    District of Columbia Child Welfare: Long-Term Challenges to Ensuring
    Children's Well-Being (Letter Report, 12/29/2000, GAO/GAO-01-191).

    Once in the care of the District of Columbia's child welfare system,
    many children have languished there for extended periods of time. Years
    of indifference, managerial shortcomings, and long-standing
    organizational divisiveness constrained the system's ability to keep
    children safe. As a result of these prolonged deficiencies, the U.S.
    District Court for the District of Columbia issued a remedial order in
    1991 to improve the performance of the child welfare agency. GAO assesed
    the agency's progress in complying with the court's requirements,
    specifically examining how financial and operational changes made by the
    Children and Family Services Agency (CFSA) have affected the protection
    of children and the provision of services to children and families, the
    extent to which critical elements of an effective child welfare system
    have been applied in the District, and issues that need to be addressed
    in planning for the transfer of CFSA back to local governance. GAO found
    that the financial and operational changes have not significantly
    improved the protection of children or the delivery of other child
    welfare services. Although the District has begun to integrate child
    welfare services with other support services, it still lacks a fully
    developed collaborative structure to help foster more efficient
    day-to-day operations and improve program accountability. Furthermore,
    multiple issues must be resolved before CFSA can be transferred back to
    local governance.

    --------------------------- Indexing Terms -----------------------------

     REPORTNUM:  GAO-01-191
         TITLE:  District of Columbia Child Welfare: Long-Term Challenges
    	     to Ensuring Children's Well-Being
          DATE:  12/29/2000
       SUBJECT:  Child abuse
    	     Foster children
    	     Public administration
    	     Municipal governments
    	     Interagency relations
    IDENTIFIER:  District of Columbia
    	     District of Columbia FACES Information System
    	     District of Columbia D.C. KIDS Program

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    GAO-01-191

    Report to the Subcommittee on the District of Columbia, Committee on
    Government Reform, House of Representatives

    December 2000 DISTRICT OF COLUMBIA CHILD WELFARE

    Long- Term Challenges to Ensuring Children's Well- Being

    GAO- 01- 191

    Letter 3 Appendixes Appendix I: Scope and Methodology 44

    Appendix II: District of Columbia Child Welfare System Features the MFO
    Required, July 2000 46

    Appendix III: Child and Family Services Agency Organization, September 2000
    54

    Appendix IV: Comments From the Child and Family Services Agency 55

    Related GAO Products 60 Tables Table 1: Modified Final Order and Actual
    Caseloads, July 2000 14

    Table 2: The Percentage of Case Plans Entered in FACES, September 2000 18
    Table 3: Cases Referred to Investigation, October 1999 to July 2000 20 Table
    4: Children Placed in Settings Prohibited by the MFO,

    July 2000 22 Table 5: The Timeliness of Case Reviews, December 1998 and

    July 1999 28 Figure Figure 1: Key Participants in the District of Columbia's
    Child

    Welfare System 34

    '

    Abbreviations

    AFDC Aid to Families with Dependent Children ASFA Adoption and Safe Families
    Act of 1997 CFSA Child and Family Services Agency CSS Court Social Services
    DHS Department of Human Services HHS Department of Health and Human Services
    ICPC Interstate Compact for the Placement of Children MFO modified final
    order MIS Management Information System MPD Metropolitan Police Department
    MSW Master of Social Work OCC Office of Corporation Counsel SACWIS Statewide
    Automated Child Welfare Information System

    Lett er

    December 29, 2000 The Honorable Tom Davis Chairman The Honorable Eleanor
    Holmes Norton Ranking Minority Member Subcommittee on the District of
    Columbia Committee on Government Reform House of Representatives

    Many children in the District of Columbia, like those in other jurisdictions
    across the country, have lived at risk of abuse and neglect. Once in the
    care of the District's child welfare system, many have languished there for
    extended periods of time. Years of indifference, managerial shortcomings,
    and long- standing organizational divisiveness constrained the system's
    ability to keep children safe. As a result of these prolonged deficiencies,
    the U. S. District Court for the District of Columbia issued a remedial
    order in 1991 to improve the performance of the child welfare agency and,
    lacking sufficient evidence of program improvement, later removed the agency
    from the District's Department of Human Services (DHS) and placed it in
    receivership in 1995. 1 Under a modified final order (MFO) established by
    that court, the receiver of the Child and Family Services Agency (CFSA) was
    directed to comply with more than a hundred policy and procedural
    requirements. These requirements include steps for improving protective
    services; services to children and families; and the placement, supervision,
    and review of children in foster care. On October 23, 2000, the court signed
    a consent order that outlines a process to terminate the receivership upon
    the satisfaction of certain specified conditions. 2

    Prompted in part by the death in January 2000 of a toddler who had been in
    the care of the child welfare agency, you asked us to assess the progress
    the receiver appointed in October 1997 had made in complying with the
    requirements of the MFO and other critical elements that are important to
    facilitating needed reforms. In May 2000, we testified on our initial
    observations of the agency's efforts to achieve compliance with the MFO

    1 The agency was known in 1991 as the Child and Family Services Division of
    the District of Columbia's Department of Human Services. A receivership is
    an arrangement in which a court appoints a person to temporarily manage a
    local agency with broad authority to ensure full compliance with the court
    order in an expeditious manner.

    2 LaShawn A. v. Anthony Williams, Consent Order, C. A. No. 89- 1754, October
    23, 2000.

    and related systemwide issues. 3 Subsequently, you asked us to conduct more
    in- depth work to examine (1) how financial and operational changes made by
    CFSA to comply with the MFO have affected the protection of children and the
    provision of services to children and families, (2) the extent to which
    critical elements of an effective child welfare system have been applied in
    the District, and (3) issues that need to be addressed in planning for the
    transfer of CFSA back to local governance.

    In conducting this work, we interviewed a variety of key participants in the
    District's child welfare system, including the receiver, CFSA managers and
    staff, and other District of Columbia officials, as well as child welfare
    experts affiliated with other organizations. We also obtained and analyzed
    information from CFSA to document the extent to which it has complied with
    key provisions of the MFO. In addition, we reviewed reports and evaluations
    that examined CFSA's performance and key challenges facing the District's
    child welfare system. We conducted our work between March and October 2000
    in accordance with generally accepted government auditing standards. (A more
    detailed discussion of our scope and methodology appears in appendix I.)

    Results in Brief The receiver has undertaken financial and operational
    changes in an effort to comply with the MFO and improve children's well-
    being by addressing

    management and programmatic needs. These changes include initiatives to
    recruit and train qualified social workers, develop policies and procedures
    to guide service delivery to children and families, establish and enhance
    organizational components, and develop a new automated information system.
    However, the implementation of these management and programmatic changes has
    not resulted in significant improvements in the protection of children and
    the provision of other child welfare services. For example, children in the
    District's care remain in the system for an average of 3.7 years, which far
    exceeds the federally mandated goal of 12 months. In addition, inadequate
    efforts to retain staff have contributed to caseloads that exceed the
    maximum caseloads allowed by the MFO and have impaired the ability of social
    workers to perform critical services, such as visiting children to ensure
    their safety and the adequacy of their care and making referrals to other
    support services.

    3 Foster Care: Status of the District of Columbia's Child Welfare System
    Reform Efforts (GAO/ T- HEHS- 00- 109, May 5, 2000).

    Our previous work has shown that critical elements of an effective child
    welfare system include collaborative operations among the agencies that
    provide child welfare- related services to children and families and
    “casespecific” initiatives that aim to bring together children,
    family members, social workers, attorneys, and others to help address the
    needs of a specific child and family. Although the District has begun
    efforts to integrate child welfare services with other support services, its
    child welfare system still lacks a fully developed collaborative structure
    to help foster more efficient day- to- day operations and improve program
    accountability. To address case- specific needs, some entities in the child
    welfare system have initiated projects of limited scope. For example, the
    District of Columbia Superior Court instituted a mediation pilot that is
    designed to involve relatives in making important decisions regarding
    children's care, and two neighborhood collaboratives began family case
    conferencing practices to address circumstances that undermine family
    stability.

    Beyond expanding efforts at collaboration, District officials also
    identified several other key factors that need to be addressed before CFSA
    can be transferred back to local governance. These factors include ensuring
    adequate staffing and elevating CFSA to a cabinet- level agency within the
    District government to provide for greater independence in setting
    priorities and obtaining resources. District officials and child welfare
    experts placed high priority on developing a transition plan that
    incorporates these issues, because the District's child welfare system
    continues to face significant challenges despite the changes initiated by
    the receiver and first steps the District has taken to foster systemwide
    collaboration. An emergency reform plan prepared at the request of this
    subcommittee on October 4, 2000, and a consent order issued on October 23,
    2000, by the U. S. District Court for the District of Columbia will
    significantly influence the pending transfer of CFSA to local governance.
    Among other priorities, both call for establishing CFSA as a cabinet- level
    agency and providing sufficient legal support for children in the agency's
    care. While the court- mandated requirements provide a framework for
    addressing longstanding structural and operational challenges, a long- term
    commitment from the Mayor and District government will also be necessary to
    develop the child welfare system's capacity to protect children. In its
    comments on a draft of this report, CFSA found it to be balanced, noting
    clarifications that we have incorporated where appropriate.

    Background The appointment of a child welfare receivership began with the
    filing of a class action in 1989 on behalf of abused and neglected children
    in the

    District of Columbia. The U. S. District Court trial and subsequent opinions
    documented many shortcomings within the child welfare system and led to a
    finding of liability on the part of the District. For example, the court
    found that as a result of inept management and the indifference of the
    mayor's administration, the District had failed to comply with reasonable
    professional standards in almost every area of its child welfare system.
    Specifically, the court found that the District had failed to investigate
    reports of neglect or abuse in a timely manner, make appropriate placements
    for children who entered the child welfare system, monitor their care, or
    adequately ensure that they had permanent homes. Court documents traced
    these failures to staffing and resource problems- namely, staff shortages,
    inconsistent application of policies and procedures, and an inadequate
    automated system to track the placement and status of children in the
    District's care. A remedial action plan was developed jointly by the
    plaintiffs and the defendants in the class action, and that plan led to the
    development of the MFO in January 1994. The MFO includes more than a hundred
    policy, procedural, and data requirements with which the agency must comply.
    These requirements include steps for improving protective services; services
    to children and families; and the placement, supervision, and review of
    children in foster care (app. II provides a summary of selected
    requirements). In 1995, the court, lacking sufficient evidence of program
    improvement, removed the agency from DHS and placed it in full receivership.
    Since then, the court has twice appointed a receiver to manage the child
    welfare agency's efforts to institute the changes outlined in the MFO. The
    first receiver served from August 1995 through June 1997. Not finding
    improvements in the child welfare program, the court appointed a second
    receiver in 1997, who served through November 30, 2000. The court appointed
    the deputy receiver for programs to serve as interim receiver effective
    November 30, 2000.

    The receiver appointed in 1997 primarily focused on changes to the
    organization's infrastructure, such as enhancing personnel management and
    implementing a new management information system, as we reported in our
    previous testimony. Additionally, in February 2000, CFSA consolidated
    functions that had been dispersed at seven locations throughout the city and
    co- located almost all staff into the same building (see the CFSA
    organization chart in app. III). CFSA has also taken steps to create new
    organizational roles or units to fulfill specific responsibilities.

    For example, in 1998, the receiver hired specialists in child care, housing,
    education, and substance abuse, who act as “internal
    consultants” by sharing their expertise with social workers and
    interacting with other District agencies. The substance abuse specialist,
    for example, identifies and locates services in the community that meet the
    needs of the population of children in CFSA's care.

    CFSA provides a range of child welfare services from the time children enter
    the system until they reach permanent stable care arrangements.
    Specifically, the Intake Administration oversees the process by which
    children enter the system. After intake, children are served by a number of
    different programs, depending on the setting in which they are placed once
    they are removed from their home, such as traditional foster care, kinship
    care, and adoptions. Other program areas provide special services, such as
    the Teen Services Division, which focuses on adolescents in care by, for
    example, helping to prepare them to live independently as adults, and the
    Family Services Division, which addresses the needs of families when a
    determination has been made that a child can safely remain at home. Health
    Services, through a program called D. C. KIDS that was established in
    October 1999, provides for initial physical and mental health screenings and
    for continuing medical care.

    In recent years, the number of children receiving such services has
    increased, while the number of social workers has declined. Although the
    agency serves children in a variety of settings, in December 1997, 2 months
    after the appointment of the second receiver, there were approximately 2,900
    children in foster care; at that time, there were 289 social workers on
    board providing a broad array of services in agency programs, such as
    kinship care, foster care, and adoptions. 4 As of August 31, 2000, there
    were about 3, 271 children in foster care, and the agency employed 241
    social workers. 5 To provide services to children, CFSA had a budget in
    fiscal year 2000 of $147 million, almost one- third of which was federal
    child welfare

    4 These data do not include social work aides and trainees who can assist
    social workers in their duties. 5 These data do not include social work
    aides and trainees who can assist social workers in their duties. As of
    August 31, 2000, CFSA had 677 employees.

    funding. 6 The MFO requires CFSA to maximize its use of several federal
    funding sources, including title IV- E and Medicaid, and it has taken steps
    to increase the receipt of such funding. CFSA has requested an increase of
    $37 million for fiscal year 2001, for a total budget of $184 million, which
    according to some agency officials is the first budget that will fully
    support their efforts to comply with the MFO.

