D.C. Child and Family Services: Better Policy Implementation and 
Documentation of Related Activities Would Help Improve		 
Performance (27-MAY-03, GAO-03-646).				 
                                                                 
The District of Columbia (D.C.) Child and Family Services Agency 
(CFSA) is responsible for protecting children at risk of abuse	 
and neglect and ensuring that services are provided for them and 
their families. GAO was asked to discuss the extent to which CFSA
has (1) met requirements of the Adoption and Safe Families Act	 
(ASFA) of 1997 and other selected performance criteria, (2)	 
adopted and implemented child protection and foster care	 
placement policies, and (3) enhanced its working relationship	 
with the D.C. Family Court. To address these questions, GAO	 
analyzed data from CFSA's child welfare information system, known
as FACES; reviewed laws, regulations, and reports; examined case 
files; and interviewed officials.				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-03-646 					        
    ACCNO:   A07003						        
  TITLE:     D.C. Child and Family Services: Better Policy	      
Implementation and Documentation of Related Activities Would Help
Improve Performance						 
     DATE:   05/27/2003 
  SUBJECT:   Agency missions					 
	     Child abuse					 
	     Child adoption					 
	     Foster children					 
	     Interagency relations				 
	     Internal controls					 
	     Performance measures				 
	     District of Columbia FACES Information		 
	     System						 
                                                                 

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GAO-03-646

a

GAO United States General Accounting Office

Report to the Chairman, Committee on Government Reform, U. S. House of
Representatives

May 2003 D. C. CHILD AND FAMILY SERVICES Better Policy Implementation and
Documentation of Related Activities Would Help Improve Performance

GAO- 03- 646

CFSA*s performance relative to three sets of measures* nine ASFA
requirements, eight selected performance criteria and six of the agency*s
foster care policies* has been mixed. The agency took actions to implement
six of the nine ASFA requirements related to the safety and well- being of
foster children and met or exceeded four of the eight selected foster care
performance criteria,

but its plans did not address all requirements not fully implemented and
unmet performance criteria. CSFA has established many foster care
policies, but caseworkers did not consistently implement the six GAO
examined. In addition, FACES lacked data related to four of the policies
reviewed for at least 70 percent of its active foster care cases. The
following table summarizes the

percentage of cases for which the data indicated the policy was
implemented.

Implementation of Selected CFSA Foster Care Policies as Documented in
FACES CFSA policy Foster care cases for which

the policy was implemented a, b Initiate face- to- face investigation of
alleged child abuse or neglect within 24 hours of receiving an allegation
on CFSA*s child abuse hotline. 26% Complete a safety assessment within 24
hours of face- to- face contact with the child. 13% Complete a risk
assessment within 30 days of receiving an allegation on the hotline. 73%
Complete an initial case plan within 30 days of a child*s entry into
foster care. 9% Arrange needed services for foster care children or their
families. 83%

Source: FACES and GAO analysis. a With the exception of the policy to
arrange needed services, the analysis is based on 943 foster

care cases that were at least 6 months old, as of Nov. 30, 2002. These
cases were initiated after FACES came on- line in Oct. 1999. The analysis
of the policy to arrange for needed services is based on 1,837 foster care
cases and includes cases that pre- dated FACES but for which services were
provided after FACES came on- line. Data show the percentage of cases for
which

caseworkers arranged at least one service. b CFSA counted cases that had
missing data as instances of caseworker noncompliance with the

applicable policy. CFSA has enhanced its working relationship with the D.
C. Family Court, but several factors hindered this relationship. For
example, CFSA*s top management and Family Court judges talk frequently
about foster care case issues. However, differing opinions among CFSA
caseworkers and judges about their responsibilities have hindered the
relationships. CFSA officials and Family Court judges have been working
together to address these hindrances. The District of Columbia (D. C.)
Child and Family Services Agency (CFSA) is responsible for protecting
children at risk of abuse

and neglect and ensuring that services are provided for them and their
families. GAO was asked to discuss the extent to which CFSA has (1) met
requirements of the Adoption and Safe Families Act (ASFA) of 1997 and
other selected performance criteria, (2) adopted

and implemented child protection and foster care placement policies, and
(3) enhanced its working relationship with the D. C. Family Court. To
address these questions, GAO analyzed data from CFSA*s child welfare
information system, known

as FACES; reviewed laws, regulations, and reports; examined case files;
and interviewed officials.

To improve CFSA*s performance GAO recommends that the Mayor require the
Director of CFSA to (1) develop plans to fully implement all ASFA
requirements, (2) establish

procedures to ensure caseworkers consistently implement all foster care
policies, and (3) document in FACES all activities related to

active foster care cases. In commenting on the draft, the Director of CFSA
generally agreed with our findings. Although she did not directly address
the

recommendations, she generally agreed with the areas we identified for
continued improvement.

D. C. CHILD AND FAMILY SERVICES

Better Policy Implementation and Documentation of Related Activities Would
Help Improve Performance

www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 646. To view the full report,
including the scope and methodology, click on the link above. For more
information, contact Cornelia M. Ashby at (202) 512- 8403 or ashbyc@ gao.
gov. Highlights of GAO- 03- 646, a report to the

Chairman, Committee on Government Reform, House of Representatives May
2003

Page i GAO- 03- 646 D. C. Child and Family Services Letter 1 Results in
Brief 3 Background 5 CFSA Undertook Actions to Implement Most ASFA
Requirements Reviewed and Met Half of the Selected Performance Criteria
for

Child Safety and Well- Being 9 CFSA Has Established Many Foster Care
Policies but Lacks Others, and the Extent of Implementation and
Documentation Varies 15 CFSA Has Enhanced Its Working Relationship with
the D. C. Family Court by Working Collaboratively, but Hindrances Remain
22 Conclusions 23 Recommendations 23 Agency Comments and Our Evaluation 24
Appendix I Scope and Methodology 26

Appendix II Comments from the Director of the Child andFamily Services
Agency 28

Appendix III GAO Contacts and Acknowledgments 32 GAO Contacts 32
Acknowledgments 32 Related GAO Products 33

Tables

Table 1: CFSA*s Progress in Implementing Nine ASFA Requirements 10 Table
2: Analysis of Selected Foster Care Performance Criteria 12 Table 3:
Implementation of Selected CFSA Foster Care Policies as

Documented in FACES 16 Table 4: Number of Cases Taking 5 or More Days to
Implement Policy (2000- 2002) 17 Contents

Page ii GAO- 03- 646 D. C. Child and Family Services Figure

Figure 1: CFSA Responsibilities Related to Permanency Goals 8
Abbreviations

ASFA Adoption and Safe Families Act CFSA Child and Family Services Agency
HHS U. S. Department of Health and Human Services OCC Office of
Corporation Counsel SACWIS Statewide Automated Child Welfare Information
System TPR Termination of Parental Rights

This is a work of the U. S. Government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. It may contain
copyrighted graphics, images or other materials. Permission from the
copyright holder may be necessary should you wish to reproduce copyrighted
materials separately from GAO*s product.

