The Casebook Blog

On June 2, 2016, the Administration for Children and Families (ACF) issued a final Comprehensive Child Welfare Information System (CCWIS) rule to replace the Statewide and Tribal Automated Child Welfare Information Systems (S/TACWIS) rule, which for more than twenty years had been the vehicle through which states sought federal assistance for funding child welfare technology efforts. This brief provides our analysis of the final rule and its implications for states and tribes seeking to modernize their technology portfolios. Note: States should consult with ACF regarding definitive interpretations of the rule. CCWIS as a Force for Innovation A key purpose of the CCWIS rule is to specify how states and tribes may obtain federal financial participation (FFP) for a CCWIS project. As with S/TACWIS, ACF determines CCWIS compliance through review and approval of a state’s or tribe’s Advance Planning Document (APD) or a Notice of Intent (for projects below the APD threshold), as well as through periodic federal monitoring. The rule does not change the APD process or the FFP rate, which remains at 50% of project costs. CCWIS, like its predecessor, is optional for states and tribes. The nature of what qualifies as a “project,” however, has changed significantly with CCWIS. Under the old S/TACWIS rules, FFP was only available to a state or tribe that developed and operated a single, large system that all public and private child welfare workers used. Moreover, ACF mandated fifty-one distinct functions that any such monolithic S/TACWIS system had to support. Under the new CCWIS rule, ACF does not specify such functional requirements. Instead, IV-E agencies are encouraged to innovate in keeping with their individual needs and practices. For example, states and tribes may obtain FFP to build smaller, more modular subsets of functionality aligned with their practice models, or perhaps with an incremental legacy system replacement plan. They might choose to obtain certain types of data through automated integrations rather than collect it within the child welfare application itself. From an implementation perspective, they might opt for a project approach based on modern Agile software development techniques, as California and other states have done. The states’ early responses to CCWIS—as embodied in procurements issued around the time the final rule was released—have already shown an eagerness to experiment with such new approaches. On June 2, 2016, the Administration for Children and Families (ACF) issued a final Comprehensive Child Welfare Information System (CCWIS) rule to replace the Statewide and Tribal Automated Child Welfare Information Systems (S/TACWIS) rule, which for more than twenty years had been the vehicle through which states sought federal assistance for funding child welfare technology efforts. This brief provides our analysis of the final rule and its implications for states and tribes seeking to modernize their technology portfolios. Note: States should consult with ACF regarding definitive interpretations of the rule. CCWIS as a Force for Innovation A key purpose of the CCWIS rule is to specify how states and tribes may obtain federal financial participation (FFP) for a CCWIS project. As with S/TACWIS, ACF determines CCWIS compliance through review and approval of a state’s or tribe’s Advance Planning Document (APD) or a Notice of Intent (for projects below the APD threshold), as well as through periodic federal monitoring. The rule does not change the APD process or the FFP rate, which remains at 50% of project costs. CCWIS, like its predecessor, is optional for states and tribes. The nature of what qualifies as a “project,” however, has changed significantly with CCWIS. Under the old S/TACWIS rules, FFP was only available to a state or tribe that developed and operated a single, large system that all public and private child welfare workers used. Moreover, ACF mandated fifty-one distinct functions that any such monolithic S/TACWIS system had to support. Under the new CCWIS rule, ACF does not specify such functional requirements. Instead, IV-E agencies are encouraged to innovate in keeping with their individual needs and practices. For example, states and tribes may obtain FFP to build smaller, more modular subsets of functionality aligned with their practice models, or perhaps with an incremental legacy system replacement plan. They might choose to obtain certain types of data through automated integrations rather than collect it within the child welfare application itself. From an implementation perspective, they might opt for a project approach based on modern Agile software development techniques, as California and other states have done. The states’ early responses to CCWIS—as embodied in procurements issued around the time the final rule was released—have already shown an eagerness to experiment with such new approaches. On June 2, 2016, the Administration for Children and Families (ACF) issued a final Comprehensive Child Welfare Information System (CCWIS) rule to replace the Statewide and Tribal Automated Child Welfare Information Systems (S/TACWIS) rule, which for more than twenty years had been the vehicle through which states sought federal assistance for funding child welfare technology efforts. This brief provides our analysis of the final rule and its implications for states and tribes seeking to modernize their technology portfolios. Note: States should consult with ACF regarding definitive interpretations of the rule. CCWIS as a Force for Innovation A key purpose of the CCWIS rule is to specify how states and tribes may obtain federal financial participation (FFP) for a CCWIS project. As with S/TACWIS, ACF determines CCWIS compliance through review and approval of a state’s or tribe’s Advance Planning Document (APD) or a Notice of Intent (for projects below the APD threshold), as well as through periodic federal monitoring. The rule does not change the APD process or the FFP rate, which remains at 50% of project costs. CCWIS, like its predecessor, is optional for states and tribes. The nature of what qualifies