IV-E Policy Changes: Candidacy Definition and Admin Claiming for In-Home Services and Foster Care
Summary
This webinar clarifies the definition of candidacy for foster care, focusing on its application to claiming CPS in-home services. It details when 4E funds can be claimed for administrative costs and worker time for children in foster care, emphasizing that the Family First Act's 14-day maintenance claiming limit does not affect administrative claiming. Key points covered include general rules for administrative cost claims for case management of foster children, exceptions, and correct usage of Field 55 on the DSS 5094 form, especially concerning extended foster care and trial home visits. The session aims to help viewers maximize reimbursements and ensure accurate data reporting.
Key Insights
4E is a series of protections and a funding source.
Beyond financial reimbursement for services like room and board, 4E mandates protections for children and parents.
Documentation of candidacy requires specific evidence.
Acceptable documentation is a written case plan, specifically the In-Home Family Services Agreement (DSS 5239), developed collaboratively with the family, indicating foster care as the planned arrangement absent preventative services.
Risk of maltreatment alone is not sufficient for candidacy.
While risk assessments can point towards candidacy, they are not enough on their own. Candidacy requires documenting the risk of entering foster care absent preventative services.
Direct conversation with the family about risk is crucial.
A child welfare worker must have a direct, honest, and non-threatening conversation with the family about the serious risk of foster care entry without preventative services.
The Family First Act's 14-day limit does not affect admin claiming.
Even after the two-week limit for maintenance reimbursement in certain licensed group settings, administrative costs can continue to be claimed for 4E if the facility remains licensed and the child eligible.
4E reimbursement is uncapped.
Unlike capped funds, 4E allows for unlimited reimbursement as long as costs are appropriate (child eligible, placement approved), similar to a checking account that doesn't run out of funds.
States must develop 4E plans to meet federal requirements.
These plans outline how states will provide mandated protections and must be updated as regulations change, often due to legislative acts.
Definition of candidacy for Title 4E.
A child is considered a candidate if at imminent or serious risk of removal from the home, with evidence of county agency efforts to prevent or pursue removal.
DSS 5010A is not sufficient for candidacy documentation.
While the DSS 5010A may address similar items, only the completed and signed DSS 5239 serves as acceptable documentation for supporting candidacy.
Content of Page 10 documentation.
This section requires clear, concise language describing the specific reasons the child is at imminent risk of removal if preventative services are not provided, alongside the services offered to address that risk.
Claiming can begin on the first day of the month requirements are met.
If candidacy requirements are met mid-month, 4E claiming for administrative costs can retroactively cover the entire month.
Candidacy must be re-documented every six months.
A written justification is required by the federal government to retain candidacy beyond six months, often aligned with case plan updates that continue to identify risks and outline preventative services.
Claiming stops when candidacy requirements are no longer met.
This includes situations where the documented reasons for risk no longer apply, or if the six-month recertification is missed, potentially leading to payback liability.
Discomfort with the conversation versus factual inaccuracy.
A worker's discomfort having the conversation is a supervisory issue, but if it's factually untrue to state foster care is the plan absent services, the child may not meet the candidacy definition.
In-home services can be provided even if a child is not a candidate.
Statute requires in-home services in certain situations, but if the child is not a candidate, these services cannot be coded to 4E; an alternative program code must be used.
Alternative program codes for non-candidate services.
The appropriate alternative program code is one for which the child is eligible and for which the county still has funds available, referencing Appendix 3.4 and day sheet training webinars for guidance.
Parental involvement in case planning is key.
Ideally, both parents should be involved in signing the case plan if they are both relevant to the issues. If only one parent signs, particularly the non-offending parent, it can weaken the claim. Refusal to sign can be managed with a statement of participation.
General rules for 4E administrative claiming in foster care.
A child must be fully 4E-eligible and in an approved, licensed foster care facility with an ID number issued by NCDSS for at least one day of the month to claim 4E admin costs for that entire month.
General rule: 4E admin claiming requires eligibility and licensed placement.
Administrative expenses cannot be claimed to 4E for a foster child not determined 4E-eligible or who hasn't been in an NCDSS-licensed placement for at least one day of the month.
Examples of 4E admin claiming scenarios.
Examples illustrate that if a child meets eligibility and placement criteria for at least one day, 4E admin can be claimed for the entire month, even with subsequent moves to non-licensed placements.
The DSS 5094 and its role in CPPS.
The DSS 5094 is the form used to enter data into the Child Placement and Payment System (CPPS), which tracks funding source eligibility and state/federal data for reimbursement.
Field 55 tracks the funding source for the child's cost of care.
This field is critical for tracking reimbursement pots and calculating the state's penetration rate for federal data.
Sections
Webinar Introduction and Logistics
Welcome and introduction to the webinar on 4E policy changes.
The webinar is developed through funding from the Division of Social Services by the Family and Children's Resource Program at the UNC School of Social Work.
Handouts and slide materials are available for download.
