Policy & Practice October 2018

Confidentiality in childwelfare cases is a priority for everyone. NEICE provides the opportunity for states to streamline the ICPC process and reduce time to placement.…New YorkOCFSwas pleased to become the 23rd state to joinNEICE and thankful for the on-going support of APHSAandTetrus to helpus get there. CAROL A. MCCARTHY, DIRECTOR, BUREAU OF PERMANENCY SERVICES, NEW YORK OFFICE OF CHILDREN AND FAMILY SERVICES

NEICE has been a true pooling of national resources. Each state that joins benefits from the lessons learned from the states who have gone before—ultimately strengthening the larger project as a result of a col- laborative approach in effect with the compact members. Beyond the stra- tegic member-to-member resource, there are also federal financial resources available for possible reim- bursement for developmental costs under SACWIS (Statewide Automated Child Welfare Information System)/ CCWIS rules or Title IV-E foster care in-placement administrative cost under 45 CFR 1356.60(c)(2). What Has Been Achieved? Child Trends evaluated the impact of the NEICE for the three-year imple- mentation grant. The evaluation of the system indicates that in the past three years, this technology has dem- onstrated substantial benefits to states and the children in their care. 2 For Child Permanency and Well- Being. Most important, because the work required and the time for the states to exchange paperwork is sig- nificantly reduced, children spend less time waiting for placement. For State Systemic Factors. States are experiencing a variety of benefits, including reduced ICPC case timelines, lower administrative costs, better communication and tracking of cases within and between states, improved data integrity and accuracy, and improved ability of states to comply with ICPC requirements. 3 For Legislative Requirements. The NEICE is a successful, secure, and functioning application that meets the purpose and guidelines defined in H.R. 1892—Title VII Family First Prevention Act Sec. 50722 that mandates, by 2027, all states use an electronic inter- state case processing system for the exchange of data and documents regu- lated by the ICPC. For State and National Reporting Requirements. State and national reports, previously unavailable, can now be generated for states on the NEICE. The NEICE data reports, aligned with federal requirements, will enable more system accountability and will serve as a source of information to improve

performance. Those states using the Modular Case Management System (MCMS) will have increased flexibility to modify their own state reports. For Data Security. The NEICE system does not have the vulnerability of an e-mail transmission or a paper copy. The NEICE team has focused extensive efforts on meeting all federal and state security measures and putting the appropriate security safe- guards in place—including liability and cyber-insurance and regular audits for system security. The NEICE is on the Microsoft Azure Government Cloud, is Fed Ramp compliant, and meets HIPAA standards. The NEICE meets FISMA (Federal Information Security Management Act) require- ments and follows National Institutes of Standards and Technology best practices for security, including having a security plan, system monitoring responsibilities, risk management activities, security incident response procedures, and others in place. One State’s Experience with the NEICE Carol A. McCarthy, Director of the Bureau of Permanency Services at the New York Office of Children and Family Services, describes the experi- ence as follows: “Confidentiality in child welfare cases is a priority for everyone. The NEICE provides the opportunity for states to streamline the ICPC process and reduce time to place- ment. However, nationwide databases like NEICE present certain chal- lenges in order to meet state-specific

requirements of confidentiality and access. Tetrus and APHSA were respon- sive to the needs of the New York State Office of Children and Family Services (OCFS) in this regard. Masking social security numbers was a requirement for OCFS and, following consultation with other NEICE states, Tetrus made it happen! User access and account- ability was another area of OCFS focus. Responsibility and accountability in regard to security is multilayered in NEICE, including the initial require- ment for each user to review and accept the NEICE Rules of Behavior for Users, followed by a requirement for users to agree to security terms with each log-in and the ability to receive audit logs ongoing. The OCFS has also requested an enhancement to meet the needs of our ICPC partners at the New York City Administration for Children’s Services (ACS). Tetrus continues work on this enhancement in order to provide ACS ICPC staff with the ability to view ICPC cases for children in their care when a voluntary agency is responsible for submission of the ICPC case. The OCFS was pleased to become the 23rd state to join the NEICE and thankful for the on-going support of APHSA and Tetrus to help us get there.” For more information or to join this national effort, contact Marci Roth, Project Director, at mroth@aphsa.org .

Reference Notes 1. Thirty-six states and the District of Columbia are live on the system or in

See NEICE on page 30

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