Tribal Readiness Assessment Tool For The Title IV-E Program

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Tribal Readiness AssessmentTool for the Title IV-E ProgramFebruary 2022

2BACKGROUNDSince the passage of Fostering Connections in 2008, tribes operating a Title IV-B, Subpart 1, program have had theoption to apply to receive funding directly from the federal government to operate foster care, adoptionassistance, and optional guardianship assistance programs, authorized by Title IV-E of the Social Security Act.These programs assist states and participating tribes with the costs of maintaining eligible children in foster care,assisting relatives with legal guardianship of eligible children, and fnding and supporting adoptive homes forchildren with special needs who are unable to return home to their family of origin. Since that time, the Title IV-Eprogram has also been expanded to include optional prevention services and kinship navigator programs. Toparticipate in the optional prevention services or kinship navigator programs, a tribe must be frst approved tooperate the mandatory foster care and adoption assistance programs.PURPOSEWhile the Title IV-E program offers an important source of child welfare funding for participating tribes, it is acomplex program that requires signifcant administration, staff, and fnancial resources to operate. To assist tribesin assessing their readiness to participate in Title IV-E programs, the Children’s Bureau (CB) developed thisvoluntary Tribal Readiness Assessment Tool. Tribes may fnd this assessment tool helpful to explore infrastructureand capacity-building needs before beginning to operate a Title IV-E program. A tribe can use this assessmenttool to focus on how to integrate Title IV-E systems and processes in a way that enhances the tribe’s own sovereignauthority to provide care for its children and families. Because of the unique histories and organizational dynamicsof each tribe, systems and processes may look different across jurisdictions. At this time, this voluntary assessmenttool focuses on the foster care and adoption assistance programs, as well as the optional guardianship assistanceprogram. It does not address specifc requirements for participation in the Title IV-E prevention services or kinshipnavigator program. The Title IV-E requirements are emphasized in bold, but addressing all areas within the belowtables provides the tribe an opportunity to communicate, explore, and connect all components of the tribal nation.February 2022

3APPLICATIONS BEYOND TITLE IV-EThis assessment tool also provides a comprehensive approach to examining the system components andprocesses necessary to support the overall system of child welfare and not just the Title IV-E program. Weencourage tribes to use this voluntary assessment tool as a part of their child and family services programdevelopment to strategically build the broad components of child and family safety, permanency, and well-being.This assessment tool looks at the child protection and social service aspects of foster care as well as the criticallyimportant roles of the tribal leadership, the tribal court system, law enforcement agencies, tribal administrationand fnancial management offcials, foster care/relative care partners, and ultimately the community voice. Aswork is done in each section, we encourage tribes to embed other tribal program requirements, objectives, andneeds to show how coordination is valued and occurring throughout the assessment.Please note that completion of this assessment does not constitute meeting federal requirements, nor does itsupersede existing laws or offcial guidance. To receive federal fnancial participation directly from theAdministration for Children and Families (ACF) to operate a Title IV-E program, a tribe must submit a Title IV-Eplan to the appropriate regional offce (RO), for approval by the Administration for Children, Youth, and Families(ACYF). Instructions and guidance for submitting a Title IV-E plan can be found in ACYF-CB-PI-18-07 - 7, and if implementing the Title IV-E prevention services program, inACYF-CB-PI-18-10 - 0.February 2022

4PARTNERSHIPWhile tribes may choose to complete the Tribal Readiness Assessment Tool internally, we highly recommend thetribe consult with its CB RO program specialist during the process. The program specialist can respond toquestions and provide additional guidance on Title IV-E program requirements as needed so that the tribe canmake a thorough and comprehensive assessment. In addition, CB encourages the tribe to refer to an additionaltechnical assistance document, “Considerations for Indian Tribes, Indian Tribal Organizations or Tribal ConsortiaSeeking to Operate a Tribal Title IV-E Program,” for an explanation of preparatory considerations to help guide itsassessment of IV-E readiness. Other resources for knowledge building around Title IV-E can be found on theCB website – https://www.acf.hhs.gov/cb; the Tribal Information Exchange – www.tribalinformationexchange.org;the Child Welfare Information Gateway – www.childwelfare.gov; and through the Capacity Building Center forTribes – https://capacity.childwelfare.gov/tribes.In summary, it is our hope that this Tribal Readiness Assessment Tool provides useful technical assistance andanswers questions that tribes have as they assess their readiness to participate in the Title IV-E programs and tosupport their child welfare programs as a whole.February 2022

