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  DFCS Online Policies & Procedures

  DFCS Online Policies & Procedures

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Handbook 13: Cross Program Protocols
13-14 Foster Youth Credit Reports
Cross Program Protocols
13-14 Foster Youth Credit Reports
Reference Points
Overview
Requesting Credit Reports on Behalf of Foster Youth aged 16 and 17
Providing Assistance to Non-Minor Dependents with Requesting Credit Reports
Assistance with Interpreting Credit Reports and Resolving Inaccuracies
Confidentiality of Credit Reports
Closed Cases
How to Document Credit Report Information in CWS/CMS
Other References


Reference Points
Effective Date:

2/28/2014

Last Updated: July 11, 2014
 Legal Basis:
Popup Window

California Department of Social Services (CDSS) All County Letter (ACL) #14-23: Foster Youth Credit Reports

Popup Window Child and Family Services Improvement and Innovation Act (Public law (P.L.) 112-34)
Popup Window California Welfare and Institutions Code (W&IC) Sections 10618.6 and 16501.1
 Non CWS/CMS Forms:
MS Word
 CWS/CMS Forms:
PDF


Overview  

On September 30, 2011, P.L. 112-34, the Children and Family Services Improvement and Innovation Act, was signed by President Obama. In part, it requires that each foster youth who has reached age 16 receive a free copy of any credit report each year until discharged from care. It also requires the foster youth to receive assistance in interpreting and resolving any inaccuracies in the credit report.

On May 28, 2012, the Administration for Children and Families issued Program Instruction No. ACYF-CB-PI-12-07, which, along with providing implementation guidance, clarified that the foster youth must receive credit reports from all three nationwide Credit Reporting Agencies (CRAs) (i.e., TransUnion, Equifax, and Experian).

On September 30, 2012, California Senate Bill No. 1521 (Chapter 847, Statutes of 2012) was chaptered, which amends Welfare and Institutions section 10618.6 to comply with federal law. It requires the County Welfare Department and County Probation Department, or the California Department of Social Services (CDSS) (if an electronic batch request process is available), to request a credit report from each of the three CRAs annually on behalf of each youth in foster care, aged 16 and 17, while under court jurisdiction.

 

It also requires the county agency to assist NMDs in requesting the three credit reports (by accessing www.annualcreditreport.com) and to ensure the minor foster youth and NMDs receive assistance in interpreting and resolving any inaccuracies in their credit reports.

 

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Requesting Credit Reports for Foster Youth Aged 16 and 17  

Each quarter, the California Department of Social Services (CDSS) will extract information from the Child Welfare Services/Case Management System (CWS/CMS) on all youth in foster care, aged 16 and 17, in order to obtain credit inquiry results and inform counties as to which credit reports, if any, they must request. 

The information will include specific data elements needed by three credit agencies, TransUnion, Experian, and Equifax in order to generate a notice that specifies whether or not credit history exists. The CDSS will transmit the data to each Credit Reporting Agency (CRA) by accessing a website operated and maintained by the CRA and uploading a file containing the necessary data.   

Upon receiving responses from the CRAs, CDSS will produce a list for each participating county that identifies, by case IDs, the foster youth aged 16 and 17 who either have or do not have a credit report from each CRA. The lists will be sorted by participating county and will be posted on the Child Welfare Data County extranet site.

 

Note:

Minors should not have a credit report. When there is an indication of a credit report, as identified on the lists posted on the extranet site, the county/DFCS must request the credit report directly from the appropriate CRAs.

 

The majority of youth will not have an account, and the existence of an account on a foster youth’s credit report does not necessarily indicate that there is an inaccuracy or that the foster youth is a victim of identity theft.

The Social Work Coordinator I (SWCI) in the Independent Living Program (ILP) Unit will: 

  • Receive the extract list for youth aged 16 and 17.
  • When there is an indication of a credit report, as identified on the lists posted on the extranet site, the SWCI must request that credit report directly from the appropriate CRAs.   
  • Contact the assigned social worker and inform that the youth has a credit report.
  • Assist in interpreting the credit information with the assigned social worker and youth.
  • If an account needs to be resolved, will notify Legal Advocates for Children and Youth (LACY) who will have the youth sign an authorization letter requesting assistance with resolving the account. LACY will return the authorization to the SWC I who will then forward a copy to the social worker.   
  • Document in CWS/CMS that the youth received assistance in interpreting credit reports and reviewed the credit report with the youth.
  • Contact the youth and provide him/her with a copy/copies of his/her credit report at no cost to the youth. Inform the youth that this is a confidential document and that the credit report(s) can be kept securely in the office of the Non- Minor Dependent Supervisor.

Note:

For any child/youth under the age of 16 if there is a reasonable suspicion that the youth has been a victim of identity theft, the social worker can contact the Social Work Coordinator I to obtain the credit reports, review and assist with further information to resolve any discrepancies or have the credit repaired. The Social Worker Coordinator I will have the youth//parent/guardian complete the release of information and follow the same procedures for youth aged 16 and 17.

