22.9 Subsidy Review

Georgia State Seal

Georgia Division of Family and Children Services
Child Welfare Policy Manual

Chapter:

(22) Kinship

Policy Title:

Subsidy Review

Policy Number:

22.9

Previous Policy Number(s):

10.9

Effective Date:

September 2020

Manual Transmittal:

2020-06

Codes/References

N/A

Requirements

The Division of Family and Children Services (DFCS) will:

  1. Conduct Subsidy Reviews of the Enhanced Relative Rate (ERR) subsidy on an annual basis following the initiation of ERR payments to determine the child’s continued eligibility for ERR (see policy 22.8 Kinship: Financial and Non-Financial Supports for Children in Foster Care or Who Have Achieved Permanency for eligibility criteria for ERR).

    The annual (12th month) subsidy review is subsidy renewal review that must be completed prior to the end of the 12th month following the initial or most recent approval of ERR.

  2. Conduct a six-month and annual (12-month) Subsidy Review following the initiation of subsidy payments for Subsidized Guardianship (SG), Non-Relative Subsidized Guardianship (NRSG) and Relative Care Subsidy (RCS) to determine the child’s continued eligibility for the subsidy (see policy 22.8 Kinship: Financial and Non-Financial Supports for Children in Foster Care or Who Have Achieved Permanency for eligibility criteria for SG and NRSG).

    1. The six-month subsidy review is a paper review completed prior to the end of the six months from the initial or most recent approval of SG/NRSG/RCS.

      A six-month paper review is not required on ERR cases as a minimum of monthly purposeful contacts are conducted with the child and caregiver.

    2. The annual (12th month) subsidy review is a subsidy renewal review completed prior to the end of the 12th month following the initial or most recent approval of SG/NRSG/RCS.

    While RCS is no longer an option available to relatives as of 01/01/2014, relative caregivers already receiving RCS shall be subject to the required subsidy reviews.

  3. Conduct a home visit as part of the annual Subsidy Review for ERR, SG, NRSG, and RCS. Conduct face to face and in private interviews with the caregiver(s), child (when age and developmentally appropriate) and any other household members present during the home visit.

    The annual subsidy review can be completed via a telephone interview if the caregiver(s) live out-of-state and the Interstate Compact on the Placement of Children (ICPC) request to complete the subsidy review was denied.

  4. Report all suspected or known allegations of child maltreatment identified through the subsidy review process to the CPS Intake Communication Center in accordance with policy 3.24 Intake: Mandated Reporters.

  5. Suspend ERR, SG, NRSG, and RCS payments if the subsidy review is not completed prior to the end of the current approval certification.

  6. Terminate the subsidy if the Subsidy Review determines that eligibility criteria are not met as outlined in policy 22.8 Kinship: Financial and Non-Financial Supports for Children in Foster Care or Who Have Achieved Permanency.

  7. Adhere to confidentiality and Health Insurance Portability and Accountability Act (HIPAA) provisions outlined in policies 2.6 Information Management: Confidentiality/Safeguarding Information and 2.5 Information Management: Health Insurance Portability and Accountability Act (HIPAA). Obtain a signed Authorization for Release of Information (ROI), when applicable.

Procedures

Six-Month Subsidy Review for SG, NRSG or RCS

The Social Services Case Manager (SSCM) will:

  1. Mail, email or fax the Notice of Six-Month Subsidy Review, along with the Subsidy Review form to the caregiver informing them of:

    1. The required completion the Subsidy Review form; and

    2. The timeframe for completion of the form and returning it to DFCS.

  2. Review the completed Subsidy Review form received from the caregiver:

    1. Discuss any changes reported on the Subsidy Review form with the caregiver.

      This may be done via telephone. Contact with the child may also be necessary to verify information reported.

    2. Obtain any needed verification of the child’s income, school verification, and information on new household members reported;

  3. Determine the following:

    1. The caregiver’s capacity to continue to provide for the child’s safety, permanency and well-being; and

    2. The continued eligibility for subsidy payments.

  4. Staff with the Social Services Supervisor (SSS) to determine continued eligibility for the subsidy, and obtain his/her approval of the continued eligibility decision;

  5. If the Subsidy Review form is not received by the 20th day of the 6th month:

    1. Send a letter of non-receipt of the completed Subsidy Review form to the caregiver.

    2. Contact the caregiver by telephone when possible to find out if they received the form and determine whether there are any barriers in completing and returning the form.

    3. In conjunction with the SSS, suspend SG, NRSG, and RCS payments for the 7th month if the review is not received and completed by the end of the 6th month.

