Requirements library 2026.11.2
What we check, and where it comes from
Each item names its source and how strongly it binds. Required items come from federal regulation for that APD type. Conditional items apply only in some situations. Advisory items come from ACF templates or are Lukshi recommendations; they are not federal requirements. The verification column says whether we matched the source text word for word.
Project overview, needs and objectives
Required
Statement of problems/needs and outcomes/objectives (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(2) · Regulation · APD narrative
The Implementation APD shall include a statement of problems/needs and outcomes/objectives.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(2) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-NEEDS-OBJECTIVES
“A statement of problems/needs and outcomes/objectives;”
Conditional
Results of planning activities (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(1) · Regulation · APD narrative
The Implementation APD shall include the results of the activities conducted under a Planning APD, if any.
- Applies to
- Implementation APD (IAPD). Only when: Applies when a Planning APD preceded this IAPD.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(1) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-PLANNING-RESULTS
“The results of the activities conducted under a Planning APD, if any;”
Required
Statement of the problem/need (Planning APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(i) · Regulation · APD narrative
The Planning APD must contain a statement of the problem or need that existing capabilities cannot resolve, new or changed program requirements, or opportunities for improved economies, efficiency and effectiveness.
- Applies to
- Planning APD (PAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(i) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-PAPD-PROBLEM-NEED
“A statement of the problem/need that the existing capabilities can not resolve, new or changed program requirements or opportunities for improved economies and efficiencies and effectiveness of program and administration and operations;”
Scope, approach, alternatives and cost benefit
Required
Cost benefit analysis (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(4) · Regulation · APD narrative
The Implementation APD shall include a cost benefit analysis.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(4) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-CBA
“A cost benefit analysis;”
Required
Nature and scope of activities and methods (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(6) · Regulation · APD narrative
The Implementation APD shall include a detailed description of the nature and scope of the activities to be undertaken and the methods to be used to accomplish the project.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(6) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-NATURE-SCOPE
“A detailed description of the nature and scope of the activities to be undertaken and the methods to be used to accomplish the project;”
Required
Requirements analysis, feasibility study and alternatives (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(3) · Regulation · APD narrative
The Implementation APD shall include a requirements analysis, feasibility study and a statement of alternative considerations including, where appropriate, service-oriented architecture and transfer of an existing system, with an explanation of why a transfer is not feasible if another alternative is chosen.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: requirements analysis; feasibility study; alternatives considered; transfer of an existing system considered; explanation if transfer rejected
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(3) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-REQUIREMENTS-FEASIBILITY-ALTERNATIVES
“A requirements analysis, feasibility study and a statement of alternative considerations including, where appropriate, the use of service-orientated architecture and a transfer of an existing system and an explanation of why such a transfer is not feasible if another alternative is identified;”
Required
Expected duration of system use (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(9) · Regulation · APD narrative
The Implementation APD shall include a statement indicating the duration the state expects to use the equipment and/or system (see also § 95.619).
- Applies to
- Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(9) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-USE-DURATION
“A statement indicating the duration the State expects to use the equipment and/or system;”
Required
Commitment to needs assessment, feasibility study, alternatives analysis, cost benefit analysis and requirements/GSD (Planning APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(v) · Regulation · APD narrative
The Planning APD must commit the state to conduct the needs assessment, feasibility study, alternatives analysis, cost benefit analysis, and to develop a Functional Requirements Specification and/or General Systems Design.
- Applies to
- Planning APD (PAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: needs assessment; feasibility study; alternatives analysis; cost benefit analysis; Functional Requirements Specification and/or GSD
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(v) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-PAPD-COMMITMENT-STUDIES
“A commitment to conduct/prepare the problem(s) needs assessment, feasibility study, alternatives analysis, cost benefit analysis, and to develop a Functional Requirements Specification and/or a General Systems Design (GSD);”
Required
Commitment to define functional requirements usable to evaluate a system transfer (Planning APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(vi) · Regulation · APD narrative
The Planning APD must commit to defining the state's functional requirements, based on business needs, in a form usable to evaluate transfer of an existing system (including another state's General System Design).
- Applies to
- Planning APD (PAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(vi) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-PAPD-FUNCTIONAL-REQUIREMENTS-TRANSFER
“A commitment to define the State's functional requirements, based on the State's business needs which may be used for the purpose of evaluating the transfer of an existing system, including the transfer of another State's General System Design that the State may adapt to meet State specific requirements;”
Advisory
At least two alternatives to the status quo compared on costs and benefits
State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter III, Standards for Approval · Guidance · APD narrative
One of the APD Guide's standards for approving an Implementation APD is whether at least two alternatives to the status quo were evaluated for costs and benefits, with a reasonable basis for selecting the chosen alternative.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative: two or more alternatives other than the status quo; costs and benefits for each; rationale for the selected alternative
- Verification
- Source text verified
- Source
- State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter III, Standards for Approval (October 2010 (cover); copy attached to OMB 0970-0417 at reginfo.gov)
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GUIDE-IAPD-TWO-ALTERNATIVES
“Were at least two alternatives to the status quo evaluated for costs and benefits?”
Governance, staffing and project management
Required
Personnel resource statement including project director (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(5) · Regulation · APD narrative
The Implementation APD shall include a personnel resource statement indicating availability of qualified and adequate numbers of staff, including a project director.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: project director identified; state staff positions/FTEs and qualifications; contractor staffing; statement that staffing is adequate
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(5) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-PERSONNEL
“A personnel resource statement indicating availability of qualified and adequate numbers of staff, including a project director to accomplish the project objectives;”
Conditional
Multi-program requests signed by the appropriate state official and routed to each HHS component
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.611(a)(4) · Regulation · Information outside the upload
Multi-program requests must be signed by the appropriate state official and submitted to the Department's Secretary or designee, with copies to each HHS agency's program office and regional office that participates in funding; single-program requests go to the applicable program office and Regional Administrator.
- Applies to
- All APD types. Only when: Applies to multi-program APDs.
- Obligation
- Conditional (Conditional)
- Expected evidence
- Information outside the upload
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.611(a)(4) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-MULTIPROGRAM-SUBMISSION
“Except as provided for in paragraph (a)(5) of this section, the State shall submit multi-program requests for Department approval, signed by the appropriate State official, to the Department's Secretary or his/her designee. For each HHS agency that has federal funding participation in the project, an additional copy must be provided to the applicable Federal program office and respective Regional Offices.”
Required
Planning project management plan (Planning APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(ii) · Regulation · APD narrative
The Planning APD must include a project management plan addressing the planning project organization, planning activities/deliverables, state and contractor resource needs, planning procurement activities and schedule.
