oversight

D.C. Child and Family Services: Better Policy Implementation and Documentation of Related Activities Would Help Improve Performance

Published by the Government Accountability Office on 2003-05-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States General Accounting Office

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


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




GAO-03-646
             a
                                               May 2003


                                               D.C. CHILD AND FAMILY SERVICES

                                               Better Policy Implementation and
Highlights of GAO-03-646, a report to the      Documentation of Related Activities
Chairman, Committee on Government
Reform, House of Representatives               Would Help Improve Performance



The District of Columbia (D.C.)                CFSA’s performance relative to three sets of measures—nine ASFA
Child and Family Services Agency               requirements, eight selected performance criteria and six of the agency’s foster
(CFSA) is responsible for                      care policies—has been mixed. The agency took actions to implement six of the
protecting children at risk of abuse           nine ASFA requirements related to the safety and well-being of foster children
and neglect and ensuring that
                                               and met or exceeded four of the eight selected foster care performance criteria,
services are provided for them and
their families. GAO was asked to               but its plans did not address all requirements not fully implemented and unmet
discuss the extent to which CFSA               performance criteria. CSFA has established many foster care policies, but
has (1) met requirements of the                caseworkers did not consistently implement the six GAO examined. In addition,
Adoption and Safe Families Act                 FACES lacked data related to four of the policies reviewed for at least 70
(ASFA) of 1997 and other selected              percent of its active foster care cases. The following table summarizes the
performance criteria, (2) adopted              percentage of cases for which the data indicated the policy was implemented.
and implemented child protection
and foster care placement policies,            Implementation of Selected CFSA Foster Care Policies as Documented in FACES
and (3) enhanced its working                                                                                      Foster care cases for which
relationship with the D.C. Family               CFSA policy                                                     the policy was implemented
                                                                                                                                            a, b


Court.                                          Initiate face-to-face investigation of alleged child abuse or
                                                neglect within 24 hours of receiving an allegation on CFSA’s
To address these questions, GAO                 child abuse hotline.                                                                     26%
analyzed data from CFSA’s child                 Complete a safety assessment within 24 hours of face-to-face
                                                contact with the child.                                                                  13%
welfare information system, known               Complete a risk assessment within 30 days of receiving an
as FACES; reviewed laws,                        allegation on the hotline.                                                               73%
regulations, and reports; examined              Complete an initial case plan within 30 days of a child’s entry
case files; and interviewed officials.          into foster care.                                                                         9%
                                                Arrange needed services for foster care children or their
                                                families.                                                                                83%
                                               Source: FACES and GAO analysis.
                                               a
To improve CFSA’s performance                   With the exception of the policy to arrange needed services, the analysis is based on 943 foster
GAO recommends that the Mayor                  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
require the Director of CFSA to (1)            based on 1,837 foster care cases and includes cases that pre-dated FACES but for which services
develop plans to fully implement all           were provided after FACES came on-line. Data show the percentage of cases for which
ASFA requirements, (2) establish               caseworkers arranged at least one service.
                                               b
procedures to ensure caseworkers                CFSA counted cases that had missing data as instances of caseworker noncompliance with the
consistently implement all foster              applicable policy.
care policies, and (3) document in
FACES all activities related to                CFSA has enhanced its working relationship with the D.C. Family Court, but
active foster care cases.                      several factors hindered this relationship. For example, CFSA’s top
                                               management and Family Court judges talk frequently about foster care case
In commenting on the draft, the                issues. However, differing opinions among CFSA caseworkers and judges
Director of CFSA generally agreed              about their responsibilities have hindered the relationships. CFSA officials
with our findings. Although she did            and Family Court judges have been working together to address these
not directly address the                       hindrances.
recommendations, she generally
agreed with the areas we identified
for continued improvement.
www.gao.gov/cgi-bin/getrpt?GAO-03-646.

To view the full report, including the scope
and methodology, click on the link above.
For more information, contact Cornelia M.
Ashby at (202) 512-8403 or
ashbyc@gao.gov.
Contents


Letter                                                                                              1
                       Results in Brief                                                             3
                       Background                                                                   5
                       CFSA Undertook Actions to Implement Most ASFA Requirements
                         Reviewed and Met Half of the Selected Performance Criteria for
                         Child Safety and Well-Being                                                9
                       CFSA Has Established Many Foster Care Policies but Lacks Others,
                         and the Extent of Implementation and Documentation Varies                15
                       CFSA Has Enhanced Its Working Relationship with the D.C. Family
                         Court by Working Collaboratively, but Hindrances Remain                  22
                       Conclusions                                                                23
                       Recommendations                                                            23
                       Agency Comments and Our Evaluation                                         24

Appendix I             Scope and Methodology                                                      26



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



Appendix III           GAO Contacts and Acknowledgments                                           32
                       GAO Contacts                                                               32
                       Acknowledgments                                                            32

Related GAO Products                                                                              33



Tables
                       Table 1: CFSA’s Progress in Implementing Nine ASFA
                                Requirements                                                      10
                       Table 2: Analysis of Selected Foster Care Performance Criteria             12
                       Table 3: Implementation of Selected CFSA Foster Care Policies as
                                Documented in FACES                                               16
                       Table 4: Number of Cases Taking 5 or More Days to Implement
                                Policy (2000-2002)                                                17




                       Page i                               GAO-03-646 D.C. Child and Family Services
Figure
         Figure 1: CFSA Responsibilities Related to Permanency Goals                               8




         Abbreviations

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



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         Page ii                                        GAO-03-646 D.C. Child and Family Services
United States General Accounting Office
Washington, DC 20548




                                   May 27, 2003

                                   The Honorable Tom Davis
                                   Chairman
                                   Committee on Government Reform
                                   House of Representatives

                                   Dear Mr. Chairman:

