D.C. Child and Family Services: Key Issues Affecting the
Management of Its Foster Care Cases (16-MAY-03, GAO-03-758T).
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 critical services are provided for
them and their families. GAO was asked to discuss the extent to
which CFSA has (1) met the 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 in the District's automated child
welfare information system, known as FACES; reviewed laws,
regulations, and reports; examined case files; and interviewed
officials.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-03-758T
ACCNO: A06914
TITLE: D.C. Child and Family Services: Key Issues Affecting the
Management of Its Foster Care Cases
DATE: 05/16/2003
SUBJECT: Child abuse
Child adoption
Foster children
Performance measures
Agency missions
Internal controls
Interagency relations
District of Columbia FACES Information
System
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GAO-03-758T
Testimony Before the Committee on Government Reform, House of
Representatives
United States General Accounting Office
GAO For Release on Delivery Expected at 10: 00 a. m. EDT Friday, May 16,
2003 D. C. CHILD AND FAMILY
SERVICES Key Issues Affecting the Management of Its Foster Care Cases
Statement of Cornelia M. Ashby, Director Education, Workforce, and Income
Security Issues
GAO- 03- 758T
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. However, because this
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separately.
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 do not address
all unmet requirements and criteria. CSFA has established many foster care
policies, but caseworkers did not consistently implement the six GAO
examined. In addition, FACES lacked data on four of these six policies for
at least 70 percent of its active foster care cases. The following table
summarizes five selected foster care policies for which data were
available and 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 critical services are provided for them and
their families. GAO was asked to discuss the extent to which CFSA has (1)
met the 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 in the District*s automated
child welfare information system, known as FACES; reviewed laws,
regulations, and reports; examined case files; and interviewed officials.
www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 758T. To view the full
testimony, click on the link
above. For more information, contact Cornelia M. Ashby, (202) 512- 8403,
ashbyc@ gao. gov. Highlights of GAO- 03- 758T, testimony
before the Committee on Government Reform, House of Representatives May
16, 2003
D. C. CHILD AND FAMILY SERVICES
Key Issues Affecting Management of Its Foster Care Cases
Page 1 GAO- 03- 758T Mr. Chairman and Members of the Committee: I am
pleased to be here today to discuss preliminary findings from our
study of the District of Columbia*s Child and Family Services Agency
(CFSA) you requested. My testimony will focus on the extent to which CFSA
has (1) taken actions to address the requirements of the Adoption and Safe
Families Act (ASFA) of 1997 and met selected performance criteria, (2)
adopted and implemented child protection and foster care placement
policies that are comparable to those generally accepted in the child
welfare community, and (3) enhanced its working relationship with the D.
C. Family Court.
My comments today are based primarily on our analysis of the information
in the District*s automated child welfare information system, known as
FACES, which CFSA is to use to manage child welfare cases and report child
abuse and neglect, foster care, and adoption information to the U. S.
Department of Health and Human Services (HHS). We selected three sets
of measures to assess CFSA*s performance. We assessed CFSA*s progress in
implementing nine ASFA requirements that were related to the safety and
well- being of children in foster care, the extent to which CFSA met or
exceeded eight selected performance criteria established during its
probationary period, and the extent to which caseworkers implemented six
foster care policies related to their day- to- day responsibilities. We
included HHS*s evaluation of how CFSA implemented ASFA requirements in our
assessment of the agency*s performance. We analyzed foster care cases in
FACES that were at least 6 months old as of November 2002 and verified the
accuracy of its data. 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.
Consequently, we also reviewed paper case files for children with
different beginning dates in the foster care system to supplement FACES
information for some cases. We also interviewed District officials; CFSA
managers, judges, and child welfare experts; and we analyzed federal and
District laws and regulations, related court documents, and child welfare
policies. Our final report will be issued later this month. We conducted
our work between September 2002 and May 2003 in accordance with generally
accepted government auditing standards.