Page 1 GAO- 03- 646 D. C. Child and Family Services

May 27, 2003 The Honorable Tom Davis Chairman Committee on Government
Reform House of Representatives

Dear Mr. Chairman: The District of Columbia*s Child and Family Services
Agency (CFSA) is responsible for protecting foster care children who have
been at risk of abuse and neglect and ensuring that critical services are
provided to them and their families. In 2002, CFSA had about 3, 000
children in foster care. As

a result of a history of poor performance, the U. S. District Court for
the District of Columbia placed CFSA in receivership in 1995. 1 To help
improve its performance during receivership, CFSA made several changes,
including establishing an automated case management system, FACES. In
2000, the District Court issued a consent order establishing a process by
which the agency*s receivership could be terminated. The order also
established a probationary period, which would begin when the receivership
ended and identified performance criteria CFSA had to meet in order to end
the probationary period. In April 2001, CFSA became a

cabinet- level agency within the government of the District of Columbia,
in June 2001 the court removed CFSA from receivership, and in October 2001
responsibility for child abuse investigations was transferred from the
District*s Metropolitan Police Department to CFSA. Additionally, new
legislation established requirements that CFSA had to meet. The Adoption
and Safe Families Act (ASFA) of 1997 mandated that all child welfare
agencies achieve timely placement of children in permanent homes. The U.
S. Department of Health and Human Services (HHS) is responsible for
setting standards and monitoring the nation*s child welfare programs,
including assessing compliance with ASFA requirements through its Child

1 The receivership was an arrangement in which the court appointed a
person to temporarily manage the agency with broad authority to ensure
full compliance with the court order in an expeditious manner. United
States General Accounting Office Washington, DC 20548

Page 2 GAO- 03- 646 D. C. Child and Family Services

and Family Services Reviews. 2 In addition, the District of Columbia
Family Court Act of 2001 required CFSA to work closely with the Family
Division of the D. C. Superior Court and the District*s Office of
Corporation Counsel (OCC). 3 In September 2002, the court- appointed
monitor reported that a child was abused by two children in a group home
licensed by CFSA. According to the monitor, this incident, together with
the history of inadequate care and attention given this child by CFSA,
indicated that its operations and policies, especially those regarding
foster care cases, may still need improvement.

You asked us to address the following questions: (1) To what extent did
CFSA address the requirements of the Adoption and Safe Families Act of
1997 and meet selected foster care performance criteria and what plans
does it have to address unmet requirements and criteria? (2) To what
extent has CFSA adopted and implemented foster care policies that are
comparable to those generally accepted in the child welfare community, and
how has implementation affected foster care children? (3) What has CFSA
done to enhance its working relationship with the D. C. Family Court and
what factors have affected these efforts?

To address these questions, we selected three sets of measures to assess
CFSA*s performance. First, we examined CFSA*s progress in implementing
nine ASFA requirements that were related to the safety and well- being of
foster children. Second, we assessed the extent to which CFSA met or
exceeded eight selected performance criteria established during its
probationary period. Third, we assessed the extent to which caseworkers
implemented six foster care policies related to their day- to- day
responsibilities. We analyzed data in the District*s automated child
welfare information system, known as FACES; reviewed laws, regulations,
and

2 Child and Family Services Reviews, conducted by HHS, cover a range of
child and family service programs funded by the federal government,
including child protective services, foster care, adoption, independent
living, and family support and preservation services. The 2001 review
evaluated seven specific safety, permanency, and well- being outcomes for
services delivered to children and families served by CFSA. As part of its
review, HHS randomly selected 50 active child welfare cases from the
period between April 2000 and July 2001. 3 The District of Columbia Family
Court Act of 2001 (P. L. 107- 114), established the Family

Court as part of the D. C. Superior Court. The Family Court replaced the
Family Division of the D. C. Superior Court. Among other responsibilities,
the Family Court handles child abuse and neglect cases, court hearings,
and other proceedings for the District*s foster children and their
families. OCC, among its other responsibilities, provides legal support to
CFSA on foster care cases.

Page 3 GAO- 03- 646 D. C. Child and Family Services

reports; examined case files; and interviewed officials. We obtained and
analyzed automated data from FACES on all foster care cases that were at
least 6 months old as of November 30, 2002. We selected ASFA requirements
and CFSA policies directly related to the safety and wellbeing of foster
children. We selected foster care performance criteria from among those
CFSA had to meet in order to end the probationary period

that, in our judgment, most directly related to the safety and permanent
placement of children in foster care. We reviewed federal and local laws,
regulations, foster care policies recommended by various organizations,
and reports on CFSA*s implementation of the District*s foster care program
and selected CFSA policies that covered several key foster care management
functions. We included HHS*s evaluation of how CFSA

implemented ASFA requirements in our assessment of the agency*s
performance. We independently verified the reliability of data in FACES;
however, CFSA had not entered into FACES detailed information on the data
elements we needed for our analysis with respect to about two- thirds of
the District*s active foster care cases* mostly cases that originated
prior to FACES going on- line in October 1999. To obtain information on
policy implementation, we also examined foster care case files. We
interviewed CFSA executives, managers, and supervisors; Family Court
judges, attorneys from OCC; and officials from organizations that
recommend policies applicable to child welfare programs. We conducted our
work between September 2002 and May 2003 in accordance with generally
accepted government auditing standards. See appendix I for additional
information on our scope and methodology.

CFSA undertook actions to implement six of nine ASFA requirements directly
related to the safety and well- being of foster care children and met or
exceeded four of eight selected foster care performance criteria, but its
plans do not address all requirements that were not fully implemented and

selected performance criteria that were not met. For example, CFSA signed
an interim border agreement to help achieve timelier placement of District
children in Maryland, which addresses ASFA*s requirement to use cross-
jurisdictional resources to facilitate timely adoptive or permanent
placements for waiting children. However, HHS*s review of the District
found that CFSA did not fully implement ASFA*s requirements to initiate or
join proceedings to terminate the rights of parents whose children are in
foster care, conduct annual hearings to review permanency goals for
children every 12 months, and provide participants a notice of reviews and
hearings. The selected foster care performance criteria CFSA met or
exceeded included the criteria that prohibit leaving children in emergency
care for more than 90 days and that require placing children in foster
care Results in Brief

Page 4 GAO- 03- 646 D. C. Child and Family Services

with one or more of their siblings. The criteria that CFSA did not meet
included the requirements regarding the frequency of caseworker visits
with children in foster care and the minimum percentage of foster care
children that must be placed in foster homes with valid licenses. CFSA has
written plans that address most of the unmet ASFA requirements and
selected performance criteria. The unmet requirements and performance
criteria not addressed in the plans are those related to providing timely
notification of all reviews and hearings to families with children in
foster care and to reducing the number of children in foster care who, for
18 months or more, have had a permanency goal to return home. Agency
officials cited staffing shortages and external demands, such as
coordinating work with other agencies, as factors that hindered the
agency*s ability to fully meet the ASFA requirements and performance
criteria. However, unless these requirements and criteria are met a
child*s safety may be jeopardized, the time a child spends in foster care
may be

prolonged, or the best decisions regarding a child*s future well- being
may not be reached.

