7. Implementation Costs And Funding

7.1. How much Federal funding is available to States to build the National Youth in Transition Database (NYTD) data system, report the data, and conduct the survey? Will funding be provided above and beyond our annual Chafee grants to help us implement NYTD effectively?

There is no additional Federal funding set-aside for the NYTD. The Chafee Foster Care Independence Program (CFCIP) program was created with a mandate for States to collect data, but the statute does not set aside funds for that specific purpose. A State with a SACWIS must incorporate NYTD information collection and reporting activities related to children in foster care into their SACWIS system and may claim such information system costs as administrative costs under title IV-E to the extent they are allowable and consistent with a State's APD and cost allocation plan (73 FR 10362).

From: NYTD Webinar Briefing - April 10, 2008; 2008 NYTD Technical Assistance Meeting - July 23-25, 2008

7.2. If States who now get small Chafee allocations decide to stop taking Chafee money because they can't afford the implementation costs, will those funds be re-distributed to the other States?

A State that does not comply with the NYTD requirements does not have to forfeit all of its CFCIP funding, rather the State will be subject to a 2.5 percent penalty of its annual CFCIP allocation for each report period of noncompliance (45 CFR 1356.86). However, if a State does not apply for funds under Chafee, as specified in section 477(d)(4) of the Social Security Act, the funds to which the State would be entitled shall be allocated to one or more other States on the basis of their relative need for additional payments as determined by the Secretary of Health and Human Services.

From: NYTD Webinar Briefing - April 10, 2008

7.3. Can Chafee funding be used for incentives to encourage youth in the baseline and follow-up populations to participate in outcomes survey?

As stated in the preamble to the final rule (73 FR 10361), a State may use CFCIP funds for any and all costs associated with implementing the NYTD. However, we encourage States to be mindful of guidance issued by the Office of Management and Budget (OMB) entitled "Guidance on Agency Survey and Statistical Information Collections." While this guidance is directed to Federal agencies, the same general principles should guide State agencies, as well.
In the guidance, OMB states that incentives are used most appropriately with hard-to-find populations or respondents whose failure to participate would jeopardize the quality of the survey data. OMB's guidelines follow a general conceptual framework that seeks to avoid the use of incentives except when the agency has clearly justified the need for the incentive and has demonstrated positive impacts on response and data quality by using an incentive. In justifying their proposed use of incentives, State agencies should consider the following principles, among others:

• Data quality: One possible justification for requesting use of an incentive is improvement in data quality. For example, agencies may be able to provide evidence that, because of an increase in response rates, an incentive will significantly improve validity and reliability to an extent beyond that possible through other means.
• Improved coverage of specialized respondents, rare groups, or minority populations: A survey may have as its target population a highly selective group. Offering incentives to this population can be justified by describing the importance and difficulty of obtaining their participation in the study.
• Equity: Agencies should treat all respondents equally with regard to incentives. OMB generally does not approve agency plans to give incentives solely to convert refusals, or treat specific subgroups differently, unless the plan is part of an experimental design for further investigation into the effects of incentives.

The OMB guidance document can be located at http://www.whitehouse.gov/omb/inforeg/pmc_survey_guidance_2006.pdf

From: NYTD Webinar Briefing - April 10, 2008; 2008 NYTD Technical Assistance Meeting - July 23-25, 2008

7.4. Can title IV-E funds be used for incentives to encourage youth in the baseline and follow-up populations to participate in outcomes survey?

No. Incentives for youth participation in NYTD activities are unallowable as they are inconsistent with title IV-E regulations found at 45 CFR 1356.60.

From: 2008 NYTD Technical Assistance Meeting - July 23-25, 2008

7.5. Can ETV funds be used to cover the cost of child welfare information system enhancements to collect information on post secondary educational supports for NYTD purposes?

No. Section 477(h)(2) of the Social Security Act (the Act) restricts funds under the voucher program to "education and training vouchers for youths who age out of foster care." Therefore, title IV-E agencies may use voucher funds only to provide the vouchers and conduct administrative activities necessary to provide the vouchers. Using ETV funds to support information system enhancements for NYTD data collection would be outside the allowable use of funds for this program.

From: Questions & Answers released on April 7, 2011

7.6. Can Chafee funding be used for incentives to encourage youth to participate in the NYTD survey even if such youth are age 21 and no longer eligible for Chafee-funded services?

Yes. Incentives paid to encourage participation in the NYTD survey meet the purposes of the Chafee Program, as referenced in section 477(d)(1) of the Social Security Act. Consequently, states may use Chafee funds to provide these incentives to 21-year-olds regardless of whether they remain eligible for Chafee services. In providing incentives to youth for NYTD purposes, we encourage states to be mindful of guidance issued by the Office of Management and Budget (OMB) entitled "Guidance on Agency Survey and Statistical Information Collections." While this guidance is directed to federal agencies, the same general principles should guide state agencies, as well (see NYTD Q&A #7.3). The OMB guidance document is available at http://www.whitehouse.gov/omb/inforeg/pmc_survey_guidance_2006.pdf.

From: Questions & Answers released on June 17, 2014

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