The credit check requirement for youth in foster care - Q&A ON IMPLEMENTATION
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the credit
check
requirement
for youth in
foster care
Q&A ON IMPLEMENTATION
FEBRUARY 2015The credit check requirement is an important step to ensure that only help with implementation of the credit check mandate but
young people leave foster care with clear credit to increase their may also serve as excellent resources for youth as they age out of
odds of achieving financial stability. Yet states, counties, tribes and foster care;
credit reporting agencies (CRAs) have faced numerous challenges to • Complexities of dealing with all three CRAs, which has created
implementation that continue to stymie efforts to be fully compliant. numerous lag times given the differing contacts, procedures,
These challenges include, but are not limited to: requirements, and offerings of the CRAs; and
• Contracting provisions that states, counties, and tribes may have • Changes in federal law, specifically recent legislation lowering the
difficulty meeting, such as provisions governing information age to 14, which requires agencies and tribes to make changes to
system requirements, confidentiality assurances, and permissible how they are currently conducting their credit checks—including
uses for the reports; possible revisions to existing contracts with the CRAs and some
• Need for training and lack of capacity among frontline staff and state laws.
administrators alike about credit issues, how to dispute credit
problems, how to work with the CRAs, how to engage partners, Despite these challenges, state and local agencies are moving
etc. Additionally, CRAs lack understanding of how child welfare forward incrementally and, along the way, are identifying credit
agencies work and the unique issues facing youth transitioning problems that are being addressed. We hope this guide can serve as
from foster care; a resource for those who are new to the issue or are still struggling
to fully implement the requirement so that no young person leaves
• Lack of robust partnerships between child welfare agencies and
foster care with unidentified credit issues.
community-based nonprofit institutions that may be able to notTable of Contents
1. BACKGROUND 2
2. FEDERAL GUIDANCE 2
3. WORKING WITH THE CRAS 4
4.
DEVELOPING STATE POLICY 6
5. DISPUTING ERRORS ON THE CREDIT REPORTS 7
6. RECOMMENDATIONS TO IMPROVE THE
IMPLEMENTATION OF THE CREDIT CHECK
REQUIREMENT 9Q&A ON IMPLEMENTATION OF THE CREDIT CHECK REQUIREMENT
1. BACKGROUND C. How many children does this
requirement impact?
A. What is the credit There is no national data on the incidence of
check requirement? identity theft or credit problems for youth in
The credit check requirement is a provision and transitioning from foster care. One pilot
in federal law1 enacted in 2011 that requires in Los Angeles found that about 5% (104
public child welfare agencies to provide credit out of 2,110) of 16 year olds in the pilot had
reports to youth in foster care at age 16 and credit issues. In a recent survey conducted by
up and address any inaccuracies found in ChildFocus and Credit Builders Alliance3,
their reports. More recent legislation enacted 5% of respondents estimated that evidence
in 2014 lowered the age to 142, and the U.S. of ID theft existed on the credit reports they
Department of Health and Human Services obtained for 10% or more of the young people
(HHS) is developing a program instruction they serve, and 60% estimated that ID theft or
to guide implementation by September 2015. errors existed on in 1-9% of the credit reports.
The credit check requirement also applies Even at the conservative estimate of 5%, this
to young people in foster care beyond their would amount to 2,700 16- and 17-year-olds
18th birthday. in foster care in 2012. As required under the
new law, 5% of the young people between the
B. Why did Congress pass the credit ages of 14 and 17 who are in foster care would
check requirement? amount to almost 4,800 children, while 5%
The requirement to check the credit of of the young people in foster care up to age 21
youth in foster care responds to stories from would impact almost 5,700 children.
young people who transitioned from foster
care with credit that had been compromised
due to identity theft or credit errors. Some
of these stories suggest that their credit was 2. FEDERAL GUIDANCE
compromised while in care, while other
credit problems occurred before they entered A. What guidance has HHS issued
care. Regardless, young people have reported about the credit check requirement?
difficulty renting an apartment, getting a HHS has issued two program instructions and
job, or obtaining a student loan due to these two information memoranda related to the
credit issues. Policymakers wanted to ensure credit check requirement.
that young people who leave foster care do • CB-PI-11-09 required states to submit a
not have to face any negative consequences plan amendment by January 31, 2012, for
of credit problems on their own and can start how to comply with the new provision.
their adult lives with a clean credit slate.