                                   The District of Columbia’s Child and Family Services Agency (CFSA) is
                                   responsible for protecting foster care children who have been at risk of
                                   abuse and neglect and ensuring that critical services are provided to them
                                   and their families. In 2002, CFSA had about 3,000 children in foster care. As
                                   a result of a history of poor performance, the U.S. District Court for the
                                   District of Columbia placed CFSA in receivership in 1995.1 To help
                                   improve its performance during receivership, CFSA made several changes,
                                   including establishing an automated case management system, FACES. In
                                   2000, the District Court issued a consent order establishing a process by
                                   which the agency’s receivership could be terminated. The order also
                                   established a probationary period, which would begin when the
                                   receivership ended and identified performance criteria CFSA had to meet
                                   in order to end the probationary period. In April 2001, CFSA became a
                                   cabinet-level agency within the government of the District of Columbia, in
                                   June 2001 the court removed CFSA from receivership, and in October 2001
                                   responsibility for child abuse investigations was transferred from the
                                   District’s Metropolitan Police Department to CFSA. Additionally, new
                                   legislation established requirements that CFSA had to meet. The Adoption
                                   and Safe Families Act (ASFA) of 1997 mandated that all child welfare
                                   agencies achieve timely placement of children in permanent homes. The
                                   U.S. Department of Health and Human Services (HHS) is responsible for
                                   setting standards and monitoring the nation’s child welfare programs,
                                   including assessing compliance with ASFA requirements through its Child




                                   1
                                    The receivership was an arrangement in which the court appointed a person to
                                   temporarily manage the agency with broad authority to ensure full compliance with the
                                   court order in an expeditious manner.



                                   Page 1                                       GAO-03-646 D.C. Child and Family Services
and Family Services Reviews. 2 In addition, the District of Columbia Family
Court Act of 2001 required CFSA to work closely with the Family Division
of the D.C. Superior Court and the District’s Office of Corporation Counsel
(OCC).3 In September 2002, the court-appointed monitor reported that a
child was abused by two children in a group home licensed by CFSA.
According to the monitor, this incident, together with the history of
inadequate care and attention given this child by CFSA, indicated that its
operations and policies, especially those regarding foster care cases, may
still need improvement.

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

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



2
 Child and Family Services Reviews, conducted by HHS, cover a range of child and family
service programs funded by the federal government, including child protective services,
foster care, adoption, independent living, and family support and preservation services. The
2001 review evaluated seven specific safety, permanency, and well-being outcomes for
services delivered to children and families served by CFSA. As part of its review, HHS
randomly selected 50 active child welfare cases from the period between April 2000 and
July 2001.
3
 The District of Columbia Family Court Act of 2001 (P.L. 107-114), established the Family
Court as part of the D.C. Superior Court. The Family Court replaced the Family Division of
the D.C. Superior Court. Among other responsibilities, the Family Court handles child
abuse and neglect cases, court hearings, and other proceedings for the District’s foster
children and their families. OCC, among its other responsibilities, provides legal support to
CFSA on foster care cases.




Page 2                                          GAO-03-646 D.C. Child and Family Services
                   reports; examined case files; and interviewed officials. We obtained and
                   analyzed automated data from FACES on all foster care cases that were at
                   least 6 months old as of November 30, 2002. We selected ASFA
                   requirements and CFSA policies directly related to the safety and well-
                   being of foster children. We selected foster care performance criteria from
                   among those CFSA had to meet in order to end the probationary period
                   that, in our judgment, most directly related to the safety and permanent
                   placement of children in foster care. We reviewed federal and local laws,
                   regulations, foster care policies recommended by various organizations,
                   and reports on CFSA’s implementation of the District’s foster care
                   program and selected CFSA policies that covered several key foster care
                   management functions. We included HHS’s evaluation of how CFSA
                   implemented ASFA requirements in our assessment of the agency’s
                   performance. We independently verified the reliability of data in FACES;
                   however, CFSA had not entered into FACES detailed information on the
                   data elements we needed for our analysis with respect to about two-thirds
                   of the District’s active foster care cases—mostly cases that originated
                   prior to FACES going on-line in October 1999. To obtain information on
                   policy implementation, we also examined foster care case files. We
                   interviewed CFSA executives, managers, and supervisors; Family Court
                   judges, attorneys from OCC; and officials from organizations that
                   recommend policies applicable to child welfare programs. We conducted
                   our work between September 2002 and May 2003 in accordance with
                   generally accepted government auditing standards. See appendix I for
                   additional information on our scope and methodology.


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


                   Page 3                                 GAO-03-646 D.C. Child and Family Services
with one or more of their siblings. The criteria that CFSA did not meet
included the requirements regarding the frequency of caseworker visits
with children in foster care and the minimum percentage of foster care
children that must be placed in foster homes with valid licenses. CFSA has
written plans that address most of the unmet ASFA requirements and
selected performance criteria. The unmet requirements and performance
criteria not addressed in the plans are those related to providing timely
notification of all reviews and hearings to families with children in foster
care and to reducing the number of children in foster care who, for
18 months or more, have had a permanency goal to return home. Agency
officials cited staffing shortages and external demands, such as
coordinating work with other agencies, as factors that hindered the
agency’s ability to fully meet the ASFA requirements and performance
criteria. However, unless these requirements and criteria are met a child’s
safety may be jeopardized, the time a child spends in foster care may be
prolonged, or the best decisions regarding a child’s future well-being may
not be reached.

