Changes CW Policy Manual

Children's Bureau, Child Welfare Policy Manual

Section 8.1H Title IV-E, Administrative Functions/Costs, Training (Click to access electronic source)

Question 21 (NEW 12/02/2016)

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?

Why we think this is important:

This is of particular note because the terminology used in the answer provides greater clarify on the types of specific training activities (topics) that are considered eligible for Federal Funding Participation (FFP).

Answer:

There are many protective factors that help to minimize risk to children and promote healthy child development. Training and providing information to title IV-E child welfare staff and foster/adoptive parents and others on such factors are allowable title IV-E training topics. Such training topics include, but are not limited to:

• Evidence-based practice: Training on the importance of using evidence-based techniques for case planning and modifying agency culture to support and sustain evidence-based practice.

• Screening and assessment: How to use of screening and assessment tools to develop the child’s case plan.

• Protective factors: Introduction to the concept of risk and protective factors and prevention; effective strategies for prevention; overview of strategies to target and encourage development of protective factors.

• Resilience: Strategies for minimizing the traumatic experience of placement(s) for children, including facilitating attachment and promoting stable relationships.

• Relational competence: An overview of the role of relational competence in family relationships.

• Child social and emotional development and well-being: Principles of child growth and social, emotional, physical, and intellectual development.

• Trauma: An overview of trauma, including definitions, key terms related to trauma and the long term impact of trauma experiences; the ways that trauma may impact children’s functioning and well-being at various stages of development; the impact of secondary trauma on caregivers and providers; general descriptions of effective treatments and strategies for addressing traumatic reactions and restoring developmentally appropriate functioning.

• Cultural competence: How to assess and serve the needs of children without bias and ensure their safety, including how to parent youth struggling with issues related to sexual orientation, gender identity and/or gender expression.

However, training on treating conditions is not allowable as a title IV-E training topic because such training supports the delivery of social services. Also, please note that all title IV-E training activities and costs must be included in the title IV-E agency's training plan for title IV-B and properly cost allocated to benefiting programs using the appropriate eligibility rate or similar method. Please see Child Welfare Policy Manual section 8.1H Q/A#8 for more information on allowable training topics.

Source/Date: 05/22/2012

Legal and Related References: Social Security Act ¿ section 474(a)(3)(B)

Question 22 (NEW 12/02/2016)

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?

Why we think this is important:

This is of particular note because it expands the post-graduation placement options for BSW/MSW stipend students.

Answer:

Yes. A title IV-E agency may claim title IV-E administrative costs for these individuals at the 50% FFP rate in accordance with section 474(a)(3)(E) of the Act because it is in line with the proper and efficient administration of the title IV-E program. The use of title IV-E for educational stipends or other allowable training costs for such prospective contract staff to perform title IV-E administration should enhance the quality of the title IV-E workforce as well as the associated case planning and management work in title IV-E programs. States may claim such costs to the extent allocable and in accordance with an approved cost allocation plan; tribes may claim such costs to the extent allocable and in accordance with an approved cost allocation methodology. Such costs may not be claimed at the 75% FFP rate. A title IV-E agency must include the basis for so allocating in its title IV-B training plan.

The title IV-E agency may claim reimbursement for stipends to train persons preparing for employment with a private agency as described above, under the following conditions and limitations:

(1) Persons preparing for employment with a private agency under contract with the title IV-E agency to perform title IV-E administrative activities are pursuing educational programs approved by the title IV-E agency;

(2) Persons preparing for employment with a private agency under contract with the title IV-E agency to perform title IV-E administrative activities are committed to work for a title IV-E contracted private agency for a period of time at least equal to the period for which financial assistance is granted if employment is offered within 2 months after training is completed;

(3) The title IV-E contracted private agency offers the individual preparing for employment a job upon completion of training unless precluded by contractual provisions or other circumstances beyond the agency's control; and if such agency is no longer operating under a title IV-E contract or cannot offer the individual employment, the title IV-E agency will either identify another title IV-E contracted agency to offer employment or release the individual from his or her commitment;

(4) The title IV-E agency keeps a record of the employment of persons trained. If the persons are not employed by a title IV-E contracted private agency, the record specifies the reason for non-employment;

(5) The title IV-E agency evaluates the training programs; and

(6) Any recoupment of funds by the title IV-E agency from trainees failing to fulfill their commitment under this section shall be treated as program income and shall be deducted from total administrative costs for the purpose of determining net costs for FFP.