1 The Child and Family Services Improvement Act, P.L.
3 The ChildFocus and Credit Builders Alliance survey was sent
112-34.
to the Credit Check Learning Community, a peer network of state
2 The Preventing Sex Trafficking and Strengthening Families and local child welfare agencies across the country. Results of the
Act, P.L. 113-34. survey can be found at childfocuspartners.com
2• ACYF-CB-IM-12-02 extended the Credit reporting agencies (CRAs) are
deadline for the state plan amendment companies that collect, store, analyze,
to August 13, 2012. The reason for the summarize and sell credit-related information
extension was to give HHS more time to on individuals and firms for a fee. Under
provide more information on the process federal law, adults 18 and older can obtain one
for checking credit for minors given that free credit report per year from each of the
the use of the government-sanctioned three largest CRAs—Equifax, Experian and
annualcreditreport.com site is only TransUnion—through AnnualCreportReport.
available to individuals 18 and older. com, the only government-sanctioned site
• ACYF-CB-PI-12-07 provides additional for consumers to access their free credit
information on how to comply with reports. Unfortunately, minors cannot use
the provision and requires child welfare annualcreditreport.com to access their reports
agencies to obtain credit reports for because, as minors, they are not legally able
minors from all three credit reporting to enter into contracts in most states, and
agencies. therefore should not have a credit report.
• ACYF-IM-14-03 outlines case plan Not all businesses or creditors report to
requirements for youth 14 and older, each of the three CRAs, which means that
including the requirement to provide obtaining a report from one of the CRAs does
a copy of an annual credit report and not guarantee that all possible credit issues
address any inaccuracies found in have been identified. Therefore, obtaining
the report. reports from all three CRAs is the best way
• HHS issued a letter to state child to ensure any credit problems are identified
welfare directors on December 5, 2014, before young people leave foster care. This
encouraging them to do more frequent means that child welfare agencies that want
credit checks for youth in foster care, to to obtain reports electronically must become
consider checking the credit for all young credentialed by and complete contracts with
people in foster care and to explore the all three CRAs (see 3(C) below).
use of credit freezes and fraud alerts for
those young people for whom identity
C. What is the role of other federal
theft or other credit issues are identified.
agencies, such as the Consumer
Financial Protection Bureau and the
B. Why do the federal regulations Federal Trade Commission?
require child welfare agencies and tribes The Consumer Financial Protection Bureau
to request reports from all three credit (CFPB) was created under the Dodd-Frank
reporting agencies? Act of 2010 to consolidate the federal
government’s approach to consumer financial
Minors cannot use annualcreditreport.com to access their reports
because, as minors, they are not legally able to enter into contracts
in most states, and therefore should not have a credit report.
3protection. As the regulator of the credit also prove that they have the right to do
reporting agencies, the CFPB has advised so on behalf of the youth in question by
HHS on implementation issues and has submitting court documentation that the
produced materials to support state efforts to young person is in foster care or a letter
dispute credit issues for youth in foster care. on agency letterhead. This process may be
Together with the Federal Trade Commission more efficient for small counties or states
(FTC), which also conducts a range of with smaller caseloads.
