Child Welfare: Improved Federal Oversight Could Assist States in 
Overcoming Key Challenges (28-JAN-04, GAO-04-418T).		 
                                                                 
Title IV-B of the Social Security Act, comprised of two subparts,
is the primary source of federal funding for services to help	 
families address problems that lead to child abuse and neglect	 
and to prevent the unnecessary separation of children from their 
families; however, a number of challenges exist that impair	 
states' ability to deliver and track these services. This	 
testimony is based on findings from three reports issued in 2003 
and addresses the following: (1) states' use of Title IV-B funds 
in providing a wide array of services to prevent the occurrence  
of abuse, neglect, and unnecessary foster care placements, as	 
well as in providing other child welfare services; (2) factors	 
that hinder states' ability to protect children from abuse and	 
neglect; and (3) the Department of Health and Human Services'	 
(HHS) role in helping states to overcome these challenges.	 
Findings are based on multiple methodologies, including a survey 
to child welfare directors on states' use of Title IV-B funds; an
analysis of nearly 600 exit interview documents completed by	 
staff who severed their employment from 17 state, 40 county, and 
19 private child welfare agencies; and a survey of all 50 states 
and the District of Columbia regarding their experiences in	 
developing and using information systems and their ability to	 
report data to HHS. In each case, GAO also conducted multiple	 
site visits to selected states and interviewed child welfare	 
experts and HHS headquarters and regional officials.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-418T					        
    ACCNO:   A09174						        
  TITLE:     Child Welfare: Improved Federal Oversight Could Assist   
States in Overcoming Key Challenges				 
     DATE:   01/28/2004 
  SUBJECT:   Child abuse					 
	     Data collection					 
	     Data integrity					 
	     Federal aid programs				 
	     Federal funds					 
	     Federal/state relations				 
	     Foster children					 
	     Funds management					 
	     Information systems				 
	     Labor force					 
	     Strategic planning 				 
	     Child welfare					 
	     HHS Adoption and Foster Care Analysis		 
	     and Reporting System				 
                                                                 
	     NCCAN National Child Abuse and Neglect		 
	     Data System					 
                                                                 
	     Statewide Automated Child Welfare			 
	     Information System 				 
                                                                 

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GAO-04-418T

United States General Accounting Office

GAO Testimony

Before the Subcommittee on Human Resources, Committee on Ways and Means,
House of Representatives

For Release on Delivery Expected at 10:30 a.m. EST

Wednesday, January 28, 2004 CHILD WELFARE

  Improved Federal Oversight Could Assist States in Overcoming Key Challenges

Statement of Cornelia M. Ashby, Director Education, Workforce, and Income
Security Issues

GAO-04-418T

Highlights of GAO-04-418T, a testimony before the Subcommittee on Human
Resources, Committee on Ways and Means, House of Representatives

Title IV-B of the Social Security Act, comprised of two subparts, is the
primary source of federal funding for services to help families address
problems that lead to child abuse and neglect and to prevent the
unnecessary separation of children from their families; however, a number
of challenges exist that impair states' ability to deliver and track these
services. This testimony is based on findings from three reports issued in
2003 and addresses the following: (1) states' use of Title IV-B funds in
providing a wide array of services to prevent the occurrence of abuse,
neglect, and unnecessary foster care placements, as well as in providing
other child welfare services; (2) factors that hinder states' ability to
protect children from abuse and neglect; and (3) the Department of Health
and Human Services' (HHS) role in helping states to overcome these
challenges. Findings are based on multiple methodologies, including a
survey to child welfare directors on states' use of Title IV-B funds; an
analysis of nearly 600 exit interview documents completed by staff who
severed their employment from 17 state, 40 county, and 19 private child
welfare agencies; and a survey of all 50 states and the District of
Columbia regarding their experiences in developing and using information
systems and their ability to report data to HHS. In each case, GAO also
conducted multiple site visits to selected states and interviewed child
welfare experts and HHS headquarters and regional officials.

www.gao.gov/cgi-bin/getrpt?GAO-04-418T.

To view the full product, including the scope and methodology, click on
the link above. For more information, contact Cornelia M. Ashby at (202)
512-8403 or [email protected].

January 28, 2004

CHILD WELFARE

Improved Federal Oversight Could Assist States in Overcoming Key Challenges

States use of Title IV-B funds to provide a wide variety of services to
prevent the occurrence of abuse, neglect, and foster care placements, as
well as to provide other child welfare services. According to GAO's Title
IV-B survey data for fiscal year 2002, states spent about 60 percent of
subpart 1 funds on the salaries of child welfare agency staff,
administration and management expenses, and child protective services,
while about 10 percent were used to provide family support and family
preservation services. In comparison, states spent about 62 percent of
their subpart 2 funds on family support and preservation services.

Child welfare agencies face a number of challenges related to staffing and
data management that impair their ability to protect children from abuse
and neglect. Low salaries hinder agencies' ability to attract potential
child welfare workers and retain those already in the profession.
According to caseworkers GAO interviewed, high turnover rates and staffing
shortages leave remaining staff with insufficient time to establish
relationships with families and make the necessary decisions to ensure
safe and stable permanent placements. States also face challenges
developing appropriate information systems needed to track abuse or
neglect reports and monitor children in foster care. In addition, several
factors affect states' ability to collect and report reliable adoption,
foster care, and child abuse and neglect data, including insufficient
caseworker training, inaccurate and incomplete data entry, and technical
challenges reporting the data.

HHS plays a role in helping states overcome some of the challenges they
face in operating their child welfare programs, but additional oversight
or technical assistance could assist states in meeting the needs of
children served by child welfare agencies. HHS's oversight of Title IV-B
focuses primarily on states' overall child welfare systems and outcomes,
but the agency provides relatively little oversight specific to Title IV-B
subpart 1. In addition, HHS plays a limited role in states' workforce
activities by offering partial reimbursement for training expenses and
managing discretionary grant programs. The agency monitors states'
information systems development and data reporting, but despite the
availability of technical assistance, states reported ongoing challenges
reporting reliable data.

In the related reports, GAO made several recommendations to HHS. GAO
recommended that HHS provide the necessary guidance to ensure that
regional offices monitor states' use of Title IV-B subpart 1 and to
consider gathering additional information on its use. GAO also recommended
that HHS take actions that may help child welfare agencies address
recruitment and retention challenges. Last, GAO recommended that HHS
consider ways to enhance the guidance and assistance offered to help
states overcome key data challenges. HHS generally agreed with GAO's
findings and recommendations, except that it noted that its level of
oversight of Title IV-B was commensurate with the program's scope and
intent.

Mr. Chairman and Members of the Subcommittee:

Thank you for inviting me here today to discuss several issues related to
the oversight of child welfare programs across the nation. As you are
aware, state child welfare agencies determined that over 900,000 children
had been the victims of abuse or neglect by their parents or other
caretakers in 2001. Additionally, more than 800,000 children are estimated
to spend some time in foster care each year, with the federal government
allocating approximately $7 billion each year to investigate abuse and
neglect, provide placements to children outside their homes, and deliver
services to help keep families together. Title IV-B of the Social Security
Act, comprised of two subparts, is the primary source of federal funding
for services to help families address problems that lead to child abuse
and neglect and to prevent the unnecessary separation of children from
their families. Funding under Title IV-E of the Social Security Act is
used primarily to pay for the room and board of children in foster care.
Since 1994, designated federal matching funds have been available to
states to develop and implement comprehensive case management systems-
statewide automated child welfare information systems (SACWIS)-to manage
their child welfare cases as well as to report child abuse and neglect,
foster care, and adoption information to the federal government.

