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Title IV-E. Quality Assurance and Accountability (QAA). QAA Team: Program Manager 2 Program Supervisors 5 Regional Teams Central – 5 Program Consultants Piedmont – 5 Program Consultants Northern – 5 Program Consultants Eastern – 4 Program Consultants Western – 4 Program Consultants.
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Quality Assurance and Accountability (QAA) • QAA Team: • Program Manager • 2 Program Supervisors • 5 Regional Teams • Central – 5 Program Consultants • Piedmont – 5 Program Consultants • Northern – 5 Program Consultants • Eastern – 4 Program Consultants • Western – 4 Program Consultants
QAA Reviews • The QAA team conducts two types of agency reviews to ensure proper use of IV-E funding • Child Welfare Case Reviews • Quarterly review of every agency • Reviews all new foster care funding cases to ensure proper IV-E eligibility determination • IV-E Ongoing Reviews • Once a year for every agency • Reviews all ongoing IV-E eligible youth for the agency • Verifies proper use of IV-E funds for services provided
Child Welfare Case Reviews (CWCR) • 10 CPS Referrals, 5 CPS Ongoing, 5 Foster Care Cases • Eligibility Determination requirements: • Required Judicial Language • Contrary to the Welfare • Reasonable Efforts to Prevent Removal • AFDC Relatedness • Income/Resources/Assistance Unit • Removed from a Specified Relative • Deprivation • Citizenship or Qualified Alien Status • Age
Ongoing Reviews • IV-E Ongoing Requirements: • Age • Approved Placement • SSI Payments • Judicial Requirements: • Annual Judicial Reviews • Voluntary Placement Language • Proper completion and documentation of IV-E payments • Clothing Allowance • VEMAT • Child Care • Transportation
OASIS Documentation and Agency Practice • OASIS: • Child Information • Eligibility Determination: IV-E vs CSA • Placement Information • Court Information • Maintenance Rates • Agency Practice • Eligibility File • All documentation is in file • All documentation is in the correct section of the file
Total Errors vs Cases with an Error • Total Errors • Total number of errors found • State level, regional level, and agency level • Number of cases with an error • Federal Case Error • Number of cases which had an error regardless of the amount of errors for that case • Example: • One case had three errors found: 2 ineligible payments and 1 safety requirement finding • 3 total errors but only 1 Federal Case Error
2019 Federal Review • On-side Review – September 23rd through the 27th, 2019 • Period Under Review – October 1, 2018 through March 31, 2019. • 80 cases randomly selected (20 oversample) • The cases that are determined for the review are selected from the Adoption and Foster Care Analysis and Reporting System (AFCARS). • Any case that had at least one IV-E foster care maintenance payment made during the PUR is eligible to be reviewed.
Substantial vs Non-Substantial Compliance • During the primary review, out of the 80 cases reviewed the State is allowed up to four federal case errors. • If five or more federal case errors are found during the primary review, the State will not be in substantial compliance • State must develop a Program Improvement Plan (PIP) • State will undergo a secondary review following the completion of the PIP.
Secondary Review • 150 cases are pulled from a new Period Under Review • State must not exceed the compliance threshold of more than 10 percent in both the federal case error rate and the dollar error rate. • If not in compliance with a secondary review, a disallowance is assessed on the basis of the agency’s total foster care population for the 6 month PUR.
QAA Preparation for IV-E Review • Meetings with federal government have begun • Determine readers for the review • Prepare and share all policy related to IV-E • Final Sample List • Immediately notify the agencies – request SPR information • Coordinate a time for our QAA consultants to review case • All cases will end up at CRO for the week of the review
Agency Preparation for Upcoming IV-E • Every agency provided a list of their IV-E eligible youth during the PUR • AFCARS Report for 10/01/18 – 03/31/19 • OASIS based – IV-E eligibility indicator • Completed internal IV-E review of cases • Provided a review tool • Fill out and return a certification that the agency read the cases • Make necessary adjustments to any ineligible IV-E payments found • Key areas of focus
Safety Requirements • 4.10% of all cases were found to have a safety requirement error • Checklist for provider approval and re-approval dates • Inconsistent or inaccurate • Pulling two resource home files during the review • Verifying that the checks were completed and in the file • Verifying the dates match the dates on the checklist • Proper documentation for LCPA homes in eligibility file • LCPA license • Certificate of Approval of the home • State Form Letter – CRC and Registry Checks
Emergency Approvals • Youth can be temporality placed for up to 60 days. • IV-E can begin the first day of the month in which all federal safety requirements are met: • Fingerprint background results • Central Registry verifications • All requirements have to be met within the 60 day and the license of approval issued. • Example: 60 day emergency approval 09/23/18 – 11/22/18 • License of Approval begin date: 11/27/18 – 11/27/21 • IV-E cannot pay from 11/23/18 – 11/26/18
Emergency Approvals Best Practice • Emergency Approval for title IV-E Reporting • Available on the Fusion IV-E website • Needs to be completed and put in eligibility file
ICPC Foster Homes • Forms 100 A and B should be in eligibility file • These forms do not have information regarding background checks • Home Study is not required to be in the eligibility file • Should have the information regarding background checks • QAA consultant will ask to see Home Study to verify checks • If checks are not in the Home Study • Agency will need to work with ICPC and the other state to get documentation of background checks
Safety Requirements Best Practice • Good working relationship between resource home unit and eligibility unit • Tracking each resource home to know when background checks are due • Spreadsheets • Shared Calendar • Sharing these tracking tools with resource and eligibility staff creates another layer of internal quality control
Ongoing Review Errors • Ineligible IV-E Expenditures • Most common error found during ongoing reviews • 18.74% of all cases reviewed had an ineligible IV-E expenditure • No longer accepting corrections on site • While this is the highest occurring error, this is the easiest error that can be addressed within the agency.
