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Every federal requirement, verified as it happens

Case notes and placement records stay in the state’s case-management system. This record is the proof beside them.

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Part 5 of 5 · The Foster Care Compliance Gap

Every requirement, verified as it happens
What the auditors said was missing

Walk me through it · about three minutes

Five requirements. What states do today, and what verified looks like.

11

federal requirements, each an event with a date

4

facts per visit: which child, where, when, by whom

Same day

a missed check-in reaches the agency, not at the next visit

Five requirements, what states do today against each, and the record made at the moment it happens.

The record, as it is made

Foster Care Compliance System on a phone: foster child 718 enrolled on case #97654 and linked to foster parent 986, the enrollment photograph held as an encrypted template

Identity enrolledA real-time photo ties the child to the record.

Foster Care Compliance System on a phone: a foster parent's check-in, photo accepted for child 718 and child 310, location verified at the placement address on 9/10/25 at 5:39 PM

Presence capturedBiometric photo and GPS at the caregiver’s home.

Foster Care Compliance System on a phone: caseworker #956's monthly visit to child 718, with which child, where, when and who all verified

Visit verifiedWhich child, where, when, by whom, appended at the door.

Illustrative screens of the system as designed.

Every federal requirement

Verified as it happens.

  1. Missing child: 24-hour report42 U.S.C. §671(a)(35)(B)
    What states do todayManual, self-reported, reconstructed after the fact. OIG estimates 69% of missing-child episodes were not reported to NCMEC as required.
    Foster Care Compliance System, as designedA failed check-in flagged to the agency the same day, with a time-stamped record.
  2. Communication through recoveryP.L. 117-348 §137
    What states do todayNo standard mechanism for demonstrating continuous contact.
    Foster Care Compliance System, as designedA dated communication log per episode, not a single filed report.
  3. Monthly caseworker visitsSSA §§422(b)(17), 424(f) · 95% of required visits
    What states do todayCaseworker-entered records. Reported compliance 47 to 99% in FFY2012.
    Foster Care Compliance System, as designedDate-, time- and GPS-verified check-ins that establish the visit occurred, and where.
  4. Checks before placement42 U.S.C. §671(a)(20) · fingerprints for the parents, registry checks for every adult in the home
    What states do todayRescreened from scratch per placement, funded by a patchwork of state, county and applicant dollars.
    Foster Care Compliance System, as designedIdentity verified once and reused across placements and agencies; each agency decides which checks it accepts.
  5. Every IV-E claim45 CFR §1356.71 · licensed placement, eligible period
    What states do todayDocumentation assembled retrospectively for audit. No full national error rate since FY2020.
    Foster Care Compliance System, as designedContemporaneous, per-claim evidence of licensing and eligibility.

Capabilities are FComply’s description of the system as designed; the Foster Care Compliance System is an active concept that FComply is building with developers and investors. CCWIS modernized how caseworker entries are recorded; it did not create independent verification that the recorded event happened.

The five requirements, side by side, as first written
Federal requirement What states do today Foster Care Compliance System, as designed
Report a missing child within 24 hours
42 U.S.C. §671(a)(35)(B)
Manual, self-reported, retrospectively reconstructed. OIG estimates 69% of missing-child episodes were not reported to NCMEC as required. A failed check-in flagged to the agency the same day, with a time-stamped record.
Ongoing communication through recovery
P.L. 117-348 §137
No standard mechanism for demonstrating continuous contact. A dated communication log per episode, not a single filed report.
Monthly caseworker visits, 95% of required visits
SSA §§422(b)(17), 424(f)
Caseworker-entered records. Reported compliance 47 to 99% in FFY2012. Date- and time-stamped, GPS-verified check-ins that independently establish that the visit occurred, and where.
Checks of the parents and every adult in the home before approval
42 U.S.C. §671(a)(20)
Rescreened from scratch per placement, funded by a patchwork of state, county and applicant dollars. Identity verified once and reused across placements and agencies; each agency decides which checks it accepts.
Licensed placement and eligible period for every IV-E claim
45 CFR §1356.71
Documentation assembled retrospectively for audit. No full national error rate since FY2020. Contemporaneous, per-claim evidence of licensing and eligibility.

When a child cannot be produced

An illustrative Foster Care Compliance System screen on a phone: a supervisor's exception on case #97654, child 310 not shown, with both statutory reports ready to file

The exception, the same dayFComply says a missed check-in reaches a supervisor the same day, so staff can follow up without waiting for the next visit. The 24-hour report runs from when the agency receives information that a child is missing.

Foster Care Compliance System on a phone: child 310 located, both reports filed inside the 24-hour window and the exception closed

Resolved, with the record keptBoth statutory reports, the photograph and the description, one tap each.

Illustrative screens of the system as designed.

Avoided disallowances, litigation exposure that turns on proof, and one identity verified once instead of at every placement.

40

rise in per-child administrative cost in four years while the number of children served fell

5

years since the last full national foster-care improper-payment estimate (FY2020)

1

verified identity, designed to be reused across placements to lower total screening cost
What verification is worth, as first written

Disallowances and withholdings can run to hundreds of thousands of dollars in a single state review; litigation and consent-decree exposure turns on whether the state can prove it did what was required; per-child administrative cost rose 40% in four years while the number of children served fell; and verifying identity once, then reusing it, is designed to lower total screening cost. No validated dollar figure for avoided cost exists yet, because the federal government has not fully measured the improper-payment rate this would reduce since FY2020. Every cost above is currently paid, recurring and documented, and each traces to an evidentiary failure rather than a policy disagreement. A pilot with agreed baseline measures is the way to produce the number; how it would roll out and the return set out the clock and the ledger.

The visit is the record
The auditor reads what happened, when

  • HHS/ACF Children’s Bureau, AFCARS Dashboard, preliminary FFY2025 estimates as of February 27, 2026.
  • HHS OIG A-07-21-06102 (March 2023) and A-07-21-06104 (May 2023); A-03-06-00564 (2007); PIIA compliance reviews FY2021 (A-17-22-52000) through FY2025 (OAS-26-17-042, August 2026); HHS Annual Performance Plans (national foster care error rates to FY2020).
  • GAO-03-357 and GAO-03-809 (2003); GAO-12-312 (March 2012); Comprehensive Child Welfare Information System final rule, 81 FR 35449 (June 2, 2016).
  • NCMEC, Missing from Care; Senate testimony of Dr. Samantha Sahl, NCMEC, on Georgia.
  • ACF monthly caseworker visit standards and federal data; P.L. 118-258 §112(d) (January 4, 2025), which repealed the 50% in-residence visit rule and the related funding penalties from October 1, 2025; Congressional Research Service, R41860, Table G-1 (October 2014), from ACF data; Missouri Department of Social Services CFSR data, FFY2008; ACF West Virginia Title IV-E primary review, 2024.

Held off this page: the fee policies of Maine, Rhode Island, New York and Mississippi, whose published fees concern child-care licensing rather than foster care. The turnover cost and the paperwork hours, once held, are now traced to a Texas Sunset Commission report and a federal OPRE study. Corrections to info@fcomply.com.