as a “project,” however, has changed significantly with CCWIS. Under the old S/TACWIS rules, FFP was only available to a state or tribe that developed and operated a single, large system that all public and private child welfare workers used. Moreover, ACF mandated fifty-one distinct functions that any such monolithic S/TACWIS system had to support. Under the new CCWIS rule, ACF does not specify such functional requirements. Instead, IV-E agencies are encouraged to innovate in keeping with their individual needs and practices. For example, states and tribes may obtain FFP to build smaller, more modular subsets of functionality aligned with their practice models, or perhaps with an incremental legacy system replacement plan. They might choose to obtain certain types of data through automated integrations rather than collect it within the child welfare application itself. From an implementation perspective, they might opt for a project approach based on modern Agile software development techniques, as California and other states have done. The states’ early responses to CCWIS—as embodied in procurements issued around the time the final rule was released—have already shown an eagerness to experiment with such new approaches. On June 2, 2016, the Administration for Children and Families (ACF) issued a final Comprehensive Child Welfare Information System (CCWIS) rule to replace the Statewide and Tribal Automated Child Welfare Information Systems (S/TACWIS) rule, which for more than twenty years had been the vehicle through which states sought federal assistance for funding child welfare technology efforts. This brief provides our analysis of the final rule and its implications for states and tribes seeking to modernize their technology portfolios. Note: States should consult with ACF regarding definitive interpretations of the rule. CCWIS as a Force for Innovation A key purpose of the CCWIS rule is to specify how states and tribes may obtain federal financial participation (FFP) for a CCWIS project. As with S/TACWIS, ACF determines CCWIS compliance through review and approval of a state’s or tribe’s Advance Planning Document (APD) or a Notice of Intent (for projects below the APD threshold), as well as through periodic federal monitoring. The rule does not change the APD process or the FFP rate, which remains at 50% of project costs. CCWIS, like its predecessor, is optional for states and tribes. The nature of what qualifies as a “project,” however, has changed significantly with CCWIS. Under the old S/TACWIS rules, FFP was only available to a state or tribe that developed and operated a single, large system that all public and private child welfare workers used. Moreover, ACF mandated fifty-one distinct functions that any such monolithic S/TACWIS system had to support. Under the new CCWIS rule, ACF does not specify such functional requirements. Instead, IV-E agencies are encouraged to innovate in keeping with their individual needs and practices. For example, states and tribes may obtain FFP to build smaller, more modular subsets of functionality aligned with their practice models, or perhaps with an incremental legacy system replacement plan. They might choose to obtain certain types of data through automated integrations rather than collect it within the child welfare application itself. From an implementation perspective, they might opt for a project approach based on modern Agile software development techniques, as California and other states have done. The states’ early responses to CCWIS—as embodied in procurements issued around the time the final rule was released—have already shown an eagerness to experiment with such new approaches. On June 2, 2016, the Administration for Children and Families (ACF) issued a final Comprehensive Child Welfare Information System (CCWIS) rule to replace the Statewide and Tribal Automated Child Welfare Information Systems (S/TACWIS) rule, which for more than twenty years had been the vehicle through which states sought federal assistance for funding child welfare technology efforts. This brief provides our analysis of the final rule and its implications for states and tribes seeking to modernize their technology portfolios. Note: States should consult with ACF regarding definitive interpretations of the rule. CCWIS as a Force for Innovation A key purpose of the CCWIS rule is to specify how states and tribes may obtain federal financial participation (FFP) for a CCWIS project. As with S/TACWIS, ACF determines CCWIS compliance through review and approval of a state’s or tribe’s Advance Planning Document (APD) or a Notice of Intent (for projects below the APD threshold), as well as through periodic federal monitoring. The rule does not change the APD process or the FFP rate, which remains at 50% of project costs. CCWIS, like its predecessor, is optional for states and tribes. The nature of what qualifies as a “project,” however, has changed significantly with CCWIS. Under the old S/TACWIS rules, FFP was only available to a state or tribe that developed and operated a single, large system that all public and private child welfare workers used. Moreover, ACF mandated fifty-one distinct functions that any such monolithic S/TACWIS system had to support. Under the new CCWIS rule, ACF does not specify such functional requirements. Instead, IV-E agencies are encouraged to innovate in keeping with their individual needs and practices. For example, states and tribes may obtain FFP to build smaller, more modular subsets of functionality aligned with their practice models, or perhaps with an incremental legacy system replacement plan. They might choose to obtain certain types of data through automated integrations rather than collect it within the child welfare application itself. From an implementation perspective, they might opt for a project approach based on modern Agile software development techniques, as California and other states have done. The states’ early responses to CCWIS—as embodied in procurements issued around the time the final rule was released—have already shown an eagerness to experiment with such new