department of health & human services …principal deputy assistant secretary for children and...

of Inspector GeneralDEPARTMENT OF HEALTH & HUMAN SERVICES Office

Memorandum Date =p 2 1997

From June Gibbs Brown Inspector Gener &

Subject Audit of Fost r Car Training Administrative Costs Claimed for Federal Reimbd“ ent by the California Department of Social& Services (A-09-96-00066)

To Olivia A. GoldenPrincipal Deputy Assistant Secretary

for Children and Families

This memorandum is to alert you to the issuance on September 4, 1997 of our final audit report. A copy is attached.

The objective of our audit was to determine whether the State ofCalifornia, Department of Social Services (State) claimedadministrative costs related to foster care training at theappropriate rate of 50 percent instead of the 75 percent rateallowed for certain training dosts specified by Federal regulations.Our audit was initiated based on problems identified in recentaudits performed by the Office of Inspector General, Office of AuditServices in California and several other States and covered theperiod July 1, 1994 through December 31, 1995.

We found that the State inappropriately claimed administrative costs related to foster care training at the enhanced rate of 75 percent instead of the rate of 50 percent allowed by Federal regulations for such costs. Our audit disclosed that about $8.4 million was claimed at the inappropriate rate, resulting in an overclaim of Federal funds of $2.1 million. We are recommending that the State refund the $2.1 million to the Federal Government and revise its instructions to the counties in California to ensure that only eligible costs are claimed at the 75 percent enhanced rate.

Our audit also disclosed that the State made two duplicate claimstotaling $6.8 million (Federal share $4.5 million) due toadministrative and procedural errors in the preparation of quarterlystatements of expenditures used for claiming Federal funds. We arerecommending that the State refund the $4.5 million, but we are notrecommending procedural changes because the State had alreadyinitiated corrective action.

- Olivia A. Golden

In addition, the State did not provide sufficient documentation tosupport some of the costs that were claimed as matching to meet theState’s cost sharing requirements for certain costs claimed at the75 percent rate. We identified $3.8 million (Federal share $2.8million) of such inadequately supported costs claimed. We arerecommending that the State provide support to the Administrationfor Children and Families for inadequately documented costs, or makean appropriate adjustment for costs which cannot be supported.

The State, in response to the draft report, concurred with therecommendation to refund the $4.s million for the duplicate claims,but did not agree with the findings and recommendations relating tothe recommended refund of $2.1 million or the unsupported costs of$3.8 million. The State did not agree that the regulations limitedFederal reimbursement of training-related administrative costs to 50percent, and commented that it considered the documentation providedin support of the costs claimed to meet its matching requirements tobe sufficient.

my questions or comments on any aspect of this memorandum arewelcomed. Please call me or have your staff contact:

Lawrence FrelotRegional Inspector General for Audit Services50 United Nations Plaza, Room 171San Francisco, CA 94102(415) 437-8360

Attachment

Department of Health and Human Services

OFFICE OFNSPECTOR GENERAL

,..

AUDIT OF FOSTER CARE TRAINING ADMINISTRATIVE COSTS CLAIMED FOR

FEDERAL REIMBURSEMENT BY THE CALIFORNIA

DEPARTMENT OF SOCIAL SERV CES

$iCvxrs

# ~

.‘4 c DEPARTMENT OF HEALTH & HUMAN SERVICES Office Inspector Generalg of ; 8 -+J+.%m Region IX

Office of Audii Services 50 United Nations Plaza San Francisw, CA 94102

CIN: A-09-96-OO066

Eloise Anderson, Director Department of Social Services 744 P Stree~ M.S. 1711 Sacramento, California 95814

Dear Ms. Anderson:

Enclosed are two copies of the U.S. Department of Health and Human Services, OffIce of Inspector General, Office of Audit Services’ report entitled “AUDIT OF FOSTER CARE TRAINING ADMINISTRATIVE COSTS CLAIMED FOR FEDERAL REIMBURSEMENT BY THE CALIFORNIA DEPARTMENT OF SOCIAL SERVICES.”

Final determination as to actions taken on all matters reported will be made by the HHS action ofilcial named below. We request that you respond to the HHS action official within

30 days from the date of this letter. Your response should pre~ent any comments or additional information that you believe may have a bearing on the final determination.

In accordance with the principles of the Freedom of Information Act (Public Law 90-23), OIG, OAS reports issued to the Department’s grantees and contractors are made available, if requested, to members of the press and general public to the extent tiormation contained therein is not subject to exemptions in the Act which the Department chooses to exercise. (See 45 CFR Part 5.)

To facilitate identification, please refer to Common Identification Number A-09-96-00066 in - all correspondence relating to this report.

Lawrence Frelot Regional Inspector General

for Audit Services

Enclosures

Direct Reply to HHS Action Official: Sharon M. Fujii, Regional Administrator Administration for Children and Families, HHS 50 United Nations Plaza, Room 351 San Francisco, CA 94102

EXECUTIVE SUMMARY

BACKGROUND

This report presents the results of our audit of administrative costs related to training provided to current and prospective employees and claimed for Federal reimbursement by the California Department of Social Services (State) under title IV-E (Foster Care program) of the Social Security Act. Federal financial participation is available at a rate of 75 percent in certain costs of training staff employed or preparing for employment by the State or local agency administering Foster Care programs. This is an enhanced rate over the 50 percent rate for administrative costs necessary for the operation of States’ Foster Care programs, including administrative costs related to training. The audit covered the period July 1, 1994 through December 31, 1995.

The primary objective of our audit was to determine whether the State claimed administrative costs related to foster ‘care training at the appropriate rate of 50 percent instead of ““ 75 percent rate allowed for certain training costs specified by Federal regulations.

SUMMARY OF FINDINGS

ADMINISTRATIVE COSTSCLAIMEDAT 75 PERCENTRATE

Inamn-opriatelv Claimed Costs. The State inappropriately claimed administrative costs related to foster care training at the enhanced rate of 75 percent rather than the allowable rate of 50 percent. We identified $8.4 million inappropriately claimed at the 75 percent rate, resulting in an overclaim of Federal Iimds totaling $2.1 million. The costs related to county welfare departments, probation departments, and State and county contracts with universities and did not meet the deftition of costs eligible for the enhanced rate under Federal regulations for the Foster Care programs.

Insufficient Documented Costs. The State did not provide sufficient documentation to support some of the costs that were claimed as matching costs to meet the State’s cost sharing requirement for certain costs claimed .at the 75 percent enhanced rate. We identified $3.8 million (Federal share $2.8 million) of such inadequately supported costs claimed. In some instances, information provided by the State was not sufficient to determine the allowability of the costs under Federal regulations; in other instances, the information was not sufficient to distinguish between (i) costs related to training activities reimbursable at the 75 percent rate, and (i) costs for administrative activities reimbursable at the 50 percent rate.

DUPLICATECOSTSCLAIMED

In its quarterly statements of expenditures, the State included adjustments to costs claimed for Federal reimbursement which resulted in two duplicate claims totaling $6.8 million (Federal

i

share $4.5 million). One duplicate claim resulted from an apparent lack of understanding on how to claim child welfare information system costs that were allowable at the 75 percent rate. This resulted in the same costs being claimed under two different cost categories. The other duplicate claim resulted from an administrative error which duplicated an earlier adjustment for underclaimed costs.

We recommend that the State refund $6.6 million, which includes $2.1 million due to the inappropriate use of the 75 percent rate, and $4.5 million resulting from the duplication of costs. We also recommend that the State provide documentation for the unsupported costs claimed or make an appropriate refund of costs which cannot be supported. Our report also includes various procedural recommendations.

The State concurred with the recommended refund of $4.5 million resulting in duplicate claims. However, the State did not concur with the recommended refund of $2.1 million in administrative costs claimed at the enhanced rate of 75 percent or the finding and recommendation relating to the $3.8 million (Federal share $2.8 million) of inadequately supported costs set aside. The State did not agree that the regulations limited Federal reimbursement of training-related administrative costs to 50 percent, and commented that it considered the documentation provided in support of the costs claimed to meet its matching requirements to be sufficient.

TABLE OF CONTENTS

EXECUTIVE SUMMARY

BACKGROUND

OBJECTIVE

SUMMARY OF FINDINGSADMINISTRATIVE COSTS CLAIMED AT 75 PERCENT RATE

Inappropriately Claimed CostsInsufficiently Documented Costs

DUPLICATE COSTS CLAIMEDRECOMMENDATIONS

INTRODUCTION

BACKGROUND

SCOPEProbation IV-E TrainingFoster Care TrainingState and Local TrainingAdjustments

FINDINGS AND RECOMMENDATIONS

ADMINISTRATIVE COSTS CLAIMED AT 75 PERCENT FFP RATECRITERIA

Provisions for Federal RegulationsDepartmental Appeals Board (DAB) Decisions

COSTS CLASSIFIED AS PROBATION TMININGCounty Welfare DepartmentsCounty Probation Department - LA County

LA COUNTY CONTRACTS WITH UNIVERSITIES

STATE CONTRACT WITH UC BERKELEY

COSTS SET ASIDE - STATE CONTR4CT WITH UC BERKELEY

RECOMMENDATIONS

STATE COMMENTS AND OIG RESPONSE

i

i

i

i i i i i

ii

1

1

1 2 3 3 3

4

5 5 5 6

7 7 8

8

9

10

12

12

TABLE OF CONTENTS

Interpretation of Federal Foster Care RegulationsState, CommentsOIG Response

Applicability of title IV-A RegulationsState CommentsOIG Response

Deftition of AdministrationState CommentsOIG Response

OIG Use of DAB DecisionsState CommentsOIG Response

Support of Matching CostsState CommentsOIG Response

DUPLICATE COSTS CLAIMED

SACWIS OVERCLAIM

DUPLICATE ADJUSTMENT

RECOMMENDATION

STATE COMMENTS

APPENDIX A - Letter Transmitting State Comments to Draft ReportAPPENDIX B - Index to State’s ResponseAPPENDIX C - Narrative of State’s ResponseAPPENDIX D - Supporting Documentation Attached to State’s Response

12 12 13 13 13 13 13 13 14 14 14 14 14 14 14

15

15

15

16

16

INTRODUCTION

This report presents the results of our audit of administrative costs related to training provided to current and prospective employees and claimed for Federal reimbursement by the State under title IV-E (Foster Care program) of the Social Security Act. The audit was initiated based on problems identified in recent audits performed by the OffIce of Inspector General (OIG) Office of Audit Services in California and several other States.

In Californi~ the State is responsible for the overall supervision of foster care training programs. The 58 counties in California provide administration at the local level. For the 18-month period of our audit the State reported a total of $71.0 million in foster care training costs, of which $53.3 million was claimed for Federal reimbursement.

BACKGROUND

The Adoption Assistance and Child Welfare Act of 1980 (Act), Public Law 96-272, established the title IV-E program - Federal Payments for Foster Care and Adoption Assistance. Under section 474 of the Act, States are entitled to 75 percent Federal financial participation (FFP) to cover the eligible costs of training State and local personnel who administer the Foster Care program.

Provisions for claiming Federal reimbursement for the cost of administering the Foster Care program are codified in Title 45 of the Code of Federal Regulations (CFR). Section 1356.60(b) of the regulation provides for FFP at the rate of 75 percent in the cost of training personnel employed or preparing for employment by the State or local agency administering the Foster Care program. Under section 1356.60(c) of the regulation, FFP at the rate of 50 percent is available for other administrative expenditures - including administrative expenditures related to training - necessary for the operation of the Foster Care program.

The State has overall responsibility for ensuring that personnel at the State and county level have the training necessary to administer its various social service programs. To carry out its responsibilities, the State provides general oversight of the training program, including the issuance of regulations related to staff development, to county welfh.re departments. It also provides training programs and consultation to county staff development officers located in the 58 counties in California. A substantial portion of the foster care training is obtained by the State and counties under training contracts, primarily with universities and colleges.

SCOPE

We performed our audit in accordance with generally accepted government auditing standards. Our objective was to determine whether the State’s claim for administrative costs related to foster care training was made at the appropriate FFP rate of 50 percent instead of the 75 percent FFP rate allowed for certain training costs specifically defined by Federal regulations. Our review was concerned principally with the categories and types of costs for which claims were made at the enhanced rate, and did not include an audit of the actual costs incurred. Further, for costs which were allocated based on time studies or other allocation methodologies,- our audit included an analysis of the types of costs allocated but did not include an evaluation of those methodologies.

Field work was performed from April 1996 through December 1996 at the State, the Los Angeles County Department of Children and Family Services (LA County), and the University of Californi~ Berkeley (UC Berkeley).

We initially surveyed the costs claimed by the State and determined that the State claimed $71.0 million (Federal share $53.3 million) in foster care training costs at the 75 percent FFP rate for the audit period July 1, 1994 through December 31, 1995.

Our survey disclosed that $65.3 million (92.0 percent of the total costs claimed) consisted of three line items on the statements of expenditures, plus adjustments:

E “Probation IV-E Training” in the amount of $21.5 million (30.3 percent),

� “Foster Care Training” in the amount of $14.9 million (21.0 percent),

F “State and Local Training” in the amount of $22.0 million (31.0 percent), and

F Adjustments totaling $6.9 million (9.7 percent).

We selected the above areas for more detailed review, and limited our audit for the specific county departments, training contracts, and other activities summarized in the following paragraphs.

Probation IV-E Training. We found that training costs were claimed by county welfare departments for costs incurred within those departments as well as county probation departments. These costs were all classified as probation training.

We selected costs claimed under the classification of probation training costs for review because it represented 30.3 percent of total costs claimed. We conducted our preliminary review of these costs at LA County because it had the most significant amount of probation

- training costs reported. We found that the preponderance of these costs consisted of county welfare department costs; only a small portion actually related to probation department training.

Our survey at LA County disclosed that the welfare department costs included a significant amount of adrninistrative costs classified as training costs. The LA County reported its costs in accordance with a State-mandated automated template which was completed by all counties for reporting costs claimed. Because all counties reported these costs in a consistent manner, we expanded our review of probation training for welfare department costs to include the next four counties with the most significant welfhre department costs reported (San Bernardino, Santa ClarZ Sacramento and Orange). These 5 counties represented over 62 percent of the county welfare department costs claimed under the category of probation training.

We did not expand our review of probation department costs beyond LA County because the amounts were relatively insignificant, i.e., they were only 20 percent of total costs classified and claimed as probation training for county probation and welfare departments. In addition, county probation department costs were consolidated with welfare department costs in county

2

claims and the detailed cost information for probation departments was not reported to the State. Although county welfare department cost details were available at the State level, the State did not have such information available for county probation departments.

Foster Care Training. This cost category represented training costs reported by various counties. This included, but was not limited to, costs for contracts between LA County and two universities: California State University, Long Beach (which in turn subcontracted with the University of Southern California), and the University of Californi~ Los Angeles. The LA County contracts with universities were selected for review based on our prior audit’ which indicated that administrative costs were included in training costs claimed.

In addition, our survey at LA County disclosed that the University of CaJiforni~ Los Angeles had $0.6 million in contract costs incurred for the period covered by our audi~ but had not submitted the invoices to LA County after our audit period. We included these costs in our audit because they were significant and related to our audit period.

State and Local Training. The majority of these costs consisted of the State contract with UC Berkeley, which in turn subcontracted with 11 other universities throughout California. The UC Berkeley contract was selected for review based on our prior auditl which indicated that administrative costs were included in training costs claimed.

.

Adjustments. The State reported some costs through prior period adjustments; these were reviewed as part of our overall reconciliation of costs claimed for the period covered by our audit.

I“Audit of Training ContractCosts Claimed for FederalReimbursementby the CaliforniaDepartmentof Social services” issued August 9, 1996under common IdentificatkmNumber A-09-95-OO056.

