Child Welfare Information Gateway -Surge Support JEFO

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Within ACYF, CB plans, manages, coordinates, and supports child abuse and neglect prevention, and child welfare services programs. CB is responsible for assisting child welfare organizations by promoting continuous improvement in the delivery of child welfare services. CB programs are designed to promote the safety, permanency, and well-being of all children, including those in foster care, available for adoption, recently adopted, abused, neglected, dependent, disabled, or homeless, and to prevent the neglect, abuse, and exploitation of children.

CB has provided training, technical assistance, and capacity building services for several years.

These services build the capacities of States, Tribes, and Territories to meet Federal standards and requirements, improve child welfare practice, strengthen organizations and systemic functioning, and achieve better outcomes for children, youth, and families. CB competed the current contract and awarded contract HHSN316201200028W/75N98120F00004 in September 2020 for the selected vendor, ICF, Inc. Bi-lateral Modification P00004 was completed on 02/10/2021 for a supplemental change for PWS revisions. The 02/10/2021 modification did not change costs; however, there was an inclusion of surge support requirements in the PWS revision that upon issuance of surge requirement would result in additional financial consideration for those potential requirements should the government elect to obligate them.

Based upon CB’s current workforce landscape and ongoing projects/associated tasks to achieve the mission, CB is electing to obligate the surge requirements. The surge requirements will allow for the Child Welfare Information Gateway to mitigate the risks of CB not having consistent, reliable, and quality AFCARS 2020 data submissions around tribal children in care. Not providing technical assistance to tribes and states needing to report on the experiences of tribal children in adoption and foster care puts CB at risk of not adhering to Executive Order 86 FR 7009 which orders agencies to advance equity for those who have been historically underserved, marginalized, and adversely affected by persistent poverty and inequality. Without high quality data from the tribes, CB risks 1) being able to adequately respond to questions from Congress and other Federal departments and agencies; 2) failing to develop short and long-term budget projections and meaningful program planning, and trend analysis; 3) not identifying areas for technical assistance efforts, discretionary grants, research and evaluation, and regulatory change; and 4) assessing outcomes for children and families.

State and tribal title IV-E agencies are required to report AFCARS case-level information on all children in foster care and children who have been adopted with title IV-E agency involvement per §479 of the Social Security Act. The regulations were updated via the final rule published in May 2020 (85 FR 28410), hereafter referred to as AFCARS 2020, which altered the structure of the data, required two different files, and expanded the data to be reported. Title IV-E agencies that fail to meet the standards set forth in 45 CFR 1355.46 will be deemed out of compliance with AFCARS 2020 requirements and are subject to financial penalties in accordance with 45 CFR 1355.47. Title IV-E tribes were not required to submit the previous version of AFCARS, hereafter referred to as AFCARS 1993, and there were no financial penalties related to AFCARS 1993.

The Children’s Bureau was concerned that meeting AFCARS 2020 requirement would be particularly challenging to the ten title IV-E tribes, which struggle with staff turnover, inadequate information systems, XML acumen, and the necessary AFCARS technical expertise. In FY22 the Children's Bureau exercised a surge support task order to address the challenges. Task order deliverables included a readiness assessment, multiple interviews with direct title IV-E tribes, analysis of interview data, document reviews, and the development of a report that documented the overall technical assistance needs of the tribes.

As a result of the readiness assessment report, a suite of technical assistance options were created for and offered to the title IV-E tribes. Each tribe chose the technical assistance options, if any, they wanted to partake in. The goal of every option was a successful and compliant AFCARS 2020 submission before the deadline of May 15, 2023. The technical assistance options included: software review, building and testing XML, policies and forms review, ongoing quality review, data collection for jurisdictional transfers, and technical training.

Nine of the ten direct IV-E tribes received one or more of the technical assistance options and all but three tribes were able to become fully compliant with both the out-of-home-care and adoption and guardianship assistance files. Without the targeted and intensive technical assistance described above and provided by the Child Welfare Information Gateway, it is unlikely that the direct IV-E tribes would have achieved this level of success.

There are still three direct IV-E tribes that have not successfully submitted AFCARS and several other tribes in the process of becoming direct IV-E recipients, therefore, CB is requesting a modification to add funds to the FY24 contract to allow the Child Welfare Information Gateway to continue providing these technical assistance options. This support helps mitigate the risks faced if tribes are unable to collect and submit AFCARS 2020 data. A compliant AFCARS 2020 submission means the under-resourced tribes avoid a financial penalty. This continued technical assistance ensures that that both the direct IV-E tribes and those working to become a direct IV-E tribe have equal access to the above technical assistance that has proven to be valuable, as every one of the tribes that received the technical assistance in the prior year were able to submit at least one compliant AFCARS file. In addition, upon a first look at the data, it appears that states with tribal IV-E agreements with tribes are not reporting on the children who are in the placement and care responsibility of the tribe correctly on their own AFCARS reports. Furthermore, without reliable and quality AFCARS 2020 data the CB is at risk of not being able to adequately respond to questions from Congress and other Federal departments and agencies; failing to develop short and long-term budget projections and meaningful program planning, and trend analysis; not identifying areas for technical assistance efforts, discretionary grants, research and evaluation, and regulatory change; and assessing outcomes for children and families. All of which are critical to CB’s mission.