Attendees can access slide handouts via a file share box provided during the webinar for review during or after the presentation.
Key goals of the webinar are outlined.
Goals include explaining foster care candidacy for CPS in-home services, proper claiming of 4E funds for administrative costs and worker time, understanding the Family First Act's impact on maintenance vs. administrative claiming, and correct use of Field 55 on the DSS 5094.
Communication channels for the webinar.
Attendees can use the chat pod to communicate with presenters and technical support. There is no microphone capability due to the large number of attendees. Questions will be monitored and addressed during the presentation or in a follow-up FAQ document.
Follow-up actions for questions and recordings.
A follow-up FAQ document will capture all questions asked, and the recorded webinar will be posted on ncswlearn. The FAQ document will be sent to all registered participants.
Interactive tools for engagement.
Attendees can use the icons on the top toolbar, such as the hand-raised icon, to request presenters to speak louder, slow down, or offer applause.
Audience understanding of foster care candidacy is assessed.
A poll is used to gauge the audience's understanding of determining candidacy for foster care, with most participants indicating a level of 'three'.
Introduction of presenters and support staff.
Rick Zuckman hosts, with technical help from Philip Armfield and question capture by John McMahon. Presenters include Beth Reilly from the Division of Social Services and Evan Friedel from UNC.
Background and Definition of Title 4E
Title 4E was created in 1980 as part of the Social Security Act.
The federal government has shared foster care costs since 1961, but 4E codified the funding source in 1980 to provide foster care assistance for children who would have been eligible for AFDC.
4E is a series of protections and a funding source.
Beyond financial reimbursement for services like room and board, 4E mandates protections for children and parents.
4E reimbursement is uncapped.
Unlike capped funds, 4E allows for unlimited reimbursement as long as costs are appropriate (child eligible, placement approved), similar to a checking account that doesn't run out of funds.
States must develop 4E plans to meet federal requirements.
These plans outline how states will provide mandated protections and must be updated as regulations change, often due to legislative acts.
Recent legislative changes impacting 4E.
Significant changes include those from MEPA, ASFA, Fostering Connections Act, Increasing Adoptions Act, and the Family First Prevention Services Act (2018).
Family First Prevention Services Act (2018) affects group home placements.
For new group home placements after October 1, 2021, 4E reimbursement for maintenance costs is limited to two weeks, even for 4E-eligible children.
North Carolina reviewed 4E policies in light of recent changes.
The state used the opportunity provided by FIPSA to review its overall 4E plan, fiscal policies, practice policies, and eligibility related to candidacy in in-home services.
Candidacy for Foster Care and Documentation
Definition of candidacy for Title 4E.
A child is considered a candidate if at imminent or serious risk of removal from the home, with evidence of county agency efforts to prevent or pursue removal.
Documentation of candidacy requires specific evidence.
Acceptable documentation is a written case plan, specifically the In-Home Family Services Agreement (DSS 5239), developed collaboratively with the family, indicating foster care as the planned arrangement absent preventative services.
DSS 5010A is not sufficient for candidacy documentation.
While the DSS 5010A may address similar items, only the completed and signed DSS 5239 serves as acceptable documentation for supporting candidacy.
Separate documentation is required for each child in a family.
Page 10 of the DSS 5239, which evidences candidacy, must have a separate copy for each child, as eligibility is determined individually, even within the same household.
Content of Page 10 documentation.
This section requires clear, concise language describing the specific reasons the child is at imminent risk of removal if preventative services are not provided, alongside the services offered to address that risk.
Claiming can begin on the first day of the month requirements are met.
If candidacy requirements are met mid-month, 4E claiming for administrative costs can retroactively cover the entire month.
Candidacy must be re-documented every six months.
A written justification is required by the federal government to retain candidacy beyond six months, often aligned with case plan updates that continue to identify risks and outline preventative services.
Claiming stops when candidacy requirements are no longer met.
This includes situations where the documented reasons for risk no longer apply, or if the six-month recertification is missed, potentially leading to payback liability.
Risk of maltreatment alone is not sufficient for candidacy.
While risk assessments can point towards candidacy, they are not enough on their own. Candidacy requires documenting the risk of entering foster care absent preventative services.
Direct conversation with the family about risk is crucial.
A child welfare worker must have a direct, honest, and non-threatening conversation with the family about the serious risk of foster care entry without preventative services.
Discomfort with the conversation versus factual inaccuracy.
A worker's discomfort having the conversation is a supervisory issue, but if it's factually untrue to state foster care is the plan absent services, the child may not meet the candidacy definition.
In-home services can be provided even if a child is not a candidate.
Statute requires in-home services in certain situations, but if the child is not a candidate, these services cannot be coded to 4E; an alternative program code must be used.
Alternative program codes for non-candidate services.
The appropriate alternative program code is one for which the child is eligible and for which the county still has funds available, referencing Appendix 3.4 and day sheet training webinars for guidance.
Case plan updates are critical for continued candidacy.
