A November letter from the Children’s Bureau, not published online until March 27, reversed a national payment policy and reduced Maryland’s disallowance by $16. The dollar amount is trivial. The implications are not.
By Michael Phillips | MDBayNews | Father & Co.
On November 14, 2025, a senior official at the federal Children’s Bureau — signing as Acting Associate Commissioner — sent a letter to Maryland’s Department of Human Services that did two things at once. It adjusted Maryland’s bill on a foster care compliance review by sixteen dollars. And it quietly reversed a national policy governing how every state in the country can claim federal reimbursement when a child leaves foster care.
That letter was not published to the federal website until March 27, 2026 — four months and thirteen days after it was written. During that gap, Maryland’s legislature was debating “Kanaiyah’s Law,” named for 16-year-old Kanaiyah Ward, who died of a drug overdose in a Baltimore hotel room in October while under state-contracted supervision. A September 2025 audit by the state Office of Legislative Audits had found background checks missing in up to half of reviewed cases, $34.5 million in unrecovered foster care provider overpayments, and a $700,000 federal penalty for safety and education failures. The system was under as much scrutiny as it had been in years.
The federal government’s response, in that climate, was to send a three-page letter that no one outside the agency and DHS’s grants office would see for four months.
THE REVIEW, THE FAILURE, AND THE LONG WALK BACK
The story of the November letter begins in March 2024, when the Children’s Bureau — the federal office within the Administration for Children and Families that oversees state foster care programs — conducted an on-site review of Maryland’s Title IV-E foster care eligibility claims. Title IV-E is the main federal funding stream for foster care, and states must demonstrate that children in their systems meet eligibility requirements in order to claim federal reimbursement. The review covered Maryland’s claims from April 1 through September 30, 2023.
Eighty cases were examined. Five were found to be errors — meaning those children did not meet federal eligibility requirements during the review period. Under the federal standard, more than four error cases in a primary review means a state is not in substantial compliance. Maryland failed by one case.
The consequences of non-compliance are significant. The bureau’s July 10, 2024, final report disallowed $240,389 in federal financial participation — funds Maryland had already claimed and spent — and required the state to develop a Program Improvement Plan and submit to a secondary review of 150 additional cases. The errors ranged from a child placed with a foster parent whose criminal background check revealed prohibited charges that a contracted placement agency had never verified, to missed judicial deadlines for permanency plan determinations, to a case where the state claimed federal funds after it had already lost legal placement and care responsibility for the child.
What followed was a bureaucratic negotiation that unfolded across three additional letters over the next 16 months, each one revising the previous findings.
On September 3, 2024, the bureau issued a first addendum revising the payment amounts upward for two cases — a mathematical correction — bringing the total disallowance to $245,063, higher than the original figure. Maryland then appealed. On October 28, 2024, the bureau reversed the error finding on one case, sample case OS-2, after Maryland provided additional documentation showing that the required judicial determination had in fact been made timely. With four error cases remaining — exactly at the four-case threshold — Maryland flipped from non-compliant to compliant. The Program Improvement Plan requirement was dropped. The secondary review was canceled. A $245,063 bill became a $234,400 bill.
Then came November 14.
A POLICY CHANGE DRESSED AS AN ACCOUNTING MEMO
The November letter, signed by Joseph J. Bock as Acting Associate Commissioner of the Children’s Bureau, opens by summarizing the prior correspondence. Then, in the third paragraph, it announces something that has nothing to do with Maryland’s specific cases:
“Following the issuance of those findings, the Children’s Bureau conducted a mid-cycle review of the IV-E review process. Based on this review, the Bureau has decided to reinstate the previous practice of allowing foster care maintenance payments for the day the state’s placement and care responsibility (P&C) ends due to a child being discharged from foster care (e.g., to adoption, reunification, or guardianship).”
In plain language: the bureau had, at some earlier point, stopped allowing states to claim the last day of foster care when a child exits — the day they’re reunified with their family, adopted, or placed under guardianship. Now it was reversing that position, saying states can claim that day after all. The legal basis cited is 42 U.S.C. § 672(a)(2)(B), which requires the state to have placement and care responsibility for the child. The bureau’s reasoning: the state still has that responsibility on the actual day of discharge.
The practical effect on Maryland was minimal. One case — case number 75 — had a portion of its disallowance tied to a single day when the state lost placement and care responsibility upon discharge. The bureau reduced that case’s disallowance from $452 to $436, a $16 adjustment. The total Maryland disallowance moved from $234,400 to $234,384.
