Understanding the Training Reimbursement Provision in Fostering Connections

Dennis Blazey, Consultant

Summary: The author offers a set of FAQs that explain the broad parameters of the Fostering Connections Act provision that expands training reimbursements.

_____________________________________________________________________________________________________

An often overlooked provision of Fostering Connections is its expansion of Title IV-E training reimbursements to include costs incurred to train court personnel. The specific provision is found in 42 USCA 674 (a)(3)(B) and requires, in pertinent part, that the Health and Human Services secretary is to reimburse states for “… such expenditures (including travel and per diem expenses) as are for the short term training of … 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 … staff members …, 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 following is a very rudimentary set of FAQ’s that explain the broad parameters of this provision and the potential for federal reimbursement of court training costs. Courts interested in exploring this opportunity for reimbursement are urged to contact their state’s child welfare agency to obtain more detail.

Q. What qualifies as “training”?

A. An activity is considered “training” if it is specifically designed and organized to impart new work skills or reinforce existing work skills. Activities such as supervision, mentoring, the employment of interns and general informational meetings are not considered “training.”

Q. What can the training be about?

A. There are many topics that a court may train its personnel on and claim reimbursement for. Here are some examples:

  • Social work practice, such as family-centered practice and social work methods, including interviewing and assessment
  • Cultural competency related to children and families (including issues for LGBTQ youth)
  • Title IV-E policies and procedures
  • Child abuse and neglect issues, such as the trauma impact of child abuse and neglect on a child, and general overviews of the issues involved in child abuse and neglect investigations, provided the training is not related to how to conduct an investigation of child abuse and neglect
  • Permanency planning, including using kinship care as a resource for children involved with the child welfare system
  • General substance abuse, domestic violence and mental health issues related to children and families in the child welfare system, provided the training is not related to providing treatment or services
  • Effects of separation, grief and loss, and visitation
  • Communication skills required to work with children and families
  • Activities designed to preserve, strengthen and reunify the family, provided the training is not related to providing treatment or services
  • Assessments to determine whether a situation requires a child’s removal from the home. Training on how to conduct specialized assessments such as psychiatric, medical or educational assessments are not permitted.
  • Ethics training associated with a Title IV-E state plan requirement, such as the confidentiality requirements in 42 USC 671(a)(8)
  • Independent living and the issues confronting adolescents preparing for independence
  • Foster care candidate determinations and effective pre-placement activities directed toward preventing removal, provided the training is not related to actually providing a service
  • Training on referral to services, but not on the actual performance of the services
  • Child and adolescent development (including pregnancy prevention, healthy relations and sexual health)

Q. What costs are reimbursable?

 A. Costs reimbursable as training expenditures include:

  • Travel, per diem, tuition, books and registration fees for trainees
  • Salaries, fringe benefits, travel and per diem for staff development personnel assigned to training functions to the extent time is spent performing such functions
  • Salaries, fringe benefits, travel and per diem for outside experts engaged to develop or conduct training programs
  • Costs of space, postage, training supplies, and purchase or development of training materials

The salary and fringe benefits cost of trainees attending training may not be claimed.

Q. What is the reimbursement rate?

A. The effective reimbursement rate will be determined by a state’s Title IV-E eligibility rate and the federal matching rate (65% in FFY 2011 rising to 75% in FFY 2013). For example, assume a state’s eligibility rate was 55%. This would make the effective reimbursement rate 35.75% per $100 in cost (65% x 55%).

Q. How can a court receive Title IV-E reimbursements for its allowable training costs?

A. To receive reimbursements, a court will need to execute an agreement with the state child welfare agency. That agreement will delineate activities and costs which can be claimed for reimbursement and establish procedures for doing same. To ease administration, it is recommended that the state child welfare agency and the state’s supreme court execute a master agreement. Under that agreement, the supreme court would serve as a central collection point for claims submitted by local courts and combine those with any state-level training costs into a single consolidated claim.

 

National CASA Association | 800.628.3233 | 100 West Harrison, North Tower, Suite 500, Seattle, WA 98119 | staff@casaforchildren.org

National CASA (Court Appointed Special Advocates) ©2015. The National CASA logo, CASA ®, "A Powerful Voice in a Child’s Life," "Stand Up for an Abused Child," "Speak Up for a Child," "Light of Hope" and "Give the Light of Hope to a Child" are all registered trademarks of National CASA.