3

FJNDINGSAND RECOMMENDATIONS

In our audit, we determined that the State (i) had inappropriately claimed administrative costs at the 75 percent FFP rate allowed for training costs, (ii) lacked sufficient documentation to support some of the costs claimed for FFP, and, (iii) in two instances submitted duplicate claims for FFP. The amounts involved are summarized in the following table, and explained in the paragraphs which follow.

2Subp~agraphs (i) and (iii), above.

3Subparagraph(ii), above.

We recommend that the State refired to the Federal Government the costs questioned of $6,611,640 and that the State analyze and adjust as necessary the $3,782,618 (Federal share $2,836,964) of costs set aside.

In a letter dated July 11, 1997, the State responded to the findings and recommendations in our draft audit report. Based on the State’s response, we made a minor revision affecting the amount questioned for the State contract with UC Berkeley. With respect to this final repo~ the State disagreed with the recommended refired of administrative costs inappropriately claimed at the 75 percent FFP rate and the related recommendations for this finding. The State agreed to refund the duplicate costs claimed. The State disagreed with the recommendations related to the matching costs which were set aside pending further review by the State of the support provided by UC Berkeley.

Along with the above referenced letter, the State included five enclosures in support of its position on the draft audit report. Enclosure I represents an index of the State’s response and Enclosure II is a narrative of the response. Enclosures III through V are the supporting documentation provided with the State’s response. We have included the State’s letter and the five enclosures as appendices A through D of this report.

ADMINISTRATIVE COSTS CLAIMED AT 75 PERCENT FFP RATE

In our audit, we identified a total of $8,428,586 that the State inappropriately claimed at the 75 percent FFP allowed for specifically defined training costs, resulting in an overclaim of Federal fimds totaling $2,107,147. In addition, the State’s claims for FFP included $3,782,618 (Federal share $2,836,964) for which the State did not provide adequate supporting documentation needed to determine the allowability of the costs, or the eligibility for the 75 percent FFP rate at which the costs were claimed.

As a result, we are questioning overclaimed Federal funds totaling $2,107,147 and recommending that the State refhnd this amount to the Federal Government. We are setting aside $3,782,618 (Federal share $2,836,964) of costs claimed without sufficient supporting documentation, and recommending that the State either provide support to Administration for Children and Families (ACF) for the costs, or refired any amount which cannot be supported.

CRITERIA

Provisions of Federal Regulations. Section 1356.60(b) of Title 45 of the CFR provides for FFP at the rate of 75 percent of the cost of training personnel employed or preparing for employment. Further, section 235.64 of the CFR defines the following specific costs as reimbursable at the 75 percent rate:

F Salaries, fringe benefits, travel and per diem of full and part time staff assigned to training functions to the extent time is spent performing such tictions.

5

Salaries, fringe benefits, travel and per diem for employees (i) in initial in-service training of at least 1 week and (ii) in agency training sessions away from the employee’s work site or for training related to the job and sponsored by professional organizations.

Salaries, fringe benefits, travel and per diem for experts outside the agency engaged to develop or conduct special programs.

Costs of space, postage, teaching supplies, purchase or development of teaching material and equipment, and costs of the agency’s library.

Salaries, fringe benefits, dependency allowance, travel, tuition, books and educational supplies for training outside of the agency for employees in fi.dl-time, long-term training programs. Certain of these types of costs are also allowable for employees in short-term training programs.

Stipends, travel, tuition, books and educational supplies for persons preparing for employment with the State or local government.

PaDents to educational institutions for salaries, fringe benefits, and travel for. instructors, clerical assistance, teaching materials, and equipment to develop, expand, or improve training for agency personnel.

Any direct or indirect costs claimed at the enhanced rate must meet the requirements listed in this regulation. Other allowable administrative costs may be claimed at the 50 percent FFP rate pursuant to 45 CFR 1356.60(c).

Departmental Appeals Board (DAB)Decisions. The DAB for the Department of Health and Human Services has made several decisions relating to appeals received from States on the appropriateness of costs that may be claimed for FFP at the 75 percent enhanced rate. The following decisions relate to issues included in this report.

E DAB Decision No. 1214, dated December 17, 1990, concluded that the burden was on the State to establish that the activities for which the 75 percent FFP rate was applied constituted training. Since the 75 percent rate is a special, enhanced rate, the DAB stated that it is appropriate to require that a State affirmatively show that activities constitute training in order to quali~ for reimbursement at that rate. In this decision, the State argued that all activities coded as administration and related to training constituted training. However, the DAB ruled against this position, and stated that administrative activities required in order for the training to take place does not make administration part of training.

E DAB Decision No. 1422, dated July 1, 1993, related to indirect costs at educational institutions providing training under the Foster Care program. The decision stated mat if the indirect rates were calculated using any costs not listed in section 235.64, the State could not properly claim indirect costs at the 75 percent FFP rate applicable to

6

training. The DAB determined that the costs charged by the use of the indirect cost rates were properly chargeable at 50 percent FFP pursuant to foster care regulations.

COSTSCLASSIFIEDAS PROBATIONTRAINING

For our audit period, the State claimed, under the classification of probation training,

$21,521,235 (Federal share $16,140,926) as foster care training costs consisting of the claims submitted by the 58 counties. In our audit, we found that the amounts consisted of costs reported for county welfare departments as well as county probation departments.

We reviewed expenditure reports submitted by the five counties which reported the lmgest amounts of training costs, which totaled $11,447,199 (Federal share $8,585,399). In our audit, we identified $4,689,052 in administrative costs claimed by the five counties for administrative costs allocated to foster care training. The administrative costs claimed were for activities that did not meet the deftition of eligible training as speciiied in Federal foster care regulations. As a result the State received excess Federal reimbursement of $1,172,263.

The five counties included in our audit were submitting their claims in accordance with the State computerized system called the State of California Automated Template (SOCAT) which provides instructions to the counties for claiming expenditures for foster care training the enhanced 75 percent FFP rate. The same problems that we found for the five counties could therefore be expected to exist in the remaining counties not included in our audit. Thus, the State needs to perform an analysis of the claims submitted by the remaining counties, and make an adjustment for administrative costs claimed inappropriately at the enhanced rate. Further, the State needs to revise its instructions to counties for claiming foster care training costs to ensure that only eligible costs are claimed at the 75 percent enhanced rate.

at

For the costs claimed by county welfare departments for probation training, our audit included claims submitted by all five counties. However, for the costs related to county probation departments, our audit included only the Los Angeles County Probation Department because of the relative insignificance of the county probation department costs, which were only 20 percent of the county welfare and probation department costs. Further, the information needed for analyzing the costs for the probation departments was not available at the State level.

The following conditions were found for the costs claimed that related to county welfare departments and county probation departments.

County Welfare Departments. The State claimed $10,593,791 (Federal share $7,945,343) in child welfare services (CWS) training costs for the 5 largest counties for the period covered by our review. In our audit, we identified $4,331,364 in county administrative costs that had been allocated to training based on a time study for all personnel whose time is directly charged to the various programs. These administrative costs were allocated to foster care training and claimed at the enhanced 75 percent FFP rate. However, we found that the amounts claimed included costs that did not meet Federal criteria for reimbursement at the 75 percent FFP rate. For example, they included:

7

costs for welfare departments’ support staff,

travel and space costs,

costs allocated under county-wide cost allocation plans, and

electronic data processing maintenance, operations and development costs.

The above procedures for claiming foster care training costs are included in the State’s automated template called SOCAT. The SOCAT instructs the county welfiwe departments to allocate administrative costs to foster care training, which results in costs inappropriately claimed at the enhanced foster care training FFP rate of 75 percent. The overclaim resulting from claiming the $4,331,364 identified in our audit was $1,082,841.

County Probation Department - LA County. The State claimed $853,408 (Federal share $640,056) in probation foster care training costs for the LA County Probation Department for the period covered by our review. In our audit we identified $357,688 in administrative costs that had been allocated to training based on a time study required for all persons whose time is directly charged to the various programs.

The LA County Probation Department claims included staff costs allocated for the Executive Offices and Support Staff, Administrative Services Bureau, Field Services Bureau and Juvenile Institution Bureau. In addition to the staff costs, indirect costs were allocated which included categories designated as Services and Supplies, Employee Benefits, Departmental Overhead, County-wide Overhead, Departmental and Bureau Carry-forward, Transportation Allowance and Building Use Allowance.

The above practices show that the costs claimed as training included administrative and indirect costs which were for administrative functions which did not represent eligible training costs as defined by Federal regulations. As such, these costs should only be claimed at the

.50 percent FFP rate for administrative activities. The overclaim resulting for inappropriately claiming the $357,688 as training costs instead of administrative costs was $89,422.

LA COUNTY CONTRACTSWITH UNIVERSITIES

The LA County contracted with California State University, Long Beach, and the University of Californi~ Los Angeles for providing training to current and future employees. Further, California State University, Long Beach subcontracted with the University of Southern California to provide similar training.

For the. period of our audit, the State claimed $4,663,479 for LA County’s contracts with these universities at the enhanced 75 percent FFP rate. Of this amount, the State inappropriately claimed $1,189,130 of administrative costs and $922,357 of indirect costs. The costs were for activities that did not meet the definition of eligible training as specified in Federal foster care regulations. As a result, the State received excess Federal reimbursement of $527,872 (administrative costs of $297,283 and indirect costs of $230,589).

8

We found that the State did not ident@ or separate the administrative activities or indirect costs from the training activities, but claimed all contract costs as training. Therefore, we evaluated salary and wage costs and indirect costs, and analyzed positions to determine whether they appeared to be administrative in nature by reviewing the written job descriptions, or the job titles if written descriptions were not provided. If positions were all or predominately administrative in nature, we classified them as administration. Otherwise, we considered the positions to be related to training activities. We considered the costs of administrative salaries and wages and indirect costs to be allowable at the 50 percent Federal FFP rate.

The administrative costs claimed for the three universities included in the LA County contracts were similar. For example, the universities reported costs for training center directors and associate directors, fiscal and administrative positions and other positions we determined to be administrative. The University of Californi~ Los Angeles also had an Inter-University Consortium Director, and the University of Southern California had several positions from the School of Social Work Dean’s office. These administrative costs are not allowable at the enhanced foster care training FFP rate as supported by specific examples contained in DAB decisions. As a result, the State received excess Federal reimbursement for administrative costs of $297,283.

The indirect costs represent the costs claimed using the negotiated indirect cost rates applied to modified total direct costs less equipment and stipends. The indirect cost rate includes general and departmental administrative costs not meeting the criteria of eligible types of costs listed in 45 CFR 235.64. As cited in DAB Decision No. 1422, described earlier in this report, such indirect costs are not allowable at the enhanced foster care training FFP rate. The decision stated that such costs were chtigeable at 50 percent FFP pursuant to foster care regulations. As a resul~ the State received excess Federal reimbursement for indirect costs of $230,589.

STATE CONTRACTWITH UC BERKELEY

The contract between the State and UC Berkeley was for a project named the California Social Work Education Center (CALSWEC). The purpose of the contract was to provide graduate education to current and Iiture employees leading to a Master of Social Work degree. The education was provided by UC Berkeley and 11 other universities in the State.

For the period covered by our audit the State claimed $16,938,771 (Federal share $12,704,078) for costs related to its contract with UC Berkeley. All of the costs were claimed at the 75 percent FFP rate. Our review disclosed that $1,628,047 of the amounts claimed were for costs of administration that did not meet the deftition of eligible training as specified in the Federal foster care regulations. As a result, the State received excess Federal reimbursement of $407,012.

We found that the State did not identi~ or separate the administrative activities from the training activities, but claimed all contract costs as training. The contract costs were for operation of the CALSWEC central office, special projects, and direct training activities at

9

UC Berkeley and the 11 other universities. A major portion of the costs incurred by the universities was represented by stipends paid to the students.

Accordingly, in evaluating salary and wage costs reported by UC!Berkeley, we analyzed positions to determine whether they appeared to be administrative in nature by reviewing the written job descriptions, or the job titles if a written description was not provided. If positions were all or predominately administrative in nature, we classified them as administration. Otherwise, we considered the positions to be related to training activities. We considered the costs of administrative salaries and wages to be allowable at the 50 percent Federal FFP rate.

The CALSWEC central office is primarily responsible for the educational oversight and coordination of the project with the participating graduate social work programs in California. We classified the majority of the salaries and wages for the central ofilce as administration. The positions we identified as administration included the Executive Director, Associate and Co-project Directors, administrative anklytimsistants and clerical staff. For example, job descriptions state that the Executive Director is responsible for the administration and management of all CALSWEC program and fiscal operations, and that the Associate Director assists the Executive Director with the overall operation of CALSWEC. The DAB decisions cited earlier in this report show that positions of this type are not considered to be training positions for purposes of claiming costs at the enhanced 75 percent FFP rate.

We considered the costs of associate specialists at the CALSWEC central office to be acceptable at the 75 percent FFP rate because their duties appeared to be related to curriculum development. We also accepted the costs of graduate student assistants at the 75 percent rate. Although their duties related to both administration and curriculum development, we considered their duties to be predominantly related to curriculum development.

Our review of special project costs indicated that most related to curriculum development. Therefore, we classified the project costs as training-related activities even though the duties of some personnel may have involved administrative activities.

Each university program generally had personnel responsible for the overall administration of the program. The personnel included project coordinators or directors who were primarily responsible for the administration of the program, and fiscal and clerical positions whose duties were predominantly administrative. For example, the job description at one university stated that the project coordinator oversaw the administration and implementation of all CALSWEC project activities. Other positions involved duties that included arranging for training, monitoring and evaluating performance of the training, monitoring budgets and expenditures and serving as liaison among other participating schools. The DAB decisions also support the ineligibility of these positions for claiming costs at the 75 percent FFP rate.

COSTSSET ASIDE - STATECONTRACTWITH UCBERKELEY

The State’s claim included $3,782,618 reported by UC Berkeley for the 18-month audit period which represented the required 25 percent match that the State required the universities to provide, which was in turn used by the State in meeting Federal matching requirements.

10

However, documentation provided to us by the State was not always sufficient to determine whether the costs were allowable for FFP under Federal criteria. Also, the documentation was not always sufficient to distinguish whether the costs related to training activities reimbursable at the 75 percent FFP rate, or to administration reimbursable at the 50 percent rate.

We noted that the matching expenditures reported appeared to be sufficient in amount to meet the required 25 percent match. However, our review of the documentation disclosed several potential problems with matching costs reported. These problems included:

Some of the matching salaries appeared to be administrative in nature. For example, some of the participating universities reported matching costs that included salaries for a director, interim director and clerical assistant, and departmental administration salaries and wages for clerical staff and admissions coordinators.

Some universities claimed in-kind matching for county welfare department employees who provided training to Master of Social Work (MSW) students. For example, one university claimed, as an in-kind match, $174,774 which represented one-half of the salaries and related costs of county social workers who trained 12 MS W students for a 30-week period. However, the salaries and related costs for county social workers involved with foster care were generally tided under the federally-assisted Foster Care program at the rate of 50 percent FFP. The remaining 50 percent is financed with State and local fimds which is required to meet Federal matching requirements for the program. Therefore, if these costs in fact represent the county share of the program costs, they would not be allowable to meet the university’s matching requirement. Information was not available at the State level in order to make that determination.

Indirect costs were not always computed properly. For example, one university claimed indirect costs based on budgeted costs instead of actual costs.

One university included stipends in its computation of indirect costs claimed as matching cos~. This is fippropriate unde~ provisions of Office of Management and Budget Circular A-21.

Because of the problems with documentation in support of the matching costs claimed under the contract between the State and UC Berkeley, we could not make a determination as to the allowability of the costs reported or the appropriateness of the 75 percent FFP rate. Accordingly, we are setting the costs aside for future resolution between the ACF and the State. We are recommending that the State provide support for the matching costs claimed under the State contract with UC Berkeley for the period covered by our audit as well as subsequent to December 31, 1995, and make an appropriate adjustment for costs claimed which cannot be supported.

