from the participation rate standard. What about the number of youth who decline to participate, who runaway or who are missing, and who are unable to be located or invited?
Answer: If a youth who participated in the survey as a member of the baseline population subsequently refuses to participate in the follow-up surveys, then they would still be included in the calculation of participation rate to determine the State's compliance with this data standard. Youth who participated in the outcomes survey as members of the baseline population who have since runaway or are missing or who are unable to be located or invited are also included in the calculation of participation rate.
Question: Is the minimum participation rate standard applied discretely to each of the two reporting periods?
Answer: Yes, the outcomes participation rate standards for youth in the follow-up population will be applied to each six-month reporting period (45 CFR 1356.86(b)(2)(iii)(iv)).
Question: Could you please provide the citations for the research papers consulted in determining acceptable outcomes survey participation rates in the Final Rule?
Answer: A number of studies documented response rates for similar outcomes surveys and assessments of youth at various ages using a variety of methods. These include:
U.S. Department of Health and Human Services, Administration for Children and Families. (2007). Multi-site evaluation of foster youth programs: Evaluation of the Life Skills Training Program. Washington, D.C.
Courtney, M.E., Dworsky, A., Cusick, G.R., Keller, T., Havlicek, J., Perez, A., Terao, S. & Bost, N. (2007). Midwest evaluation of the adult functioning of former foster youth: Outcomes at age 21. Chicago, IL: Chapin Hall Center for Children at the University of Chicago.
Pecora, P. J., Kessler, R. C., Williams, J., O'Brien, K., Downs, A. C., English, D., White, J., Hiripi, E., White, C. R., Wiggins, T. & Holmes, K. E. (2007). Improving family foster care: Findings from the Northwest Foster Care Alumni Study. Seattle, WA: Casey Family Programs. Available at http://www.casey.org.
Courtney, M.E., Dworsky, A., Cusick, G.R., Keller, T., Havlicek, J., Perez, A., Terao, S. & Bost, N. (2005). Midwest evaluation of the adult functioning of former foster youth: Outcomes at age 19. Chapin Hall Working Paper. Chicago, IL: Chapin Hall Center for Children at the University of Chicago.
Courtney, M.E., Piliavin, I., Grogan-Kaylor, A. & Nesmith, A. (2001). Foster youth transitions to adulthood: A longitudinal view of youth leaving care. Child Welfare, 80(6), 685-717.
Question: How did ACF arrive at the participation rate standards of 80% of youth in foster care and 60% of youth discharged from foster care?
Answer: In developing the proposed rule, we carefully considered the available
research on this population (see above), what we believed was a reasonable expectation for States that still have responsibility for the youth's care and placement, and our necessity for ample information to meet the statutory mandate. We believe that the 80 percent participation rate of youth in foster care and 60 percent of youth discharged from foster care is an appropriate standard. While the process of collecting outcomes data from youth no longer in the State's foster care will be challenging, we are seeking a standard that will provide us with a level of confidence in the outcome information that is reported to us. After considering the research on response rates and reviewing the Office of Management and Budget's guidance on surveys (see various publications at http://www.whitehouse.gov/omb/inforeg/statpolicy.html#pr), we do not believe that a rate lower than 60 percent would serve our purposes.
Question: How much Federal funding is available to States to build the NYTD data system, report the data and conduct the survey?
Answer: There is no additional Federal funding set-aside for the NYTD. The CFCIP program was created with a mandate for States to collect data, but the statute does not set-aside funds for that specific purpose. A State with a SACWIS must incorporate NYTD information collection and reporting activities related to children in foster care into their SACWIS system and may claim such information system costs as administrative costs under title IV-E to the extent they are allowable and consistent with a State's APD and cost allocation plan (73 FR 10362).
Question: Can Chafee funding be used for incentives to encourage youth in the baseline and follow-up populations to participate in outcomes survey?
Answer: A State may use CFCIP funds for any and all costs associated with implementing the NYTD (73 FR 10361). However, we encourage States to be mindful of guidance issued by the Office of Management and Budget (OMB) entitled "Guidance on Agency Survey and Statistical Information Collections." While this guidance is directed to Federal agencies, the same general principles should guide State agencies, as well.
In the guidance, OMB states that incentives are used most appropriately with hard-to-find populations or respondents whose failure to participate would jeopardize the quality of the survey data. OMB's guidelines follow a general conceptual framework that seeks to avoid the use of incentives except when the agency has clearly justified the need for the incentive and has demonstrated positive impacts on response and data quality by using an incentive. The OMB guidance document can be located at: http://www.whitehouse.gov/omb/inforeg/pmc_survey_guidance_2006.pdf
Question: Can title IV-E funds be used for incentives to encourage youth in the baseline and follow-up populations to participate in outcomes survey?
Answer: No. Incentives for youth participation in NYTD activities are unallowable as they are inconsistent with title IV-E regulations found at 45 CFR 1356.60.
Answer: Our plan is to host similar technical assistance meetings each year.
Question: What is the citation for the definition of foster care that you are using for this reporting system?
Answer: The regulatory definition of foster care can be found at 45 CFR 1355.20(a).
Question: If a youth is under care and control of a State but is not currently in placement (i.e., is on a trial reunification or runaway) then would the youth be considered in foster care for NYTD purposes?
Answer: Youth are generally considered to be in "foster care" for NYTD purposes if they are in 24-hour substitute care under the State's placement and care responsibility and are in foster family homes, group homes, shelter care and child care institutions, regardless of whether such homes or institutions are licensed, approved or paid. If a youth is in what the State considers a "trial reunification" (i.e., at home but in the placement and care responsibility of the State agency), then the youth is excluded from the baseline and follow-up population. Youth who have run away from a foster care placement are considered to be in foster care if they are still under the placement and care responsibility of the State title IV-B/IV-E agency. If the youth is on runaway status at the time(s) that the State attempts outcomes data collection, the State will report the youth as having run away in the outcomes reporting status element (45 CFR 1356.83(g)(34)) to explain why that youth's information was not collected.
Question: Many States have developed strong partnerships with sister State agencies such as Departments of Health and Departments of Labor to increase foster care youth's access to programs funded through these other agencies. It seems counterproductive not to count these as independent living services "paid for or provided" by the State CFCIP agency.
Answer: We recognize that States collaborate with State agency partners in a variety of ways to benefit youth as required under the CFCIP State plan. However, including youth served as a result of those collaborations or otherwise arranged or brokered by the State agency in the served population is too far removed from the statutory mandate to collect data on youth served under the CFCIP. Rather, we are interested in a State collecting and reporting information on youth who receive an independent living service due to the State agency's commitment of funds or resources to provide the service. Therefore, an independent living service is provided by the State agency if it is delivered by State agency staff or an agent of the State, including a foster parent, group home staff, or child care institution staff. The service is also provided by the State agency if it is provided to the youth pursuant to a contract for such services between the State agency and a provider, public or private agency or any other entity, regardless of whether the contract includes funding for the particular service. Services that are paid for directly or indirectly by the State agency are included as well.
Question: My State agency partners with five other organizations and we pool our funds to improve services and outcomes for foster youth. My agency is the fiscal agent for all funds. Would we count all of the services provided through this partnership?
Answer: Yes. If a State CFCIP agency partially funds independent living services for youth through pooling resources with other State agencies, then we would consider that the State CFICP agency has "paid for or provided" these independent living services (73 FR 10341).
Question: If the State agency that administers CFCIP also administers TANF, food stamps, health family initiatives, etc., then if youth are served under any of these programs, does that count as a service under the NYTD data elements 20-33?
Answer: It depends. States are required to collect and report information on youth who receive an independent living service due to the CFCIP agency's commitment of funds or resources to provide the service. Services provided due to another State program's commitment of funds or resources do not count as a service provided by the State CFCIP agency. However, if a service is provided to the youth pursuant to a contract for such services between the CFCIP agency and a provider, public or private agency or any other entity, regardless of whether the contract includes funding for the particular service, then that service would be reported to the NYTD. Services that are paid for directly or indirectly by the CFCIP agency are included as well.
Question: Our State is in the process of finalizing a Memorandum of Agreement (MOU) between the State CFCIP agency and Student Conservation Association (SCA) to provide internships in the conservation career area. SCA will post some of their instructors onsite at our contracted work-to-learn programs. Does this meet the definition of an independent living service?
Answer: Based on the description, it is not clear whether this arrangement is paid for or provided by the State CFCIP agency. The regulation requires that if a service is provided to the youth pursuant to a contract for such services between the State CFCIP agency and a provider, public or private agency or any other entity, regardless of whether the contract includes funding for the particular service, then the service would be reported to the NYTD. In general, we do not view MOUs to be agency contracts for services or require for the service to be reported unless it is clear that a service under the MOU is provided or paid for by the State CFCIP agency.
Question: If the State CFCIP agency is also responsible for administering the State's juvenile facilities and provides title IV-E funds for the juvenile delinquents in the facilities with less than 25 beds, are these youth considered to be in foster care and therefore potentially part of the baseline population? Would they be potentially part of the served population if they received independent living services?
Answer: The answer to both questions is yes. The baseline population includes youth in foster care pursuant to 45 CFR 1355.20, which includes delinquent youth who receive title IV–E foster care maintenance payments. A youth is a part of the served population if the youth received at least one independent living service paid for or provided by the State during a reporting period.
Question: If a youth that is eligible for Chafee receives services through either TANF or Title XX for teen parent services or homelessness, would those services be counted in the survey data?
Answer: It is not clear whether the question refers to youth that are in the served population or the baseline and follow-up populations. For the served population, we are requiring States to collect and report information on youth who receive an independent living service due to the State agency's direct or indirect commitment of funds or resources to provide the service. Services provided due to another State program's commitment of funds or resources do not count as a service provided by the CFCIP agency. For the outcomes data collection, the State will report the youth's response to the survey questions. It is possible that a youth may report receiving services funded by TANF or Title XX in response to some of the outcome survey questions.
Question: Please clarify what constitutes a "service." If a foster parent helps a youth write a résumé, would that count as providing the independent living service "career preparation" (data element 23)? Would it make a difference whether a foster parent spent two minutes explaining the purpose of a résumé or three hours helping a youth write a résumé? Does the service have to be curriculum-based?
Answer: Each State determines what services are included in their Independent Living Program and we have not regulated a minimum timeframe or curriculum-basis for reporting a service to NYTD. Therefore, to the extent that foster parents, as agents of the State agency, provide training or other services described in the independent living services data elements (data elements 20-33) regardless of whether these services are curriculum-based or simply provided in the home by a foster parent, States may report "yes" for data elements 20-33 as appropriate.
Question: Can one independent living service paid for or provided by the State CFCIP agency be counted more than once if it meets the definition of more than one independent living service data element?
Answer: It is possible that one specific independent living service may be reported in more than one service category. We did not regulate how States should decide on whether to report a service in more than one data element, but strongly suggest that the State consider the primary purpose of the service in deciding whether to report a service for more than one data element. For example, if a youth attends a class that spends an equal time on housing education and home management (data element 26) and on health education and risk prevention (data element 27), then the State could report that the youth received services under both service categories. If a youth attends a class that primarily covers budgeting and financial management (data element 25) but also briefly discusses housing education and home management (data element 27), then we expect that the State will report this service only in the budgeting and financial management category.