activities related to consumer financial • The electronic batch process allows
protection, the CFPB has been an invaluable agencies to send a CSV spreadsheet—
resource to child welfare agencies on consumer similar to an Excel spreadsheet—through
protection laws, including the Fair Credit each CRA’s online portal for creditors
Reporting Act, and the practices of credit and other businesses with a permissible
reporting agencies. purpose under federal law to pull credit
The FTC has also advised HHS on credit reports. Those using the electronic batch
issues and has numerous resources related process must be credentialed by each CRA
to preventing and addressing identity theft as having all the necessary procedures
in particular. CFPB and FTC resources in place to access their respective online
are available on Resources to Support portals, which requires a contract between
Implementation of the Credit Check the child welfare agency and the credit
Requirement for Youth in Foster Care. reporting agency. The CRA runs the names
and other relevant information (e.g., Social
Security number) for all the young people
listed on the spreadsheet, and if anything
3. WORKING WITH THE CRAS comes up, a credit report is delivered
electronically to the agency (see Accessing
A. What options do child welfare Credit Reports through the CRA Online
agencies and tribes have for Portals for more information about the
obtaining reports from the credit process). The child welfare agency can
reporting agencies? then refer any credit report that may exist
Child welfare agencies have two options for
for a young person to the appropriate staff
requesting credit reports:
person or contracted agency to review and
• The manual process is a relatively determine if there are credit issues that
traditional approach by which agency staff need to be disputed or evidence of ID theft
send a written request by mail, email or fax that needs to be addressed. The absence
to the CRAs for individual young people. of a report for a minor simply means that
This can be done in a centralized fashion (a there are no reported credit issues.
county, region or state administrator makes It should be noted that for youth younger than
the request) or by frontline staff (foster care 18, the presence of a credit report is in and of
or independent living worker) on behalf itself a red flag. Legally, minors cannot enter
of young people in their caseload. When into contracts, so they generally should not
requesting reports through the manual have any type of credit report, although there
process, the child welfare agency will are cases in which the existence of a credit
receive any consumer disclosure reports (see report does not necessarily indicate erroneous
3(B) below) that exist for minors so they or fraudulent activity (one example is if a
can be reviewed and disputed if necessary. minor has legitimately been added by a parent
Those conducting manual requests must or guardian as an authorized user on a credit
4It should be noted that for youth younger than 18,
the presence of a credit report is in and of itself a red flag.
card account). CRAs will flag credit reports Division Reports, see the Credit Builders
that exist for minors in foster care to determine Alliance reference guide for child welfare
if they were victims of identity theft or other agencies, Accessing Credit Reports for
fraudulent activities and to begin the process of Foster Youth: A Reference Guide for Child
disputing the reports. Welfare Agencies.
B. What can agencies expect to get When an agency receives a Business Division
back when a credit issue is identified? Report for a young person for whom a credit
Typically, agencies that use the manual process issue has been identified, they should consider
will receive a Consumer Disclosure Report requesting a Consumer Disclosure Report
(also called a Consumer Education Report), from the CRA(s) in question. This will allow
which is similar to what a consumer will them to show the young person what is on
get if he or she requests the report through his or her report in a format that is easier to
AnnualCreditReport.com. Consumer understand and more consistent with what he
Disclosure Reports are relatively easy to read or she will receive when requesting it through
and include all the information needed to link AnnualCreditReport.com once he or she is
credit problems back to the original creditor 18 and older.
for dispute purposes. Consumer Disclosure C. How do child welfare agencies
Reports are also what young people can use become credentialed by the credit
to monitor their credit once they are over 18, reporting agencies to submit electronic
so it’s important they become comfortable batch requests online?
