ICPC - pg. 4

Compliance Timeline

Time frames for completing the steps required for ICPC compliance can be difficult for courts and agencies to implement. The Association of Administrators for the Interstate Compact on the Placement of Children has established a recommended time line for completing the ICPC process. Keep in mind that this is recommended and is non-binding.

There are three categories for placements: placements that do not involve foster home/adoption licensing, placements that do involve licensing, and priority placements. The table below will compare the recommended time lines for each category.

Procedure Licensing not required Licensing required Priority Placement**
Court orders interstate placement 1 day 1 day 2 days
Local agency completes paperwork and forwards it to sending ICPC office Max. 5 working days + 2 for mailing Max. 5 working days + 2 for mailing 3 days
Sending ICPC office reviews paperwork and forwards to receiving ICPC office 3 working days + 2 for mailing 3 working days + 2 for mailing 2 days
Receiving ICPC office reviews paperwork and forwards to local receiving agency 3 working days + 2 for mailing 3 working days + 2 for mailing 20 days, if more than 30 days receiving ICPC office is out of compliance.
Receiving local agency completes home study and recommendation paperwork sending results to receiving ICPC?office 30 days + 2 for mailing *ASFA: 3 to 6 months or more
Receiving ICPC?office reviews material, approves or denies placement and sends results to sending ICPC office 3 working days + 2 for mailing 3 working days + 2 for mailing
Sending ICPC office reviews material and approves or denies placement 3 working days + 2 for mailing 3 working days + 2 for mailing 1 day
Total time 60 days 120 to 210 days or more 28 days, 38 max

*The Adoption and Safe Families Act has two requirements that greatly increase the time it takes to complete the home study process.

  1. Before any child can be placed into a Title IV-E subsidized foster care or relative placement that placement must be licensed. This process can take between two and four months. The licensing process cannot be waived just because the child is being placed with a relative. But ICPC does approve of a child being placed with a relative going through the licensing process as long as the relative foregoes any Title IV-E payments until after they have been licensed.

  2. All prospective foster or adoptive parents must undergo a criminal background check. Federal background checks can take up to four months for completion. If a receiving agency initiates the licensing process and the background check at the same time, this can reduce the time line to two to four months. If it does not attempt to complete both requirements at the same time, it could take as long as eight months to complete the fifth step in the review process.

**To be identified as a priority placement, a case must meet some requirements. A priority placement cannot be used when:

  • A placement is for foster care or adoption. These must follow licensing requirements.
  • A child is already in the receiving state in violation of the ICPC.

If neither of these situations is present, the placement must meet one or more of the following circumstances to be considered a priority placement.

  • The proposed placement is with a parent, grandparent, adult aunt or uncle, adult sibling, or a guardian; and

    • the child is under two years of age; or
    • the child is in an emergency placement; or
    • the child has spent substantial time in the home of the placement recipient.
  • The receiving state has had a completed "Request for Placement" form and supporting documentation for over 30 business days, but has not notified the sending agency whether or not the child may be placed.

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