    CFSA operates in a complex child welfare system. Although it provided many
    services directly, in fiscal year 2000, about 57 percent of all agency
    expenditures were spent on contracted services. For example, contracts
    provide for placements of children in group homes as well as some foster
    homes and other facilities. The agency spends about $6. 2 million annually
    on eight Healthy Families/ Thriving Communities collaboratives, nonprofits
    that provide neighborhood- based support services to stabilize families so
    that fewer children enter the child welfare system. CFSA also works with a
    consortium of 22 private agencies to place children in foster and adoptive
    homes. 7 In addition, CFSA relies on services provided by other District
    government agencies. For example, both the Fire Department and the Health
    Department inspect facilities where children are placed; D. C. Public
    Schools prepares individual education plans for children in care; and the D.
    C. Interstate Compact office in the Department of Human Services has
    responsibility for working with CFSA and other states to process the
    interstate placement of children. 8 To process cases through the court
    system, CFSA interacts with 59 D. C. Superior Court judges, each of whom has
    responsibility for a share of the child abuse and neglect caseload. Under
    District of Columbia law, while CFSA has primary responsibility for

    6 Federal funding is primarily authorized under title IV- E of the Social
    Security Act, which reimburses states for a portion of out- of- home care
    costs for children under the Aid to Families with Dependent Children (AFDC)
    program. Although legislation passed in 1996 eliminated the AFDC program,
    children who meet the 1996 eligibility criteria for AFDC continue to be
    eligible for title IV- E assistance.

    7 Consortium members include agencies like Lutheran Social Services,
    Catholic Charities, and For Love of Children. 8 The Interstate Compact for
    the Placement of Children (ICPC) is essentially a uniform law, enacted in
    all 50 states, the District of Columbia, and the U. S. Virgin Islands, that
    governs the interstate placement of children in foster and adoptive homes.
    Under ICPC, the state from which a child is sent retains jurisdiction over
    the child and his or her placement. Each state must, however, provide the
    other with information sufficient to ensure that a placement is appropriate
    and in the best interest of the child. Although this report discusses the
    District's role in the ICPC process, we use “interstate
    placement” to refer to placements outside District boundaries.

    investigating neglect cases, the Metropolitan Police Department (MPD) has
    primary responsibility for investigating abuse cases. 9 This arrangement,
    known as “bifurcation,” is unique among child welfare systems
    nationwide. Following MPD investigation, the office of Court Social Services
    (CSS) of the District's Superior Court provides oversight and management of
    these abuse cases, which totaled about 600 in July 2000. In abuse cases in
    which a child cannot be returned home and no relative can be found, CSS
    transfers the case to CFSA.

    In addition to complying with the provisions of the MFO and District law,
    CFSA must comply with applicable federal laws, including the Adoption and
    Safe Families Act of 1997 (ASFA), which placed new responsibilities on all
    child welfare agencies nationwide. The act introduces new time periods for
    moving children toward permanent stable care arrangements and penalties for
    noncompliance. For example, it requires states to hold a permanency planning
    hearing no later than 12 months after the child is considered to have
    entered foster care.

    In an effort to provide for greater accountability among court- appointed
    receivers in the District, including the child welfare receiver, the
    Congress passed and the President signed in October 2000 the District of
    Columbia Receivership Accountability Act of 2000 (Pub. L. No. 106- 397). The
    act provides for increased oversight and accountability of receivership
    performance. The act specifies several approaches for enhancing oversight,
    including periodic fiscal, management, and program audits, that are intended
    to strengthen the structure of accountability for District government
    programs.

    Receiver's Changes Since 1997, the receiver introduced management and
    programmatic

    Had Limited Effect on changes intended to meet the requirements of the MFO
    and to improve

    child welfare outcomes in the District. These changes include initiatives to
    Children's Well- being

    recruit and train qualified social workers, provide additional funding for
    community- based services, establish and enhance organizational components,
    and develop a new automated system. The implementation of these efforts has
    fallen short of expected results, and these efforts have had a limited
    effect on CFSA's ability to provide needed child welfare services to enhance
    children's well- being and guide their progress toward

    9 D. C. Code Ann. 6- 2104. The MFO requires CFSA to conduct joint
    investigations with MPD.

    permanent stable care arrangements. For example, although many new staff
    have been hired, some had not yet been assigned caseloads because of delays
    in obtaining professional social work licenses. As a result of such delays
    and inadequate efforts to retain staff and maintain adequate staffing
    levels, caseloads remain above standards defined in the MFO. This impairs
    social workers' ability to perform critical casework functions, such as
    visiting children to ensure their safety and adequacy of care, preparing
    court reports, and investigating cases within designated time periods.
    Likewise, CFSA issued a policy handbook in 1995 to which it has made
    numerous revisions. While a recent effort to include these policies in the
    agency's automated system may improve staff access to them, many staff told
    us that they have lacked consistent direction in how to implement policies
    during the course of their work. Moreover, the policy handbook and
    subsequent revisions do not yet include policies covering all requirements
    of the MFO. In addition, CFSA's new automated system- FACES- lacks complete
    case information, and social workers have not fully used it in conducting
    their daily case work. 10

    Changes in Key In response to management- related requirements contained in
    the MFO,

    Management Requirements the receiver undertook changes in areas such as
    recruitment and retention,

    Fall Short of Expected training, social worker caseload reduction, the
    development of policies and

    Results procedures, and the implementation of a new automated information

    system. However, these changes have generally fallen short of expected
    results. (See app. II for an assessment of CFSA's compliance with selected
    provisions of the MFO.)

    Recruitment, Retention, and Problems with the recruitment and retention of
    qualified social workers

    Training Activities preceded the receivership. Recognizing these challenges,
    the MFO required

    CFSA to improve recruitment efforts and hire a sufficient number of social
    workers who had obtained Master of Social Work (MSW) degrees. 11

    10 An agencywide contest provided the name for the information system. 11 In
    order to carry cases, social workers with an MSW must also obtain
    professional social work licenses. One factor that delayed the immediate
    deployment of social workers upon their being hired was a prolonged
    licensing process. Some newly hired social workers we spoke to said that
    they had been on the job for periods ranging from 3 to 5 months before
    receiving their licenses. The Deputy Mayor for Children, Youth, and Families
    announced in September 2000 that the Mayor had signed an order allowing the
    District to automatically recognize licenses granted by other states as one
    way to expedite licensing for some new hires.

    Following recent recruitment efforts, CFSA hired 56 social workers between
    March and June 2000, which represented 80 percent of its goal of 70 new
    hires for that period. 12 This hiring activity resulted from recruitment
    efforts that included obtaining independent hiring authority in October
    1999, developing a recruitment plan in March 2000, conducting several job
    fairs, raising salaries, and offering additional recruitment incentives.

    The retention of qualified social workers, however, has been a constant
    challenge for CFSA. To help the agency maintain a stable workforce, the MFO
    required it to develop a retention plan. As of August 2000, CFSA had created
    a retention committee that meets periodically and reports to the receiver,
    but it has not developed an agencywide retention plan. The agency continues
    to experience a fluctuating yet significant loss of social workers. CFSA
    staff estimated that in 1997, the first year of the receiver's term, the
    agency lost about 15 social workers per month. While CFSA officials stated
    that this rate had declined by June 2000 to about four or five social
    workers per month, attrition continues to be a significant issue. 13
    Overall, according to a CFSA official's estimate, the agency lost about
    onethird of its social workers between January 1999 and July 2000.

    While attrition is high in many other child welfare agencies across the
    country, turnover among social workers in the District is explained in large
    part by unmanageable workloads and the availability of better- paying jobs
    with other District agencies and the private sector, according to CFSA
    officials and staff. Furthermore, according to CFSA's analysis of interviews
    with staff who left the agency, some social workers cited the quality of
    supervision as a reason for their decision to resign. 14 CFSA officials
    noted that the creation of a social worker associate position at the
    Bachelor's of

    12 Before CFSA obtained independent hiring authority in October 1999, it
    could not conduct direct recruitment and had to depend on the District's
    Office of Personnel to refer candidates to fill positions. According to CFSA
    human resources officials, the agency received only 10 to 15 referrals of
    job candidates each year from DHS before CFSA obtained its independent
    hiring authority. CFSA officials believed the agency would comply with the
    MFO with 60 new hires.

    13 Agency data for June, July, and August 2000 show that CFSA lost between
    five and nine social workers each month. 14 CFSA officials indicated that
    two new initiatives- the conversion of all agency management and supervisory
    employees from career service to the District government's Management and
    Supervisory Service and the development of a new agency performance
    appraisal system- could enhance accountability for management and
    supervisory employees.

    Social Work level could help agency retention efforts by providing more
    flexibility in assigning such workers to deliver some MFO- required
    services.

    High turnover adversely affects CFSA's capacity to effectively manage the
    provision of services to children and families. According to CFSA staff, the
    agency is losing many of its more experienced social workers, whereas the
    new hires selected to replace these workers and to help CFSA attain more
    desirable staffing levels face a significant learning curve. New hires,
    senior social workers, and supervisors we spoke with also cited casework
    problems associated with high turnover, such as delays that result when
    social workers resign and cases previously assigned to them need certain
    actions, including transfer to another program area. New hires also stated
    that once on the job, they were assigned cases previously handled by others
    that lacked sufficient case data, forcing them to spend extra time to
    recreate the data and learn the case history. Additionally, high turnover
    results in the assignment of a succession of social workers to the case of a
    child in CFSA's care, furthering instability in the lives of these children.

    The MFO also required CFSA to establish a full- time training unit and to
    provide minimum requirements for training new hires and ongoing training for
    more senior workers. While CFSA has met these requirements, casework
    priorities often lead to low attendance at training sessions. In response to
    these requirements, the agency initially conducted a needs assessment to
    plan the development of the training unit. Until the training unit was
    established, an administrator and a trainer provided or obtained training
    for agency employees. In January 1999, CFSA established the training unit
    through a contract with Virginia Commonwealth University to provide training
    to agency social workers beginning in February 1999. 15 The university has
    developed a training course for new hires, which provides the 80 hours the
    MFO requires, and a curriculum of about 30 courses, from which more senior
    staff can choose classes to meet the continuing education requirements of
    the MFO. The training program director reported that between May and October
    2000, 54 of 72 new hires completed their initial training. 16 Additional
    training has been provided in areas such as preparing for court appearances
    and meeting ASFA requirements.

    15 The contract is supported by subcontracts with Howard University and
    Catholic University of America. 16 Additionally, the training program
    director stated that 212 CFSA staff with casework responsibilities received
    some form of training between May and October 2000.

    Staff we interviewed expressed a variety of views on the quality of
    training. For example, some new hires who had recently earned their MSWs
    stated that they found portions of the new- hire training to be elementary
    or insufficiently tailored to their case management duties at CFSA. In
    addition, staff at all levels stated that they wanted additional training in
    how to assess the risks a child faces at home to determine whether removal
    is necessary, as well as additional training in agency policies and
    procedures. CFSA officials stated that risk assessment training has been
    offered to intake workers several times but cancelled for poor attendance.
    CFSA officials and social workers stated that casework priorities often
    result in low attendance at classes, which leads to either course
    cancellations or rescheduling trainers. CFSA incurs additional training
    costs that range from $500 to $800 per day for rescheduled classes.

    In addition, the MFO required CFSA to assess whether staff satisfactorily
    master the course content. CFSA lacks such methods, although the agency
    hired a curriculum specialist in September 2000 to develop methods for
    evaluating the extent to which social workers apply training content to the
    work they perform.

    Caseload Reduction The MFO established caseload limits to help social
    workers respond to the service needs of children and families. Although CFSA
    has achieved these caseload levels in some program areas, the caseloads CFSA
    reported for other areas remain significantly above the maximum caseloads
    allowed by the MFO, limiting social workers' ability to meet the needs of
    children and families. For each program area, table 1 identifies staffing
    levels, caseloads per staff required by the MFO, and average caseloads
    carried by CFSA social workers in teams in each program area as of July
    2000. As the table shows, social workers were carrying actual average
    caseloads that exceeded the MFO limits in 6 of 10 CFSA programs. For
    example, workers in the traditional foster care program were carrying
    average caseloads that ranged from 13 to 55, compared with the MFO limit of
    16. Moreover, eight of the agency's nine traditional foster care teams had
    average worker caseloads that exceeded this limit.