While CSFA has adopted many foster care policies similar to those
recommended for child welfare programs, caseworkers did not
consistently implement the six we examined, potentially leaving children
subject to continued abuse or neglect or delaying efforts to achieve
permanent and safe placements. In those cases for which data were
available, we found that the extent to which CFSA implemented selected
foster care policies varied. For example, caseworkers implemented the
policy requiring initial case plans to be completed within 30 days of a
child’s entry into foster care in 9 percent of the cases, and they
implemented the policy that children and their families receive needed
services in 83 percent of the cases. While timeframes for initiating
investigations and completing safety assessments improved between
2000 and 2002, caseworkers still took considerably longer than the
prescribed time limits to complete these tasks. Caseworkers and managers
said that the policies were not always implemented because of limited
staff and competing demands, such as making visits to children or
participating in court proceedings. In addition, CFSA’s automated system
lacked data on four of the six policies for at least 70 percent of its active
foster care cases. Complete, accurate, and timely case management data
enables caseworkers to quickly learn about new cases, supervisors to
know the extent to which caseworkers are completing their tasks, and
managers to know whether any aspects of the agency’s operations are in
need of improvement. Without information on all cases, caseworkers do
not have a readily available summary of the child’s history, which may be
critical to know when making plans about the child’s care. Additionally,


Page 4                                 GAO-03-646 D.C. Child and Family Services
             without information on all cases, managers do not have information
             needed to assess program operations and make improvements, if needed.

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

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

             The Director of CFSA, on behalf of the District’s Deputy Mayor for
             Children, Youth, Families, and Elders provided written comments on a
             draft of this report. In commenting on the draft, the Director generally
             agreed with our findings. Although the CFSA Director did not directly
             address the recommendations, she generally agreed with the areas we
             identified for continued improvement. Additionally, she suggested several
             changes to help clarify the report, which we incorporated as appropriate.
             The comments are discussed in the report and are shown in appendix II.

             While CFSA is responsible for protecting thousands of foster care
Background   children, many children in CFSA’s care languished for extended periods of
             time due to managerial shortcomings and long-standing organizational
             divisiveness in the District of Columbia. As a result of these deficiencies,
             the U.S. District Court for the District of Columbia issued a remedial order
             in 1991 to improve the performance of the agency. Under a modified final


             Page 5                                 GAO-03-646 D.C. Child and Family Services
order established by the court in 1993, CFSA was directed to comply with
many requirements. In 1995, lacking sufficient evidence of program
improvement, the agency was removed from the District’s Department of
Human Services and placed in receivership. Among its efforts to improve
agency performance, CFSA established an automated system, FACES, to
manage its caseload. The District Court issued a consent order in 2000
establishing a process by which the agency’s receivership could be ended.
The order also established a probationary period, which began when the
receivership ended, and identified performance standards CFSA had to
meet in order to end the probationary period. The court-appointed
monitor, the Center for the Study of Social Policy, was to assess CFSA’s
performance and had discretion to modify the performance standards. In
April 2001, CFSA became a cabinet-level agency within the government of
the District of Columbia. In June 2001, the court removed CFSA from the
receivership and its probationary period began. In October 2001,
responsibility for child abuse investigations was transferred to CFSA from
the District’s Metropolitan Police Department. CFSA’s probationary period
ended in January 2003.

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

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



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




Page 6                                       GAO-03-646 D.C. Child and Family Services
the state should continue to pursue reunification with the child’s family or
some other permanency goal—not later than 12 months after the child
enters foster care. The District of Columbia Family Court Act of 2001
established the District’s Family Court and placed several requirements on
the District’s Mayor and various District government agencies, including
CFSA and OCC. The District of Columbia Family Court Act requires the
Mayor, in consultation with the Chief Judge of the Superior Court, to
ensure that CFSA and other District government agencies coordinate the
provision of social services and other related services to individuals
served by the Family Court.

CFSA relies on services provided by other District government agencies.
For example, both the Fire Department and the Health Department inspect
facilities where children are placed, and D.C. Public Schools prepare
individual education plans for some foster care children. CFSA also works
with agencies in Maryland, Virginia, and other states to arrange for
placements of District children and also works with private agencies to
place children in foster and adoptive homes. In addition, CFSA is
responsible for licensing and monitoring organizations with which it
contracts, including group homes that house foster care children.

The management of foster care cases involves several critical steps
required by CFSA policy. (See fig. 1.) Typically, these cases begin with an
allegation of abuse or neglect reported to the CFSA child abuse hot line.
CFSA staff are required to investigate the allegations through direct
contact with the reported victim. If required, the child may be removed
from his or her home, necessitating various court proceedings handled by
the District’s Family Court. CFSA caseworkers are responsible for
managing foster care cases by developing case plans; visiting the children;
participating in administrative review hearings involving CFSA officials,
children, parents, and other officials; attending court hearings; and
working with other District government agencies. CFSA caseworkers are
also responsible for documenting the steps taken and decisions made
related to a child’s safety, well-being, and proper foster care placement, as
well as those related to developing the most appropriate goal for
permanency. Depending on their circumstances, children leave foster care
and achieve permanency through reunification with their birth or legal
parents, adoption, legal guardianship with a relative, or independence.5 As


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




Page 7                                         GAO-03-646 D.C. Child and Family Services
                                       of September 2002, a child’s length of stay in the District’s foster care
                                       program averaged 2.8 years.

Figure 1: CFSA Responsibilities Related to Permanency Goals




                                       Page 8                                  GAO-03-646 D.C. Child and Family Services
                       HHS is responsible for setting standards and monitoring the nation’s child
                       welfare programs. In fiscal year 2001, about $6.2 billion in federal funds
                       were appropriated to HHS for foster care and related child welfare
                       services. HHS’s monitoring efforts include periodic reviews of the
                       operations, known as Child and Family Services Reviews, and of the
                       automated systems, known as Statewide Automated Child Welfare
                       Information System (SACWIS) Reviews, in the states and the District of
                       Columbia. HHS last reviewed CFSA’s child welfare information system in
                       2000 and its overall program in 2001.