knowing how to understand them. A The first step toward obtaining credit reports
disadvantage with Consumer Disclosure through the online portal is to become
Reports is that they may be difficult to access credentialed by each of the three main CRAs
if an individual doesn’t have all the required (Experian, Equifax and TransUnion). The
information to get through security questions, credentialing process allows the CRAs to
such as “last known address,” which might be conduct their due diligence to ensure the
challenging for young people who have moved agencies have a permissible purpose for pulling
frequently while in care. the reports. Once credentialed, a child welfare
Agencies using the online portal will receive agency must enter into a contract with the
a Business Division Report if a credit report CRAs to outline the requirements of the
exists, which is what creditors, employers, credit reporting process. Contracts address
landlords, and other businesses receive when the purpose for pulling reports, the scope of
they request a credit report for an individual. work and responsibilities of each party (the
Business Division Reports may be more CRAs and the child welfare agency), including
difficult to interpret and may not include all confidentiality of information, data handling/
the information needed to dispute a report sharing requirements and safeguards, fees and
directly with an original creditor. For more payments, warranties and due process issues,
on the advantages and disadvantages of and more. Once contracts have been finalized,
Consumer Disclosure Reports and Business
5the child welfare agency is authorized to TransUnion and Experian provide these credit
pull reports. reports for free, which means they are waiving
Child welfare agencies in state-administered the typical fee for use of the online portal.
states can become credentialed at the state
level. Those in county-administered states
likely must become credentialed at the county 4.
DEVELOPING STATE POLICY
level. Once credentialed, the state or county
can determine who within the agency has the State and/or county policy is essential to
authority to request the reports on behalf of guide the process for securing credit reports
an individual or a group of young people. for youth in foster care, disputing any
inaccuracies, and helping young people
D. How difficult is the understand what is on their credit report, if
contracting process? they have one, and how to protect their credit
States and counties report that the contracting in the future. Policy should, at a minimum,
process is the most complex and time- address the following:
consuming aspect of the credit check
mandate. Certain standard contractual A. Who is responsible for accessing the
language may require modification before credit report?
contracts can be finalized by the agencies, Policy should be clear as to whether the agency
and they typically have to be reviewed by a is using a manual or electronic process to
state office that handles contracts and/or the access reports. If using the manual process,
attorney general’s office. While states report the policy should spell out who is responsible
few problems working with the CRAs, the for accessing the report and how that person
contracting process has at times felt daunting will be notified when it is time to process
and has created lag times for agencies trying the credit check. If the agency is sending a
to implement the credit check requirement. spreadsheet through an online CRA portal,
Given the complexities of the contracting the policy should include clear instructions
process, states may find it useful to reach about who is responsible for producing the
out to other child welfare agencies across the spreadsheet, who will send it to the CRA,
country for advice on their experiences. when it will be sent, and who will review any
reports that come back.
E. How much does it cost to get credit
reports for youth in foster care? B. How does the process differ for
By law, individuals are entitled to receive minors vs. young people ages 18
one free annual Consumer Disclosure Credit and older?
Report every year from each CRA. However, Agency policy should be clear that the
the CRAs typically charge for Business process for requesting reports may differ for
Division Reports, which are what child welfare youth between ages 14 and 17 and those
agencies will receive if they request electronic who are 18 and older. Young people 18
reports through the online portals. According and over should be able to access their own
to correspondence with states, Equifax, consumer disclosure report for free through
By law, individuals are entitled to receive one free annual
consumer disclosure credit report every year from each CRA.
6annualcreditreport.com. Policy supporting this until the issues are cleared and/or there is clear
is recommended—with appropriate assistance documentation of the steps taken to clear their
of an adult—to ensure that the young adult credit so they have the tools to explain these
knows how to pull and review his or her issues to employers, creditors and others in
own credit report in the future. However, the future.
it may be difficult for a youth to answer all For more suggestions on disputing reports, see
of the security questions required to access section 5.
his or her report. Agencies should consider
instituting an alternative procedure, such as E. How should child welfare agencies
directly requesting older youths’ credit reports involve young people in the process?
in batches or individually through the CRA Older youth need to understand what a credit
portals, if possible. report is, why it is important, how to protect
their credit, and the actions child welfare
C. Who is responsible for addressing agencies are taking to check their credit and
any inaccuracies? clear reports if there are any inaccuracies.
The legislation clearly states that child welfare Policy should clearly set expectations for
agencies are responsible for addressing any involving youth in the process and how to
inaccuracies found on the credit reports. This determine their developmental readiness to be
should apply to minors as well as youth 18 involved.
and over who are still in foster care. Policy
should articulate who is responsible for F. What credit-related training should
this process. child welfare agencies offer to staff and
others responsible for youth in care?