    Table 1: Modified Final Order and Actual Caseloads, July 2000 Average Number
    of

    caseload MFO caseload social workers

    range a limit Intake investigations 47 6- 26 12

    Kinship care b 45 3- 33 17

    Family services

    In- home 40 10- 17 17 Intensive family services 10 2- 4 4

    Permanency and placement

    Teen services 13 20- 34 16 Teen life options 5 19 c 12 Traditional foster
    care b, d 36 13- 55 16 Adoptions 34 10- 21 12 Adoption home studies 5 16 c
    30 Family resources 9 25 e 30

    Total 244

    Note: The definition of case varies, depending on the service provided. For
    example, in traditional foster care and adoptions, each child constitutes a
    case. In intake, a case is an investigation; in family services, each family
    is a case; and in adoption home studies, a case is a prospective adoptive
    home. In September 2000, the receiver announced plans to hire 22 additional
    social workers. As a result, actual caseloads carried by social workers
    since then may vary from these data. a CFSA reported average caseloads
    carried per worker by team (or “section”) in each program area.
    A

    team typically consists of five social workers. The data reflect the range
    of average caseloads carried by workers in each team. Of the seven case-
    carrying teams in intake, four exceeded the MFO caseload limit; seven of ten
    kinship teams exceeded the limit; all three teen services teams exceeded the
    limit, as did the teen life options team; eight of nine traditional foster
    care teams exceeded the limit; and five of seven adoptions teams exceeded
    the limit. b Taken together, the kinship and traditional foster care
    programs account for about two- thirds of the

    children in CFSA's care, according to CFSA officials. c Data reflect average
    caseloads for one team in these areas.

    d In foster care, children are placed with foster families after being
    removed from the home. CFSA uses “traditional” to distinguish
    this form of care from “therapeutic foster care,” a form of
    foster care for children who have special needs. Contractors handle CFSA's
    therapeutic foster care program. e Data reflect two teams, each reporting an
    average caseload of 25.

    Source: CFSA.

    Moreover, average caseloads may understate the caseloads actually carried by
    some social workers. Social workers we spoke to consistently described their
    caseloads as overwhelming and unmanageable. To illustrate the effect of high
    caseloads, a senior social worker, also in traditional foster care, told us
    that his caseload included responsibility for 44 children. He described

    the following duties that he must fulfill to meet the needs of these
    children and their families: He must prepare 44 case plans, assess the needs
    of 44 children and make appropriate referrals, attend the court hearings for
    these cases, participate in internal reviews of these cases, and ensure
    appropriate placements in 44 different schools, among other activities. In
    addition, the social worker is responsible for obtaining a variety of goods
    and services, including clothing, transportation, health and mental health
    services, and mentoring services.

    Caseloads that exceed prescribed limits have several effects. For example,
    supervisors reported that they sometimes must carry cases. This practice not
    only violates an MFO requirement that supervisors not carry cases; it also
    limits their ability to provide effective supervision. Yet, CFSA data as of
    June 2000 showed 25 supervisory staff carrying the cases of 129 children.
    High caseloads also have a very direct effect on the availability and level
    of CFSA oversight of the children in its care. Specifically, social workers
    reported that when caseloads are high, certain other activities assume a
    lower priority. Among these are providing referrals so that children can
    obtain needed services, conducting required visits to assess children's
    progress in their placements, and entering data in the management
    information system.

    Finally, social workers we spoke to acknowledged that high caseloads also
    lengthen the time required to process cases, and they contribute to
    difficulties in moving children to permanency without delay. According to a
    report prepared for the Deputy Mayor for Children, Youth, and Families,
    children still spend an average of 3.7 years in the District's child welfare
    system. 17 In this environment, these time periods jeopardize the District's
    ability to comply with ASFA's requirement that children reach permanency
    within 12 months, according to District Superior Court officials.

    Policies and Procedures The MFO required CFSA to develop policies and
    procedures covering 28

    Development key child welfare program areas, including conducting timely

    investigations, providing needed services, developing performance- based
    contracting, appropriately placing children and achieving permanency for

    17 Carolyn N. Graham and Kennedy Khabo, The District of Columbia Safe
    Passages to Permanency Initiative( Washington, D. C.: Office of the Deputy
    Mayor for Children, Youth, and Families, Oct. 1999).

    them, and managing social worker caseloads. 18 The agency issued policies in
    a 1995 handbook. Since then, these policies have been revised by changes
    communicated through “circular letters” that provided draft
    updates to specific policies and procedures and direction that varied from
    supervisor to supervisor. As a result, staff expressed confusion over how to
    achieve consistent implementation of agency policies. Moreover, agency
    policies do not cover all court- mandated requirements contained in the MFO.
    Additionally, until October 2000, CFSA had assigned only one worker to
    coordinate the development of draft policies.

    Even though policies have been in place, CFSA staff told us they have not
    been completely clear or useful in carrying out their work. Uncertainty over
    CFSA's policies constrained supervisors' ability to communicate priorities
    and direct the work of social workers under their supervision, and in some
    cases, social workers expressed a reluctance to seek guidance from their
    supervisor because they felt their supervisor lacked sufficient knowledge.
    Finally, staff we interviewed said that, as a result, CFSA's ability to work
    effectively with other key child welfare partners was constrained. For
    example, according to a CFSA official, the lack of clear and consistent
    policies created uncertainty regarding how social workers should respond to
    directives from the District's Superior Court regarding the preparation of
    court- mandated reports, appearances at court hearings, and other legal
    matters. Even though policies are now available through FACES, CFSA staff
    indicated that social workers will still need to seek supervisory guidance
    to clarify and implement them consistently.

    CFSA officials demonstrated the approved policies and procedures manual
    feature of the automated information system to GAO in October 2000. 19 While
    the policies and procedures appeared to be at least as comprehensive as
    earlier policies, it is too early to say how staff will rely on this new
    feature to obtain consistent direction to their work. However, CFSA
    officials stated that social workers will receive training on using the
    automated policies and can contact CFSA's Office of Planning, Policy, and
    Program Support to obtain clarification on specific policy implementation.

    18 App. II lists these policy requirements and identifies the extent to
    which CFSA has begun to draft policies corresponding to each mandate. 19 The
    feature is available through the system's “Help” menu and
    provides an index and search capability.

    New Automated Information The MFO required CFSA to develop an automated
    information system to

    System permit the agency to comply with the provisions of the MFO and with

    District law. On October 1, 1999, CFSA implemented the FACES system, adapted
    from systems previously implemented in Oklahoma and West Virginia, at a cost
    of about $20 million. 20 While additional modifications or enhancements
    could be made, CFSA considers the system fully implemented and available for
    staff use. According to the system administrator, several factors
    contributed to system design: the requirements of federal law, compliance
    with the provisions of the MFO, and input from a team of 70 “end
    users” consisting of staff from various program areas throughout the
    agency. While CFSA officials believe FACES will comply with federal
    requirements, it cannot produce all the reports the MFO required. 21 For
    example, CFSA reported that FACES could not produce reports on the
    timeliness of administrative reviews and could not generate certain
    placement data as specified by the MFO. 22

    CFSA staff also do not fully use the system. Staff across the agency noted
    that they continue to use spreadsheets or databases outside of FACES. 23 The
    system administrator expressed concerns about the completeness of the data
    in FACES- and, therefore, its validity- noting that incomplete data entry
    undermines the purpose for which the system was designed. She described
    FACES as a tool that supports case practice and allows social workers and
    supervisors to track cases, assess risks to children, control vendor
    payments, and assess contractor performance. The system can also document
    actions social workers perform during a case's entire history. To the extent
    that timely and complete data entry is not achieved, however, the agency's
    ability to track its entire caseload is compromised. In part, this low usage
    stems from the lack of case data entry into the system by social workers.
    For example, CFSA officials estimated that as of September 2000,

    20 Included in this cost is $10 million in federal funding. 21 System
    officials stated that the federal Statewide Automated Child Welfare
    Information System (SACWIS) compliance visit took place in June 2000. CFSA
    officials expected that the federal Department of Health and Human Services
    (HHS) would provide a draft of its review in December 2000.

    22 Federal law and the MFO require an administrative review every 6 months
    of the progress toward permanency and the achievement of case plan goals for
    all children in foster care. 23 For example, staff in administrative review,
    adoptions, placement, and monitoring said that they maintain data outside
    FACES. System staff believe that FACES could accommodate some of these
    functions and said that they have begun to discuss with staff in certain
    program areas how such data could be included in FACES.

    across all programs, about half of all case plans had been entered into
    FACES; however, Superior Court judges and a court official we spoke to
    believe that this estimate may overstate the actual rate of data entry. CFSA
    officials also noted that the percentage of data entered in the system
    varies by program area, as shown in table 2.

    Table 2: The Percentage of Case Plans Entered in FACES, September 2000
    Program area Percentage of case plans entered

    Intake a 100 Adoptions 70 Family services 65 Teen services 60 Traditional
    foster care 42 Kinship care 35 Note: Together, kinship and traditional
    foster care account for about two- thirds of all children in CFSA's care,
    according to CFSA officials. a Intake workers are responsible for creating
    cases in FACES and for entering data that support the

    case plan, such as legal information, family demographics, and contact
    notes. Because a case cannot be transferred to another program area if these
    data are left blank, CFSA officials stated that 100 percent of these data
    are entered as new cases are created. However, CFSA officials estimated that
    70 percent of the cases that remain in intake for more than 30 days have
    been entered in the system.

    Source: CFSA.

    The system administrator identified several possible reasons why social
    workers might not be entering complete data into FACES: a lack of comfort
    with learning new technology and a “cultural” preference for
    paper documents among child welfare practitioners, a lack of knowledge among
    staff about the system's capabilities, supervisors' decisions to allow
    social workers to continue using paper, and insufficient time to use the
    system because of other case priorities. Social workers also said that when
    caseloads become difficult to manage, other activities like data entry
    assume a lower priority.

    Finally, FACES is not yet well linked with systems in other agencies. 24
    Existing linkages with other agencies are limited and do not include key
    participants in the child welfare system, such as MPD, CSS, Office of

    24 In this context, “linked with” means “able to
    access” FACES or FACES data from a remote location.

    Corporation Counsel (OCC), D. C. Superior Court, and D. C. KIDS. 25
    Officials in some of these agencies expressed a desire for access to FACES
    to track children in the child welfare system and report more complete case
    information in support of District efforts to obtain additional federal
    funds. In July 2000, the CFSA System Administrator noted that the agency's
    2001 budget provides for limited linkages with OCC, CSS, and MPD and a full
    FACES interface with D. C. KIDS. However, implementation priority to date
    has focused on rolling out the system within CFSA.

    Changes in Key ProgramRelated In addition to requirements that address human
    resources and caseloads,

    Areas Also Fail to the MFO imposed program requirements on CFSA in a number
    of areas,

    Meet Established Goals ranging from intake and assessment to efforts to
    provide children with

    permanent placements. Despite progress in some areas, CFSA still faces
    challenges in meeting the terms of the court order. In particular, the
    agency has not met certain MFO time periods for initiating and completing
    investigations. While the agency has begun to address its need for
    additional homes and facilities, it continues to place children in settings
    prohibited by the MFO, such as homes without current licenses and homes with
    more children in their care than their licenses permit. Additionally, CFSA
    has not consistently met MFO requirements regarding the provision of ongoing
    support services to children once they are placed, and its oversight of
    contractors' service delivery is limited. Moreover, while the agency has
    added staff to process the cases of children placed outside the District
    without proper documentation, a large backlog of these cases remains.
    Finally, despite MFO requirements to expedite the process by which children
    move into permanent, stable care arrangements, children still spend an
    average of 3. 7 years in the system.

    Intake and Assessment The court order mandated certain time periods to
    expedite the process by which children enter the child welfare system. For
    example, it required that investigations be initiated within 48 hours of the
    receipt of the abuse or neglect report and completed within 30 days of the
    report. District law exceeds the MFO requirement and requires that the
    initial investigation be

    25 CFSA exchanges data with the Income Maintenance Administration and has
    system linkages with the Office of Early Childhood Development, some of the
    Healthy Families/ Thriving Communities collaboratives, and 22 private
    consortium agencies (a group that includes Lutheran Social Services,
    Catholic Charities, For Love of Children, and others).

    initiated within 24 hours of the report. 26 As shown in table 3, CFSA has
    had great difficulty meeting these requirements. For example, roughly one-
    third of all cases referred for investigation since October 1999 were not
    initiated within 24 hours of the report and CFSA failed to complete
    investigations within 30 days on about half of them.

    Table 3: Cases Referred to Investigation, October 1999 to July 2000 Not

    Rate not completed

    Completed completed

    within time within time

    within time Total number

    period period

    period

    Investigations initiated within 24 hours 2, 586 954 1, 632 37%

    Investigations completed within 30 days a 2,894 1, 495 1,399 52%

    Note: Investigations include child neglect cases investigated by CFSA and
    child abuse cases investigated by MPD. An investigation constitutes cases in
    which every member of the household under investigation has been
    interviewed, according to CFSA officials. a These numbers refer to cases
    undergoing investigation between October 1999 and July 2000.