 

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Providing  Assistance to Non-Minor Dependents (NMD’s) with Requesting Credit Reports  

Understanding financial management and the risk of identity theft is vital as the Non-Minor Dependent (NMD) becomes more independent. It is best practice for the social worker to explain to the NMD why obtaining a copy of one’s credit report is important.

The process of obtaining credit reports for NMDs is different than for minors. Whereas requests are made on behalf of minors, NMDs may request and receive the credit reports themselves.

The assigned social worker must ensure the NMD receives assistance in requesting and reviewing the reports. The level of assistance the NMD receives should be based on the NMD’s developmental needs and may include, but is not limited to, the following:

  • Referring the NMD to the www.annualcreditreport.com website, where the NMD may obtain and complete the request form, obtain the telephone number for requests, or use the secure website to request the credit reports,
  • Assisting the NMD with accessing the www.annualcreditreport.com website and completing the credit report application  online,
  • Providing the NMD with the telephone number (contact the Social Work Coordinator I) for  making a request and assisting him or her through the call, as needed, or
  • Securing written authorization from the NMD for the child welfare or probation agency to receive the credit reports on his/her behalf. Minor and NMD required to sign a consent to resolve credit inaccuracies. 
  • Document the credit report information in CWS/CMS.  See section below “How to document Credit Reports in CWS/CMS”. 
 

The social worker will contact the Social Work Coordinator I in the Independent Living Program unit if there is a discrepancy in the report and the NMD needs assistance in interpreting and resolving the inaccuracies.   

The Social Work Coordinator I in the Independent Living Program unit will: 

  • Will have Legal Advocates for Children and Youth contact the NMD and sign an authorization letter requesting assistance with resolving the account. Legal Advocates for Children and Youth will return the authorization to the Social Work Coordinator I who will then forward a copy to the social worker.  

If an NMD is resistant to requesting a credit report:

  • The social worker should continue to work with the NMD and address issues related to the credit report results during monthly face-to-face visits.
  • It would be considered best practice to help educate the NMD about the value of being knowledgeable about his or her own credit.

The objective of obtaining the credit reports could be a goal in the NMD’s Transitional Independent Living Plan (TILP). The TILP also provides an opportunity to document which individuals will assist the NMD with obtaining and interpreting the credit reports and resolving any inaccuracies.

 
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Assistance with Interpreting Credit Reports and Resolving Inaccuracies  

Federal and California laws require that foster youth receive assistance in interpreting the credit reports and resolving any inaccuracies. The county welfare or probation department is responsible for ensuring minor youth and NMDs receive assistance with interpreting the credit reports and resolving any inaccuracies.

 

Foster Youth:

The Social Work Coordinator I will assist the social worker and foster youth in interpreting the credit reports.

If an inaccurate account exists on a foster youth’s credit report, the Social Work Coordinator I will refer the youth to Legal Advocates for Children and Youth (LACY) to sign an authorization letter to request the assistance to resolve or repair credit discrepancies. 

  • Once the authorization letter is signed LACY will assist the youth with interpreting the credit report and clearing any inaccuracies.

 

Non-Minor Dependents:

 The assigned social worker for the NMD will contact the Social Work Coordinator I for assistance with discrepancies in the credit report.

The Social Work Coordinator I will refer the youth to LACY to sign an authorization letter to request assistance to resolve or repair credit discrepancies.

  • Once the authorization letter is signed, LACY will assist the youth with interpreting the credit report and clearing any inaccuracies.

 

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Confidentiality of Credit Records  

The credit report is a confidential document and must not be attached to the court report, any other court filing or be otherwise distributed.

The social worker must take necessary steps to prevent improper disclosure or misuse of information contained in the credit report.

Note:

Foster Youth and Non-Minor Dependents should be advised about the sensitive

nature of credit information and how to keep the credit report safe.

Foster Youth Credit Reports:

  • The Social Work Coordinator I will give the original and all copies of the Foster Youth Credit Reports to the Non-Minor Dependent Supervisor who will lock/secure them in the supervisor’s office.

NOTE: The credit reports will not be kept in the case file.

 

Non-Minor Dependent Credit Reports:

  • Non-Minor Dependents can keep copies of their own credit reports, or if they prefer they can be kept locked and secure in the office of the Non-Minor Dependent Supervisor.

 

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Closed Cases  

For Minor Foster Youth and Non-Minor Dependents:

 

Cases that have had Dependency dismissed and closed and  have an indication of a credit report, as identified on the lists posted on the extranet site, the Social Worker Coordinator I (SWCI) must request that credit report directly from the appropriate CRAs.  

If an account needs to be resolved, the SWCI will notify Legal Advocates for Children and Youth (LACY) who will contact the youth and have the youth sign an authorization letter requesting assistance with resolving the account. LACY will work with the youth in resolving the discrepancy and provide the youth with a copy of the credit report. 