RECOMMENDATIONS

We recommend that the State:

1. Refired $2,107,147 for Federal fimds for administrative costs inappropriately claimed at the 75 percent FFP rate.

2. Revise its instructions to counties for claiming foster care training costs to ensure that only eligible costs are claimed at the 75 percent enhanced rate.

3. Perform an analysis of the claims submitted by the remaining counties not covered by our audit and make an adjustment for administrative costs claimed inappropriately at the enhanced rate.

4. Perform an analysis of the claims submitted by the counties subsequent to our audit period ended December 31, 1995 and make an adjustment for administrative costs claimed inappropriately at the enhanced rate.

5. Provide support to ACF for the matching costs claimed under the State contract with UC Berkeley, and make an appropriate adjustment for any costs claimed which cannot be supported. .

STATE COMMENTSAND OIG RESPONSE

The State disagreed with the five recommendations related to refunding $2,107,147, revising its instructions for claiming foster care training costs, performing additional analyses to adjust for administrative costs claimed at the inappropriate rate, adjusting claims subsequent to our audit period for inappropriately claimed costs at the enhanced FFP rate, and providing support for inadequately supported matching costs. The following paragraphs provide summaries of the State comments and the OIG response to the comments. The full response of the State is included as Appendices A through D.

Intemretation of Federal Foster Care Regulations

State Comments. The State contended that there was no explicit or implied direction in the Federal regulations that costs of administering training were not eligible for FFP at the 75 percent rate.

The State commented that Federal regulations did not distinguish between training costs for which 75 percent FFP was available and training costs which were eligible for 50 percent FFP. Further, the State noted that 45 CFR 235.64, as cited in our repo-~ related to title IV-A of the Social Security Act (Aid to Families with Dependent Children) and not to title IV-E (Foster Care program). The State contended that the foster care regulations which refer to conducting training programs in accordance with the provisions of AFDC regulations were

permissive. The basis for that position is that the foster care regulations state, “...training may (emphasis added) be provided in accordance with the provisions of sections 235.63 through

12

235.66(a) of this title.” The State contended that the regulation was permissive in that it didnot say shall be provided.

OIG Response. Title 45 CFR 1356.60 contains the fiscal requirements for foster caretraining. Paragraph (b) of this section provides for FFP at the rate of 75 percent for State andlocal training for foster care and adoption assistance. Paragraph (b)(3) specifically cross-references the fiscal requirements for the title IV-E Foster Care program to AFDC regulationsat 45 CFR 235.63 through 235.66(a).

Title 45 CFR 235.64 provides States with a description of the activities that are claimable astraining expenditures and was in effect before title IV-E of the Social Security Act wasenacted. Accordingly, that regulation did not list title IV-E as one of the programs to whichit was applicable. Title 45 CFR 1356.60(b)(3) tied the two regulations together to define thefoster care training activities that would be reimbursable at the enhanced rate of 75 percentFFP. The regulations support our position that only specific training costs as defined by 45CFR 235.64 are allowable at the enhanced rate of 75 percent for foster care training and thatadministrative costs are allowable at the 50 percent FFP rate.

In addition, section 1356.60(c) states that FFP is available at the rate of 50 percent foradministrative expenditures necessary for the proper and efficient administration of the FosterCare program.

Atmlicability of title IV-A Regulations

State Comments. The State said that since Congress repealed title IV-A of the SocialSecurity Act on August 22, 1996 and enacted the block grants for Temporary Assistance toNeedy Families (TANF), title IV-A and the related Federal regulations are obsolete and nolonger apply to the foster care training program.

OIG Response. Region IX ACF officials have advised us that although title IV-A wasrepealed in 1996 and replaced by TANF, the regulations still apply to other programs towhich they are applicable, including foster care training. Accordingly, our recommendationsfor revising instructions to counties for claiming foster care training costs, and for performinganalyses of claims subsequent to our audit period, are appropriate.

Definition of Administration

State Comments. The State agreed that the OIG correctly distinguished between expensesdirectly related to instruction and those which were administrative in nature. However, theState disagreed with the deffition of administration as reflected in the regulations. The Statecommented that the foster care training program - one which prepared employees orprospective employees of State and local agencies for work in foster care and adoptions - isunique and different from other educational programs. The State maintained that the use ofthe word administration in Federal regulations refers to an individual worker’s management ofa case and not to administration as conducted at educational institutions. The State arguedthat the tasks of planning, developing, managing, directing, and leading which fall under the

13

definition of administration at the educational institution level should be allowable as training costs.

OIG Response. The definition of administration as included in the regulations includes management of a case, but also includes other administrative activities as well. The regulations, at section 1356.60(c), provide for 50 percent FFP in the administrative expenditures for the proper and efficient administration of the title IV-E State plan, and do not limit those allowable expenditures to case management costs. We agree that the administrative costs in question relate to training activities. However, according to DAB Decision No. 1214 which we cited in our repofi the fact that the administrative costs were required in order for the training to take place does not make administration part of training.

OIG’S Use of DAB Decisions

State Comments. The State objected to our use of DAB decisions and indicated that they were used as a substitute for clear regulations and policy interpretations.

OIG Response. The DAB decisions were not used as a substitute for Federal regulations and policy interpretations, but rather to show that the DAB for the Department of Health and Human Services has sustained findings on foster care administrative costs similar to those included in this report.

SuP~ort for Matching Costs

State Comments. The State commented that it provided extensive data supporting the matching costs for which we were unable to express an opinion as to their allowability. The State also commented that most of the matching costs was represented by indirect costs incurred but not reimbursed and was based on rates negotiated with the Federal Government. The State questioned whether the OIG was disputing the use of the negotiated indirect cost rates by the universities to determine indirect costs under the CALSWEC contract.

OIG Response. The data provided by the State were not sufficient to determine whether the costs were allowable under Federal regulations or, if allowable, were administrative costs reimbursable at 50 percent FFP or training costs reimbursable at 75 percent. We are not questioning the allowability of these costs but are setting them aside for the State to obtain additional information and perform additional analyses to support the allowability of these costs. Further, we are not disputing the use of negotiated indirect cost rates as a basis for charging costs. However, we found problems with how the rates were applied, such as applying the rates to stipends which is not allowable under the rate agreements with the universities.

14


The State made administrative errors in preparing quarterly statements of expenditures which resulted in two duplicate claims totaling $6,749,420 (Federal share $4,504,493). The State made an error resulting in an overclaim of $2,190,023 Federal share of expenditures related to the Statewide Automated Child Welfare Information System (SACWIS). Also, the State overclaimed training costs on the March 1995 quarterly statement of expenditures by $2,314,470 when it made an adjustment to an underclaim of expenditures for the September 1993 quarter.

SACWIS OVERCLAIM

For the quarter ended December 31, 1995, the State claimed $2,920,030 (Federal share $2,190,023) for SACWIS costs as IV-E training costs while at the same time including the $2,920,030 on an addendurn to the December 1995 quarterly statement of expenditures. As a result, SACWIS costs were claimed twice on the quarterly report for December 1995.

State officials indicated that there had been some misunderstanding on how the $2,920,030 of SACWIS costs were to be reported to ACF. The costs had initially been claimed as administrative costs at the 50 percent FFP rate. It was subsequently determined that the costs were allowable at an enhanced FFP rate of 75 percent. In order to obtain the 75 percent FFP rate, the State revised its quarterly report of expenditures by reducing the administrative costs by the $2,920,030 and increasing foster care training costs (which are allowable at 75 percent FFP) by the same amount.

ACF subsequently provided instructions to the State to report the SACWIS costs as an addendum to the quarterly statement of expenditures. To comply with the suggested reporting format, the State submitted an addendum to a revised quarterly statement of expenditures which claimed the SACWIS costs at the correct 75 percent FFP rate. However, the State inadvertently did not reduce the training costs by the SACWIS costs. As a result of this

. action, the State claimed the SACWIS costs twice on the December 1995 quarterly statement of expenditures.

DUPLICATEADJUSTMENT

The State overclaimed training and administrative costs on the March 1995 quarterly statement of expenditures by $2,314,470 when it made an adjustment to an underclaim of expenditures for the September 1993 quarter. However, our review disclosed the underclaim

15

hadalready been corrected onthe September 1994 quarterly claim. The duplicate adjustment resulted in overclaimed training and administrative costs as shown in the following schedule.

We recommend that the State refhnd the duplicate costs clairne~ totaling $4,504,493 ($2,190,023 + $2,314,470).

STATE COMMENTS

The State concurred with our recommendation to refund the $4,504,493 for duplicate costs claimed related to the SACWIS overclaim of $2,190,023 and the duplicate adjustment overclaim of $2,314,470. In addition, the State said that it is currently implementing new financial reconciliation procedures to prevent this type of error in the fiture.

16

APPENDICES

f/

APPENDIX Ar .

STATEOFCAUFORNIA--HEALTH AGENCY f’ETE WILSON, GovenorANDWELFARE

DEPARTMENT OF SOCIAL SERVICES . 744 P STREET. SACRAMENTO, CA 95814

Lawrence Frelot Regional Inspector General

For Audk Services Department of Health and

Human Services, Region IX 50 United Nations Plaza San Francisco, CA 94102

Dear Mr. Frelot:

July 11, 1997

SUBJECT DRAFI’ REPORT: DHHS-OIG “AUDIT OF FOSTER CARE TRAINING

ADMINISTRATIVE COSTS CLAIMED FOR FEDERAL REIMBURSEMENT BY THE CALIFORNIA DEPARTMENT OF SOCIAL SERVICES/ A-09-96-OO066”

This is in response to your April 11, 1997 request for the California Department of Social Services (CDSS) comments regarding the findings and recommendations contained in the above named draft audit report. Thank you for granting the CDSS additional time (until July 11, 1997) to submit our comments. In the preparation of our response, we followed the same order that the findings, are listed in the report “Table of Contents” (see Crosswalk in Enclosure I). CDSS

-comments are contained in Enclosure K Supporting documentation is contained Enclosures ID, IV, and V.

If you have any questions regarding our response, please call me at (916) 657-3266 or have your staff contact

Enclosures

c: P.Shultz “

N. Dickinson

G. Guilden

Glen H. Brooks, Jr., Fiscal Policy Bureau, at (916) 657-3440.

Sincerely,

(?e’~RVIO A. GREVIOUS

Deputy Director Administration Division

APPENDIX B, Page 1 of 3

Enclosure I

CROSSWALK FROM CDSS COMMENTS TO REPORT CONTENTS

A-09 -96- OO066 DRAFT REPORT

ENCLOSURE II REPORT CONTENTSPAGE

ADMINISTRATIVE COSTS CLAIMED AT 75 PERCENT FFP RATE

1 I. COSTS CLASSIFIED AS PROBATION TRAINING 1 COUNTY WELFAREDEPRTkl=lTS 1 COUNTYPROBATIONDEPARTMENT- LA COUNTY

1 Recommendation

l&2 CDSS comments: 3 Recommendation

3 CDSS Comments: 3 Recommends tion

3 CDSS Canzments:

IA: Repay $1,172,263 for CWD &Probation “administrative”costs disclaimed to TitleIV-E Training/75% FFP.

IB: Revise CWD administrativeclaiming instructions so“administrative” costs notclaimed to Title IV-E/75% FFP.

IC: Analyze Title IV-E TrainingClaims for 53 non-auditedcounties since 7/1/94; andadjust for disclaimed“administrative” costs.

11. LA COUNTY CONTRACTS WITH UNIVERSITIES

REPORT

PAGE

5

6

7

8

12

12

12

8

12

12

4 Recommendation 11A:

4 CDSS Comments 4 Recommendation IIB:

Repay $527,872 for“administrative” and“indirect” costs claimed inLA County contracts withuniversities to Title IV-ETraining/75% FFP, instead ofto Title IV-E M.mini.strati.on/50% FFP.

Revise CWD administrativeclaiming instructions so“administrative” and “indirect”costs within training contractsare identified to Title IV-E“Administration’’/5O% FFP, not

to Title IV-E Training/75% FFP.4 CDSS comments:


. . CROSSWALKPAGE 2

ENCLOSURE II REPORT CONTENTS

PAGE

4 Recommendation IIC: Analyze Title IV-E Trainingclaims for 53 non-auditedcounties since 7/1/94 toidentify direct chargedtraining contracts andwithin these contractsadjust for contractor’s“Administrative” and“indirect” costs claimed toTitle IV-E Training/75% FFP

5 CDSS Comments:

111. STATE CONTRACT WITH UC BERKEIJEY (CAI&EC)

REPORTPAGE

12

9

12

12

5

5-999

1010

10

Recommendation 111A:

CALSWEC Comments:CDSS Comments:Recommendation IIIB:

CDSS Comments: Recommends tion IIIC:

CDSS Comments:

Repay $407,461 for“administrative” and“indirect” costs claimedin LA County contractswith universities to TitleIV-E Training/75% FFP insteadof to Title IV-EAdministration/50% FFP.

Revise CDSS’ State supportclaiming instructions to ensure“administrative” and “indirect”costs within training contractsare identified to Title IV-E“Administration”/SO% FFP, notto Title IV-E Training/75% FFP.

Analyze CDSS’ State sUppOrt 12Claims for Title IV-ETraining/75% FFP since7/1/94 to identify directcharged training contractsand within these contractsadjust for contractor’s“administrative” and“indirect” costs claimed toTitle IV-E Training/75% FFP


. . .

CROSSWALK

Page Three

ENCLOSURE II REPORT CONTENTS

PAGE

IV.

11

1213

v.

13

13

14

14

COSTS SET ASIDE-STATE CONTRACT WITH UC BERKELEY

Recommendation IV: Document all costs constitutingThe 25% CALSWEC match annuallysince July 1, 1994 into threeapplicable categories, namely:“ineligible costs”, ‘eligiblefor match at 50%/Title IV-Eadministration rate, and“eligible for match at 75%/Title IV-E Training rate”. Identify and repay any resultant undermatch.

CALSWEC Comments:cxxs comments:


SACWIS OVERC=MRecommendation VI: Repay $2,190,023 in duplicate

SACWIS costs claimed.c!DSS comments:

DUPLICATE ADJUS=N’rRecommendation V2: Repay $2,314,470 for adjusting

September 1993 quarter under-claim twice (in September 1994and in March 1995) .

CDSS comments:

REPORTPAGE

10

12

12

13

13

APPENDIX C, Page 1 of 14

Enclos-ure II

CALIFORNIA DEPARTMENT OF SOCIAL SERVICES (CDSS) COMMENTS

Following is the CDSS response to audit findings and recommendationscontained in the HHS Office of Inspector General (OIG) draft reportentitled “AUDIT OF FOSTER CARE TRAINING ADMINISTRATIVE COSTS CLAIMEDFOR FEDERAL REIMBURSEMENT BY THE CALIFORNIA DEPARTMENT OF SOCIAL

SERVICES/ A-09-96-OO066”.

PART I ADMINISTRATIVE COSTS CLASSIFIED AS COUNTY WELFAREDEPARTMENT (C’1’m)& PROBATION TWKtNING CLAIMED ATENHANCED TRAINING WiTE

(Draft Report, C1’lDChild Welfare Services (cws) Training CostsPage 7)

Finding: During the 18 month audit period, five (5)audited counties claimed $10,593,791 in training costs”to “Title IV-E, Training/75% FFP”. Of this total,$4,331,364 consisted of CWD administrative costsallocated to “Title IV-E Training/75% FFP” based ontime study ratios derived from personnel whose timewas directly charged to the Title IV-E FC Program.These claims were ineligible for “Title IV-ETraining/75% FFP” because they did not meet Federalcriteria for training costs. The resulting overclaimfor the 5 audited counties during the audit period was$1,08”2,841.