    However, the total number of cases is higher than that for cases initiated
    within 24 hours because 308 of these investigations were begun before
    October 1999.

    Source: CFSA.

    CFSA has made some progress in reducing the backlog of cases for which
    investigations had not been completed within 30 days. An intake official
    recently reported that the backlog of incomplete neglect investigations had
    been significantly reduced and that only 30 incomplete investigations
    remained as of August 2000. Beginning in June 2000, CFSA set a unit of
    recently hired intake workers to helping the MPD reduce its own backlog that
    had not met the 30- day time period from 177 cases to 64 cases. However,
    intake officials acknowledged continuing difficulties in meeting both the
    24- hour and the 30- day time periods. Intake officials cited staff turnover
    as one explanation. CFSA lost about 26 percent of its intake workers in
    1999. Intake officials believe they will be able to comply with both time
    periods if the agency is fully staffed, and they cited the succes

    26 D. C. Code Ann. 6- 2102 and 6- 2103.

    that new intake workers had in reducing the backlogs in July 2000 as one
    example of their ability to comply, given additional staff.

    The MFO also required joint investigations of abuse cases by CFSA social
    workers and police officers and mandated that CFSA develop policy to guide
    such joint activities. While CFSA reported that 562 joint investigations
    were conducted in fiscal year 2000, joint investigations are not yet
    routine. 27 For example, CFSA and MPD officials agree that this number
    refers to investigations in which CFSA and MPD staff collaborated in some
    way on a case. The number of cases in which CFSA and MPD jointly visited
    families to conduct investigations is much lower, and the officials could
    not provide a concrete number. While CFSA and MPD officials developed a
    protocol for working together in September 2000, the lack of available staff
    in both agencies is likely to continue to limit their ability to conduct
    joint investigations.

    Opportunities for Placing The MFO addressed the placement of children by
    requiring that CFSA

    Children in Foster, Adoptive, and prepare a needs assessment and development
    plan to identify more

    Group Homes placement opportunities in additional foster, adoptive, and
    group homes

    and other facilities. The MFO also prohibited placing children in settings
    considered harmful to them, such as placing children younger than 6 in group
    homes. 28 While CFSA has not developed a resource development plan per se,
    the agency's strategic plan for fiscal year 2000 identified goals for
    developing more foster and adoptive homes, for example, and included time
    periods and specific steps to be taken. This plan had not yet been updated
    by October 2000.

    Social workers we spoke to emphasized that the development of additional
    capacity in foster and adoptive homes is crucial if children are to be
    appropriately placed in a timely manner. CFSA staff also cited a shortage of
    group homes, noting that 76 placement slots have been lost because of the

    27 Overall, MPD investigated more than 2, 000 abuse cases each year for the
    past 3 years. The Safe Shores D. C. Children's Advocacy Center, a nonprofit
    organization in partnership with District and federal government agencies,
    coordinates the work of an interagency multidisciplinary team to investigate
    allegations of child physical and sexual abuse. The Center has both a CFSA
    liaison and MPD officers on site to facilitate joint responses to case
    referrals.

    28 The MFO exempts from this prohibition children who have exceptional needs
    that cannot be met by any other type of care.

    recent closing of several group homes. 29 Finally, social workers noted that
    the supply shortage is especially acute for emergency care facilities,
    infant care facilities, and homes for large sibling groups.

    CFSA's difficulties in securing appropriate placement facilities are
    illustrated by the fact that CFSA has placed children in facilities that
    lack current licenses, facilities where the number of children exceeds the
    number permitted by the license, and inappropriate facilities- all practices
    prohibited by the MFO. 30 For example, as shown in table 4, in July 2000,
    CFSA reported that 62 children younger than 6 were residing in congregate
    care or group homes for as long as 3 months to almost 2 years. A national
    child welfare expert described such placements as very harmful to young
    children.

    Table 4: Children Placed in Settings Prohibited by the MFO, July 2000 Number
    of

    Number of Type of setting children facilities

    Homes without current licenses 147 81 Homes with more children than allowed
    by license 25 20

    Group homes with children younger than 6 62 5 Source: CFSA.

    The lack of placement options has also led to extended stays by children in
    CFSA's on- site “respite center,” which was not designed for
    overnight care. CFSA staff confirmed that the respite center has been used
    to place children on an emergency basis for several days at a time.

    Recognizing the need to develop new placement capacity, CFSA has taken some
    recent steps to do so, but the effects of these activities are not yet
    known. Moreover, several officials we spoke to agreed on the need for a
    comprehensive analysis of needs, matched with an analysis of existing

    29 As of September 2000, CFSA had slots for 297 children in 17 group homes.
    30 In October 2000, the receiver said that in most cases homes without
    current licenses reflect expired medical information not updated by foster
    parents. At the time of our review, CFSA was exploring ways to obtain such
    information in a more timely manner. Additionally, the consent order
    requires licensing functions to be consolidated within CFSA.

    system capacity to meet the agency's long- term needs for placement
    opportunities. 31

    To address its placement needs, CFSA has worked with the Annie E. Casey
    Foundation to study ways to recruit additional foster homes, and it
    implemented a project with this aim in June 2000. The foundation's Familyto-
    Family initiative, for example, uses strategies to recruit, train, and
    retain foster families that are community- based and culturally sensitive.
    Additionally, CFSA's adoption program manager identified ways to improve
    adoptive home recruitment by, for example, conducting effective follow- up
    with persons interested in adopting. 32 In September 2000, the receiver
    announced emergency plans to pursue contract modifications that would allow
    providers who have an immediate capacity to accept additional children to do
    so.

    Support Services for Foster and CFSA has had difficulties in providing pre-
    placement and post- placement

    Adoptive Families support services. For example, the MFO required social
    workers to visit

    children in foster homes not less frequently than once a week for the first
    2 months after placement. While CFSA reported that as of June 2000 social
    workers had visited most foster children at least once, agency data show
    that in most cases the reported visits were less frequent than once a week.
    As of June 2000, CFSA reported that 53 children had not been visited at all
    since being placed. 33

    Moreover, foster and adoptive parents may not be fully prepared for the
    complexity of children's needs. CFSA's Office of Quality Assurance studied
    children who had experienced multiple placements and concluded that many
    foster parents lacked an understanding and knowledge of how to cope with the
    special needs of some children. 34 These needs reflect underlying conditions
    such as depression, attention deficit hyperactivity

    31 In September 2000, the need for such an analysis was cited by a Chapin
    Hall Center for Children survey of the private organizations providing child
    welfare services to children and families in the District. See Fred Wulczyn,
    Emily Zimmerman, and Jennifer Haight, An Assessment of Contract Agency
    Capacity in the Washington, DC Child Welfare System,

    Chapin Hall Center for Children at the University of Chicago (Chicago: June
    2000). 32 Toni Oliver, Issues in Recruitment( College Park, Ga.: J. T.
    Oliver & Associates, 1993).

    33 Of 1, 030 children needing visits, CFSA reported in June 2000 that 977
    had been visited at least once and 53 had not yet been visited. 34 CFSA
    Office of Quality Assurance, “Children with Four or More
    Placements,” Spring 2000.

    disorder, post- traumatic stress disorder, and attachment disorder. In some
    cases, CFSA has provided insufficient support to stabilize placements and
    prevent disruptions. For example, the report found that, in some cases,
    social workers failed to implement recommendations included in psychological
    and psychiatric evaluations and that some children who had been physically
    or sexually abused were not provided therapy or other services aimed at
    addressing the effect of abuse when they entered foster care.

    Similarly, the MFO recognized that services are necessary to preserve
    adoptive families and requires that families at risk of disruption receive
    appropriate services. A CFSA adoption official acknowledged that many
    children also have special needs that present long- term issues that may not
    become apparent until some time after the adoption has been finalized. This
    situation can appear to be overwhelming to adoptive parents, who may need
    ongoing services to ensure family stabilization and prevent disruption. In
    response to the needs of adoptive families, CFSA initiated a new
    postadoption program, supported by an initial grant from Freddie Mac in June
    1999. 35 The new program will coordinate a range of referrals for adoptive
    parents, such as medical and mental health advocacy groups, developmental
    specialists and therapists, and experts who are knowledgeable about the
    needs of adopted children.

    Oversight of Contracted Services Although the MFO requires CFSA to use
    performance- based contracting, CFSA has made little progress in holding its
    contractors more accountable for the services they provide. 36 For example,
    although CFSA has succeeded in introducing some performance measures to
    guide oversight of the eight Healthy Families/ Thriving Communities
    collaboratives, these performancebased contracts represent a small
    proportion of all contracts. More generally, CFSA's capacity for effective
    oversight of contracts is limited in several ways. The agency employed six
    contract monitors to oversee contract expenditures of about $80 million for
    fiscal year 2000. 37 A CFSA

    35 The Freddie Mac Foundation provides grants to improve outcomes for
    children and families, including initiatives in foster care and adoption. In
    1999, the foundation gave about $1. 9 million to foster care and adoption
    projects nationwide.

    36 The MFO required that each contract include specific standards by which
    contractors' performance can be measured. 37 CFSA stated that this amount
    did not reflect some outstanding payables as of October 2000.

    contracts official stated that some of these contract monitors lack training
    and experience corresponding to this level of responsibility. 38

    CFSA's oversight of certain facilities is augmented by group home and
    residential treatment center monitors, who are responsible for ensuring that
    facility staff and conditions are consistent with the terms of the contract.
    Specifically, 4 group home monitors are responsible for overseeing about 17
    homes, and 3 residential treatment center monitors have oversight of about
    30 facilities. 39 Generally, contracts with the group homes require visits
    by the group home monitors at least once a month, and visits with each
    residential treatment center are to be made at least quarterly. Given the
    monitors' oversight responsibilities and staff resources, they told us they
    need additional monitoring staff to more effectively oversee facility
    performance. Moreover, the monitors stated that there is currently no
    oversight of about 200 purchase- of- service agreements, which are small
    contracts that usually involve specific services for one child each. Agency
    officials stated that CFSA plans to develop a process to monitor these
    contracts.

    Specialized Organizational Units Although not required to do so by the MFO,
    CFSA has added staff to existing organizational units that address
    relationships with the court and the processing of interstate placements for
    children. While both units have helped the agency address specific problems,
    the units face ongoing challenges related in part to high social worker
    caseloads and the agency's difficulties in securing placements for children.

    Since 1998, CFSA has added nine positions to its Court Liaison Unit, which
    formerly consisted of one person. 40 The unit is to track all court reports
    and court orders, submit court reports and case plans in timely fashion, and

    38 CFSA's FACES system has the ability to aggregate social workers' detailed
    ratings of contractor performance to provide specific feedback at contract
    renewal. However, to be effective, this mechanism depends on complete data
    entry, and social workers were not consistently using this feature as of
    October 2000, according to the deputy receiver for operations.

    39 The residential treatment centers are located throughout the country. For
    example, there are centers serving youth in CFSA's care in Florida,
    Massachusetts, New Mexico, Pennsylvania, South Carolina, and Texas.
    According to CFSA's residential treatment coordinator, there were about 130
    youths in these centers as of August 2000.

    40 Of the current staff assigned to the unit, three social services
    assistants were assigned as recently as May 2000.

    maintain relationships with the judges. Despite these additional resources,
    as of July 2000, Superior Court judges said that social workers consistently
    fail to submit court reports and case plans in a timely way, which adversely
    affects working relationships between CFSA and the court. Social workers we
    spoke to acknowledged that when caseloads become difficult tomanage, they
    cannot always document case information, compounding the court's
    dissatisfaction with their performance.

    Regarding interstate placements, the agency hired four social workers on a
    temporary basis in May 2000 to reduce a backlog of several hundred
    placements that lacked proper documentation. Numerous clearances (for
    example, police clearances and medical reports) are required when children
    are placed in foster homes. Because these clearances require lead time to
    process, children were placed outside the District before all the paperwork
    could be completed. According to CFSA officials and social workers, CFSA
    continued making such placements without completing all the necessary
    documentation, effectively violating the ICPC requirement to provide
    sufficient information to the state where the placement is made. Agency
    staff cited several factors that contributed to the growth of the backlog.
    For example, some children were required to be placed out of state by court
    order, some were placed with relatives, and, for other children, no
    alternative placements were available in the District. Some social workers
    said that all or most of their cases require interstate placement and,
    therefore, completion of the ICPC process. CFSA reported 999 children in its
    ICPC backlog as of September 2000. 41 The interstate compact coordinator
    reported that the majority of these backlog cases needing additional
    documentation were in Maryland. 42 In September 2000, CFSA, the Deputy Mayor
    for Children, Youth, and Families, and the state of Maryland signed a
    memorandum of understanding regarding the completion of interstate compact
    documentation for children already placed in Maryland and expedited the
    processing of current and future interstate compact approvals. The
    memorandum provides that 10 percent of Maryland's emergency placement slots
    are to be designated for District placements of up to 30 days. According to
    the terms of the consent order, CFSA will assume total responsibility for
    the ICPC function and will no

    41 Of the 999, CFSA reported that, as of September 2000, 249 ICPC packets
    were either being prepared for submission or had been submitted to the
    District ICPC office for processing. 42 The agency stated in September 2000
    that it relies on 754 foster homes in Maryland for placements; these homes
    represented 60 percent of all foster homes available to the agency.

    longer need to forward paperwork to DHS for processing, creating an
    opportunity to reduce processing delays.