In addition to this funding, the Department of Health and Human Services'
(HHS) Administration for Children and Families (ACF) monitors states'
compliance with key federal goals, specified in part by the Adoption and
Safe Families Act (ASFA) of 1997, to keep children safe and ensure their
placement in stable and permanent homes. Through its formal review
process, known as the Child and Family Services Review (CFSR), HHS uses
specific assessment measures, such as agencies' ability to conduct timely
abuse and neglect investigations and regularly visit children in their
homes, to assess the performance of states' child welfare systems.

My testimony today will focus on three key issues: (1) states' use of
Title IV-B funds in providing a wide array of services to prevent the
occurrence of abuse, neglect, and foster care placements, as well as other
child welfare services; (2) factors that hinder states' ability to protect
children from abuse and neglect; and (3) HHS's role in helping states to
overcome the challenges they face in protecting children from abuse and
neglect. My

comments are based primarily on the findings from three reports:1 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.: March 31, 2003; Child Welfare: Most States Are
Developing Statewide Information Systems, but the Reliability of Child
Welfare Data Could Be Improved. GAO-03-809. Washington, D.C.: July 31,
2003; and Child Welfare: Enhanced Federal Oversight of Title IV-B Could
Provide States Additional Information to Improve Services. GAO-03-956.
Washington, D.C.: September 12, 2003. Those findings were based on
multiple methodologies, including a survey of child welfare directors on
states' use of Title IV-B funds; an analysis of 600 exit interview
documents completed by staff who severed their employment from 17 state,
40 county, and 19 private child welfare agencies; and a survey of all 50
states and the District of Columbia regarding their experiences in
developing and using information systems and their ability to report data
to HHS. In each case, we supplemented these surveys and analyses by
conducting multiple site visits to selected states and by interviewing
child welfare experts and HHS headquarters and regional officials.

In summary, we found that states use Title IV-B funds to provide a wide
variety of services to prevent the occurrence of abuse, neglect, and
foster care placements, as well as to provide other child welfare
services. Subpart 1 dollars were most frequently used to fund staff
salaries, with almost half of these funds designated for the salaries of
child protective services (CPS) 2 social workers. In comparison, states
spent half of their subpart 2 funds on family support or prevention
programs and another 12 percent on family preservation services. CFSR
results for the past 2 years, however, indicate that states have not
performed strongly in terms of assessing the services families need and
providing those services. Child welfare agencies face a number of issues
related to staffing and data management that impair their ability to
protect children from abuse and neglect. In particular, low salaries
hinder agencies' ability to attract potential child welfare workers and to
retain those already in the profession. Our analysis of CFSRs in 27 states
indicated that large

1We also recently testified on one of these reports. See U.S. General
Accounting Office, Child Welfare: States Face Challenges in Developing
Information Systems and Reporting Reliable Child Welfare Data.
GAO-04-267T. (Washington, D.C.: Nov. 19, 2003).

2Child protective services activities typically include reviewing reports
of alleged child abuse and neglect, investigating those that meet the
state's criteria as a potential incident of abuse or neglect to determine
if the alleged incident occurred, and, in some cases, referring families
to needed services and removing the child from the home, if necessary.

caseloads and worker turnover delay the timeliness of investigations and
limit the frequency of worker visits with children, hampering agencies'
attainment of some key federal safety and permanency outcomes.
Furthermore, states face challenges developing appropriate information
systems needed to track abuse or neglect reports and monitor children in
foster care, with many states reporting development delays. In addition,
several factors affect the states' ability to collect and report reliable
adoption, foster care, and child abuse and neglect data, including
insufficient caseworker training, inaccurate and incomplete data entry,
and technical challenges reporting the data. Although HHS plays a role in
monitoring child welfare programs, additional oversight or technical
assistance could assist states in meeting the needs of children served by
child welfare agencies. For example, HHS's oversight of Title IV-B focuses
primarily on states' overall child welfare systems and outcomes, but the
agency provides relatively little oversight specific to the services
provided under Title IV-B subpart 1.3 In addition, HHS plays a limited
role in states' workforce activities by offering partial reimbursement for
training expenses and managing discretionary grant programs. The agency
monitors SACWIS development and data reporting, but despite the
availability of technical assistance, states reported ongoing challenges
reporting reliable data.

Background 	ACF is responsible for the administration and oversight of
federal funding to states for child welfare services under Titles IV-B and
IV-E. HHS headquarters staff are responsible for developing appropriate
policies and procedures for states to follow in terms of obtaining and
using federal child welfare funds, while staff in HHS's 10 regional
offices and 10 national resource centers provide guidance and technical
assistance to improve child welfare services nationwide. HHS compiles
state-reported child welfare data in two databases: the Adoption and
Foster Care Analysis and Reporting System (AFCARS) and the National Child
Abuse and Neglect Data System (NCANDS). HHS relies on the information
available in its databases to analyze and track children's experiences in
the child welfare system, to determine states' performance on federal
child welfare outcome measures, and to report to Congress on children's
well being and child welfare experiences. However, the monitoring of
children served by state

3Our September 2003 report on Title IV-B focused primarily on subpart 1
because little, if any, research has been conducted on how subpart 1 funds
have been spent on child welfare services. In contrast, a number of
studies have been conducted on the services provided under subpart 2.

child welfare agencies is the responsibility of the state agencies that
provide the services to these children and their families. Child welfare
caseworkers at the county or local level are the key personnel responsible
for documenting the wide range of services offered to children and
families, such as investigations of abuse and neglect; treatment services
offered to families to keep them intact and prevent the need for foster
care; and arrangements made for permanent or adoptive placements when
children must be removed from their homes. Most states and counties
provide some child welfare services directly and provide others through
contracts with private agencies. National survey data confirm that both
state and private child welfare agencies are experiencing similar
challenges recruiting and retaining qualified caseworkers. For instance,
turnover of child welfare staff has been estimated at between 30 percent
and 40 percent annually nationwide, with the average tenure for child
welfare workers being less than 2 years.

In 2000, HHS established a new federal review system to monitor state
compliance with federal child welfare laws. One component of this system
is the CFSR, which assesses state performance in achieving safety and
permanency for children, along with well-being for children and families.
The CFSR process includes a self-assessment by the state, an analysis of
state performance in meeting national standards established by HHS, and an
on-site review by a joint team of federal and state officials. Based on
the results of this process, HHS determines whether a state achieved
substantial conformity with (1) outcomes related to safety, permanency,
and well-being, such as keeping children protected from abuse and neglect
and achieving permanent and stable living situations for children and (2)
key systemic factors, such as having an adequate case review system and an
adequate array of services. States are required to develop program
improvement plans to address all areas of nonconformity.