(Draft Report, Los Angeles County Probation Department (LACPD)Page 8)

Finding: During the audit period, the LACPD claimed$853,408 in probation related foster care trainingcosts . Of this total, $357,688 consisted of LACPDadministrative costs allocated to “Title IV-ETraining/75% FFP”. Claiming these administrative andindirect costs inappropriately to “Title IV-ETraining/75% FFP” on LADCS’ administrative expenseclaims for the 18 month audit period resulted in an LACounty overclaim of $89,422.

(Draft Report, Recommendation IA:Page 12)

California should repay $1,172,263 disclaimed toTitle IV-E Training/75% FFP. This was the amountoverclaimed during the audit period by 5 audited countywelfare departments and by the LACPD.

CDSS Comments: The CDSS does not concur with thisfinding. Federal regulations governing training, Code

of Federal Regulations (CFR) part 1355 et. seq. do not distinguish between training costs for which 75% Federal match is available and training costs which are eligible for 50% Federal match. The regulation

., . . r

f,

Page TwoCDSS CommentsA-09-96-OO066


. .

specifies that “Federal financial participation isavailable at the rate of seventy-five (75%) in thecosts of training personnel employed or preparing foremployment by the State or local agency administeringthe plan.” The regulation further specifies that “Alltraining activities and costs funded under Title IV-Eshall be included in the State agency’s training planfor Title IV-B.” There is no explicit or implicitdirection that any cost of developing, implementing or“administering” training is not eligible for Federalfinancial participation (FFP) at the 75% rate. Theregulation also discusses “Federal matching funds forother (emphasis added) State and local administrativeexpenditures for foster care. ...“ This confirms thattraining is recognized in the regulation as anadministrative expenditure necessary for theadministration of the program and that it is to betreated differently as specified in 45 CFR Part1356(b). Again there is no “direction or implicationthat certain types of training activities or costs areeligible for 75% but other types of training activitiesor costs are eligible for 50%. Regulation 45 CFR1356.60(b) governs FFP for training; 45 CFR 1356.6 (c)governs FFP for “other administrative costs.”

The draft audit report cites 45 CFR section 235.64 asthe section which “defines the following specific costsas reimbursable at the 75 percent rate. ...“ Theregulation cited is a Title IV-A regulation whichspecifies internally the other titles to which itapplies. It begins, “Under Title I, X, XIV, or XVI...of the Act, FFP is available at the rate of 75 percentand under title IV-A. ...“ The regulation does notdirect itself to Title IV-E. The regulations governingTitle IV-E specify that “Short and long term trainingat educational institutions and in-service training may(emphasis added) be provided in accordance with theprovisions of section 235.63 through 235.66(a) of thistitle.” The regulation as stated is permissive; itdoes not say shall be provided.

The draft audit report’s case is not supported inFederal regulation. There is nothing in Federalregulation that requires differential claiming oftraining costs.

LADCFS Comments: The LADCFS does not concur with thisrecommendation. Instead, LADCFS concurs with the

. . . . 1

fr APPENDIX C, Page 3 Of 14

. . Page ThreeCDSS Com”entsA-09-96-00066

(Draft Report,Page 12)


PART II.

(Draft.Report,Page 8)

State’s interpretation that Federal regulation languagesupports claims of all integral staff includingtraining administrators at the 75% rate.

Recommendation IB:

California should revise its instructions to countiesfor claiming foster care training costs to ensure thatonly eligible costs are claimed at the 75% enhancedrate.

CDSS Comments: The CDSS does not concur with thisrecommendation. Since current Federal regulations donot explicitly or implicitly provide that the cost ofdeveloping, implementing or administering training isineligible for FFP at the 75% rate, it is not necessarYto revise existing CDSS instruct-ions to the counties.See CDSS response to “Recommendation IA”.

Recormnendation IC:

California should analyze claims submitted by the non-audited 53 counties, determine the amount of ~tadministrative” costs disclaimed to Title IV-E Training/75% FFP and complete adjustments for the resultant amount overclaimed at the 75% enhanced rate.

CDSS Comments: The CDSS does not concur with thisrecommendation. Since current Federal regulations donot explicitly or implicitly provide that the cost ofdeveloping, implementing or administering training isineligible for FFP at the 75% rate, it is not necessarYto analyze, identify and ad-just any alleged overpayments in the unaudited 53 counties. See CDSSresponse to “Recommendation IA”.

LA COUNTY CONTRACTS WITH UNIVERSITIES

Finding: During the audit period, LADCS claimed$4,663,479 in CSULB Inter-University Consortium (IUC)training services contract costs to Title IV-ETraining/75% FFP. Of this amount, LADCSinappropriately claimed $1,189,130 administrative costsand $922,357 indirect costs because these type costsare not eligible training costs specified in Federalfoster care regulations. The overclaim resulting frominappropriately including administrative costs in the

-. . . r

Page FourCDSS CommentsA-09-96-OO066





. .

IUC contract costs claimed to Title IV-E Training/75%FFP during the audit period was $297,283. Theoverclaim resulting from inappropriately includingindirect costs in the IUC contract costs claimed toTitle IV-E Training/75% FFP during the audit period was$230,589.

Recommendation 11A:

California should repay $527,872 for administrative($297,283)’and indirect (230,589) costs included in theLA County University Training contract costsinappropriately claimed to Title IV-E Training/75% FFP.

CDSS Comments: The CDSS does not concur with thisrecommendation for the same reasons contained in theDepartment’s responses to “Recommendations IA and IB”.Although the County agrees that individuals in questionin the Los Angeles Consortium were not providing directclassroom training, these staff were integral to thedirect training “operation, so their costs were claimedcorrectly at the 75% FFP rate.

Recommendation IIB:

California should revise its instructions to counties for claiming contracted foster care training costs to ensure that contractor’s costs which are all or predominantly “administrative” in nature are claimed as ~administrative~ costs (50% FFP) and “only eligible training costs” in the contract are claimed to enhancedFoster Care program training funds (75% FFP).

CDSS Connnents: The CDSS does not concur with thisrecommendation. Since current Federal regulations donot explicitly or implicitly provide that the cost ofdeveloping, implementing or administering training isineligible for FFP at the 75% rate, it is not necessaryto re~ise existing CDSS instructions to the counties.See CDSS response to “Recommendation IA”.

Recommendation IIC:

California should analyze quarterly countyadministrative expense claims, and identify counties

-. . . /

t,

Page FiveCDSS CominentsA-09-96-00066

PART III .




. .

which claimed third party contract costs to Title IV-ETraining/75% FFP. Then for each contract claimed toTitle IV-E Training/75% FFP during this period,determine which contract costs were “all orpredominately administrative in nature” and processnecessary adjustments to applicable county claims toensure that the contractor’s administrative costs werecorrectly claimed to 50% FFP and only eligible trainingcosts of the contractor were claimed at the enhancedTitle IV-E training rate.

CDSS Comments: The CDSS does not concur with thisrecommendation. Since current Federal regulations donot explicitly or implicitly provide that the cost ofdeveloping, implementing or administering training isineligible for FFP at the 75% rate, it is not necessaryto analyze, identify and adjust-any alledgedoverpayments in the unaudited 53 counties. See CDSSresponse to “Recommendation IA”.

STATE CONTRACT WITH UC BERKELEY

Finding: During the audit period, CDSS contractedwith the UC Berkeley, California Social Work EducationCenter (CALSWEC) project to provide graduate educationfor current and future employees leading a Master ofSocial Work degree.

During the audit period, CALSWECclaimed $16,938,771 (Federal share $12,704,078) for Title IV-E Traini,ng/75% FFP . Of this amount, CALSWECclaimed $1,629,845, allegedly for administrative costs that did not meet the definition of eligible training costs as specified , i.n Federal foster care regulations. The overclaim resulting from including these administrative costs the university contracts disclaimed to Title IV-E Trainhg/75% FFP was $407,461.

Recommendation 111A:

California should repay $407,461 in administrative costs inappropriately claimed at the 75% enhanced

CALSWEC Comments: The CALSWEC does not concur withrecommendation because there is no regulatoryrequirement for reimbursing the costs of the

in

rate.

this

I


Page SixCDSS CommentsA-09 -96-OO066

administration of training by an educationalinstitution at the 50 percent rate. The CALSWECfurther distinguishes between the use of the word“administration” as defined in the regulations and asapplied to the job of developing, expanding, orimproving training through an educational institutionwhich is allowed in the regulations at a 75 percent

claims that “Under Section 1356.60(c) of theregulation, FFP at the rate of 50 percent is availablefor other administrative expenditures - including administrative expenditures related to training(emphasis added) - necessary for the operation of thefoster care program.” There is no language in1356.60(c) which refers to “administrative expendituresrelated to training.” The language specifically statesthat ‘~Federal financial participation is available atthe rate of fifty percent (50%) for administrativeexpenditures necessary for the proper and efficientadministration of the Title IV-E State Plan. The

State’s cost allocation plan shall identify which costsare allocated and claimed under this program.”

The regulation continues and identifies “examples ofallowable administrative costs” in 1356.7(c) (l-5) .None of these examples names “administrativeexpenditures related to training.” The only trainingexample refers to travel and per diem for short-termtraining for foster and adoptive parents and staff oflicensed or approved child care institutions providingfoster care. The other examples refer to the duties of

agency staff for performing such activities asdetermination and redetermination of eligibility, fairhearings and appeals and rate settings, referral toservices, preparation for and participation in judicialdeterminations, placement of the child, development ofthe case plan, case reviews, case management andsupervision, recruitment and licensing of foster homesand institutions and rate setting.

section 1456.60(b) (1) is very clear that “Federalfinancial participation is available at the rate ofseventy-five percent (75%) in the costs of training

tofficeOfAudit Services note- The shaded area represents comments applicabletothe draftreportthat areno longer relevantdueto chanaesmade inthefinalreport.1


. . Page SevenCDSS CommentsA-09-96-00066

(emphasis added) personnel employed or preparing for“ employment by the State or local agency administering

the plan.” The real “costs of training” in auniversity are all of the costs of activitiesassociated with developing and implementing aneducational program, including instruction andadministration. There is no provision in Part 1356.60that defines the term training expenditure or thatdistinguishes a direct training expenditure from anindirect training expenditure.

Section 1356.60(b) (3) adds that “short and long termtraining at educational institutions and in-servicetraining may (emphasis added) be provided in accordance with the provisions of 235.63 through 235.66(a) of “this title. “ The use of the word “may” implies choice, not requirement.

.

The regulations referenced above are Title IV-A regulations, not Title IV-E. On August 22, 1996, Congress repealed Title IV-A and enacted block grants for Temporary Assistance to Needy Families (TZ+NF). upon approval of a new state plan, Title iv-A and its regulations no longer apply. To the extent that 45 CFR 235.65 could have ever been a basis for supporting ACF’S policy interpretation, the above-referencedFederal legislation renders the cited regulation, andACF’S accompanying interpretation, obsolete. Congressmade no provisions for old Title IV-A regulations tosurvive and be applicable to the Title IV-E trainingprogram.

Disputed definition of ‘administration”. Even thoughit applies to Title IV-A, Section 235.63(c) (1-5)describes the conditions under which grants are made toeducational institutions at 75% FFP: (1) “Grants aremade for the purpose of developing, expanding, or improving training for personnel employed by the Stateor local agency or preparing for employment. ..Grantsare made for an education program (curriculumdevelopment, classroom instruction, field instruction,or any combination of these) that is directly relatedto the agency’s program. ..“

Educational institutions which develop, expand orimprove training are doing more than merely educatingin their traditional ways. The educational program

APPENDIX C, Page 8 of ’14

Page EightCDSS CommentsA-09 -96- OO066

(“curriculum development, classroom instruction, fieldinstruction, or any combination of these”) requiresdevelopment, adaptation, and oversight to make itapplicable for “personnel employed by the State orlocal agency or preparing for employment.” These aretasks of planning, developing, managing, directing, andleading which fall under the category of“administration” in the usual use of the word and notin the definition of the work in these regulations. As demonstrated above, ‘administrative” Easks in these regulations refer to the agency staff tasks of implementing eligibility determination, case planning, referral to services, case reviews, case management and supervision, and so on. This use of the word “administration” in the regulations refers to anindividual worker’s management of a case. In aneducational institution, the administrative functionsensure the educational program’s integrity, usefulnessand responsiveness.

The OIG refers to Section 235.64 of the CFR and liststhe specific costs reimbursable at the 75 percent rate.part (d) specifically names “salaries, fringe benefits,and travel of instructors, clerical assistance,teaching materials and equipment”. for payments toeducational institutions. While “administrative costs”are not specifically mentioned in that section, theyare also not specifically mentioned as being precludedin the following section 235.65, “Activities and costsnot matchable as training expenditures.”

The CALSWEC does not dispute the OIG’S claims thatcertain expenses in the contract between CDSS and UCBerkeley relate to the administration of theeducational program. For the most part, they havecorrectly distinguished between those expenses relatedto direct instruction and those which areadministrative in nature. The Center disagrees withthe definition of “administration” as reflected in theregulations and in the nature of educationalinstitutions. This particular type of educationalprogram --one which prepares employees or prospectiveemployees of State and local a’gencies for work infoster care and adoptions-- is unique and different fromother educational programs typically conducted byinstitutions of higher learning. Without enhancedfunding for all expenses related to Title IV-Etraining, universities will not be able to participatefully in the development and implementationof these educational programs. Consequently, the

/

APPENDIX C, Page 9 of 14 Page NineCDSS CommentsA-09-96-00066

quality and quantity of child welfare training andeducation will decrease, with an accompanying reductionin child welfare workers’ skills, and an increase inthe number of children put at risk.

Departmental Appeals Board (DAB) decisions. The use ofDAB decisions to substitute for clear regulations andpolicy interpretations by DHHS is confusing andunacceptable. Many of these decisions are still beingpursued through the courts and”are at variance withinterpretations in other HHS regions. Moreover, no DABdecisions have been sent by DHHS to all regions asexamples of Title IV-E training regulations which thedepartment supports.

CDSS Comments: The CDSS does not concur with thisrecommendation for reasons cited in the Department’sresponse to Recommendation IA and the Departmentconcurs with more detailed arguments presented above bythe CALSWEC.

(Draft Report, Recommendation IIIB:

Page 12)California should revise its internal instructions for

claiming CDSS direct service contracts for foster caretraining to ensure that contractor’s costs which areall or predominantly “administrative” in nature areclaimed as i\a~inistrative ~~costs (soy. FFp) and “only

IofficeofAudit Services note- Theshaded area rePr@S@n@cOmm@ntS applicabletothe draftreportthat are nolon9errelevant dueto changes made in thefinalreport.]

., -. t

r,

Page TenCDSS CommentsA-09-96-00066

Draft Report,Page 12)

PART IV.

(Draft Report, Pgs 10 & 11)


eligible training costs” 3.n the contract are claixned to enhanced Foster Care program training funds (75% FFP) .

CDSS Comments: The CDSS does not concur with this recommendation. Since current Federal regulations do not explicitly or implicitly provide that the cost ofdeveloping, implementing or administering training isineligible for (FFP) at the 75% rate, it is notnecessary to revise existing CDSS instructions to thecounties. See CDSS response to “Recommendation IA”.

Recommendation IIIC:

California should review its’ State support claims submitted to identify instances where CDSS claimed contract costs to Title IV-E Training/75% FFP. Then, for individual contracts claimed in this sub-universe, determine which contract costs were “all or

predominately administrative in naturef’ and process necessary adjustments to CDSS’ claims to ensure that the contractor’s administrative costs were claimed ~o 50% FFP and only eligible training costs of the contractor were claimed at the enhanced Title IV-E training rate.

CDSS Comments: The CDSS does not concur with thisrecommendation. Since current Federal regulations donot explicitly or implicitly provide that the cost ofdeveloping, implementing or administering training isineligible for FFP at the 75% rate, it is not necessavto analyzer identify, and adjust any allegedoverpayments in the unaudited counties. See CDSSresponse to “Recommendation IA”.