Page 2 GAO- 03- 758T In summary, CFSA has taken actions to implement
various ASFA requirements and met several selected foster care performance
criteria, 1 established child protection and foster care placement
policies and
procedures, and enhanced its working relationship with the D. C. Family
Court; however, much remains to be done. CFSA took actions to implement
two- thirds of the ASFA requirements and met or exceeded half of the
selected foster care performance criteria we used and developed
written plans to address two of the three ASFA requirements not fully met
and three of the four unmet foster care performance criteria. In addition,
CFSA has adopted child protection and foster care placement policies and
procedures that are comparable to most, but not all, of those recommended
by organizations that develop standards applicable to child welfare
programs. However, CFSA has not adopted some key policies and procedures
for ensuring the safety and permanent placement of children,
and caseworkers have not consistently implemented or documented some of
the policies and procedures that have been adopted. While timeframes for
implementing certain policies, such as initiating investigations and
completing safety assessments have improved since 2000, caseworkers still
take considerably longer than the prescribed time limits to complete these
critical tasks, thereby increasing the potential risks posed to the safety
and well- being of the District*s children. In addition, CFSA has
developed an automated child welfare data system to help manage its
caseload, among other initiatives to help improve its performance.
However, detailed information for the data elements related to four of the
six policies reviewed had not been entered into the system for at least 70
percent of its active foster care cases. Further, CFSA has improved its
working relationship with the Family Court through improved communication
and support from top CFSA managers and Family Court judges; however, both
CFSA and the Family Court still need to overcome barriers that continue to
hinder this relationship. While CFSA is responsible for protecting
children at risk of abuse and
neglect, 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
1 These performance criteria were among those included in the performance
standards that CFSA had to meet in order to end the probationary period
following the general receivership. We selected those performance criteria
that in our judgment most directly relate to the safety and permanent
placement of children. Background
Page 3 GAO- 03- 758T in 1991 to improve the performance of the agency.
Under a modified final 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. 2 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
terminated. The order also established a probationary period, which would
commence upon termination of the receivership, 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 the discretion to modify
the performance standards. In June 2001, the court removed CFSA from
receivership. In September 2002, the court- appointed monitor reported
that a 7- year old child was abused by two children in a group home
licensed by CFSA. This incident, according to the monitor, 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. CFSA operates in a complex child
welfare system. 3 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 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 (P. L. 107- 114) established the
District*s Family Court and placed several
requirements on the District*s Mayor and various District agencies, 2 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. 3 We issued
several reports that addressed CFSA operations and program plans. For more
information see related GAO products.
Page 4 GAO- 03- 758T including CFSA and the Office of Corporation Counsel
(OCC). 4 The District of Columbia Family Court Act of 2001 requires the
Mayor, in
consultation with the Chief Judge of the Superior Court, to ensure that
CFSA and other D. C. government offices 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 children in care. 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
responsibilities required by CFSA policy. Typically, these cases begin
with an allegation of abuse or neglect reported to CFSA*s 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, attorneys, and other officials; attending
court hearings, and working with other District government agencies. CFSA
case workers 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
4 Among other responsibilities, OCC provides legal support to CFSA in its
handling of foster care cases. 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 is no
longer eligible to receive federal reimbursement for foster care
expenditures.
Page 5 GAO- 03- 758T of September 2002, a child*s length of stay in the
District*s foster care program averaged 2.8 years.
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, 6 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 we
included in our study, but CFSA*s plans to improve its performance do not
include all unmet ASFA requirements or selected performance criteria.
Table 1 summarizes CFSA*s progress in implementing the nine ASFA
requirements that we reviewed.
6 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. CFSA Undertook
Actions to Implement
Most ASFA Requirements Reviewed and Met Half of the Selected Performance
Criteria for Child Safety and Well- Being
Page 6 GAO- 03- 758T 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 arrangements
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. The HHS 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 there was a
lack of
Page 7 GAO- 03- 758T communication in notifying caregivers and prospective
caregivers of the time and place of a hearing, if such notification took
place at all.
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 of the criteria 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 included
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 8 GAO- 03- 758T 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 with a social worker.
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 home 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 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 for the performance measure to this criterion do not allow for the
determination of whether caseworkers visited children each month they were
in foster care.
