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6.10A. Initial submission
Answer
No. A record from the title IV-E agency signed by the governor, tribal leader, or designated state or tribal official notifying ACF that the title IV-E agency elects not to transition a S/TACWIS project to a CCWIS project is sufficient. However, the IV-E agency must continue to submit applicable APDs for the non-CCWIS project.
Source/Date
10/27/2016
Legal and Related References
45 CFR 95 Subpart F; 45 CFR 1355.51; 45 CFR 1355.52(i)(1); 45 CFR 1355.56(d)(1) 81 FR 35450 at 35467 - 35468 and 35473 (issued June 2, 2016); 80 FR 48200 at 48205, 48216 - 48217, and 48220 (issued August 11, 2015)
Answer
The start date of a CCWIS project is the date ACF indicates in its response letter to an approvable submission from the title IV-E agency.
Source/Date
10/27/2016
Legal and Related References
45 CFR 95 Subpart F; 45 CFR 1355.51; 45 CFR 1355.52(i)(1); 81 FR 35450 at 35467 - 35468 (issued June 2, 2016); 80 FR 48220 at 48205 and 48216 - 48217 (issued August 11, 2015)
Answer
The submission must meet the requirements of 1355.52(i)(1), which means that the title IV-E agency must submit an Advance Planning Document (APD) or, if below the APD submission thresholds defined at 45 CFR 95.611, a Notice of Intent. The APD or Notice of Intent must include:
- A description of how the CCWIS will meet the requirements in1355.52 (a) through (h) and, if applicable 1355.54;
- A list of all automated functions included in the CCWIS; and
- A notation of whether each automated function included in the CCWIS meets, or when implemented will meet, the following requirements:
- The automated function supports at least one requirement of 1355.52 or, if applicable,1355.54;
- The automated function is not duplicated within the CCWIS or systems supporting child welfare contributing agencies and is consistently used by all child welfare users responsible for the area supported by the automated function; and
- The automated function complies with the CCWIS design requirements at 1355.53(a), unless exempted in accordance with 1355.53(b).
Source/Date
10/27/2016
Legal and Related References
45 CFR 95 Subpart F; 45 CFR 1355.51; 45 CFR 1355.52(i)(1); 81 FR 35450 at 35467 - 35468 (issued June 2, 2016); 80 FR 48220 at 48205 and 48216 - 48217 (issued August 11, 2015)
Answer
Yes, if the contract service provider meets the definition of a child welfare contributing agency, any automated functions in the provider's system that duplicate automated functions in CCWIS must be included in the automated function list described in paragraph 1355.52(i)(1)(ii). Per section 1355.51, a child welfare contributing agency is a public or private entity that, by contract or agreement with the title IV-E agency, provides child abuse and neglect investigations, placement, or child welfare case management (or any combination of these) to children and families.
Source/Date
10/27/2016
Legal and Related References
45 CFR 1355.51; 45 CFR 1355.52(i)(1); 81 FR 35450 at 35453 and 35468 (issued June 2, 2016); 80 FR 48220 at 48205 and 48216 - 48217 (issued August 11, 2015)
Answer
Yes. The list includes existing automated functions of the transitioning system that will be used in the CCWIS as well as newly developed automated functions that will be part of the CCWIS. Providing this list in addition to the more detailed information required in paragraph 1355.52(i)(1)(iii) at the start of a CCWIS project will help both ACF and the title IV-E agency to more reliably estimate project costs.
Source/Date
10/27/2016
Legal and Related References
45 CFR 1355.52(i)(1); 80 FR 48220 at 4648216 - 48217 (issued August 11, 2015)
Answer
No. While the title IV-E agency is required to include the system description and automated function list as specified in 1355.52(i)(1)(i) - (iii) when submitting an APD notifying ACF of the agency's plan to implement a CCWIS, the information may be integrated into the APD project documentation described at 45 CFR 95.610.
Source/Date
2/12/2018
Legal and Related References
45 CFR 95.610; 45 CFR 1355.52(i)(1); 81 FR 35450 at 35467 - 35468 (issued June 2, 2016); 80 FR 48200 at 48216 - 48217 (issued August 11, 2015)
Answer
Yes. An electronic data exchange is "a computerized process or collection of related processes to achieve a purpose or goal" and therefore is an automated function as defined at paragraph 1355.51(a).
Source/Date
9/19/2019
Legal and Related References
45 CFR 1355.51(a); 45 CFR 1355.52(i)(1)(ii); 80 FR 48200 at 48204 - 48205 and 48216 (issued August 11, 2015)
Answer
The title IV-E agency must report only automated functions that support the child welfare program on the list of automated functions. This includes: 1) automated functions that only support child welfare; and 2) automated functions that support child welfare and another program. Previous policy required that a title IV-E agency developing or operating a CCWIS as part of an enterprise system report all automated functions of the entire system. We revised this policy to reduce requirements and provide more flexibility in meeting the CCWIS design requirements.
This question and answer is repeated in the On-going Submission section.
Source/Date
09/19/2019; updated 07/11/2023
Legal and Related References
45 CFR 95. 605; 45 CFR 95.610; 45 CFR 1355.52(i)(1)(ii) and 1355.53(a); 80 FR 48200 at 48216 - 48218 (issued August 11, 2015)
Answer
"Consistently used" means that public and private child welfare workers use an automated function as required by the title IV-E agency. Examples of an automated function not being consistently used are:
- workers interpreting data fields differently than instructed and entering incorrect data because the CCWIS data fields are not clearly labeled; and
- workers skipping required steps and screens because they are not consistently trained on the CCWIS case management tool.