While CSFA has adopted many foster care policies similar to those
recommended for child welfare programs, caseworkers did not consistently
implement the six we examined, potentially leaving children subject to
continued abuse or neglect or delaying efforts to achieve permanent and
safe placements. In those cases for which data were available, we found
that the extent to which CFSA implemented selected foster care policies
varied. For example, caseworkers implemented the policy requiring initial
case plans to be completed within 30 days of a child*s entry into foster
care in 9 percent of the cases, and they implemented the policy that
children and their families receive needed

services in 83 percent of the cases. While timeframes for initiating
investigations and completing safety assessments improved between 2000 and
2002, caseworkers still took considerably longer than the prescribed time
limits to complete these tasks. Caseworkers and managers said that the
policies were not always implemented because of limited staff and
competing demands, such as making visits to children or participating in
court proceedings. In addition, CFSA*s automated system lacked data on
four of the six policies for at least 70 percent of its active foster care
cases. Complete, accurate, and timely case management data enables
caseworkers to quickly learn about new cases, supervisors to

know the extent to which caseworkers are completing their tasks, and
managers to know whether any aspects of the agency*s operations are in
need of improvement. Without information on all cases, caseworkers do not
have a readily available summary of the child*s history, which may be
critical to know when making plans about the child*s care. Additionally,

Page 5 GAO- 03- 646 D. C. Child and Family Services

without information on all cases, managers do not have information needed
to assess program operations and make improvements, if needed. CFSA has
enhanced its working relationship with the D. C. Family Court by

working more collaboratively, and several factors have strengthened or
hindered these relationships. For example, CFSA, the Family Court, and
other District agencies have participated on various committees to address

interagency operations affecting children and families served by CFSA and
involved in cases before the court. In addition, since 2002, attorneys
from OCC have been located at CFSA and work closely with caseworkers to
help them prepare for court appearances. Support from top CFSA management
and Family Court judges has been a key factor in improving these
relationships. However, CFSA officials and Family Court judges noted
several hindrances that constrain CFSA*s efforts to enhance its working
relationship with the Family Court. These hindrances include the need for
caseworkers to balance court appearances with other case management
responsibilities, an insufficient number of caseworkers, caseworkers who
are unfamiliar with cases that have been transferred to them, and
differing opinions about the responsibilities of CFSA caseworkers and
judges.

To improve CFSA*s management of the foster care program and outcomes for
children in the District of Columbia, we recommend that the Mayor require
the Director of CFSA to (1) develop plans to fully implement all unmet
ASFA requirements, (2) establish procedures to ensure that caseworkers
consistently implement all foster care policies, and (3) document in FACES
all events related to active foster care cases.

The Director of CFSA, on behalf of the District*s Deputy Mayor for
Children, Youth, Families, and Elders provided written comments on a draft
of this report. In commenting on the draft, the Director generally agreed
with our findings. Although the CFSA Director did not directly

address the recommendations, she generally agreed with the areas we
identified for continued improvement. Additionally, she suggested several
changes to help clarify the report, which we incorporated as appropriate.
The comments are discussed in the report and are shown in appendix II.

While CFSA is responsible for protecting thousands of foster care
children, many children in CFSA*s care languished for extended periods of
time due to managerial shortcomings and long- standing organizational

divisiveness in the District of Columbia. As a result of these
deficiencies, the U. S. District Court for the District of Columbia issued
a remedial order in 1991 to improve the performance of the agency. Under a
modified final Background

Page 6 GAO- 03- 646 D. C. Child and Family Services

order established by the court in 1993, CFSA was directed to comply with
many requirements. In 1995, lacking sufficient evidence of program
improvement, the agency was removed from the District*s Department of

Human Services and placed in receivership. Among its efforts to improve
agency performance, CFSA established an automated system, FACES, to manage
its caseload. The District Court issued a consent order in 2000
establishing a process by which the agency*s receivership could be ended.

The order also established a probationary period, which began when the
receivership ended, and identified performance standards CFSA had to meet
in order to end the probationary period. The court- appointed monitor, the
Center for the Study of Social Policy, was to assess CFSA*s performance
and had discretion to modify the performance standards. In April 2001,
CFSA became a cabinet- level agency within the government of the District
of Columbia. In June 2001, the court removed CFSA from the receivership
and its probationary period began. In October 2001, responsibility for
child abuse investigations was transferred to CFSA from the District*s
Metropolitan Police Department. CFSA*s probationary period ended in
January 2003.

However, in September 2002, the court- appointed monitor reported that a
7- year old boy was abused by two children in a group home that CFSA had
licensed to provide care for 9- 21 year olds. The report also identified
several actions CFSA took or failed to take and concluded that the child
was not adequately protected or served by CFSA. For example, contrary to
its policies, CFSA did not place the child with his sibling, and there was
no evidence that CFSA assessed his social, emotional, or behavioral needs.
According to the court- appointed monitor, these events indicated that
CFSA*s operations and policies may still need improvement.

CFSA operates in a complex child welfare system. 4 Several federal laws,
local laws, and regulations established goals and processes under which
CFSA must operate. ASFA, with one of its goals to place children in
permanent homes in a timelier manner, placed new responsibilities on all
child welfare agencies nationwide. ASFA introduced new time periods for
moving children toward permanent, stable care arrangements and established
penalties for noncompliance. For example, ASFA requires child welfare
agencies to hold a permanency planning hearing* during which the court
determines the future plans for a child, such as whether

4 We issued several reports that addressed CFSA operations and program
plans. For more information, see related GAO products at the end of this
report.

Page 7 GAO- 03- 646 D. C. Child and Family Services

the state should continue to pursue reunification with the child*s family
or some other permanency goal* not later than 12 months after the child
enters foster care. The District of Columbia Family Court Act of 2001
established the District*s Family Court and placed several requirements on
the District*s Mayor and various District government agencies, including
CFSA and OCC. The District of Columbia Family Court Act requires the

Mayor, in consultation with the Chief Judge of the Superior Court, to
ensure that CFSA and other District government agencies coordinate the
provision of social services and other related services to individuals
served by the Family Court.

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, and D. C. Public Schools prepare
individual education plans for some foster care children. CFSA also works
with agencies in Maryland, Virginia, and other states to arrange for
placements of District children and also works with private agencies to
place children in foster and adoptive homes. In addition, CFSA is
responsible for licensing and monitoring organizations with which it
contracts, including group homes that house foster care children.

The management of foster care cases involves several critical steps
required by CFSA policy. (See fig. 1.) Typically, these cases begin with
an allegation of abuse or neglect reported to the CFSA child abuse hot
line.

CFSA staff are required to investigate the allegations through direct
contact with the reported victim. If required, the child may be removed
from his or her home, necessitating various court proceedings handled by
the District*s Family Court. CFSA caseworkers are responsible for

managing foster care cases by developing case plans; visiting the
children; participating in administrative review hearings involving CFSA
officials, children, parents, and other officials; attending court
hearings; and working with other District government agencies. CFSA
caseworkers are also responsible for documenting the steps taken and
decisions made related to a child*s safety, well- being, and proper foster
care placement, as well as those related to developing the most
appropriate goal for

permanency. Depending on their circumstances, children leave foster care
and achieve permanency through reunification with their birth or legal
parents, adoption, legal guardianship with a relative, or independence. 5
As

5 Independent living arrangements may be attained once a child, who has
not been reunified with his family or adopted, reaches the age of 18 or,
in some jurisdictions, 21 and for whom federal reimbursement for foster
care expenditures is no longer available.

Page 8 GAO- 03- 646 D. C. Child and Family Services

of September 2002, a child*s length of stay in the District*s foster care
program averaged 2.8 years.

