Nov. 2 Federal Update: Children’s Bureau Publishes Issue Brief on Title IV-E Prevention Candidacy 

A recent issue brief published by the Children’s Bureau identifies the continuum of decisions states and tribes have made to date on Title IV-E prevention candidacy, including who is eligible and how eligibility is determined. 

As a result of the Family First Prevention Services Act, Title IV-E agencies can claim certain mental health, substance use, and in-home parenting services to help prevent foster care entry. States and tribes hold critical flexibility to describe imminent risk in their Title IV-E five-year prevention plan, enabling agencies to recognize different ways a child could enter foster care and offer help before a safe option for preventing entry is lost. 

The brief offers guidance regarding five-year plans, detailing why prevention may be needed, referral pathways, and the timeframes when prevention can begin or resume. 

Children’s Bureau Brief Reviews Out-of-State Child Abuse and Neglect Registry Checks 

The Children’s Bureau published a brief examining federal requirements, recommendations, and reported state practices for child abuse and neglect registry checks. The document maintains that state child welfare agencies should make required child abuse and neglect registry checks easier to request and faster to complete.  

Prompt, reliable responses help workers assess safety and approve qualified foster and adoptive homes without unnecessary delay. Timely checks are especially important for kin caregivers who may already be caring for a child while awaiting approval and the financial support that licensure can make available. The report accordingly identifies practical steps state child welfare agencies can take to make required checks easier to request and faster to complete. 

According to the Children’s Bureau, the most immediate opportunities are administrative. States can accept an agency’s consent attestation, exchange requests and results electronically, eliminate processing fees and unnecessary signature formalities, and maintain a central intake channel. These changes reduce the work needed to obtain a check while preserving safety and confidentiality requirements.  

ACL Awards $3M for National Technical Assistance Center for Kinship and Grandfamilies 

The Administration for Community Living’s Administration on Aging is awarding a new cooperative agreement to operate the National Technical Assistance Center for Kinship and Grandfamilies. The three-year award provides $1 million per year, for a total of $3 million, to strengthen the national aging services network and other organizations’ capacity to support the health and well-being of caregivers, children, and parents. 

Through collaboration with subject matter experts, the Center will provide technical assistance, resources, and training across the many systems that impact kinship and grandfamilies; foster peer-to-peer learning; and support planning for emergencies and disasters. The funding opportunity also calls for the center to strengthen coordination among aging, kinship, disability, child welfare, and tribal service systems and to develop and disseminate evidence-informed tools, resources, and best practices. 

Education Department Withdraws Proposed Rule to Deregulate Charter Schools Program 

The Education Department withdrew proposed regulations to alter its federal grant program for charter schools. 

The proposal would have significantly deregulated the Charter Schools Program, which funds the creation and expansion of charter schools. The changes aimed to simplify eligibility and application criteria, minimize redundancies, and provide greater flexibility in compliance reporting. 

Proposed Rule Seeks to Enhance Security of SNAP Electronic Benefit Transfer Cards 

A proposed rule issued by the Department of Agriculture would modernize Electronic Benefit Transfer, improving the Supplemental Nutrition Assistance Program’s integrity and convenience. 

The rule follows a report from the U.S. Department of Agriculture Office of Inspector General that found critical vulnerabilities to benefit theft and projected SNAP theft could rise to $233 million between 2025 and 2026, largely due to skimming. The loss of benefits is particularly challenging for SNAP recipients, as most states do not replace stolen benefits. 

Card skimming, the unauthorized capture of personal information to access benefit accounts, often relies on security vulnerabilities within the cards. The proposed rule would require all states to adopt chip-enabled EBT cards. It also requires retailers that accept SNAP benefits to have payment terminals that support tap-pay.   

USDA estimates that the changes will reduce stolen benefits by at least $1.5 billion over the next decade. Comments are due Dec. 22. 

