Finding Text
45 CFR § 1356.60(a)(1)(i) states "Federal financial participation (FFP) is available to title IV-E agencies under an approved title IV-E plan for allowable costs in expenditures for foster care maintenance payments as defined in section 475(4) of the Act, made in accordance with §§ 1356.20 through 1356.30, section 472 of the Act, and, for a Tribal title IV-E agency, section 479B of the Act..." Ohio Admin. Code § 5101:2-47-11 states:
"(A) In order to be reimbursed for Title IV-E foster care maintenance (FCM) costs when a child is placed in a children’s residential center (CRC), group home, maternity home, residential parenting facility, or with a parent in a substance use disorder (SUD) residential facility as defined in rule 5101:2-1-01 of the Administrative Code a JFS 02911 "Title IV-E Single Cost Report" as described in rule 5101:2-47-26.1 of the Administrative Code is to be submitted to the Ohio department of job and family services annually. Agencies certified prior to October 1, 2020 have until October 1, 2024 to become compliant with the requirements related to meeting qualified residential treatment program (QRTP) standards.
(B) If a JFS 02911 cost report has been approved for children placed in a CRC, group home, maternity home, residential parenting facility or SUD residential facility, two Title IV-E reimbursement ceiling amounts are calculated and rounded to the nearest dollar.
(1)The FCM reimbursement ceiling amount is based on reported and allowable FCM costs.
(2)The Title IV-E administration reimbursement ceiling amount is based on reported allowable Title IV-E administration costs.
(C) Reimbursement to the Title IV-E agency for children placed in a CRC, group home, maternity home, residential parenting facility, or SUD residential facility is based on the lesser of:
(1)The FCM reimbursement ceiling amount established by the JFS 02911 multiplied by the number of care days or the amount paid by the Title IV-E agency for foster care maintenance.
(2)The administration reimbursement ceiling amount established by the JFS 02911 multiplied by the number of care days or the amount paid by the Title IV-E agency for administration."
Furthermore, Ohio Admin. Code § 5101:2-47-11(G) states:
"To receive reimbursement a Title IV-E agency processing their payments and seeking reimbursement from Ohio statewide automated child welfare information system (SACWIS) is to:
(1)Record placement, service authorization and placement cost information for each child.
(2)Generate a payment by creating a payment request and sending the payment information to the county auditor for payment.
(3)Disburse payments through the county auditor at any point during a month. These payments will be reimbursed during the monthly reimbursement process conducted by ODJFS on the first business day of the following month.
(4)Access reports to review all itemized reimbursements and assure the reimbursements are accurate."
The Children's Services Department completed the required reporting within the SACWIS system; however, due to lack of controls over review of the system for accuracy, the August 2023 reimbursement was overpaid by 12 care days for one child. The SACWIS report was used for federal reimbursement to the Children's Services Department and thus resulted in $1,628 more in reimbursements than the department was entitled based on the provider invoices.
Failure to properly report number of care days can result in loss of revenue, excess reimbursements, and/or federal questioned costs. The Logan County Children's Services Department should implement policies and procedures to ensure the accuracy of data input within the SACWIS system.