                       CFSA undertook actions to implement six of the nine ASFA requirements
CFSA Undertook         we reviewed and met or exceeded four of the eight performance criteria
Actions to Implement   included in our study, but as of March 2003, its plans to improve its
                       performance did not include all ASFA requirements not fully implemented
Most ASFA              or selected performance criteria. With regard to implementing ASFA
Requirements           requirements, for example, CFSA signed a border agreement to achieve
                       more timely placement of District children in Maryland, which addresses
Reviewed and Met       the ASFA requirement to use cross-jurisdictional resources to facilitate
Half of the Selected   timely adoptive or permanent placements for waiting children. Table 1
Performance Criteria   summarizes CFSA’s progress in implementing the nine ASFA requirements
                       that we reviewed.
for Child Safety and
Well-Being




                       Page 9                                GAO-03-646 D.C. Child and Family Services
Table 1: CFSA’s Progress in Implementing Nine ASFA Requirements

ASFA requirements CFSA has                           ASFA requirements CFSA has not fully
implemented                                          implemented
1. Include the safety of the child in state          1. Initiate or join proceedings to terminate
   case planning and in a case review                   parental rights for certain children
   system.                                              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             2. Provide participants a notice of reviews
   background clearances and have                       and hearings and an opportunity to be
   procedures for criminal record checks.               heard.
3. Develop a case plan documenting steps             3. Conduct mandatory permanency
   taken to provide permanent living                    hearings every 12 months for a child in
   arrangements for a child.                            foster care.
4. Develop plans for the effective use of
   cross-jurisdictional resources to
   facilitate
   timely adoptive or permanent
   placements for waiting children.
5. Provide for health insurance coverage
   for children with special needs in state
   plans for foster care and adoption
   assistance.
6. Incorporate standards to ensure quality
   services for children in foster care in
   state plans.
Source: ASFA and HHS’s CSFR and GAO analysis.

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


HHS’s review of CFSA found that the agency did not meet three
requirements. CFSA did not consistently petition the Family Court to
terminate parental rights when returning the child to his or her family had
been deemed inappropriate and the child had been in foster care for 15 of
the last 22 months. Based on its review of 50 foster care cases, HHS
reported that 54 percent of the children who were in care longer than
15 months did not have hearings initiated for the termination of parental
rights and reasons for not initiating such hearings were not documented in
the case plan or court order. HHS also found that not all cases had
hearings to review a child’s permanency goal within the timeframe
prescribed by ASFA. In addition, foster parents, relative caretakers, and
pre-adoptive parents were not consistently notified of reviews or hearings
held on behalf of the foster child. HHS found that not all caregivers and
prospective caregivers were notified of the time and place of a hearing, if
such notification took place at all.


Page 10                                             GAO-03-646 D.C. Child and Family Services
We also analyzed automated data from FACES related to eight foster care
performance criteria and found that CFSA met or exceeded four of them.
For example, one criterion requires 60 percent of children in foster care to
be placed with one or more of their siblings; we found that as of November
30, 2002, 63 percent of children were placed with one or more siblings. The
areas in which CFSA’s performance fell short were the criteria related to
(1) caseworker visitation with children in foster care, (2) placement of
children in foster homes with valid licenses, (3) progress toward
permanency for children in foster care, and (4) parental visits with
children in foster care who had a goal of returning home. For example,
none of the 144 children placed in foster care during the 2-month period
prior to November 30, 2002, received required weekly visits by a CFSA
caseworker. Table 2 summarizes our analysis of the selected foster care
performance criteria.




Page 11                                GAO-03-646 D.C. Child and Family Services
Table 2: Analysis of Selected Foster Care Performance Criteria

    Foster care performance criteria                                 Analysis
    1. Current case plans for foster care                Met     As of September 30, 2002,
         cases.                                                  46 percent of foster care
             Forty-five percent of foster care                   cases had current case
             cases have current case plans.                      plans.
    2. Visitation between children in foster           Not met   As of November 30, 2002, 1
        care and their parents.                                  percent of children with a
             Thirty-five percent of cases in                     return home goal had
             which children have a permanency                    parental visits at least every 2
             goal of return home have parental                   weeks.
             visits at least every 2 weeks.
    3. Social worker visitation with children in       Not met   As of November 30, 2002, no
        foster care.                                             children had weekly visits
             Twenty-five percent of children in                  and at least 98 percent of
             foster care have weekly visits with                 children did not have monthly
                                                                                           a
             social workers in their first 8                     visits with a caseworker.
             weeks of care; 35 percent of all
             children in foster care have at least
             monthly visits.
    4. Appropriate legal status for children in          Met     As of November 30, 2002, no
        foster care.                                             children in emergency care
             No child in emergency care for                      more than 90 days.
             more than 90 days.
    5. Current and valid foster home licenses.         Not met   As of November 30, 2002, 47
             Seventy-five percent of children are                percent of children were in
             placed in foster homes with valid                   foster homes with valid
             licenses.                                           licenses.
    6. Progress toward permanency.                     Not met   As of November 30, 2002, 30
             No more than 10 percent of                          percent of children had a
             children in foster care have a                      permanency goal of return
             permanency goal of return home                      home more than 18 months.
             for more than 18 months.
    7. Foster care placement with siblings.              Met     As of November 30, 2002, 63
             Sixty percent of children in foster                 percent of children were
             care are placed with one or more of                 placed with one or more
             their siblings.                                     siblings.
    8. Placement stability.                              Met     As of November 30, 2002, 21
             No more than 25 percent of                          percent of children had three
             children in foster care as of May                   or more placements.
             31, 2002, have had three or more
             placements.
Source: GAO analysis.
a
 For 2 percent of the children, caseworker visits equaled or exceeded the number of months in
placement. However, CFSA’s data did not allow us to determine when caseworkers visited children or
if they visited children each month.