Federal Funding of Child Welfare Services and Programs

Two titles of the Social Security Act provide federal funding targeted
specifically to foster care and related child welfare services.4 Title
IV-E5 provides an open-ended individual entitlement for foster care
maintenance

4In addition, Title XX provides funds under the social services block
grant that may be used for many purposes, including child welfare.

5In fiscal year 2002, total Title IV-E spending was approximately $6.1
billion. The state matching rate for these payments is based on a state's
per capita income and ranges from 50 percent to 83 percent.

payments to cover a portion of the food, housing, and incidental expenses
for all foster children whose parents meet certain federal eligibility
criteria.6 Title IV-E also provides payments to adoptive parents of
eligible foster children with special needs.7 To qualify for federal IV-E
funding for SACWIS, states must prepare and submit an advance planning
document (APD) to ACF's Children's Bureau, in which they describe the
state's plan for managing the design, development, implementation, and
operation of a SACWIS that meets federal requirements and state needs in
an efficient, comprehensive, and cost-effective manner. Since the
administration and structure of state child welfare agencies vary across
the nation, states can design their SACWIS to meet their state needs, as
long as states meet certain federal requirements.

Title IV-B of the Social Security Act, established in 1935, authorizes
funds to states to provide a wide array of services to prevent the
occurrence of abuse, neglect, and foster care placements.8 In 1993, the
Congress created a new program as subpart 2 of Title IV-B (now known as
Promoting Safe and Stable Families), which funds similar types of services
but is more prescriptive in how states can spend the funds. 9 No federal
eligibility criteria apply to the children and families receiving services
funded by Title IV-B.

6States are entitled to Title IV-E reimbursement on behalf of children who
would have been eligible for Aid to Families with Dependent Children
(AFDC) (as AFDC existed on July 16, 1996), but for the fact that they were
removed from the home of certain specified relatives. While the AFDC
program was replaced by the Temporary Assistance for Needy Families
Program in 1996, eligibility for Title IV-E payments remains tied to the
income eligibility requirements of the now defunct AFDC program. In
addition, certain judicial findings must be present, and all other
requirements included in section 472 (a) and (b) of the Social Security
Act must be met, in order for the child to be eligible for Title IV-E
foster care maintenance payments.

7Special needs are characteristics that can make it difficult for a child
to be adopted and may include emotional, physical, or mental disabilities,
emotional disturbance, age, or being a member of a minority race. To
qualify for an adoption subsidy under Title IV-E, a state must determine
that the child cannot or should not return home; a state must make a
reasonable, but unsuccessful effort to place the child without the
subsidy; and a specific factor or condition must exist that makes it
difficult to place the child without a subsidy.

8In fiscal year 2003, the Congress appropriated $292 million for subpart 1
and $405 million for subpart 2. These federal funds cover 75 percent of
states' total Title IV-B expenditures because states must provide an
additional 25 percent using nonfederal dollars.

9States must spend a "significant portion" of their subpart 2 funds on
each of the four service categories. HHS program instructions require
states to spend at least 20 percent of their subpart 2 funds on each of
the four service categories, unless a state has a strong rationale for
some other spending pattern.

Title IV-B subpart 1 provides grants to states for child welfare services,
which are broadly defined. Subpart 1 funds are intended for services that
are directed toward the accomplishment of the following purposes: (1)
protect and promote the welfare of all children; (2) prevent or remedy
problems that may result in the abuse or neglect of children; (3) prevent
the unnecessary separation of children from their families by helping
families address problems that can lead to out-of-home placements; (4)
reunite children with their families; (5) place children in appropriate
adoptive homes when reunification is not possible; and (6) ensure adequate
care to children away from their homes in cases in which the child cannot
be returned home or cannot be placed for adoption.

In 1980, the Congress enacted legislation that limited the total subpart 1
funds states could use for three categories of services: foster care
maintenance payments, adoption assistance payments, and child care related
to a parent's employment or training.10 The total of subpart 1 funds used
for these purposes cannot exceed a state's total 1979 subpart 1
expenditures for all types of services. The intent of this restriction,
according to a congressional document, was to encourage states to devote
increases in subpart 1 funding as much as possible to supportive services
that could prevent the need for out-of-home placements.11 However, this
restriction applies only to the federal portion of subpart 1 expenditures,
as the law notes that states may use any or all of their state matching
funds for foster care maintenance payments.

Subpart 2 authorizes grants to states to provide four categories of
services, which are defined below:

o  	Family preservation services: Services designed to help families at
risk or in crisis, including services to (1) help reunify children with
their families when safe and appropriate; (2) place children in permanent
homes through adoption, guardianship, or some other permanent living
arrangement; (3) help children at risk of foster care placement remain
safely with their families; (4) provide follow-up assistance to families

10For our September 2003 report on Title IV-B and in this testimony, we
mention only foster care maintenance and adoption assistance payments when
referring to subpart 1 limits, although we did include planned spending on
child care in our analyses of states' planned subpart 1 spending.

11Staff of the House Committee on Ways and Means, 106th Congress,
Background Material and Data on Programs Within the Jurisdiction of the
Committee on Ways and Means (Comm. Print 2000).

when a child has been returned after a foster care placement; (5) provide
temporary respite care; and (6) improve parenting skills.

o  	Family support services: Community-based services to promote the
safety and well-being of children and families designed to increase the
strength and stability of families, to increase parental competence, to
provide children a safe and supportive family environment, to strengthen
parental relationships, and to enhance child development. Examples of such
services include parenting skills training and home visiting programs for
first time parents of newborns.

o  	Time-limited family reunification services: Services provided to a
child placed in foster care and to the parents of the child in order to
facilitate the safe reunification of the child within 15 months of
placement. These services include: counseling, substance abuse treatment
services, mental health services, and assistance to address domestic
violence.

o  Adoption promotion and support services: Services designed to encourage

  States Spend IV-B Funds on A Variety of Services, With Subpart 2 Focusing More
  on Prevention

more adoptions of children in foster care when adoption is in the best
interest of the child, including services to expedite the adoption process
and support adoptive families.

In our September 2003 report on Title IV-B, we found that states use these
funds to provide a wide variety of services to prevent the occurrence of
abuse, neglect, and foster care placements, as well as services to help
children in foster care and their parents; however, relatively few subpart
1 dollars are used to provide family support and family preservation
services, while the majority of subpart 2 funds are used for these
purposes. According to our survey data for fiscal year 2002,12 states
spent subpart 1 funds most frequently on the salaries of child welfare
agency staff, administration and management expenses, CPS services, and
foster care maintenance payments. In comparison, states spent half of
their subpart 2 funds on family support or prevention programs and another
12 percent on family preservation services. CFSR results for the past 2
years, however, indicate that states have not performed strongly in terms
of assessing the services families need and providing those services.

12To obtain a breakdown of state spending for subparts 1 and 2 for the
Title IV-B report, we sent a survey to all 50 states and the District of
Columbia and received responses from 47 states.

