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.