Staffing for Administration of the Interstate Compact On Adoption and Medical Assistance

Introduction

The Interstate Compact on Adoption and Medical Assistance (ICAMA) is a mechanism which will make the administration of certain functions relating to interstate cases of adoption assistance more efficient and effective. The primary services affected will be the Medicaid Program as applied to children covered by an adoption assistance agreement who come into or leave a state and who are eligible for Medicaid coverage in their own right. Medicaid eligibility in interstate cases was established by federal law, the 1986 Consolidated Omnibus Budget Reconciliation Act (COBRA). Further, federal law gives states the option to make state subsidy children in interstate situations eligible for Medicaid in the state of residence as authorized under COBRA.

Since the Medicaid services and benefits involved relate to children under adoption assistance agreements, the planning and administration of adoption services for individual children is also a consideration. For children whom a state is placing or has already placed through its adoption assistance program, this planning function is already being performed. The difference under ICAMA will be that in considering the interstate aspects of such planning, the Compact will provide regular channels of interstate communication through which to obtain needed information from the other states. Thus, the quality of state administration and its results will be favorably affected, but work loads will not increase nor will shifts in staff assignments necessarily occur.

Identifying Affected Staffing Areas and Work

ICAMA will provide a framework and standardized procedures to address the needs of adoption assistance children and their families affected by federal and state law. Under ICAMA, interstate Medicaid eligibility can be established, continued, documented and (when appropriate) terminated. For children covered by state adoption assistance agreements and for children covered by adoption assistance agreements with other states who are entitled to state Medicaid, the state already is obligated to process and administer the cases. It does so under the state Medicaid Program in the department responsible for Human services. Under ICAMA, the regularized Compact procedures and interstate cooperative contacts with the other ICAMA states will be used. They will be used by the staff persons who now perform the relevant Medicaid functions.

Adoption services personnel consider interstate aspects of their adoption assistance cases when they are trying to consummate adoption assistance arrangements and for post-adoptive responsibilities. They will be assisted by the information received from and about other states through ICAMA, but the functions now performed will be essentially the same as those which the state Adoption Assistance Program is now obligated to perform.

Administration of the Compact

States must decide how to coordinate responsibilities for the interstate aspects of adoption assistance and medical assistance activities. Each ICAMA state needs to have a Compact Administrator (See ICAMA, Article IV) who is the central point for contact to which the other ICAMA states can relate and upon whom they can call to facilitate resolution of any interstate problem that may arise. Present ICAMA procedures now provide that the notice of eligibility for Medicaid which depends on adoption assistance agreements with the state should be sent to the Compact Administrator of the state which is to provide the Medicaid. This is to assure that there is an appropriate and easily located record in each state concerned with a particular case. The process also makes it easier for state and local personnel to send notices or request information with assurance of reaching the right point of contact in another state. The Compact Administrators route inquiries or documents to the appropriate place and individual. They also are the repository for case documentation so that a complete file on an interstate case can be found.

The Compact Administrator and Administrative Delegation

The chief executive of the human services department should be the one to execute ICAMA for the state. As with most operating functions, it is unlikely that the head of a major department will personally administer ICAMA. The department head may decide to retain the title of Compact Administrator or might designate the chief of a subsidiary unit whose responsibilities include some or all of the administrative tasks to which ICAMA applies. As already explained, the actual tasks affected by ICAMA are being performed by persons in the Adoption and Medicaid Programs of the state. This also includes personnel in area or county offices.

In some states, two departments of government are involved. This happens when the Adoption Program is in one department while the Medicaid Program is in another. This indicates that the Compact Administrator should be in one of these departments. The other department should have a Deputy Compact Administrator. A state can have (in addition to the Compact Administrator) as many Deputy Compact Administrators as the state wishes. However, it is important that the Compact Administrator and the one or more Deputy Compact Administrators each hold positions in their agencies which give them relevant policy and operational functions. This is appropriate so that when actions are taken on a joint basis by the ICAMA Compact Administrators of the party states, the individual representing the state will be a suitable person to participate on behalf of the state.

The ICAMA Secretariat

The ICAMA Secretariat has been established pursuant to the Compact. The American Public Welfare Association has been chosen to perform this function.

The Secretariat assists all of the Compact states. It staffs the Association of Administrators of the Interstate Compact on Adoption and Medical Assistance (AAICAMA). It develops and keeps current a variety of informational instruments used by all party states to make the interstate adoption assistance and interstate Medicaid tasks easier and more efficient in actual performance. The Secretariat also provides technical assistance to party states (when requested by them) with matters of interstate administration and in the handling of federal-state problems related to adoption assistance and Medicaid programs.

Conclusion

ICAMA provides the interstate mechanism necessary to achieve the interstate cooperation essential to make the administration of interstate cases proceed as smoothly and effectively as possible. The staffing tasks for states joining and participating in ICAMA involve the identification of the persons in the relevant agencies who will be designated to have a formal connection with the Compact. It will be necessary to identify the individuals who will perform tasks and have responsibilities associated with the interstate aspects of the Adoption Assistance and Medicaid programs. Creation of separate administrative machinery for ICAMA is unnecessary. Through identification of the right people, dissemination and explanation of interstate procedures, states can provide interstate protection for special needs adopted children.

ISSUE BRIEF II