Background
On, November 23, 2021 the Ohio Department of Job and Family
Services provided notification regarding updated guidance from the Children’s
Bureau and the posting of Ohio
Administrative Code rule 5101:2-47-21 to external clearance as a result of the
guidance. The updated guidance specified that a child placed into a non-QRTP
placement setting that becomes QRTP
compliant after placement, the placement can become title IV-E reimbursable. The
purpose of this procedure letter is to further clarify the information provided
in the previous notification that the placement can be Title IV-E reimbursable
as long as the the required 30-day CANS
assessment and 60-day judicial determination timeframes are met. The beginning date for these requirements is
the date the placement setting in which an eligible child is placed, becomes
QRTP compliant.
The Office of Families and Children has revised Ohio
Administrative Code rule 5101:2-47-21 which will be effective in early March
2022, allowing for FCM reimbursement retroactively to October 1, 2021, if the
requirements outlined in federal guidance are met. In the interim it is
important to follow the guidance below.
If you have any questions, please reach out to Title IV-E policy
developer, Deanna Robb at Deanna.Robb@jfs.ohio.gov
or the SACWIS Help Desk.
FCM Reimbursements for a Non-QRTP Placement Setting Which Becomes
QRTP Compliant.
Based on federal guidance, Title IV-E FCM may be available when
a child placed in a non-QRTP placement setting becomes a QRTP compliant placement
setting and is eligible for reimbursement.
Beginning with the date the non-QRTP meets the QRTP
certification requirements, a child may be reimbursable back to the first day
of that month if the following requirements are met:
(1)A qualified
individual, who is a trained professional or licensed clinician and meets the
requirements in rule 5101:2-42-12 of the Administrative Code is to assess a
child within thirty-days of the setting becoming a QRTP.
(2)Within
sixty-days of the setting becoming a QRTP, the Title IV-E agency is to confirm
that the juvenile court:
(a)Considers the
assessment, determination, and documentation made by the qualified individual
conducting the assessment outlined in paragraph (B) of this rule.
(b)Determined
whether the needs of the child can be met through placement in a foster home,
or, if not, whether the placement of the child in a QRTP provides the most
effective and appropriate level of care for the child in the least restrictive
environment and whether that placement is consistent with the short and
long-term goals for the child, as specified in the permanency plan.
(c)Approves or
disapproves of the placement of the child into a QRTP.
If the 30-day CANS and 60-day judicial determination are not
both completed timely, the child’s placement will not be reimbursable for the
duration of that placement.
Once the changes are realized in Ohio SACWIS, Title IV-E agencies
will be able to claim IV-E FCM reimbursement for children impacted by the
updated guidance retroactively back to 10/1/2021. In order for reimbursement to be issued,
Title IV-E agencies must ensure the CANS/QRTP assessments and judicial
determinations are entered into Ohio SACWIS. To assist agencies with meeting
the above requirements prior the Ohio SACWIS functionality changes, agencies
can utilize the Qualified Residential Treatment Program Compliance report to
see any agency who has become compliant within a specified timeframe and the
Agency Placement Cost report to see all children in placement and their
placement provider’s agency (Network Agency).
To ensure agencies do not miss the required timeframes, it is critical
that agencies utilize these reports to monitor when the assessments and
judicial hearings are due for their children.
INSTRUCTIONS:
The following chart depicts what materials should be deleted
from the Family, Children and Adult Services Manual (FCASM) and what materials
are to be inserted in the FCASM.
LOCATION
|
REMOVE AND FILE AS OBSOLETE
|
INSERT/REPLACEMENT
|
PROCEDURE LETTERS
| |
FCASPL No. 381
|