Source/Date: December 2, 2016

Legal and Related References: Social Security Act § 474(a)(3)(E); 45 C.F.R. 235.63(b)

Updates to Existing Questions:

Question 1 (updated 11/02/2016)

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)?

Why we think this is important:

This is of particular note as costs previously noted as "not allowable" in the 3rd paragraph are now included as "matchable".

Prior answer (07/23/2007 - 11/01/2016)

Costs matchable as training expenditures under this provision may include: (1) travel, per diem, tuition, books and registration fees for trainees; (2) salaries, fringe benefits, travel and per diem for staff development personnel assigned to training functions to the extent time is spent performing such functions; (3) salaries, fringe benefits, travel and per diem for experts outside the agency engaged to develop or conduct training programs; and (4) costs of space, postage, training supplies, and purchase or development of training material. Costs not allowable for trainees under this provision include salaries and fringe benefits.

Current Answer:

Section 474(a)(3)(A) of the Social Security Act (the Act) provides that States and Tribes with plans approved under title IV-E shall be entitled to Federal matching funds for the proper and efficient administration of the plan in the following proportions of total amounts expended: 75 percent for the training (including both short-term training and long-term training at educational institutions, through grants to the institutions or by direct financial assistance to students enrolled in such institutions) of personnel employed or preparing for employment by the title IV-E agency or by the local agency administering the title IV-E plan; and 474 (a)(3)(B) of the Act provides for the short-term training of current or prospective foster or adoptive parents or relative guardians, the members of the staff of State or Tribal-licensed or approved child care institutions providing care to foster and adopted children receiving assistance under this part and members of the staff of abuse and neglect courts, agency attorneys, attorneys representing children or parents, guardians ad litem, or other court-appointed special advocates representing children in proceedings of such courts, in ways that increase the ability of such current or prospective parents, guardians, staff members, institutions, attorneys and advocates to provide support and assistance to foster and adopted children, and children living with relative guardians whether incurred directly by the State or by contract.*

The regulations at 45 CFR 1356.60(b) and (c) specify what is considered a training cost and what is considered an administrative expense under title IV-E. Section 1356.60(c) explains that the State's cost allocation plan shall identify which costs are allocated and claimed under title IV-E. Tribal title IV-E agencies must identify which costs are allocated and claimed under title IV-E in the Tribe's cost allocation methodology (CAM) (see ACYF-CB-PI-10-13). With regard to costs of educational programs (approved by the title IV-E agency) leading to a baccalaureate or graduate degree, the regulations clearly indicate that training to prepare persons who are employed or about to be employed by the title IV-E agency administering the title IV-E plan can include such long-term training. Grants to the institution or to the person attending the institution are reimbursable at a Federal matching rate of 75 percent. (See 45 CFR 1356.60 (b)(1)(i), 235.63 (c) and 235.64 (c) for further clarification.)

Costs matchable as training expenditures at 75% FFP under this provision may include: (1) salaries, fringe benefits, travel, per diem, tuition, books and registration fees for title IV-E agency trainees in allowable short-term or long-term training (regardless of the duration of the training) for the time period the employee is actually participating in training; (2) salaries, fringe benefits, travel and per diem for staff development personnel assigned to training functions to the extent time is spent performing such functions; (3) salaries, fringe benefits, travel and per diem for experts outside the agency engaged to develop or conduct training programs; (4) travel, per diem, tuition, books and registration fees for foster parents and other persons identified under section 474(a)(3)(B) of the Act in short-term training; and (5) costs of space, postage, training supplies, and purchase or development of training material.

Federal regulations at 45 CFR 1356.60 (b)(2) require that all training activities and costs funded under title IV-E must be included in the title IV-E agency's training plan for title IV-B. Title IV-E agencies will be reimbursed under title IV-E for such costs only if the activities and costs are described and included in the jointly developed and approved title IV-B plan.

All training costs must be allocated to the benefiting title IV-E foster care, adoption assistance or guardianship assistance program and other State/Tribal/Federal programs consistent with the State's CAP or Tribe's CAM and in such a manner as to ensure that the cost is charged to the program in accordance with the relative benefits that the program receives from the training. Title IV-E agencies may determine the manner in which they allocate costs but must do so in accordance with the cost principles delineated at 45 CFR Part 75 Subpart E.

