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6.16. Cost allocation
Answer
Yes. Section 474(a)(3)(C) and (D) of the Social Security Act mandates the 50% FFP rate.
Source/Date
11/9/2016
Legal and Related References
Section 474(a)(3)(C) and (D) of the Social Security Act.
Answer
Yes. FFP is available for CCWIS development and operational costs.
Source/Date
11/9/2016
Legal and Related References
Section 474(a)(3)(C) and (D) of title IV-E of the Social Security Act; 45 CFR 1355.57(e); 81 FR 35450 at 35475 (issued June 2, 2016); 80 FR 48220 at 48222 (issued August 11, 2015)
Answer
It depends.
Federal financial participation is not available to develop COTS products. Software developed using a CCWIS cost allocation must be owned by the state or tribe. The federal government must be granted a royalty-free, nonexclusive, and irrevocable license to reproduce, publish, or otherwise use and authorize others to use for federal government purposes, the software, modifications, and other documents produced.
However, CCWIS cost allocation may be available for COTS licensing fees for the use of COTS products. CCWIS cost allocation may also be available to configure and install COTS products.
Source/Date
11/9/2016
Legal and Related References
45 CFR 1355.57(e)(1); 45 CFR 95.617; 81 FR 35450 at 35475 (issued June 2, 2016); 80 FR 48220 at 48222 (issued August 11, 2015); ACF-OA-PI-31-01 (issued June 11, 2013)
Answer
No. These systems are not eligible for funding under the CCWIS cost allocation methodology.
Source/Date
11/9/2016
Legal and Related References
45 CFR 1355.57(f); 45 CFR 1356.60(d); 81 FR 35450 at 35475 (issued June 2, 2016); 80 FR 48200 at 48222 (issued August 11, 2015)
Answer
Pursuant to 1355.57(a) - (e), the title IV-E agency may allocate development costs using a CCWIS cost allocation methodology unless the automated functions in the CCWIS are:
- Duplicated in other systems supporting the state or tribe's title IV-E or title IV-B programs, pursuant to 1355.57(a)(2)(ii) and (b)(2)(ii);
- Not used consistently by all child welfare users responsible for the area supported by the automatic function, pursuant to 1355.57(a)(2)(ii) and (b)(2)(ii);
- Unique child welfare related program functions (such as juvenile justice and adult protective services) not used by the title IV-E program, pursuant to 1355.57(e) and (f) and 45 CFR 95.631; and
- Common or unique functions benefiting other health and human service programs (such as child'support, child care, Supplementary Nutritional Assistance Program, Temporary Assistance to Needy Families, Medicaid, courts and/or education programs), pursuant to 1355.57(e) and (f) and 45 CFR 95.631.
This question and answer is repeated in the Child Abuse and Neglect Systems section.
Source/Date
10/26/2017
Legal and Related References
45 CFR 95.631; 45 CFR 1355.52(e)(2)(i); 45 CFR 1355.57; 81 FR 35450 at 35473 - 35475 (issued June 2, 2016); 80 FR 48200 at 48213 and 48220 - 48222 (issued August 11, 2015)
Answer
Pursuant to 1355.57(e), the title IV-E agency must allocate development costs using a non-CCWIS cost allocation methodology if the automated functions reside in an external system.
This question and answer is repeated in the Child Abuse and Neglect Systems section.
Source/Date
10/26/2017
Legal and Related References
45 CFR 95.631; 45 CFR 1355.52(e)(2)(i); 45 CFR 1355.57; 81 FR 35450 at 35473 - 35475 (issued June 2, 2016); 80 FR 48200 at 48213 and 48220 - 48222 (issued August 11, 2015)
Answer
Pursuant to 1355.57(e), the title IV-E agency must allocate development costs using a non-CCWIS cost allocation methodology if the automated functions reside in both a CCWIS and an external system. The duplicated development costs are allocated to the benefiting program or programs. All programs pay their share of an automated function under a non-CCWIS cost allocation methodology.
This question and answer is repeated in the Child Abuse and Neglect Systems section.
Source/Date
10/26/2017
Legal and Related References
45 CFR 95.631; 45 CFR 1355.52(e)(2)(i); 45 CFR 1355.57; 81 FR 35450 at 35473 - 35475 (issued June 2, 2016); 80 FR 48200 at 48213 and 48220 - 48222 (issued August 11, 2015)
Answer
No. CCWIS cost allocation is only available for CCWIS automated functions that are not duplicated, pursuant to paragraphs 1355.57(a)(2)(ii) and (b)(2)(ii).
Source/Date
9/19/2019
Legal and Related References
45 CFR 1355.52(e)(1)(ii); 45 CFR 1355.57(a)(2)(ii) and (b)(2)(ii); 81 FR 35450 at 35461 - 35463 and 35474 - 35475 (issued June 2, 2016); 80 FR 48200 at 48211 - 48212 and 48221 (issued August 11, 2016)
Answer
No. CCWIS cost allocation is only available for automated functions that are not duplicated, pursuant to paragraphs 1355.57(a)(2)(ii) and (b)(2)(ii). It is irrelevant how the CWCA's information system is funded.
This question and answer is repeated in the Child Welfare Contributing Agencies section.