Continuing the technical assistance options described above in FY24 supports the following six Children’s Bureau’s objectives:

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      1. Support to direct title IV-E tribes on their collection and submission of AFCARS 2020,
      
      
      2. Increase the capacity of tribal IV-E programs to be ready to collect and report AFCARS 2020,
      
      
      3. Build an electronic system based on the paper AFCARS collection form so that the Children's Bureau may help any tribal direct title IV-E agency that is unable to otherwise submit AFCARS 2020,
      
      
      4. Improve efforts in states with a title IV-E agreement with a tribe in their state on their collection of tribal data for state AFCARS 2020 reporting,
      
      
      5. Provide guidance to states and tribes on the need and mechanisms for sharing data necessary for AFCARS 2020 reporting, and
      
      
      6. Provide resources and tools for the Children’s Bureau to provide intensive onsite AFCARS 2020 technical assistance for the tribes and title IV-E agencies.
      
      
      
      
   
   
   
   

Additional information on each of the tasks related to the above objectives is below.

1. Support to direct title IV-E tribes on their collection and submission of AFCARS 2020.

2. Increase the capacity of tribal IV-E programs to be ready to collect and report AFCARS 2020.

Objectives 1 and 2 are a direct continuation of the technical assistance options offered in FY23 with a focus on sustaining current performance of IV-E tribes, ensuring compliant submissions from tribes that were not able to submit, and assisting tribes in the process of becoming direct IV-E to ensure they are prepared to submit when required to do so. The kinds of technical assistance to be provided are: software review, building and testing XML, policies and forms review, ongoing quality review, data collection for jurisdictional transfers, and technical training.

1. Build an electronic system based on the paper AFCARS collection form so that the Children's Bureau may help any tribal direct title IV-E agency that is unable to otherwise submit AFCARS 2020.

Objective 3 will continue the work that was started during the current fiscal year. The Child Welfare Information Gateway developed an AFCARS 2020 paper form and drafted the design and requirements for an electronic system based on the paper form. Building the system would allow any direct tribal IV-E agency that is unable to submit AFCARS using its software or other case management mechanism to submit via the electronic system.

1. Improve efforts in states with a title IV-E agreement with a tribe in their state on their collection of tribal data for state AFCARS 2020 reporting.


2. Provide guidance to states and tribes on the need and mechanisms for sharing data necessary for AFCARS 2020 reporting.

Objectives 4 and 5 will require the consultant to coordinate state-agency technical assistance in consultation with the regional offices. It will include the development of draft guidance for states on collecting and reporting AFCARS data with both tribes under a IV-E agreement or other direct title IV-E tribes.

1. Provide resources and tools for the Children’s Bureau to provide intensive onsite AFCARS 2020 technical assistance for the tribes and title IV-E agencies.

Objective six will require the consultant to develop resources and tools to assist CB when it provides tribes onsite technical assistance to address common but difficult to solve issues around AFCARS 2020 data collection, extraction, and submission issues. These tools are expected to be used in future years.

These tasks will need the resources of one highly skilled consultant of approximately 30 hours per week who has the experience of working with tribes on data information systems, child welfare IT systems, and AFCARS 2020 to direct the implementation of the project. At least one additional resources will be needed to support objectives 1, 2, 4, 5, and 6. These resources will need experience similar to the skilled consultant. Objective 3 require a single resource that is skilled in IT system development and familiar with the system requirements to ensure an effective and efficient build.

The day-to-day activities will be under the direction of the above consultant but would involve additional level of effort with project management expertise and the skillset and experience to work with tribes and CB to identify solutions to address the tribes’ needs.

AFCARS has always been a complex dataset that required deep knowledge of the regulations, child welfare practice and policy, and child welfare information systems and the underlying databases. The AFCARS 2020 regulations introduced extensive changes to the established data reporting and naturally increased the need for the subject matter expertise to support its implementation. Very few vendors had AFCARS 1993 experience at the federal level in helping states and tribes with their submissions and only ICF through the Child Welfare Information Gateway has the requisite knowledge of AFCARS 2020 regulations, the XML schema, the data compliance errors, and penalty structure in combination with the direct technical assistance experience and existing relationship with states and tribes necessary to deliver the six objectives and mitigate the risks identified above.

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