January 5, 2018 – Upcoming Changes in Accrediting Entity Activities
February 1, 2018 – Adoption Notice: IAAME Fee Schedule, Explanation, and FAQ
February 8, 2018 – State Department Letter to Adoptive Parents
The Department has no reason to believe that the new accrediting entity (AE) fees will lead ASPs to close.
For clarity:
Under IAAME’s fee schedule, ASPs are required to pay between $8,800 and $20,800 for four years of accreditation or approval. These fees will result in a decrease in fees for home study only ASPs and for ASPs with fewer than 5 cases.
In addition, ASPs who are primary providers will be assessed a $500 fee per adoption case for each child as new clients are accepted into their programs to cover M&O. As a result, ASPs will only be assessed fees when they begin providing services to new clients.
The Department reviewed IAAME’s proposed fee schedule and approved it in accordance with 22 CFR. 96.8. Section 96.8 requires that the accrediting entity (AE) demonstrate, among other things, that the total fees that it expects to collect under the schedule of fees does not exceed the full costs of accreditation or approval. This section also requires that the schedule of fees must include “the costs of all activities associated with the accreditation or approval cycle, including but not limited to, costs for completing the accreditation or approval process, complaint review and investigation, routine oversight and enforcement, and other data collection and reporting activities, …”
The Department plans to regularly review IAAME’s schedule of fees as part of its annual review of IAAME and will assess whether the fees collected under this new schedule of fees cover only IAAME’s costs of accreditation or approval services, as discussed in the regulations.
The Department requested the AEs, both COA and IAAME, increase their focus on M&O in order to ensure ASPs remain in substantial compliance with accreditation standards in the interests of children and families. Information about specific activities associated with M&O was posted on the Department’s web site on January 5, 2018. The actual work associated with these additional activities will generate additional costs for AEs.
IAAME has also decided to use paid staff, rather than volunteers, for all AE activities, which carries higher costs than a volunteer-based model. The Department supports IAAME’s decision in this regard because it will improve consistency between evaluators inter-rater reliability and avoid potential conflicts of interest that may result when employees of one ASP evaluate, as a volunteer, another ASP. Although COA decided to withdraw as an AE, that has not changed the plan for increased M&O of ASPs, which will result in greater costs of such activity for the AE. IAAME’s fees are in line with these costs.
The specific benefits to families and children that will result from increased M&O activity are significant, as discussed in the Department’s letter to prospective adoptive parents posted to our web site on February 8, 2018. We trust that ASPs do their best to comply with the federal regulations governing intercountry adoption, but those that do not create significant risk of exploitation and abuse of children, as well as financial and emotional risks to adoptive parents.
IAAME’s schedule of fees is designed to cover the projected cost of conducting M&O activities for ALL intercountry adoptions across ASPs and country programs. AEs monitor ASP activity as a whole. This includes conducting M&O for adoption cases that do not ultimately result in the placement of a child. Although structured as a per case model, the fees are not directly attached to individual cases. Rather, all of the fees will be aggregated to ensure IAAME has sufficient funds to cover M&O activities for all accredited ASPs. M&O activities are also performed on an ongoing basis. Because the fee model allows ASPs to pay fees incrementally as cases are accepted, rather than paying the fees as a lump sum at the beginning of the four year accreditation cycle, the AE will receive fees monthly. Fees may be expended on M&O activities immediately after IAAME receives them and thus are non-refundable.
February 15, 2018 - ASPs must begin recording each intercountry adoption case accepted on or after that date (please see below for more information about what constitutes an accepted case.)
March 5, 2018 - ASPs will report to IAAME the number of cases accepted from February 15, 2018 through February 28, 2018. Thereafter, ASPs will report to IAAME on the 5th of each month the number of accepted cases for the prior month.
March 15, 2018 - IAAME will send an invoice to each ASP for M&O fees due based on the number of cases reported.
April 15, 2018 - ASPs will pay the invoiced amount.
IAAME will invoice ASPs on the 15th of each month for M&O fees, with payment due to IAAME on the 15th of the following month.
Most ASPs use a model in which the prospective adoptive parent submits an application to the ASP, and when accepted as a client, pays fees and signs/submits contracts and other documents to the ASP. Under this model, the acceptance of the new case would be the trigger to report to IAAME. IAAME is aware that some agencies use alternative procedures. In this event, the client is considered to have been accepted into the program, and the case should be reported, at the first stage that the ASP acts as a primary provider. This may include, but is not limited to, the time at which fees are collected, contracts are signed, or any adoption services are provided, including the identification of a child.
In response to a specific question received from an ASP, the Department notes that a “soft referral” is not acceptable practice under the regulations and may lead to adverse action.
In accordance with the answer above, if the client has either paid fees charged by the ASP or signed a contract with the ASP for intercountry adoption services prior to February 15, 2018, the case may be grandfathered and not be included in the ASP’s report to IAAME for the purpose of the M&O fees. In the circumstance described in the question above, the case would be grandfathered and M&O fees would not be required for that case.
Cases in which there is a record of acceptance of an application by an accredited ASP acting as the primary provider prior to February 15, 2018 are exempt from the M&O fee. After February 15, 2018, if a case transfers from one ASP to another, the second ASP (to whom the case is transferred) will not be responsible for the M&O fee if the first ASP (who transferred the case) accepted the client and already paid the M&O fee to IAAME.