- Applies to
- Planning APD (PAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: organization/governance of the planning effort; planning activities and deliverables; state and contractor resource needs; planning procurements; planning schedule
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(ii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-PAPD-PMP
“A project management plan that addresses the planning project organization, planning activities/deliverables, State and contractor resource needs, planning project procurement activities and schedule;”
Advisory
Submission signed by the state agency head or authorized official
State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter I.F · Guidance · APD narrative
The HHS State Systems APD Guide states that APD submissions must be signed by the State agency head or an authorized State agency official, and that unsigned submissions may be returned. Check that the document or its transmittal includes a signature block for the authorized official.
- Applies to
- All APD types
- Obligation
- Advisory (Template alignment)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter I.F (October 2010 (cover); copy attached to OMB 0970-0417 at reginfo.gov)
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GUIDE-SIGNED-BY-AUTHORIZED-OFFICIAL
“must be signed by the State agency head or authorized State agency official”
Schedule and milestones
Required
Updated project activity schedule (Annual APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(iv) · Regulation · APD narrative
The Annual APDU must include an updated project activity schedule for the remainder of the project.
- Applies to
- Annual APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(iv) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-APDU-UPDATED-SCHEDULE
“An updated project activity schedule for the remainder of the project;”
Required
Proposed activity schedule (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(7) · Regulation · APD narrative
The Implementation APD shall include the proposed activity schedule for the project.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(7) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-SCHEDULE
“The proposed activity schedule for the project;”
Advisory
Milestone dates in the narrative match the schedule and procurement documents
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(7) · Regulation · Attachment
Match milestones mentioned with dates in the APD narrative (e.g., contract award, go-live, rollout) against the same milestones in attached schedules or procurement documents and report differing dates.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- Attachment
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(7) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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CONSIST-MILESTONE-DATES
“The proposed activity schedule for the project;”
Budget, cost allocation and funding
Conditional
Approved or anticipated changes to cost allocation basis (Annual APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(vii) · Regulation · APD narrative
The Annual APDU must report any approved or anticipated changes to the allocation basis in the APD's approved cost allocation methodology.
- Applies to
- Annual APD Update (APDU). Only when: Applies when the cost allocation basis has changed or will change; otherwise state 'no changes'.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(vii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-APDU-COST-ALLOCATION-CHANGES
“A report of any approved or anticipated changes to the allocation basis in the APD's approved cost allocation methodology; and”
Required
Project expenditures report with projected-vs-actual explanation (Annual APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(vi) · Regulation · APD narrative
The Annual APDU must include a detailed accounting of all project development expenditures over the past year and explain differences between projected expenses in the approved APD and actual expenditures.
- Applies to
- Annual APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: actual expenditures by category; approved/projected amounts for comparison; explanation of each material variance
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(vi) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-APDU-EXPENDITURE-REPORT
“A project expenditures report that consists of a detailed accounting of all expenditures for project development over the past year and an explanation of the differences between projected expenses in the approved APD and actual expenditures for the past year;”
Required
Revised life-cycle budget including operational and development categories (Annual APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(v) · Regulation · APD narrative
The Annual APDU must include a revised budget for the entirety of the project's life-cycle, including operational and development cost categories.
- Applies to
- Annual APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: all fiscal years of the project life cycle; development and operational costs shown separately; federal and state shares
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(v) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-APDU-REVISED-BUDGET
“A revised budget for the entirety of the project's life-cycle, including operational and development cost categories;”
Advisory
Development vs. operational cost identification and CAP amendment (§ 95.631)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.631(a) · Regulation · APD narrative
States must identify development costs in project cost centers and distribute them per the approved APD methodology, amending the cost allocation plan to include it; operational costs are assigned under the approved cost allocation plan.
- Applies to
- Implementation APD (IAPD); Annual APD Update (APDU); Operational APD (OAPD)
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative: development and operational costs distinguished; statement that the CAP will be/was amended for development costs; operational costs tied to the approved CAP
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.631(a) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-COST-IDENTIFICATION-95631
“The State agency shall amend the cost allocation plan required by subpart E of this part to include the approved APD methodology for the identification, assignment and distribution of the development costs.”
Required
Proposed budget accounting for all activity costs (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(8) · Regulation · APD narrative
The Implementation APD shall include a proposed budget accounting for all possible IAPD activity costs (e.g., system conversion, vendor and state personnel, capacity planning, supplies, training, hardware, software and miscellaneous ADP expenses).
- Applies to
- Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: budget by fiscal year; cost categories covering personnel, contractors, hardware, software, training, conversion; federal and state shares; total project cost
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(8) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-BUDGET
“A proposed budget (including an accounting of all possible Implementation APD activity costs, e.g., system conversion, vendor and state personnel, computer capacity planning, supplies, training, hardware, software and miscellaneous ADP expenses) for the project;”
Required
Prospective cost allocation/distribution and procedures (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(10) · Regulation · APD narrative
The Implementation APD shall include an estimate of the prospective cost allocation/distribution to state and federal funding sources and the proposed procedures for distributing costs.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: benefiting programs identified; allocation basis/statistic for each cost pool; estimated dollar distribution by funding source; procedure and timing for distributing costs; reference to the cost allocation plan
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(10) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-COST-ALLOCATION
“An estimate of the prospective cost allocation/distribution to the various State and Federal funding sources and the proposed procedures for distributing costs;”
Conditional
Additional requirements for enhanced funding or title IV-E agencies (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(12) · Regulation · APD narrative
Where the state requests enhanced funding (title IV-D § 307.15, Medicaid 42 CFR part 433 subpart C) or title IV-E funding, the IAPD must include the additional content those rules require; for CCWIS this is § 1355.52(i).
- Applies to
- Implementation APD (IAPD). Only when: Applies when enhanced or title IV-E funding is requested.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(12) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-IAPD-ENHANCED-OR-CCWIS-ADDITIONAL
“Additional requirements, for acquisitions for which the State is requesting enhanced funding, as contained at § 307.15 and 42 CFR subchapter C, part 433 or funding for title IV-E agencies as contained at § 1355.52(i) of this title.”
Required
Annual budget by project/system (Operational APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(3)(iii) · Regulation · APD narrative
The Operational APDU must include an annual budget by project/system receiving funding through the covered programs.
- Applies to
- Operational APD (OAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(3)(iii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-OAPDU-ANNUAL-BUDGET
“Annual budget by project/system receiving funding through the programs covered under this part.”
Required
Specific budget for the planning phase (Planning APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(iii) · Regulation · APD narrative
The Planning APD must contain a specific budget for the planning phase of the project.
- Applies to
- Planning APD (PAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(iii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
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APD-PAPD-BUDGET
“A specific budget for the planning phase of the project;”
Required
Estimated total project cost and prospective cost allocation (Planning APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(iv) · Regulation · APD narrative
The Planning APD must give an estimated total project cost and a prospective state and federal cost allocation/distribution covering planning and implementation.