Supplemental Clothing Allowance • Most common issue is the lack of documentation to support the purchase of clothing. • Receipts need to be in eligibility file to support payment • Shipping and handling is a non-reimbursable cost • Shall not exceed the designated rate • Regardless of IV-E, CSA, or combination of the two • It should be used by May 31st of each year • The date the bill is paid determines the fiscal year in which the payment is counted when it comes to fiscal year end
Supplemental Clothing AllowanceBest Practice • IV-E Quick Reference Guide: • Internal Clothing Tracking Tool • Ensure the agency does not go over • Track which youth still has money available at the end of the fiscal year
December DYK - Definitions and Details: Title IV-E Allowable Costs • Definitions and Details: Title IV-E Allowable Costs • Available on the Fusion IV-E website
Prorating Foster Care Rates • Common errors when prorating: • Paying the entire month or incorrect amount of days • Rounding the daily rate to the incorrect amount • Payments begin = date the child is placed in the home • Payments end = date prior to the removal date of that home
Prorated Foster Care Rates • IV-E Quick Reference Guide • Available on the Fusion IV-E website under resources
January DYK – VEMAT Scores of 36 • Common and costly • VEMAT scores 28 or above must be reassessed every 3 months • VEMAT score of 36 due solely to severe medical and physical needs can be assessed annually • Physicians statement • Detailing the child’s condition • Statement that the condition is unlikely to improve • Obtained within three months of the initial VEMAT Assessment score of 36 • New statement must be obtained along with the next annual VEMAT Assessment
January DYK – VEMAT Scores of 36 • If the agency does not receive the physician’s statement prior to the expiration date of the first VEMAT with the score of 36, then title IV-E funds should cease beginning the first day of the following month. • Example: VEMAT effective 02/01/18 – 04/30/18 • Physicians statement not obtained prior to 04/30/18 • IV-E funds cannot be used beginning 05/01/18 • If the agency receives a physician’s statement after the expiration of the VEMAT, title IV-E funds can be used again beginning the first day of the month following receipt of the statement for the remainder of the year of approval
VEMAT Broadcast and Form • “VEMAT Administration with a Physician's Statement” • 05/13/19 Broadcast
VEMAT Best Practice • Excel spreadsheet of all VEMATs and due dates • Shared calendar with all VEMAT due dates • Eligibility workers can serve as a secondary level of internal quality assurance. • Any questions on the quality of the physician’s statement should be sent to regional permanency consultant
Best Practice of Local Agencies • Internal Reviews • Benefit Specialist to conduct quarterly reviews of eligibility file and OASIS • Identify areas in need of improvement and implement reviews • Technical Assistance • QAA Consultants • Agency to agency collaboration • Communication within the agency • Services, benefits, finance, and resource home staff
Role of Finance Staff in IV-E • Knowing which youth are IV-E eligible • Access to OASIS • Easily accessible database of IV-E eligible youth • Knowing which payments can be paid from IV-E • Knowing IV-E rules surrounding eligible payments • Tracking of clothing allowances • Communication • Notice of Action
Updated IV-E Application/Evaluation • Updated IV-E Application and Evaluation has been posted to Fusion • An e-mail went out via our DYK distribution list with the application and description of changes
Title IV-E Training • New IV-E Training is offered every month • Each training should be posted to the Learning Center six months prior to training taking place • Online IV-E modules are available on Learning Center and are prerequisites for the in class training
Contact Information • Morgan Nelson – QAA Program Manager • Morgan.nelson1@dss.Virginia.gov • 804-726-7521 • Matthew Lafrinere – QAA Program Supervisor • Matthew.lafrinere@dss.Virginia.gov • 804-351-6203