Several years have gone by since the Children’s Bureau (CB) of the Administration for Children and Families (ACF) released updated guidance as part of Comprehensive Child Welfare Information System (CCWIS) Technical Bulletins (TB) #7 and #8, that helped reshape how title IV‑E agencies can approach data governance, data exchange, and duplicative functions. The updates provided practical tools for assessing CCWIS progress, defining compliance expectations, and standardizing how data is shared across systems. Just as importantly, they signal a shift in how Child Welfare Contributing Agencies (CWCA) can support state and tribal programs. Creating new opportunities to better leverage CWCA technology investments that they have built and invested in, improve data quality, and strengthen coordination to achieve child safety and permanency outcomes.

CWCAs play a critical role in supporting states and tribes to implement their title IV-E program, often taking much of the direct responsibility for ensuring child safety, stabilizing families, and achieving placement permanency. To perform their roles well and efficiently, many CWCAs have invested in automating their business processes, and there is much that can be learned from these automation efforts as states and tribes continue their CCWIS journey. The reconsideration of how duplicative functions were defined demonstrates ACF’s focus on data management, governance, and quality efforts and reemphasized opportunities for title IV-E agencies to remain at the center of title IV-E data activities.

Why This Matters for CCWIS Compliance

CCWIS introduces significant opportunities to standardize data definitions and exchange processes across agencies. But these are also core requirements for compliance and federal funding. Successfully meeting these expectations requires coordinated ownership across your organization.

Data management is not solely an Information Technology (IT) responsibility. Maintaining data quality and compliance depends on clear roles and accountability across key stakeholders:

• Frontline staff directly impact data quality through how data is entered and used. Data creation and usage are the most critical points in the data lifecycle.
• Program leadership must define priorities and ensure data supports outcomes
• Governance structures must establish clear rules for how data is shared, stored, and secured across partners

Without alignment across these roles, agencies risk inconsistent data, ineffective data exchange, and noncompliance with CCWIS requirements, which puts federal funding at risk.

Include CWCAs in Your Data Governance Strategy

To further meet CCWIS requirements and ensure effective data exchange, you must actively include CWCAs in your data governance strategy.

Bi-directional data exchange introduces cross-sector data management challenges that require shared standards and ongoing coordination with external partners. Without alignment, agencies risk inconsistent data, incompatible systems, and noncompliance with CCWIS requirements.

Establishing cross-agency working groups or advisory structures can help sustain collaboration and define how data is governed, shared, and maintained across partners.

Just as importantly, collaboration must extend beyond technical teams. Limiting discussions to IT staff from state agencies and CWCAs creates critical gaps in understanding and missed opportunities to strengthen partnerships.

Without broader engagement:

• Program leadership cannot define which data is most critical for services and outcomes
• Technical teams lack insight into how data quality issues originate at the frontline level

Expanding collaboration across program, technical, and partner agencies not only improves data quality and compliance—it also strengthens long-term relationships with CWCAs.

Next Steps You Can Take Today

1. Define Stakeholders Early: Identify the stakeholders who need to be involved and align shared goals across data exchange sectors (e.g., Education, Courts, and Medicaid) before defining standards. Establish common priorities and develop a governance charter to guide decision-making and keep teams focused on high-impact outcomes. While some agencies may need to align internally first, be sure to engage CWCAs once core decisions and processes are defined.
2. Use the TB #7 tools advantageously. TB #7 contains information for technical assistance (TA) activities throughout the lifecycle of CCWIS and how these activities should be viewed as a collaborative effort between the title IV-E agency and ACF. TA activities should be viewed as iterative processes that will need to be adaptable to the changing phases of a project lifecycle. The Self-Assessment Tools that are referenced in TB #7 will help agencies frame compliance criteria more discretely and can also help with procurement and contract requirements.
3. Use TB #8 to open the dialogue on data exchange standards. Required and recommended data exchange standards are clarified to a point, but the title IV-E agency will still need to decide on specific standards. Collaboration with CWCAs should be an ongoing dialogue that helps both title IV-E agency and CWCAs achieve their goal of protecting their state’s most vulnerable citizens. Title IV-E agencies and CWCAs may have their own data standards, but by working together, they will have a better chance of defining a data exchange standard that meets both their needs.

Connect with us to get expert support to define your CWCA data strategy and meet CCWIS compliance requirements.

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Public Consulting Group LLC (PCG) is a leading public sector solutions implementation and operations improvement firm that partners with health, education, and human services agencies to improve lives. Founded in 1986 and headquartered in Boston, Massachusetts, PCG employs over 2,500 professionals in more than 40 offices worldwide. PCG offers Human Services consulting services and technology solutions that help state and local child welfare, children and juvenile justice services, public assistance, workforce and economic development, aging and disability, public health and veteran services programs. To learn more, visit Human Services Consulting | PCG.