Figure 1: CFSA Responsibilities Related to Permanency Goals

Page 9 GAO- 03- 646 D. C. Child and Family Services

HHS is responsible for setting standards and monitoring the nation*s child
welfare programs. In fiscal year 2001, about $6.2 billion in federal funds
were appropriated to HHS for foster care and related child welfare
services. HHS*s monitoring efforts include periodic reviews of the
operations, known as Child and Family Services Reviews, and of the
automated systems, known as Statewide Automated Child Welfare Information
System (SACWIS) Reviews, in the states and the District of Columbia. HHS
last reviewed CFSA*s child welfare information system in 2000 and its
overall program in 2001. CFSA undertook actions to implement six of the
nine ASFA requirements

we reviewed and met or exceeded four of the eight performance criteria
included in our study, but as of March 2003, its plans to improve its
performance did not include all ASFA requirements not fully implemented or
selected performance criteria. With regard to implementing ASFA
requirements, for example, CFSA signed a border agreement to achieve more
timely placement of District children in Maryland, which addresses the
ASFA requirement to use cross- jurisdictional resources to facilitate
timely adoptive or permanent placements for waiting children. Table 1
summarizes CFSA*s progress in implementing the nine ASFA requirements that
we reviewed. CFSA Undertook

Actions to Implement Most ASFA Requirements

Reviewed and Met Half of the Selected Performance Criteria for Child
Safety and Well- Being

Page 10 GAO- 03- 646 D. C. Child and Family Services

Table 1: CFSA*s Progress in Implementing Nine ASFA Requirements ASFA
requirements CFSA has implemented ASFA requirements CFSA has not fully

implemented

1. Include the safety of the child in state case planning and in a case
review system.

1. Initiate or join proceedings to terminate parental rights for certain
children in foster care* such as those who have been in foster care for 15
of the most

recent 22 months of care. 2. Comply with requirements for criminal
background clearances and have

procedures for criminal record checks. 2. Provide participants a notice of
reviews

and hearings and an opportunity to be heard. 3. Develop a case plan
documenting steps taken to provide permanent living

arrangements for a child. 3. Conduct mandatory permanency

hearings every 12 months for a child in foster care. 4. Develop plans for
the effective use of

cross- jurisdictional resources to facilitate timely adoptive or permanent
placements for waiting children. 5. Provide for health insurance coverage
for children with special needs in state

plans for foster care and adoption assistance. 6. Incorporate standards to
ensure quality

services for children in foster care in state plans. Source: ASFA and
HHS*s CSFR and GAO analysis.

Note: Our assessment of CFSA*s progress in implementing three
requirements* include the safety of the child in case planning, develop a
case plan documenting steps taken to provide permanent living arrangement
for a child, and provide for health insurance coverage for children with
special needs* is based on data and information provided to us. Our
assessment of CFSA*s progress in implementing the remaining ASFA
requirements is based on HHS*s review of CFSA.

HHS*s review of CFSA found that the agency did not meet three
requirements. CFSA did not consistently petition the Family Court to
terminate parental rights when returning the child to his or her family
had been deemed inappropriate and the child had been in foster care for 15
of the last 22 months. Based on its review of 50 foster care cases, HHS

reported that 54 percent of the children who were in care longer than 15
months did not have hearings initiated for the termination of parental
rights and reasons for not initiating such hearings were not documented in
the case plan or court order. HHS also found that not all cases had

hearings to review a child*s permanency goal within the timeframe
prescribed by ASFA. In addition, foster parents, relative caretakers, and
pre- adoptive parents were not consistently notified of reviews or
hearings held on behalf of the foster child. HHS found that not all
caregivers and prospective caregivers were notified of the time and place
of a hearing, if such notification took place at all.

Page 11 GAO- 03- 646 D. C. Child and Family Services

We also analyzed automated data from FACES related to eight foster care
performance criteria and found that CFSA met or exceeded four of them. For
example, one criterion requires 60 percent of children in foster care to
be placed with one or more of their siblings; we found that as of November

30, 2002, 63 percent of children were placed with one or more siblings.
The areas in which CFSA*s performance fell short were the criteria related
to (1) caseworker visitation with children in foster care, (2) placement
of

children in foster homes with valid licenses, (3) progress toward
permanency for children in foster care, and (4) parental visits with
children in foster care who had a goal of returning home. For example,
none of the 144 children placed in foster care during the 2- month period
prior to November 30, 2002, received required weekly visits by a CFSA
caseworker. Table 2 summarizes our analysis of the selected foster care
performance criteria.

Page 12 GAO- 03- 646 D. C. Child and Family Services

Table 2: Analysis of Selected Foster Care Performance Criteria Foster care
performance criteria Analysis

1. Current case plans for foster care cases.

Forty- five percent of foster care cases have current case plans.

Met As of September 30, 2002, 46 percent of foster care cases had current
case plans. 2. Visitation between children in foster

care and their parents. Thirty- five percent of cases in which children
have a permanency goal of return home have parental visits at least every
2 weeks.

Not met As of November 30, 2002, 1 percent of children with a return home
goal had parental visits at least every 2 weeks.

3. Social worker visitation with children in foster care.

Twenty- five percent of children in foster care have weekly visits with
social workers in their first 8 weeks of care; 35 percent of all children
in foster care have at least monthly visits. Not met As of November 30,
2002, no children had weekly visits

and at least 98 percent of children did not have monthly visits with a
caseworker. a 4. Appropriate legal status for children in foster care.

No child in emergency care for more than 90 days.

Met As of November 30, 2002, no children in emergency care more than 90
days. 5. Current and valid foster home licenses.

Seventy- five percent of children are placed in foster homes with valid
licenses.

Not met As of November 30, 2002, 47 percent of children were in foster
homes with valid licenses. 6. Progress toward permanency. No more than 10
percent of

children in foster care have a permanency goal of return home for more
than 18 months.

Not met As of November 30, 2002, 30 percent of children had a permanency
goal of return home more than 18 months.

7. Foster care placement with siblings. Sixty percent of children in
foster care are placed with one or more of their siblings.

Met As of November 30, 2002, 63 percent of children were placed with one
or more siblings. 8. Placement stability.

No more than 25 percent of children in foster care as of May 31, 2002,
have had three or more placements.

Met As of November 30, 2002, 21 percent of children had three or more
placements.

Source: GAO analysis. a For 2 percent of the children, caseworker visits
equaled or exceeded the number of months in placement. However, CFSA*s
data did not allow us to determine when caseworkers visited children or if
they visited children each month. CFSA*s Program Improvement Plan, a plan
required by HHS to address

those areas determined not met in a CFSR, identifies how it will address
two of the unmet ASFA requirements*( 1) to initiate or join proceedings

Page 13 GAO- 03- 646 D. C. Child and Family Services

to terminate parental rights (TPR) of certain children in foster care and
(2) to ensure that children have a permanency hearing every 12 months
after entering foster care. For example, CFSA has outlined steps to
improve its filings of TPR petitions with the Family Court. To help
facilitate this process, CFSA hired additional attorneys to expedite the
TPR proceedings. The new attorneys have been trained in ASFA requirements
and in the process for referring these cases to the Family Court. CFSA is
also developing a methodology for identifying and prioritizing cases
requiring TPR petitions. In another plan, the April 2003 Implementation
Plan, CFSA states that it will redesign its administrative review process
to improve, among other things, notification and attendance of relevant
parties and to provide for a comprehensive review of case progress,
permanency goals, and adequacy of services. 6 However,

this plan does not make it clear whether all applicable hearings and
proceedings will be included, such as permanency hearings.

Another CFSA plan, the Interim Implementation Plan, includes measures that
were developed to show the agency*s plans for meeting the requirements of
the modified final order issued by the U. S. District Court for the
District of Columbia. This plan includes actions to address three of the
four performance criteria the agency did not meet* visits between children
in foster care and their parents, social worker visitation with children
in foster care, and placement of children in foster homes with current and
valid licenses. The plan states that, for new contracts, CFSA will require
its contactors to identify community sites for parental visits to help
facilitate visits between children in foster care and their parents. The

plan also indicates that CFSA will concentrate on the recruitment and
retention of caseworkers. According to CFSA officials, caseworkers would
have more time for quality casework, including visitation with children,
parents, and caregivers, once they hire more caseworkers. Additionally,
the plan established a goal to have 398 unlicensed foster homes in
Maryland licensed by December 31, 2002. According to an agency official,
104 of these foster homes remained unlicensed as of May 14, 2003. However,
CFSA does not have written plans that address the performance criterion to
reduce the number of children in foster care who, for 18 months or more,
have had a permanency goal to return home. Without complete plans for
improving performance for all measures, CFSA*s ability

6 In April 2003, the court- appointed monitor submitted an implementation
plan containing additional performance measures to the U. S. District
Court for its approval. The plan established goals CFSA must meet by 2006.
The U. S. District Court approved the plan in May 2003.