approaches. On June 2, 2016, the Administration for Children and Families (ACF) issued a final Comprehensive Child Welfare Information System (CCWIS) rule to replace the Statewide and Tribal Automated Child Welfare Information Systems (S/TACWIS) rule, which for more than twenty years had been the vehicle through which states sought federal assistance for funding child welfare technology efforts. This brief provides our analysis of the final rule and its implications for states and tribes seeking to modernize their technology portfolios. Note: States should consult with ACF regarding definitive interpretations of the rule. CCWIS as a Force for Innovation A key purpose of the CCWIS rule is to specify how states and tribes may obtain federal financial participation (FFP) for a CCWIS project. As with S/TACWIS, ACF determines CCWIS compliance through review and approval of a state’s or tribe’s Advance Planning Document (APD) or a Notice of Intent (for projects below the APD threshold), as well as through periodic federal monitoring. The rule does not change the APD process or the FFP rate, which remains at 50% of project costs. CCWIS, like its predecessor, is optional for states and tribes. The nature of what qualifies as a “project,” however, has changed significantly with CCWIS. Under the old S/TACWIS rules, FFP was only available to a state or tribe that developed and operated a single, large system that all public and private child welfare workers used. Moreover, ACF mandated fifty-one distinct functions that any such monolithic S/TACWIS system had to support. Under the new CCWIS rule, ACF does not specify such functional requirements. Instead, IV-E agencies are encouraged to innovate in keeping with their individual needs and practices. For example, states and tribes may obtain FFP to build smaller, more modular subsets of functionality aligned with their practice models, or perhaps with an incremental legacy system replacement plan. They might choose to obtain certain types of data through automated integrations rather than collect it within the child welfare application itself. From an implementation perspective, they might opt for a project approach based on modern Agile software development techniques, as California and other states have done. The states’ early responses to CCWIS—as embodied in procurements issued around the time the final rule was released—have already shown an eagerness to experiment with such new approaches. On June 2, 2016, the Administration for Children and Families (ACF) issued a final Comprehensive Child Welfare Information System (CCWIS) rule to replace the Statewide and Tribal Automated Child Welfare Information Systems (S/TACWIS) rule, which for more than twenty years had been the vehicle through which states sought federal assistance for funding child welfare technology efforts. This brief provides our analysis of the final rule and its implications for states and tribes seeking to modernize their technology portfolios. Note: States should consult with ACF regarding definitive interpretations of the rule. CCWIS as a Force for Innovation A key purpose of the CCWIS rule is to specify how states and tribes may obtain federal financial participation (FFP) for a CCWIS project. As with S/TACWIS, ACF determines CCWIS compliance through review and approval of a state’s or tribe’s Advance Planning Document (APD) or a Notice of Intent (for projects below the APD threshold), as well as through periodic federal monitoring. The rule does not change the APD process or the FFP rate, which remains at 50% of project costs. CCWIS, like its predecessor, is optional for states and tribes. The nature of what qualifies as a “project,” however, has changed significantly with CCWIS. Under the old S/TACWIS rules, FFP was only available to a state or tribe that developed and operated a single, large system that all public and private child welfare workers used. Moreover, ACF mandated fifty-one distinct functions that any such monolithic S/TACWIS system had to support. Under the new CCWIS rule, ACF does not specify such functional requirements. Instead, IV-E agencies are encouraged to innovate in keeping with their individual needs and practices. For example, states and tribes may obtain FFP to build smaller, more modular subsets of functionality aligned with their practice models, or perhaps with an incremental legacy system replacement plan. They might choose to obtain certain types of data through automated integrations rather than collect it within the child welfare application itself. From an implementation perspective, they might opt for a project approach based on modern Agile software development techniques, as California and other states have done. The states’ early responses to CCWIS—as embodied in procurements issued around the time the final rule was released—have already shown an eagerness to experiment with such new approaches. On June 2, 2016, the Administration for Children and Families (ACF) issued a final Comprehensive Child Welfare Information System (CCWIS) rule to replace the Statewide and Tribal Automated Child Welfare Information Systems (S/TACWIS) rule, which for more than twenty years had been the vehicle through which states sought federal assistance for funding child welfare technology efforts. This brief provides our analysis of the final rule and its implications for states and tribes seeking to modernize their technology portfolios. Note: States should consult with ACF regarding definitive interpretations of the rule. CCWIS as a Force for Innovation A key purpose of the CCWIS rule is to specify how states and tribes may obtain federal financial participation (FFP) for a CCWIS project. As with S/TACWIS, ACF determines CCWIS compliance through review and approval of a state’s or tribe’s Advance Planning Document (APD) or a Notice of Intent (for projects below the APD threshold), as well as through periodic federal monitoring. The rule does not change the APD process or the FFP rate, which remains at 50% of project costs. CCWIS, like its predecessor, is optional for states and tribes. The nature of what qualifies as a “project,” however, has changed significantly with CCWIS. Under the old S/TACWIS rules, FFP was only available to a state or tribe that developed and operated a single, large system that all public and private child welfare workers used. Moreover, ACF mandated fifty-one distinct functions that any such monolithic S/TACWIS system had to support. Under the new CCWIS rule, ACF does not specify such functional requirements. Instead, IV-E agencies are encouraged to innovate in keeping with their individual needs and practices. For example, states and tribes may obtain FFP to build smaller, more modular subsets of functionality aligned with their practice models, or perhaps with an incremental legacy system replacement plan. They might choose to obtain certain types of data through automated integrations rather than collect it within the child welfare application itself. From an implementation perspective, they might opt for a project approach based on modern Agile software development techniques, as California and other states have done. The states’ early responses to CCWIS—as embodied in procurements issued around the time the final rule was released—have already shown an eagerness to experiment with such new approaches. On June 2, 2016, the Administration for Children and Families (ACF) issued a final Comprehensive Child Welfare Information System (CCWIS) rule to replace the Statewide and Tribal Automated Child Welfare Information Systems (S/TACWIS) rule, which for more than twenty years had been the vehicle through which states sought federal assistance for funding child welfare technology efforts. This brief provides our analysis of the final rule and its implications for states and tribes seeking to modernize their technology portfolios. Note: States should consult with ACF regarding definitive interpretations of the rule. CCWIS as a Force for Innovation A key purpose of the CCWIS rule is to specify how states and tribes may obtain federal financial participation (FFP) for a CCWIS project. As with S/TACWIS, ACF determines CCWIS compliance through review and approval of a state’s or tribe’s Advance Planning Document (APD) or a Notice of Intent (for projects below the APD threshold), as well as through periodic federal monitoring. The rule does not change the APD process or the FFP rate, which remains at 50% of project costs. CCWIS, like its predecessor, is optional for states and tribes. The nature of what qualifies as a “project,” however, has changed significantly with CCWIS. Under the old S/TACWIS rules, FFP was only available to a state or tribe that developed and operated a single, large system that all public and private child welfare workers used. Moreover, ACF mandated fifty-one distinct functions that any such monolithic S/TACWIS system had to support. Under the new CCWIS rule, ACF does not specify such functional requirements. Instead, IV-E agencies are encouraged to innovate in keeping with their individual needs and practices. For example, states and tribes may obtain FFP to build smaller, more modular subsets of functionality aligned with their practice models, or perhaps with an incremental legacy system replacement plan. They might choose to obtain certain types of data through automated integrations rather than collect it within the child welfare application itself. From an implementation perspective, they might opt for a project approach based on modern Agile software development techniques, as California and other states have done. The states’ early responses to CCWIS—as embodied in procurements issued around the time the final rule was released—have already shown an eagerness to experiment with such new approaches. On June 2, 2016, the Administration for Children and Families (ACF) issued a final Comprehensive Child Welfare Information System (CCWIS) rule to replace the Statewide and Tribal Automated Child Welfare Information Systems (S/TACWIS) rule, which for more than twenty years had been the vehicle through which states sought federal assistance for funding child welfare technology efforts. This brief provides our analysis of the final rule and its implications for states and tribes seeking to modernize their technology portfolios. Note: States should consult with ACF regarding definitive interpretations of the rule. CCWIS as a Force for Innovation A key purpose of the CCWIS rule is to specify how states and tribes may obtain federal financial participation (FFP) for a CCWIS project. As with S/TACWIS, ACF determines CCWIS compliance through review and approval of a state’s or tribe’s Advance Planning Document (APD) or a Notice of Intent (for projects below the APD threshold), as well as through periodic federal monitoring. The rule does not change the APD process or the FFP rate, which remains at 50% of project costs. CCWIS, like its predecessor, is optional for states and tribes. The nature of what qualifies as a “project,” however, has changed significantly with CCWIS. Under the old S/TACWIS rules, FFP was only available to a state or tribe that developed and operated a single, large system that all public and private child welfare workers used. Moreover, ACF mandated fifty-one distinct functions that any such monolithic S/TACWIS system had to support. Under the new CCWIS rule, ACF does not specify such functional requirements. Instead, IV-E agencies are encouraged to innovate in keeping with their individual needs and practices. For example, states and tribes may obtain FFP to build smaller, more modular subsets of functionality aligned with their practice models, or perhaps with an incremental legacy system replacement plan. They might choose to obtain certain types of data through automated integrations rather than collect it within the child welfare application itself. From an implementation perspective, they might opt for a project approach based on modern Agile software development techniques, as California and other states have done. The states’ early responses to CCWIS—as embodied in procurements issued around the time the final rule was released—have already shown an eagerness to experiment with such new approaches.