    Time Periods to Achieve As embodied in ASFA, an important goal in child
    welfare is to reduce the

    Permanent, Stable Care amount of time children spend in the system and move
    them into

    permanent placements as soon as possible. Permanent placements may take one
    of several forms, such as family reunification, adoption, independent
    living, and placement with a relative or guardian. Although the number of
    adoptions has increased, the agency has made little progress in moving
    children into other permanent placements. CFSA relies on several processes
    to expedite permanency, but each has its shortcomings, and children still
    spend about 3. 7 years on average in the system. Moreover, under ASFA, which
    requires a permanency hearing no later than 12 months after a child enters
    foster care and allows the federal government to withhold funding in the
    event of noncompliance, the District faces additional pressures to reduce
    delays in moving children into permanency.

    The MFO included various provisions to expedite processing adoption cases.
    43 While the agency has been instrumental in increasing the number of
    adoptions, more can be done to expedite the cases of children waiting to be
    adopted. In fiscal year 1999, CFSA achieved 250 adoptions that were made
    final by the District Superior Court- a record number and an increase of
    almost 200 percent from 1995. In fiscal year 2000, 329 adoptions were made
    final. The adoption program manager attributes the increase to efforts that
    have been made to identify various ways to expedite the processing of
    adoption cases, such as moving the cases of abandoned babies directly from
    intake to adoptions, using the waiver of parental rights (which can be more
    timely than the termination process), and setting deadlines for paperwork
    submitted by pre- adoptive parents. However, CFSA's adoption program manager
    estimated that at least 600 children in CFSA's care with a goal of adoption
    are being handled by other programs, such as traditional foster care and
    kinship care, and concluded that more needs to be done to transfer adoption
    cases to the adoption program in a timely way.

    43 For example, within 30 days of establishing a permanency goal of
    adoption, CFSA social workers are to develop a plan with attorneys of OCC
    regarding the termination of parental rights and, within 5 days of
    establishing this goal, the case should be transferred from its original
    program (for example, foster care or kinship) to the adoption program.

    Several agency processes aim to expedite moving children into permanent
    care: administrative reviews, special staffings, and using new performance
    standards in staff appraisals. Regarding administrative review, federal law
    and the MFO require every 6 months an administrative review of the progress
    toward permanency and the achievement of case plan goals for all children in
    foster care. 44 The objective of these reviews is to ensure that children's
    physical, social, and emotional needs are being met and that progress toward
    permanency is timely. However, as shown in table 5, a report prepared by the
    court- appointed monitor shows that as of July 1999, while CFSA had made
    some progress in reducing the number of cases with no review between
    December 1998 and July 1999, the agency had made no progress in reducing the
    number of cases with untimely reviews. 45 Moreover, of the cases with
    untimely reviews in July 1999, about half had not been reviewed in more than
    a year. As of October 2000, the agency could not provide more recent data on
    cases without reviews and cases with untimely reviews. 46

    Table 5: The Timeliness of Case Reviews, December 1998 and July 1999 Cases
    December 1998 July 1999

    No administrative review 490 212 Untimely administrative reviews 362 366
    Source: Center for the Study of Social Policy.

    In late 1998, CFSA began a series of special “permanency
    staffings” meetings to review children's progress toward obtaining
    permanent, stable care arrangements. The effort focused on the cases of
    children who had been in foster care for 15 of the past 22 months. 47 CFSA
    plans to continue to hold these meetings in order to reduce the backlog of
    cases in this category.

    44 42 U. S. C. 675( 5)( B). 45 Center for the Study of Social Policy,
    LaShawn A. v. Williams Progress Report as of December 31, 1999( Washington,
    D. C.: Mar. 7, 2000).

    46 Data on reviews were still being entered into FACES and this data entry
    was expected to be complete by the end of the calendar year; once data entry
    is complete, the system is expected to be able to generate the data
    necessary to track the timeliness of reviews.

    47 Newer cases continue to go through the administrative review process.

    For each case reviewed, the cognizant worker and supervisor review the case
    plan and the permanency goal and make suggestions for determining whether
    the permanency goal is still appropriate and consistent with the case plan.
    In some instances, it may be determined that the child has reached
    permanency and that the case is ready to be closed. However, the meetings do
    not routinely include legal advice that may be required to determine whether
    a case is ready to be closed. In February 2000, a District Superior Court
    official reviewed 68 cases that were subject to these special permanency
    staffings and found that, for most cases, documents contained insufficient
    information to make a determination of case closure and that legal input to
    determine whether certain legal standards (for example, “reasonable
    efforts”) had been met was lacking. 48

    Finally, according to CFSA officials, children's movement toward permanency
    will be considered in a new staff appraisal process that incorporates
    performance standards developed by the firm of Arthur Andersen. 49 While
    this step would enhance individual social worker accountability for progress
    toward permanency, the performance standards had not been implemented in
    September 2000 as planned, pending resolution of a citywide collective
    bargaining process.

    While CFSA needs to demonstrate more progress in moving children into
    permanent placements, the implementation of ASFA, with its specific time
    periods and financial penalties, introduces new risks for CFSA's federal
    funding. 50 Federal regulations provide for periodic audits of states'

    48 Established under the Adoption Assistance and Child Welfare Act of 1980
    (Pub. L. No. 96272), the term “reasonable efforts” is not
    defined in federal statute or regulations and has been interpreted in a wide
    variety of ways by states and the courts. According to HHS, services offered
    or provided to the family, such as family counseling, respite care, and
    substance abuse treatment, have often been considered to constitute
    reasonable efforts to prevent a child from being removed from home or to
    return a child home.

    49 Larry A. King, Development of Performance Standards( Washington, D. C.:
    Arthur Andersen, June 20, 2000). 50 For example, ASFA modified the
    definition of the case review system to require a permanency hearing no
    later than 12 months after a child entered foster care and the filing of a
    petition to terminate parental rights when a child has been in foster care
    for 15 of the most recent 22 months or a court has determined that a child
    is abandoned or the parent has murdered another child (or committed certain
    other offenses). See 42 U. S. C. 675( 5)( C) and (E). Failure to comply with
    these and other requirements can jeopardize federal funding for foster care
    maintenance payments. See 45 C. F. R. 1356. 21( a).

    substantial compliance with ASFA. 51 The audits review outcomes and
    timeliness on small samples of about 30 to 50 cases. If CFSA is deemed out
    of substantial compliance with ASFA, penalties could be imposed,
    jeopardizing a portion of the agency's federal funding. CFSA officials
    expect that HHS will conduct this audit in July 2001.

    The District's Efforts to Our previous work and studies by other
    organizations have shown that

    Provide More certain systemwide initiatives are critical to improving child
    welfare

    outcomes. Critical initiatives include collaborative operations among the
    Collaborative Services

    agencies that provide child welfare and other support services, as well as
    Are Limited in Scope

    case- specific initiatives aimed at bringing together children, family
    members, social workers, attorneys, and others to help address the needs of
    children and their families. 52 Some participants in the District's child
    welfare system have recently taken initial steps to improve operations. For
    example, District agencies have initiated recent efforts to integrate child
    welfare services with other family services. However, systemwide
    collaboration has not yet been fully developed, leaving the District's child
    welfare system hampered by continued fragmentation. In addition, while some
    District families have access through the collaboratives to an approach
    called family case conferencing that brings relatives into decision- making
    around a child's well- being, CFSA has not adopted this approach in its own
    practice with families.

    Collaboration on Two Levels In our earlier testimony, we reported that
    effective working relationships

    Is Critical to Effective Child among key child welfare system participants
    who play a role in keeping

    children safe are essential to successful reform efforts. 53 In order to
    Welfare Systems

    function effectively, child welfare agencies need a rich array of services
    to meet the needs of abused and neglected children and their families.
    Rarely, however, does a single state or local agency have control over
    acquiring all the needed services, and many of those services, such as
    mental health care and drug treatment, are outside the control of the child
    welfare agency. Therefore, strong collaboration among all stakeholders who
    play a role in

    51 45 C. F. R. 1355. 31- 1355. 39 (as added Jan. 25, 2000). 52 Case-
    specific initiatives focus on practice at the case level rather than the
    system or interagency level. 53 Foster Care: Status of the District of
    Columbia's Child Welfare System Reform Efforts (GAO/ T- HEHS- 00- 109, May
    5, 2000).

    helping children and families, such as the courts, private provider
    agencies, neighborhood collaboratives, the police department, local
    government leaders, substance abuse and mental health agencies, and agency
    legal counsel, is essential to obtaining the necessary services.

    Collaborative approaches can occur on two levels- some focus on integrating
    the key child welfare system participants to develop joint solutions to
    cross- cutting problems, and others focus on building collaboration in
    making decisions on individual child welfare cases. In our earlier
    testimony, we reported that strong collaboration among all stakeholders who
    play a role in helping children and families is essential to obtaining
    necessary services. 54 For example, jurisdictions in five states-
    California, Florida, Illinois, North Carolina, and Ohio- have convened
    multidisciplinary advisory committees to work on resolving turf battles,
    dispel the mistrust among system participants, and develop and implement
    reforms. Committees were typically composed of representatives from key
    groups such as child welfare agencies, attorneys, judges, court- appointed
    special advocates, and other advocates. 55

    For example, Cook County, Illinois, established a Child Protection Advocacy
    Group of 32 individuals representing all offices of the court, the child
    welfare agency, private social service agencies, legal service providers,
    advocacy groups, and universities. The group's subcommittees focus on
    various issues such as formulating alternatives to court intervention,
    making decisions in the best interest of the child, and terminating parental
    rights. To help reform the child welfare system and the court's role in it,
    the group was charged with advising the presiding judge on all matters
    relating to improving the court's Child Protection Division. Participants in
    these groups noted that working together in this way provided a unifying
    force that was invaluable in initiating and institutionalizing reforms.

    In a 1999 report, the National Association of Public Child Welfare
    Administrators, an affiliate of the American Public Human Services
    Association, also cited the benefits of interagency collaboration. According
    to the association, an interagency approach to providing child protection

    54 GAO/ T- HEHS- 00- 109. 55 Court- appointed special advocates, usually
    volunteers, are trained to assist the court and oversee a child's case.

    and other services can improve agency coordination, identify service gaps,
    and advocate for needed resources. 56

    Other jurisdictions across the country have taken a different approach to
    building collaboration by pooling or blending funds from multiple funding
    sources to obtain the needed services on a more integrated, systemwide
    basis. For example, Boulder County, Colorado, pooled its child welfare
    allocation from the state with funding from the mental health agency and the
    youth corrections agency to provide joint programming and placement
    decision- making for adolescents in need of out- of- home care in group or
    residential settings. Similarly, the Wraparound Milwaukee program in
    Wisconsin blended Medicaid, child welfare, and federal grant funds into a
    single buying pool to purchase individualized, family- based services to
    help children placed in residential treatment centers return to their
    families, foster homes, or other living arrangements in the community. 57

    Other collaborative efforts focused on improving decision- making on
    individual cases, intervening at key points to gather and share
    comprehensive information among participants. For example, Day One
    Conferences in North Carolina's District 20 are held on the first business
    day after a child is taken into custody by the child welfare agency. In
    attendance are the parents, child welfare caseworkers, guardians ad litem,
    public and mental health liaisons, attorneys, public education liaisons,
    child support liaisons, and law enforcement officers. 58 These meetings
    provide a forum to arrange immediate services for the family and provide an
    opportunity to reach agreement on many aspects of the case outside the
    courtroom, thus reducing the number of times a case is continued in court.
    59 Our previous work showed that state and local officials who had
    implemented these conferences believe that additional time invested at the
    beginning of a case can shorten the length of time it takes to make a

    56 American Public Human Services Association, Guidelines for a Model System
    of Protective Services for Abused and Neglected Services and Their Families,
    rev. ed. (Washington, D. C.: 1999). 57 The county child welfare agency and
    the state health care financing agency each agreed to pay a specific monthly
    rate for services to children. These funds were pooled with a federal grant
    to pay the costs of residential treatment, group and foster care, and all
    other services except physical health care.