* Beginning October 1, 2008, section 474(a)(3)(B) of the Act was expanded to authorize FFP for the short-term training of additional trainees. The additional trainees are: relative guardians (if the title IV-E agency has opted per section 471(a)(28) to offer a guardianship assistance program), members of licensed or approved child welfare agencies providing services to children receiving assistance under title IV-E, members of the staff of abuse and neglect courts, agency attorneys, attorneys representing children or parents, guardians ad litem, or other court-appointed special advocates representing children in the proceedings of such courts in ways that increase their ability to provide support and assistance to title IV-E eligible children. FFP is available for the additional categories of trainees in increasing rates rising to 75% in FY 2013. The specific rates of FFP are 55% in FY 2009, 60% on FY 2010, 65% in FY 2011, 70% in FY 2012 and 75% each FY thereafter.

Note: This answer previously referenced OMB Circular A-87 and 2 CFR Part 225. 45 CFR Part 75 supersedes OMB Circular A-87 and 2 CFR Part 225 effective December 26, 2014 (79 FR 75871, Dec. 19, 2014).

Question 15 (updated 11/02/2016)

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?

Why we think this is important:

This is of particular note because the terminology used in the answer provides greater clarify on the types of specific situations in which a current staff may be considered as a "new employee" for training purposes.

Current Answer:

Yes, the State may claim title IV-E training funds at the 75 percent match rate to train through an initial in-service training program current State agency employees who accept employment in a different position in the title IV-E agency, such as from a caseworker position to a supervisory position or from one program area to another such as from foster care to adoption. The training must meet the definition of initial in-service training, however, and therefore be intensive, task-oriented and last for at least one week as specified in the regulations at 45 CFR 235.61(a) and 235.64(b)(1).

While the definition of in-service training specifically indicates that such training is for "new employees," it is reasonable, within the context of this definition, to treat someone in a new position in the State agency as a "new" employee for training purposes. The employee's training needs are similar to those of a new employee. If the training is associated with the administration of an approved title IV-E State plan requirement and intended to give the staff the specific skills required to perform title IV-E foster care and adoption functions, it may be matched at the 75 percent FFP rate. Training focused on the development of supervisory skills and tasks related to supervision (generic skills training) may be matched at the rate of 50 percent FFP. The training activities and costs must be included in the State agency's training plan for title IV-B.

Question 16 (updated 12/02/2016)

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?

Why we think this is important:

This is of particular note because the terminology used in the answer provides greater clarify on what is considered "initial in-service training", both in terms of caseload carrying and degree of supervision for the employee undergoing initial in-service training.

Current Answer:

Intensive training is training that is highly concentrated and intended to significantly strengthen and increase the employee's knowledge. Given these parameters, an employee could not participate in intensive training while maintaining a full caseload. There is not enough time in a regular work week to accommodate both maintaining a full caseload and participating in intensive training, whether classroom or on-the-job training is provided. The majority of the employee's time during intensive training is dedicated to training activities. An intensive training program may encompass an on-the-job component in which an employee maintains a partial caseload provided in a structured learning environment with a higher degree of supervision than a regular employee would experience.

As specified in the regulations at 45 CFR 235.64, Federal financial participation is available at 75% for employees in initial in-service training for at least one week for salaries, fringe benefits, travel and per diem to the extent that the training is related to the examples of allowable administrative costs necessary for the administration of the foster care program at 45 CFR 1356.60(c)(2).

Each State's title IV-B training plan must accord with the definition of in-service training at 45 CFR 235.61(a). In addition, course descriptions, activities and costs must be described in the State's approved training plan for title IV-B. Training that benefits the overall administration of a State's foster care or adoption assistance program, and not only children eligible under title IV-E, must be allocated to all benefiting Federal and State programs in accordance with 45 CFR Part 75 Subpart E cost principles and an approved cost allocation plan.

Source/Date *09/05/07 (revised 11/2/2016)

Legal and Related References: 45 CFR Part 75, 235.64, 235.61(a) and 1356.60(c)(2); 79 FR 75871, Dec. 19, 2014.; 81 FR 3022, Jan. 20, 2016 & CFR Part 75 Subpart E cost principles and an approved cost allocation plan.