The In Good Standing Adoption Agencies Act of 2026 directs the Secretary of Health and Human Services to compile and publish a national list of private child placement agencies that each State certifies as licensed or accredited, in good standing, and exempt under section 501(c)(3). States must submit their lists to HHS by January 1 each fiscal year, and the Children’s Bureau will maintain a publicly available catalog and send annual reports to Congress identifying mismatches and any state disciplinary actions.
The bill ties state compliance to federal incentives: a State that fails to submit the required list forfeits eligibility for adoption and legal guardianship incentive payments under section 473A. The measure centralizes basic regulatory information about private adoption agencies, increasing transparency while creating new administrative and compliance consequences for States and providers — and excluding agencies that are not 501(c)(3) tax-exempt from the federal roster.
At a Glance
What It Does
Requires each State with an approved Title IV‑B/IV‑E plan to submit, by January 1 of each fiscal year, a roster of private child placement agencies that were licensed or accredited, in good standing, and exempt under section 501(c)(3) as of the end of the prior fiscal year. HHS (via the Children’s Bureau) compiles a public national list and sends annual reports to Congress identifying agencies licensed by States but not included on the federal list and detailing any state disciplinary actions.
Who It Affects
Private child placement agencies that place children in prospective adoptive homes (limited to ones claiming 501(c)(3) exemption), State child welfare agencies responsible for licensure and reporting, the HHS Children’s Bureau, and recipients of adoption/guardianship incentive payments.
Why It Matters
The bill creates a single federal source of information about private adoption providers and uses federal funding leverage to enforce state reporting. That shifts oversight dynamics: reputational and funding consequences flow from whether a provider appears on the national list, and States must align licensure records to federal reporting cycles.
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What This Bill Actually Does
The core obligation in this bill is a recurring data submission from States to the Secretary of Health and Human Services. Each State with an approved plan under the relevant parts of the Social Security Act must, by January 1 of each fiscal year, send HHS a list of private child placement agencies that were licensed or accredited and ‘‘in good standing’’ with the State at the end of the preceding fiscal year.
The bill limits the roster to agencies that are tax-exempt under section 501(c)(3), and it defines a child placement agency narrowly as an agency that places children in prospective adoptive homes.
Once HHS receives the State lists, the Children’s Bureau is responsible for assembling those submissions into a single, publicly available national list. The Bureau must also prepare an annual written report to Congress that includes that compiled list and calls out any agency that a State licenses but did not include on its submission.
The Congressional report must also specify disciplinary measures a State has taken against private child placement agencies, giving lawmakers a regular window into state-level enforcement activity.The bill attaches a direct financial consequence to noncompliance: it amends the incentive-payment eligibility criteria so that a State that fails to submit the required list for the prior fiscal year loses eligibility for adoption and legal guardianship incentive payments under section 473A. In practice that makes timely and accurate reporting a condition of receiving certain federal funds tied to adoption outcomes.Operationally, the statute leaves several practical choices to States and HHS.
The timing is annual with a January 1 submission deadline; the list reflects agency status as of the end of the prior fiscal year; and the Children’s Bureau is the central publisher. The bill does not prescribe a specific format, validation process, or an appeal mechanism for agencies omitted from a State’s submission, so those implementation details will matter for accuracy and for how the public and stakeholders interpret the national list.
The Five Things You Need to Know
States must submit to HHS, not later than January 1 of each fiscal year, a list of private child placement agencies that were licensed or accredited and in good standing with the State as of the end of the preceding fiscal year.
The statute limits the federal roster to agencies that are exempt from federal income tax under section 501(c)(3); for‑profit or other non‑501(c)(3) placement entities are excluded from the required submissions.
HHS, through the United States Children’s Bureau, must compile and maintain a publicly available national list using the most recent State submissions.
HHS must submit to Congress annually (beginning by the second December 31 after enactment) a written report that includes the compiled list and identifies any agency licensed by a State but not included on that State’s submission, and it must specify disciplinary actions States have taken against private placement agencies.
The bill amends section 473A(b) so that a State’s failure to comply with the list-submission requirement for the preceding fiscal year makes the State ineligible for adoption and legal guardianship incentive payments.
