News & Perspectives

Child Welfare Funding Updates in Response to the COVID-19 Emergency

21. April 2020 PCG Human Services

Updated: May 20th, 2020

Families First Coronavirus Response Act (FFCRA)

Federal Medical Assistance Percentage (FMAP) Increase

Title IV-E: Increases the FMAP rate defined in Section 1905(b) of the Social Security Act by 6.2%.

Title XIX: Increased FMAP is available for allowable Medicaid medical assistance expenditures for which federal matching is paid ordinarily at the state-specific FMAP rate defined in Section 1905(b) of the Act. Note: States do not need to submit a State Plan Amendment or a waiver for the increase, unless there are tests or treatments not currently in their state plan that can be/will be used to treat COVID-19.

Opportunities to reimburse provider payments at a higher FMAP rate for eligible portions:

Increase payments to congregate care providers, e.g., providing lump-sum provider-relief payments to help support costs such as hazard pay for direct care staff, additional sanitation and protective equipment supply expenses, and additional sick-leave coverage for direct care staff; or re-evaluating overall provider payment rates to cover additional costs.

Coronavirus Aid, Relief, and Economic Security Act (CARES Act)

Stimulus Rebates
One-time direct payments to individuals according to income levels from 2018 and 2019 income tax returns, and payment per child under age 17 who is claimed as a dependent.

Opportunities to support foster parents who may not be eligible for the dependent child rebates:

Increase personal incidentals for foster children considering offsets from decreased transportation costs, extracurricular/fun activity costs, etc.

Increase to Title IV-B

Includes $45 million in funding for Child Welfare Services under Title IV-B, which provides grants to states and tribes to develop and expand services to protect and promote the welfare of all children. This will be distributed to states based on the current Title IV-B Subpart 1 formula.

Extra: Key Provisions of the CARES Act for Community-Based Human Service Organizations

Federal Emergency Management Agency (FEMA) Funding

Under the agency’s Public Assistance Program and the Robert T. Stafford Disaster Relief and Emergency Assistance Act, reimbursement of eligible emergency protective measures taken to respond to the COVID-19 emergency is allowed at the direction of public health officials. FEMA assistance will be provided at the 75% federal cost share. FEMA will not duplicate assistance provided by the Department of Health and Human Services (HHS), including the Centers for Disease Control and Prevention, or other federal agencies.

Opportunities to consider using funding:

Childcare, supplies (personal protective equipment, PPE, for social workers), meals (per diems for emergency workers), emergency shelters, etc.

Title IV-E Flexibilities Allowable Under the Stafford Act

The Children’s Bureau identifies the following selected requirements as administrative conditions under the Stafford Act that a Title IV-E agency may request flexibility in meeting requirements. Flexibility under the Stafford Act applies only to jurisdictions that have major disaster declarations, and only during the time the Title IV-E agency is unable to meet a requirement because of the major disaster.

Title IV-E Eligibility for Youth, Ages 18 and Older — Simplified Process: Title IV-E agencies may request a simplified process for extending Title IV-E assistance instead of submitting a Title IV-E plan amendment.

Title IV-E Assistance for Youth, Ages 18 and Older – Education and Employment Conditions: Requirements for extended eligibility for Title IV-E assistance with respect to foster care, adoption, and legal guardianship services, related to 

education and employment, may be modified for youth, ages 19-21, who are unable to fulfill this requirement as a direct result of the COVID-19 emergency.

Accreditation and Re-Accreditation of Qualified Residential Treatment Programs (QRTPs): If conditions related to the COVID-19 emergency prevent a facility from completing its accreditation or re-accreditation as a QRTP, the Title IV-E agency may request flexibility that allows it to claim reimbursement of Title IV-E expenses on behalf of an otherwise eligible child who is placed in the QRTP.

Provisional Licensure for Foster Family Homes: Title IV-E agencies may request flexibility that allows them to claim Title IV-E reimbursement on behalf of an otherwise eligible child who is placed in a foster family home that is provisionally or conditionally approved or licensed, if the declared major disaster precludes full completion of the licensing process.

How To Request Flexibility

Title IV-E agencies in jurisdictions that have major disaster declarations that want to request flexibility in meeting requirements, must complete Attachment A (and Attachment B, if applicable), included in the PI, and submit it to its designated Children’s Bureau Regional Program Office.