D. What are the steps for The CBA-ChildFocus survey results
disputing inaccuracies? suggest that many caseworkers have not
Policy should outline the steps for addressing received sufficient training to fulfill their
inaccuracies and the importance of a clear responsibilities under the credit check
plan for ensuring problems are resolved mandate. Those who did receive training cited
before youth leave foster care. Disputing the 2014 webinar series as the only training
errors on credit reports takes time, patience, they have had. It’s critically important that
and understanding of the resources available caseworkers have the tools and knowledge
to support those who are trying to clear needed to talk to young people about credit
credit records for youth. The Credit Builders and dispute credit issues. Some suggested
Alliance and ChildFocus’ 2014 six-part resources for training are included in
webinar series includes a number of resources Resources to Support Implementation of
to support this process, including advice about the Credit Check Requirement for Youth in
disputing with both the CRAs and businesses, Foster Care.
sample dispute letters, whether to institute a
credit freeze, whether to file a police report
in instances of identity theft, and more. This
series can be accessed on CBA’s website. 5. DISPUTING ERRORS ON THE
CREDIT REPORTS
In rare situations, issues of serious identity
theft may not be resolved by the time a young
A. What’s the best process for
person leaves foster care. In these situations,
disputing errors on credit reports?
policy should be clear about expectations for
While every situation is different, there are
linking young people with those who can help
some basic guidelines for disputing credit
them continue to dispute the credit issues
7reports that every frontline staff member • Template dispute letter for minors and
should know to assist young people with 18+ population
this process: • CBA webinar on disputing credit problems
• Write a letter to the creditor/business: • Credit counseling organizations across
For young people whose credit problems the country who can help with the dispute
were incurred while they were minors, process
writing a letter to this effect with a copy • CBA members across the country who
(never send originals) of their birth can help with the dispute process
certificate to prove their age is often
C. When should a credit freeze or
sufficient to have credit issues cleared.
fraud alert be considered?
• Dispute with creditors/businesses and The HHS letter issued to all child welfare
CRAs: Whenever possible, disputes directors December 5, 2014, encouraged them
should be made simultaneously to CRAs to consider a credit freeze or fraud alert for
and to creditors/businesses. Creditors/ certain young people with credit problems.
businesses that clear credit for a young Considerations for whether to freeze credit or
person are required to inform all CRAs to issue a fraud alert include:
which they report.
• Seek help from experts: When • State law: What is the state law governing
credit freezes and fraud alerts, and how
roadblocks occur, there are experts in most
would those laws impact young people,
communities to assist with this process.
including those who may leave care before
Accredited nonprofit credit counseling
credit issues have been completely cleared?
organizations, some other community-
based nonprofit institutions, and the State • Limitations: Credit freezes and fraud
Attorney General Office have in-depth alerts only protect young people from
knowledge that is sometimes needed to new fraud and do not address the existing
clear credit. fraud that has been identified.
• For particularly serious incidences of • How to unfreeze or turn off a fraud
identity theft or credit errors, a credit alert: Young people in foster care and
freeze may be appropriate. See below for their families are very mobile and may
more information on the pros and cons of cycle in and out of care and various
a credit freeze. placements while in custody. States
considering using these tools should have
B. What resources are available to help very clear policies and procedures to
with the dispute process? ensure a credit freeze can be unfrozen and
Frontline staff and others disputing problems fraud alerts turned off so young people
identified on a credit report should not have can access credit in the future.
to reinvent the wheel. Helpful resources to For more on credit freezes and alerts, visit
support the dispute process include: www.consumer.ftc.gov
While every situation is different, there are some basic
guidelines for disputing credit reports that every frontline staff
member should know to assist young people with this process.