    58 Guardians ad litemare attorneys or trained volunteers who represent a
    child in court, investigate the case, and monitor case progress. 59 Judges
    continue a case by rescheduling it for another day.

    permanent placement decision. 60 The National Council of Juvenile and Family
    Court Judges has also provided guidance on how to improve casespecific
    decision- making in child abuse and neglect cases. The council reported that
    the nation's juvenile and family courts need clear guidance on how they can
    best fulfill their responsibilities in child abuse and neglect cases.
    According to the council, such guidance should explain the decisionmaking
    process in these cases and identify the individuals required to attend
    applicable proceedings. 61

    District Agencies Have In the District of Columbia, numerous and diverse
    agencies provide

    Undertaken Initial programmatic and legal services for the many children in
    CFSA's custody,

    Collaborative Efforts as depicted in figure 1. District officials and child
    welfare experts familiar

    with the District acknowledge that collaboration is key to protecting
    children. Toward this end, various District agencies and others have
    undertaken initial efforts to work together to improve services for children
    and families. However, these efforts have been limited in scope. The
    information below highlights such interagency efforts.

    60 Juvenile Courts: Reforms Aim to Better Serve Maltreated Children( GAO/
    HEHS- 99- 13, Jan. 11, 1999). 61 National Council of Juvenile and Family
    Court Judges, Resource Guidelines: Improving Court Practice in Child Abuse
    and Neglect Cases( Reno: 1995).

    Figure 1: Key Participants in the District of Columbia's Child Welfare
    System

    a Leads a remedial project intended to expedite case review for children in
    foster care 15 of the past 22 months. b A nonprofit, nongovernment agency
    reporting directly to the U. S. District Court.

    Source: CFSA data and interviews with system participants.

    Children's Advocacy Center. Created in 1995, the D. C. Children's Advocacy
    Center-“ Safe Shores”- operates a nonprofit organization in
    partnership with the District and federal government agencies. The center
    coordinates the work of an interagency, multidisciplinary team that
    investigates allegations of physical and sexual abuse of children. The
    interagency team includes law enforcement officers, social service
    officials, prosecution attorneys, mental health workers, medical personnel,
    and victim advocates. Despite the collaborative efforts spearheaded by the
    center, its efforts focus on the population of physically and sexually
    abused children and do not reach the population of neglected children.
    Family Reunification. Recognizing the central role proper housing can

    play in helping to reunify children and their families, CFSA and the
    District's Housing Authority have worked together to help families obtain
    suitable housing. Funds from the U. S. Department of Housing and Urban
    Development support this effort for the benefit of families with children in
    CFSA's custody, among other program participants. However, the demand for
    housing in this program exceeds the supply. Court Reform Project. The D. C.
    Superior Court and CFSA have had

    difficulty sustaining effective working relationships, as discussed
    previously. To address these difficulties, the court, in conjunction with
    the National Council of Juvenile and Family Court Judges, has been selected
    to participate in a court reform project aimed at applying best practices to
    court processes, including practices to improve working relationships
    between CFSA and other selected child welfare system participants.

    Another approach to improving collaboration across programs and systemwide
    operations is pooling or blending funds. To help facilitate access to
    various funding sources, CFSA has budgeted for emergency cash assistance to
    help finance such needs as one- time rent deposits, furniture, and clothing.
    While such assistance may help social workers and other staff gain access to
    funds in support of multiple needs, these budgeted funds do not cover other
    service needs, such as mental health services for children living with their
    birth parents or kin. The separation of funding streams that are tied to
    different programs may also hamper the ability to pool or blend funds across
    programs or to target funds appropriately. According to the Children's
    Advocacy Center Executive Director's testimony in May 2000, the historical
    lack of a citywide strategic funding plan for maltreated children has
    adversely affected the prevention of child abuse and has allowed funding
    from multiple sources to determine programming rather

    than permitting the needs of the community's children to drive the system's
    response. 62

    In addition to collaborative efforts involving specified agencies and
    funding sources, several CFSA officials, District officials, and other child
    welfare experts we spoke with suggested that systemwide authority is needed
    to provide overarching leadership and accountability. The information below
    highlights two existing structures to provide interagency oversight and
    coordination.

    Deputy Mayor for Children, Youth, and Families. In 1999, the District's
    Mayor appointed a Deputy Mayor for Children, Youth, and Families as a new
    cabinet position with responsibility for overseeing initiatives aimed at
    addressing the needs of the District's children, youth, and families. In
    this position, the Deputy Mayor oversees DHS, the Department of Health,
    Office on Aging, and the Department of Recreation. CFSA management and
    District officials we interviewed acknowledged the Deputy Mayor as a focal
    point for fostering greater communication or collaboration among District
    government agencies on behalf of children and families. Mayor's Advisory
    Committee on Child Abuse and Neglect. During an

    earlier mayoral administration, the Mayor's office established the Mayor's
    Advisory Committee on Child Abuse and Neglect to promote public awareness of
    child abuse and neglect, assist in improving services and coordinating
    interagency activities, and make recommendations regarding needs assessments
    and policies, among other priorities. The committee recommends program
    improvements to the Mayor. While the committee includes 27 members, as of
    September 2000, its membership did not include representatives from the
    District's substance abuse agency, public school system, or public housing
    authority. Moreover, the committee has relatively limited funding. It
    administers a $50,000 fund held in trust for the District's children.

    Case- specific initiatives can improve efforts to meet the needs of children
    and their families as well. For example, District agencies recently
    initiated efforts to address circumstances that undermine family stability
    and case processing needs. The D. C. Superior Court's Special Master, among
    other

    62 Testimony from Safe Shores, the D. C. Children's Advocacy Center, before
    the House of Representatives Committee on Government Reform, Subcommittee on
    the District of Columbia, May 5, 2000.

    priorities, reviews the status of child welfare cases to facilitate timely
    action and reduce case backlogs. 63 In addition, the Superior Court has
    begun a permanency mediation pilot designed to include birth parents and
    relatives in decisions concerning particular permanency goals for children,
    such as adoption. Finally, two of the Healthy Families/ Thriving Communities
    neighborhood collaboratives began family case conferencing practices aimed
    at bringing families together, with the support of trained facilitators, to
    develop a strategy to support the child's well- being. CFSA program managers
    said that, consistent with a neighborhood- based service delivery
    philosophy, the agency has chosen to rely on the collaboratives to initiate
    efforts at achieving family case- conferencing and other casespecific
    collaboration, preferring instead to hold special meetings with agency
    personnel, once a child is in its custody. As of September 2000, CFSA
    reported that it had referred 17 families to collaborative- sponsored family
    case conferencing. The receiver acknowledged that CFSA could adopt family
    case conferencing for its own case practice and that such an approach would
    benefit children and families. However, she said that this approach would
    not be appropriate for all families.

    Collaborative Efforts Are While various entities in the child welfare system
    have begun efforts to

    Constrained by LongStanding improve collaboration between CFSA and others,
    these efforts have been

    Organizational constrained by ineffective working relationships among CFSA
    and other

    Impediments key participants. In 1999, the Mayor's office issued the results
    of a study

    that reviewed the status of interagency operations in the District's child
    welfare system. 64 The study found that CFSA lacks functional relationships
    with critical executive branch government agencies, such as DHS, the
    Department of Health, Fire and Emergency Medical Services, and the District
    of Columbia public school system. In addition, CFSA staff and Superior Court
    judges said the agency and the court have poor working relationships. CFSA
    social workers have not consistently provided court reports and other
    hearing documentation when ordered by the court, and they have not always
    reported to court to attend hearings. Attorneys from OCC have responsibility
    for prosecuting civil abuse and neglect cases on behalf of the District of
    Columbia. CFSA attorneys acknowledge this role, noting that OCC represents
    not the legal interests of children but the

    63 A special master is a parajudicial officer appointed to assist the court
    with a particular matter or case. 64 Graham and Khabo.

    District as a whole. As a result, the opinions of CFSA social workers and
    OCC attorneys are sometimes at odds. In this instance, CFSA social workers
    believe that they do not have adequate representation. Moreover, OCC
    management acknowledged that it does not have enough attorneys to cover all
    cases. Given these resource constraints, they focus on new cases entering
    the system and other critical issues.

    As specified in its child welfare system emergency reform plan of October
    2000, the District plans to provide additional resources to OCC to help
    eliminate the backlog of foster care and adoption cases and achieve
    compliance with ASFA. Toward this end, the plan requires a workload analysis
    of OCC and a survey of other jurisdictions to determine the staffing and
    resource levels necessary to help ensure ASFA compliance and to expedite
    prosecutions for child abuse and neglect. In addition, the U. S. District
    Court's consent order requires the District to provide CFSA with adequate
    legal staff to enable the agency to meet its legal obligations under the
    MFO, including the creation of a legal unit within OCC to provide legal
    services to CFSA.

    Bifurcated responsibilities for child abuse investigations compound the
    organizational fragmentation of the District's child welfare system. Under
    this bifurcated approach, the District's criminal statutes assign MPD lead
    responsibility for investigating child abuse cases. The investigatory
    practices of MPD are sometimes at odds with those of CFSA social workers,
    which can make it more difficult for social workers to respond to the needs
    of the child and family based on their own established protocols.
    Investigatory responsibilities are further complicated by resource
    constraints. While the MFO requires MPD and CFSA to conduct joint
    investigations of abuse cases, department and agency officials said that the
    inability of both organizations to jointly staff investigations has
    prolonged investigatory time periods. MPD and CFSA attributed the lack of
    joint investigations to the lack of available police officers and social
    workers when an instance of child abuse is first alleged. The bifurcated
    approach also splits case administration responsibilities between CSS and
    CFSA. According to CSS staff, they administer about 600 child abuse cases
    that are not included in CFSA's automated system. To address the
    difficulties posed by having bifurcated investigatory responsibilities
    between CFSA and MPD, a District task force has developed joint
    investigatory protocols involving child protection workers and law
    enforcement officials. The U. S. District Court's consent order addresses
    the current bifurcated system and calls for District government to enact
    legislation requiring CFSA and MPD to conduct joint investigations of child
    abuse allegations.

    The Structural Issues Long- standing challenges such as a lack of effective
    working relationships

    Are Important in in the child welfare system impede the District's ability
    to fully apply best

    practices to protect children. As it prepares for the transfer of CFSA to
    Transferring CFSA

    local governance, the District faces many organizational and operational
    Back to the District

    challenges. To maximize the opportunity for the child welfare system to
    improve the well- being of children and their families, District officials
    and child welfare experts have acknowledged that a sound transition plan
    should be developed to help facilitate this transfer. They believe this plan
    should address several factors, such as the organizational context within
    which the new child welfare agency would operate, the recruitment and
    retention of qualified personnel, and a mechanism for ongoing oversight and
    accountability.

    Participants in the child welfare system took the first step and developed
    an emergency reform plan at the request of the Subcommittee on the District
    of Columbia of the House Committee on Government Reform. Prepared with input
    from key participants in the District's child welfare system and presented
    to the subcommittee by the Mayor in October 2000, this plan addresses the
    roles of OCC, MPD, the D. C. Superior Court, and others in the District's
    child welfare system. 65 In October 2000, the U. S. District Court issued a
    consent order terminating the receivership upon the satisfaction of several
    major conditions, such as the enactment of legislation ending bifurcated
    investigations of child abuse and neglect allegations, the appointment of a
    child welfare agency administrator by the District's mayor, and the
    development of licensing standards for foster homes and group homes. The
    order also provides for a 1- year probationary period during which CFSA must
    meet specific performance standards, such as meeting investigation time
    periods, complying with social work visitation requirements, and complying
    with ASFA time periods, among others. During this probationary period, the
    MFO is not enforceable, allowing the District time to make improvements to
    the system without the threat of litigation. At the conclusion of this
    period, if the court believes the agency has performed satisfactorily, the
    MFO will again become fully enforceable and the monitor will continue to
    report on the agency's compliance with the order.

    65 District of Columbia Child Welfare System Emergency Reform Plan,
    submitted to the House of Representatives, Committee on Government Reform,
    Subcommittee on the District of Columbia (Washington, D. C.: Oct. 4, 2000).

    The plan and subsequent consent order attempt to address a number of the
    organizational challenges faced by CFSA and the District's child welfare
    system as a whole. The consent order mandates that CFSA be established as a
    cabinet- level agency with independent hiring authority and independent
    procurement authority consistent with District law, as a precondition for
    terminating the receivership. CFSA officials said that certain benefits
    would be associated with separate, cabinet- level status. These officials
    believe that cabinet- level status would provide CFSA with greater
    independence for setting program priorities and obtaining needed resources.
    For example, some officials believed this status would provide the agency
    more control over recruiting staff and would allow the agency to respond
    more flexibly to the needs of children and families. One official thought
    that cabinet- level status would enhance service delivery and interagency
    coordination.