  6. Document the review and/or attempts to complete the six-month subsidy review in the Narrative of the Contact Detail page in Georgia SHINES within 72 hours of occurrence. Upload the Subsidy Review form and any other information obtained in External Documentation.

Annual (12-Month) Subsidy Review for ERR, SG, NRSG, and RCS

The SSCM will:

  1. Schedule a home visit with the caregiver(s) and child.

  2. Mail, email or fax the Subsidy Review form to the caregiver for their review and completion prior to the home visit.

  3. Screen the child on the Clearinghouse for any income.

  4. Assess family functioning and the caregiver’s capacity to continue to provide for the child(ren)'s safety, permanency and well-being (see Practice Guidance: Subsidy Review and Renewal Assessment).

    1. Interview the child, caregiver and other household members present at the home visit:

      1. Discuss any changes to the developmental stages of the family including the tasks associated with the stages and the involvement of the family to accomplish these tasks (see policy 19.2 Case Management: Family Developmental Stages and Tasks);

      2. Gain an understanding of any challenges the family/individual is having in accomplishing the tasks;

      3. Evaluate the need for services to assist the family in completing everyday tasks;

      4. Discuss all information included in the Subsidy Review form;

        A portion of the interview with the child must be conducted in private, away from the caregiver and any other household members.

      5. Discuss the Terms and Conditions included in the Enhance Relative Rate Application and Agreement, Subsidized Guardianship/Non-Relative Subsidized Guardianship Application and Agreement, or Relative Care Subsidy Renewal Application and Agreement with all caregivers receiving subsidy payments and obtain their signatures;

      6. If the caregivers are receiving ERR, inform him or her that any new adult household members will need to be screened (see policy 19.8 Case Management: Criminal Records Checks and 19.9 Case Management: Safety Screenings); and

      7. Inform the caregiver that he/she will be notified of the re-approval decision after SSS review of the information gathered.

    2. Complete a walkthrough of the home noting and addressing any safety concerns with the caregiver;

      If there is an infant in the home, discuss and address Infant Safe to Sleep in accordance with Infant Safe to Sleep Guidance and Protocol.

    3. Obtain any needed verification of the child’s income or information on new household members.

    4. Contact collaterals including the school, health care providers, other service providers and other relevant parties to obtain/verify information. An Authorization for Release of Information form must be signed by the caregiver before any contact is made with collaterals.

    If based on the Subsidy Review, there is suspected or known child abuse, report to CICC in accordance with policy 3.24 Intake: Mandated Reporters.

  5. Staff with the SSS to obtain a re-approval decision. The discussion should include, but is not limited to the following:

    1. The safety of the home environment;

    2. Any changes in household composition, developmental stages of the family, daily tasks and challenges associated with the developmental stages, income, well-being needs and/or visitation with the parents;

    3. Collateral information obtained;

    4. Decision to reapprove the ERR, SG, NRSG, and RCS payments for another 12 months.

    5. Document the staffing discussion and re-approval decision in the Narrative section of the Contact Detail page in Georgia SHINES within 72 hours of the staffing.

  6. Notify the caregiver of the decision regarding the re-approval of ERR, SG, NRSG or RCS payments;

  7. Send a copy of the approved ERR, SG, NRSG or RCS Renewal Application and Agreement to the caregiver;

  8. Complete a new Payment of Care (POC) in Georgia SHINES;

    A new POC must be completed every 12 months. Upload the Subsidy Review form and ERR, RCS Renewal or SG/NRSG Application and Agreement into External Documentation in Georgia SHINES;

  9. Suspend payments until the renewal process can be completed if the SSCM is unable to contact the caregiver prior to the expiration of the current ERR/RCS/SG/NRSG approval period.

Out-of-County Annual Subsidy Review

Utilize one of the options below to complete the annual subsidy review, if the caregiver resides out-of-county:

  1. Contact the DFCS County Director/designee where the caregiver resides to request permission to cross county lines and complete the ERR, SG, NRSG or RCS renewal process; or

  2. Request that the local DFCS office where the caregiver resides complete the ERR/RCS/SG/NRSG renewal process. If the receiving county decides that they are unable to complete the renewal process, approval may be granted to the legal county of the child to complete the renewal.

Out-of-State Annual Subsidy Review

  1. Contact the caregiver to notify them of the need for renewal of the ERR, SG, NRSG, or RCS payments and that payments will be suspended if the renewal process is not completed timely.

  2. Mail, email or fax the letter of notification of the subsidy review, Subsidy Review form, and the ERR, RCS Renewal or SG/NRSG Application and Agreement to the caregiver.

  3. Make an ICPC request to conduct a home visit to interview the caregiver, the child and any other household members present. Include the following in your request:

    1. ICPC Request-Form 100A;

    2. ICPC Request Letter;

    3. ERR, RCS Renewal or SG/NRSG Application and Agreement.

  4. Inform the other state that if the renewal process is not completed timely, the ERR/RCS/SG/NRSG payments will be suspended;

If the ICPC denies the request to conduct the review, complete the annual subsidy review via telephone.

The SSS will:

  1. Review and make an approval determination on the following, as appropriate:

    1. Subsidy Review form;

    2. Enhanced Relative Rate Application and Agreement;

    3. Relative Care Subsidy Renewal Application and Agreement;

    4. Subsidized Guardianship/Non-Relative Subsidized Guardianship Application and Agreement.

  2. Initiate a staffing with the SSCM when the following occurs:

    1. The outcome of the subsidy review to make an approval decision on continuation of the subsidy.

    2. Changes in the caregiver household circumstances including:

      1. Any impact the changes have on child safety and/or eligibility for the subsidy;

      2. Whether the subsidy needs to be suspended or terminated;

      3. Any additional information that is needed;

      4. Next steps with the family or case.

    3. Reinstatement of suspended or terminated subsidies is requested.

  3. Ensure the SSCM provides appropriate notifications including written notification to:

    1. The caregiver prior to any suspension or termination of the subsidy;

    2. Regional Accounting regarding the suspension, termination or renewal of any subsidy.

  4. Review Georgia SHINES to ensure all pertinent subsidy forms and documentation is completed, updated and uploaded.

Practice Guidance

Subsidy Review and Renewal Assessment

Subsidy reviews are conducted to ensure the child and caregiver continue to meet the eligibility criteria to receive a subsidy payment as well as to determine whether the caregiver continues to be qualified to provide care for the child. During the subsidy review process, observation and/or an understanding of the family’s involvement in completing the everyday tasks is essential in providing insight into the family’s parenting practices, strengths and areas for continued caregiver development. The subsidy review process also provides the opportunity to determine whether the family may have additional needs through which offering community supports may be critical to maintain and stabilize the home and consequently prevent re-entry of the child into foster care.

When assessing the caregiver to determine whether they continue to be qualified to provide care for the child, parental capacity and child vulnerabilities must be assessed to assure the child’s safety, permanency and well-being. Also determine the following:

  1. What are the current developmental stages of the family?

  2. What tasks are associated with the developmental stages, i.e. waking to feed an infant; getting children off to school; disciplining teenagers; etc., and what is the involvement of the family in completing the tasks?

  3. What are the challenges the family is having in meeting the daily tasks? Are there competing needs within the family, impacting the caregiver’s ability to continue to provide appropriate care for the child?

  4. How are the child(ren)'s health and medical needs being met?

  5. How are the child(ren)'s emotional needs being met?

  6. How are the child(ren)'s educational needs being met?

  7. What services have the caregiver sought for the child when there are identified needs? What services are needed to ensure daily tasks are completed?

  8. Who cares for the child in the caregiver’s absence?

  9. Describe how the child is thriving in the care of the caregiver.

  10. Is the living environment safe? Are there immediate threats of harm or impending dangers?

  11. Does the caregiver continue to meet eligibility requirements for ERR, RCS, SG or NRSG?

  12. What information was provided by collateral contacts (health provider, school officials, etc.) regarding child vulnerabilities and parental capacity?

Forms and Tools

Authorization for Release of Information
Authorization for Release of Information (Spanish)
Enhanced Relative Rate Application and Agreement
Enhanced Relative Rate Application and Agreement (Spanish)
ICPC Cover Letter for Subsidy Reviews
Infant Safe to Sleep Guidelines and Protocol
Notice of Six-Month Subsidy Review
Notice of Six-Month Subsidy Review (Spanish)
Notice of Annual (12-Month) Subsidy Review
Notice of Annual (12-Month) Subsidy Review (Spanish)
Relative Care Subsidy Renewal Application and Agreement
Relative Care Subsidy Renewal Application and Agreement (Spanish)
Subsidized Guardianship/Non-Relative Subsidized Guardianship Application and Agreement
Subsidized Guardianship/Non-Relative Subsidized Guardianship Application and Agreement (Spanish)
Subsidy Review
Subsidy Review (Spanish)