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8.1H  TITLE IV-E, Administrative Functions/Costs, Training

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Question 1.  
 What costs can the title IV-E agency claim for Federal financial participation (FFP) to train title IV-E agency employees, foster parents, adoptive parents, relative guardians, employees of private child placing and child care agencies, and the other individuals listed in section 474(a)(3)(B) of the Social Security Act (the Act)?

Question 2.  
 May State agencies contract with another organization, such as a community college to conduct training on behalf of the State agency? This training would be considered State agency training, not educational institution training?

Question 3.  
 May the States fund adoptive parents' attendance at adoption conferences with title IV-E training funds?

Question 4.  
 May allowable costs include salary, travel and per diem for State agency program staff or State agency staff development unit staff conducting training of employees or foster parents?

Question 5.  
 Is title IV-E training limited to training related to foster care maintenance or can it be related to the entire provision of foster care including meeting the child's service needs? Since most training programs for foster parents discuss the "total" child, the hope would be the training costs would not need to be separated between title IV-E and title IV-B.

Question 6.  
 Prior to the on-site portion of a child and family services review (CFSR), the State members of the team must participate in a State team training. Can the costs related to such participation be claimed by the State at the 75 percent rate of Federal financial participation (FFP)?

Question 7.  
 The Departmental Appeals Board (DAB) found in Decision No. 1737 that States may claim FFP for allowable administrative costs paid with private funds that are donated to support specific activities. Does this finding mean that funds donated from a private source can be used to match Federal financial participation (FFP) at the 75% rate for title IV-E training?

Question 8.  
 What are the title IV-E training topics that the State may claim at the enhanced Federal financial participation rate under section 474 (a)(3)(A) and (B) of the Social Security Act and 45 CFR 1356.60(b)?

Question 9.  
 May the State claim title IV-E funds at the 75 percent match rate for any administrative activities that are directly related to carrying out the State agency¿s training initiatives?

Question 10.  
 May the State claim title IV-E administrative expenses at the 50 percent match on training topics not allowable at the 75 percent match rate?

Question 11.  
 What training topics are not allowable as either a training cost or an administrative cost under the title IV-E program?

Question 12.  
 Would you explain the cost-sharing or matching requirements for the title IV-E training program?

Question 13.  
 May a State claim title IV-E training funds at the 75 percent match rate for initial in-service training if there are gaps of days or weeks or longer when the newly hired staff is not receiving training either in the classroom or on the job?

Question 14.  
 May the State claim title IV-E training funds for the portion of the initial in-service training program that includes actual work experience?

Question 15.  
 May the State claim title IV-E training funds at the 75 percent match rate to train current title IV-E agency staff who are either promoted or transfer to another position within the agency, such as from caseworker to supervisor, under an initial in-service training program?

Question 16.  
 The regulations at 45 CFR 235.61(a) define initial in-service training as a period of intensive, task-oriented training to prepare new employees to assume job responsibilities. What is meant by "intensive?" Are there any circumstances whereby an employee can be considered to be participating in initial in-service training while maintaining a full caseload?

Question 17.  
 For what short-term training content may a title IV-E agency claim Federal financial participation (FFP) to train the categories of individuals specified in section 474(a)(3)(B) of the Social Security Act (the Act)?

Question 18.  
 May title IV-E agencies claim Federal financial participation (FFP) for the short-term training of judges under section 474(a)(3)(B) of the Act (the Act)?

Question 19.  
 Section 474(a)(3)(B) of the Social Security Act (the Act) permits States to claim short-term training costs for members of the staff of State-licensed or State-approved child welfare agencies providing services to children receiving title IV-E assistance. Is there a Federal definition of a State-licensed or State-approved child welfare agency?

Question 20.  
 Section 474(a)(3)(B) of the Social Security Act allows the title IV-E agency to claim as title IV-E expenditures the short-term training costs to train attorneys who represent children and their parents in such ways that increase the ability of the attorney to provide support and assistance to these children. Must the attorneys be employed by the title IVE agency in order for the title IV-E agency to claim the short-term training costs for these attorneys?

Question 21.  
 What are allowable title IV-E training topics related to the role of protective factors in healthy child development, such as resiliency; relational competence; child social and emotional development; trauma; cultural competence and related areas?

Question 22.  
 May a title IV-E agency claim title IV-E federal financial participation (FFP) for training costs on behalf of individuals who are preparing for employment with a private agency performing title IV-E administrative activities through a contractual arrangement with the title IV-E agency?



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