Clarifying Duplication in Modular Modernization, Replacement, and Data Readiness Efforts for Comprehensive Child Welfare Information Systems (CCWIS)

Dear State Child Welfare Director,

We are pleased to share the Children's Bureau (CB) Information Memorandum (IM), ACYF-CB-IM-26-03: Clarifying Duplication in Modular Modernization, Replacement, and Data Readiness Efforts for Comprehensive Child Welfare Information Systems (CCWIS).

American children, families, and the professionals who serve them deserve technology that supports timely decision-making, reduces administrative burden, and helps agencies continuously improve outcomes. As child welfare practice continues to evolve, information systems must evolve as well. Modern, modular, and data-driven systems enable caseworkers to spend more time serving children and families, provide agency leaders with more reliable information, and strengthen the ability of jurisdictions to improve safety, permanency, and well-being.

As part of ACF's A Home for Every Child initiative, we are committed to helping jurisdictions build child welfare systems that are more responsive, connected, and effective. Achieving that vision requires more than sound policy and practice. It requires modern technology that serves as the trusted ecosystem of record for child welfare. Title IV-E agencies need information systems that bring together accurate, timely, and reliable information to support every stage of a child's journey, from prevention through permanency. These systems should reduce administrative burden, strengthen collaboration across programs and partners, and equip the workforce with the information needed to make informed decisions on behalf of children and families.

Across the country, title IV-E agencies have made significant investments CCWIS. While some jurisdictions have made substantial progress, there is still important work ahead to fully realize the vision of modern, interoperable systems that support children, families, and the child welfare workforce. As technology, policy, and program needs continue to evolve, agencies continue to modernize their capabilities to improve interoperability, strengthen data quality, reduce technical debt, and build systems that are better equipped to support today's workforce and improve outcomes for America's children and families. As agencies undertake this work, questions have emerged regarding when replacing or substantially improving previously federally funded system capabilities may constitute duplication. This IM provides greater clarity by reinforcing that the CCWIS regulations are intended to prevent unnecessary duplicative investments, not to discourage responsible modernization that results in meaningful improvements for children, families, and the child welfare workforce.

We encourage title IV-E agencies to continue advancing their CCWIS modernization efforts with confidence. This IM is intended to clarify ACF's interpretation of duplication requirements so that uncertainty does not become a barrier to meaningful technology improvements that strengthen child welfare practice and improve outcomes for America’s children and families.
This IM does not establish new requirements for title IV-E agencies. Rather, it provides guidance and practical resources to support consistent planning and implementation of modernization efforts. We encourage you to review this guidance with your program, technology, and procurement partners.
Thank you for your continued leadership and partnership in advancing a modern child welfare system that supports the vision of A Home for Every Child and improves outcomes for the children, families, and communities we all serve.

Best regards,

IM#: ACYF-CB-IM-26-03

DATE: June 26, 2026

TO: State, Tribal, and Territorial Agencies Administering or Supervising the Administration of Titles IV-B And IV-E of The Social Security Act

SUBJECT: Clarifying Duplication in Modular Modernization, Replacement, and Data Readiness Efforts for Comprehensive Child Welfare Information Systems (CCWIS)

ATTACHMENTS: 

• ACF-ACYF-CB-IM-26-03 (PDF)
• Attachment A - Suggested Decision Framework (PDF)
• Attachment B - Illustrative Examples of Modernization and Duplication Scenarios (PDF)
• Attachment C - Suggested Replacement Documentation Checklist (PDF)

PURPOSE

The purpose of this Information Memorandum is to provide guidance to title IV-E agencies, CCWIS project teams, coordinators for Advanced Planning Documents (APD) and technology partners regarding how ACF considers duplication when title IV-E agencies propose to modernize, replace, consolidate, or substantially improve automated functions. This Information Memorandum is intended to support consistent planning, documentation, and review of CCWIS modernization efforts, particularly where an agency proposes to replace or substantially re-engineer functionality that was previously funded with federal financial participation (FFP) under section 474(a)(3)(C) and (D) and section 474(c) of the Act.

LEGAL AND RELATED REFERENCES: 

Section Title IV-E of the Social Security Act; 45 CFR §§ 1355.50—1355.59

BACKGROUND

Title IV-E agencies need information systems that can evolve with changes in law, policy, practice, data standards, security expectations, technology, and service-delivery needs. In some cases, an automated function that was previously developed with federal financial participation may no longer adequately support program operations, data quality, interoperability, modularity, reporting, analytics, security, usability, or maintainability. ACF recognizes that responsible modernization may require replacing or substantially re-engineering functions that was previously in an approved APD. Replacement is not automatically impermissible duplication. Instead, ACF will consider whether the proposed automated function materially improves or replaces the existing function, avoids unnecessary parallel operation, complies with applicable CCWIS requirements, and is cost allocated appropriately when determining whether the replacement is allowable.