Page 14 GAO- 03- 646 D. C. Child and Family Services

to comply with the ASFA requirements and meet the selected performance
criteria may be difficult. Furthermore, unless these requirements and
criteria are met, the time a child spends in foster care may be prolonged,
or the best decisions regarding a child*s future well- being may not be
reached.

CFSA officials cited several factors that hindered their ability to fully
implement the ASFA requirements and meet the selected performance
criteria, including court- imposed requirements, staffing shortages, and
high caseloads. For example, program managers and supervisors said that

the new court- imposed mediation process intended to address family issues
without formal court hearings places considerable demands on caseworkers*
time. The time spent in court for mediation proceedings, which can be as
much as 1 day, reduces the time available for caseworkers to respond to
other case management duties, such as visiting with children in foster
care. Furthermore, managers and supervisors reported that staffing
shortages have contributed to delays in performing critical case
management activities, such as identifying cases for which attorneys need
to file TPR petitions. However, staffing shortages are not a unique
problem to CFSA. We recently reported that caseworkers in other states
said that

staffing shortages and high caseloads had detrimental effects on their
abilities to make well- supported and timely decisions regarding
children*s safety. 7 We also reported that as a result of these shortages,
caseworkers have less time to establish relationships with children and
their families, conduct frequent and meaningful home visits, and make
thoughtful and well- supported decisions regarding safe and stable
permanent placements. 7 U. S. General Accounting Office, Child Welfare:
HHS Could Play a Greater Role in

Helping Child Welfare Agencies Recruit and Retain Staff, GAO- 03- 357
(Washington, D. C.: Mar. 31, 2003).

Page 15 GAO- 03- 646 D. C. Child and Family Services

CSFA has established many foster care policies, but caseworkers did not
consistently implement the six we selected. These policies covered the
range of activities involved in a foster care case, but did not duplicate
those examined in our review of the AFSA requirements or the selected
foster care performance criteria. In addition, CFSA*s automated system
lacked data on four of the six policies we examined for at least 70
percent of its active foster care cases. Without information on all cases,
caseworkers do not have a readily available summary of the child*s history
needed to make decisions about a child*s care and managers do not have
information needed to assess and improve program operations.

While we previously reported in 2000 8 that CFSA lacked some important
child protection and foster care placement policies, CFSA has now
established many such policies and most are comparable to those
recommended by organizations that develop standards applicable to child
welfare programs. For example, CFSA has policies for investigating

allegations of child abuse, developing case plans, and establishing
permanency goals for foster children. In addition, one policy is more
rigorous than suggested standards. Specifically, CFSA*s policy requires an
initial face- to- face meeting with children within 24 hours of reported
abuse

or neglect, while the suggested standard is 24 to 48 hours or longer,
depending on the level of risk to the child*s safety and well- being.
However, CFSA does not have some recommended policies, namely those
addressing (1) written time frames for arranging needed services for
children and families (e. g., tutoring for children and drug treatment for
family members); (2) limits on the number of cases assigned to a
caseworker, based on case complexity and worker experience; and (3)
procedures for providing advance notice to each person involved in a case
about the benefits and risks of services planned for a child and
alternatives to those services. CFSA managers said that the agency had not
established these policies because agency executives gave priority to
complying with court- ordered requirements.

CFSA did not consistently implement the policies we examined. We selected
six policies that did not duplicate those examined in our review of the
AFSA requirements or the selected foster care performance criteria in
order to cover most of the case management duties and responsibilities.

8 U. S. General Accounting Office, District of Columbia Child Welfare:
Long- Term Challenges in Ensuring Children*s Well- Being, GAO- 01- 191
(Washington, D. C.: Dec. 29, 2000) and Foster Care: Status of the District
of Columbia*s Child Welfare System Reform Efforts, GAO/ T- HEHS- 00- 109
(Washington, D. C.: May 5, 2000). CFSA Has Established

Many Foster Care Policies but Lacks Others, and the Extent of
Implementation and Documentation Varies CSFA Has Established Many Foster
Care Policies, but Caseworkers Did Not Consistently Implement Those We
Selected

Page 16 GAO- 03- 646 D. C. Child and Family Services

CFSA could not provide automated data regarding the implementation of one
policy requiring administrative review hearings every 6 months. 9 As for
the remaining five policies, data in FACES indicate that caseworkers*
implementation of them varied considerably. Table 3 summarizes these five
policies and the percentage of cases for which the data indicated the
policy was implemented.

Table 3: Implementation of Selected CFSA Foster Care Policies as
Documented in FACES

Policy Percent of foster care cases for which the policy was

implemented a, b Initiate face- to- face investigation of alleged child
abuse or neglect within 24 hours of receiving an allegation on CFSA*s
child abuse hotline. 26 Complete a safety assessment within 24 hours of
faceto- face contact with the child. 13 Complete a risk assessment within
30 days of receiving an allegation on the hotline. 73 Complete an initial
case plan within 30 days of a child*s entry into foster care. 9 Arrange
needed services for foster care children or their families. 83 Source:
FACES data and GAO analysis.

a With the exception of the policy to arrange needed services, the
analysis is based on 943 foster care cases that were at least 6 months
old, as of November 30, 2002. These cases were initiated after FACES came
on- line in October 1999. The analysis of the policy to arrange for needed
services is based on 1,837 foster care cases and includes cases that
predated FACES but for which services

were provided after FACES came on- line. Data show the percentage of cases
for which caseworkers arranged at least one service. b CFSA counted cases
that had missing data as instances of caseworker noncompliance with the

applicable policy. The policies related to initiating face- to- face
investigations and completing safety assessments are particularly critical
to ensuring children*s safety. CFSA*s policy requires caseworkers to
initiate an investigation of alleged child abuse or neglect within 24
hours of the call to CFSA*s hot line through face- to- face contact with
the child. Also, caseworkers are required to complete a safety assessment
within 24 hours of the face- to- face

contact with the child. While it took CFSA caseworkers considerably 9
Administrative review hearings are held to make decisions about a child*s
permanent placement. They generally involve foster care children, family
members, CFSA caseworkers, attorneys, and others with a role in the future
well- being of the child.

Page 17 GAO- 03- 646 D. C. Child and Family Services

longer than the time specified in the policy to take these actions in some
cases, CFSA*s performance has improved. CFSA has reduced the average time
it takes to make contacts and complete the assessments. In 2000, it took
caseworkers an average of 18 days to initiate a face- to- face
investigation, whereas in 2002 the average was 2 days. Similarly,
caseworkers took an average of 30 days to complete safety assessments in
2000, whereas the average time declined to 6 days in 2002. Although there
were cases that took much longer than the 24- hour limits, there were
fewer in 2002 than in 2000. CFSA caseworkers took 5 or more days to
initiate a face- to- face investigation for 61 cases in 2000, and for 16
cases in 2002. Table 4 summarizes the number of cases for which
caseworkers took

5 or more days to initiate investigations and complete safety assessments
from 2000 through 2002. Table 4: Number of Cases Taking 5 or More Days to
Implement Policy (2000- 2002)

Fiscal Year Policy 2000 2001 2002 Total

Initiate face- to- face investigation of alleged child abuse or neglect
within 24 hours of receiving an allegation. 61 66 16 143

Complete a safety assessment within 24 hours of face- to- face contact
with child. 101 122 50 273

Source: FACES data and GAO analysis.