- Applies to
- Planning APD (PAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(iv) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-PAPD-TOTAL-COST-ALLOCATION
“An estimated total project cost and a prospective State and Federal cost allocation/distribution, including planning and implementation;”
Advisory
Budget periods are not duplicated and variances reconcile
Reviewer recommendations (APD Checker maintainers) — not federal requirements · Lukshi recommendation · Budget workbook or table
Multiyear budget tables should not repeat a fiscal year (which double-counts it in the total), and approved-versus-actual tables should show variances that equal the difference between the two amounts.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- Budget workbook or table: multiyear budget table; approved vs actual expenditure table
- Verification
- Source text verified
- Source
- Reviewer recommendations (APD Checker maintainers) — not federal requirements (library 2026.11.1)
- ID
BUDGET-PERIODS-VARIANCE
Advisory
Federal and state shares reconcile to totals and to the stated rate
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(10) · Regulation · Budget workbook or table
Where a table shows total, federal share and state share, verify federal + state = total and, if a percentage is stated in the header or in the project's funding assumptions, that federal share = total x rate within tolerance. A rate stated in the document is reported as an assumption to confirm, not assumed to be the applicable FFP rate for every line.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- Budget workbook or table
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(10) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
BUDGET-SHARE-MATH
“An estimate of the prospective cost allocation/distribution to the various State and Federal funding sources and the proposed procedures for distributing costs;”
Advisory
Budget table line items add up to the stated totals
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(8) · Regulation · Budget workbook or table
For every table that looks like a budget (currency columns with a Total row and/or Total column), recompute each total from its line items and compare with the stated figure. Differences beyond the rounding tolerance are reported with operands and locations. Missing or unreadable cells are reported as extraction issues, never treated as zero.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- Budget workbook or table
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(8) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
BUDGET-TABLE-TOTALS
“A proposed budget (including an accounting of all possible Implementation APD activity costs, e.g., system conversion, vendor and state personnel, computer capacity planning, supplies, training, hardware, software and miscellaneous ADP expenses) for the project;”
Required
CCWIS cost allocation tied to qualifying automated functions and approved activities
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.57(e)(1) · Regulation · APD narrative
CCWIS cost allocation applies to automated functions that support IV-B/IV-E programs and at least one § 1355.52 (or § 1355.54) requirement and are not duplicated/consistently used; title IV-E may be charged for the share of approved activities and functions that benefit title IV-E participants, with development costs also chargeable for functions benefiting IV-B or both IV-E and child welfare programs; other project costs follow HHS cost allocation rules and § 1356.60(d).
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); Annual APD Update (APDU); As-Needed APD Update (APDU); Operational APD (OAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: qualifying functions/activities identified; share to title IV-E and basis; non-qualifying costs allocated under HHS rules; development and operational costs distinguished
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.57(e)(1) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-COST-ALLOCATION-FUNCTIONS
“A title IV-E agency may allocate CCWIS development and operational costs to title IV-E for the share of approved activities and automated functions that:”
Required
Title IV-E funding is 50% of the costs allocated to title IV-E (checked per funding stream)
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1356.60(e) · Regulation · Budget workbook or table
Federal matching funds for CCWIS and non-CCWIS are available at fifty percent (50%) of allowable costs allocated to title IV-E (45 CFR 1356.60(e), cost allocation under § 1355.57). It does not make the whole budget 50 percent federal: in a project shared with other programs, each funding stream is checked separately (allocated cost, any participation adjustment, and that program's own rate or arrangement). The checker supplies only the IV-E rate; other programs are checked against the rate the APD states, or flagged for clarification.
- Applies to
- All APD types
- Obligation
- Required (Required)
- Expected evidence
- Budget workbook or table: cost allocation table or workbook by program; rate or funding arrangement for each program; federal and state amounts per program
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1356.60(e) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-FFP-RATE-50
“Federal matching funds for CCWIS and Non-CCWIS. Federal matching funds are available at the rate of fifty percent (50%). Requirements for the cost allocation of CCWIS and non-CCWIS project costs are at § 1355.57 of this chapter.”
Advisory
Total project cost stated in the narrative matches the budget tables and workbook
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(8) · Regulation · Budget workbook or table
Compare dollar totals stated in the narrative (e.g., "total estimated cost of $8,525,000") with the grand totals computed from budget tables in the APD and in attached budget workbooks.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- Budget workbook or table
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(8) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
CONSIST-TOTAL-COST
“A proposed budget (including an accounting of all possible Implementation APD activity costs, e.g., system conversion, vendor and state personnel, computer capacity planning, supplies, training, hardware, software and miscellaneous ADP expenses) for the project;”
Procurement and contracting
Conditional
Acquisition summary for the upcoming year or phase (Annual APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(viii) · Regulation · APD narrative
The Annual APDU must include an acquisition summary with type and scope of contract, procurement strategy, estimated cost or not-to-exceed amount, timeframe, and a compliance statement including software ownership rights under § 95.617.
- Applies to
- Annual APD Update (APDU). Only when: Applies when acquisitions are planned for the coming year.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(viii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-APDU-ACQUISITION-SUMMARY
“An acquisition summary for the upcoming year or development phase that provides the following information on proposed acquisitions:”
Conditional
Changes to the acquisition summary (As-Needed APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(2)(vi) · Regulation · APD narrative
Where acquisitions change, the As-Needed APDU must describe changes to type and scope of contract, procurement strategy, estimated cost or not-to-exceed amount, timeframe, the compliance statement including § 95.617, and any new acquisitions not summarized in the Annual APDU.
- Applies to
- As-Needed APD Update (APDU). Only when: Applies when acquisitions change.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(2)(vi) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-ASNEEDED-ACQUISITION-CHANGES
“New acquisitions not summarized in the Annual APDU.”
Conditional
Emergency acquisition request contents (§ 95.624)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.624(a) · Regulation · Information outside the upload
If the APD relies on an emergency acquisition, the prior request to the Department must describe the equipment/services and estimated cost, the circumstances requiring action before approval, and the harm if not acquired immediately; a formal request with § 95.611 information is due within 90 days.
- Applies to
- All APD types. Only when: Applies only to emergency acquisitions.
- Obligation
- Conditional (Conditional)
- Expected evidence
- Information outside the upload
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.624(a) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-EMERGENCY-ACQUISITION
“The State must submit a request to the Department, prior to the acquisition of any ADP equipment or services. The request must be reflected in a record, and include:”
Required
Acquisitions (Operational APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(3)(ii) · Regulation · APD narrative
The Operational APDU must include acquisitions.
- Applies to
- Operational APD (OAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(3)(ii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-OAPDU-ACQUISITIONS
“Acquisitions; and,”
Conditional
Acquisition summary for the upcoming year or phase (Planning APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(viii) · Regulation · APD narrative
The Planning APD must include an acquisition summary giving, for each proposed acquisition, the type and scope of contract, procurement strategy, estimated cost or not-to-exceed amount, timeframe, and a statement or certification of compliance with state and federal requirements including software ownership rights under § 95.617.