CFSA*s Program Improvement Plan, a plan required by HHS to address those
areas determined not met by HHS, identifies how it will address two of the
unmet ASFA requirements*( 1) to initiate or join proceedings to terminate
parental rights (TPR) of certain children in foster care and (2) to ensure
that children in foster care have a permanency hearing every 12 months.
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
Page 9 GAO- 03- 758T referring these cases to the Family Court. CFSA is
also developing a methodology for identifying and prioritizing cases
requiring TPR petitions.
While CFSA*s updated Program Improvement Plan states its intent to provide
notification of hearings to all participants, this plan does not make it
clear whether all applicable reviews and hearings will be included.
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. 7 This plan includes actions to address three of the
four performance criteria CFSA 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. 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 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
meet the ASFA requirements and the selected performance criteria,
including court- imposed requirements, staffing shortages, and high
caseloads. For example, program managers and supervisors said that the new
courtimposed mediation process intended to address family issues without
formal court hearings places considerable demands on caseworkers* time.
7 In April 2003, the court- appointed monitor submitted a final
implementation plan containing additional performance measures to the U.
S. District Court for the District of Columbia for its approval. Once
approved, this plan will establish goals CFSA must meet by 2006.
Page 10 GAO- 03- 758T 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. 8
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
wellsupported decisions regarding safe and stable permanent placements.
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 policy implementation 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.
8 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). CFSA Has Established
Many Foster Care Policies but Lacks Others, and the Extent of
Implementation and Documentation Vari es
Page 11 GAO- 03- 758T While we previously reported in 2000 9 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 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. CFSA could
not provide automated data regarding the implementation of one policy
requiring administrative review hearings every 6 months. 10 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.
9 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).
10 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. CSFA Has Established Many Foster Care
Policies,
but Caseworkers Did Not Consistently Implement Those We Selected
Page 12 GAO- 03- 758T 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 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. 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 maltreatment 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 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.
Page 13 GAO- 03- 758T 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 faceto- 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 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 hearings. 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
Page 14 GAO- 03- 758T friendly. Agency officials explained that, in part,
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 they recently made changes to help improve the
implementation of some of the policies we reviewed. They said 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
also said that they anticipate a reduction in the number of administrative
review hearings that are rescheduled. They said the responsibility for
notifying administrative review hearing participants 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.
Page 15 GAO- 03- 758T 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.
In our efforts to assess CFSA*s implementation of the six selected foster
care policies related to the safety and well- being of children as shown
in table 2, 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. 11 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. Of the 2,510 foster care cases at least 6
months old as of November 30, 2002, data were not available for 1,763 of
them. 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 11 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). CFSA Has Established
Policies and Goals for Group Homes
CFSA*s Automated System Lacked Data on Many Foster Care Cases
Page 16 GAO- 03- 758T 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
the District of Columbia 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. However, in its review of FACES, HHS
found CFSA*s system was not in full compliance with several requirements,
including the need to prepare and document service/ case plans and to
conduct and record the results of case reviews. 12 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 child*s father.
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 17 GAO- 03- 758T 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.
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 two caseworkers who assist in
arranging court- ordered 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 Family Court judges overruled service recommendations made by
caseworkers. Family Court judges told us that they sometimes made
decisions about services for children because caseworkers did not always
recommend appropriate ones or provide the CFSA Has Enhanced
Its Working Relationship with the D. C. Family Court by Working
Collaboratively, but
Hindrances Remain
Page 18 GAO- 03- 758T court with timely and complete information on the
facts and circumstances of the case. Caseworkers and judges agreed that
appropriate and timely decisions 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,
Family 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 in the most timely way, 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. Conclusions
Page 19 GAO- 03- 758T Mr. Chairman, this concludes my prepared statement.
I will be happy to respond to any questions that you or other Subcommittee
members may
have. For further contacts regarding this testimony, please call Cornelia
M. Ashby at 202- 512- 8403. Individuals making key contributions to this
testimony included Carolyn M. Taylor, Mark E. Ward, Sheila Nicholson,
Vernette Shaw, Joel Grossman, and James Rebbe. GAO Contact and
Acknowledgments
Page 20 GAO- 03- 758T 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. GAO
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