86. RECOMMENDATIONS TO IMPROVE Development of suggested data to
THE IMPLEMENTATION OF THE CREDIT collect to inform implementation, such
as percentage and number of youth
CHECK REQUIREMENT
in care who have credit reports with
There are a number of actions that can and errors and/or ID theft and success rates
should be taken at multiple levels to improve in dealing with both.
the likelihood of success with implementing • Develop a plan for technical assistance.
the credit check requirement. HHS, in consultation with CFPB and
FTC, should develop a plan for continued
A. What additional actions can the technical assistance on implementation to
federal government take to support the be carried out by one or a combination of
credit check requirement? the National Resource Centers. Technical
• Amend existing regulations. HHS assistance plans should include:
should consider amending existing
Growing and facilitating the Credit
regulations to require that states, counties
Check Learning Community (CCLC)
and tribes participating in the online
as a safe space for states, counties and
process contract with only one CRA as
tribes to communicate with each other
a starting point and extend deadlines for
about implementation issues and to
finalizing contracts with the other CRAs.
share resources, including policies,
• Convene a cross-sector working group contracts, forms, training, and data
to address implementation issues. HHS
Supports for frontline staff, including
should convene a working group made up
curriculum on credit issues, clear
of CRAs, child welfare agencies, national
instructions on how to dispute credit
organizations and key federal agencies
issues, the pros and cons of fraud
(i.e., CFPB and FTC) to brainstorm ways
protection and products relevant for
to streamline the credit check process.
youth, state laws on how to freeze
The working group could consider the
credit, etc.
following:
Mechanisms for child welfare agencies
Challenges of lowering the age to
to troubleshoot any issues they have
14 as required in the Preventing Sex
negotiating and finalizing contracts
Trafficking and Strengthening Families
with the CRAs.
Act, including possible revisions to
existing contracts, amendments to laws, Technical assistance on the
IT challenges, challenges of working development of clear state policy to
with younger youth around credit guide implementation.
issues, etc. • Survey the CRAs. CFPB, as the overseer
Ways to streamline the credentialing of CRAs, should survey the CRAs to
and contracting process to ensure that find out what kinds of implementation
contracts are negotiated in a timely and challenges they are facing and continue to
mutually acceptable manner. engage them productively in the process.
The CBA/ChildFocus survey of child
Development of a guide for disputing
welfare agencies yielded many important
credit issues for youth in foster care
insights into implementation, and CRAs
directly with CRAs and creditors/
will likely have additional ideas about how
businesses.
to strengthen the process.
Clearer guidance on the pros and cons
of credit freezes and fraud alerts.
9Understanding how effective and helpful this process is from
the perspective of the young people themselves can help inform
the introduction of greater implementation efficiencies and
effective policies and procedures throughout the process.
• Engage young people in the process. • Get started with one credit reporting
The goal of the credit check mandate is agency. States that have not begun to
to verify the credit status of youth and implement the credit check requirement
help them resolve any errors, identity should begin accessing manual reports or
theft or fraud reflected on their credit develop at least one contract with a credit
reports before they leave foster care. reporting agency for electronic submission
Understanding how effective and helpful to begin helping young people leave care
this process is from the perspective of with clear credit. States that feel they do
the young people themselves can help not have the capacity should reach out
inform the introduction of greater to community partners (philanthropy,
implementation efficiencies and effective banks, nonprofit financial institutions,
policies and procedures throughout the credit counseling organizations, etc.)
process. It can also help uncover new and for assistance.
innovative ideas for empowering youth • Go beyond the requirements of the law.
around credit issues as they transition States should consider a process to check
to adulthood. the credit for all youth in foster care,
• Continued involvement by the CFPB not just those who are 14 and older, and
and FTC. Other federal agencies should should develop age-appropriate policies
develop plans for continued involvement, and procedures for dealing with any issues
informed in large part by regularly that arise.