States Use Subpart 1 Funds Primarily for Staff Salaries

Relatively few subpart 1 dollars were used for family support or family
preservation services; instead, they were most frequently used to fund
staff salaries, with almost half of these funds designated for the
salaries of CPS social workers. Another 20 percent of these funds were
used for the salaries of other social workers.13 During a site visit to
the state of Washington for the Title IV-B report,14 child welfare
officials told us that they used over 50 percent of the state's subpart 1
funds for salaries of staff providing direct services, including CPS
social workers, other types of social workers, social work supervisors,
and clerical support staff. Administration and management comprised the
second largest category of service, accounting for almost 17 percent of
subpart 1 dollars. This category included rent and utilities for office
space, travel expenses for agency staff, and staff training.15

CPS represents the third largest category of services that states funded
with subpart 1. States used about 16 percent of their subpart 1 funds to
provide a variety of CPS services, such as telephone hotlines for the
public to report instances of child abuse and neglect, emergency shelters
for children who needed to be removed from their homes, and investigative
services. During our site visit to California, for example, officials
reported using about 40 percent of their subpart 1 dollars to fund staff
salaries and operating expenses associated with a variety of shelter care
services provided by counties, such as emergency shelters and foster
homes. A child is placed in one of these shelters when no other placement
option is immediately available-for example, when an investigation in the
middle of the night determines that the child is at immediate risk of
harm. States also used nearly 11 percent of their subpart 1 funds to make
recurring payments for the room and board of foster children who are not
eligible

13The survey data reported in this category reflect the salaries of staff
affiliated with the child welfare agency. These figures do not include the
salaries of child welfare agency staff dedicated to a specific program,
which may be embedded within some of the other direct service categories,
such as family support and family preservation. In addition, a state may
use Title IV-B funds to contract with an organization to provide a
particular program, which may include salary expenses as well as direct
service expenditures.

14For the Title IV-B report, we conducted site visits in California, New
Jersey, Ohio, and Washington to obtain more in-depth information on the
services provided and the types of children and families served. These
states represent both geographic diversity and diversity in how states
used subpart 1 funds.

15This amount may be underestimated, since some states may not have
separately reported administrative expenses associated with a specific
program. For example, officials in one state reported that the total
spending for a family support program included salaries for agency staff,
overhead expenses, and related staff travel.

for reimbursement through Title IV-E. About 10 percent of subpart 1
dollars were used to provide family support and family preservation
services.

Subpart 2 Most Frequently Funds Family Support and Family Preservation
Services

In contrast to subpart 1, states used over 80 percent of their subpart 2
dollars to fund services in its four mandated service categories-family
support, family preservation, family reunification, and adoption promotion
and support services (see app. I for additional information on states'
comparative expenditures on subparts 1 and 2). For example, states
reported using half of their subpart 2 dollars to fund family support and
prevention services. These services included mentoring programs to help
pregnant adolescents learn to be self-sufficient; financial assistance to
lowincome families to help with rent and utility payments; and parenting
classes, child care, and support groups provided by a community-based
resource center. Washington funded a network of public health nurses and
social service agencies to provide support services to families that are
the subject of a report of abuse or neglect-these services are provided in
lieu of, or following, a formal investigation when the level of risk to
the child is not considered high.

Family preservation services-designed to keep families together and
prevent the need to place a child in foster care-represented the second
largest service category funded by subpart 2. Washington used subpart 2
funds for its statewide family preservation program, which offers
counseling and parent training services for up to 6 months to families
with children who are at risk of being placed in foster care.

In addition, states reported using about 11 percent of their subpart 2
funds for adoption support and preservation services. With these funds,
states provided services such as counseling for children who are going to
be adopted, family preservation services to adoptive families, and respite
care16 for adoptive families. Officials in Ohio reported using almost half
of its subpart 2 dollars for adoption services, including post adoption
services and services to recruit families for children in need of adoptive
homes.

16Respite care refers to the temporary care of children that can provide a
break for the families from the daily demands of caring for their children
or respite during times of emergencies.

Finally, states spent about 9 percent of their subpart 2 dollars on family
reunification services. States funded a diverse array of family
reunification programs, such as supervised visitation centers for parents
to visit with their children and coordinators for alcohol and drug
treatment services for families whose primary barrier to reunification is
substance abuse. New Jersey funded a supervised visitation program that
offers parenting education, counseling, transportation, and support groups
and is located in a private home, allowing families to visit together in a
homelike setting and engage in more natural interactions.

CFSRs Find States Are Weak in Assessing Families' Service Needs

  Staff and Data Issues Affect States' Ability to Protect Children From Abuse
  and Neglect

While states are using Title IV-B funds to provide this array of services,
CFSR results for the past 2 years indicate that states have not performed
strongly in terms of assessing the services families need and providing
those services. When HHS reviewed case files it determined that 31of the
32 states that underwent a CFSR in 2001 or 2002 needed improvement in
terms of assessing family needs and providing services to meet those
needs. While 21 of the 32 states were considered to have an appropriate
array of services for families, HHS found that the accessibility of
services was a particular weakness in that many services were either not
available statewide or had long waiting lists or other barriers to
accessibility.

Child welfare agencies face a number of issues related to staffing and
data management that impair their ability to protect children from abuse
and neglect. In particular, low salaries hinder agencies' ability to
attract potential child welfare workers and to retain those already in the
profession. Additionally, caseworkers in the four states we visited for
the March 2003 child welfare workforce report17 cited high caseloads and a
lack of supervisory support as issues impacting their ability to work
effectively. According to these caseworkers, high turnover rates and
staffing shortages leave remaining staff with insufficient time to
establish relationships with children and families and make the necessary
decisions to ensure safe and stable permanent placements. Furthermore, our
July 2003 report found that states face challenges developing appropriate
information systems needed to track abuse or neglect reports and monitor

17For this report, we conducted site visits in California, Illinois,
Kentucky, and Texas to obtain more in-depth information on workforce
issues and their effect on children's safety and permanency outcomes.
Among other factors, these states represent geographic diversity and
diversity in the practices they have implemented to address their
recruitment and retention challenges.

children in foster care. While 47 states are developing or operating a
SACWIS, many states18 reported that the development of their SACWIS is
delayed. Most states responding to our survey faced challenges to SACWIS
development, such as obtaining state funding and developing a system that
met the child welfare agency's needs statewide. In addition, several
factors affect states' ability to collect and report reliable adoption,
foster care, and child abuse and neglect data, including insufficient
caseworker training, inaccurate and incomplete data entry, and technical
challenges reporting the data.

Recruitment and Retention Challenges May Hamper Agencies' Attainment of
Federal Child Welfare Outcomes

In our report on the child welfare workforce, we found that public and
private child welfare agencies face a number of challenges recruiting and
retaining qualified caseworkers and supervisors. Low salaries, in
particular, hinder agencies' ability to attract potential staff and to
retain those already in the profession. For example, caseworkers in each
of the four states we visited said that many of their former child welfare
colleagues pursued positions in the education field where they could not
only make more money but also work with children without risking their own
safety. For example, the Bureau of Labor Statistics' national wages
survey19 reports that elementary and middle school teachers earn, on
average, about $42,000 annually while social workers earn about $33,000.20

Additionally, high caseloads, administrative burdens, limited supervision,
and insufficient training reduce the appeal of child welfare work.
Caseworkers and supervisors in all four states we visited cited demanding

18These reports were obtained through both site visit interviews and
survey responses. For the child welfare information systems and data
report, we conducted site visits in Colorado, Iowa, New York, North
Carolina, and Oklahoma to obtain more in-depth information on states'
experiences developing SACWIS and reporting data to HHS. These states
represent both geographic diversity and different stages of SACWIS
implementation. In addition, we surveyed all 50 states and the District of
Columbia regarding their experiences in developing and using information
systems and their ability to report data to HHS. We received responses
from 49 states and the District of Columbia, although some states did not
respond to every question. Forty-six of these states reported that they
are developing or operating a SACWIS. Nevada, which HHS reported has an
operational SACWIS, did not respond to our survey. Throughout this
testimony, references to state survey responses for our July 2003 report
include the District of Columbia.