    The emergency plan and court mandates contained in the consent order also
    call for additional responsibilities to be transferred to the agency. For
    example, these requirements call for transferring to CFSA responsibility for
    (1) implementing the ICPC from DHS; (2) licensing, regulating, and
    monitoring foster and group homes from the Department of Health; and (3)
    managing the child abuse cases currently handled by CSS. The emergency
    reform plan also calls for, among other things, developing a communitybased
    service delivery system in which services are provided to children and
    families in their own neighborhoods and for expanding the Safe Shores
    Children's Advocacy Center into a Children's Assessment Center- colocating
    and integrating the work of all agencies involved in the investigation and
    prosecution of child abuse and neglect. Accomplishing many of these
    initiatives, however, would require developing and implementing new local
    legislation and enhancing federal funding. Although the emergency plan
    provides time periods for implementing the initiatives, it does not discuss
    some of the details regarding implementation, such as the need for new staff
    to handle the increased responsibilities. A member of the Mayor's staff
    indicated that the District will develop an implementation plan as part of
    its legislative package outlining how the District will carry out the
    requirements of the consent order.

    With respect to personnel issues, particularly those in higher- level
    management positions, it remains unclear whether the CFSA staff hired as
    employees under the receivership would be converted to District government
    positions. About one- third of CFSA's current workforce was hired by the
    former receiver. CFSA officials added that the agency will need

    to plan for how it will address the future employment status of these
    employees upon transfer of the agency to the District. The emergency reform
    plan was silent on how these personnel issues will be handled. The consent
    order, however, requires the named parties to develop a plan for addressing
    the status of employees hired under the receivership.

    With regard to the continued need for agency oversight, District officials
    outside CFSA have pointed to the need for a mechanism to ensure the agency's
    accountability in the future. Upon transfer of CFSA to the District, the
    court- appointed monitor will retain responsibility for assessing the extent
    to which CFSA meets the performance standards contained in the consent
    order. The development of a baseline by which to measure CFSA's performance
    is a critical step in carrying out the consent order. The order provides the
    monitor with the authority to establish the baselines for compliance by
    conducting a case record review and by relying on CFSA data that the monitor
    determines are reliable and appropriate. The monitor will also have
    authority to modify the standards if the defendant or plaintiffs believe
    they are unreasonable in relation to the baseline.

    Conclusions CFSA faces many of the same challenges it faced more than a
    decade ago when it became the subject of a class action suit filed on behalf
    of the

    District's abused and neglected children. Since then the agency has
    continued to confront long- term managerial shortcomings, and the lack of
    integration in its child welfare system has contributed significantly to the
    lack of success in preventing children from entering the system and reducing
    their length of stay while in the District's care. After 5 years of
    operating under receivership, CFSA has shown limited progress in meeting the
    requirements of the MFO. Compounding these agency challenges, the child
    welfare system- of which CFSA is a part- continues to operate without a
    fully developed collaborative structure and the effective working
    relationships it needs to provide integrated services to children and their
    families. Moreover, the agency has not fully applied best practices to
    enhance collaboration, such as family case conferencing, that could enhance
    outcomes for children and families. While the goals outlined in the
    emergency reform plan and consent order are a necessary first step, longterm
    structural and operational challenges must be considered in transferring the
    agency back to local governance and to foster improved outcomes. It will
    take a fully collaborative system to help ensure progress toward improving
    program outcomes and sustained commitment from the Mayor and District
    government to make achieving the goals a priority. Without such
    collaboration and leadership, the District will continue to

    lack the operational framework necessary to protect and meet the needs of
    children and ultimately to ensure accountability for these goals.

    Agency Comments and We received written comments on a draft of this report
    from CFSA and one

    Our Evaluation oral comment from the District of Columbia. CFSA found the
    report to be

    balanced in its findings but believed that clarification was needed on
    several points (see app. IV). CFSA also provided a number of technical
    comments that we incorporated where appropriate. One of the agency's
    comments addressed the issue of social worker caseloads. CFSA commented that
    it is somewhat misleading to report caseload averages for a team of social
    workers rather than an average caseload per worker in the various program
    areas. When we asked CFSA for caseload data during the course of our review,
    the agency provided the range of average caseloads by team. These data do,
    however, reflect average caseloads carried by workers assigned to teams in
    each program area. Both CFSA and the Deputy Mayor for Children, Youth, and
    Families commented on the status of the agency's policies, indicating that
    policies had existed to a greater extent than portrayed in the draft report.
    CFSA said it has relied on a 1995 policy handbook and subsequent policy
    revisions to guide the work of the agency. CFSA further stated that it had
    been developing an on- line version during the course of our review. We have
    reviewed the 1995 policy handbook and we have noted the extent to which
    these policies address court- mandated requirements in appendix II. However,
    despite the existence of the 1995 handbook, staff we spoke to throughout the
    course of our review expressed confusion over which policies and procedures
    to follow and, in some cases, which policies had been approved.

    As we agreed with your offices, unless you publicly announce the report's
    contents earlier, we plan no further distribution of it until 4 days from
    the date of this letter. We will then send copies to the Honorable Anthony
    A. Williams, Mayor of the District of Columbia, the interim receiver, and
    other District officials. We will also send copies to others who are
    interested on request.

    If you or your staffs have any questions about this report, please contact
    Diana M. Pietrowiak, Assistant Director, at (202) 512- 6239. Other major
    contributors were Christopher D. Morehouse, Elizabeth O'Toole, and Mark E.
    Ward.

    Diana Eisenstat Director, Education, Workforce, and

    Income Security Issues

    Appendi Appendi xes xI

    Scope and Methodology Using primary and secondary source material, we
    designed our methodology to validate the status of progress the Child and
    Family Services Agency (CFSA) has made toward meeting requirements of the
    modified final order (MFO). We asked CFSA to provide copies of written
    policies and procedures and management information system (MIS) reports so
    that we could assess its status in complying with the courtmandated
    requirements. We did not independently verify the accuracy of the data in
    the MIS reports that CFSA provided. In addition, we reviewed our earlier
    reports and studies by the American Public Human Services Association, Child
    Welfare League of America, and other organizations to identify generally
    accepted best practices of child welfare systems and we assessed the extent
    to which the District had applied these principles in implementing
    systemwide child welfare changes. In conducting our work, we relied on a
    broad array of testimonial, documentary, and analytical evidence in
    responding to the three research questions.

    To identify the financial and operational changes that the receiver
    appointed in 1997 made to comply with the MFO requirements, we analyzed
    policies, procedures, and information system reports generated by the
    receiver and reports from other agencies. Based, in part, on findings
    contained in our testimony entitled Foster Care: Status of the District of
    Columbia's Child Welfare Reform Efforts( GAO/ T- HEHS- 00- 109, May 5,
    2000), our work focused on requirements directly related to agency
    resources, services for children and families, working relationships with
    other key stakeholders, and program results. These MFO requirements direct
    CFSA to address staffing and caseloads, financial management, management
    information systems, resource development, out- of- home care, and family
    services. We also obtained and analyzed child welfare agency policies,
    regulations, memorandums, and other information on agency procedures in
    order to document financial and operational changes undertaken in efforts to
    attain MFO compliance. To obtain a broad range of perspectives from staff
    across CFSA's program areas and with different levels of experience, we
    interviewed CFSA managers, supervisors, senior social workers, new hires,
    and other officials knowledgeable about the level of agency compliance. For
    group interviews with agency staff, we asked CFSA to invite employees with
    diverse levels of experience to meet with us.

    Regarding the efforts to initiate improvements in the District's child
    welfare system, such as interagency collaboration and the pooling or
    blending of funds, we examined the extent to which such practices have been
    included in the day- to- day operations of the District's system and the
    challenges the

    system faces in adopting such initiatives. To make this assessment, we
    identified initiatives other organizations cited as efforts intended to
    improve the operations and program results of child welfare systems in other
    jurisdictions. These organizations include the Annie E. Casey Foundation,
    the Casey Family Program, the Child Welfare League of America, the Edna
    McConnell Clark Foundation, and the National Council of Juvenile and Family
    Court Judges.

    To identify additional changes required to return the District's child
    welfare agency to local governance, we focused our analysis on areas that
    affect the interaction of child welfare agencies with other organizations.
    We obtained perspectives on these issues from CFSA staff, program officials
    in other District of Columbia government agencies, and other organizations.
    In addition, we analyzed transfer- related documentation developed by the
    Mayor's office and other organizations to examine proposed scenarios and
    operational issues the District identified in the context of transferring
    CFSA back to local governance.

    District of Columbia Child Welfare System

    Appendi xII

    Features the MFO Required, July 2000 Under No efforts Feature a Developed
    development initiated b

    Protective services (intake and assessment)

    Written policies and procedures for cooperative screening and X
    investigation with the Metropolitan Police Department (MPD) of alleged child
    abuse complaints.

    Written policies and procedures for screening complaints of X

    abuse and neglect to determine whether they are within the definitions of
    District law.

    Written policies and procedures for prioritizing response times to X each
    report of abuse and neglect. Written policies and procedures for conducting
    risk assessments

    X and ensuring that the child protective services investigations and
    decisions are based on a full and systematic analysis of a family's
    situation and the factors placing a child at risk and for guiding decision-
    making.

    An assessment form. X Written policies and procedures for determining which
    children

    X (who are the subject of abuse or neglect reports or other children in the
    household) should receive a complete medical, psychological, or psychiatric
    evaluation.

    Ability to produce data showing, for the children who need X medical
    reports, how many received them within 48 hours after the report of neglect
    or abuse was supported.

    Written policies and procedures for the reporting, investigation, X

    and determination of reports of neglect or abuse (including specifications
    of what information must be included), in a final determination of whether
    abuse or neglect has occurred.

    A standardized form for recording final determination. X Written policies
    and procedures for ensuring that workers

    X receive immediate access to police protection. Services to children and
    families

    Written policies and procedures for determining and ensuring X

    that families are referred to and receive the intensity and level of
    services necessary to preserve family relationships, to prevent additional
    abuse and neglect, to promote better parental care, and to ensure good care
    for the child.

    Written policies and procedures for specifying criteria for the X

    provision of family services and for referring families to private agencies
    the agency contracts with for such services.

    Ability to produce management data showing the actual X caseloads by worker,
    for workers in home- based services units.

    (Continued From Previous Page)

    Under No efforts Feature a Developed development initiated b

    Placement of children

    Written policies and procedures for governing the placement X

    process to ensure that children are placed in the least restrictive, most
    family- like setting that meets their individual needs and that they are
    placed in or in close proximity to the homes and communities in which they
    resided before entering the agency's custody.

    Written policies and procedures for ensuring the prompt and X c

    appropriate placement- including return home, where appropriate- of infants
    who are residing in hospitals in the District of Columbia but who are, or
    are soon to be, medically ready for discharge.

    Ability to produce management data showing, for children X needing medical
    screening on entering the agency's custody, those who receive screening
    within 24 hours.

    Ability to produce management data showing, for children X

    placed in substitute care facilities and needing a thorough, professional
    evaluation of their needs, those who receive evaluation within 30 days.

    Written policies and procedures for providing regulations to X govern all
    foster- care facilities it places children in. Permanency planning

    Written policies and procedures that establish a planning X

    process that initially will seek to work intensively with the child's
    parents and other appropriate family members to allow the child to remain at
    home, if appropriate; in instances in which removal is necessary, will work
    intensively with the child's parents and other appropriate family members
    collaboratively to return the child home under appropriate circumstances
    consistent with reasonable professional standards; and if, after all
    reasonable efforts have been made but have not succeeded in returning the
    child home, will assure the child an alternative, appropriate, permanent
    placement as quickly as possible.

    Written policies and procedures for ensuring that in all instances X

    in which a report of abuse or neglect is supported, the case is transferred
    to a foster- care worker within 5 working days of the finding.

    Ability to produce management data showing, of all cases in X

    which a report of abuse or neglect is supported, those that were transferred
    to a foster- care worker within 5 working days of the finding.

    Ability to produce management data showing, of all cases in X

    which a report of abuse or neglect is substantiated, those in which a worker
    met with parents within 7 calendar days of the substantiation, those in
    which a meeting was held after 7 days and those in which no meeting was
    held.

    (Continued From Previous Page)

    Under No efforts Feature a Developed development initiated b

    Ability to produce management data showing children for whom X a case plan
    was not developed within 30 days. Ability to produce management data showing
    the number of

    X children with a permanency goal of returning home for 12 months or more.

    A standardized form for 90- day reviews. X Ability to produce management
    data showing the number of

    X children with a current, valid 90- day review; number of children without
    such a review.

    Adoption

    Written policies and procedures for governing the process of X freeing
    children for adoption and matching children with adoptive homes.

    Ability to produce management data showing, of the children X

    with a permanency goal of adoption, the number referred to the adoption
    branch within 5 days of their permanency goal becoming adoption.

    Ability to produce management data showing the number of X children legally
    free for adoption and awaiting placement for more than 6 months.

    Supervision of children in placement

    Ability to produce management data showing, of the children X placed in a
    DHS foster home, the number whom an agency worker has visited at specified
    intervals.