COSTS SET ASIDE - STATE CONTRACT WITH UC BERXEIIEY

Finding: During the audit period, CDSS claimed$3,782,618 in CALSWEC project costs, which represented25% of CALSWEC contract costs incurred by theparticipating universities to meet the Federal matchingrequirements. The terms of the contract required theuniversities to provide a 25 percent match which wasused by the State to meet Federal matchingrequirements. However, documentation of these costsprovided by the State was insufficient to (1) determinewhether the costs were allowable for FFP under Federal“administrative costs” criteria or under Federal


. . Page ElevenCDSS CommentsA-09 -96- OO066

“eligible training costs” criteria; and if allowableunder either criteria; (2) to distinguish whether suchcosts could be identified as “eligible trainingactivities” reimbursable at the 75% FFP rate or “whetherthey could be identified as “administrative activities”reimbursable at the 50% FFP rate.

Several potential matching problems were reported.Some of the matching salaries appeared to beadministrative in nature (i.e., the match contributedby some universities included salaries for a director,interim director and clerical assistant, anddepartmental administration salaries and wages forclerical staff and admissions coordinators) . Someuniversities claimed in-kind matching for 50% of thepersonnel service costs of CWDemployees who providedtraining to Master of Social Work students. These sameemployees generally identified their personnel servicecosts to Title IV-E Foster Care at 50% FFP. Thenonfederal share was supposed to be met from state. andlocal funds required as the match for Federal Title IVE funds. Therefore, costs which represented the countyshare of Title IV-E costs would not be allowable tomeet the university’s matching requirement. Oneuniversity claimed indirect costs based on budgetedcosts instead of actual costs. One university includedstipends in its computation of indirect costs claimedas matching costs which is inappropriate under OMBCircular A-21.

Because the State was unable to provide documentationto support the allowability of these matching costs,the OIG was unable to make a determination regardingwhether the costs reported by the universities as matchwas allowable and appropriate for the 75% FFP rate.Accordingly, the total amount of match claimed for thisperiod has been set aside for future resolution betweenHHS-ACF and the State.

(Draft. Report, Recommendation IV:.Page 12)

CDSS should provide support for all matching costsclaimed under the State-UC Berkeley CALSWEC projectcontract and submit Federal claims adjustments tocorrect for any Costs claimed which did not meet the

Federal criterion for eligible ‘~administration” or

APPENDIX C, Page 12 of ’14

. . Page TwelveCDSS CommentsA-09 -96- OO066

~~training costs~~; and correct for anY eligible

~~a~nistration costs” which were inappropriately

claimed as match at the 75% enhanced rate.

Comments: CALSWEC : The CALSWEC does not concur with thisrecommendation. The OIG set aside costs reported by UCBerkeley to support the 25 percent match required byFederal regulations, because they “could not make adetermination as to the allowability of the costsreported or the appropriateness of the 75 percent FFPrate. “ The eleven universities participating in theCDSS-UC Berkeley contract at the time of the audit usedindirect foregone and some in-kind match to meet the 25percent match requirement. The CALSWEC providedextensive data showing the sources of our match. TheCALSWEC believes that the Center fulfilled therequirements of the regulations for providing a 25percent match and that the auditbrs did not give areasonable basis for questioning the allowability ofthese costs.

Most of the match comes from the decisions byuniversities not to charge indirect costs associatedwith the direct training costs of this contract. Ifthe OIG is disputing the use of Federal Rate Agreementsto determine legitimate indirect costs of thiscontract, then it seems that one Federal agency isdisputing what another Federal agency has approved.The Federal Rate Agreements of each university arenegotiated between that university and the Division ofCost Allocation of the Department of Health and HumanServices. Each agreement contains the followinginformation about its “use by other Federal agencies:The rates in the Agreement were approved in accordancewith the authority in Office of Management and Budget(OMB) Circular A-87, and should be applied to grants,contracts and other agreements covered by OMB CircularA-21, subject to any limitations in A above.”

There is no provision in Title IV-E or Title IV-Eregulations that expressly excludes the use of indirectcosts from being considered allowable training costs.As these indirect costs are dete~ined by the FederalGovernment to be legitimate costs of a university,included fully in the cost of providing a Title IV-Eeducational program, they should be acceptable to DHHSas fully claimable for match at the 75 percent rate.


. . Page ThirteenCDSS CommentsA-09 -96- OO066

The attempt by the OIG to use thetraining/administration distinction is not any morevalid here than in the earlier sections of their draftreport.

CDSS Comments: The CDSS agrees with the arguments

presented above by the CALSWEC.

PART V DUPLICATE COSTS CLAIMED

(Draft Report, Finding: Statewide Automated Child Welfare Information Pgs 12 & 13) system (SACWIs) mf=rcla~

For the quarter ended December 31, 1995, CDSS initiallyclaimed SACWIS costs totaling $2,920,030 (Federal share$2,190,023) at the 50% admkistr.ative rate. Subsequently, CDSS learned these same costs were claimable to 75% FFP. In order to reclaim at the enhanced rate, CDSS revised its December 31, 1995 claimby reducing its “administrative” costs by $2,920/030 andincreasing its FC Training costs claimed at 75% FFP.ACF subsequently instructed the State to report SACWIScosts as an addendum to its ~arterly statement ofexpenditures . CDSS then submitted an addendum to arevised quarterly statement of expenditures whichclaimed SACWIS costs at 75% FFP, but not reduce totaltraining costs by the SACWIS costs already claimed. As aresult, California claimed the SACWIS costs twice in theDecember 199S statement of expenditures.

(Draft Report, Recommendation VI: California should refund duplicatePage 13) SACWIS costs claimed of $2,190,023.

CDSS Comments: The CDSS concurs with the finding. The

Department corrected this overclaim of $2,190,023 by arevision to Form IV-E-12, dated May 22, 1996 (seepertinent part of the May 1996 claim contained inEnclosure IV) . The CDSS is currently implementing newFederal financial reconciliations to correct this typeof problem.

(Draft Report, Finding: Duplicate Adjustment

Page 13)CDSS overclaimed training and administrative costs onthe March 1995 quarterly statement of expenditures by$2,314,470 when it made an adjustment to an underclaim


. .

Page FourteenCDSS CommentsA-09-96-00066

for the September 1993 quarter. However, this sameunderclaim had already been corrected on the September1994 quarterly claim, resulting in a duplicateadjustment of $2,314,470.

(Draft Report, Recommendation V2: CDSS should repay $2,314,470 in Page 13) duplicate costs.

CDSS Comments: The CDSS concurs with this finding. TheDepartment corrected this duplicate adjustment of$2,314,470 by a revision to Form IV-E-12, datedDecember 24, 1996 (see pertinent part of the December1996 claim contained in Enclosure V). The CDSS iscurrently implementing new Federal financialreconciliations to correct this type of problem.

JD/WP/c:OO066b

EllC

l_OS

UREill

CA

LIF

OF

7N!A

0S

S

-R

EV

IEW

O

F

AD

M

CO

ST

S

RE

LA

TE

D

TO

T

ITL

E

IV-E

T

RA

ININ

G

AC

TIV

ITIE

S

CIN

A

.0S

+8-W

W6

kLY

SIS

O

F

CO

ST

S

CIA

IME

D

(FU

LL

-TIM

E

& P

AR

T-T

IME

P

RO

GR

AM

S)

FO

R

C$t

J..S

AN

F

RA

NC

ISC

O

and

DE

TE

RM

IW4T

ION

O

F

AM

OU

hT

R

EL

AT

EO

T

O

AD

MIN

IST

MT

ION

&

TH

E

RE

SU

LT

ING

E

XC

ES

S

FE

DE

RA

L

CO

ST

S

CM

IME

D

FIL

E

= C

S-S

F-O

.WE

2

WI’Q

Ref

T

ota

l O

ired

M

min

ktra

tFF

e C

od

s N

on

-Fed

eral

(M

atch

ing

)

No

te

Fo

r C

ost

a T

rain

ing

T

ota

l F

or

To

tal

Fo

r T

ota

l F

or

To

tal

F

Cat

ego

ry

Co

mm

ents

R

ef

cost

s C

laim

ed

costs

To

tal

Invo

lc-s

13.

18

Invo

lca

19.2

2 T

ota

l In

volc

.s 1

3.18

In

volc

a 19

——

——

Salxh&Wages:

%ojeu

Co

ord

inat

or

(1)

S.1

211-

2 $1

05,3

72.2

4 $1

05,3

72.2

4 S

52,4

28.C

M

S52

,943

.40

%o

ject

Tra

inar

(2

) s-

l U

-z

17,1

33.2

4 17

,133

24

k.st

Fm

ld I+

on

~p

~fi<

.:.+

f$+’

, +.

<;

:Idca

l 1.

6542

2 1,

6542

2 ‘r

n!d

In

stn

xio

r 70

,591

.20

‘ield

In

stm

cso

r Va

riow

(6

) S-

lZM

-2

77,7

94.0

7 77

,794

.87

:br!u

l As

st

No m

m

gtie

n (5

) S-

12JI

.2

15.3

29.5

6 15

,329

.50

7,58

2.C6

7,

747.

50

@xm

t2n@

scal

No

m

gh%

n (4

) s-

12if-

2 20

,123

.7S

20,1

.B.W

hU

Ua

lson

No

nan

m g

iven

(3

) S-

12J1

.2

23,4

44.7

9 23

,444

,79

Ieric

al

No n

ame

give

n (5

) S-

1211

.2

4,7U

.00,

4,

744.

00

1,74

3.00

3,

c01!

oo

ield

In

sh-u

dio

fiia

iso

n

No

n

ame

giv

en

(6)

s-12

11-2

/ f,a

17.rw

1,

817.

00

hlld

Wel

fare

In

stru

ctio

n

No

n

ame

giv

en

(7)

s-1

2/1

-2

34,2

M.S

O

24,2

34.s

0 to

nal

SU

ppor

r tJ

Onam

egiv

en

(5)

S-lm

-z

2,15

6.60

2.

156.

60

Otal

S

380,

023.

82

$2S

2,92

3.80

$1

2’7,

1 W

.02

S63

,406

.12

S63

,691

.90

$0.0

0 So

.oo

tip

and

s (A

dva

nce

s)

(6)

sl,i4

7,so

o.o

o

S1,

147,

500.

00

$0.0

0 $0

.00

$0.0

0 So

.oo

So.o

o

Wan

&

Fee

s (9

) S

17,0

56.3

3 $1

7,05

6.33

S

o.o

o

SO

.oo

$0

.00

So.o

o SO

.oo

her

ln

stru

dJo

naI

C

Osb

:

wip

men

t (C

ptr

Pri

nte

r)

(lo

) S5

,564

.84

$5,584.84

$5,564.64

SO.o

o So

.oo

@ie

s/S

ervi

cas

(lo

) 9,

952.

59

9,952.59

9.952.59

Iep

ho

nes

(l

o)

512.

67

512.67

.

512.67

avel

(l

o)

4, W

0.31

4.

WG

,31

-4,

0420

.31

M

Oth

er

Inst

mxs

)on

al

Ccu

ts

S20

,030

.41

SO

.oo

S

20,0

30.4

1 $0

.00

$20,

030.

41

SO.o

o $0

.00

4

UI

Fed

eml

Sh

are

S1,

564,

610.

56

S1,

417,

480.

13

$147

,130

.43

S63

,408

.12

S83

,722

.31

So.o

o So

.oo

n-F

*dsm

l S

ham

(M

atch

ing

):

n.F

eder

al

Sh

are

(A)

(11)

34

21,5

36.4

3 S

421,

536,

43

198,

598.

54

S22

2,9:

khin

g

on

Ad

van

cas

100,

000,

00

10G

,OO

O,O

O

W

No

n-F

ader

al

Sh

are

(Mat

chin

g)

$521

,536

.43

Sloo

,ooo

.oo

So.o

o SO

.oo

SO.o

o 34

21,5

36.4

3 S

198,

598.

54

-:

21 t

nvo

lce

(To

tal

Fad

ed

+ N

on

-Fad

eral

) S

2,06

6,14

8.99

S1

,617

,480

.13

S147

,430

.43

S63;

408.

12

$63.

722.

31

S42

1 ,5

36.4

3 S

398,

598.

W

$222

,92

;s A

dva

nc8

s O

edu

ded

30

0,00

0.W

30

0,00

0.02

.

. .a

Mat

ch

on

Ad

van

cas

Ded

wte

d

10Q

,OO

O.O

O

lomoaoo

al A

mo

un

t C

lalm

ed

S1,

686,

146.

99

$1,1

+7,

480.

13

S14

7,13

0.43

S

63,4

06.1

2 -

S42

1,63

6.43

~

$222

,91

s C

OS

IS P

revi

ou

sly

Ols

allo

wed

(1

2)

14,9

W.9

1 14

,900

.91

46,6

70,6

6 46

.670

.68

ust

ed

Ad

min

ism

sUve

JMat

chln

g

Co

ats

Cla

lmed

S

132,

229.

S2

S48

,507

.21

S63

,722

.31

S37

4,86

5.75

S

151.

927.

96

* S

222,

91

——

.

. +1

7

.

------

I “. r

.“ r- APPENDI)( D, page&“$~!~r. Iv1-

STATE OF CALIFORNIA—HEALTH ANO WELFA!K AGENCY

DEPARTMENT OF SOCIAL SERVICES MAY 22 1996 . “—“-

: a“ 744 P Street, Sacramento, CA 95814 ~.

@,.,...-.

Mr. Joseph Lonergan, Acting Director Administration for Children

and Families M.S. OFNVDFEBG

370 L’Enfant Promenade, S. W. Washington, D. C. 20447 .

Dear Mr. Lonergan:

GWNT NO. 9601 CA1401, 9601 CA1404, 9601 CA1407 FOSTER CARE AND ADOPTIONS PROGWM .

Enclosed is the revised quarterly Statement of Expenditures for the October 1995 through December 1995 quarter for Maintenance Assistance, Administration and Training for the Foster Care and Adoptions Assistance Program funded under Title IV-E of the Social Security Act.

This revision is to correct parts I and 11,form IV-E-12, column (a) line A3, due to double reporting of SACWIS costs for the 12/95 quarter.

The following forms are also included:

If you have any questions Patsy Mackie,ofmystaff,at(916)

Enclosures

c: Sharon Fujii

Form No.IV-E-12

(WithEnclosures)

regarding this report, please contactmeat(916) 654-1630 or 654-1635. .

,,-“-

Sincplely,ii t

LER, Chief

FundAccountingand ReportingBureau

RegionalProgram Director

AdministrationforChildren

and Families

50 UnitedNationsplaza,Room L150

-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

-------------------------------------------------------------------------------------------------

------------------- ------------------- ----------------------------------------------

-------------------------------------------------------------------------------- ----------

----------------------------------------------------------------------------------------------------

1. .“

‘ ;Vj APPENDIX D, Page 3 of 13

ADIIINISTRAIIONFOR CHIIDREN,YOUTH AND FAHILIES TITLE IV-E FORM APPROVfD through l.igz STATEQUARIERLYREPORT OF EXPENDITURESAND ESIIHAIES Form IV-E-12 OM8 NO. O98O-OI31O

.COVERP.AGE

-----==c=--===:===-==I Paperwork Act Notice:Stateagenciesare requiredto providethe informationrequested in order to receiveI a grant aitardunder the provisionsof Title IV-E (sections471-476)of the Social Security ActI (42 USC 671-676). lhe Administrationfor Children,Youthand Faailieswill use these dat~ to calculateI the federal share of fundsavailableto the Stateto administerthe FosterCare and AdoptIon AssistanceI Programs. This is public information.I Reporting 8urden Notice: The reportingburdeniaposedby this collectionof information is estimatedI to average 25 hours per response. This includestime for reviewinginstruction,searching data sources,[ gathering and aaintaininqthe data needed andcoapletingand reviewingthe infor~ationcollected, SendI comments regardingeither thisburden estimateor other aspectof this requestfor information to: Formula

\ Grants Division,Children’sBureau,Ad~inistratiortfor Children,Youth and Families, P.0, Box 1182,I Washington,D.C, 20013 and to the Office of Informationand RegulatoryAffairs,Office of 14anageuientand\ Budget, Washington.D.C, 20503.