19U.S. Department of Labor, Bureau of Labor Statistics, 2000 National
Occupational Employment and Wage Estimates.

20This amount is specific to child, family, and school social workers (the
occupation under which caseworkers would likely be classified).

and complex caseloads and related administrative requirements, such as
casework documentation, as factors affecting retention. Some of the
caseworkers we interviewed handled double the number of cases recommended
by advocacy organizations,21 and one study found that caseloads for
individual child welfare workers ranged from 10 to 110 children,22 with
workers handling an average of about 24 to 31 children each. Furthermore,
some of the caseworkers we interviewed told us that they spent between 50
and 80 percent of their time completing paperwork, thereby limiting their
time to assist children and families.

Caseworkers told us that their desire to stay in the child welfare
profession was influenced by high-quality supervision and adequate
onthe-job training; however, these elements were often lacking. According
to supervisors in one city we visited, about half of new trainees left
their jobs before completing 1 year, in part, because these newly hired
caseworkers were not sufficiently trained to do their jobs. Furthermore,
some newly promoted supervisors have requested demotions because they felt
unprepared to meet job demands, and the caseworkers they supervised
complained of poor management and insufficient support.

There is some evidence to suggest how recruitment and retention challenges
affect the safety and permanency of children in care, but the magnitude of
this effect is unknown. Caseworkers in the four states that we visited
said that high turnover rates and staffing shortages leave remaining staff
with insufficient time to conduct the types of home visits necessary to
assess children's safety and to make well-supported decisions to ensure
safe and stable permanent placements. For example, when staff change,
caseworkers may have to reestablish information to update the case record
and families may become hesitant to work with unfamiliar caseworkers,
making it difficult to learn the history of the case. Worker turnover also
disrupts the continuity of services, particularly when newly assigned
caseworkers have to conduct or reevaluate educational, health, and safety
assessments due to poor or insufficient information in case files left
behind by others. Furthermore, caseworkers explained that high caseloads
require them to limit the number and quality of the home visits

21The Child Welfare League of America suggests a caseload ratio of 12 to
15 children per caseworker, and the Council on Accreditation for Children
and Family Services suggests that caseloads not exceed 18 children per
caseworker.

22American Public Human Services Association, Report from the Child
Welfare Workforce Survey: State and County Data and Findings, May 2001.

they conduct, forcing them to focus only on the most serious circumstances
of abuse and neglect. One caseworker in Texas noted that when she does
make a home visit, the visit is quick and does not enable her to identify
subtle or potential risks to the child's well-being.

Our analysis of federal CFSRs corroborated caseworker accounts,23 showing
that large caseloads and worker turnover delay the timeliness of
investigations and limit the frequency of worker visits with children,
thereby hampering agencies' attainment of some key federal safety and
permanency goals. Although identifying workforce deficiencies is not an
objective of the CFSR process, in all 27 CFSRs we analyzed, HHS explicitly
cited workforce deficiencies-high caseloads, training deficiencies, and
staffing shortages-that affected the attainment of at least one assessment
measure. While the number of affected assessment measures varied by state,
we found that HHS cited these factors for an average of nine assessment
measures per state, with more than half of the 27 states exceeding this
average. For example, in New Mexico's CFSR, reviewers cited staff turnover
and vacancies as impairing workers' ability to investigate child
maltreatment reports, provide appropriate services for families, and
establish timely permanency goals. Furthermore, the District of Columbia's
CFSR describes heavy workloads, high staff turnover, and a climate in
which supervisors often call new workers out of training to handle ongoing
caseload activities.

Delays in SACWIS Completion and Challenges with Data Collection Affect
States' Ability to Ensure Reliable Data on Children's Experiences

In addition to performing a wide range of services to protect children,
child welfare caseworkers are the key personnel who collect and document
information on children and families served by children welfare agencies.
Case file documentation is generally captured in state computer systems.
In our July 2003 report, HHS reported that 47 states are using targeted
federal funds to develop or operate their child welfare computer
systems-known as SACWIS-but many continue to face challenges completing
their systems. In our November 2003 testimony on SACWIS,24 we reported on
the costs associated with developing SACWIS and the associated barriers,
such as development delays and difficulties in

23At the time of the original study, CFSR final reports were available for
only 27 states; as of January 28, 2004, HHS had released reports for an
additional 14 states.

24See U.S. General Accounting Office, Child Welfare: States Face
Challenges in Developing Information Systems and Reporting Reliable Child
Welfare Data, GAO-04-267T (Washington, D.C.: Nov. 19, 2003).

receiving state funding approval, creating a system that reflects child
welfare work processes, and securing contractors knowledgeable about child
welfare. Many state officials said that they recognize the benefit their
state will achieve by developing SACWIS, such as contributing to the
timeliness of child abuse and neglect investigations. In Oklahoma, for
example, caseworkers and state officials noted that they believe their
children are safer since the implementation of SACWIS simply because the
information on the children is easily accessible to the caseworkers and
their supervisors. According to our survey results, automated systems
provided easier access to data and allowed caseworkers to better monitor
children in their care, which may contribute to additional child welfare
and administrative benefits, such as decreased incidences of child abuse
and neglect, shortened length of time to achieve adoption, timeliness of
payments to foster families, and timeliness of payments to foster
facilities.

Some of the data captured in case file records are reported to two HHS
databases that compile child welfare data-AFCARS and NCANDS. We found that
several factors affect states' ability to collect and report reliable data
to HHS on children served by state child welfare agencies. Almost all of
the states responding to our survey25 reported that insufficient
caseworker training and inaccurate and incomplete data entry into their
information system affect the quality of AFCARS and NCANDS data. Although
most states reported these as separate factors, HHS and the states we
visited found that insufficient training and inaccurate and incomplete
data entry are often linked. Caseworkers, supervisors, and managers in the
five states that we visited reported that additional factors, such as
difficulties balancing data entry with the time that they spend with the
families and children, contributed to inaccurate or incomplete data entry.
Supervisors in Iowa explained that since caseworkers are responsible for
ensuring that children and their families receive the services they need,
the caseworkers tend to initially limit data entry to the information that
is necessary to ensure timely payment to foster care providers, and
complete all other data elements when the caseworkers have time. In
addition, caseworkers in Colorado said that they are between 30 and 60
days behind in their data entry, so the information in the automated
system may not accurately reflect the current circumstances of children in
care.