Source/Date
9/19/2019
Legal and Related References
45 CFR 1355.57(a)(2)(ii) and (b)(2)(ii); 81 FR 35450 at 35473 - 35475 (issued June 2, 2016); 80 FR 48200 at 48220 - 48221 (issued August 11, 2015)
Answer
A title IV-E agency must allocate project costs in accordance with applicable HHS regulations and other guidance pursuant to 1355.57(d). A state title IV-E agency must claim FFP for costs associated with a program only in accordance with its approved Public Assistance Cost Allocation Plan (PACAP). However, if a state title IV-E agency has submitted a PACAP or an amendment, it may, at its option claim FFP based on the proposed PACAP or amendment, unless otherwise advised by the Department of Health and Human Services (DHHS) Cost Allocation Services (CAS), pursuant to 45 CFR 95.517(a) and 95.631(b).
Tribal title IV-E agencies follow ACF's guidance, ACYF-CB-PI 10-13, for claiming FFP for a CCWIS. The Office of Grants Management (OGM) permits tribes, upon notification from OGM, to claim FFP based on a proposed Title IV-E Cost Allocation Methodology (CAM) or amendment.
Source/Date
4/3/2020
Legal and Related References
45 CFR 95.517(a); 45 CFR 95.631(b); 45 CFR 1355.57(d); 80 FR 48200 at 48221 - 48222 (issued August 11, 2015); ACYF-CB-PI-10-13 (issued November 23, 2010)
Answer
A title IV-E agency must allocate project costs in accordance with applicable HHS regulations and other guidance pursuant to 1355.57(d). A state title IV-E agency must claim FFP for costs associated with a program only in accordance with its approved Cost Allocation Methodology (CAM). However, if a state title IV-E agency has submitted a CAM or an amendment, it may, at its option claim FFP based on the proposed CAM or amendment, unless otherwise advised by the Department of Health and Human Services (DHHS), pursuant to 45 CFR 95.517(a) and 95.631(a).
Tribal title IV-E agencies follow ACF's guidance, ACYF-CB-PI 10-13, for claiming FFP for a CCWIS. The Office of Grants Management (OGM) permits tribes, upon notification from OGM, to claim FFP based on a proposed Development CAM or plan amendment.
Source/Date
4/3/2020
Legal and Related References
45 CFR 95.517(a); 45 CFR 95.631(a); 45 CFR 1355.57(d); 80 FR 48200 at 48221 - 48222 (issued August 11, 2015); ACYF-CB-PI-10-13 (issued November 23, 2010)
Answer
Certain training activities may be allowable CCWIS project activities provided the title IV-E agency describes the activities and costs in the applicable Advance Planning Document (APD) and ACF approves the activities and costs, pursuant to 45 CFR 95.610(b)(8).
In general, training activities directly related to the CCWIS design, development, installation, and operation are allowable CCWIS project activities, such as training for CCWIS project staff, technical training for system operators, and training the staff that will train workers and management staff. Examples of costs associated with such activities include costs for:
- salaries, fringe benefits, and travel of program and system project staffs directly involved in the development of training plans and materials;
- training of trainers;
- system resources needed to support the training effort; and
- salaries, fringe benefits and travel of trainers to conduct user training.
The costs for users to take CCWIS trainings (including time spent preparing for, traveling to, or participating in training) are not allowable CCWIS project activities; these costs may qualify for 75% FFP pursuant to paragraph 1356.60(b).
Source/Date
4/3/2020
Legal and Related References
45 CFR 95.610(b)(8); 45 CFR 1356.60(b); ACF-OISM-001 (issued: February 24, 1995); ACF-OSS-05 (reissued August 21, 1998)
Answer
It depends.
Title IV-E agencies may allocate costs to develop trainings (such as developing training materials, classroom presentations, and online trainings) according to the approved development cost allocation methodology per Action Transmittals (AT) ACF-OISM-001 and ACF-OOS-05.
Title IV-E agencies may allocate costs to deliver trainings (such as the costs of trainers to travel to classroom sites and the costs to deliver the training) during the CCWIS project's implementation phase according to the approved development cost allocation methodology per ACF-OISM-001 and ACF-OOS-05.
Title IV-E agencies may allocate the costs to deliver trainings during the CCWIS project's operational phase according to the approved operational cost allocation methodology per ACF-OISM-001 and ACF-OOS-05.
Source/Date
4/3/2020
Legal and Related References
45 CFR 95.631; ACF-OISM-001 (issued February 24, 1995); ACF-OSS-05 (issued: February 24, 1995 revised: August 21, 1998)
Answer
No. Only automated functions of a CCWIS may qualify for CCWIS cost allocation, pursuant to paragraphs 1355.57(a) and (b). However, another system supporting the child welfare program (such as a data warehouse containing CCWIS data) may qualify for non-CCWIS cost allocation pursuant to paragraph 1355.57(f).
Source/Date
4/3/2020
Legal and Related References
45 CFR 1355.57(a), (b), (c), and (f); 81 FR 35450 at 35473 - 35475 (issued June 2, 2016); 80 FR 48200 at 48220 - 48222 (issued August 11, 2015)