- Applies to
- Planning APD (PAPD). Only when: Applies when the planning phase includes proposed acquisitions.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(a)(2)(viii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-PAPD-ACQUISITION-SUMMARY
“An acquisition summary for the upcoming year or development phase that provides the following information on proposed acquisitions:”
Conditional
Prior approval thresholds that appear to apply (§ 95.611)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.611(a)(1) · Regulation · APD narrative
Prior written approval is required for ADP acquisitions with proposed FFP at the regular match rate when total acquisition costs are $5,000,000 or more in federal and state funds; for sole-source/non-competitive acquisitions of $1,000,000 or more; and for contracts and amendments above the thresholds in § 95.611(b). This check compares the budget totals to those thresholds and reports which conditions appear to be triggered. It does not determine approval status.
- Applies to
- All APD types. Only when: Depends on acquisition cost and funding rate.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.611(a)(1) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-PRIOR-APPROVAL-THRESHOLDS
“A State shall obtain prior approval from the Department which is reflected in a record, as specified in paragraph (b) of this section, when the State plans to acquire ADP equipment or services with proposed FFP at the regular matching rate that it anticipates will have total acquisition costs of $5,000,000 or more in Federal and State funds.”
Advisory
Procurement follows 2 CFR parts 200 and 300 regardless of prior approval
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.613(a) · Regulation · APD narrative
Procurements of ADP equipment and services are subject to the procurement standards in 2 CFR parts 200 and 300 regardless of any prior-approval conditions. References to superseded authorities (45 CFR part 75, 45 CFR part 92, OMB Circular A-102/A-87) should be updated.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.613(a) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-PROCUREMENT-STANDARDS
“Procurements of ADP equipment and services are subject to the procurement standards prescribed by 2 CFR parts 200 and 300 regardless of any conditions for prior approval.”
Conditional
Software ownership rights clause and federal license (§ 95.617)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.617(a) · Regulation · APD narrative
Procurement instruments must include a clause giving the state or local government all ownership rights in software, modifications and documentation developed with FFP, and the Department reserves a royalty-free, nonexclusive, irrevocable license to use them for federal purposes. FFP is not available for proprietary application software developed specifically for the covered programs.
- Applies to
- All APD types. Only when: Applies when software or modifications are developed or acquired with FFP.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative: state ownership of software/modifications/documentation developed with FFP; federal royalty-free license reserved; treatment of proprietary COTS/low-code platform licenses; statement that the clause is in all procurement instruments
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.617(a) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-SOFTWARE-OWNERSHIP
“The State or local government must include a clause in all procurement instruments that provides that the State or local government will have all ownership rights in software or modifications thereof and associated documentation designed, developed or installed with Federal financial participation under this subpart.”
Conditional
Sole source justification for noncompetitive acquisitions over $1,000,000
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.611(b)(1)(iv) · Regulation · APD narrative
For noncompetitive acquisitions, including contract amendments, when the resulting contract is anticipated to exceed $1,000,000, the state must submit a sole source justification in addition to the acquisition document; it may be provided in the Planning, Annual or As-Needed APDU.
- Applies to
- All APD types. Only when: Applies to noncompetitive acquisitions over $1 million.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.611(b)(1)(iv) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-SOLE-SOURCE-JUSTIFICATION
“For noncompetitive acquisitions, including contract amendments, when the resulting contract is anticipated to exceed $1,000,000, States will be required to submit a sole source justification in addition to the acquisition document. The sole source justification can be provided as part of the Planning, Annual or As-Needed APDU.”
CCWIS automated functions and design
Conditional
Replacement or modernization of an automated function justified (duplication analysis)
ACYF-CB-IM-26-03 — Clarifying Duplication in Modular Modernization, Replacement, and Data Readiness Efforts for CCWIS, § Body · Guidance · APD narrative
When an APD proposes replacing, modernizing or consolidating an existing automated function, IM-26-03 says the agency must provide sufficient documentation through the APD process (citing CWPM 6.10A, 6.10B and 6.11): the existing and proposed function, business need, applicable CCWIS requirement, prior federal funding, material improvement, transition and decommissioning plan for the legacy function, modular design and reuse, data quality benefits, cost allocation, and governance and risk management.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); Annual APD Update (APDU); As-Needed APD Update (APDU). Only when: Applies when the APD proposes replacing, modernizing, consolidating or substantially improving an existing automated function. IM-26-03 is non-binding but points to binding CWPM 6.10A/6.10B/6.11 documentation requirements.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative: existing function and proposed function; business need and CCWIS requirement supported; prior federal funding in the existing function; material improvement; duplication analysis and any time-limited parallel operation; transition, migration and decommissioning plan with date; modular design and reuse; data quality benefits; cost allocation; governance and risk management
- Verification
- Source text verified
- Source
- ACYF-CB-IM-26-03 — Clarifying Duplication in Modular Modernization, Replacement, and Data Readiness Efforts for CCWIS, § Body (Issued 2026-06-26)
- ID
CB-IM2603-REPLACEMENT-DOCUMENTATION
“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.”
Conditional
Predictive analytics or risk modeling described as ACF's 2026 guidance requests
Dear Colleague Letter: New CCWIS Guidance on Predictive Analytics (Tab A: information to include in the APD), § Tab A · Guidance · APD narrative
When the APD includes predictive analytics or predictive risk modeling, ACF's 2026 guidance asks the APD to: describe the services supported and data sources; show the bi-directional exchange with CCWIS (external tool) or list the function on the automated function checklist (inside CCWIS); describe security, privacy, data quality and design plans; give a business case; include the procurement on the acquisition summary; and allocate costs to all benefiting programs and include them in the budget.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); Annual APD Update (APDU); As-Needed APD Update (APDU); Operational APD (OAPD). Only when: Applies only when the APD includes predictive analytics, risk modeling or similar decision-support functionality.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative: services supported and all data sources; bi-directional exchange with CCWIS (external) or listing on the automated function checklist (internal); security, privacy, data quality and design plan; business case tied to requirements; acquisition summary entry if procured; costs allocated to benefiting programs and included in the budget
- Verification
- Source text verified
- Source
- Dear Colleague Letter: New CCWIS Guidance on Predictive Analytics (Tab A: information to include in the APD), § Tab A (2026 (received by states 2026-07-13; acf.gov page dated 2026-07-14, updated 2026-08-31 per search listings))
- ID
CB-PA-PREDICTIVE-ANALYTICS-CONTENT
“Provide a business case by identifying the requirements that the predictive analytics function satisfies and explain why the function is an efficient, economical, and effective approach to meeting those requirements;”
Required
List of all automated functions included in the CCWIS
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(i)(1)(ii) · Regulation · APD narrative
The APD or Notice of Intent must list all automated functions included in the CCWIS. (The optional ACF checklist is one acceptable format; the list itself is required, the format is not.)