    Ability to produce management data showing, of the children X placed in a
    private- agency foster home, the number whom a private agency worker has
    visited at specified intervals.

    Ability to produce management data showing, of the children X

    placed in a foster family or facility, the number who have been visited at
    specified intervals.

    Case review

    Written policies and procedures for ensuring that all children X receive
    administrative reviews. A quality assurance report. X

    Written policies and procedures by which the quality assurance X unit will
    conduct quality assurance reviews. A standardized form used in the quality
    assurance process. X

    Caseloads

    Ability to produce management data showing the caseload X

    figures by worker for all workers conducting investigations of reports of
    abuse or neglect.

    (Continued From Previous Page)

    Under No efforts Feature a Developed development initiated b

    Ability to produce management data showing the caseload X figures by worker
    for all workers providing services to families in which the children are
    living in their home.

    Ability to produce management data showing the caseload X

    figures by worker for all workers providing services to children in
    placement, broken out by children with special needs and all other children.

    Ability to produce management data showing the caseload X

    figures by worker for all workers with responsibility for children
    (including situations in which the private agency has responsibility for
    both the child and the family) in placement with a private agency.

    Ability to produce management data showing the caseload X figures by worker
    for all workers with responsibility for children in the adoption branch.

    Written policies and procedures for using a caseload weighing X

    formula to ensure that workers who have caseloads that fall into more than
    one category (mixed caseloads) have caseloads that conform with the
    equivalent of the maximum limits.

    Ability to produce management data showing the caseload X figures by worker
    for all workers with mixed caseloads. Ability to produce management data
    showing the caseload

    X figures by supervisor for all supervisors. A workload study. X

    Ability to produce management data showing the number of X

    children assigned to a worker within 3 hours of the agency's assuming
    custody of the child.

    Staffing

    Ability to produce management data showing the formal X

    identification and assessment of District of Columbia practices and
    procedures that affect the recruitment and retention of social workers.

    A recruitment plan for professional staff. X

    Worker qualifications

    Ability to produce management data showing the number of X supervisors with
    MSWs and the number without. Ability to produce management data showing the
    number of

    X supervisors with at least 3 years of social work experience in child
    welfare.

    (Continued From Previous Page)

    Under No efforts Feature a Developed development initiated b

    Training

    Written policies and procedures for providing a comprehensive X

    child- welfare training program that will ensure that all persons charged
    with responsibilities for children in the plaintiff class will receive
    sufficient training to permit them to comply with the relevant mandates of
    agency policy, District of Columbia law, and all MFO provisions.

    An assessment of staff training needs. X Assessments of training
    effectiveness. X Ability to produce management data showing the number of
    new

    X hires with 80 hours of instructional training. Ability to produce
    management data showing the number of new

    X hires with 80 hours of field training. Ability to produce management data
    showing the number of

    X workers with 40 hours of in- service training each calendar year. Ability
    to produce management data showing the number of

    X senior workers with casework responsibility who have 24 hours of training.

    Ability to produce management data showing the number of X

    supervisors meeting within 3 months of promotion to supervisor the
    requirement for 40 hours of training that is directed to supervising child
    welfare social workers.

    Ability to produce management data showing the number of X supervisors with
    24 hours of in- service training each calendar year.

    Ability to produce management data showing the number of X foster parents
    completing 15 hours of training. Ability to produce management data showing
    the number of

    X prospective adoptive parents completing 30 hours of training. Ability to
    produce management data showing the number of

    X judges trained to date in judicial training program. Ability to produce
    management data showing the number of

    X professional staff demonstrating satisfactory mastery of the curriculum
    for the following training: new hire 80- hour instruction, new hire 80- hour
    field, workers 40- hour in- service, senior workers 24- hour additional,
    supervisors 40- hour within 3 months, and supervisors 24- hour in- service.

    Resource development

    Resource needs assessments. X Resource development plan. X Reports
    projecting the number of emergency placements, foster X

    homes, group homes, therapeutic foster homes, and institutional placements
    that children in the agency's custody will require during the next 12
    months.

    (Continued From Previous Page)

    Under No efforts Feature a Developed development initiated b

    A placement implementation plan. X Written policies and procedures for
    ensuring that decisions are

    X made promptly concerning the issuance of a license for any foster- care
    facility in which a member of the plaintiff class may be placed, including
    foster homes, group homes, residential treatment centers, and other child-
    care facilities.

    Written policies and procedures for monitoring all facilities and X

    foster homes in which children in the agency's physical or legal custody are
    placed.

    Ability to produce management data showing the number of X foster homes and
    group facilities the monitoring unit visits at least once a year.

    Ability to produce management data showing by worker the X caseload figures
    for all workers monitoring foster homes. Ability to produce management data
    showing by worker the

    X caseload figures for all workers monitoring group homes and institutions.

    Written policies and procedures for licensing relatives as foster X c
    parents. Contract review

    Written policies and procedures for specific contract X performance and a
    contract performance review process for each category of services.

    Ability to produce information systems reports showing, for each X

    worker with direct responsibility for any children in the agency's physical
    or legal custody, the number of children for whom that worker is
    responsible.

    Ability to produce information systems reports showing, for each X

    worker with direct responsibility for any children in the agency's physical
    or legal custody, the number of children for whom that worker is responsible
    for whom any of the following events either are late or are due in the 60
    days following the report: expiration of allowed emergency care status, case
    plan review, administrative review, judicial review, or dispositional
    hearing.

    Ability to produce information systems reports showing, for each X

    supervisor who has principal responsibility for any child in the agency's
    physical or legal custody, the number of children for whom that supervisor
    is responsible.

    Ability to produce information systems reports showing all X

    facilities- foster homes, group homes, institutions, consortium or other
    contract homes, or any other facility for which any vacancies exist-
    including the name of the facility, the type of facility, and the number of
    vacancies.

    (Continued From Previous Page)

    Under No efforts Feature a Developed development initiated b

    Ability to produce information systems reports showing the X

    number of children, by unit, who are placed in facilities- foster homes,
    group homes, institutions, consortium or other contract homes, or any other
    facility- that do not have current valid permits or licenses.

    Ability to produce information systems reports showing the X

    number of children, by unit, who are placed in facilities- foster homes,
    group homes, institutions, consortium or other contract homes, or any other
    facility- in which there are more children than is permitted by the
    facility's license or permit.

    Ability to produce information systems reports showing each X

    facility- foster homes, group homes, institutions, consortium or other
    contract homes, or any other facility- in which there are more children than
    is permitted by the facility's license or permit.

    Ability to produce information systems reports showing all social X

    workers, by unit, who have caseloads exceeding the caseload limits
    established in the MFO, including the name and identification of the worker,
    the worker's supervisor, and the size of the worker's caseload.

    Ability to produce information systems reports showing all cases X

    in which an investigation has not been initiated within 48 hours of the
    receipt of the report.

    Ability to produce information systems reports showing all cases X in which
    an investigation has not been completed within 30 days of the receipt of the
    report of abuse or neglect.

    Ability to produce information systems reports showing all cases X in which
    a child does not have a written case plan within 30 days of entering the
    department's custody.

    Ability to produce information systems reports showing all cases X

    in which a child has not received an administrative review during the
    preceding 9 months.

    Ability to produce information systems reports showing all cases X in which
    a child has not received a dispositional hearing within 21 months of
    entering the department's custody.

    Ability to produce information systems reports showing all cases X in which
    a child younger than 6 has been placed in a congregate- care facility.

    Ability to produce information systems reports showing all cases X

    in which a child has had a plan of adoption and who has not been referred to
    the adoption program within 30 days of the establishment of the permanency
    goal.

    Ability to produce information systems reports showing all cases X in which
    a child younger than 12 has been assigned a permanency goal of continued
    care.

    (Continued From Previous Page)

    Under No efforts Feature a Developed development initiated b

    Ability to produce information systems reports showing all cases X in which
    a child younger than 16 has been assigned a permanency goal of independent
    living.

    Written policies and procedures for maximizing funds available X

    to the agency through titles IV- B and IV- E of the Adoption Assistance and
    Child Welfare Act of 1980, the Medicaid Act, and Supplemental Security
    Income.

    Note: We selected MFO requirements for examination that we identified as key
    to operating child welfare programs, such as delivering services to children
    and families and placing children in foster homes and other facilities. a We
    assessed CFSA's ability to produce written policies and procedures,
    management data, and

    information system reports as evidence of the extent to which it had
    developed practices required by the MFO. b A checkmark in this column
    indicates that unless otherwise specified, CFSA could not provide any

    policy or data in response to our request. c In commenting on a draft of
    this report, CFSA reported that these written policies, procedures, or

    forms had been developed or were under development. However, at the time of
    our review, the agency had not provided documentation to support this
    development.

    Source: CFSA.

    Child and Family Services Agency

    Appendi xI II Organization, September 2000

    Comments From the Child and Family

    Appendi xI V

    Services Agency Now on page 8. Now on page 7. Now on page 7.

    Now on pages 10, 15, and 16.

    Now on page 11.

    Now on page 12. Now on page 13. Now on page 14.

    Now on page 20. Now on page 22.

    Now on pages 22- 23. Now on pages 24- 25.

    Now on page 25. Now on page 29. Now on page 33.

    Now on page 39. Now on pages 44- 51.

    Related GAO Products Child Welfare: New Financing and Service Strategies
    Hold Promise, but Effects Unknown( GAO/ T- HEHS- 00- 158, July 20, 2000).

    Foster Care: HHS Should Ensure That Juvenile Justice Placements Are Reviewed
    (GAO/ HEHS- 00- 42, June 9, 2000).

    Foster Care: Status of the District of Columbia's Child Welfare System
    Reform Efforts (GAO/ T- HEHS- 00- 109, May 5, 2000).

    Foster Care: States' Early Experiences Implementing the Adoption and Safe
    Families Act( GAO/ HEHS- 00- 1, Dec. 22, 1999).

    Foster Care: Effectiveness of Independent Living Services Unknown (GAO/
    HEHS- 00- 13, Nov. 5, 1999).

    Foster Care: HHS Could Better Facilitate the Interjurisdictional Adoption
    Process( GAO/ HEHS- 00- 12, Nov. 19, 1999).

    Management Reform: Elements of Successful Improvement Initiatives (GAO/ T-
    GGD- 00- 26, Oct. 15, 1999).

    Foster Care: Kinship Care Quality and Permanency Issues( GAO/ HEHS- 99- 32,
    May 6, 1999).

    Foster Care: Increases in Adoption Rates( GAO/ HEHS- 99- 114R, Apr. 20,
    1999).

    Juvenile Courts: Reforms Aim to Better Serve Maltreated Children (GAO/ HEHS-
    99- 13, Jan. 11, 1999).

    Child Welfare: Early Experiences Implementing a Managed Care Approach (GAO/
    HEHS- 99- 8, Oct. 21, 1998).

    Foster Care: Agencies Face Challenges Securing Stable Homes for Children of
    Substance Abusers( GAO/ HEHS- 98- 182, Sept. 30, 1998).

    Child Protective Services: Complex Challenges Require New Strategies (GAO/
    HEHS- 97- 115, July 21, 1997).

    Child Welfare: States' Progress in Implementing Family Preservation and
    Support Services( GAO/ HEHS- 97- 34, Feb. 18, 1997).

    (116043) Lett er

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    GAO United States General Accounting Office

    Page 1 GAO- 01- 191 District of Columbia Child Welfare

    Contents

    Contents Page 2 GAO- 01- 191 District of Columbia Child Welfare

    Page 3 GAO- 01- 191 District of Columbia Child Welfare United States General
    Accounting Office

    Washington, D. C. 20548 Page 3 GAO- 01- 191 District of Columbia Child
    Welfare

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    Appendix I

    Appendix I Scope and Methodology

    Page 45 GAO- 01- 191 District of Columbia Child Welfare

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    Appendix II

    Appendix II District of Columbia Child Welfare System Features the MFO
    Required, July 2000

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    Appendix II District of Columbia Child Welfare System Features the MFO
    Required, July 2000

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    Appendix II District of Columbia Child Welfare System Features the MFO
    Required, July 2000

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    Appendix II District of Columbia Child Welfare System Features the MFO
    Required, July 2000

    Page 50 GAO- 01- 191 District of Columbia Child Welfare

    Appendix II District of Columbia Child Welfare System Features the MFO
    Required, July 2000

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    Appendix II District of Columbia Child Welfare System Features the MFO
    Required, July 2000

    Page 52 GAO- 01- 191 District of Columbia Child Welfare

    Appendix II District of Columbia Child Welfare System Features the MFO
    Required, July 2000

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    Appendix III

    Page 55 GAO- 01- 191 District of Columbia Child Welfare

    Appendix IV

    Appendix IV Comments From the Child and Family Services Agency

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    Appendix IV Comments From the Child and Family Services Agency

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    Appendix IV Comments From the Child and Family Services Agency

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    Appendix IV Comments From the Child and Family Services Agency

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