CFSA’s Program Improvement Plan, a plan required by HHS to address
those areas determined not met in a CFSR, identifies how it will address
two of the unmet ASFA requirements—(1) to initiate or join proceedings



Page 12                                              GAO-03-646 D.C. Child and Family Services
to terminate parental rights (TPR) of certain children in foster care and
(2) to ensure that children have a permanency hearing every 12 months
after entering foster care. For example, CFSA has outlined steps to
improve its filings of TPR petitions with the Family Court. To help
facilitate this process, CFSA hired additional attorneys to expedite the
TPR proceedings. The new attorneys have been trained in ASFA
requirements and in the process for referring these cases to the Family
Court. CFSA is also developing a methodology for identifying and
prioritizing cases requiring TPR petitions. In another plan, the April 2003
Implementation Plan, CFSA states that it will redesign its administrative
review process to improve, among other things, notification and
attendance of relevant parties and to provide for a comprehensive review
of case progress, permanency goals, and adequacy of services. 6 However,
this plan does not make it clear whether all applicable hearings and
proceedings will be included, such as permanency hearings.

Another CFSA plan, the Interim Implementation Plan, includes measures
that were developed to show the agency’s plans for meeting the
requirements of the modified final order issued by the U.S. District Court
for the District of Columbia. This plan includes actions to address three of
the four performance criteria the agency did not meet—visits between
children in foster care and their parents, social worker visitation with
children in foster care, and placement of children in foster homes with
current and valid licenses. The plan states that, for new contracts, CFSA
will require its contactors to identify community sites for parental visits to
help facilitate visits between children in foster care and their parents. The
plan also indicates that CFSA will concentrate on the recruitment and
retention of caseworkers. According to CFSA officials, caseworkers would
have more time for quality casework, including visitation with children,
parents, and caregivers, once they hire more caseworkers. Additionally,
the plan established a goal to have 398 unlicensed foster homes in
Maryland licensed by December 31, 2002. According to an agency official,
104 of these foster homes remained unlicensed as of May 14, 2003.
However, CFSA does not have written plans that address the performance
criterion to reduce the number of children in foster care who, for
18 months or more, have had a permanency goal to return home. Without
complete plans for improving performance for all measures, CFSA’s ability


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




Page 13                                       GAO-03-646 D.C. Child and Family Services
to comply with the ASFA requirements and meet the selected performance
criteria may be difficult. Furthermore, unless these requirements and
criteria are met, the time a child spends in foster care may be prolonged,
or the best decisions regarding a child’s future well-being may not be
reached.

CFSA officials cited several factors that hindered their ability to fully
implement the ASFA requirements and meet the selected performance
criteria, including court-imposed requirements, staffing shortages, and
high caseloads. For example, program managers and supervisors said that
the new court-imposed mediation process intended to address family
issues without formal court hearings places considerable demands on
caseworkers’ time. The time spent in court for mediation proceedings,
which can be as much as 1 day, reduces the time available for caseworkers
to respond to other case management duties, such as visiting with children
in foster care. Furthermore, managers and supervisors reported that
staffing shortages have contributed to delays in performing critical case
management activities, such as identifying cases for which attorneys need
to file TPR petitions. However, staffing shortages are not a unique problem
to CFSA. We recently reported that caseworkers in other states said that
staffing shortages and high caseloads had detrimental effects on their
abilities to make well-supported and timely decisions regarding children’s
safety.7 We also reported that as a result of these shortages, caseworkers
have less time to establish relationships with children and their families,
conduct frequent and meaningful home visits, and make thoughtful and
well-supported decisions regarding safe and stable permanent placements.




7
U.S. General Accounting Office, Child Welfare: HHS Could Play a Greater Role in
Helping Child Welfare Agencies Recruit and Retain Staff, GAO-03-357 (Washington, D.C.:
Mar. 31, 2003).




Page 14                                     GAO-03-646 D.C. Child and Family Services
                             CSFA has established many foster care policies, but caseworkers did not
CFSA Has Established         consistently implement the six we selected. These policies covered the
Many Foster Care             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
Policies but Lacks           foster care performance criteria. In addition, CFSA’s automated system
Others, and the              lacked data on four of the six policies we examined for at least 70 percent
                             of its active foster care cases. Without information on all cases,
Extent of                    caseworkers do not have a readily available summary of the child’s history
Implementation and           needed to make decisions about a child’s care and managers do not have
Documentation Varies         information needed to assess and improve program operations.

CSFA Has Established         While we previously reported in 20008 that CFSA lacked some important
Many Foster Care Policies,   child protection and foster care placement policies, CFSA has now
but Caseworkers Did Not      established many such policies and most are comparable to those
                             recommended by organizations that develop standards applicable to child
Consistently Implement       welfare programs. For example, CFSA has policies for investigating
Those We Selected            allegations of child abuse, developing case plans, and establishing
                             permanency goals for foster children. In addition, one policy is more
                             rigorous than suggested standards. Specifically, CFSA’s policy requires an
                             initial face-to-face meeting with children within 24 hours of reported abuse
                             or neglect, while the suggested standard is 24 to 48 hours or longer,
                             depending on the level of risk to the child’s safety and well-being.
                             However, CFSA does not have some recommended policies, namely those
                             addressing (1) written time frames for arranging needed services for
                             children and families (e.g., tutoring for children and drug treatment for
                             family members); (2) limits on the number of cases assigned to a
                             caseworker, based on case complexity and worker experience; and
                             (3) procedures for providing advance notice to each person involved in a
                             case about the benefits and risks of services planned for a child and
                             alternatives to those services. CFSA managers said that the agency had not
                             established these policies because agency executives gave priority to
                             complying with court-ordered requirements.