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); As-Needed APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(i)(1)(ii) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-AUTOMATED-FUNCTIONS-LIST
“A list of all automated functions included in the CCWIS; and”
Required
Notation for each automated function (supports a requirement; not duplicated; meets design requirements)
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(i)(1)(iii) · Regulation · APD narrative
For each listed automated function the APD must note whether it meets, or when implemented will meet, three conditions - it supports at least one § 1355.52 (or § 1355.54) requirement; it is not duplicated within CCWIS or contributing-agency systems and is consistently used by all responsible child welfare users; and it complies with the § 1355.53(a) design requirements unless exempted under § 1355.53(b).
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); As-Needed APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: per-function notation of supported requirement; per-function duplication/consistent-use notation; per-function design-requirement notation or exemption
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(i)(1)(iii) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-AUTOMATED-FUNCTIONS-NOTATIONS
“A notation of whether each automated function listed in paragraph (i)(1)(ii) of this section meets, or when implemented will meet, the following requirements:”
Required
Description of how the CCWIS will meet § 1355.52(a)–(h) (and § 1355.54 if applicable)
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(i)(1)(i) · Regulation · APD narrative
Before claiming CCWIS cost allocation, the title IV-E agency must submit an APD (or Notice of Intent if below thresholds) that describes how the CCWIS will meet the project requirements in § 1355.52(a) through (h) and, if applicable, § 1355.54.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); As-Needed APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: (a) efficient, economical, effective; (b) data requirements; (c) reporting; (d) data quality; (e) bi-directional exchanges; (f) data exchange standard; (g) single eligibility function; (h) software provision to federal repository
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(i)(1)(i) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-DESCRIPTION-OF-COMPLIANCE
“A description of how the CCWIS will meet the requirements in paragraphs (a) through (h) of this section and, if applicable § 1355.54;”
Required
CCWIS design requirements (modular, plain language, standards-based, shareable)
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.53(a) · Regulation · APD narrative
Unless exempted, CCWIS automated functions must follow a modular design separating business rules from core programming, be documented in plain language, adhere to a state/tribal/industry standard that promotes efficient development and reliable systems, and be capable of being shared, leveraged and reused as separate components.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); As-Needed APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: modularity and separation of business rules; plain language documentation; named standard (state, tribal or industry); shareability/reuse of components; any 1355.53(b) exemption requested
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.53(a) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-DESIGN-REQUIREMENTS
“Follow a modular design that includes the separation of business rules from core programming;”
Required
Same automated function(s) used for all title IV-E eligibility determinations
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(g)(1) · Regulation · APD narrative
A state title IV-E agency must use the same automated function or group of functions for all title IV-E eligibility determinations.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); Annual APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(g)(1) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-SINGLE-ELIGIBILITY-FUNCTION
“A state title IV-E agency must use the same automated function or the same group of automated functions for all title IV-E eligibility determinations.”
Conditional
Copy of agency-owned software to the federal repository on request
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(h) · Regulation · APD narrative
The title IV-E agency must provide a copy of agency-owned software designed, developed or installed with FFP, with documentation, to the designated federal repository upon request.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD). Only when: Applies to agency-owned software developed with FFP.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(h) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-SOFTWARE-PROVISION
“The title IV-E agency must provide a copy of the agency-owned software that is designed, developed, or installed with FFP and associated documentation to the designated federal repository within the Department upon request.”
Required
Updated automated functions list, duplication notation and design changes (Annual APDU / Operational APD)
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(i)(2) · Regulation · APD narrative
Annual APD Updates and Operational APDs for CCWIS projects must include an updated list of all automated functions, a notation whether each meets the non-duplication/consistent-use requirement, and a description of changes to scope or § 1355.53(a) design criteria for any listed function.
- Applies to
- Annual APD Update (APDU); Operational APD (OAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: updated list of all automated functions; non-duplication/consistent-use notation per function; description of scope/design changes
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(i)(2) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-UPDATE-AUTOMATED-FUNCTIONS
“Annual APD Updates and Operational APDs for CCWIS projects must include:”
Advisory
Optional ACF automated-functions checklist format (optional; source not retrieved)
Advance Planning Document (APD) Checklist — Automated Functions (Optional) · Template · APD narrative
The optional APD checklist for automated functions is a format ACF offers for the list and notations required by 45 CFR 1355.52(i). Using the checklist is optional; the content is required by regulation (see CCWIS-AUTOMATED-FUNCTIONS-LIST and -NOTATIONS).
- Applies to
- All APD types
- Obligation
- Advisory (Template alignment)
- Expected evidence
- APD narrative
- Verification
- Source not retrieved; not used to score documents yet
- Source
- Advance Planning Document (APD) Checklist — Automated Functions (Optional) (unknown (not verified))
- ID
DRAFT-AUTOMATED-FUNCTIONS-CHECKLIST-FORMAT
Data quality, exchanges and interfaces
Advisory
Plan to incorporate title IV-E prevention data into CCWIS
ACYF-CB-IM-26-04 — Clarifying Title IV-E Prevention Data Requirements and Opportunities to Accelerate Title IV-E Prevention Implementation and CCWIS Development, § Body · Guidance · APD narrative
IM-26-04 reminds agencies that they should develop plans to incorporate title IV-E prevention data into CCWIS and describe these plans in the APD; prevention data held in an external system must be electronically exchanged with CCWIS.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); Annual APD Update (APDU); As-Needed APD Update (APDU)
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- ACYF-CB-IM-26-04 — Clarifying Title IV-E Prevention Data Requirements and Opportunities to Accelerate Title IV-E Prevention Implementation and CCWIS Development, § Body (Published 2026-10-06; updated 2026-10-07)
- ID
CB-IM2604-PREVENTION-DATA-PLAN
“ACF reminds agencies that they should develop plans to incorporate title IV-E prevention data into CCWIS and describe these plans in the APD.”