collected data from the child welfare • Get help. States should develop
agencies and the CRAs on their technical partnerships with those who have
implementation experiences, and by expertise on credit and identity
the experiences of and outcomes for theft issues. Ideas for developing
young people. For instance, the CFPB partnerships include:
should continue to support HHS on its Convene a statewide or local working
regulatory responsibility for the provision group with diverse stakeholders
and develop materials as needed. FTC to discuss ways to help young
should also keep providing technical people learn about and protect
assistance on identity theft, including their credit. This working group can
ways to prevent ID theft and address it go beyond child welfare to include
when it occurs. other youth-serving systems (juvenile
B. What additional action can states, justice, housing, youth employment,
communities and tribes take to support education), community-based financial
the credit check requirement? institutions, and businesses that
10routinely show up as problematic on programs for helping young people with
young people’s credit reports. credit and other financial capability
Develop a partnership with the issues. Drawing on lessons from the Jim
attorney general’s office, which Casey Youth Opportunities Initiative’s
should have expertise on identity theft Opportunity PassportTM, outlined in a
and fraud and can help child welfare bri ef called Building Financial Capacity
agencies troubleshoot with CRAs and for Youth Transitioning from Foster Care,
businesses. Attorney general’s offices these efforts should help young people in
typically have resource materials to foster care practice what they are learning
educate and help protect consumers in real life and use opportunity moments
from harmful financial products, (buying a car, renting an apartment,
scams, and more. first paycheck, etc.) to apply classroom
Work with statewide or municipal knowledge in real life.
entities that exist in many • Engage young people, including
communities to build financial alumni of foster care. States, counties
capability of adults. Many city and and tribes can engage young people in
state treasurer’s offices, governors, and the development of policies and practices
mayors have created special initiatives designed to help them learn about credit,
to empower low-income adults around understand what’s on their credit report,
financial issues, including becoming dispute credit problems and other issues.
safely banked, participating in financial • Engage key businesses. If trends emerge
coaching, and building credit through around the types of business accounts
reporting of payments on loans. Child showing up on youth credit reports (i.e.,
welfare agencies can engage leaders in utility accounts in collections), mostly as
these initiatives to consider a special a result of ID theft, engage directly with
focus on youth in foster care. executives of those companies to try to
• Spread the capacity to help young strengthen internal controls and prevent
people build financial capability. States future ID theft or improve early warning
should develop plans to build knowledge signs that ID theft might be at play.
and skill among foster parents, biological • Ensure young people transition from
parents, youth leaders and others who care with the right tools. At a minimum,
can help young people with credit issues. young people leaving care should have
To accomplish this, states can work with a copy of their consumer disclosure
foster parent associations, non-profit credit report, understand the purpose
organizations, CASAs, etc. Training of checking it regularly, and have basic
and others efforts should building knowledge about the importance of
understanding of how identity theft by building and protecting their profiles in
biological or foster parents impacts the the future.
well-being of youth and strategies to
C. What additional actions can
help young people deal with it. Such
CRAs take to support the credit
efforts should also focus on prevention of
check requirement?
identity theft and future credit problems.
• Streamline the process. CRAs can
• Use Chaffee dollars more strategically. create common forms, spreadsheets, and
States can use funding from the John contracts that can serve as templates
H. Chaffee Foster Care Independence for states, communities and tribes as
Program to develop more effective
11they become credentialed to pull credit for child welfare agencies, including a fact
reports. They should also streamline sheet that describes a step-by-step process
documentation requirements, particularly for completing contracts, obtaining credit
for manual reporting. reports, and disputing errors.
• Build capacity. By now, CRAs likely • Be flexible and responsive. CRAs
understand that the credit check should be as flexible as possible in their
requirement is an unfunded mandate requirements for child welfare agencies.
and that most child welfare agencies do They should also create a single point
not have internal expertise around these of contact who can be responsive to
issues. CRAs might consider some tools their needs.
and resources that are specifically designed
12The project to support implementation of the credit check requirement for youth in foster care was made possible through the generous support of the Annie E. Casey Foundation
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