Re-entry to Foster Care

In certain situations, AAP youths who were receiving extended AAP benefits after their 18th birthday but before reaching 21, may request to re-enter EFC as NMD. Refer to Foster Care Re-entry for Kin-GAP and AAP Youth.

Adoption Assistance Program Monitoring

The W&I Code Sections 10605(c)(1) authorizes the CDSS to conduct reviews in order to meet its oversight obligation to monitor AAP activities to ensure compliance with federal requirements.

Federal enforcement of regulations for non-compliance puts the state and counties at risk for significant penalties and/or loss of federal financial participation funds. In accordance with 45-CFR 92.43, the following action may be taken for non-compliance:

Withhold cash payments pending correct of deficiency.
Disallow all or part of the activity not in compliance.
Wholly or partly suspend or terminate the current award for the program.
Withhold further awards for the program.
Take other remedies that may be legally available.

Monitoring is the first step toward ensuring compliance with federal and state regulations. The monitoring will also prepare the AAP eligibility and AAP SW file so that they are better prepared in the event of an audit and the risk of non-compliance.

Over a two year period, on site monitoring of AAP will be conducted in all 58 counties starting spring 2014. Counties with case loads of 500 or more will be monitored annually. For County of Santa Clara 20 cases will be randomly selected and two additional cases for over sampling for a total of 22 cases. Cases selected must be open as of October 2009, currently active and receiving federal AAP benefits.

During the on-site monitoring AAP eligibility cases files and adoption SW case files including confidential AAP files will be reviewed.
The major milestone of the monitoring process will consist of the following activities:

Monitoring Time Lines	CDSS Action
30 days prior to monitoring,	Initial contact with the county. Counties must send a list of open federal AAP cases as requested.
15 days prior to monitoring,	Provides list of cases to be reviewed.
Monitoring,	On site monitoring with entrance and exit meetings.
15 days after monitoring.	Feedback with written findings.
45 days after monitoring	When applicable, counties must provide a Corrective Action Plan (CAP).

Note: The monitoring time lines are subject to change at the discretion of CDSS to allow for flexibility when providing feedback and to allow time or completing the CAP.

Case File Content to be Monitored

Federally funded AAP cases opened on or after October 2009 are subject to monitoring. The AAP monitoring process focuses primarily on eligibility; however, all facts of administering AAP cases are subject to monitoring. At the minimum the following documents will be reviewed:

“Federal Eligibility Certification for Adoption Assistance Program” (FC 8),
“Eligibility Certification Adoption Assistance Program” (AAP 4),
“Adoption Assistance Program Negotiated Benefits Amount and Approval” (AAP 6),
“Payment Instructions Adoption Assistant Program” (AAP 2),
“Adoption Assistance Program Non Recurring Adoption Expenses Agreement” (AAP 8), and
“APP Notice of Action” form (NA 791) sent to the adoptive parents.

During the monitoring CDSS will review the adoption SW file and the eligibility file separately. The form versions will be checked to ensure outdated forms are not being used. Additionally, signatures and dates on the forms must be present.

Note: It is important to note that CDSS will monitor the adoption SW file and the eligibility file separately to ensure all documents sent from the adoption SW file to the eligibility file are the same and vice versa.

Electronic Files

Counties with electronic cases must make available a computer with printing capability for the AAP monitor to use, however, the AAP monitor may request copies of documents. The forms must show the copies were signed by hand, electronic signatures are not acceptable. Files must be stored in a designated area and made available for review.

Corrective Action Plan (CAP)

At the conclusion of the visit CDSS will meet with county staff to discuss findings, concerns, and address any questions. The findings report will be distributed to the county within 15 calendars days of the exit meeting.

When a CAP is requested, the counties must complete it in 30 calendar days following the receipt of the findings to ensure the CAP is received by CDSS within 45 days. When the county cannot comply to the 30 days, an extension may be requested and must be submitted in writing to CDSS.

When a CAP is required, CDSS will follow-up at the next AAP monitoring visit and review cases that required correction to ensure the CAP is implemented.

AAP Monitoring Details

The AAP monitoring manual and the AAP monitoring assignments can be located at the following website: