Question: Do We Have to Maintain a Separate Record for Eligibility Documentation Outside of SACWIS?

Question:  After reviewing transmittal letter 205 (dated 9/25/07), the rule for case record requirements for FCM (OAC 5010:2-47-09) still states that "the Title IV-E agency is required to maintain a separate record for eligibility documentation, and it is to be contained in a file outside of the child's case record. Included in the record is a completed JFS 1452 and/or JFS 12452A."

I am concerned that we are unable to print the eligibility documentation out of SACWIS. I was told that the eligibility documentation was not required since it is all housed in SACWIS.  So, what I was verbally told is not what the rule specifically states.  Do we still have to maintain a separate record for eligibility documentation outside of SACWIS?

 

Answer:  (From OCF FCM Policy) OAC 5101:2-47-09 (effective 8/19/2011) does require all title IV-E agencies to maintain a separate IV-E Case Record file for all children determined to be IV-E FCM eligible. All documentation to support the eligibility determination will need to be contained in the FCM IV-E case record file. All JFS 01452, JFS 01452A, or a copy of the eligibility determination screen prints from SACWIS or the screen prints of any redetermination of continued eligibility done in SACWIS prior to April 1, 2010 need to be maintained in the IV-E case record file.

OCF FCM policy is working with SACWIS to develop a form or report of the FCM eligibility for each child. Keep in mind the file is requested frequently for auditing purposes, and there are many auditors such as ORAA, Federal Reviews, OIG, Auditors of State and State reviews. We suggest printing the Financial Screens for FCM eligibility and reimbursability along with the detail screens. A copy of all court orders and complaints as identified in OAC 5101:2-47-09 must also be maintained in the FCM file.