Department of Housing and Urban Development (HUD) Funding

HUD awarded $24.4 million to public housing authorities nationwide through the Family Unification Program to provide stable housing to young adults (ages 18 24) who have aged out of the foster care system and are at risk of homelessness, and families whose lack of adequate housing is the primary reason their children are in foster care.

Additional Administration for Children and Families (ACF) Guidance & Resources

Family First Transition Act Transition Grants: ACF will not require a separate application for this funding. Transition Grants may be used for any purpose specified in Title IV-B Subparts 1 and 2. Funds may also be used for activities directly associated with implementation of the Families First Prevention Services Act (FFPSA). Funds are estimated to be released by June 2020.

Kinship Navigator Funding: ACF announced a deadline extension for these applications until May 1, 2020. This funding is noncompetitive funding to support the development, enhancement, or evaluation of kinship navigator programs.

ACF Grant Flexibilities in Conducting Human Service Activities: States can continue charging salaries to the federal grant in accordance with how salaries are paid now. ACF will accept other allowable costs (e.g., program-related, allocable, and reasonable costs) that are necessary to resume activities supported by the award—to be charged to the awards, consistent with applicable federal cost principles and the benefit to the project.

Reference: Information Memorandum IM-ACF-OA-2020-01

Video Conferencing Guidelines & Resources: During circumstances when an emergency prohibits or strongly discourages person-to person contact for public health reasons, the in-person child/caseworker home visit requirement is waived, and monthly caseworker visits are permitted to be accomplished through video conferencing.

Legal & Court Requirements: ACF identifies statutory requirements that cannot be waived, and delivers the expectation that courts and states will work together to determine how best to balance child safety-related statutory requirements against public health mandates, and that courts can and should use flexible means of convening required hearings.

COVID-19 Resources for Child Welfare: Select resources outlining guidance for social workers and caregivers to support and address the unique needs of children, youth, and families during the COVID 19 emergency.

Allowable Costs for Cell Phone & Maintaining Contact: The purchase and operation of cell phones for children/youth in foster care, their parents, or foster parents is allowable under Title IV-B and/or the Chafee Program. Resources available through Assurance Wireless offer eligible low-income individuals a free phone, free monthly minutes, free monthly data, and unlimited texting.

Allowable Costs for Personal Protective Equipment (PPE): PPE used by child welfare caseworkers to minimize exposure to COVID-19 is an allowable case management administrative cost under Title IV-E, and an allowable expenditure of Title IV-B funds, for purposes such as caseworker visits by state and tribal Title IV-B agencies. Under Title IV-B, the purchase of PPE for providers, such as foster parents, kinship providers, and staff of child care institutions, may be allowable if it fits within one of the purposes outlined under Title IV-B, Subpart 2.

Title IV-E Reviews Postponed Indefinitely: ACF announced an updated postponement of Title IV-E Foster Care Eligibility Reviews, and the National Youth in Transition Database Reviews, for the foreseeable future, in response to the COVID-19 public health emergency.

Existing Title IV-E Flexibilities: ACF highlighted a number of existing Title IV-E flexibilities of which states can take advantage, that may help agencies better serve children, youth, and families, during the COVID-19 emergency.

  • Title IV-E agencies may establish a rate structure that enhances foster care maintenance payment (FCMP) for children who have tested positive for COVID-19.
  • Title IV-E agencies may establish and apply modified foster family home licensing standards.
  • Title IV-E agencies may claim a full month’s foster care maintenance payment (FCMP), if a child’s brief absence from an otherwise allowable provider does not exceed 14 days, and the child’s placement continues with the same provider after the absence, as long as all other eligibility requirements are met.
  • Title IV-E agencies are encouraged to allow for quick and developmentally-appropriate re-entry into foster care for youth over age 18.
  • Federal child welfare laws do not dictate a distinction between hazard pay and other types of pay. States and tribes determine worker salaries, and Title IV-E agencies may claim any allowable Title IV-E administrative costs associated with this work.
  • Title IV-E agencies with the approved Title IV-E plan amendment to serve youth in foster care until age 21, or agencies that are operating a comparable program using state or tribal funds, may extend Chafee Program services until age 23.