INFORMATION

Clarification of CCWIS Duplication

The CCWIS duplication requirements (§§ 1355.52(a)(3) and (i)(1)(iii)(B); 1355.57(a)(2)(ii) and (b)(ii)) should be applied to prevent unnecessary overlapping systems and duplicative federal investment. It should not be interpreted to require agencies to preserve outdated, inefficient, poorly integrated, or insufficiently modular technology solely because that technology was previously funded. ACF will not treat a proposed automated function as impermissible duplication solely because a title IV-E agency previously received FFP for a related function.

A proposed replacement, modernization, consolidation, or substantially improved module may be allowable when the agency demonstrates that the proposed investment:

1. Supports title IV-B or title IV-E program purposes and applicable CCWIS requirements;
2. Meets applicable CCWIS design requirements, including modularity and reuse;
3. Addresses documented limitations in the existing function;
4. Provides a material improvement over the existing function;
5. Includes a plan to retire, consolidate, integrate, or limit the legacy function;
6. Avoids unnecessary long-term parallel operation;
7. Is justified through the APD or APD update, as applicable; and
8. Is cost allocated appropriately.

Working Definition of Duplication

Duplication may exist when two automated functions perform substantially the same business purpose for the same users, same workflow, same population, and/or same authoritative data source, and both remain in active operational use without a justified transition, consolidation, integration, or retirement plan (see also Child Welfare Policy Manual (CWPM) §§ 6.10A #13 and 6.16A #10). Attachment B provides illustrative examples of modernization and duplication scenarios.

Modernization and Replacement of Previously Funded Functions

A title IV-E agency may determine that an existing automated function is no longer sufficient to meet current program, operational, technical, or data needs. Examples include functions that are difficult to maintain, built on outdated or insecure technology, poorly integrated, unable to support reliable data exchange or reporting, inconsistent with current practice, or insufficient to support modular reuse or responsible analytics. In these circumstances, a replacement or modernization effort may be appropriate if the agency documents why replacing, consolidating, or substantially re-engineering the function is more efficient, economical, effective, or necessary than continuing to maintain or enhance the existing function.

Material Improvement

A proposed replacement or modernization should demonstrate a material improvement over the existing function. A material improvement is more than a cosmetic redesign, minor interface change, or duplicative rebuild of existing capability. It may include meaningful improvements to program operations, data quality, authoritative data sources, auditability, modularity, interoperability, security, privacy, scalability, maintainability, reporting, analytics readiness, technical debt, or long-term operating costs.

Modular Design as a Strategy to Avoid Duplication

When building a CCWIS, title IV-E agencies must approach modernization through modular design (§ 1355.53(a)(1)). Modular design helps agencies avoid future duplication by creating reusable components, shared services, and clear interfaces that can support multiple workflows, programs, and reporting needs. Modular or reusable components may include services for person search, provider management, eligibility and business rules, document management, identity and access management, notifications, data exchange, data quality, reporting, analytics, financial functions, placement matching, case assignment, audit logging, and security monitoring. A modular approach can reduce duplicative development and data entry, promote reuse and interoperability, and make future modernization more efficient.

Data Quality and Analytics Readiness

High-quality data is foundational to effective CCWIS operations and to the next generation of child welfare technology. Modern, modular systems that capture accurate, timely, complete, and well-governed data can help agencies improve casework, supervision, reporting, program monitoring, continuous quality improvement, interoperability, and decision support. ACF encourages title IV-E agencies to consider how CCWIS modernization can position them to take advantage of predictive analytics, predictive risk modeling, and other advanced decision-support tools. These technologies help agencies use data more effectively to identify needs, support caseworkers, improve placement decisions, strengthen prevention efforts, and make more informed decisions for children and families. Predictive analytics is most valuable when it is built on strong system infrastructure and reliable data. Modernization efforts that improve structured data capture, reduce duplicate or conflicting records, establish authoritative data sources, strengthen data governance, and enhance auditability can create the foundation agencies need to use predictive tools effectively. As ACF continues to support state innovation through efforts such as the Child Welfare Technology Incubator and predictive analytics funding opportunities, agencies are encouraged to view data quality and modular modernization as strategic investments in better decision-making. Modern systems with reliable data can help agencies use predictive analytics and risk models to provide caseworkers and agency leaders with timely, actionable information that supports child safety, caseworker decision-making, and improved outcomes for children and families.

Documentation Considerations

When proposing replacement, modernization, consolidation, or substantial improvement of a previously funded or related automated function, the title IV-E agency must provide sufficient documentation through the APD process, as applicable (CWPM §§ 6.10A #3, 12; 6.10B #4; and 6.11). The documentation should describe the existing function, proposed function, business need, applicable CCWIS requirement, prior federal funding, material improvement, modular design and reuse approach, data quality benefits, cost allocation, and governance or risk management considerations. If the proposed function overlaps with an existing function, the agency should also describe how unnecessary duplication will be avoided, including any retirement, consolidation, integration, read-only, or time-limited parallel operation plan. Attachment C provides a suggested documentation checklist.

INQUIRIES: Child Welfare Technology Incubator Team ccwis@acf.hhs.gov, creighton.cathey@acf.hhs.gov.

Disclaimer: Information Memoranda (IMs) provide information or recommendations to states, Indian tribes, grantees, and others on a variety of child welfare issues. IMs do not establish requirements or supersede existing laws or official guidance.