Yes. M&O fees will be charged to each primary provider based on the number of new cases accepted, whether it is for an incoming or an outgoing case. For each new case in which the ASP agrees to serve as a primary provider, a per case fee of $500 will accrue.
No, the M&O fee is associated with the ASP that acts as a primary provider for the prospective adoptive parents. Generally, ASPs that only do home studies will not pay M&O fees. However, if a home study-only ASP does become the primary provider, they will be responsible for paying the M&O fee.
Yes. The amount of the M&O fee per adoption case was established based on the projected number of total adoption cases and IAAME’s projected expenses for conducting M&O activities. At this time, there is insufficient data to allow IAAME to create a model that exempts siblings from the M&O fee structure. This may be considered in the future.
The M&O fee will be charged per adoption case for each child. Each month, the primary provider will report to IAAME one case for each newly accepted case. Later, when the referral for additional children is accepted, the primary provider will report one additional case for each additional child to be adopted. The primary provider is responsible for paying the M&O fee per child. ASPs that elect to pass the M&O fee to adoptive families will need to decide how to reflect that in their contracts, procedures, and billing in order to ensure families who adopt sibling groups pay the additional M&O fees.
IAAME will invoice ASPs for M&O fees based on the number of cases that each ASP reports. However, IAAME will compare the number of cases reported by each ASP with the Adoption Tracking Service (ATS) and other sources to verify the accuracy of the self-reported numbers. IAAME is aware there are data issues with the ATS and other systems that will require contact and discussion with the ASP prior to finalization of any reconciliation process. IAAME will present information it has collected regarding the number of cases for which an ASP is responsible for paying the M&O fee to the ASP and will provide the ASP with a timeframe to review and respond to the data/information. IAAME and the ASP will exchange information and will communicate until IAAME determines that the reconciliation is complete. IAAME expects that this checks and balance process will, over time, improve the information in the ATS and other systems so that information and data can be relied upon for billing, reporting, etc.
IAAME expects that, by April 1, 2018, ASPs will be able to upload case information into a secure IAAME web system. IAAME is working on several online reports where ASPs will be able to document this information rather than uploading an Excel spreadsheet into the secure system. Until April 1, 2018, ASPs will need to provide the information to IAAME on an Excel spreadsheet and send it in an encrypted and password protected manner.
Yes. An ASP’s current accreditation is valid through the applicable expiration date, which is generally four years from the date of accreditation or five years, if the ASP was granted an extension.
Any ASP that is already accredited and will be seeking renewal of accreditation will pay the $800 renewal application fee to IAAME for its next accreditation cycle. Only new applicants, who have not previously been accredited for intercountry adoption or whose previous accreditation was cancelled or lapsed, will pay the $3000 application fee.
Any accrediting entity has the authority to travel to a country of origin if necessary to fulfill its regulatory responsibilities, including to conduct M&O activities and complaint review. IAAME will use discretion regarding international travel.
Under the current fee schedule, there is a flat fee charged for site visit travel, and IAAME will charge actual costs for transportation plus Federal per diem rates to cover lodging, meals, and incidentals. Under Federal per diem guidelines, lodging is covered at the actual cost, up to an amount designated for the specific city destination; meals and incidentals are paid at a specific amount per day, with travel days being covered at 75%.
Many site visits may actually cost less under IAAME’s model. For example, as of February 12, 2018, for a four-day trip to Boston, under the existing flat rate model, an ASP would pay $1200 for the first 2 days and $225 for each additional day, for a total cost of $1650; this would include travel and maintenance (hotel, meals, incidentals.) The Federal per diem rate for Boston is $267 for lodging (paid at actual costs, up to this amount) and $69 per day for meals and incidentals. Under IAAME’s model, as of February 12, 2018,the estimated expenses would be:
Airfare: approximately $250 (Gainesville to Boston)
Lodging for 3 nights @ $267/night = $801
Per diem = $241.50 (travel days are paid at 75%; full days paid at 100% of $69)
TOTAL: $1292.50 (** Other costs may include airline baggage fees and taxis.)
IAAME’s authority is based on the Federal law and regulations that govern intercountry adoption and through which the Department designated IAAME as an accrediting entity. Since IAAME will be the sole accrediting entity, any ASP that handles intercountry adoption must cooperate with IAAME as the accrediting entity. A specific contract or written agreement with individual ASPs is not required. IAAME, however, does plan to have a written agreement with ASPs.
IAAME is working diligently to finalize its policies and procedures manual. The timeframe for its publication is largely dependent on the Department’s clearance process. The Department anticipates that it will be published before May 2018.
Information on the semi-annual report of complaints and the annual attestations will be available by March 15, 2018.
Different people use the term “forensic accounting” to describe different activities, but it generally means a more in depth review than general monitoring and oversight of financial activities. In general, forensic accounting would only be utilized in circumstances where a specific concern exists about an ASP’s activities that cannot be resolved through typical accounting and/or financial review procedures. IAAME does not intend forensic accounting to be a standard part of its M&O or complaint review procedures.
