This procedure letter clarifies data collection requirements involving the Title IV-B State Plan as required by federal law. Public Children Services Agencies (PCSAs), Private Child Placing Agencies (PCPAs) and Private Non-custodial Agencies (PNAs) engaged in inter-country adoptions must complete the JFS 01670, "Inter-Country Adoption Data Collection," and submit the form to the Ohio Department of Job and Family Services (ODJFS) by May 12, 2008. The time period for the data collection is Federal Fiscal Year (FFY) 2007.

Definitions:

For the purpose of this inter-country adoption data collection, the following definitions apply. These definitions can be found at 22 CFR 96.2 and the Child Welfare Policy Manual at http://www.acf.hhs.gov/j2ee/programs/cb/laws_policies/laws/cwpm/policy_dsp.jsp?citID=178#1200.

A "disruption" is the interruption of a placement for adoption during the post-placement period. An example of this is when a child who came to the United States for the purpose of adoption entered foster care prior to the finalization of the adoption, regardless of the reason for the foster care placement. The PCSA, PCPA or PNA must report these disruptions even if the child's plan is reunification with the prospective adoptive parent and the stay in foster care is brief. Such disruptions typically occur after a child enters the United States under the guardianship of the prospective adoptive parents or an adoption agency with an "IR-4 visa" for the purposes of completing the adoption process domestically.

A "dissolution" is the termination of the adoptive parent's parental rights after the adoption. An example of this is when a child for whom an inter-country adoption occurred (whether the full and final adoption occurred in the foreign country or domestically) entered foster care as a result of a court terminating the adoptive parent's rights or the adoptive parent relinquished his or her rights to the child. Since the child's legal relationship with his or her adoptive parent may not be severed until some time after the child enters foster care, the PCSA, PCPA or PNA must also report to ODJFS, the child for whom an inter-country adoption occurred and the child was already in foster care at the time that the adoption dissolved.

Data Collection Requirements:

Each PCSA, PCPA, and PNA must complete a separate JFS 01670 for each child who was adopted via inter-country and who entered foster care due to an adoptive placement disruption or due to an adoption dissolution as defined above. The agency must collect and report to ODJFS the following information on the JFS 01670:

• Identification of the child who was adopted from another country and entered into agency custody in FFY 2007 as a result of the disruption of a placement for adoption (42 USC 622[b][12]).
• Identification of the child who was adopted from another country and entered into agency custody in FFY 2007 as a result of the dissolution of an adoption (42 USC 622[b][12]).
• Explanation of the permanency plan for the child, the reasons for the disruption or dissolution and the steps taken to achieve permanency after the disruption or dissolution occurred.
• Identification of the PCSA, PCPA or PNA that handled the adoptive placement or the adoption finalization.
• Description of the activities that the PCSA, PCPA, PNA or any other agency undertook for the child adopted from another country, including the provision of adoption and post-adoption services. (42 USC 622[b][11]).

PCSAs, PCPAs and PNAs are not required to collect data on a child who enters foster care after a finalized adoption if the adoptive parent's legal rights to the child remain intact. An example of this may be a child for whom an inter-country adoption occurred and the child was admitted to a residential treatment center but the adoptive parent maintained legal custody of the child.

Please contact the Office for Children and Families Help Desk at 1-866-886-3537, Option 4, if you have additional questions or concerns.

INSTRUCTIONS:

The following chart depicts what materials should be removed from and what material should be inserted into the Family, Children and Adult Services Manual (FCASM).