But the policy change itself is not minimal. Title IV-E is a roughly $10 billion annual federal program. The rule change — reinstating the day-of-discharge payment — applies to every state conducting or awaiting a review. For states with larger case populations or more cases flagged on this precise issue, the financial impact could be substantially larger. The decision was made through a “mid-cycle review” — an internal bureau process — with no public notice, no formal rulemaking under the Administrative Procedure Act, and no apparent opportunity for public comment.
The letter provides no further information about what triggered the mid-cycle review, how many states were affected, or who signed off on the policy decision. Bock’s title — Acting Associate Commissioner — indicates the decision was made by someone in a temporary role, during the period following the federal administration transition in January 2025.
THE GAP
The letter is dated November 14, 2025. According to federal records, it was not posted to the Children’s Bureau website until March 27, 2026.
That four-month gap is not necessarily unusual — federal correspondence of this type is sometimes posted with delays. But the timing gives the gap meaning. The November letter arrived while the Maryland General Assembly was actively investigating the state’s foster care system in the wake of Kanaiyah Ward’s death and the September OLA audit. It arrived while Secretary Rafael López, who received the letter, was defending DHS before lawmakers and publicly committing to systemic reform. It arrived while “Kanaiyah’s Law” — legislation to restrict the placement of foster youth in hotels and tighten vendor oversight — was being drafted.
None of that legislative activity touched the Title IV-E compliance track. But the compliance track is where the money flows. And the November letter, for all its bureaucratic modesty, is a document about who gets to decide how that money is counted — and when those decisions become public.
THE COMPLIANCE LEDGER
The full arc of the 2024 Title IV-E review, from original finding to final revised disallowance, shows how substantially a state’s compliance status and financial exposure can shift through the appeals and revision process:
July 10, 2024: Final report issued. 5 error cases. Not in substantial compliance. Total disallowance: $240,389.
September 3, 2024: First addendum. Payment amounts were corrected upward for two cases. Revised disallowance: $245,063.
October 28, 2024: Maryland appeal upheld on one case. Error count reduced to 4 — exactly at the compliance threshold. Status flips to substantial compliance. Program Improvement Plan and secondary review dropped. Revised disallowance: $234,400.
November 14, 2025: National policy reversed on day-of-discharge payments. Maryland’s disallowance reduced by $16. Final disallowance: $234,384. Maryland remains in substantial compliance.
Net change from the original finding to the final ruling: Maryland’s disallowance fell by $6,005. Its compliance status went from failure to passing. The Program Improvement Plan — a significant accountability mechanism — was never written.
WHAT WASN’T FIXED
The Title IV-E compliance review measures something specific and narrow: whether the paperwork and judicial documentation supporting individual foster care cases meets federal eligibility standards. It is not designed to measure whether children are safe, whether placements are appropriate, or whether providers are properly vetted. Those questions are the province of the OLA audit — which, as of this writing, Maryland is in the process of responding to with a corrective action plan.
The September 2025 OLA audit and the federal Title IV-E review are separate tracks, governed by different agencies, measuring different things, and producing different remedies. A state can be in federal compliance and still have 14 children sleeping in hotel rooms. It can pass a Title IV-E review while 1,600 children go without required dental care. It can negotiate a disallowance down from $245,063 to $234,384 while a $465 million foster care expansion contract is advancing procurement.
Maryland’s child welfare system serves approximately 3,724 children in out-of-home care on any given day, 56 percent of them Black, in a state where Black children make up 33 percent of the child population. That ratio — documented in DHS’s own December 2025 legislative report — has been consistent for years. It does not appear in federal compliance letters. It does not affect disallowance calculations.
What the November 14 letter tells us, in the end, is that the federal compliance apparatus is precise about the things it measures and silent about most of the things that matter. The bureau caught a one-day payment error in one Maryland case and corrected it. It then reversed the national rule that made it an error in the first place. It did all of this in a letter that took four months to reach a public website.
The children in Maryland’s foster care system will not notice the $16.
Keep Father & Co. Free
Father & Co. exists to support parents navigating separation, custody, and systems that are often confusing, isolating, or overwhelming. This work is grounded in lived experience, careful research, and respect for the real stakes families face.
If this article helped you feel less alone, better informed, or more grounded, reader support helps keep these resources free and available to others who need them.
Need help reviewing or organizing court or formal documents?
Father & Co. offers non-legal document review and organization for people representing themselves. This includes clarity, structure, neutral tone, and timeline organization — not legal advice or representation.
Have a story, experience, or resource to share?
Submissions are reviewed with care and discretion. We respect privacy and handle sensitive information responsibly.
Discover more from Fatherand.Co
Subscribe to get the latest posts sent to your email.