Updates to Page 10 of the case plan are necessary to identify ongoing issues that maintain a child's candidacy status for 4E eligibility.
Parental involvement in case planning is key.
Ideally, both parents should be involved in signing the case plan if they are both relevant to the issues. If only one parent signs, particularly the non-offending parent, it can weaken the claim. Refusal to sign can be managed with a statement of participation.
4E Fund Reimbursement for Administrative Costs
General rules for 4E administrative claiming in foster care.
A child must be fully 4E-eligible and in an approved, licensed foster care facility with an ID number issued by NCDSS for at least one day of the month to claim 4E admin costs for that entire month.
The Family First Act's 14-day limit does not affect admin claiming.
Even after the two-week limit for maintenance reimbursement in certain licensed group settings, administrative costs can continue to be claimed for 4E if the facility remains licensed and the child eligible.
Examples of 4E admin claiming scenarios.
Examples illustrate that if a child meets eligibility and placement criteria for at least one day, 4E admin can be claimed for the entire month, even with subsequent moves to non-licensed placements.
SSI use does not preclude 4E admin claiming.
If SSI is used for the maintenance payment, 4E maintenance cannot be claimed, but 4E admin costs can still be coded (e.g., 109z) if the child is in a licensed placement.
Interstate compact placements in licensed facilities are eligible for admin claims.
If a 4E-eligible child is in a licensed placement in another state via the interstate compact, 4E admin reimbursement for worker case management is permissible.
General rule: 4E admin claiming requires eligibility and licensed placement.
Administrative expenses cannot be claimed to 4E for a foster child not determined 4E-eligible or who hasn't been in an NCDSS-licensed placement for at least one day of the month.
Exceptions to the general claiming rule exist.
These exceptions are designed to help maximize reimbursement and include situations like a child being on runaway status or placed in an unlicensed relative home with a pending licensure application.
4E admin can be claimed for children on runaway status.
If diligent efforts are being made to find the child, and case management activities continue as if the child were present, 4E admin time can be claimed.
Unlicensed relative home exception for pending licensure.
A 4E-eligible child in an unlicensed relative's home is eligible for 4E admin claiming if an application for licensure or approval is pending and the relative is actively involved, for a maximum of 12 months.
Exception for the month prior to moving to licensed placement.
The entire month prior to a child moving from an ineligible facility to a licensed placement can be claimed as 4E admin, even if only in a licensed placement for part of the subsequent month.
Trial home visits have specific 4E admin claiming rules.
Generally not eligible, but exception exists if the 4E-eligible child spends every day of a federal fiscal quarter in a court-ordered trial home placement.
Federal fiscal quarters are specific timeframes.
These quarters are Oct 1-Dec 31, Jan 1-Mar 31, Apr 1-Jun 30, and Jul 1-Sep 30. Meeting the trial home visit requirement necessitates continuous placement within one of these full quarters.
Using Field 55 on the DSS 5094
The DSS 5094 and its role in CPPS.
The DSS 5094 is the form used to enter data into the Child Placement and Payment System (CPPS), which tracks funding source eligibility and state/federal data for reimbursement.
CPPS closure date for updates.
Updates to the DSS 5094 affect the service month payment until the 19th of the following month. Changes made after this date impact a future service month.
Field 55 tracks the funding source for the child's cost of care.
This field is critical for tracking reimbursement pots and calculating the state's penetration rate for federal data.
Using the '4E' box (Field 55) for children under 18.
Enter 'X' if making a maintenance payment for a 4E-eligible child in an NCDSS-licensed placement, unless SSI funds are used for all or part of the payment, in which case the box is left blank.
Using the '4E' box for licensed group homes (under 18).
An 'X' is entered if a maintenance payment is made for a 4E-eligible child in an NCDSS-licensed group home, regardless of placement date, as the system calculates the two-week limit for new placements.
Using the 'T' box (Field 55) for T-Eligible children.
Enter 'X' for a T-eligible child not eligible for 4E and without SSI. Field 54 requires a begin date; an incorrect date impacts reimbursement from state SFHF funds initially.
State funds via 'State' box (Field 55).
Enter 'X' if the child is not eligible for 4E or T, or if a 4E-eligible child's payment is covered by SSI (for amounts exceeding SSI coverage).
Field 55 for Extended Foster Care (18-21 program).
Use 'E' for 4E-eligible young adults and 'E' for those not 4E-eligible (determined by 5120e or NC Fast eligibility process).
The '4E Admin Eligible' box (part of Field 55).
This box is an indicator used to identify children eligible for administrative payments during the month, even if 4E wasn't used for maintenance, to accurately calculate the state's penetration rate.
When to check the '4E Admin Eligible' box.
Check if: 4E-eligible child's SSI is used for payments, a 4E-eligible child on runaway status from a reimbursable placement, a 4E-eligible child in an unlicensed relative home with pending licensure, or a 4E-eligible child in a court-ordered trial home placement for a full federal fiscal quarter.
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