At its March 14 meeting, the State Executive Council for Children’s Services (SEC) approved seeking public comment on a Notice of Intent to Develop/Revise Policy for SEC Policy 4.5.2, Time Frames Regarding CSA Pool Fund Reimbursement. This action is the first step in the policy revision process; after the initial public comment period, the SEC will determine whether to move forward and will seek additional public comment.
The proposed revisions to the policy, which may be found at this link, result from discussions at the SEC at its December meeting regarding a set of appeals from several counties that had missed the September 30 deadline for submission of reimbursement requests. Under current SEC policy, counties in this situation may submit a waiver request to the Office of Children’s Services, but the Executive Director does not have explicit authority to grant these requests, so waiver requests must be considered by the SEC. The proposed revisions to the policy would allow the Executive Director to grant a waiver based on a determination of “good cause,” as defined in the policy. A locality that disagrees with the Executive Director’s determination could appeal to the State Executive Council.
VACo seeks members’ feedback on the proposed revisions, in particular on the following items:
- Is the proposed definition of “good cause” in Section 4.5.2.3 adequate? Are there other circumstances that should be listed as examples of good cause?
- Does your locality already meet requirements under the proposed new sections D and E under Section 4.5.2.4 (Pool Fund Reimbursements) (a requirement to adopt and implement procedures to reconcile actual CSA reimbursements against expected reimbursements using local general ledgers and certain CSA resources, and a requirement to adopt procedures to address position vacancies, including temporary unavailability, in the roles of Report Preparer and Fiscal Agent)?
Member feedback will inform VACo’s public comments and may be sent to Katie Boyle (kboyle@vaco.org). Members may also submit comments directly to the Office of Children’s Services; public comment is being accepted until 5 p.m. on May 2, 2024, and may be submitted online via the Public Policy Comment Form (available at this link), via email to csa.office@csa.virginia.gov, or via U.S. Mail (1604 Santa Rosa Road, Suite 137, Richmond VA 23229). If members submit comments directly to the Office of Children’s Services, VACo staff would greatly appreciate receiving a copy of your comments.
VACo Contact: Katie Boyle