Letter to Prospective Adoptive Parents about the IAAME Fee Schedule
Dear Prospective Adoptive Parents,
We are aware that many families are receiving information about upcoming fee increases for intercountry adoption processing. The Department offers the following information and trusts it is helpful to you in understanding the upcoming changes.
Who we are: The Office of Children’s Issues at the U.S. Department of State is responsible for U.S. policy on intercountry adoption and for executing the U.S. government’s responsibilities under the Hague Adoption Convention. Although you may not have had direct contact with our office, we work behind the scenes of your adoption cases in many ways. We coordinate with foreign governments to advocate for intercountry adoption programs to become and remain a viable option for children in need of permanency. We support and advise U.S. Embassies and Consulates on intercountry adoption matters, and we collaborate with other federal agencies such as the U.S. Citizenship and Immigration Services and the Department of Health and Human Services. We provide information, both proactively on our website and through our listserv and in response to specific inquiries or requests for assistance.
One of our most important roles is to monitor and oversee the work of accrediting entities who accredit and approve adoption service providers (ASPs) and monitor ASPs’ compliance with the federal regulations that govern intercountry adoption.
Accrediting Entities (AE): Currently, there are two designated AEs: the Council on Accreditation (COA) and the Intercountry Adoption Accreditation and Maintenance Entity, Inc. (IAAME), which was designated as an AE in July, 2017. The Department’s original intent was for both organizations to work together and to align their procedures related to accreditation and monitoring and oversight of ASPs. However, when COA decided to withdraw as an AE, our focus shifted to a full transition of AE responsibilities to IAAME. If you are interested in more background on this, you may wish to review the notices posted to our website:
New Fees: On February 1, 2018, IAAME published its Department-approved fee schedule, and on February 5, 2018, held conference calls with all accredited ASPs to address their questions about its implementation. We understand that prospective adoptive parents may be hearing that the new fee schedule could have a detrimental impact on intercountry adoption and families. We are committed to ensuring this is not the case and would like to address those concerns directly.
In response to documented problems, the Department asked the AEs to increase the focus on their monitoring and oversight responsibilities. The December 2016 temporary debarment of an ASP soon after the renewal of its accreditation made it clear that changes were urgently needed in how AEs execute their responsibilities. The Department requested that AEs increase ongoing monitoring and oversight of ASPs to promote greater consistency in compliance with the regulations that serve to protect children and families. The information about this decision was published in a January 5, 2018, notice and disseminated by email to ASPs and all stakeholders subscribed to our listserv. We are committed to safeguarding protections for children and families by ensuring the AE has the authority and resources needed to do its job. The notice provides details about what specific monitoring and oversight (M&O) activities the AE would be undertaking and explains the reasons for the Department’s request.
The accreditation regulations exist to protect children and families. The Department recognizes that most ASPs act in good faith, in the best interests of children, and in compliance with regulations. The AE’s responsibility is to ensure that ASPs provide adoption services in substantial compliance with the regulations, not only at the moment in which an ASP is accredited, but also throughout the four years of the accreditation cycle. Fulfilling this critical role requires the AE to be diligent in its assessment of both an ASP’s capacity and its actual performance. When this does not happen, children and families can be harmed. Unfortunately, through a review of records and complaints filed by adoptive parents and others, we have seen the devastating impact failure to do so can have on those involved.
The accreditation regulations have been in effect since 2008. They include many protections for adoptive families and children. For example, in the area of financial and risk management, the regulations require that ASPs ensure that all intercountry adoption fees, including those charged and collected overseas, are reasonable. In addition, ASPs must maintain thorough documentation about such fees and provide refunds for any services that are not rendered. When this does not happen, families pay the price both emotionally and financially.
Another critical requirement under the accreditation regulations is for ASPs acting as a primary provider to supervise, and to maintain written agreements, with all foreign supervised providers who provide adoption services in the country of origin. When the Department learned that many ASPs had not been complying with this obligation, it communicated a deadline for compliance by all accredited ASPs and requested the AE increase monitoring and oversight in this area. Inadequate supervision of foreign adoption service providers places children at risk of abuse or exploitation and families at risk of additional financial and emotional harm. When ASPs take responsibility for supervising the activities of the foreign providers with whom they work, the incidences of inappropriate or unethical activity drop dramatically.
The regulations also require the AE to charge sufficient fees to cover, but not exceed, the full costs of its work to accredit, monitor, and oversee ASPs. Under the regulations, an AE can only charge as much as it costs to perform their work. IAAME is a 501(c)(3) organization that will not profit from fees charged for accreditation, monitoring, and oversight. IAAME’s actual costs will be greater than COA’s have been in past years because of the increased focus on and activity related to M&O. In addition, IAAME decided to hire full-time staff to conduct the accrediting entity work. This is a shift from COA’s use of volunteer evaluators. The Department fully supports this change as it should improve consistency across evaluators.
IAAME, in consultation with the Department, considered many potential models for the fee schedule but determined the new fee structure was the best option.
IAAME’s new fee schedule has an accreditation fee, paid per agency, that covers the four-year accreditation cycle, and an M&O fee of $500 per case. ASPs are free to choose how they will recoup the costs, including by passing on the M&O fee directly to prospective adoptive parents. If you have not yet reviewed the fee schedule yourself, you may wish to read the Department’s notice posted on February 1, 2018 – Adoption Notice: IAAME Fee Schedule, Explanation, and FAQ.
IAAME’s decision to spread M&O fees out as a per case fee, rather than as a lump sum that would cover the four-year ASP accreditation cycle, avoids ASPs experiencing a sudden large increase in fees. M&O fees will only be assessed to the ASPs at the time the families enter the adoption process. Under this model, fees for many agencies are actually expected to decline.
The Department believes that, based on the average cost of an intercountry adoption, families will experience a 1.4% increase in total costs. The Department is sensitive to any increase in fees paid by prospective adoptive parents who may find intercountry adoption to be a financial challenge. However, the increase is offset by the protections that will be afforded by enhanced oversight and monitoring of ASPs, including reviews of ASP financial solvency, monitoring their use of fees, and enforcement of the requirement that ASPs refund fees for services not rendered. This ultimately provides greater stability and financial protection to families.
We do not believe any ASP will be forced to close its program solely based on this fee schedule.
We recognize changes of this type may be difficult. However, the Department believes that because of greater monitoring and oversight and enforcement of ASP regulatory requirements, that the change in fees will result in positive, long-term benefits for families and children. The Department also expects that greater transparency and AE oversight will enhance countries of origin confidence in the U.S. accreditation system and help to maintain intercountry adoption as a viable option for children in need of permanency.
The Office of Children’s Issues hopes this information is useful. You are welcome to communicate directly with us by email to Adoption@state.gov if you have questions about this matter or anything else pertaining to intercountry adoption.
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