Required
Bi-directional data exchanges identified
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(e)(1) · Regulation · APD narrative
The CCWIS must support bi-directional data exchanges with financial/claims systems, child welfare contributing agency systems, systems used for IV-E eligibility components, and external systems used to collect CCWIS data; and, to the extent practicable, with CAN, IV-A, Medicaid (eligibility and MMIS), IV-D, courts and education systems.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); Annual APD Update (APDU); As-Needed APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: each (e)(1) exchange addressed or marked not applicable; each (e)(2) exchange addressed with a practicability statement; direction of exchange stated
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(e)(1) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-BIDIRECTIONAL-EXCHANGES
“The CCWIS must support efficient, economical, and effective bi-directional data exchanges to exchange relevant data with:”
Required
Single data exchange standard for contributing agencies and external data-collection systems
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(f) · Regulation · APD narrative
Upon implementing a CCWIS the agency must use a single data exchange standard (data, definitions, formats, other specifications) for exchanges with each child welfare contributing agency and with external systems used by agency staff to collect CCWIS data.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); Annual APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(f) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-DATA-EXCHANGE-STANDARD
“The title IV-E agency must use a single data exchange standard that describes data, definitions, formats, and other specifications upon implementing a CCWIS:”
Advisory
Data quality approach described in the Implementation APD (recommended)
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(d)(2) · Regulation · APD narrative
The data quality plan is required in Annual and Operational APDs (§ 1355.52(d)(5)); an Implementation APD that describes how the design will meet the data quality requirements in § 1355.52(d)(1)–(2) avoids a gap at the first annual update. Reviewer recommendation, not a requirement for the IAPD itself.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(d)(2) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-DATA-QUALITY-APPROACH-IAPD
“The title IV-E agency must implement and maintain automated functions in CCWIS to:”
Required
CCWIS data quality plan included in Annual or Operational APDs
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(d)(5) · Regulation · APD narrative
The title IV-E agency must develop, implement and maintain a CCWIS data quality plan in a manner prescribed by ACF and include it in Annual or Operational APDs; the plan must describe the comprehensive data quality strategy (meeting § 1355.52(d)(1)–(3)) and report the status of compliance with (d)(1).
- Applies to
- Annual APD Update (APDU); Operational APD (OAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: comprehensive DQ strategy; steps to meet (d)(1) standards, (d)(2) automated functions and (d)(3) biennial reviews; status of compliance with (d)(1)
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.52(d)(5) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-DATA-QUALITY-PLAN
“The title IV-E agency must develop, implement, and maintain a CCWIS data quality plan in a manner prescribed by ACF and include it as part of Annual or Operational APDs submitted to ACF as required in 45 CFR 95.610. The CCWIS data quality plan must:”
Security, privacy and disaster recovery
Required
Security, interface, system failure and disaster recovery/business continuity (Implementation APD)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(11) · Regulation · APD narrative
The Implementation APD shall set forth the security and interface requirements to be employed and the system failure and disaster recovery/business continuity procedures available or to be implemented.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: security requirements and standards referenced; interfaces/data exchanges identified; disaster recovery and business continuity procedures with status (available or to be implemented)
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(11) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-IAPD-SECURITY-INTERFACE-DR
“A statement setting forth the security and interface requirements to be employed and the system failure and disaster recovery/business continuity procedures available or to be implemented; and”
Advisory
ADP security program components (§ 95.621(f))
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.621(f)(2)(ii) · Regulation · APD narrative
State agencies must determine appropriate ADP security requirements and maintain a security plan covering physical security, equipment security, software and data security, telecommunications security, personnel security, contingency plans, emergency preparedness and designation of an Agency ADP Security Manager, with periodic risk analyses and biennial security reviews.
- Applies to
- Implementation APD (IAPD); Annual APD Update (APDU); Operational APD (OAPD)
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative: security plan exists or has an owner and date; physical, equipment, software/data, telecommunications and personnel security addressed; contingency/emergency preparedness; ADP Security Manager designated; periodic risk analysis and biennial review
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.621(f)(2)(ii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-SECURITY-PROGRAM-95621F
“Establishment of a security plan and, as appropriate, policies and procedures to address the following area of ADP security:”
Federal oversight and IV&V
Advisory
Federal access to the system and records (§ 95.615)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.615 · Regulation · APD narrative
The state agency must allow the Department access to the system in all its aspects, including pertinent state staff, design developments, operation, and contractor/subcontractor cost records.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD)
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.615 (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-ACCESS-TO-SYSTEMS
“The State agency must allow the Department access to the system in all of its aspects, including pertinent state staff, design developments, operation, and cost records of contractors and subcontractors at such intervals as are deemed necessary by the Department to determine whether the conditions for approval are being met and to determine the efficiency, economy and effectiveness of the system.”
Conditional
Independent Verification and Validation (§ 95.626)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.626(c) · Regulation · APD narrative
IV&V may be required for projects meeting listed risk criteria; IV&V must be independent of the state, report directly to the federal agencies that required it, and the IV&V acquisition documents and contract must name key personnel and be submitted for prior written approval.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); Annual APD Update (APDU). Only when: Applies when the project meets § 95.626 IV&V criteria or ACF requires IV&V.
- Obligation
- Conditional (Conditional)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.626(c) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-IVV
“The acquisition documents and contract for required IV&V services must be submitted to the Department for prior written approval.”
Advisory
Consequences of failing APD or CCWIS requirements (§ 1355.58) - corrective time frames in the APD
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.58(b)(2) · Regulation · APD narrative
ACF may suspend IV-B/IV-E funding approved in the APD if the agency fails to comply with 45 CFR part 95 subpart F or §§ 1355.52–1355.56, and may recoup title IV-E funds if an APD is suspended or the agency voluntarily ceases the CCWIS. Suspension for unmet CCWIS requirements begins when the agency "has not corrected the failed requirements according to the time frame in the approved APD", so APDs should state time frames for correcting known gaps.
- Applies to
- Implementation APD (IAPD); Annual APD Update (APDU); Operational APD (OAPD)
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.58(b)(2) (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-APD-FAILURE-CONDITIONS
“Meet the requirements at § 1355.52 or, if applicable, § 1355.53, § 1355.54, or § 1355.56 and has not corrected the failed requirements according to the time frame in the approved APD.”
Advisory
Continuing ACF review of CCWIS projects (§ 1355.55)
45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.55 · Regulation · APD narrative
ACF reviews, assesses and inspects CCWIS planning, design, development, installation, operation and maintenance on a continuing basis under the APD requirements. The APD should support that review by keeping requirements traceability (automated functions to § 1355.52/.53) current.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR 1355.50–1355.59 — Comprehensive Child Welfare Information System (CCWIS); also §§ 1355.20 and 1355.30, § 1355.55 (eCFR issue date 2026-11-05; CCWIS sections from 81 FR 35479 (June 2, 2016); § 1355.58 amended 89 FR 80073 (Oct. 2, 2024))
- ID
CCWIS-REVIEW-ASSESSMENT-AWARENESS
“ACF will review, assess, and inspect the planning, design, development, installation, operation, and maintenance of each CCWIS project on a continuing basis, in accordance with APD requirements in 45 CFR part 95, subpart F, to determine the extent to which the project meets the requirements in §§ 1355.52, 1355.53, 1355.56, and, if applicable, § 1355.54.”
Project status and reporting
Required
Project activity report with status, problems/delays and risk management plan (Annual APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(ii) · Regulation · APD narrative
The Annual APDU must include a project activity report covering the status of the past year's major tasks and milestones, degree of completion, remaining tasks, past and anticipated problems or delays against the approved APD, and a risk management plan with mitigation strategies.