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


                             8
                              U.S. General Accounting Office, District of Columbia Child Welfare: Long-Term
                             Challenges in Ensuring Children’s Well-Being, GAO-01-191 (Washington, D.C.: Dec. 29,
                             2000) and Foster Care: Status of the District of Columbia’s Child Welfare System Reform
                             Efforts, GAO/T-HEHS-00-109 (Washington, D.C.: May 5, 2000).




                             Page 15                                      GAO-03-646 D.C. Child and Family Services
CFSA could not provide automated data regarding the implementation of
one policy requiring administrative review hearings every 6 months.9 As
for the remaining five policies, data in FACES indicate that caseworkers’
implementation of them varied considerably. Table 3 summarizes these
five policies and the percentage of cases for which the data indicated the
policy was implemented.

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

                                                                   Percent of foster care cases
                                                                      for which the policy was
    Policy                                                                      implementeda, 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 data and GAO analysis.


a
 With the exception of the policy to arrange needed services, the analysis is based on 943 foster care
cases that were at least 6 months old, as of November 30, 2002. These cases were initiated after
FACES came on-line in October 1999. The analysis of the policy to arrange for needed services is
based on 1,837 foster care cases and includes cases that predated FACES but for which services
were provided after FACES came on-line. Data show the percentage of cases for which caseworkers
arranged at least one service.
b
 CFSA counted cases that had missing data as instances of caseworker noncompliance with the
applicable policy.


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



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




Page 16                                             GAO-03-646 D.C. Child and Family Services
longer than the time specified in the policy to take these actions in some
cases, CFSA’s performance has improved. CFSA has reduced the average
time it takes to make contacts and complete the assessments. In 2000, it
took caseworkers an average of 18 days to initiate a face-to-face
investigation, whereas in 2002 the average was 2 days. Similarly,
caseworkers took an average of 30 days to complete safety assessments in
2000, whereas the average time declined to 6 days in 2002. Although there
were cases that took much longer than the 24-hour limits, there were
fewer in 2002 than in 2000. CFSA caseworkers took 5 or more days to
initiate a face-to-face investigation for 61 cases in 2000, and for 16 cases in
2002. Table 4 summarizes the number of cases for which caseworkers took
5 or more days to initiate investigations and complete safety assessments
from 2000 through 2002.

Table 4: Number of Cases Taking 5 or More Days to Implement Policy (2000-2002)

                                                                   Fiscal Year
 Policy                                                   2000     2001     2002     Total
 Initiate face-to-face investigation of alleged child
 abuse or neglect within 24 hours of receiving an
 allegation.                                                 61       66       16     143
 Complete a safety assessment within 24 hours of
 face-to-face contact with child.                          101      122        50     273
Source: FACES data and GAO analysis.


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

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



Page 17                                          GAO-03-646 D.C. Child and Family Services
hearings. Agency officials explained that changes have been made to
FACES to enable them to track how many times an administrative review
is re-scheduled. Long delays between administrative review hearings could
mean delays in getting children into permanent placement. As for
arranging needed services, we could not determine from case files or
FACES whether services recommended by caseworkers were approved by
supervisors or if all needed services were provided. The FACES data
indicate that at least one service was provided for 83 percent of the cases,
but do not include a complete record of all services caseworkers
determine to be needed, nor do they indicate whether the services were
provided on a timely basis.

Officials said that several factors affected the implementation of some of
the policies we reviewed. Caseworkers’ supervisors and managers
explained that, generally, the policies were not always implemented
because of limited staff and competing demands, and the policies were not
documented because some caseworkers did not find FACES to be user
friendly. Agency officials explained that, in part, the data on the
implementation of the initial investigations and safety assessment
reflected a change in who was responsible for the initial investigation of
child abuse cases. Until October 2001, the District’s Metropolitan Police
Department had this responsibility and data on initial investigations were
not entered into FACES. CFSA now has responsibility for both child abuse
and neglect investigations. Further, program managers and supervisors
said that several factors contributed to the time frames required to initiate
face-to-face investigations, including difficulty in finding the child’s correct
home address, contacting the child if the family tries to hide the child from
investigators, and even obtaining vehicles to get to the location. Regarding
administrative review hearings, the records indicate that they were
rescheduled for a variety of reasons, such as the caseworker needing to
appear at a hearing for another case or the attorney not being able to
attend the hearing. Managers also said that the data on service delivery
was not always entered into FACES because caseworkers sometimes
arranged services by telephone and did not enter the data into FACES.

CFSA officials said that they recently made changes to help improve the
implementation of some of the policies we reviewed. They said that CFSA
has focused on reducing the number of cases for which a risk assessment
had not been completed and has reduced the number of these
investigations open more than 30 days from 807 in May 2001 to 263 in May
2002. CFSA officials said that they also anticipate a reduction in the
number of administrative review hearings that are rescheduled. They said
the responsibility for notifying administrative review hearing participants


Page 18                                  GAO-03-646 D.C. Child and Family Services
                         about a scheduled hearing was transferred from caseworkers to staff in
                         CFSA’s administrative review unit, and they intend to provide notification
                         well in advance of the hearings. Additionally, another official said that
                         CFSA has begun testing a process to ensure that all needed services are
                         provided within 45 days.

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


CFSA Has Established     In addition to its policies for managing cases, CFSA has policies for
Policies and Goals for   licensing and monitoring group homes, plans for training staff in group
Group Homes              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.




