Equipping agencies to respond to new joint IV-E/IV-D guidance on foster care referrals.

Last year, a joint letter from the Children’s Bureau and the Office of Child Support Services highlighted new guidance issued by the Children’s Bureau. The letter advises IV-E foster care agencies to refer cases to IV-D child support agencies. However, only after a thorough case review to ensure that such a referral would not impede the family reunification process. The intent is to mitigate financial hardships experienced by families seeking reunification while also being required to reimburse the state and federal government for foster care services.  

With the recent policy change, it is crucial to examine the circumstances leading to its implementation and the need to prepare agencies to respond to this change effectively. 

Historical Context and Consequences

Historically, states shouldered foster care financing until the 1970s, when federal reimbursement was linked to parental eligibility for Aid to Families with Dependent Children. In 1984, Congress mandated states to bill parents whose children received federally subsidized foster care under Title IV-E of the Social Security Act. The legislative intent was to instill a sense of shared responsibility. However, this imposed debt on parents inadvertently extended the time children spent in foster care. Economist Maria Cancian, Dean of Georgetown University’s McCourt School of Public Policy, revealed that even a nominal charge of one hundred dollars per month in child support resulted in an average extension of approximately 6.6 months in foster care duration.

The Family First Prevention Services Act, enacted in February 2018, marked a significant shift in federal child welfare financing and programs. This act emphasized prevention services, limited congregate care, and promoted family-based solutions. Its goal was to prioritize the safety and support of children within their families whenever feasible, thus focusing on reunification over adoption.  

Connection Between Foster Care and Child Support

The Child Support Enforcement Amendments of 1984 required states to provide Title IV-D child support services to any child receiving foster care maintenance payments (FCMPs) under Title IV-E and retain child support collections in certain foster care cases as reimbursement of FCMPs. To further reinforce parental responsibility for support, the Amendments also required IV-E agencies, where appropriate, to take all steps to secure an assignment of support rights on behalf of each child receiving FCMPs.   

At that time, the Children’s Bureau issued policy guidance requiring IV-E agencies to refer children receiving title IV-E foster care to IV-D child support agencies for enforcement but providing IV-E agencies flexibility in determining which cases were appropriate for referral. 

The evolution of federal legislation prioritizing family reunification changed the Children’s Bureau policy guidance. Rather than a case-by-case approach, ACF’s new policy “encourages child welfare agencies to implement across-the-board policies that require an assignment of the rights to child support for children who receive Title IV-E FCMPs only in rare circumstances.” 

The new joint IV-E/IV-D guidance highlights the government’s ongoing efforts to realign policies with the best interest of children and families. Effective implementation of this policy requires collaboration and communication between state child welfare and child support agencies. 

Equipping Agencies on How to Respond

For many states, the new IV-E/IV-D guidance is crucial to examine the circumstances leading to its implementation and prepare agencies. It is a cultural shift. Both agencies can benefit from an Organizational Change Management approach that includes the following framework and tools: 

Planning

• Conducting risk assessments.  
• Developing an implementation plan with timelines and identification of responsible parties or agencies.  
• Developing a communication plan. 
• Engaging stakeholders. 
• Establishing a resource strategy.  
• Realigning goals and objectives. 
• Reviewing laws, policies, and procedures for alignment with guidance. 

Communication

• Ensuring consistent messaging across both agencies. 
• Scheduling continuum meetings to maintain alignment. 
• Supporting supervision and stakeholder engagement. 

Resource Allocation

• Allocating necessary financial, human, and technological resources. 
• Investing in technology improvements for streamlined processes. 
• Utilizing federal funding for technical enhancements. 

Training

• Training staff on new guidance, processes, procedures, and terminology. 
• Training on trauma-informed care, cultural competency and biases, family-centered approaches, continuous quality improvement, and effective communication techniques. 

Public Knowledge®, Your Catalyst for Change

Public Knowledge® has significant child support and child welfare expertise. This allows us to effectively equip and guide your agency in responding to the new guidance. Our consultants understand child support and child welfare professionals’ unique challenges. We specialize in public policy, child support and child welfare laws, financials, business process redesign, and strategic planning. Additionally, we understand the importance of consistent professional development for optimal service delivery.