Proposed Rule Seeks to Strengthen Eligibility Requirements for Affordable Care Act Subsidies 

The Centers for Medicare & Medicaid Services recently proposed additional eligibility requirements that would require Affordable Care Act (ACA) enrollees seeking enhanced tax credits and cost-sharing reductions to verify income, citizenship, and residential information before financial assistance begins. 

Currently, eligible enrollees can receive financial assistance for a brief window before their documentation is verified. However, that grace period would end in plan year 2028, and enrollees would be required to complete eligibility redeterminations each year.  

CMS estimates 332,500 fewer individuals per year would enroll in ACA plans due to the rule. For further information, the agency has published a fact sheet. 

Comments are due Nov. 27. 

ACL Awards Support Health & Wellness Initiatives for Individuals with Disabilities  

The Administration for Community Living announced three separate awards to advance the Americans with Disabilities Act (ADA), the National Information and Referral Support Center, and the National Institute on Disability, Independent Living, and Rehabilitation Research. 

Grants include, 

• $11,074,444 in fiscal year 2026 funding for the 10 regional centers of the ADA National Network through ACL’s National Institute on Disability, Independent Living, and Rehabilitation Research (NIDILRR) to support a nationwide resource operating for people with disabilities, employers, public agencies, businesses, and others who want to understand and carry out the ADA. 
• $35,763,912 in fiscal year 2026 funding for 68 new grants from the NIDILRR to support research, technology development, training, and technical assistance and improve health, expand job opportunities, and support independent living and community life for people with disabilities. 
• A three-year award providing $225,000 per year, for a total of $675,000, to strengthen the quality, capacity, and professionalism of aging and disability information, referral, and assistance programs nationwide, helping older adults, people with disabilities, caregivers, and families connect with information, services, and supports. 

Sector Updates from the Judiciary  

Supreme Court Declares Student IDs as Invalid for Voter Registration 

A Supreme Court verdict allows New Hampshire to bar student IDs as a valid form of identification to confirm voter eligibility. The decision affirms guidance from the Secretary of State clarifying a recent state law that removed student IDs from the list of identifications ballot clerks are required to accept when an individual requests a ballot.  

The Supreme Court decision affirms the Purcell principle, preventing changes to election rules immediately prior to elections.   

Federal Court Prevents Changes to Fair Housing Grants 

The First Circuit Court of Appeals upheld an order to prevent the US Department of Housing and Urban Development from implementing sweeping changes to a Fair Housing Initiatives Program. The program was created by Congress in 1987 to provide multi-year ‌grants for ⁠fair housing organizations to help enforce the Fair Housing Act and address housing discrimination. 

Through the Fair Housing Initiatives program, more than 100 grants ranging from $75,000 to $425,000 would typically be awarded. However, the agency recently announced it would not allocate any of its congressionally appropriated funding for the 2025 fiscal year to private enforcement initiatives or to multi-year grants issued through the Fair Housing Initiatives Program. In its place, $46 million of the total $56 ​million Congressionally appropriated funds would be directed to ⁠five grants and $10 million toward a state or local agency. 

The verdict safeguards critical funding for nonprofit organizations and protects fair housing access. 

Federal Court Rejects Work Requirements for Medicaid Beneficiaries with Serious Medical Conditions  

The U.S. District Court for the District of Massachusetts issued a temporary injunction, safeguarding Medicaid coverage for individuals with serious medical conditions. The decision follows a lawsuit filed by 25 states and the District of Columbia against a rule that would have required individuals with qualifying conditions to prove that their illnesses significantly impaired their ability to comply with emerging work requirements.  

The tax and reconciliation law, H.R. 1, defined medically frail to include people who are blind or disabled, have substance use disorders or disabling mental disorders, have certain disabilities that significantly impair daily activities, or have serious or complex medical conditions. 

Judge Richard G. Stearns affirmed the profound expected harm of the rule and the burden states would face in implementing the rule.  

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