Is it allowable to utilize Title IV-E funding for programs currently being county and locally funded?
It is not allowable to utilize Title IV-E funding to replace county funds, without maintaining the amount previously expended, as this may be considered supplanting. Per the requirements set forth in WIC 16588, “A county shall use federal funds received under this chapter to supplement, and not supplant, local and State foster care prevention expenditures used for the maintenance of effort, as described in Section 471(e)(7) of the federal Social Security Act [42 U.S.C. Sec. 671(e)(7)].” If the county continues to maintain previous levels of funding for a particular service, they can only use Title IV-E for funding services above and beyond what was previously provided.
However, if the county decides to expand on its current program (e.g., expanding the services provided and/or increasing the population being served), the county may draw down the Title IV-E funds to supplement the difference.
For example, if the county is already administering a Title IV-E eligible EBP, such as Child-Centered Group Play Therapy, using local funding but wants to institute a culturally responsive adaptation of the practice, Title IV-E funding could supplement the existing funding.
If a county implements a new program, it may use Title IV-E and State Block Grant to help implement the program. Please refer to County Fiscal Letter CFL No. 21-22-110 for SBG claiming instructions and allowable funding expenditures.