Implementation of Revised Substantial Compliance System Delayed to April 1, 2021

Last Updated: October 27, 2020

This notice supersedes the May 29, 2020 notice, Updated Substantial Compliance System (SCS) Implementation.

The Department has decided to move full implementation of the revised Substantial Compliance System (SCS) from November 1, 2020 to April 1, 2021. 

The SCS is a system of weightings the accrediting entity uses to evaluate the compliance of accredited and approved adoption service providers (ASP) with required standards under the federal regulations governing intercountry adoption. The SCS is a critical tool for protecting the safety and best interests of children adopted through the intercountry process, as well as adoptive families and birth families.

The Department recognizes concerns that although the accrediting entity, Intercountry Adoption Accreditation and Maintenance Entity (IAAME) has provided training for ASPs on the updated SCS, additional training on key aspects of the intercountry adoption regulations and how IAAME carries out its accreditation and monitoring and oversight responsibilities is forthcoming. The Department wants ASPs to be successful in their transition to the revised weightings and anticipates that delaying full implementation of the SCS will allow ASPs to better prepare for this transition. 

IAAME will reach out to ASPs impacted by the delay immediately. Adoption service providers seeking new accreditation will continue to be evaluated according to the revised SCS, in accordance with the first phase of implementation of the new SCS that began in March 2019. As recently reported, two Adoption Service Providers (Catholic Charities of the Diocese of Green Bay and St. Nick's Kids, Inc.) received initial accreditation based on the revised SCS. We welcome these new members of the ASP community.