- - -l--I STATE (Naae amd CoupleteAddress) I SU8KISSION I CURRENTQUARTER ENDED I NEXT QUARTER ENDING

I I I I ] CALIFORNIA I I I I STATE DEPARTHEN1OF SOCIALSERVICES [ I I I 744 P STREET , HS 13-72 I 1. I

,I SACRAIIIEN1O CALIFORNIA 95814 I (1 Neu [X] Revised I 12/31/95 I 06/30/96 ,-------.--

I EHPLOYER IOENIIFICAIIONNUHBER 194600 1347 A7

III ALLFORHS HU$T BE COIIPLETEOANO ATTACHEDas noted:I LIST OF FOR14S:

I\ COYER PAGE, Quarterly,I PART I: EXPENDITURESAND GRANTREQUEST, 10TALCOHPUTA6LE,PAGE 1, Quarterly,I PART 11: EXPENDITURESAND GRANTREQUEST,FEOERAL.SHARE,PAGE 2, Quarterly,

______ --.---_------

I PART III: ESTIHATES,CURRENT4 THO FUTURE YEARS,TOTALCOKPUTA8LE,PAGE 3, Semi-Annually,I PART IV: ESllHATES,CURRENT& THO FUTURE YEARS.FEDERALSHARE,PAGE 4, Semi-Annually.I PRIOR QUARTER AD.3USTHENTS(as needed),NUKBEROF PAGES , Quarterly,I PART V: DETAILEDEXPLANATIONOF,INCREASEOR DECREASEOF 5% OR KORE, EXPENDITURES,PAGE 5, Quarterly.I PART Vl: OETAILIOEXPLANATIONOf INCREASEOR OECREASEOF St OR KORE, GRANT REQUEST,”PAGE 6, Quarterly. I PART VII: TYPE OF PLACEMENT,ALL CHILDREN IN FOSTERCARE & TITLE IV-E CHILOREN,PAGE 7, Quarterly.\ PART VIII: TYPE OF IV-E-ADOPTIONASSISTANCECHILDREN,PAGE 7, Quarterly,I PART IX: (VoluntaryFora),SELECTIONOF TRANSFERFROK TITLE IV-E-FOSTERCARE 10 TITLE IV-B (Child Welfare\ Services, PAGE 7, Selectedand Completed?_ Yes _ No, July 30.,l -----------+----------I This is to certify that al] informationreportcdcin all parts of this for~ is accurate and true to the best ] of By knowledgeand belief.This also certifiesthat the State’sshare of the funds requested for the next

] quarter ”incategory E (Column(c)) of PART 11 is or will be availableto meet the non-federal share ofI expendituresas requiredby law.l--_-----

I Signature or AuthorizedCertifyingOf fical[ TypedName, [itle, Agency Name, lelephone Number

I ,,- I (Area Code, Nunber,Extention) \

I l-w CarleenC. Kistler,Chief I Fund Accounting$ ReportingBureau I (916)657-1630

--_-__-------_--!-----------------------------------------------

Date Submitted MAY 221996 I

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

------------------------------------- -----------------------------------------

--

-------------------------------------------------------------------------------------------------------- --------

~ . ‘.

@29;.,’ - of13 “ ‘age 4

o d0: (’ ‘PEND’X

&j /?J?_6_c-rl *

AO14[NISlRAlION FOR CfflLDREN, YOUIH AND FAMILIES TITLE IV-E PAGk 1

STATE QUARTERLYREPORT OF EXPENDITURESAND ESl It4ATES Form IV-E-12 O14BNo.O98I)-O131O.

STATE: CALIFORNIA CURRENT QUARTERENDED: 12/31/95 NEXT QUARTER ENOING: 06/30/96

IPAR1 1. TOTAL CO14PUTABLEFOR I I I I FEDERAL PARTICIPATION I EXPENDITURES I /,--------- 1 I (c) NEXT QUARTER

~I ~ (a)“C:Ll;~;jl~;;[~ER (b) PRIOR QUARTER I ESTIHATES II CATEGORY ADJUSTMENTS 1 II I I II I I I1A. NON-VOLUNTARYFOSTER CARE i i IIl. IlaintenanceAssistancePAYHENTS I I II a. TOTAL I 159,713,526 I o I 162,599,810I b. Child SupportCollections I -940,608 I o I -1,448,860I c. Amount Subject to Sequestration I 0 I o II d, NET TOTAL PAYMENTS I 158,772,918 I o I 161,150,95jI e, Average Ifonthlyi of Children I 60,341 I o I 54,96112. State and Local ADMINISTRATION I I I II a. Case Planning& Management I 94,240,342 I o I 102,800,000 II b. Pre-placeeentActivities I 9,281,160 1. 0 I 10,000,000 II c. EligibilityDeterminations I 18,736,958 I o I 22,200,000 II d. Other I 14,116,256 -l,723,8t8 I 10,200,000I e. TOTAL ADMINISTRATION I 136,374,716 -1,723,888 I 145,200,000i3, State and Local TRAINING i 11;063;079~ -29,963 I 11,000,000

IIi IlBo VOLUNTARYFOSTER CARE I IIl. MaintenanceAssistancePAYNENTS II a, TOTAL I 658,688 o I 543,900 I b, Child SupportCollections I o 0 I oI c. Anount Subject to Sequestration I o o I o’ I- d. NET TOTALPAYMENTS I 658,688 0 I 543,900I e. Average Honthly 1 of Children I 230 0 I 20912. State and Local ADMINISTRATION I 239,434 -722 I 192,69013. State and Local lRAININfJ I 1,519 -7 I 1,049

;C..ADOPTIONASSISTANCE i 1. IIl. MaintenanceAssistancePAYHENTS I I II a. TOTAL I 18,666,208 I o It 18,970,640I b, Amount Subjectto Sequestration I o I o I o I c. NET TOTAL PAY14ENTS I 18,666,208 I o I 18,970,640 I d. Average Monthly i of Children ~ 14,671 1 0 I 14,504’12.State and Local ADKINISIRATION I II a, TOTAL I 6,298,376 I -340,912 \ 6,500,000I b. Amount of NON-RECURRINGCosts I o I o I oI c, # of Children for whoh II Non-recurring Costs Paid o I o I o 13. Stateand Local TRAINING 1 lli,215

======,==--:--== ====== =====:=========:===l========= ===.: ============:!;!::====:============!::::::=====.,======== ID. TOTAL COHpUTA81E (ALL PROGRAHS) I 335,381,601 I -8,102,122 I 370,383,729

---------------------------------------------------------

---------------------------------------

. . .

---------------

-----------------------------------------------------------------------------------------------------------------

APPENDIX D, Page 5 of 13

. .. ... ...- --. . /

FOR CHILDREN, YOUT, .{DFAMILIES TITLE IV-t .(j~AiHIiiISTRATION lo PAGE2 AND ESTIMATES form IV-E-12 ~~ti OK8 No.0980-(1131(1STATEQUARTERLYREPORTOF EXPENDITURES

@D

STATE: CALIFORNIA CURRENT QUARTER ENDED: 12/31/95 NEX1 QUARTERENDING: 06/30/96=:=:========:==:==================--====:--== =======================:::=======::==:=------

IPART II. FEDERAL SHARE OF I I I1- EXPENDITURES I EXPENDITURES I I I

,-------------------.--------------------------, (c) NEXTQUARTER 1I I (a)CURRENTQUARTER I (b) PRIOR QUARTER I ESTIHATES I I CATEGORY I EXPENDITURES I AOJUSTHENTS I iI I I II I FNAP = 501 I I FtfAPz I 1A.NON-VOLUNTARYFOSTERCARE i i“ I Il.-MaintenanceAssistancePAY14ENTS I ..... . . I I I a. 10TAL I 79,85&.16$ I o I 81,299,905 \ b. Child SupportCollections I -470,304 I o -724,430 I c. Auount Subject to Sequestration I o I o ! o I d. NET TOTALPAYHENTS I 79,386,459 I o I 80,575,475 I e. Average Honthly 4 of Children ] 60,341 I o 54,961 12. State and Local ADMINISTRATION I I /I a. Case Planningt Hanagenent I 47,120,171 I o 51,400,000 I b. Pre-placenentActivities I 4,640,580 I . 0 5,000,000 I c. EligibilityDeter~inations I 9,368,479 I o 11,100;000 I I d, Other I 7,058,128 I -3,861,944 5,100,000 I I e. TOTAL ADMINISTRATION I 68,187,358 I -3,861,944 72,600,000 I [3. State and Local TRAINING I 8,297,309-f1 -22,472 8,250,000 I

I

1 ill.VOLUNTARYFOSTERCARE i i I Il.MaintenanceAssistancePAYNENTS I I I I a. TOTAL I 329,344 o I 271,950 I I b. Child SupportCollections I o o I o I I c. Amount Subject to Sequestration I o o I o~ I d. NET TOTAL PAYHENTS I 329,344 o I 271,950 I e, Average Honthly 1 of Children I 230 0 209 12. State and Local ADMINISTRATION I 119;717 -361 I 96,345 13. State and Local TRAINING I 1,139 -5 I 187

I I I I I IC.ADOPTIONASSISTANCE I I /1. MaintenanceAssistancePAYMENTS I I [ a, TOTAL I 9,333,104 o 9,485,320 ! b. Amount Subject to Sequestration I .c. NET TOTALPAYHENTS

I

I o

9,333,104 [ 0 o

II

o 9,485,320

I d. Average Honthly I of “Children I 14,671 I o I t 14,504 12. State and Local ADMINISTRATION I I II a. TOTAL 3,149,188 I -170,456 [ 3,250,000 I b, Amount of NON-RECURRING Costs I o I o! o I C. I of Childrenfor whoa I I I Non-recurring Costs Paid I I o 0 [3. State and Local TRAINING I 129,20: I -4,973 I 134,250

- ,==__ :===== =====: ==:=== =,==-_,===----=-== =========:-- ========:= =======--=-_ __===zzzz:==,:,z,==,,, ===------ --------:=:C= z 1 10. TOTALFEDERALSHARE(ALLPROGRAHS) I 171,283,616 [ -4,060,211 194,642,2S2 !==== ===== ===== :==== ============[========== ====================l=======================, ========:= :=~,===========IE. STATE SHARE OF EXPENDITURES 164,097,985 /1////1/1/1/1111/1///111 175,735,477 I

----

----

---

----

---

----

----

----

----

----

----

---

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

--

----

----

----

----

----

----

----

----

----

----

----

----

----

---

----

----

----

----

----

----

---

------

-----

------

-----

------

----

------

----

------

-----

------

------

------

------

-----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

-

----

----

----

----

----

----

----

----

----

---

----

----

----

----

---

----

----

----

----

----

----

----

--

SUM

?IAR

Y O

F C

OU

NT

Y AOMIN C

LA

IMS

A

ND

CU

RR

EN

T QUARTEREXPENDITURESWORKSHEET.

Ouarter Ended 12/31/95

CA

CQ

E12

95

FF’P

F

ED

ER

AL

C

OU

NT

Y

t C

OIII

L

ounc

y A

UIW

~fI.

Cla

ims.

Q

tr.

12/9

S&

BASI

S R

AT

E

SHAR

E A

DJU

ST

ME

NT

pgfl P

in

Cod

e:

LIN

E:

I.”Ca

se

P&

Mgm

t,5A

L.

127,

147,

148,

149

94,2

40,3

42

50%

47

,120

,171

F

C A

dm

in.

327.

5a,

. .

. .

..e.

.e

. .

...12

7 8,

548,

647

2,

Pre-

plac

emen

t Ac

tiviti

es

5A,L

,128

9,

281,

160

50%

4,

640,

580

Cas

e P

&

M

gm

t.

. .

. .

. .

. .

..}47

15

,91.

1,72

8 .

. .

. .

. .

...14

8 22

,659

,796

3.

Eli

g.

Det

erm

.327

.5A

L

129,

137,

143

4,52

9,79

8 50

%

2,26

4,89

9 .

. .

. .

. .

. .

. 14

9 0

4.

AF

DC

-FC

32

7.5B

-

L20

5 14

,207

,160

50

%

7,10

3,58

0 T

otal

E

ligi

bili

ty

Det

erm

inat

ion:

18

,736

,958

50

%

9,36

8,47

9

5.

FPP

327.

5A

L,1

77,1

79,5

00

327.

4A

500

2,85

8,59

0 50

%

1,42

9,29

5 (L

ine

1)

TO

TA

L

----

--~

47,120,171

6.

Lice

nsin

g/Re

crui

tmen

t.5A

L,15

5 1,

797,

054

50%

89

8,52

7 7,

*

FC

IV-E

SL

IAG

-

Prog

Fam

.Fro

m

mod

pg

. 0

50%

0

FC

Adm

in.

FPP

327.

5a

..

..

..

..

..

..

..

..1

77

1,10

7,67

2

8.

k SA

WS

168,

497

50%

84

,249

,.,

.,,

.. .

. 17

9 15

9,85

9

9,

* St

ate

Adm

inis

trat

ion(

from

fcsurnlzqs)

9,23

2,99

6 50

%

4,61

6,49

8 .

. .

. .

. .

...50

0 16

1,42

8

10. * probation

L.ljl,

59,1

18

50%

29

,559

32

7.4a

.

..

..

..

..

..

..

...52

3 13

6TitleIV-E,327.5A

TotalO

ther

: 14

,116

,255

50

%

7,05

8,12

8 (L

ine

5)

TO

TA

L

----

--~

1,42

9,29

5

TO

TA

L

FOST

ER

C

AR

E A

DM

INIS

TR

AT

ION

:

13b,374,715 50%

68

,187

,358

11.

FC

Tra

inin

g.32

7.4A

L

. 13

7,14

3,14

5,]4

7,

FC

Adm

in.

327.

5a

..

..

..

..

..

..

..

..l29

1,

123,

177

148,

14

9,15

5,15

8,16

2,17

4,17

7,

179,

504,

506

2,36

4,25

2 75

%

1,77

3,18

9 El

ig.D

eter

m.

. ..!

.

. ..!

.137

0

12.

FPP/

CW

S 32

7,5A

-162

,174

L

ies

158

504,

506

‘318

;747

75

%

689,

060

. .

. .

. .

. ...

143

1,10

8,24

0

13.

AFD

C-F

C

Eli

gibi

l T

rng-

FE

D

327,

4B”L

205

51,2

44

75%

38

,433

@

J %

Tb#

o”~

., .

. .

. .

...52

3 33

,482

14

. *

FC

Iv_E

S

LIA

fj

-S

taff

D

ev

(mod

.Pg.

)

o 75

%

()

@w

dt

>””

15,

* SA

WS

o 75

%

o . ‘

,~~

,qo

@’

(Lin

e 3)

T

OT

AL

--

----

>

2,26

4,89

9

16.

* St

ate

&

Lot

. T

rain

ing(

from

fc

sum

1295

) 3,

008,

205

75%

2,

25b,

154

a “

z’

17.

�

F’R

08A

TIO

N

FC

TR

AIN

ING

5A

L

.130

,1L

5 4,

720,

631

75%

3,

540,

473

FC

Tr’

aini

ng

327.

4a

. .

. .

. .

. .

. .

. .

. ...

137

15,5

12

TO

TA

L

FOST

ER

C

AR

E

TR

AIN

ING

:

ll,0

b3,0

79

75%

8,

297,

309

/ 7-

. .

. .

. ..!

. .1

43

8,03

8 ..........

