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

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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

Page 49 GAO- 01- 191 District of Columbia Child Welfare

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

Page 51 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

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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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United States General Accounting Office Washington, D. C. 20548- 0001

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