5INSTRUCTIONSThe Tribal Readiness Assessment Tool contains several charts that are topic specific. The charts do not need to befilled out in the order they are presented. Each chart contains questions that address the specific topic. Werecommend that the tribe work through the questions in the chart, respond with ‘Yes’ or ‘No,’ and provide thefollowing: a narrative addressing services, infrastructure, and systems that they currently have in place; what theymay need to develop in order to operate a Title IV-E program; and a description of any goals/objectives that areneeded to accomplish the requirement(s). We believe the narrative portion will aid in further discussions as wellas in making decisions and developing next steps for accessing IV-E (e.g., applying for IV-E direct or applying for aIV-E development grant or entering into a IV-E tribal-state agreement). This document is adaptable and can beused as a snapshot in time and/or be used over time in the tribe’s planning and/or tracking.February 2022

6Scope of the Title IV-E ProgramThe Title IV-E program has two mandatory components (foster care maintenance payments and adoptionassistance) and several optional components (guardianship assistance, extended foster care, and preventionservices). The following questions address the tribe’s current foster care, adoption, and guardianship assistanceprograms.Service/ProgramYesNo If YES, please provide description of what services/programs the tribe currently ofers tofamilies from each Service/Program category.If NO, please explain the tribe’s plan to develop this in the next few years.Does the tribeoperate a foster careprogram? If yes, is thefoster care programfunded by the tribe orthrough anagreement with astate?Does the tribeoperate an adoptionassistance program?If yes, is the adoptionassistance programfunded by the tribe orthrough anagreement with astate?February 2022

7Service/ProgramYesNo If YES, please provide description of what services/programs the tribe currently ofers tofamilies from each Service/Program category.If NO, please explain the tribe’s plan to develop this in the next few years.Does the tribe have aprocess to fnalizeadoptions?Does the tribe practicecustomary adoption andhave policy and/or codein place to support thispractice?Does the tribe operate aguardianship assistanceprogram? If yes, is theguardianship assistanceprogram funded bythe tribe or through anagreement with a state? If no, does the tribe planto develop the optionalguardianship assistanceprogram?What services andassistance does the tribeoffer to a child placedwith a relative and to therelative?February 2022

8Comprehensive child welfare continuumThe Tribal Readiness Assessment Tool contains several charts that are topic specifc. The charts do not need to beflled out in the order they are presented. Each chart contains questions that address the specifc topic. Werecommend that the tribe work through the questions in the chart, respond with ‘Yes’ or ‘No,’ and provide thefollowing: a narrative addressing services, infrastructure, and systems that they currently have in place; what theymay need to develop in order to operate a Title IV-E program; and a description of any goals/objectives that areneeded to accomplish the requirement(s). We believe the narrative portion will help aid in further discussions aswell as in making decisions and developing next steps. This document is adaptable and can be used as a snapshotin time and/or be used over time in the tribe’s planning and/or tracking.February 2022

9Part A Child Protective ServicesA Title IV-E agency must have a service program designed to help children who are at risk of removal remain athome safely. The following questions address services and programs the tribe has in place, or plans to develop,that will contribute to a complete Title IV-E program.Service/ProgramYesNo If YES, please provide description of what services/programs the tribe currently ofers tofamilies from each Service/Program category.If NO, please explain the tribe’s plan to develop this in the next few years.Does the tribe have aprocess for respondingto reports of child abuseand neglect?Does the tribe conductrisk assessments todetermine whether thechild is currently safe inthe home and whetherany interventions areimmediately needed toprotect the child?February 2022