145

1,35

0,00

6 1S

. A

dopt

A

sst

Adm

n.-5

A

L11

7,12

1 ,1

23,

5,07

1,55

4 50

% 2,

535,

777-

(@h

5{3

. .

. .

. .

. ...

147

118,

071

19.

327.

50

-L

230

M

Eli

gibi

lity

-FE

D

424,

056

50%

21

2,02

8 .

. .

. .

. .

...14

8 17

5,38

9 20

. k

SAW

S o

50%

o

..

..

..

..

,, 14

9 0

21,

* St

ate

Adm

inis

trat

ion(

from

fc

sum

1295

) 64

8,43

6 50

%

324,

218

F .,

. .

. .

. ...

155

6,19

8 .

..

..

..

...15

8 4,

607

22.

* PR

OB

AT

ION

AD

OP

TIO

NS

32

7 .5

A

L.

132

154,

330

50X

77

,165

.

.,....

...16

2 0

TO

TA

L A

DO

PT

ASS

IST

AN

CE

A

DM

INIS

TR

AT

ION

:

6,29

8,37

6 50

%

3,14

9,18

8 ,..

,...

. .

. 17

4 51

1 . .

. . .

. . .

,. 1

77

6,27

7 23

, A

dopt

. A

ssis

t. T

rg.

327.

5A

-12

5 14

1,21

1 75

%

105,

908-

,. ,.

. .

. ,.

. I

79

880

24.

327.

4A

-L

117

,125

A

A T

rain

ing-

FE

D

29,0

81

75%

21

,811

,

. .

. .

. .

. ..5

OL

6&

,925

25

. 32

7.4B

-

L23

0 A

A E

ligi

b.

Trn

-FE

D

1,98

3 75

%

1,48

7 (L

ine

II)

TOTA

L ---

---~

1,75

0,41

4 26

.*

SAW

S o

75%

o

t

27.

* St

ate

& L

oc.T

rain

lng(

from

tc

sum

1295

) o

75%

o

FC

Pr

ohtlo

n 12

7.5a

.

..

..

..

..

..

..

...l

3O

801,

719

Trai

ning

. .

..

..

..

..

. 14

5 2,

73S

,754

TO

TAL

ADO

PTIO

N AS

SIST

ANCE

TR

AINI

NG

: 17

2,27

5 75

%

129,

206

28.

327.

5A

CUS-

CASE

M

GT:

V

O1

FC

L.1

54

126,

052

50%

b3

,02

6-(L

ine

17)

TO

TA

L -

----

->

3,54

0,47

3 29

. 32

7 .5

B

AFD

C-F

C-V

OL

PG

M L

.206

11

3,38

2 50

%

56,6

91

TO

TA

L V

OL

FO

STE

R

CA

RE

AD

MIN

. :

239,

434

50%

11

9,71

7 A

dopt

ion

32

7.5a

. (L

18)

. .

. .

. .

. .

..ll7

2,

463,

829

Ass

t A

dmin

. (L

ine

18)

. .,,

......

121

39,8

33

30

327.

4A

CW

S-C

ASE

MG

T:

VO

1 F

C

L,15

4 55

2 75

%

414-

(Lin

e 18

) .

. .

. .

. .

...12

3 32

,115

31

, 32

7 .4

B AF

DC-V

OL-

FC

PGM

L.

20

6 96

7 75

%

725

Prob

atio

n (L

ine

22)

. .

. .

. .

. ...

132

77,1

65

TOTA

L VO

L FO

STER

C

AR

E T

RA

ININ

G:

1,51

9 75

%

1,13

9 TO

TAL

------

> 2,

612,

942

c.*.

A

T

.ral

A

ilmin

an

d

Tra

inin

g

FC/A

DOP

and

Vol

unta

ry

FC/A

DO

P 79

,883

,917

-.

.-t

b-l,-

! N

-?-.

A

II n

qi

tle

line

[ter

n

amou

nts

are

inpu

tted

di

rect

ly.

----

----

----

---

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

---

----

---

-

----

----

----

----

----

----

----

----

----

----

----

----

--

----

----

----

---

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

---

----

----

----

---

----

---

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

-

----

----

----

----

----

----

----

---

----

----

----

----

----

----

-

.

SUM

MA

RY

OF

CO

UN

TY

AD

MIN

C

LA

IMS

A

ND

C

UR

RE

NT

Q

UA

RT

ER

E

XP

EN

DIT

UR

ES

W

OR

KSH

EE

T.

Qua

rter

E

nded

12

/31/

95

CA

C(j

E12

95

FFP

FE

DE

RA

L

CO

UN

TY

Fr

omCo

unty

Adm

in.

Cla

ims

Otr

. 12

/95

—--

-B

ASI

S R

AT

E

SH

AR

E

AD

JUS

TM

EN

T

Pgl

) &

P

in

Cod

e:

LIN

E:

Cas

e P

&

Mgm

t,5A

L

.127

,147

,148

,149

‘3

4,24

0,34

2 50

%

47,1

20,1

71

FC

Adm

in.

327.

5a

. .

. .

. .

. .

. .

. .

. ...

127

8,54

8,64

7 P

re-p

~ace

men

t A

ctiv

ities

5A

,L.]

28

9,28

1,16

0 50

%

4,64

0,58

0 C

ase

P &

M

gmt.

. .

. .

. .

. ...

147

15,9

11,7

28

. .

..

. .

....

148

22,6

59,7

96

Eli

g.

Dete

rm.3

27;5

A L1

29,1

37,1

43

4,52

9,79

8 50

%

2,26

4,89

9 .

..

..

..

..

.14

9 0

,. A

FDC

-FC

32

7.5B

-

L20

5 14

,207

,160

50

%

7,10

3,58

0

Determination:

18,736,958 50%

9,368,479

TotalEligibility

327.4A500

:,858,590 50%

1,429,295

(Line1)TOTAL------>

47,1

20,1

71,.

FPP327.5AL,177,179,500

L,155

1,797,054 50%

898,527

J. Licensing/Recruitment.5A

*FC IV

-E

SL

IAG

-

Pro

gram

,Fro

m

mod

pg

. o

50%

o FC

A

dmin

. F

PP

327,

5a

..

..

..

..

..

..

..

..l77

1,

107,

872

1,

k SA

WS

168,

498

50%

84

,249

.,

. .

. .

. ...

179

159,859

1.

* St

ate

Adm

inis

trat

ion(

from

E

csum

1295

) 9,

232,

996

50%

4,

616,

498’

v’

. .

..!

. .

...50

0 161,428

).

* P

roba

tion

T

itle

IV

-E,3

27.5

A

L.1

31,

59,1

18

50%

29

,559

32

7.4a

.

. .

. .

. .

. .

. .

. .

...52

3 136

Tot

al

Oth

er:

14,1

16,2

56

50%

7,

058,

128

(Lin

e 5)

T

OT

AL

--

----

>

1,429,295

TO

TA

L

FOST

ER

C

AR

E

AD

MIN

IST

RA

TIO

N

: 13

6,37

4,71

6 50

%

68,1

87,3

58

----

----

----

----

----

----

=--

----

-

[,

FC

Tra

inin

g.32

7.4A

L

, 13

7,14

3,14

5,14

7,

FC

Adm

in.

327,

5a

. .

. .

. .

. .

. .

. .

. .

..l29

1,

123,

177

148,

14

9,15

5,15

8,16

2,17

4,17

7,

179,

504,

506

2,36

4,25

2 75

%

1,77

3,18

9 E

lig,

Det

eno.

.

. .

. .

. .

. .,

137

0 2,

FPP

ICW

S 32

7.5A

-162

’,

174

Lie

s 15

8 50

4,50

6 91

8,74

7 75

%

689,

060

Opf

l .

. .

. .

. .

. .

. 14

3 1,

108,

240

1, A

FDC

-FC

E

ligi

bil

Trn

g-F

ED

32

7.4B

L

205

S1,

244

75%

38

,433

9c

:%5\

@ti

b;fi

~ +

.

..

..

..

...52

3 33

,482

i,

*

FC

IV-E

S

LIA

G

-S

taff

D

ev

(mod

,Pg.

)

o 75

%

ord

\w5,

@

,9

‘ i.

*

SAW

S o

75%

“

~’

~}@

(j

J@’

(Lin

e 3)

T

OT

AL

-.

----

->

2,26

4,89

9 i.

*

Stat

e &

L

oc.

Tra

inin

g(fr

om

fcsu

m12

95)

5,92

8,23

6 75

%

4,44

5;

17!*

’bk

7,

* PR

OB

AT

ION

FC

T

RA

ININ

G

5A

L.1

30,1

45

4,72

0,63

1 s

75%

3,

540,

473

FC

Tra

inin

g 32

7.4a

.

. .

. .

. .

. .

. .

. .

. ..l

37

15,5

12

TO

TA

L

FOST

ER

C

AR

E

TR

AIN

ING

:

13,9

83,1

09

75%

10

,487

,332

$+

.

. .

. .

. .

...14

3 8,

038

.--_

_---

----

----

----

---

. .

. .

. .

. ...

145

1,35

0,00

6 3.

A

dopt

A

sst

Adm

n.-5

A

L11

7,12

1,12

3,

5,07

1,55

4 50

%

2,53

5,77

7-,..

......

,147

11

8,07

1 1.

32

7.5B

-

L23

0 A

A

Eli

gibi

lity

-FE

D

424,

056

50%

21

2,02

8 .

. .

. .

. .

...14

8 17

5,38

9 ).

*

SAW

S o

50%

o

..

..

..

..

.014

9 0

1.

* St

ate

Adm

inis

trat

ion(

from

fc

sum

1295

) 64

8,43

6 50

%

324,

218

. .

. .

. .

. .

. .

155

6,19

8 .

..

..

..

...15

8 4,

607

2.

* pR

oBA

TIo

N

~opT

1oN

s 32

7.5A

L

e132

15

4,33

0 50

%

77,1

65

., ..

....

..,.

162

0 T

OT

AL

A

DO

PT

A

SSIS

TA

NC

E

AD

MIN

IST

WT

ION

:

6,29

8,37

6 50

%

3,14

9,18

8 .

. .

. .

. .

. .

. 17

4 51

1 --

----

----

----

---.

.-

-__-

----

--__

-.

. .

. .

. .

. .

. 17

7 6,

277

3,

Ado

pt.

Ass

ist.

Trg

. 32

7.5A

-

125’

14

1,21

1 75

X

105,

908-

..!

. .

. .

...17

9 88

0 4.

32

7.4A

-

L11

7,12

5 A

A

Tra

inin

g-F

ED

29

,081

75

%

21,8

11

...

,..,,

. . 5

04

64,9

25

5,

327.

4B

-L

230

AA

E

ligi

b.

Trn

-FE

D

1,98

3 75

%

1,48

7 (L

ine

11)

TO

TA

L

----

-->

1,

750,

414

6.

*SA

WS

o 75

%

0 7.

*

Sta

te

&

Lo

c.T

raln

lng

(fro

m

fcsu

m12

95)

o 75

%

0 FC

P

rob

atiu

n

327,

5a.

,. ...

,..

,,

. .

. ..l

3O

801,

719

“ .

Tra

inin

g.

..

..

..

..

..

145

2,73

8,75

4 T

OT

AL

A

DO

PT

ION

A

SSIS

TA

NC

E

TR

AIN

ING

:

172,

275

75%

12

9,20

6 ++

8.

327.

5A

CW

S-C

ASE

fl

GT

: V

O1

FC

L.1

54

126,

052

50%

63

,026

-(L

ine

17)

TO

TA

L

----

-->

3,

540,

673

9.

327.

5B

AFD

C-F

C-V

OL

PG

M L

,206

11

3,38

2 50

%

56,6

91

TO

TA

L

VO

L

FOST

ER

C

AR

E

AD

MIN

.: 23

9,43

4 50

%

119,

717

Ado

ptio

n 32

7,5a

.(L

18)

. ..!

.

. .

...11

7 2,

463,

829

-A

sst

Adm

in.

(Lin

e 18

) .

. .

. .

. .

...12

1 39

,833

0

327.

4A

CW

S-C

ASE

M

GT

: V

O1

FC

L.1

54

552.

75

%

414-

(Lin

e 18

) .

. .

. .

. .

...12

3 32

,115

1.

32

7,4B

A

FDC

-VO

L-F

C

PGM

L,2

06

967

75%

72

5 P

roba

tion

(L

ine

22)

, .

. .

. .

. ...

132

77,1

65

TO

TA

L

VO

L

FOST

ER

C

AR

E

TW

ININ

G:

1,51

9 75

%

1,13

9 *

--

----

-LL-

---

TO

TA

L

----

-->

2,

612,

942

..

.J

m..

..,

.1-:

. ..A

7

...<

-.””

cr

.lhn

nn

.-

A

!I,-

.lq,e

v,v.

-p

piA

nn

p

R7

n73

Q

.4n

-

---

---

APPENDIX D, Page 8 Of 13 f“ Enclosure v

“l”.. .>.--’f

PETE WILSON. GO.ernOrSTATE OF CALIFORNIA-HEALTH AND WELFARE AGENCY

DEPARTMENT OF SOCIAL SERVICES

744 P StreeL Sacramento, CA 95S14

M. Joseph ~nergan, Acting Director Administration for Children

and Families M.S. OFM/DFEBG 370 L’Enfimt Promenade, S. W. Washington, D. C. 20447 . .

Dear Mr. Lonergan:

GRANT NO. 9601 CA1401, 9601 CA1404, 9601 CA1407 FOSTER CARE AND ADOPTIONS PROG~ .

Enclosed is “tie revised quarterly Statement of Expenditures for the July 1996 though September 1996 quarter for Maintenance Assistance, Administration and Training for the Foster Care and Adoptions Assistance Program funded under Title IV-E of the Social Security Act.

This revision includes amounts for audited County Administration Claims for the September 1996 quarter.

The following forms are also included:

Form NO. ~-~12 (with Enclosures)

If you have any questions regarding this repo~ please contact me at (916) 654-1630 or Patsy Mackie, of my staff, at (916) 654-1635.

r

Enclo~es

c: Sh~og @jii.

RegionalProgramDir~tor

AdministrationforChildren

andFamilies

jk

since Iy,

4%2T-CARLE C. KISTLE~ Fund Accounting and

Reporting Bureau

. Chief

-. . ..

so UnitedNationsPI- Room 45o,--------

---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

------- -------- - ---------- - ------- - --- ------ ---------- --- - --- ----------

--------------------------------------------------------- -----------------------------------------

--- ---- ----- -------------- - ---- - - - - --------- - - ------------- - -----------------------

-----------------------------------------------------------------------------------------------------------------

---------------------------------------------------------------------------------------------------------------

.r APPENDIX D, Page 9 Of 13 i

Lr_“c. . .

. “t

ADHINISIRATIONFOR CtlllDREN,YOUTH ANO FAHII-IES TITLE IV-E FORK APPROVED through 1/92 STATE QUARTERLY REPORT OF EXPENDITURES AND ESTIHATES Form IV-E-12 0X8 NO. 0980-01310 .