The phrase "by all child welfare workers responsible for the area supported by the automated function" means that all workers responsible for a task use the automated function(s) designed for the task in the manner required by the title IV-E agency. Examples of all workers responsible for a task not using the required automated function are:
- some workers using different automated assessment tools when the title IV-E agency requires that all workers conducting assessments use a specified automated assessment tool; and
- some workers not entering home visit notes into CCWIS within the timeframe required by the title IV-E agency.
This question and answer is repeated in the Cost Allocation for Transitioning Systems and Cost Allocation for New CCWIS sections.
Source/Date
9/19/2019
Legal and Related References
45 CFR 1355.52(i)(1)(iii)(B); 45 CFR 1355.57(a)(2)(ii) and (b)(2)(ii); 81 FR 35450 at 35468 and 35474 - 35475 (issued June 2, 2016); 80 FR 48200 at 48217 and 48221 (issued August 11, 2015)
Answer
A title IV-E agency determines that a CCWIS automated function is duplicated within the CCWIS if more than one automated function within the CCWIS supports the same child welfare business practice. For example, it is duplication if a CCWIS has an automated function to record contacts with children during home visits and another to record similar information from family members during home visits.
A title IV-E agency determines that a CCWIS automated function is duplicated within systems supporting child welfare contributing agencies (CWCAs) if at least one automated function in any CWCA system supports the same child welfare business practice as the CCWIS automated function. For example, it is duplication if a CCWIS and a CWCA system each had an automated function for matching children to placements.
This question and answer is repeated in the Cost Allocation for Transitioning Systems and Cost Allocation for New CCWIS sections.
Source/Date
9/19/2019
Legal and Related References
45 CFR 1355.52(a)(3); 45 CFR 1355.52(i)(1)(iii)(B); 45 CFR 1355.57(a)(2)(ii) and (b)(2)(ii); 81 FR 35450 at 35468 and 35474 - 35475 (issued June 2, 2016); 80 FR 48200 at 48203 - 48204, 48206, 48217 and 48221 (issued August 11, 2015)
Answer
On the list of automated functions, the title IV-E agency must report:
- The shared platform;
- automated functions that support the child welfare program but are not on the shared platform; and
- automated functions running on the shared platform, such as a document management function, that support the administration of title IV-B and IV-E plans, per 1355.52(i)(1)(ii).
We revised this policy to reduce requirements and provide more flexibility in meeting the CCWIS design requirements.
This question and answer is repeated in the On-going Submission section.
Source/Date
5/15/20; updated 07/11/2023
Legal and Related References
45 CFR 95.610; 45 CFR 1355.52(i)(1)(ii); 81 FR 45450 at 35467 – 35468 (issued June 2, 2016); 80 FR 48200 at 48216 – 48217 (issued August 11, 2015)
Answer
It depends.
If the title IV-E agency reports planned development work on the automated function in an APD, and the schedule indicates that work on that function will start or continue during the current annual APD reporting cycle, the agency will report both the planned and the existing functions on the automated function checklist. For example, if an agency plans to replace an existing automated function to eliminate duplication during the current annual APD reporting cycle, then the agency indicates on the automated function checklist:
1. the planned function that will eliminate duplication and notes it is unduplicated per 1355.52(i)(1)(iii)(B); and
2. the existing function and notes it is duplicated per 1355.52(i)(1)(iii)(B).
However, if ACF does not approve the plan, the agency may be required to revise the automated function checklist.
In this example, if the title IV-E agency does not commit to start or continue to work on the planned automated function within the current annual APD reporting cycle, then the agency reports only the existing automated function on the checklist and notes it is duplicated per 1355.52(i)(1)(iii)(B).
This question and answer is repeated in the On-going submission section.
Source/Date
9/4/2020
Legal and Related References
45 CFR 95.610(c); 45 CFR 1355.52(i); 81 FR 35450 at 35467 – 35468 (issued June 2, 2016); 80 FR 48200 at 48216 – 48217 (issued August 11, 2016)
Answer
A CCWIS automated function is duplicated within the CCWIS if more than one automated function within the CCWIS itself supports the same child welfare business practice. If automated functions supporting child welfare business processes in the CCWIS are duplicated in a child welfare contributing agency (CWCA), we no longer consider that to conflict with the regulatory requirement for non-duplication. This is because, our initial interpretation is unduly narrow and may be a disincentive for title IV-E agencies to continue to innovate and update the CCWIS and contract with CWCAs for services as needed. Duplication exists only if an automated function for the same child welfare business practice within the CCWIS itself is duplicated, and not across the CCWIS and CWCAs. For example, it is no longer considered a duplicated function if the CCWIS supports foster care placement activities and a CWCA system duplicates that support. Therefore, CCWIS automated functions that are duplicated by automated functions in a CWCA may qualify for CCWIS cost allocation.
This question and answer is repeated in the Cost Allocation for Transitioning Systems and Cost Allocation for New CCWIS sections.
Source/Date
2/3/2022
Legal and Related References
45 CFR 1355.52(a)(3); 45 CFR 1355.52(i)(1)(iii)(B); 45 CFR 1355.57(a)(2)(ii) and (b)(2)(ii)