10Service/ProgramYesNo If YES, please provide description of what services/programs the tribe currently ofers tofamilies from each Service/Program category.If NO, please explain the tribe’s plan to develop this in the next few years.Does the tribe use adifferential oralternative responseprocedure thatestablishes multiplepathways to respondto child maltreatmentreports? If yes, what isthe tribe’s procedure?Does the tribeconduct child abuseand neglectinvestigations? If no,then who conductsinvestigations?Does the tribeconduct safetyplanning to ensure theimmediate and futuresafety and well-beingof the child?February 2022

11Part B Services - Family Preservation, Family Support, Promoting Safeand Stable Families, Domestic Violence, etc.A Title IV-E agency must have a service program designed to help children in foster care return home safely. Thefollowing questions address the types of services the tribe has in place or will develop.Service/ProgramYesNo If YES, please provide description of what services/programs the tribe currently ofers tofamilies from each Service/Program category.If NO, please explain the tribe’s plan to develop this in the next few years.Does the tribecurrently operate aTitle IV-B-1 program?Does the tribe havecase planning andcasemanagementservices?Does the tribe offerfamily strengtheningand/or education andsupport services?Does the tribe offerintensive in-homeservices?February 2022

12Service/ProgramYesNo If YES, please provide description of what services/programs the tribe currently ofers tofamilies from each Service/Program category.If NO, please explain the tribe’s plan to develop this in the next few years.Does the tribe offerfamily preservationservices such as inhome parentingeducation andsupport services?Does the tribe havehome maintenance –education andsupport services?Does the tribe offerfnancial literacyeducation andsupport services?Does the tribe offerother services notlisted above?February 2022

13Part C Legal/Judicial Processes and Case Review SystemWorking with courts is an essential part of a Title IV-E agency’s responsibility. The Title IV-E program does not fundgeneral court activities but does require the tribe to obtain judicial determinations from the courts. The followingquestions address the tribe’s legal and judicial processes for taking children into its placement and careresponsibility and meeting Title IV-E case review requirements.Process / SystemYesNo If YES, please provide description of the tribes currently process.If NO, please explain the tribe’s plan to develop this process/system over the next fewyears.Does the tribe’s childwelfare program havewritten policies andprocedures?Does the tribe haveaccess to a court withauthority to orderplacement and careresponsibility of a tribalchild and make relatedjudicial determinations?If yes, is the authorityand process establishedin the Children’s Code,Title IV-E manual,resource guide, policy,etc.?February 2022

14Process / SystemYesNo If YES, please provide description of the tribes currently process.If NO, please explain the tribe’s plan to develop this process/system over the next fewyears.Does the tribe use a statecourt for some childabuse/neglect cases?Does the tribe havea process to ensure aperiodic review for eachchild occurs no lessfrequently than onceevery 6 months eitherby a court oradministrative review?Does the tribe have aprocess to ensure thateach child has apermanency hearing ina court of competentjurisdiction oradministrative bodyappointed or approvedby a court that occursno later than 12 monthsfrom the date the childentered foster care andno less frequently thanevery 12 monthsthereafter?February 2022

15Process / SystemYesNo If YES, please provide description of the tribes currently process.If NO, please explain the tribe’s plan to develop this process/system over the next fewyears.Do tribal court ordersinclude the requiredchild-specifc Title IV-Efndings?This includes: Placement and Careto the Tribal ChildWelfare agency Contrary to theWelfare Reasonable Efforts toPrevent Removal ORReasonable EffortsNot Required Reasonable Efforts toFinalize thePermanency PlanFebruary 2022

16Process / SystemYesNo If YES, please provide description of the tribes currently process.If NO, please explain the tribe’s plan to develop this process/system over the next fewyears.Does the tribe have aprocess for fling apetition fortermination of parentalrights, modifcation ofparental rights, or someother alternativeprocess that will resultin a child becomingavailable for adoptionand for the tribe toconcurrently identify,recruit, process, andapprove a qualifedadoptive family?Does the tribe have aprocess for voluntaryplacements? If yes, doesthe tribe have a processfor obtaining a judicialdetermination that theplacement is in the bestinterests of the childwithin the frst 180days.February 2022