LACY will return the authorization to the SWC I who will then forward a copy to the SWCI who will:

  • Call for the closed case and file the authorization,
  • Document in CWS/CMS that the youth received assistance from LACY in interpreting credit reports, assisting with resolving any discrepancies and provided the youth with a copy of the credit report.   

 

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How to Document Credit Report Information  in CWS/CMS      

For Minor Foster Youth, the Social Work Coordinator I will document the following necessary information in CWS/CMS:

• Credit reports that were requested from all three CRAs at no cost to the youth; Credit

   reports were received from the CRAs and the date(s) received;

• Credit reports that were provided to the youth and the date(s) provided;

• If credit reports contain any accounts, how the county ensured the youth received

   assistance with interpreting credit reports and resolving inaccuracies, including

   referrals made for assistance and any resulting actions; and

• Any communication from CDSS indicating youth does or does not have credit report, as

   determined by the CRAs.

 

For Non-Minor Dependents (NMD’s) the assigned social worker will document the following necessary information in  CWS/CMS:

• Efforts the county has made to assist the NMD in obtaining credit reports;

• If credit reports contain any accounts, how the county ensured the NMD received

   assistance with interpreting credit reports and resolving inaccuracies, including

   referrals made for assistance and any resulting actions;

• Any barriers to obtaining credit reports and steps that will be taken to resolve them;

   and,

• If NMD refuses to request credit reports, the efforts made to assist the NMD in

   requesting the credit reports and understanding the value of being knowledgeable

   about one’s own credit.

 

To Record Credit Reports in CWS/CMS

Please note this is a temporary solution to record Credit Reports in CWS, new fields will be created in November 2014. 


Credit Checks for Minor Foster Youth and Non-Minor Dependents will be completed annually.

 

      

 

 

 

1.  Click on the Orange Button

2.  Click on the plus sign to Create New Contact

 

 

 

1. When the dialogue box pops up, select ALL the children. 

2. Click Ok.

 

contact page

This page is the basic foundation of all contacts and the yellow fields must be completed.

1) Staff person

2) Start Date and End Date

3) Contact Purpose (Deliver Services to

    Client)

4) Method (In Person, Telephone)

5) Location

6) Status (completed, attempted, or

    scheduled)

7) Participants, only the people present

    (include clients, collaterals, service

    providers, current caretaker, and

    others).

 

 

On the Associated Services Tab, Click on the plus sign to add a new service.  All the yellow fields must be completed.

1.  Start Date (date of service)

2.  Service Category (Case Management  

      Services)

3.  Service Type (Other)

4.  Service Recipient (Child receiving

     Service)

5.  Provider

 

 

6.  Narrative:

For minor foster youth, the following must be documented in CWS/CMS:

• Credit reports were requested from all  

   three CRAs at no cost to the youth;

• Credit reports were received from the

   CRAs and the date(s) received;

• Credit reports were provided to the

   youth and the date(s) provided;

• If credit reports contain any accounts,

   how county ensured youth received

   assistance with interpreting credit

   reports and resolving inaccuracies,

   including referrals made for assistance

   and any resulting actions; and

• Any communication from CDSS

   indicating youth does or does not have

   credit report, as determined by the

   CRAs.

 

For NMDs, the following must be documented in CWS/CMS:

• Efforts the county has made to assist

   NMD in obtaining credit reports;

• If credit reports contain any accounts,

   how county ensured NMD received

   assistance with interpreting credit

   reports and resolving inaccuracies,

   including referrals made for assistance

   and any resulting actions;

• Any barriers to obtaining credit reports

   and steps that will be taken to resolve

   them; and

• If NMD refuses to request credit

   reports, the efforts made to assist the

   NMD in requesting the credit reports

   and understanding the value of being

   Knowledgeable about one’s own credit.

 

  

 

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Resources  

Information on Youth Credit Reports can be found on the following websites:

Youth and Credit: Protecting the Credit of Youth in Foster Care:

http://www.aecf.org/~/media/Pubs/Topics/Child%20Welfare%20Permanence/Other/YouthandCredit/YouthandCredit.pdf

National Foundation for Credit Counseling:

http://www.nfcc.org/rpc/member_locator/find.cfm

The United States Department of Justice List of Approved Counseling Agencies:

www.justice.gov/ust/eo/bapcpa/ccde/cc_approved.htm

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Contacts  

Matt Gibson, Social Work Coordinator I, Independent Living Program Unit

Telephone: (408) 501-6825  

Email: Matt.Gibson@ssa.sccgov.org

Mary Bianchi, Social Work Supervisor, Non-Minor Dependent Unit

Telephone: (408) 501-6890

Email: Mary.Bianchi@ssa.sccgov.org

 

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Other References  
PDF

OPP 4-3, Transitional Independent Living Plan (TILP)

 

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