- Applies to
- Annual APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: status of each major task/milestone; degree of completion and remaining work; problems/delays against approved dates; risk register or risk management plan with mitigations
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(ii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-APDU-ACTIVITY-REPORT-RISK
“A project activity report which includes the status of the past year's major project tasks and milestones, addressing the degree of completion and tasks/milestones remaining to be completed, and discusses past and anticipated problems or delays in meeting target dates in the approved APD and approved changes to it and provides a risk management plan that assesses project risk and identifies risk mitigation strategies;”
Required
Report of deliverables completed and degree of completion (Annual APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(iii) · Regulation · APD narrative
The Annual APDU must report all project deliverables completed in the past year and the degree of completion for unfinished products and tasks.
- Applies to
- Annual APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(iii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-APDU-DELIVERABLES
“A report of all project deliverables completed in the past year and degree of completion for unfinished products and tasks;”
Required
Reference to the approved APD and all approved changes (Annual APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(i) · Regulation · APD narrative
The Annual APDU must reference the approved APD and all approved changes.
- Applies to
- Annual APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(i) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-APDU-REFERENCE-APPROVED
“A reference to the approved APD and all approved changes;”
Required
As-Needed APDU states the triggering change and justifies the budget change (As-Needed APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(2) · Regulation · APD narrative
An As-Needed APDU requests approval for additional funding and/or authority for continuation when significant changes are anticipated (incremental expenditures exceeding thresholds, schedule extension of more than 60 days for major milestones, major scope or procurement changes, significant cost distribution changes, significant cost-benefit changes) and must provide supporting documentation justifying any change to the approved budget.
- Applies to
- As-Needed APD Update (APDU)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative: the triggering change is named; the approved baseline (budget/schedule/scope) is cited; the new values are stated; justification and supporting documentation are provided
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(2) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-ASNEEDED-TRIGGER-AND-JUSTIFICATION
“The As-Needed APDU shall provide supporting documentation to justify the need for a change to the approved budget.”
Conditional
Changes since the approved APD that may require an As-Needed APDU
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.611(c)(1)(ii) · Regulation · Information outside the upload
Compares the APD with the latest approved baseline (an attached approved APD, approved amendments, or approved figures stated in the APD). Under § 95.611(c), regular-FFP projects need written approval through an As-Needed APDU for a projected cost increase of $1,000,000 or more, a major-milestone extension of more than 60 days, a significant procurement change, a change in system concept or project scope, or a change to the approved cost allocation methodology. Enhanced-FFP program shares have a lower cost threshold ($300,000 or 10% of project cost, whichever is less). Without a baseline the check reports that it cannot be assessed.
- Applies to
- Annual APD Update (APDU); As-Needed APD Update (APDU). Only when: Applies when changes from the approved APD meet a § 95.611(c) threshold; needs the approved baseline to assess.
- Obligation
- Conditional (Conditional)
- Expected evidence
- Information outside the upload: latest approved APD or approval letter (baseline); approved and revised milestone dates; approved and projected total cost
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.611(c)(1)(ii) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-ASNEEDED-TRIGGERS
“A projected cost increase of $1,000,000 or more.”
Required
Summary of activities (Operational APDU)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(3)(i) · Regulation · APD narrative
The Operational Advance Planning Document Update is an annual submission that must include a summary of activities.
- Applies to
- Operational APD (OAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(3)(i) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-OAPDU-SUMMARY-ACTIVITIES
“Summary of activities;”
Advisory
Figures and dates carried over from the prior APD are consistent
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(i) · Regulation · Attachment
Where a prior APD is attached, compare its stated total cost, approval date and implementation period with the current draft and report differences as questions for the author (changes are normal; unexplained changes are not).
- Applies to
- Implementation APD (IAPD); Annual APD Update (APDU); As-Needed APD Update (APDU)
- Obligation
- Advisory (Recommended)
- Expected evidence
- Attachment
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(1)(i) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
CONSIST-PRIOR-APD
“A reference to the approved APD and all approved changes;”
Advisory
Annual update explains variances and corrective action for overruns or slippage
State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter IV, Standards for Approval · Guidance · APD narrative
The APD Guide's standards for approving APD updates ask whether the state has initiated corrective action for cost overruns or schedule slippage; its Annual APDU outline asks for an explanation of problems and slippage and of budget increases of 10 percent or more.
- Applies to
- Annual APD Update (APDU); As-Needed APD Update (APDU)
- Obligation
- Advisory (Template alignment)
- Expected evidence
- APD narrative: cause of each overrun or delay; corrective action and owner; explanation of budget increases of 10% or more
- Verification
- Source text verified
- Source
- State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter IV, Standards for Approval (October 2010 (cover); copy attached to OMB 0970-0417 at reginfo.gov)
- ID
GUIDE-APDU-VARIANCE-CORRECTIVE-ACTION
“Has the State initiated corrective action to address cost overruns or schedule slippages?”
Advisory
As-Needed update follows the approved APD's format and includes the changed elements
State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter IV.B · Guidance · APD narrative
The APD Guide says As-Needed APD Updates follow the format of the APD being amended but include only the elements that have changed, so reviewers can see exactly what is being requested.
- Applies to
- As-Needed APD Update (APDU)
- Obligation
- Advisory (Template alignment)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter IV.B (October 2010 (cover); copy attached to OMB 0970-0417 at reginfo.gov)
- ID
GUIDE-ASNEEDED-CHANGED-ELEMENTS
“the format of the APD being amended but including only those elements that have changed”
Document completeness and consistency
Required
APD must include all information required by § 95.610
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.611(a)(6) · Regulation · APD narrative
The Department will not approve any Planning or Implementation APD that does not include all information required in § 95.610. Placeholders and incomplete sections therefore block approval.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD)
- Obligation
- Required (Required)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.611(a)(6) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-COMPLETENESS-95611A6
“The Department will not approve any Planning or Implementation APD that does not include all information required in § 95.610.”
Advisory
Operational APDU length (no more than two pages per § 95.610(c)(3))
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(3) · Regulation · APD narrative
Section 95.610(c)(3) describes the OAPDU as "an annual submission of no more than two pages". Program instructions may prescribe a fuller template; a longer document is not necessarily deficient, but the author should be aware of the regulatory description.
- Applies to
- Operational APD (OAPD)
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(c)(3) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-OAPDU-LENGTH
“The Operational Advance Planning Document Update (OAPDU) is an annual submission of no more than two pages, including:”
Advisory
Citations to superseded grant rules (45 CFR part 75/92/74, OMB A-87/A-102)
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.613(a) · Regulation · APD narrative
HHS repealed 45 CFR part 75 and adopted 2 CFR parts 200 and 300 effective October 1, 2025 (89 FR 80055); 45 CFR 95.613 and 95.621 were amended accordingly. APD text citing 45 CFR part 75, part 92, part 74 or OMB Circulars A-87/A-102 for cost principles or procurement is out of date. Note: § 95.631(c) itself still refers to OMB Circular A-87 for central service cost allocation plans; such a reference is not an error in itself.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.613(a) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
APD-OUTDATED-CITATIONS
“Procurements of ADP equipment and services are subject to the procurement standards prescribed by 2 CFR parts 200 and 300 regardless of any conditions for prior approval.”
