The Multiethnic Placement Act of 1994, 42 U.S.C. 622(b) (9), 671(a) (18), 674(d) and 1996(b) (hereinafter "MEPA") and Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq as it applies to the foster care and adoption process (hereinafter "Title VI"), prohibits any adoption and/or foster placement agency or entity that accepts federal assistance from:

• Delaying or denying a child's foster care or adoptive placement on the basis of the child's or the prospective parent's race, color or national origin (RCNO); or from
• Denying to any individual the opportunity to become a foster or adoptive parent on the basis of the prospective parent's or the child's RCNO.

Under Title VI of the Act, federal funding for programs could be denied if any evidence of discrimination based on RCNO was present.

This Procedure Letter serves as a notice that public children services agencies (PCSAs), private non-custodial agencies (PNAs), and private child placing agencies (PCPAs) must cease using any non-JFS forms that contain RCNO of certified and licensed foster and/or adoptive parents when requesting information for a child's placement. All agencies shall also stop verbally requesting the RCNO of prospective, certified and licensed foster and/or adoptive parents when seeking placement of a child. The PCSA/PCPA MEPA Monitors or the PNA Director shall review all forms in which the agency created when soliciting placement information to ensure MEPA compliance. Agencies shall conduct an initial review of all forms by January 31, 2012 and submit the attached document confirming completion.

When an agency discovers information contained within a form, either from its own agency or one that has been received from another agency, the following steps shall occur:

1)Return a copy of the form with a MEPA alert to the agency and/or area which originally completed the form. Highlight the section requesting RCNO and indicate that it may be considered a MEPA violation and will not be completed.

2)Forward a copy of the form with a MEPA alert to the Ohio Department of Job and Family Services, Office of Families and Children, Deputy Director, P.O. Box 182709, Columbus, Ohio 43218-2709.

In order to maintain compliance with MEPA and Title VI as it pertains to the adoption and foster care process, there will be a discussion about forms created by agencies during MEPA onsite visits. Also, the JFS 01668, Multi Ethnic Placement Act (MEPA) Biennial Comprehensive Self-Assessment Report will be modified to include information pertaining to any additional documents the agency has created other than the required JFS forms.

Please contact Joan Van Hull if you should have any questions at (614) 752-0657 or Joan.VanHull@jfs.ohio.gov

Attachment: Forms Referencing the Race, Color or National Origin (RCNO) of Prospective, Certified and Licensed Foster and/or Adoptive Parents