Agenda Item   



                                                                                                                        ASR Control  19-000384




legal entity taking action:

Board of Supervisors

board of supervisors district(s):

All Districts

SUBMITTING Agency/Department:

Probation   (Approved)

Department contact person(s):

Tawnya Medina (714) 896-7555 



Bryan Prieto (714) 645-7002



Subject:  Contract with Justice Benefits, Inc. for Title IV-E Administrative Claims


      ceo CONCUR

County Counsel Review

Clerk of the Board


Approved Agreement to Form

Consent Calendar



3 Votes Board Majority




    Budgeted: N/A

Current Year Cost: N/A

Annual Cost: FY 2019-20 $198,530
FY 2020-21 $200,000
FY 2021-22 $205,000




    Staffing Impact:


# of Positions:

Sole Source: No

    Current Fiscal Year Revenue: N/A

  Funding Source: See Financial Impact Section

County Audit in last 3 years: No



    Prior Board Action: 5/13/2014 #34




Authorize the Chief Probation Officer or designee to execute a three-year contract with Justice Benefits, Inc. for Technical Assistance in Title IV-E Administrative Claims, effective July 1, 2019, through June 30, 2022, for an amount not to exceed $603,530, renewable for two additional one-year periods.







Approval of Contract with Justice Benefits, Inc. provides the Orange County Probation Department with Technical Assistance in Title IV-E Administrative Claiming Services to ensure compliance with federal reimbursement guidelines and to maximize funding for the Orange County Probation Department.






Section 472 of the Social Security Act (commonly known as “Title IV-E”) is a federally-funded program that allows probation departments to seek reimbursement for activities associated with services to youth at imminent risk for foster care placement. The Orange County Probation Department (Probation) submits a quarterly claim to the Orange County Social Services Agency (SSA) for pre-placement activities associated with the eligible youth. SSA submits the claim to the California Department of Social Services who then submits the final Title IV-E claim to the Federal Government.


On May 13, 2014, the Board of Supervisors (Board) approved a five-year contract for Technical Assistance in Title IV-E Claim Services.  In anticipation of the contract expiring on June 30, 2019, Probation issued a Request for Proposals (RFP) on February 21, 2019. The RFP closed on March 28, 2019, and Probation received three responsive proposals from the following contractors:


  • Public Consulting Group, Inc. (PCG)
  • Justice Benefits, Inc. (JBI)
  • Sivic Solutions Group, LLC (SSG)


An evaluation committee consisting of three members with experience in Title IV-E Claims rated proposals in accordance with the criteria outlined in the RFP and scored each proposal using pre-established weighting factors. After summarizing the scoring, the evaluation committee ranked the following firms as represented in the table below:


Proposer Name

Total Points (300 Points Maximum)

Average Scores

Proposer Ranking














The evaluation committee recommended JBI for contract award. Probation is seeking Board authorization to execute a three-year contract with JBI for Administrative Claim Services, effective July 1, 2019, through June 30, 2022, in an amount not to exceed $603,530, renewable for two additional one-year periods.


Under the proposed Contract, JBI will provide technical assistance and training in the Title IV-E Claims process to ensure compliance with federal reimbursement guidelines and to maximize funding for Probation. There are two cost components under the proposed revenue-based contract with JBI:  (i) an administrative fixed fee; plus (ii) a revenue-based fee of 2.5 percent billed based on actual revenue received by Probation.


The chart below provides a breakdown of the calculation of the contract monetary limit, which includes the fixed annual fee, and an estimate of the revenue JBI anticipates Probation will receive. The revenue-based fee will be based on actual revenue received by Probation; therefore, it is only an estimate for the purposes of establishing a monetary limit in the contract:



Contract Year

Fixed Annual Fee ($40,000 per Quarter)


Estimated Revenue

Revenue- Based Fee

(2.5 percent)

Based on Estimated Revenue

Estimated Annual  Contract Cost Based on Estimated Revenue






















JBI is Probation’s current provider and has 17 years of experience in maximizing federal revenue for state and local agencies, with a specialty in Title IV-E administrative claiming for juvenile justice departments.  On an annual basis, Probation has received approximately $1.3 million and paid approximately $230,000 per year for services provided. 


JBI provides a web-based time keeping system using its proprietary software called Random Moment Sampling (RMS).  JBI's RMS is a federally-approved methodology to document and identify the time spent on Title IV-E activities. JBI will provide training to Probation staff assigned to participate in the automated timekeeping process, which is monitored daily for coding accuracy and statistical validity.  The time study results are compiled quarterly and submitted to SSA for processing.


This item was submitted less than 30 days prior to commencement of contract due to ongoing staff shortages in Probation's Contracts unit, which resulted in a delay with the release of the RFP.


The Contractor's performance has been confirmed as satisfactory. Probation has verified there are no concerns that must be addressed with respect to JBI’s ownership/name, litigation status or conflicts with County interests.  The contract does not currently include subcontractors or pass through to other providers.  See Attachment C for the Contract Summary Form.






Appropriations and revenue for this Contract are included in the FY 2019-20 Budget and will be included in the budgeting process for future years. The services provided under this proposed contract are funded by the general fund and include an annual fee and as well as a fixed percentage of the revenue received.  The revenue received as a result of the contracted services are Title IV-E federal dollars.


The proposed contract with JBI contains language that will permit immediate reduction of services or termination of the contract due to fiscal non-appropriation, without penalty. Such provision can be triggered if the budget approved by your Honorable Board, state funding, or other appropriations are not forthcoming, or otherwise become limited.











Attachment A - Contract No. MA-057-19011459 between Justice Benefits, Inc. and the County of Orange for Technical Assistance in Title IV-E Administrative Claims
Attachment B - Individual Evaluator Score Sheets
Attachment C - Contract Summary Form
Attachment D - Section 472 of Social Security Act (Title IV-E)