We also reviewed case files and examined related data from FACES for 30
foster care cases to assess compliance with policies requiring timely case
planning, periodic administrative review hearings, and arrangements for
needed services. The case files we reviewed were often voluminous,
inconsistently organized, and contained information that was not always
traceable to data entered in FACES. Our review found that case plans were
not routinely completed within 30 days, as required by CFSA policy. The
FACES data provided subsequent to our case file review supported this
assessment.

We also found that for almost half of the cases we examined administrative
review hearings, which are held to ensure that key stakeholders are
involved in decisions about a child*s permanent placement, were
rescheduled, resulting in their being held less frequently than required
by CFSA policy. CFSA policy requires that these hearings be held every 6
months, and FACES automatically schedules them to occur 6 months after the
most recent hearing. However, CFSA officials are unable to track how
frequently they are rescheduled or the length of time between hearings
because the system overrides the dates of prior

Page 18 GAO- 03- 646 D. C. Child and Family Services

hearings. Agency officials explained that changes have been made to FACES
to enable them to track how many times an administrative review is re-
scheduled. Long delays between administrative review hearings could mean
delays in getting children into permanent placement. As for

arranging needed services, we could not determine from case files or FACES
whether services recommended by caseworkers were approved by supervisors
or if all needed services were provided. The FACES data indicate that at
least one service was provided for 83 percent of the cases, but do not
include a complete record of all services caseworkers

determine to be needed, nor do they indicate whether the services were
provided on a timely basis.

Officials said that several factors affected the implementation of some of
the policies we reviewed. Caseworkers* supervisors and managers explained
that, generally, the policies were not always implemented because of
limited staff and competing demands, and the policies were not documented
because some caseworkers did not find FACES to be user friendly. Agency
officials explained that, in part, the data on the implementation of the
initial investigations and safety assessment reflected a change in who was
responsible for the initial investigation of child abuse cases. Until
October 2001, the District*s Metropolitan Police Department had this
responsibility and data on initial investigations were

not entered into FACES. CFSA now has responsibility for both child abuse
and neglect investigations. Further, program managers and supervisors said
that several factors contributed to the time frames required to initiate
face- to- face investigations, including difficulty in finding the child*s
correct home address, contacting the child if the family tries to hide the
child from investigators, and even obtaining vehicles to get to the
location. Regarding administrative review hearings, the records indicate
that they were

rescheduled for a variety of reasons, such as the caseworker needing to
appear at a hearing for another case or the attorney not being able to
attend the hearing. Managers also said that the data on service delivery
was not always entered into FACES because caseworkers sometimes arranged
services by telephone and did not enter the data into FACES.

CFSA officials said that they recently made changes to help improve the
implementation of some of the policies we reviewed. They said that CFSA
has focused on reducing the number of cases for which a risk assessment

had not been completed and has reduced the number of these investigations
open more than 30 days from 807 in May 2001 to 263 in May 2002. CFSA
officials said that they also anticipate a reduction in the

number of administrative review hearings that are rescheduled. They said
the responsibility for notifying administrative review hearing
participants

Page 19 GAO- 03- 646 D. C. Child and Family Services

about a scheduled hearing was transferred from caseworkers to staff in
CFSA*s administrative review unit, and they intend to provide notification
well in advance of the hearings. Additionally, another official said that
CFSA has begun testing a process to ensure that all needed services are
provided within 45 days. Such improvements are needed because without
consistently

implementing policies for timely investigations and safety and risk
assessments, a child may be subject to continued abuse and neglect. Delays
in case plan preparation and in holding administrative review hearings
delay efforts to place children in permanent homes or reunite them with
their families. Further, without knowing whether children or families
received needed services, CFSA cannot determine whether steps have been
taken to resolve problems or improve conditions for children in its care,
which also delays moving children toward their permanency

goals. In addition to its policies for managing cases, CFSA has policies
for licensing and monitoring group homes, plans for training staff in
group homes, and a goal to reduce the number of young children in group
homes. CFSA*s policies for group homes are based primarily on District
regulations that went into effect July 1, 2002. For example, the
regulations prohibited CFSA from placing children in an unlicensed group
home as of January 1, 2003. According to CFSA officials, as of March 2003,
all CFSA group homes were licensed, except one, and CFSA was in the
process of removing children from that home. CFSA plans to monitor group
homes by assessing their compliance with contractual provisions and
licensing requirements. CFSA also plans to provide training to group home
staff to make it clear that, as District regulations require, any staff
member who observes or receives information indicating that a child in the
group home has been abused must report it. Further, CFSA has a goal to
reduce the number of children under 13 who are placed in group homes.
According to agency officials, CFSA has reduced the number of children
under 13 in

group homes from 128 in August 2002 to 70 as of February 2003 and has
plans to reduce that number even further by requiring providers of group
home care to link with agencies that seek foster care and adoptive
families. CFSA Has Established

Policies and Goals for Group Homes

Page 20 GAO- 03- 646 D. C. Child and Family Services

In our efforts to assess CFSA*s implementation of the selected foster care
policies related to the safety and well- being of children as shown in
table 3, we determined that FACES lacked data on many active foster care
cases. In December 2000, we reported that FACES lacked complete case
information, and caseworkers had not fully used it in conducting their
daily casework. 10 During our most recent review, we determined that FACES
lacked data on four of six foster care policies for at least 70 percent of
its active foster care cases. 11 Of the 2,510 foster care cases at least 6
months old as of November 30, 2002, data were not available for

1,763. CFSA officials explained that all of these cases predated FACES,
and the previous system was used primarily to capture information for
accounting and payroll purposes, not for case management. Top agency
managers said that CFSA does not plan to make it an agency priority to
transfer information kept in paper files for cases that predated FACES
into the system. Additionally, FACES reports show that data were not
available on many of the cases that entered the foster care system after
FACES came on line. For example, complete data on the initiation of
investigations and completion of safety assessments were not available for
about half of the 943 cases that entered the foster care system after
FACES came on line. CFSA officials explained that they intend to focus on
improving a few data elements at a time for current and future events.

Having systems that provide complete and accurate data is an important
aspect of effective child welfare programs. HHS requires all states and D.
C. to have an automated child welfare information system. These systems,
known as SACWIS, must be able to record data related to key child welfare
functions, such as intake management, case management, and resource
management. In its review of FACES, HHS found CFSA*s system was in
compliance with most of the requirements and identified several that
needed improvement, including the requirements to prepare and document
service/ case plans and to conduct and record the results of

10 U. S. General Accounting Office, District of Columbia Child Welfare:
Long- Term Challenges to Ensuring Children*s Well- Being, GAO- 01- 191
(Washington, D. C.: Dec. 29, 2000).

11 The four polices for which FACES lacked data included (1) initiate
face- to- face investigation of alleged child abuse or neglect within 24
hours of receiving an allegation on CFSA*s child abuse hotline, (2)
complete a safety assessment within 24 hours of face- toface contact with
the child, (3) complete a case plan within 30 days of a child*s entry into
foster care, and (4) schedule and attend administrative review hearings
every 6 months. CFSA*s Automated System

Lacked Data on Many Foster Care Cases

Page 21 GAO- 03- 646 D. C. Child and Family Services

case reviews. 12 According to a CFSA official, D. C. responded to the HHS
report and made changes to address most of the findings. He said that the
changes included redesigning the FACES screens documenting service/ case
plans and the results of case reviews. These changes were made in
collaboration with caseworkers to help improve usability.

