20, No. 1
The Use of Safety Resources and Title IV-E Funding
The first objective of child welfare agencies is to keep children safe. Funding influences the way agencies achieve this goal. In our state and throughout the country, federal Title IV-E dollars are a key source of funding for services for children who are in foster care or who are at imminent risk of entering foster care. States must follow federal rules for use of IV-E funds and are subject to periodic reviews/audits by the federal government.
Can Title IV-E funding be used to cover administrative costs* when children have been placed by their parents with a safety resource? To date, the federal Administration on Children and Families has not issued written guidance about this issue. In general, ACF approves the use of IV-E funds when a child is removed from the home by a child-placing agency, not voluntarily by the parents. However, if agencies can convincingly document that the child is at imminent risk of placement in foster care, use of IV-E when children are placed with a safety resource seems defensible. Effective documentation here is vital.
Of course, IV-E isn't the only option. If a county DSS believes "the child and family could benefit from services and potentially decrease the risk of future reports of maltreatment, but there is insufficient information to justify that the child is at imminent risk of removal and placement, county staff can still decide to provide in-home services" (NCDSS, 2012). These services would just need to be paid for with other funds.
* IV-E support for foster care board rate payments in this situation is incorrect--temporary safety resource placements are not foster care placements and receive no board rate.