                         Page 19                                GAO-03-646 D.C. Child and Family Services
CFSA’s Automated System   In our efforts to assess CFSA’s implementation of the selected foster care
Lacked Data on Many       policies related to the safety and well-being of children as shown in table
Foster Care Cases         3, we determined that FACES lacked data on many active foster care
                          cases. In December 2000, we reported that FACES lacked complete case
                          information, and caseworkers had not fully used it in conducting their
                          daily casework.10 During our most recent review, we determined that
                          FACES lacked data on four of six foster care policies for at least
                          70 percent of its active foster care cases.11 Of the 2,510 foster care cases at
                          least 6 months old as of November 30, 2002, data were not available for
                          1,763. CFSA officials explained that all of these cases predated FACES,
                          and the previous system was used primarily to capture information for
                          accounting and payroll purposes, not for case management. Top agency
                          managers said that CFSA does not plan to make it an agency priority to
                          transfer information kept in paper files for cases that predated FACES into
                          the system. Additionally, FACES reports show that data were not available
                          on many of the cases that entered the foster care system after FACES
                          came on line. For example, complete data on the initiation of
                          investigations and completion of safety assessments were not available for
                          about half of the 943 cases that entered the foster care system after
                          FACES came on line. CFSA officials explained that they intend to focus on
                          improving a few data elements at a time for current and future events.

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




                          10
                           U.S. General Accounting Office, District of Columbia Child Welfare: Long-Term
                          Challenges to Ensuring Children’s Well-Being, GAO-01-191 (Washington, D.C.: Dec. 29,
                          2000).
                          11
                            The four polices for which FACES lacked data included (1) initiate face-to-face
                          investigation of alleged child abuse or neglect within 24 hours of receiving an allegation on
                          CFSA’s child abuse hotline, (2) complete a safety assessment within 24 hours of face-to-
                          face contact with the child, (3) complete a case plan within 30 days of a child’s entry into
                          foster care, and (4) schedule and attend administrative review hearings every 6 months.




                          Page 20                                         GAO-03-646 D.C. Child and Family Services
case reviews.12 According to a CFSA official, D.C. responded to the HHS
report and made changes to address most of the findings. He said that the
changes included redesigning the FACES screens documenting
service/case plans and the results of case reviews. These changes were
made in collaboration with caseworkers to help improve usability.

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

Complete, accurate, and timely case management data enables
caseworkers to quickly learn about new cases, supervisors to know the
extent that caseworkers are completing their tasks, and managers to know
whether any aspects of the agency’s operations are in need of
improvement. Child welfare automated systems need to have complete
case data to help ensure effective management of child welfare programs.
A child welfare expert said that there is a great need to transfer
information from old case records to new automated systems. For
example, the expert said that records of older teens have been lost, and,
with them, valuable information such as the identity of the children’s
father. Without data in FACES, CFSA’s caseworkers will have to look for
paper records in the case files, some of which are voluminous. This file
review effort is much more time-consuming than reviewing an automated
report and as a result, when cases are transferred to new caseworkers, it
requires more time for them to become familiar with cases.




12
  HHS completed its SACWIS assessment review of FACES in June 2000. The purpose of
this review is to assess whether the child welfare information system performs functions
that are important to meeting the minimal requirements.




Page 21                                       GAO-03-646 D.C. Child and Family Services
                        CFSA has enhanced its working relationship with the D.C. Family Court by
CFSA Has Enhanced       working more collaboratively, but several factors have hindered these
Its Working             relationships. By participating in committees and training sessions,
                        collocating OCC attorneys with caseworkers, and communicating
Relationship with the   frequently, CFSA has enhanced its working relationship with the Family
D.C. Family Court by    Court. CFSA participates in various planning committees with the Family
                        Court, such as the Implementation Planning Committee, a committee to
Working                 help implement the District of Columbia Family Court Act of 2001. CFSA
Collaboratively, but    caseworkers have participated in training sessions that include OCC
Hindrances Remain       attorneys and Family Court judges. These sessions provide all parties with
                        information about case management responsibilities and various court
                        proceedings, with the intent of improving and enhancing the mutual
                        understanding about key issues. Additionally, CFSA assigned a liaison
                        representative to the Family Court who is responsible for working with
                        other District agency liaison representatives to assist social workers and
                        case managers in identifying and accessing court-order services for
                        children and their families at the Family Court. Also, since 2002, OCC
                        attorneys have been located at CFSA and work closely with caseworkers.
                        This arrangement has improved the working relationship between CFSA
                        and the Family Court because the caseworkers and the attorneys are
                        better prepared for court appearances. Furthermore, senior managers at
                        CFSA and the Family Court communicated frequently about day-to-day
                        operations as well as long-range plans involving foster care case
                        management and related court priorities, and on several occasions
                        expressed their commitment to improving working relationships.

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


                        Page 22                                 GAO-03-646 D.C. Child and Family Services
                  about services for children and their families are important ones that can
                  affect a child’s length of stay in foster care.

                  CFSA officials and Family Court judges have been working together to
                  address some of the hindrances that constrain their working relationship.
                  CFSA managers said that scheduling of court hearings has improved.
                  According to agency officials, in March 2003, CFSA began receiving daily
                  schedules from the Family Court with upcoming hearing dates. This
                  information allows caseworkers to plan their case management duties
                  such that they do not conflict with court appearances. Also, as of March
                  2003, court orders were scanned into FACES to help ensure that
                  caseworkers and others involved with a case have more complete and
                  accurate information. To help resolve conflicts about ordering services,
                  CFSA caseworkers and Family Court judges have participated in sessions
                  during which they share information about their respective concerns,
                  priorities, and responsibilities in meeting the needs of the District’s foster
                  care children and their families.