In addition to the standards and requirements established by HHS for all
child welfare systems, the modified final order requirements established
by the U. S. District Court for the District of Columbia direct CFSA to
produce management data and many reports on their operations. For example,
the modified final order requires that CFSA be able to produce a variety
of data such as, the number of children (1) for whom a case plan was not
developed within 30 days, (2) with a permanency goal of returning home for
12 months or more, and (3) placed in a foster home or facility who have
been visited at specified intervals.

Complete, accurate, and timely case management data enables caseworkers to
quickly learn about new cases, supervisors to know the extent that
caseworkers are completing their tasks, and managers to know whether any
aspects of the agency*s operations are in need of improvement. Child
welfare automated systems need to have complete case data to help ensure
effective management of child welfare programs. A child welfare expert
said that there is a great need to transfer information from old case
records to new automated systems. For example, the expert said that
records of older teens have been lost, and, with them, valuable
information such as the identity of the children*s

father. Without data in FACES, CFSA*s caseworkers will have to look for
paper records in the case files, some of which are voluminous. This file
review effort is much more time- consuming than reviewing an automated
report and as a result, when cases are transferred to new caseworkers, it

requires more time for them to become familiar with cases. 12 HHS
completed its SACWIS assessment review of FACES in June 2000. The purpose
of this review is to assess whether the child welfare information system
performs functions that are important to meeting the minimal requirements.

Page 22 GAO- 03- 646 D. C. Child and Family Services

CFSA has enhanced its working relationship with the D. C. Family Court by
working more collaboratively, but several factors have hindered these
relationships. By participating in committees and training sessions,
collocating OCC attorneys with caseworkers, and communicating frequently,
CFSA has enhanced its working relationship with the Family Court. CFSA
participates in various planning committees with the Family Court, such as
the Implementation Planning Committee, a committee to help implement the
District of Columbia Family Court Act of 2001. CFSA caseworkers have
participated in training sessions that include OCC attorneys and Family
Court judges. These sessions provide all parties with information about
case management responsibilities and various court proceedings, with the
intent of improving and enhancing the mutual understanding about key
issues. Additionally, CFSA assigned a liaison representative to the Family
Court who is responsible for working with other District agency liaison
representatives to assist social workers and case managers in identifying
and accessing court- order services for children and their families at the
Family Court. Also, since 2002, OCC attorneys have been located at CFSA
and work closely with caseworkers. This arrangement has improved the
working relationship between CFSA and the Family Court because the
caseworkers and the attorneys are better prepared for court appearances.
Furthermore, senior managers at CFSA and the Family Court communicated
frequently about day- to- day operations as well as long- range plans
involving foster care case management and related court priorities, and on
several occasions expressed their commitment to improving working
relationships.

However, CFSA officials and Family Court judges also noted several
hindrances that constrain their working relationship. These hindrances
include the need for caseworkers to balance court appearances with other
case management duties, an insufficient number of caseworkers, caseworkers
who are unfamiliar with cases that have been transferred to them, and
differing opinions about the responsibilities of CFSA caseworkers and
judges. For example, although CFSA caseworkers are responsible for
identifying and arranging services needed for children and their families,
some caseworkers said that some Family Court judges overruled their
service recommendations. Family Court judges told us that they sometimes
made decisions about services for children because they believe
caseworkers did not always recommend appropriate ones or provide the court
with timely and complete information on the facts and circumstances of the
case. Furthermore, the Presiding Judge of the Family

court explained that it was the judges* role to listen to all parties and
then make the best decisions by taking into account all points of view.
Caseworkers and judges agreed that appropriate and timely decisions CFSA
Has Enhanced

Its Working Relationship with the D. C. Family Court by Working
Collaboratively, but

Hindrances Remain

Page 23 GAO- 03- 646 D. C. Child and Family Services

about services for children and their families are important ones that can
affect a child*s length of stay in foster care. CFSA officials and Family
Court judges have been working together to address some of the hindrances
that constrain their working relationship. CFSA managers said that
scheduling of court hearings has improved. According to agency officials,
in March 2003, CFSA began receiving daily schedules from the Family Court
with upcoming hearing dates. This

information allows caseworkers to plan their case management duties such
that they do not conflict with court appearances. Also, as of March 2003,
court orders were scanned into FACES to help ensure that caseworkers and
others involved with a case have more complete and accurate information.
To help resolve conflicts about ordering services,

CFSA caseworkers and Family Court judges have participated in sessions
during which they share information about their respective concerns,
priorities, and responsibilities in meeting the needs of the District*s
foster care children and their families.

CFSA has taken steps to implement several ASFA requirements, met several
performance criteria, developed essential policies, and enhanced its
working relationship with the Family Court. In addition, CFSA has
implemented new group home policies, improved the average time caseworkers
took to implement certain policies and undertaken initiatives, in
conjunction with the Family Court, to improve the scheduling of court
hearings. However, CFSA needs to make further improvements in order to

ensure the protection and proper and timely placement of all of the
District*s foster care children. By implementing all ASFA requirements,
meeting the performance criteria and effectively implementing all
policies, CFSA will improve a child*s stay in the foster care system and
reduce the time required to attain permanent living arrangements.
Furthermore, complete, accurate, and timely case management data will
enable caseworkers to quickly learn about new cases and the needs of
children and their families, supervisors to know the extent to which
caseworkers are completing all required tasks, and managers to know
whether any critical aspects of the agency*s operations are in need of
improvement. Without automated information on all cases, caseworkers do
not have a readily available summary of the child*s history, which may be
critical to know when making plans about the child*s safety, care, and
well- being.

To improve CFSA*s performance and outcomes for foster care children in the
District of Columbia, we recommend that the Mayor require the Director of
CFSA to (1) develop plans to fully implement all ASFA Conclusions

Recommendations

Page 24 GAO- 03- 646 D. C. Child and Family Services

requirements; (2) establish procedures to ensure that caseworkers
consistently implement foster care policies; and (3) document in FACES all
activities related to active foster care cases, including information from
paper case files related to the history of each active foster care case.

We received written comments from the Director of the District of
Columbia*s Child and Family Services Agency who provided them on behalf of
the Deputy Mayor for Children, Youth, Families, and Elders. These comments
are reprinted in appendix II. The Director generally agreed with our
findings related to the extent to which CFSA implemented ASFA
requirements, developed policies, and improved its relationship with the
D. C. Family Court. Although the CFSA Director did not directly address
the recommendations, she generally agreed with the areas we identified for
continued improvement and said that CFSA is deeply committed to continuing
improvements in the FACES information system.

Additionally the Director provided overall comments concerning the (1)
implementation plan, (2) establishment of CFSA, and (3) timeframes of the
receivership. CFSA suggested that we modify the report to reflect

strategies listed in the April 2003 Implementation Plan regarding timely
notification and reducing the number of children in foster care for 18
months or more with a permanency goal of returning home. We changed the
report to reflect the notification strategy but did not make changes
regarding children and their progress towards permanency because the April
2003 plan did not include a relevant strategy. CFSA also

suggested that we include the date the agency was established as a single
cabinet- level District agency and the date the agency gained
responsibility for abuse cases from the Metropolitan Police Department. We
made these changes. Additionally, CFSA recommended that we discuss the
policy implementation trends earlier in the report, and asked that we note
the time period for the cases included in the HHS review, which we did.
CFSA also asked that we explain that the data we collected and analyzed

generally covered the October 1999 to mid- 2002 period. We did not make
this change. As explained in the scope and methodology section of the
report, we reviewed and analyzed a variety of data related to all active
foster care cases. Some of the data was as of November 2002, and some
analyses were based on active cases that began prior to October 1999.