25The analysis of survey responses about reporting data to HHS is based on
responses from 49 states and the District of Columbia. All states,
regardless of SACWIS development, were asked to complete these questions.

  Improvements in HHS'S Oversight of Child Welfare Programs Could Help States
  Overcome Some Challenges

We also reported in our July 2003 report and November 2003 testimony that
many states experienced technical challenges reporting their data to HHS.
The problems reported by states are typically a result of challenges
associated with data "mapping"-matching state data elements to the federal
data elements. For example, 36 states reported in our survey that matching
their state-defined data to HHS's definitions affected the quality of the
data reported to NCANDS and AFCARS. In addition to the challenges reported
in our survey, HHS reported that transferring data from older data systems
into SACWIS affects the quality of the data reported to AFCARS and NCANDS.

HHS plays a role in helping states implement their child welfare programs,
but in some cases, additional federal oversight or technical assistance
could help states provide more effective services. In terms of child
welfare funding, HHS focuses its programmatic oversight on the overall
child welfare system in each state and provides relatively little
oversight specific to Title IV-B subpart 1. HHS's role in assisting states
overcome the child welfare workforce challenges is limited to partial
federal reimbursement for training expenses and management of
discretionary grant programs, such as the Child Welfare Training Program.
HHS also monitors SACWIS development and data reporting and provides
assistance to states to address some of the associated challenges;
however, states reported ongoing challenges, such as the lack of clear and
documented guidance on how to report child welfare data, despite the
availability of this assistance.

HHS Focuses Oversight on the Overall Child Welfare System, but Has Limited
Knowledge about States' Use of Subpart 1 Funds

HHS focuses much of its programmatic oversight on the overall child
welfare system in each state, rather than focusing specifically on subpart
1 or any other federal funding source. A major component of HHS's subpart
1 oversight is having the regional offices actively work with states to
develop appropriate goals for their child welfare systems and ensure that
available funds are used to support those goals. To receive Title IV-B
funding, HHS requires states to submit a Child and Family Services Plan,
which covers a 5-year period and describes the state's goals and
objectives toward improving outcomes related to the safety, permanency,
and wellbeing of children and families, as well as the services and
programs the state will pursue to achieve these goals. In addition to the
5-year plan, HHS requires states to submit an update each year to discuss
their progress in meeting the goals outlined in their plans. Some regional
officials noted that states are still struggling to use these documents
appropriately for planning purposes and frequently just describe their
current programs,

rather than focusing on outcomes and collecting data to measure progress
toward those outcomes.

The CFSR process is an additional tool HHS uses to ensure that states
conform to federal child welfare requirements and to help states improve
their child welfare services. Staff at one regional office described the
CFSR as a thorough review of the services funded by different federal
programs, such as Title IV-B, providing an opportunity to determine
whether states are providing the services they report in their planning
documents and whether those services are adequate and appropriate to meet
the needs of the state's children and families. When asked about HHS's
role in guiding states' use of subpart 1 funds to address weaknesses
identified by the CFSRs, an HHS official told us that the agency provides
technical assistance to states to help them determine the most effective
use of their resources, while giving states much latitude to determine the
most appropriate use of their subpart 1 funds.

HHS does not require states to provide any data about their use of subpart
1 funds, such as their subpart 1 expenditures for specific services.26 As
a result, several regional offices noted that they have no way of knowing
how states actually spend their subpart 1 funds. Instead, HHS requires
states to submit annual estimates of the amount of subpart 1, subpart 2,
and other federal funds the state plans to spend in the upcoming year on
different categories of services (such as family support or CPS). However,
these estimates may not provide reliable data as to how states are using
subpart 1 funds. HHS officials explained that states' actual expenditures
may vary from these estimates, as they address unforeseen circumstances.

26States are required to submit general reports on their total subpart 1
expenditures, but these provide no data on how the funds are actually
used. Per instructions from the Office of Management and Budget, agencies
must require states receiving federal grants to complete a financial
status report (SF 269), providing general information on state
expenditures. For example, the form might indicate that a state spent $10
million in subpart 1 funds in a specific fiscal quarter, but it provides
no details on how the $10 million was used.

In addition, HHS requires states to submit their estimates before the
final spending amounts have been appropriated.27

The descriptions provided by regional office staff of their review of
these estimates indicate that they review them for relatively limited
purposes. As a result, most HHS regional offices do not review the annual
estimates for compliance with the statutory limits. In addition, HHS's
annual program instruction, which details what information states must
include in their estimates and serves as the basis for the regional
offices' review of subpart 1 spending, does not mention the subpart 1
limits. Five regional offices were unaware that any limits on the use of
subpart 1 funds existed. Four other regional offices were aware of the
limits, but did not ensure that states complied with the limits.

This lack of review led HHS to approve spending plans for 15 states that
reported fiscal year 2002 planned subpart 1 expenditures for foster care
maintenance and adoption assistance payments that exceeded the statutory
limits.28 The dollar amounts by which the subpart 1 spending estimates
surpassed the limits were small in some cases, but large in others. For
example, Georgia reported that it planned to spend $1,497,000 of subpart 1
funds for these purposes in 2002, which would exceed its statutory limit
by $1,558. At the other extreme, Florida's estimate indicated that it
planned to spend over $9 million, which was more than $7 million over the
maximum allowable spending of $1.9 million. In total, these 15 states
submitted planned subpart 1 spending estimates for foster care maintenance
and adoption assistance payments that would exceed the statutory limits by
over $30 million.

27HHS requires states to submit their annual estimates for the upcoming
fiscal year on a form CFS-101. For example, for fiscal year 2002, the
CFS-101 was due by June 30, 2001. Because they are submitted before final
appropriations have been enacted, a state might not request the full
amount of funds to which it is entitled, if the final appropriation is
greater than the state's initial estimate. States must submit a revised
CFS-101 by June 30, 2002, to request any additional fiscal year 2002 Title
IV-B funds that might be available to them once appropriations are
finalized. In addition, states can request additional Title IV-B funds if
other states do not use the total funds to which they are entitled.

28In most cases, we reviewed the final revised CFS-101 approved by HHS.
For 1 state, however, we used the initial CFS-101 approved by HHS because
it included planned subpart 1 expenditures that exceeded the limits for
foster care and adoption assistance payments. Although the revised CFS-101
did not show that the state planned to exceed the limit, we used the
initial CFS-101 to show that HHS had previously approved a spending plan
that did not comply with the statutory limits.