COVERPAGE--a-

I Paperwork Act Notice: State agenciesare requiredto providethe informationrequestedin order(toreceive 1

I a grant auard under the provisionsof Title IV-E (sections47.1:476)of the SocialSecurityAct I I (42 USC 671-676). The Administrationfor Children,Youth and FaailiesMill use these data to calculate I I the Federalshareof funds availableto the State to administerthe FosterCare and AdoptionAssistance I I PrograIs. This is public information, I I Reporting Burden Notice: The reportingburden iaposedby this collectionof info~aationis estimated I I to average 25 hours per response. This includestime for revieuinginstruction,searchingdata sources, I I gathering and maintainingthe data needed and completingand reviewingthe informationcollected, Send I I conments regardingeither this burden.estilateor otheraspectof this requestfor informationto: Formula I I GrantsDivision, Children’s Bureau, Administration for Children,Youthand Families,P,O. Box 1182, I I Uashington,D.C.20013 and to the Office of Informationand RegulatoryAffairs,Office of 14anagementand II fludget,!fashington:D.C. 20503. I

..---------- .------- . -- . ------------------- I STATE (Hate aad Complete Address) I SUBMISSION I CURRENTQUARTEREHDED I HEXT QUARTER ENDING [

I I I I CALIFORNIA I I I I STATE DEPARTHEHT OF SOCIAL SERVICES I 1. I I 744 P STREET , HS 13-72 I I I I SACRAMENTO , CALIFORNIA 95814 I [1 ftew [Xl Revised [ 09/30/96 I 03/31/97 I

.- ---------.----I

EHPLOYER IDENTIFICATIONNUHBER 1 946001347 A7 I

I1 ALL FORHS I(USTBE COHPLETEDAND ATTACHED as noted: II LIST OF FORM: II I I COVER PAGE, Quarterly. I I PART I: EXPENDITURESAND GRANT REQUEST, TOTALCOMPUTABLE,PA6E 1, Quarterly. I I PART II: EXPENDITURESAND GRANT REQUEST,FEDERALSHARE,PA6E 2, Quarterly, I I PART 111: ESTIHATES,CURRENT & TUO FUTURE YEARS. TOTAL. COHPUTA6LE, PAGE 3, Seai-Annually, I I PART IV: ESTIHATES, CURRENT t TWO f4JTURE YEARS. FEDERAL SHARE, PAGE 4, Seai-Annually. I I PRIOR QUARTER ADJUSTMENTS (as needed), NUH8ER OF PA6ES_, , Quarterly. I I PART V: DETAILED EXPLANATIONOF INCREASEOR DECREASEOF St OR HORE, EXPENDITURES, PA6E 5, Quarterly. I I PART VI: DETAILED EXPLANATION OF INCREASE OR DECREASE OF St OR HORE, 6RANT REQUEST, PAGE 6X Quarterly. I I PART VII: TYPE OF PLACEHENT,ALL CHILDREN IN FOSTER CARE & TITLE IV-ECHILDREN,PAGE 7, Quarterly, I I PART VIII: TYPE OF IV-E-ADOPTIONASSISTANCECHILDREN,PAGE 7, Quarterly, I I PART IX: (VoluntaryFora), SELECTIOHOF TRANSFERFROH TITLE IV-E-FOSTERCAllETO TITLE IV-8 (ChildHelfare I

Services, PA6E 7, Selectedand Co~pleted? — yes _ttO. July 30.o ‘< I - ----.----_---- - --.----.------- I

This is to certify that all informationreportedon all parts of this fort is accurateand true to the best I of ay knouledge and belief, This also certifies that the State’s share of the funds requester for the next I quarteiin Category E (Coluan (c)) of PART 11 is or uill be availableto ~eet the non-Federalshare of I expendituresas requiredby law, I

I Signature or AuthorizedCertifyingOffical[ Typed Name, Title,AgencyNaae, Telephone Number I

1 (Area Code, Nuaber, Extention) I i

Fund Accounting&Reporting BureauY4??+%ZL4LJ& car’eenc’Kist’erchief [ I

I (916)657-1630 ~ I --1

f)~ a 4 j99fj Date Subaitted I

------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

------- ----------------------- --------------------------- --------------------------------------- --

----------------------------------------- -------------------------------------- ----

-----------------------------------------------------------------------------------------------------------------

APPENDIX D, Page 10 of 13

FOR CHILDREN,YOUTH .,riDADt41NISlRATIOf4 FAHILIES TIILE IV-E PAGE ~

STATE QUARTERLYREPORT OF “EXPENDITURESAND ESTIMATES form IV-E-12 0H8 No.0980-01310

STATE: CALIFORNIA CURRENTQUARTERENDED: 09/30/96 NEXT QUARTER ENDING: 3/31/97===-

IPART Il. FEDERAL SHARE OF I iI EXPENDITURES EXRENOITURES I

(c) NEXT QUARTER II--------------------------------:------l----------------------------------------------I I (a) CURRENTQUARTER I (b) PRIOR QUARTER I ESTIUATES i,i CATEGORY I EXPENDITURES I ADJUSTHENlj I II I I I II I FHAP = 501 I I Ft4AP= 50.23% 11A. NON-VOLUNIARYFOSTERCARE I I I IIl. MaintenanceAssistancePAYMENTS I I I II a. TOTAL I 87,452,150 I 7,046 ] 89,500,000 1I b. Child Support Collections I -1,357,385 1 0 I -1,000,000 II c. Anount Subj~ct to Sequestration I o I o I o II d. NET TOTAL PAYHENTS I 86,094,765 I 7,046 I 88,500,000 1I e. AYerage Honthly # of Children I 64,267 I 5 I 65,000 I12. State and Local AWIINISTRA11ON ] I I iI a. Case Planning & Hanagenent I 50,489,284 I o I 56,000,000 \I b. Pre-placeaentActivities I 5,089,688 I “ o I 5,000,000 II c. EligibilityDeterminations I 9,297,933 I o I 11,000,000 [I d. Other I 50,400,019 I o I 15,000,000 II e. TOTAL ADMINISTRATION I 115,276,924 I 824,431 I 87,000,000 I13. State and Local TRAINING I 9,067,348 ] -1,800,337X+ I 8,900,000 1

I I I I I18..VOLUNTARYFOSTER CARE I IIl. 14ain.te.nanceAssistancePAYHENTS I I I II a. TOTAL I 303,621 I o I 300,000 II b. Child Support Collections I o I o I o II c. Amount Subject to Sequestration o I o I o II d.-HET TOTAL PAYHENTS I 303,621 I o I 300,000 [I e. AYerage Honthly i of Children I 234 I o I 230 I12. State and Local ADMINISTRATION I 108,881 I 1,022 I 170,000 I13. State and Local TRAINING I 971 I -2 I 1,800 II I I I II I I “1 IIC. ADOPTION ASSISTANCE I I I IIl. MaintenanceAssistancePAYHENTS I I I II a; TOTAL I 10,177,358 I ~ ~ o I 10,500,000 I[ b. Anount Subject to Sequestration I o I o I o II c. NET TOTAL PAYIIENTS I 10,1?7,358 I o I 10,500,000 II d. AverageHonthly i of Children I 15,721 I o I 16,500 I12. State anrJLocal AOHINISTRATION I / I[” a. TOTAL I 3,927,690 / -418,471 3,750,000 II b. Acount of NON-RECURRING Costs 1 0 I o I o II c. I of Children for tihon I I II Non-recurringCostsPaid o I o I o I[3. State and Local TRAINING I 106,213 I 340 .16.0,000 I,=T:_-: . ~--_s=---------.--.--.7--------- ,==- ,==-------------------- -=-_==--= ===-- I-=---- ~.:s>.-.-.--:- ;==- ====--- ====--

ID..TOTAL,F$DER,AL.. SHARE (ALL.PROGRAHS~ 1“ 221,291,237 I -1,385,977 I 204;657,716 I.... .,==== ~~ -_-_l,:- ,==_- ,====----=============:=======:===:====----- z-==============IIE. STATE SHARE OF EXPENDITURES I 219,689,904 ////11//1///1//1/1/111/1 197,707,138 I

----

---

----

----

----

----

-------

---

----

-

.

10s

I I

88

II I

Is

10s

/ /

01

,.’

I I

,’

10s

~I P89’iII

I

/ 0s

/ [ Z[8’91f

’l

II

0s

I [9

2’s,

I SZ

s’ol

piwmp~

II

II

iSl

I i

IOI1

66SI

T .-

-.--

-..-

.-.-

:--

............ ........ ........................ .......................

,,\-

--::

1-

----

----

----

----

-.--

~ /-

----

----

----

---

(Xog

I

11-1

S

IWd

~s

asu

adx3

(t

0s

le)

I U

?JP

l!~~

[

~l?

~ ~

[py

JO

Ja~J

en~

Jo~

~ ~u

aals

n[p

y s!

qI

I q

jaq

])

I jo

I

(tsl

I?

) I

6U!J

Jn)’

?#.

UO

N

~ Iu

nomy

Jo

I

I dV

H~ I

al

?~ dVH

440

Iunw

$

I ~u

nouy

[ p

aq)e

~ly

I (q

) uu

n[oj

I

s2Jn

l!p

uad

x~

I.

...~

. -

..

..

..

..

..

..

..-.

..

..

..-.

..

..i

4[~l

UO

H

1...

--.

-.:

..

...-

----

. -

..

..---

. --

--1

,?lq

eln

dto

l

I ‘J

JPN

‘[1

Jo

au!

~ ‘H

i 6u

!u!e

Jl

07

I

S?

Jn

]!P

U?

dX

~ U

O!~

?J]

S!U

\UP

V

‘~1

?6e

J?A

y ‘~

I

a)ue

ls!s

sy

slua

a~ed

‘a

l 1V

101

‘:

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

....

.....

......

...

......

...

......

....

......

.. --

-.-.

----

----

-I

I S

lH3H

lSllr

OV

9N

lSV

3i13

30

I

I 11

2’92

i

11S

’61S

’1

I 60

[’21

88

s’81

z’t

I SI

vlol

I

/---

--..

..--

-; --

o--

--/-............. .................

11-1

----

----

-P

----

----

- l------

----

----

---

!--O

..

--!

.-1-

----

----

----

----

----

---

,....I............

I I I

II

I I

II

I /

/ I

Sl,

I 111’Zf

I I6L1’OLS’II

I 0s

8S

[(0)

1’[

I ‘IJ

!wPV

~s/

ZT

JJ?

3 J~

lSO

j19

I

I 13

r[[’

1 /

/I

ist

~ L

1l’1

I

I I

I I 0

s I

6of’z

l 81

9’iZ

I

I I

I I

I I

I lZO

’[

Ins

I )5

0’2

[ I

I u

I

I I

Ob(

I I

I is

li

i t5

i I

‘6u

J[

$6/z

l su

o!ld

opy]

z 1-

,,

II

I I

II

II

II

Ilm

I !0

[’8

I 01

9’91

‘U

!OP

V

$6/z

l wo

!~dw

ll i~

l---

----

----

-l-

----

----

----

----

l -l

----

----

----

----

-l"

""

-"--

" --

"-"

-"--

----

----

----

"---

" -"

---"

--

--"

Ql-

----

----

----

----

----

----

----

---.

!.

----

--"

1"~:

"-"-

---

--"

--""

""

l---

---"

i-

-""

----

-"

----

" 1"

-1

I (X

og

( [I

-I

S18V

d ~

~sas

uad

x~

I (;

os

w)

I U

~JP

(!~~

I

a]e~

I

(PV

lo Ja

llen

O JO

j /

Iuao

lsn[

pv

S!ql

1

(fqe

~!l

ddv

)J)

~ (’e

a;:;:

;oc)

~

~ ~

I yl

aq~)

]

(tsl

, 1?

) 6U

\l Jn

3a~.

UO

N

I ~u

no

uy

t d

VH

j I

alet

i d

VH

4 Jo

lu

nO”V$ I

~uno

wv

I pJ

q3ej

)y

I (q

) i~

n(o~

I

saJn

]!pu

adx]

~.-

..........

-.........

-..--

----

----

~ &:

N l--

----

----

----

----

----

----

----

---l

a[qe

]nds

o~

~ aq

snN

~!pn

y I

Ja]J

enj

o~

i I *

I “J

J?N

’1

1 Jo

au

!l

‘H1

6U\U

\?J~

‘g

I

saJn

l!pu

adx3

uo

!~eJ

ls!u

!upv

“j

! a6

?JJA

v ‘j

I

a]ue

ls!s

sy

s]ua

u~ed

’0

1 1V

101

“31

~eJa

paj

“91

alqe

o!ld

d.v

‘vII

I ~

..

..

..

..-.

..

..

..

..

..

..

..

..

..

..

..

..

..

..

..

..

..

..

..

.. .......................................................................................................................................

....

.. -10

I $I

t/31

1~sl

lrov

J1

99t

lfsv

3tf2

Nl

vINM

0411

KI :

31VI

S$

ii31

dVf1

011

-]-A

I uJ

o4

SlN3

HlSf

lfIN

ti

Olb’

d(]

Joda

~ AI

Ja]J

enO

01 q)

e]]v

) 3-

AI31

1!1

OIfIO08

60“O

N9N0

S3

111H

Vj

‘N38

011H

3ON

VHl

flOA

vO

jNO

IIVt

il$I

NIKO

VE’

~-A[

9661‘0[J?q

ga3?

0 96fi

e3-A

l

.

----

----

--

-

I (u

!U

I

0 10

Ill

I

I I

I lbI

II

I I

II 1.

11

,: 10

10

10

10

10

10

10

IsI

10I

1010

II

10

10

!010

10

Il

l <

1’

I

,/:

10

II

*“’

. .

I t9

)’[8

8’l

I ll

L’08

t’[

;...

....

!.!....

....

..

..

!..

.. ..

!!..

!.

!..

..

...

!...

..

...

...

....

...

....

....

....

....

....

...!

....

....

....

....

....

....

..

...

.....

......

...

......!

........

...

!..

!!..........

!....

...

. .

.....

!...

......

....

..

..

1010

10

10

10

I I

16i

/ 10

I

1010

II

10

10

10

10

10

III

/;:

10

I II

10

10

10

10/0$

::

/

11I

/ ...

”..:

;0

10.1

~so~

~mau

oJl

I

10

L!

10

~ly=

\o

I I

9[$’

a tU

INpV

[6/6

m~

]als

od19

I /

I!

10

/ j~

o~p?

l~uo

jl

[

,-~o

10

10

!0s

/ I

W’1

lf’1

“6

1Jf6

/6 U

PJ J

?~50

J]$1

qJI

L

~i~l

~ I

10

J(-)!.’:;9.kl@$j

10”

II +Q

mw

I

~o

10

!1

10

;: 1)

I [:

/ .~

; 10

~s

o~l

1

C,,>

UI$

W

! I

o !0

I 0$

1 9Lt’K8

I ~2

PJ~U

O~ “U

!Mpv

[6

/6 u

o!~d

opvl

(I

H

10

I10

I U

Pj

!0

10

[ LOL’[S

10

t tIt’LOl

I ‘OU!pv)6/9Q

J?~S

Od

S

AP

$~/

~

;;

I /

/ 10

I II

/

10/

;:

10

10.

II

/10

10

10

10

1010

$I

10

/ III

1---

----

----

---

-"--

----

-'--

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

----

---.

----

----

----

----

----

----

----

----

-

]0

[ it$

L 3P

) I

6uIJ

Jno

a!+u

oH

I

juno

mv

I ]0

1 I

dVH

di

a~uj

dvH

JJo

~uno

av$

I Ju

nouv

I

[q)

Um

ill”j

I

sa~n

~!pu

adxa

1...

....

....

....-

....-

....

...-

. -.

.-...

-1

L[q

luot

i 1.

....

....

....

....-

....

...-

....-

-.

-...1

al

qe~n

dwoj

I

]aqm

N~!

pnv

~ Ja

JTo~

~

~ ]0

aul

q O

HI

6UIU

IPIJO

j I

sa~n

~!pu

adxgu

o!~u

~s!u

!apv

OA

I .?

6ela

Av‘3

I

axqs

!ssv

s~

uade

d “~

I NJ(U

“21

[ela

pad

“RI

a[qm

[ddv

“v

i{ I

.....

.....

.....

....

.....

........

...

...

....

.....

....

....

....

....

.--

----

----

....

....

..--

----

----

....

....

....

....

....

....

....

.....

....

...

....

....

...

....

...

....

....

....

...

....

....

....

....

I

I S.lNS’NMIKIV

9NISV3UN1

I-—

VINL+OJIIVJ:a

ws

department of health & human services …principal deputy assistant secretary for children and...

Documents