17Process / SystemYesNo If YES, please provide description of the tribes currently process.If NO, please explain the tribe’s plan to develop this process/system over the next fewyears.Does the tribe have aprocess fornotifying foster parents,pre-adoptive parents,and relativecaregivers of childrenin foster care of theirRight to be Heard in anyproceeding held withrespect to the child?Does the tribe utilize awritten case plan that isdeveloped jointly withchild and parents?If the tribe utilizes awritten case plan, doesthe tribal child welfareagency share the caseplan with the court?February 2022

18Part D StafingThe Title IV-E agency is required to train staff as an ongoing activity related to child and family services policies,programs, and practices. The following questions address the tribal staff currently in place to support/implementall aspects of the tribe’s program and the training the tribe has in place to ensure a qualifed workforce specifc tothe Title IV-E program or the training that the tribe will develop.Positions / ProcessYesNo If YES, tell us about the tribe’s current stafing and training.If NO, please indicate how the tribe will provide coverage of these necessary programfunctions.Does the tribe havestaff who work onchild protectiveservices?Does the tribe havestaff who work onpermanency (fostercare, adoption /customary adoption,guardianship)?Does the tribe havestaff who work onlicensing andrecruitment of fostercare and adoptivefamilies?February 2022

19Positions / ProcessYesNo If YES, tell us about the tribe’s current stafing and training.If NO, please indicate how the tribe will provide coverage of these necessary programfunctions.Does the tribe havefscal staff able tomeet Title IV-Ereportingrequirements andprocesses?Does the tribe havea process for trainingnew staff?Does the tribe have aprocess for ensuringthat all staff canreceive ongoingtraining?Does the tribe utilizeprocedure manuals forchild welfare staff?Does the tribe’s staffpartner with the Stateto gather informationnecessary to make aTitle IV-E eligibilitydetermination?February 2022

20Positions / ProcessYesNo If YES, tell us about the tribe’s current stafing and training.If NO, please indicate how the tribe will provide coverage of these necessary programfunctions.Does the tribe’s staffpartner with the tribalcourt? If yes, in whatways?Is the tribal childwelfare agencyrepresented in childwelfare proceedings?Does the tribe haveenough staff tooperate its childwelfare program andprovide services?February 2022

21Part E Recruitment, Safety, and Licensing of Family Resource Homes, Child Care Institutions,and Residential Treatment FacilitiesThe Title IV-E agency is required to conduct criminal background checks and child abuse and neglect registrychecks for prospective foster and adoptive parents, relative guardians, and adults working in child care institutions. The following questions address the policies and procedures the tribe has in place for the recruitment,licensing, and safety checks of tribal family resource homes or what policies and procedures the tribe will developto meet Title IV-E program requirements.Policy and ProcedureYesNo If YES, tell us about the policies and procedures currently in place.If NO, how will the tribe develop these policies and practices that are integral components ofa Title IV-E program.Does the tribecurrently recruit fosterfamily homes?Does the tribecurrently recruit fosterfamily and/or adoptivefamily homes?Does the tribecurrently license orcertify foster familyhomes?February 2022

22Policy and ProcedureYesNo If YES, tell us about the policies and procedures currently in place.If NO, how will the tribe develop these policies and practices that are integral components ofa Title IV-E program.Does the tribe utilizedifferent licensingprocesses for thevarious types of fosterfamily homes (kinship,foster, adoptive)?Does the tribe havelicensing standardsfor foster familyhomes?Does the tribe have asystem for thetraining and supportof relatives, fosterparents, andadoptive parents?Does the tribe havea process in place forconductingfngerprint-basedcriminal backgroundchecks?February 2022