Several regional offices said that they are not concerned about a state
planning to spend significant proportions of its subpart 1 funds on foster
care maintenance and adoption assistance payments if they believed the
state had a strong child welfare system with an appropriate array of
services. Regional office staff said that they would, however, ask a state
to reconsider its funding strategy if the state were performing poorly.
However, many of the states with approved subpart 1 estimates above the
statutory ceilings did not achieve strong outcomes on their CFSR
evaluations with regard to providing needed services and having an
appropriate array of services. HHS has conducted CFSRs on 13 of the 15
states with approved annual estimates over the subpart 1 spending limits
and determined that appropriately assessing family needs and providing
services to address those needs was an area needing improvement in 12 of
the 13 states. In addition, 7 of the 13 states were also determined to
need improvement in terms of having an appropriate array of services to
meet the needs of families in the state.29

In discussing the current structure of Title IV-B, officials in all of
HHS's regional offices told us that they believe states need some
flexibility to use Title IV-B funds to address state-specific child
welfare needs as is currently the case under subpart 1. At the same time,
officials in 8 of HHS's 10 regional offices also stressed the importance
of subpart 2 to ensure that states use some funds on family support
services and prevention activities to help preserve families and keep
children from entering foster care. Several regional offices expressed
concern that, in the absence of the minimum spending requirements outlined
in subpart 2, states would neglect preventive services, while using Title
IV-B funds for more urgent services, such as CPS or foster care. State and
local child welfare officials in one state we visited, along with
officials at 2 HHS regional offices, said that states need more federal
funds to provide services to prevent foster care placements, such as an
increase in funds available under Title IV-B or more flexibility to use
Title IV-E funds to provide services. HHS is currently developing a
legislative proposal to give states more flexibility in using Title IV-E
foster care funds for such preventive services.30

29Ten of the 13 states were also cited as needing improvement in ensuring
that needed services are accessible to families in all areas of the state
and 9 of the 13 states were categorized as needing improvement in terms of
individualizing services to meet the unique needs of individual families.

30Under this new proposal, states could voluntarily choose to receive a
fixed IV-E foster care allocation, which could be used for any services
provided under Titles IV-B and IV-E.

HHS's Involvement with States' Child Welfare Workforce Is Limited

HHS's primary connection to the child welfare workforce has been through
partial federal reimbursement-75 percent-of states' training funds to
implement educational programs for current child welfare staff and to
enhance the child welfare curriculum of undergraduate and graduate social
work programs to better educate and prepare potential caseworkers.31 This
funding may also be used for curriculum development, materials and books,
support for current workers to obtain a social work degree, and incentives
to induce entry to the child welfare field. During fiscal year 2002, 49
states received $286 million in title IV-E training reimbursements.32
These reimbursements ranged from a low of approximately $10,400 in Alaska
to a high of more than $79 million in California, with the median
reimbursement approximating $2.7 million.

In addition, ACF's Children's Bureau manages six discretionary grant
programs through which it funds various activities related to improvements
in the child welfare system. One of these programs-the Child Welfare
Training Program, authorized by Section 426 of Title IV of the Social
Security Act-awards grants to public and private nonprofit institutions of
higher learning to develop and improve the education, training, and
resources available for child welfare service providers.33 This is the
only program of the six with a specific emphasis on staff training;34
however, in fiscal year 2003, it received the second smallest share-8
percent-of the Children's Bureau's total discretionary funds.

According to HHS officials, HHS has no authority to require states to
address caseload issues in their CFSR-related program improvement plans or
to enforce any caseload standards. Furthermore, HHS officials said that
states have made few requests of HHS's national resource centers for
assistance with child welfare staff recruitment and retention. Although

31As authorized under Title IV-E of the Social Security Act, the federal
government reimburses 75 percent of states' training expenditures related
to foster care and adoption services. States providing training for
contracted private agency staff can receive 50 percent federal
reimbursement for this purpose.

32Fiscal year 2002 data are the most recent data available at the time of
this testimony. The District of Columbia, Massachusetts, and Puerto Rico
have not participated in title IV-E reimbursements for the last three
fiscal years.

33In fiscal year 2003, among other child welfare training project
activities, HHS awarded grants to eight recipients for developing models
of effective child welfare staff recruitment and retention training.

34Although the other discretionary grant programs fund initiatives that
can involve caseworker training, caseworker training and development is
not their primary focus.

HHS officials told us that they plan to examine the CFSRs to better
understand the relationship between recruitment and retention and safety
and permanency outcomes across the states, the agency is still conducting
these reviews and is not expected to complete them until March 2004.

HHS Offers Assistance to Help States Develop SACWIS and Improve Their
Data, but States Report Ongoing Challenges with Some of HHS's Efforts

In response to some of the challenges states face in developing SACWIS and
collecting and reporting child welfare data, HHS has conducted on-site
reviews of information systems and provided technical assistance from a
variety of sources. For example, at the time of our review, HHS had
conducted on-site reviews in 26 states with operational SACWIS to ensure
that the systems met all federal requirements and to offer assistance to
states that faced challenges completing the development of their SACWIS.
Few systems have been determined complete after an on-site review because
of unresolved issues, such as not being able to build links to other state
information systems or not implementing certain eligibility determination
functions. To help states address some of these development challenges,
the SACWIS review team provides the state with recommendations for
complying with SACWIS requirements and schedules a conference call with
the state officials to walk through the system's deficiencies and offer
guidance on how the state can move forward. In addition, in an attempt to
help states comply with the reporting standards and address some of the
factors that contribute to data quality problems, HHS performs
comprehensive reviews of state information systems' ability to capture
AFCARS data to identify problems associated with data collection and
reporting and to ensure that the information in the automated system
correctly reflects children's experiences in care.

Other technical assistance is available to states in a variety of formats.
HHS facilitates the sharing of information between states developing
SACWIS through an automated system users' group that allows state and
federal officials to exchange information, ideas, and concerns. In
addition to the users' group, HHS officials sponsor a Listserv-an
electronic mailing list-that allows state officials to exchange
information, a monthly conference call with state information technology
directors,35 an annual technical assistance meeting, and an NCANDS state
advisory group. The

35In commenting on a draft of the July 2003 report, HHS indicated that a
Web resource is available to states interested in learning about other
states' efforts to develop human services-child welfare, food stamps,
Temporary Assistance to Needy Families, child care, and child support
enforcement-information systems at http://www.acf.hhs.gov/nhsitrc.

National Resource Center for Information Technology in Child Welfare,
which opened in 1999, also provides assistance to states on SACWIS
development and data issues.

HHS has also made available to states the software it uses to examine
states' AFCARS and NCANDS submissions for inconsistencies and invalid
data. Officials in all the states that we visited said that they regularly
use this software, and an HHS official said that nearly every state has
used the software at least once. HHS officials reported that these tests
help them to identify some data quality errors, such as missing data, and
said that they believe that, in general, data have improved in recent
years. However, the officials indicated that the tests cannot pinpoint the
underlying problems contributing to these errors. Furthermore, one
official reported that no specific efforts have been conducted to track
the individual data elements and, therefore, HHS cannot report on how data
quality has changed over time.

Although the states we visited appreciated some of HHS's efforts to assist
with improving state data quality, they and most states responding to our
survey agreed that the assistance is not always consistent or easily
accessible. The primary concerns reported by the states we visited were
delays in receiving clear written guidance on defining and reporting
certain data elements and the lack of state input in suggesting changes to
AFCARS. Despite the written guidance available to states in the form of
regulations and an online policy manual, states reported that the
variation in state policies and practices makes it difficult to interpret
how to apply the general guidance. As a result, states consult with HHS to
ensure they are applying the regulations appropriately. However, in
commenting on a draft of the July 2003 report, officials in Oklahoma told
us that a common concern among the states is the lack of timely response
from HHS when seeking guidance on how to report data. In commenting on a
draft of the same report, HHS explained that it first refers states to its
Web site for information and believes that the available guidance
addresses states' concerns in most instances. In addition, the states that
have had an AFCARS review experienced delays in obtaining guidance on how
to proceed following the on-site review. An HHS official told us that
since the review process is relatively new, the agency is still developing
a process to respond to the states and recognizes that it has not been
responsive to the states already reviewed. In addition, HHS is taking
steps to gather feedback from states and other users of AFCARS data to
determine how to improve the system to make the data more accurate and
usable. As a part of these efforts, HHS has published a Federal Register
notice soliciting comments and held focus group meetings at national
conferences. The

difficulties states face in receiving federal guidance and assistance, as
well as the other challenges they face in reporting data, may negatively
affect the reliability of the data available in AFCARS and NCANDS.