Section-by-Section Breakdown
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Short title
Provides the Act’s official name: the In Good Standing Adoption Agencies Act of 2026. This is a standard header provision with no operational effect beyond identifying the measure.
State reporting requirement and definition of child placement agency
Requires each State with an approved plan under part IV to submit an annual list (by January 1) of private child placement agencies that were licensed or accredited, in good standing, and exempt under section 501(c)(3) as of the end of the prior fiscal year. The provision defines 'child placement agency' narrowly as an agency that places children in prospective adoptive homes, which focuses the requirement on adoption-focused providers rather than all foster or placement services.
HHS compilation and public national list
Directs the Secretary, via the Children’s Bureau, to compile each State’s most recent submission into a consolidated, publicly accessible national list. Practically, that centralizes basic licensing and tax-status information about private adoption providers, putting the onus on HHS to host and present the data but not prescribing format, verification steps, or remediation procedures.
Annual reporting to Congress identifying omissions and disciplinary actions
Obligates HHS to deliver an annual written report to Congress that contains the compiled list and highlights any agency a State licenses but did not include on its submission, plus a specification of any disciplinary actions a State has taken against a private child placement agency. This creates a formal transparency channel from State licensure actions to federal oversight and policy review.
Conditioning incentive payments on State compliance
Modifies the eligibility rules for adoption and legal guardianship incentive payments so that a State must have complied with the new annual reporting requirement to receive those funds. That amendment uses the existing federal payment mechanism as enforcement leverage, making the reporting obligation material to State budgets and program incentives.
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Explore Social Services in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Prospective adoptive parents and families — gain a central, public source to check whether a private placement agency in a State reports as licensed, accredited, and in good standing, improving transparency when selecting providers.
- Congress and federal policymakers — receive a standardized, annually updated dataset and specified disciplinary histories to inform oversight, policy design, and potential legislative fixes.
- Child welfare advocates and researchers — obtain a public, aggregated list that can be used for analysis, monitoring provider behavior across States, and identifying patterns in disciplinary actions.
- Licensed 501(c)(3) private placement agencies that comply with State requirements — can use listing as a credibility signal to prospective parents and referral sources.
Who Bears the Cost
- State child welfare agencies — must establish or adapt reporting processes to produce the annual roster (administrative burden) and face the risk of losing adoption/guardianship incentive payments if they miss the deadline or submit incomplete data.
- Private placement agencies that are not 501(c)(3) organizations — are excluded from the federal list and lose the reputational advantages of appearing on the national roster, potentially reducing referrals and visibility.
- HHS Children’s Bureau — must operate, maintain, and publish the national list and prepare annual Congressional reports without the bill specifying dedicated funding, adding ongoing operational responsibilities.
- Individual agencies and staff — may face reputational and business impacts from public listing errors or state disciplinary disclosures, with limited statutory remediation pathways provided in the bill.
Key Issues
The Core Tension
The central dilemma is between transparency and centralized oversight on one hand, and accuracy, due process, and state regulatory autonomy on the other: the bill seeks to expose who is 'in good standing' nationally, but it relies on disparate State definitions and uses federal funding leverage to enforce reporting, a combination that can both improve visibility into providers and unfairly penalize States or agencies when records, definitions, or processes diverge.
The bill tightens transparency by compiling a single federal list, but it leaves several implementation points unresolved. It does not define 'in good standing' or set uniform standards for 'licensed or accredited,' so States will apply their own licensure criteria; that will produce variation in who appears on the national list and complicate cross‑State comparisons.
The exclusion of non‑501(c)(3) providers is a hard cutoff that could reshape the market for private placement services — for example, for faith‑based or for‑profit entities that are licensed by States but do not claim tax‑exempt status.
Using incentive payments as enforcement gives the federal government a blunt tool to induce compliance, yet withholding or conditioning funds could have downstream effects on child welfare services and adoption initiatives that rely on those payments. The bill also omits a clear correction or appeals process for agencies that are omitted from a State submission or inaccurately characterized, and it does not specify data‑quality standards, verification protocols, or privacy safeguards for the published material.
Those gaps create real operational and legal risks — inaccurate public listings could harm agencies and families, and ambiguous disciplinary reporting could be misinterpreted without contextual details.
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