23Policy and ProcedureYesNo If YES, tell us about the policies and procedures currently in place.If NO, how will the tribe develop these policies and practices that are integral components ofa Title IV-E program.Does the tribe havea process in place foraccessing the stateand local criminalhistories ofapplicants?Does the tribe havea process in place tocheck tribe and statechild abuse/neglectregistries?Does the tribecurrently providesome form ofpayment to the tribe’sresource families?February 2022

24Policy and ProcedureYesNo If YES, tell us about the policies and procedures currently in place.If NO, how will the tribe develop these policies and practices that are integral components ofa Title IV-E program.Does the tribe licenseplacements otherthan foster familyhomes? Placementscould includeemergency shelters,group homes,specializedcommunity homes,therapeutic fosterhomes (TFC),childcare institutions,etc.February 2022

25Policy and ProcedureYesNo If YES, tell us about the policies and procedures currently in place.If NO, how will the tribe develop these policies and practices that are integral components ofa Title IV-E program.Does the tribeutilize other licensedplacement resourcesbesides ones that arelicensed by the tribe?These otherresources couldinclude qualifedresidential treatmentprograms (QRTPs),foster youthplacements with theirparent in a licensedfamily-basedresidential facility,group homes,specializedcommunity homes,TFC, and institutions.February 2022

26Part F Collaborations and PartnershipsCollaborations and partnerships are necessary to administer a Title IV-E program. The following questions addresscollaborations and partnerships with tribal leadership, program staff, various stakeholders, as well as state andother federal partners and collaborations and partnerships the tribe will be developing for the Title IV-E program.Collaboration/PartnersYesNo If YES, provide information and detail, explaining how this area/situation is addressed.If NO, explain tribe’s plan for ensuring the objective will eventually be fulfilled or met.Are leaders from allkey tribal programsand agencies insupport of developinga Title IV-E program?Key programs andagencies includesocial services, ICWA,CPS, courts, attorneys,licensing, and fscal.Are leadersactively involved inTitle IV-E planning,development, anddecision-makingprocesses?February 2022

27Collaboration/PartnersYesNo If YES, provide information and detail, explaining how this area/situation is addressed.If NO, explain tribe’s plan for ensuring the objective will eventually be fulfilled or met.Are plans in place toensure the continuity,support, andsustainability of theTitle IV-E program ifthere is a change inleadership?Does the tribecurrently havecollaborations/partnerships in placewith other agencies?Does the tribe have acurrent agreement orcontract in place withthe state for thepass-through of anyportion of Title IV-Efunds includingmaintenance,administration and/ortraining? If yes, pleasedescribe.February 2022

28Collaboration/PartnersYesNo If YES, provide information and detail, explaining how this area/situation is addressed.If NO, explain tribe’s plan for ensuring the objective will eventually be fulfilled or met.Is the tribe able toaccess the familyincome andemploymentinformationneeded to determinethe AFDC related torequirements of IV-Eeligibility?Does the tribe have apartnership with thechild supportagency?Does the tribe have apartnership/collaboration withstate Medicaid andsocial securityagencies?Does the tribe have apartnership/collaboration withlaw enforcementagencies?February 2022

29Collaboration/PartnersYesNo If YES, provide information and detail, explaining how this area/situation is addressed.If NO, explain tribe’s plan for ensuring the objective will eventually be fulfilled or met.Does the tribe have apartnership/collaboration witheducation agenciesand schools?Does the tribecurrently makereferrals to outsideagencies for additionalneeded supports tochildren and families?How does the tribemake foster/adoptiveplacements out ofstate (e.g. tribal-stateagreement, BIAplacements)?February 2022

30Part G Data Collection and ITAFCARS regulations require Title IV-E agencies to collect and report data to ACF on children in out-of-home care,children who exit out-of-home care to adoption or legal guardianship, and children who are covered by a Title IV-Eadoption or guardianship assistance agreement.The following questions address the tribe’s current system for tracking and recording case information and otherdata, or those that will be developed.Information SystemsYesNo If YES, provide information and detail, explaining how this area/situation is addressed.If NO, explain tribe’s plan for ensuring the objective will eventually be fulfilled or met.Does the tribecurrently use a papercase managementsystem for trackingchild welfare cases?Does the tribecurrently use anelectronic casemanagement systemfor tracking childwelfare cases?If the tribe utilizes anelectronic datasystem, is the tribeable to generatereports?February 2022