                  CFSA has taken steps to implement several ASFA requirements, met
Conclusions       several performance criteria, developed essential policies, and enhanced
                  its working relationship with the Family Court. In addition, CFSA has
                  implemented new group home policies, improved the average time
                  caseworkers took to implement certain policies and undertaken initiatives,
                  in conjunction with the Family Court, to improve the scheduling of court
                  hearings. However, CFSA needs to make further improvements in order to
                  ensure the protection and proper and timely placement of all of the
                  District’s foster care children. By implementing all ASFA requirements,
                  meeting the performance criteria and effectively implementing all policies,
                  CFSA will improve a child’s stay in the foster care system and reduce the
                  time required to attain permanent living arrangements. Furthermore,
                  complete, accurate, and timely case management data will enable
                  caseworkers to quickly learn about new cases and the needs of children
                  and their families, supervisors to know the extent to which caseworkers
                  are completing all required tasks, and managers to know whether any
                  critical aspects of the agency’s operations are in need of improvement.
                  Without automated information on all cases, caseworkers do not have a
                  readily available summary of the child’s history, which may be critical to
                  know when making plans about the child’s safety, care, and well-being.

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


                  Page 23                                 GAO-03-646 D.C. Child and Family Services
                     requirements; (2) establish procedures to ensure that caseworkers
                     consistently implement foster care policies; and (3) document in FACES
                     all activities related to active foster care cases, including information from
                     paper case files related to the history of each active foster care case.


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

                     Additionally the Director provided overall comments concerning the
                     (1) implementation plan, (2) establishment of CFSA, and (3) timeframes of
                     the receivership. CFSA suggested that we modify the report to reflect
                     strategies listed in the April 2003 Implementation Plan regarding timely
                     notification and reducing the number of children in foster care for
                     18 months or more with a permanency goal of returning home. We
                     changed the report to reflect the notification strategy but did not make
                     changes regarding children and their progress towards permanency
                     because the April 2003 plan did not include a relevant strategy. CFSA also
                     suggested that we include the date the agency was established as a single
                     cabinet-level District agency and the date the agency gained responsibility
                     for abuse cases from the Metropolitan Police Department. We made these
                     changes. Additionally, CFSA recommended that we discuss the policy
                     implementation trends earlier in the report, and asked that we note the
                     time period for the cases included in the HHS review, which we did. CFSA
                     also asked that we explain that the data we collected and analyzed
                     generally covered the October 1999 to mid-2002 period. We did not make
                     this change. As explained in the scope and methodology section of the
                     report, we reviewed and analyzed a variety of data related to all active
                     foster care cases. Some of the data was as of November 2002, and some
                     analyses were based on active cases that began prior to October 1999.

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


                     Page 24                                 GAO-03-646 D.C. Child and Family Services
staff assigned to the Family Court. We did not include the March 2003
data listed in the comments because we could not verify the accuracy of
the data.

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

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

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

Sincerely yours,




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




Page 25                                GAO-03-646 D.C. Child and Family Services
             Appendix I: Scope and Methodology
Appendix I: Scope and Methodology


             To provide a comprehensive assessment of the Child and Family Services
             Agency’s (CFSA) performance relative to Adoption and Safe Families Act
             of 1997 (ASFA) requirements and selected foster care performance
             criteria, we relied on several sources of information and analyses. We
             reviewed the U. S. Department of Health and Human Services’ (HHS) Child
             and Family Services Review (February 2002) and obtained and analyzed
             data to assess CFSA’s implementation of ASFA’s requirements. Our
             analysis of CFSA’s implementation of ASFA identified whether the agency
             had implemented procedures in accordance with the ASFA requirements
             and did not assess the extent to which or how well it had implemented the
             requirement across all applicable foster care cases.

             To perform our assessment of CFSA’s performance with regard to the
             selected performance criteria established during its probationary period,
             we obtained and analyzed relevant automated data from FACES1 on all
             active foster care cases as of November 30, 2002, the last complete month
             for which data were available at the time of our work. We analyzed these
             data for six of the eight criteria. For the other two criteria, we analyzed
             data on all foster homes as of November 30, 2002, and data on case plans
             as of September 30, 2002. Additionally, we obtained and analyzed
             automated FACES data for 943 foster care cases that were at least 6
             months old as of November 30, 2002, to assess how CFSA caseworkers
             implemented foster care policies that covered several key functions from
             investigations through the delivery of services to foster children and their
             families. Many of the active foster care cases began prior to October 1999.

             We also obtained and analyzed reports by the court-appointed monitor to
             assess CFSA’s performance relative to the specified requirements and
             criteria. In addition, we reviewed and included relevant information from
             several of our prior reports on CFSA and the District’s Family Court. In
             addition, we independently verified the reliability of automated data by
             reviewing related reports on the data maintained in FACES and by
             assessing the degree to which FACES contained erroneous or illogical
             data entries. To obtain additional information on policy implementation
             and documentation, we reviewed case files for children who entered the
             foster care system at different times. Our case file review included
             analyses of data contained in FACES and in paper case files for selected
             foster care cases. We pretested our data collection instrument for
             collecting case file information and received training in the content and


             1
              CFSA’s automated case management system.




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




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




Page 27                                GAO-03-646 D.C. Child and Family Services
              Appendix II: Comments from the Director of the Child and Family Services Agency
Appendix II: Comments from the Director of
the Child and Family Services Agency




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




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




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




Page 31                                      GAO-03-646 D.C. Child and Family Services
                  Appendix III: GAO Contacts and
Appendix III: GAO Contacts and
                  Acknowledgments



Acknowledgments

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


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




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


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

             Foster Care: States Focus on Finding Permanent Homes for Children,
             but Long-Standing Barriers Remain. GAO-03-626T. Washington, D.C.:
             April 8, 2003.

             District of Columbia: Issues Associated with the Child and Family
             Services Agency’s Performance and Policies. GAO-03-611T. Washington,
             D.C.: April 2, 2003.

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

             District of Columbia: More Details Needed on Plans to Integrate
             Computer Systems With the Family Court and Use Federal Funds. GAO-
             02-948. 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.




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