Concluding Observations

Despite its relatively small funding level compared to other funding
sources for child welfare services, Title IV-B represents an important
federal commitment to states' efforts to protect children from abuse and
neglect. However, HHS does not provide in-depth oversight specific to
Title IV-B subpart 1. Two key issues further compound states' ability to
prevent abuse and neglect. For example, given the difficulties that public
and private child welfare agencies are experiencing in hiring, training,
and retaining their workforces, these agencies' ability to provide
services to children is threatened. In addition, states face challenges in
completing their SACWIS systems and in ensuring that caseworkers input
complete and accurate case data in a timely manner.

We recommended in our September 2003 report on Title IV-B that the
Secretary of HHS provide the necessary guidance to ensure that HHS
regional offices monitor states' use of Title IV-B subpart 1 funds for
compliance with statutory restrictions on the use of these funds. We also
recommended that the Secretary consider the feasibility of collecting
basic data on states' use of these funds to facilitate its oversight of
the program and to provide guidance to help states determine appropriate
services to fund. In commenting on a draft of that report, HHS agreed with
our first recommendation but noted that the statutory limitations on Title
IV-B funds no longer serve a useful purpose and are incompatible with its
current proposal to offer states much more flexibility in using other
federal child welfare dollars. HHS disagreed with our second
recommendation, stating that it believes that its level of oversight is
commensurate with the scope and intent of the program and minimizes
states' reporting requirements.

We recommended in our March 2003 report on child welfare worker
recruitment and retention that, because of the reported impact staffing
shortages and high caseloads have on the attainment of federal outcome
measures, that the Secretary of HHS take actions that may help child
welfare agencies address the recruitment and retention challenges they
face. In commenting on a draft of that report, HHS generally agreed with
our findings and concurred with our recommendation, saying that it has
begun to explore the effectiveness of child welfare training programs,
with an emphasis on lessons learned and best practices. However, HHS
stressed that it has no authority to require states to address caseload

issues in their CFSR program improvement plans or to enforce any caseload
standard.

To improve the reliability of state-reported child welfare data, we
recommended in our July 2003 SACWIS report that the Secretary of HHS
consider, in addition to HHS's recent efforts to improve AFCARS data, ways
to enhance the guidance and assistance offered to states to help them
overcome the key challenges in collecting and reporting child welfare
data. HHS generally agreed with our findings and, in response to our
recommendation, noted that the data definitions need to be updated and
revised and said it is currently in the process of revising the AFCARS
regulations to further standardize the information states are to report.
More recently, HHS said that it would be creating policy guidance that
will delineate what will happen if a state fails to complete its SACWIS
within a reasonable time frame.

Mr. Chairman, this concludes my prepared statement. I would be pleased to
respond to any questions that you or other members of the Subcommittee may
have.

GAO Contact and For further information regarding this testimony, please
call Cornelia M. Ashby at (202) 512-8403. Individuals making key
contributions to this Acknowledgments testimony include Diana Pietrowiak,
Joy Gambino, Sara Schibanoff, and Michelle St. Pierre.

                   Appendix I: Subparts 1 and 2 Expenditures

Table 1: Fiscal Year 2002 Expenditures for Subparts 1 and 2 Service
Categories

                    Subpart 1 Subpart 2 Amount of Amount of

                                             Percentage of subpart 2 fundingb

                                Service category

Number of states

subpart 1 fundinga

Percentage of subpart 1 funding

Number of states

subpart 2 fundinga

        Staff positions        25  $70,965,578   27.6   17 $6,229,058  
      Administration and       16  43,143,097    16.8   18 11,614,667  
          management                                                   
       Child protective        17  40,543,000    15.8    5 2,248,690   
           services                                                    
          Foster care          17  27,890,783    10.8     2 647,154    
     maintenance payments                                              
      Multiple responsesc       8  25,806,347    10.0    4 3,503,585   
            Family             17  19,840,891    7.7   28 127,430,496  
      support/prevention                                               
     Counseling and mental      2   8,350,562    3.2     5 1,354,763   
        health services                                                
      Family preservation       7   5,986,045    2.3    23 30,308,896  
       Adoption subsidy         7   4,657,546    1.8      2 737,412    
           payments                                                    
     Family reunification       4   2,446,570    1.0    26 23,625,973  
        Recruitment and         9   2,260,061    0.9    16 6,828,885   
         training for                                                  
    foster/adoptive parents                                            
     Adoption support and       2    446,877     0.2    27 28,481,585  
     preservation services                                             
             Other             11   4,817,180    1.9    15 12,795,915  
            Totald                $257,154,537  100.0   $255,807,079    100.0 

Source: GAO survey.

Notes: Percentages do not always total to 100 due to rounding.

Data on subpart 1 expenditures are based on survey responses from 46
states and data on subpart 2 expenditures are based on survey responses
from 44 states. While Pennsylvania responded to our survey, it did not
provide expenditure data for subparts 1 or 2.

aWhen providing data for our survey, states were asked to indicate the
single service category that best described the type of program funded by
subparts 1 and 2. Thus, programs that fall into multiple service
categories may not be fully captured. For example, one state indicated it
funded a family support program, which includes some family preservation
and reunification services. In addition, states may not have been
consistent in categorizing services. For example, several HHS officials
told us that the delineation between family support and family
preservation services is not clear, so that two states providing the same
services to the same types of families may report them in different
categories. Inconsistencies such as these could have an effect on any
measured differences among service categories.

bStates may spend less than 20 percent of their subpart 2 funds on any of
the required service categories if they have a strong rationale. Some HHS
regional officials said that they approve exceptions to the 20 percent
requirement if a state is spending a significant amount of nonfederal
funds on a subpart 2 service category.

cAlthough states were asked to indicate the single service category that
best described the type of program funded by subparts 1 and 2, several
states selected multiple program categories when responding to our survey.
For example, Rhode Island reported that it funded a home visitation
program and indicated that this program includes family support, health,
and family reunification services. Thus, the responses from states that
reported multiple categories for a program are represented by this
category.

dThe aggregate dollars reported in the service categories do not match the
total allocations for subparts 1 and 2 in fiscal year 2002. States have 2
years to spend their Title IV-B allocations; as a result, expenditures in
fiscal year 2002 may include dollars from a state's fiscal year 2001 Title
IV-B allocation, as well as its fiscal year 2002 Title IV-B allocation.
Similarly, some fiscal year 2002 allocations may not have been spent until
fiscal year 2003.

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