31Information SystemsYesNo If YES, provide information and detail, explaining how this area/situation is addressed.If NO, explain tribe’s plan for ensuring the objective will eventually be fulfilled or met.Is the tribe able tocollect AFCARS data?February 2022

32Part H Fiscal Reporting - Financial Controls - Audits - Match - Cost Allocation MethodologyThe Title IV-E program has complex rules for determining which costs may be claimed under the program andwhich federal fnancial participation rates apply. Title IV-E agencies must also follow Offce of Management andBudget rules for charging only necessary and reasonable costs to the Title IV-E program and allocating allowablecosts relative to the benefts received. The following questions address the tribe’s current policies and proceduresfor fscal reporting or how those policies and procedures will be developed.Policies andProcedures for FiscalReportingYesNo If YES, explain the policy/procedure.If NO, how will the tribe accomplish this with or without the use of Title IV-E DevelopmentGrant funds?Does the tribe have aprocess forprogrammatic andfnancial leadership tomonitor fnancialmanagement?Does the tribe havewritten accountingand fnancial policiesand procedures?February 2022

33Policies andProcedures for FiscalReportingYesNo If YES, explain the policy/procedure.If NO, how will the tribe accomplish this with or without the use of Title IV-E DevelopmentGrant funds?Does the tribe havewritten policies andprocedures fordetermining theallowability of costs inaccordance with thefederal cost principles?Does the tribe have aplan for allocatingcosts to various childwelfare programs?Does the tribe havea plan for allocatingcosts to various childwelfare programs?Does the tribe haveactive internalcontrol - bothprogram and fscal?February 2022

34Policies andProcedures for FiscalReportingYesNo If YES, explain the policy/procedure.If NO, how will the tribe accomplish this with or without the use of Title IV-E DevelopmentGrant funds?Does the tribe have afnancial process forbudgeting andallocating costsassociated with thechild welfareprogram?Does the tribe havesystems that produceaccurate and reliablefnancial reports?Does the tribe havesystems in place toretain fnancialrecords that identifythe source and fnaluse of funds?February 2022

35Policies andProcedures for FiscalReportingYesNo If YES, explain the policy/procedure.If NO, how will the tribe accomplish this with or without the use of Title IV-E DevelopmentGrant funds?Does the tribe have aprocess to correct anyaudit fndings thatdemonstratesignifcant or materialaudit exceptionsunder grants orcontracts related tothe delivery of socialservices?Does the tribe have anapproved Indirect CostRate Agreement withthe BIA?Title IV-E is areimbursementprogram that does notcover all expenses. Willthe tribe be able tocover all other costsnot covered by TitleIV-E as well as thematch requirementsfor the program?February 2022

36Policies andProcedures for FiscalReportingYesNo If YES, explain the policy/procedure.If NO, how will the tribe accomplish this with or without the use of Title IV-E DevelopmentGrant funds?Does the tribe havein-kind expendituresfrom third-partysources that may beused as a source ofmatch foradministrative costs?Does the tribe haveany other source offederal fundingavailable to supporttheir child welfareprogram?If the tribe is a currentTitle IV-B grantee, areall SF-425s reportscurrent?Has the tribeexperienceddiffculties in the pastexpending its TitleIV-B funds?February 2022

37Policies andProcedures for FiscalReportingYesNo If YES, explain the policy/procedure.If NO, how will the tribe accomplish this with or without the use of Title IV-E DevelopmentGrant funds?Does the tribe havea quality assuranceprogam currently inplace?February 2022

voluntary Tribal Readiness Assessment Tool. Tribes may fnd this assessment tool helpful to explore infrastructure and capacity-building needs before beginning to operate a Title IV-E program. A tribe can use this assessment tool to focus on how to integrate Title IV-E systems and processes in a way that enhances the tribe's own sovereign

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