On Friday, April 17, 2020, the Children’s Bureau released a letter to the child welfare field on allowable use of funds during the national emergency for the purchase of cell phones and other tools to facilitate or maintain contact with children and youth in foster care and their parents and the purchase of personal protective equipment (PPE). Milner stated in the letter that:

“The purchase and operation of cell phones for children and youth in foster care, their parents, or foster parents is an allowable cost under title IV-B and/or the John H. Chafee Foster Care Program for Successful Transition to Adulthood (Chafee) as long as the costs are necessary to fulfill one or more program purposes in §422 (relating to the state plan for child welfare services under title IV-B, subpart 1), §432 (relating to the state plan for child welfare service under title IV-B, subpart 2) and/or §477 (relating to Chafee program purposes) of the Act. For example, access to a cell phone for a youth receiving Chafee services may be determined as necessary if it will either facilitate participation in program services or enhance the effectiveness of the services in transitioning him/her to adulthood. The purchase of a cell phone for a parent or foster parent can meet a title IV-B program purpose if it is determined that it will facilitate needed communications for case management purposes between such an individual and the agency caseworker, or allow a parent to participate in a remotely-located court hearing or visitation with the child.”

“In addition, PPE is an allowable expenditure of title IV-B funds for program purposes such as caseworker visits (§422(b)(17) of the Act and for states, §424(f) of the Act) by both state and Tribal title IV-B agencies. Under title IV-B, the purchase of PPE for providers such as foster parents, kinship providers and staff of child care institutions may be allowable if it fits within one of the purposes outlined in the statute (§421 of the Act) and may be allowable under title IV-B, subpart 2 if it is consistent with one of the four service categories. Additionally, P.L. 116-136 authorized additional funding under title IV-B, subpart 1 “to prevent, prepare for, and respond to coronavirus, domestically or internationally.” States and Tribal title IV-B agencies must also consider whether the activity is consistent with 45 CFR §1357, grant regulations and OMB Circular A-87 (a cost must be both “necessary and reasonable”). To the extent that providing PPE such as masks and gloves to providers fits within the title IV-B subpart 1 and 2 purposes, it may be allowable.”