The CFSA Director also made several detailed comments. As she suggested,
we added language to clarify the requirement for a permanency hearing,
included information on changes made to FACES regarding rescheduling
administrative reviews and corrected the number of CFSA Agency Comments

and Our Evaluation

Page 25 GAO- 03- 646 D. C. Child and Family Services

staff assigned to the Family Court. We did not include the March 2003 data
listed in the comments because we could not verify the accuracy of the
data.

Although the CFSA director did not directly address the recommendations,
we continue to think that in order for CFSA to further improve its
performance, the agency should develop plans to fully implement all ASFA
requirements, establish procedures to ensure that caseworkers consistently
implement all foster care policies, and document in FACES all activities
related to active foster care cases.

As agreed with your office, unless you publicly release its contents
earlier, we will make no further distribution of this report until 30 days
after its issue date. At that time, we will send copies of this report to
the Mayor of the District of Columbia; the Deputy Mayor for Children,
Youth, Families, and Elders; the Director of the District of Columbia
Child and Family Services Agency; and the Chief Judge of the District of
Columbia Superior Court. We will also make copies of this report available
to others on request. In addition, the report will be available at no
charge on GAO*s Web site at http:// www. gao. gov.

If you have any questions about this report, please contact me on (202)
512- 8403. Other contacts and staff acknowledgments are listed in appendix
III.

Sincerely yours, Cornelia M. Ashby Director, Education, Workforce, and
Income Security Issues

Appendix I: Scope and Methodology Page 26 GAO- 03- 646 D. C. Child and
Family Services

To provide a comprehensive assessment of the Child and Family Services
Agency*s (CFSA) performance relative to Adoption and Safe Families Act of
1997 (ASFA) requirements and selected foster care performance criteria, we
relied on several sources of information and analyses. We reviewed the U.
S. Department of Health and Human Services* (HHS) Child and Family
Services Review (February 2002) and obtained and analyzed data to assess
CFSA*s implementation of ASFA*s requirements. Our

analysis of CFSA*s implementation of ASFA identified whether the agency
had implemented procedures in accordance with the ASFA requirements and
did not assess the extent to which or how well it had implemented the
requirement across all applicable foster care cases.

To perform our assessment of CFSA*s performance with regard to the
selected performance criteria established during its probationary period,
we obtained and analyzed relevant automated data from FACES 1 on all
active foster care cases as of November 30, 2002, the last complete month
for which data were available at the time of our work. We analyzed these
data for six of the eight criteria. For the other two criteria, we
analyzed data on all foster homes as of November 30, 2002, and data on
case plans

as of September 30, 2002. Additionally, we obtained and analyzed automated
FACES data for 943 foster care cases that were at least 6 months old as of
November 30, 2002, to assess how CFSA caseworkers implemented foster care
policies that covered several key functions from investigations through
the delivery of services to foster children and their

families. Many of the active foster care cases began prior to October
1999. We also obtained and analyzed reports by the court- appointed
monitor to assess CFSA*s performance relative to the specified
requirements and criteria. In addition, we reviewed and included relevant
information from several of our prior reports on CFSA and the District*s
Family Court. In addition, we independently verified the reliability of
automated data by reviewing related reports on the data maintained in
FACES and by

assessing the degree to which FACES contained erroneous or illogical data
entries. To obtain additional information on policy implementation and
documentation, we reviewed case files for children who entered the foster
care system at different times. Our case file review included analyses of
data contained in FACES and in paper case files for selected foster care
cases. We pretested our data collection instrument for collecting case
file information and received training in the content and

1 CFSA*s automated case management system. Appendix I: Scope and
Methodology

Appendix I: Scope and Methodology Page 27 GAO- 03- 646 D. C. Child and
Family Services

use of FACES. In addition, while FACES did not contain all data on the
implementation of the policies we selected, we analyzed information on
CFSA*s most recent performance to provide a comprehensive assessment of
various agency initiatives intended to improve implementation of foster
care policies. We also reviewed federal and local laws, regulations, and
selected CFSA policies. Using interview protocols, we interviewed CFSA
executives, managers, and supervisors; OCC officials; the Office of the
Deputy Mayor for Children, Youth, Families, and Elders; Family Court

judges and other court officials; and child welfare experts in
organizations that recommend policies applicable to child welfare
programs.

Appendix II: Comments from the Director of the Child and Family Services
Agency Page 28 GAO- 03- 646 D. C. Child and Family Services

Appendix II: Comments from the Director of the Child and Family Services
Agency

Appendix II: Comments from the Director of the Child and Family Services
Agency Page 29 GAO- 03- 646 D. C. Child and Family Services

Appendix II: Comments from the Director of the Child and Family Services
Agency Page 30 GAO- 03- 646 D. C. Child and Family Services

Appendix II: Comments from the Director of the Child and Family Services
Agency Page 31 GAO- 03- 646 D. C. Child and Family Services

Appendix III: GAO Contacts and Acknowledgments

Page 32 GAO- 03- 646 D. C. Child and Family Services

Carolyn M. Taylor, (202) 512- 2974, taylorcm@ gao. gov Mark E. Ward, (202)
512- 7274, wardm@ gao. gov

The following individuals also made important contributions to this
report: Sheila Nicholson, Vernette Shaw, Joel Grossman, and James Rebbe.
Appendix III: GAO Contacts and

Acknowledgments GAO Contacts Acknowledgments

Related GAO Products Page 33 GAO- 03- 646 D. C. Child and Family Services

D. C. Child and Family Services: Key Issues Affecting the Management of
Its Foster Care. GAO- 03- 758T. Washington, D. C.: May 16, 2003.

Foster Care: States Focus on Finding Permanent Homes for Children, but
Long- Standing Barriers Remain. GAO- 03- 626T. Washington, D. C.: April 8,
2003. District of Columbia: Issues Associated with the Child and Family

Services Agency*s Performance and Policies. GAO- 03- 611T. Washington, D.
C.: April 2, 2003.

Child Welfare: HHS Could Play a Greater Role in Helping Child Welfare
Agencies Recruit and Retain Staff. GAO- 03- 357. Washington, D. C.: March
31, 2003.

District of Columbia: More Details Needed on Plans to Integrate Computer
Systems With the Family Court and Use Federal Funds. GAO02- 948.
Washington, D. C.: August 7, 2002.

Foster Care: Recent Legislation Helps States Focus on Finding Permanent
Homes for Children, but Long- Standing Barriers Remain. GAO- 02- 585.
Washington, D. C.: June 28, 2002.

D. C. Family Court: Progress Made Toward Planned Transition and
Interagency Coordination, but Some Challenges Remain. GAO- 02- 797T.
Washington, D. C.: June 5, 2002.

D. C. Family Court: Additional Actions Should Be Taken to Fully Implement
Its Transition. GAO- 02- 584. Washington, D. C.: May 6, 2002.

D. C. Family Court: Progress Made Toward Planned Transition, but Some
Challenges Remain. GAO- 02- 660T. Washington, D. C.: April 24, 2002.
District of Columbia Child Welfare: Long- Term Challenges to Ensuring

Children*s Well- Being. GAO- 01- 191. Washington, D. C.: December 29,
2000.

Foster Care: Status of the District of Columbia*s Child Welfare System
Reform Efforts. GAO/ T- HEHS- 00- 109. Washington, D. C.: May 5, 2000.
Related GAO Products

(130203)

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