Advisory
Fiscal years are consistent across narrative, budget and schedule
45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(7) · Regulation · Attachment
Compare the set of fiscal years referenced in the APD narrative with those in budget tables/workbooks and schedules. Extra or missing years, and mixed federal/state fiscal-year labels (FFY vs SFY vs FY), are reported as potential inconsistencies for the author to explain.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- Attachment
- Verification
- Source text verified
- Source
- 45 CFR Part 95, Subpart F — Automatic Data Processing Equipment and Services — Conditions for Federal Financial Participation (FFP), § 95.610(b)(7) (eCFR issue date 2026-11-05; last amendments 89 FR 80071 (Oct. 2, 2024, effective Oct. 1, 2025) to §§ 95.613 and 95.621)
- ID
CONSIST-FISCAL-YEARS
“The proposed activity schedule for the project;”
Advisory
Operational APD follows the ACF child-welfare operational APD template (source not retrieved)
ACF-CB-PI-11-07 — Operational APD instructions and template (child welfare) · Program instruction · APD narrative
ACF's operational APD instructions/template (referenced via ACF-CB-PI-11-07 and the HHS "Operational APD Instructions and Template", 2010) prescribe the content ACF expects in a child welfare Operational APD. The source was not retrievable here, so the required sections are not listed. Upload the document, then complete this rule's check_spec from its actual section headings.
- Applies to
- Operational APD (OAPD)
- Obligation
- Advisory (Template alignment)
- Expected evidence
- APD narrative
- Verification
- Source not retrieved; not used to score documents yet
- Source
- ACF-CB-PI-11-07 — Operational APD instructions and template (child welfare) (2011 (not verified))
- ID
DRAFT-OAPD-TEMPLATE-SECTIONS
Advisory
Spreadsheet formulas without cached values or with errors
Reviewer recommendations (APD Checker maintainers) — not federal requirements · Lukshi recommendation · Budget workbook or table
Budget workbooks whose formulas have no cached results (or contain error values) cannot be verified: the totals a reviewer sees in Excel may differ from anything computed here. Open and re-save the workbook in Excel or LibreOffice, or confirm the figures manually.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- Budget workbook or table
- Verification
- Source text verified
- Source
- Reviewer recommendations (APD Checker maintainers) — not federal requirements (library 2026.11.1)
- ID
EXTRACT-STALE-FORMULAS
Advisory
Scanned or unreadable pages reduce review coverage
Reviewer recommendations (APD Checker maintainers) — not federal requirements · Lukshi recommendation · APD narrative
Pages without a text layer, unreadable pages, truncated sheets and embedded objects were not reviewed. Run local OCR or supply a text-based version; otherwise the affected content is 'not assessed'.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- Reviewer recommendations (APD Checker maintainers) — not federal requirements (library 2026.11.1)
- ID
EXTRACT-UNREADABLE-CONTENT
Advisory
Implementation APD organized in the six sections of the HHS APD Guide
State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter III · Guidance · APD narrative
The APD Guide describes an Implementation APD in six sections: needs and objectives; summary of the requirements analysis, feasibility study and alternatives analysis; project management plan; proposed budget; prospective cost allocation; and proposed activity schedule, with the cost benefit analysis and budget detail as enclosures. The format is not mandatory.
- Applies to
- Implementation APD (IAPD)
- Obligation
- Advisory (Template alignment)
- Expected evidence
- APD narrative: Statement of needs and objectives (executive summary); Summary of requirements analysis, feasibility study and alternatives analysis; Project management plan (scope, methods, schedule, deliverables, organization and personnel, resources, system life); Proposed budget by category, year and quarter; Prospective cost allocation (program, share, amount, FFP rate, federal and state share); Proposed activity schedule; Cost benefit analysis and budget detail enclosures
- Verification
- Source text verified
- Source
- State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter III (October 2010 (cover); copy attached to OMB 0970-0417 at reginfo.gov)
- ID
GUIDE-IAPD-STRUCTURE
“As described in 45 CFR §95.610, the Implementation APD should have six sections”
Advisory
Planning APD organized in the four sections of the HHS APD Guide
State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter II · Guidance · APD narrative
The APD Guide describes a Planning APD in four sections: (A) statement of need, (B) project management plan for planning, (C) planning project budget and cost allocation, and (D) total project cost. The format is not mandatory but is the standard HHS reviewers use.
- Applies to
- Planning APD (PAPD)
- Obligation
- Advisory (Template alignment)
- Expected evidence
- APD narrative: A. Statement of Need (vision, scope and objectives, problems and needs); B. Project Management Plan for Planning (organization, key staff, milestones, contractor acquisition strategy); C. Planning budget by cost category and cost allocation exhibit; D. Total project cost estimate (planning and implementation)
- Verification
- Source text verified
- Source
- State Systems APD Guide (HHS: ACF and CMS), October 2010 — OMB control number 0970-0417, § Chapter II (October 2010 (cover); copy attached to OMB 0970-0417 at reginfo.gov)
- ID
GUIDE-PAPD-STRUCTURE
“The Planning APD has four sections”
Advisory
Acronyms used without definition
Reviewer recommendations (APD Checker maintainers) — not federal requirements · Lukshi recommendation · APD narrative
Acronyms that appear repeatedly without an expansion make federal review slower. Reviewer recommendation only.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- Reviewer recommendations (APD Checker maintainers) — not federal requirements (library 2026.11.1)
- ID
REC-ACRONYMS-DEFINED
Advisory
Future-tense commitments without owner or date (e.g., "a plan will be developed")
Reviewer recommendations (APD Checker maintainers) — not federal requirements · Lukshi recommendation · APD narrative
Commitments phrased as "will be developed/established/determined" with no responsible party, standard or date are weak evidence. Reviewers typically ask who, by when, and against which standard.
- Applies to
- Planning APD (PAPD); Implementation APD (IAPD); As-Needed APD Update (APDU)
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- Reviewer recommendations (APD Checker maintainers) — not federal requirements (library 2026.11.1)
- ID
REC-SECURITY-PLAN-OWNER-DATE
Advisory
Text addressed to automated reviewers (possible prompt injection)
Reviewer recommendations (APD Checker maintainers) — not federal requirements · Lukshi recommendation · APD narrative
Passages that instruct an automated reviewer or AI to ignore instructions, report compliance, or take actions are flagged. They are excluded from the AI context and should be removed from the draft; a submission should not contain text aimed at reviewers' tools.
- Applies to
- All APD types
- Obligation
- Advisory (Recommended)
- Expected evidence
- APD narrative
- Verification
- Source text verified
- Source
- Reviewer recommendations (APD Checker maintainers) — not federal requirements (library 2026.11.1)
- ID
SEC-PROMPT-INJECTION