oversight

D.C. Child and Family Services: Key Issues Affecting the Management of Its Foster Care Cases

Published by the Government Accountability Office on 2003-05-16.

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

                            United States General Accounting Office

GAO                         Testimony
                            Before the Committee on Government
                            Reform, House of Representatives


For Release on Delivery
Expected at 10:00 a.m.EDT
Friday, May 16, 2003        D.C. CHILD AND FAMILY
                            SERVICES
                            Key Issues Affecting the
                            Management of Its Foster
                            Care Cases
                            Statement of Cornelia M. Ashby, Director
                            Education, Workforce, and Income Security Issues




GAO-03-758T
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                                                May 16, 2003


                                                D.C. CHILD AND FAMILY SERVICES

                                                Key Issues Affecting Management of Its
Highlights of GAO-03-758T, testimony            Foster Care Cases
before the Committee on Government
Reform, House of Representatives




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
(CFSA) is responsible for                       foster care policies—has been mixed. The agency took actions to
protecting children at risk of abuse            implement six of the nine ASFA requirements related to the safety and
and neglect and ensuring that
critical services are provided for              well-being of foster children, and met or exceeded four of the eight
them and their families. GAO was                selected foster care performance criteria, but its plans do not address all
asked to discuss the extent to                  unmet requirements and criteria. CSFA has established many foster care
which CFSA has (1) met the                      policies, but caseworkers did not consistently implement the six GAO
requirements of the Adoption and                examined. In addition, FACES lacked data on four of these six policies for at
Safe Families Act (ASFA) of 1997                least 70 percent of its active foster care cases. The following table
and other selected performance                  summarizes five selected foster care policies for which data were available
criteria, (2) adopted and                       and the percentage of cases for which the data indicated the policy was
implemented child protection and                implemented.
foster care placement policies, and
(3) enhanced its working
relationship with the D.C. Family               Implementation of Selected CFSA Foster Care Policies, as Documented in FACES
Court.
                                                                                                                     Foster care cases
To address these questions, GAO                                                                                for which the policy was
                                                                                                                                      a, b
analyzed data in the District’s                 CFSA policy                                                             implemented
automated child welfare                         Initiate face-to-face investigation of alleged child                                26%
information system, known as                    abuse or neglect within 24 hours of receiving an
FACES; reviewed laws, regulations,              allegation on CFSA’s child abuse hotline.
and reports; examined case files;               Complete a safety assessment within 24 hours of                                        13%
and interviewed officials.                      face-to-face contact with the child.
                                                Complete a risk assessment within 30 days of                                           73%
                                                receiving an allegation on the hotline.
                                                Complete an initial case plan within 30 days of a                                        9%
                                                child’s entry into foster care.
                                                Arrange needed services for foster care children or                                    83%
                                                their families.
                                                Source: FACES and GAO analysis.
                                                a
                                                 With the exception of the policy to arrange needed services, the analysis is based on 943 foster
                                                care cases that were at least 6 months old, as of Nov. 30, 2002. These cases were initiated after
                                                FACES came on-line in Oct. 1999. The analysis of the policy to arrange for needed services is
                                                based on 1,837 foster care cases and includes cases that pre-dated FACES but for which services
                                                were provided after FACES came on-line. Data show the percentage of cases for which
                                                caseworkers arranged at least one service.
                                                b
                                                 CFSA counted cases that had missing data as instances of caseworker noncompliance with the
                                                applicable policy.


                                                CFSA has enhanced its working relationship with the D.C. Family Court, but
                                                several factors hindered this relationship. For example, CFSA’s top
                                                management and Family Court judges talk frequently about foster care case
                                                issues. However, differing opinions among CFSA caseworkers and judges
www.gao.gov/cgi-bin/getrpt?GAO-03-758T.         about their responsibilities have hindered the relationships. CFSA officials
To view the full testimony, click on the link   and Family Court judges have been working together to address these
above. For more information, contact            hindrances.
Cornelia M. Ashby, (202) 512-8403,
ashbyc@gao.gov.
Mr. Chairman and Members of the Committee:

I am pleased to be here today to discuss preliminary findings from our
study of the District of Columbia’s Child and Family Services Agency
(CFSA) you requested. My testimony will focus on the extent to which
CFSA has (1) taken actions to address the requirements of the Adoption
and Safe Families Act (ASFA) of 1997 and met selected performance
criteria, (2) adopted and implemented child protection and foster care
placement policies that are comparable to those generally accepted in the
child welfare community, and (3) enhanced its working relationship with
the D.C. Family Court.

My comments today are based primarily on our analysis of the information
in the District’s automated child welfare information system, known as
FACES, which CFSA is to use to manage child welfare cases and report
child abuse and neglect, foster care, and adoption information to the U.S.
Department of Health and Human Services (HHS). We selected three sets
of measures to assess CFSA’s performance. We assessed CFSA’s progress
in implementing nine ASFA requirements that were related to the safety
and well-being of children in foster care, the extent to which CFSA met or
exceeded eight selected performance criteria established during its
probationary period, and the extent to which caseworkers implemented
six foster care policies related to their day-to-day responsibilities. We
included HHS’s evaluation of how CFSA implemented ASFA requirements
in our assessment of the agency’s performance. We analyzed foster care
cases in FACES that were at least 6 months old as of November 2002 and
verified the accuracy of its data. However, CFSA had not entered into
FACES detailed information on the data elements we needed for our
analysis with respect to about two-thirds of the District’s active foster care
cases—mostly cases that originated prior to FACES going on-line in
October 1999. Consequently, we also reviewed paper case files for
children with different beginning dates in the foster care system to
supplement FACES information for some cases. We also interviewed
District officials; CFSA managers, judges, and child welfare experts; and
we analyzed federal and District laws and regulations, related court
documents, and child welfare policies. Our final report will be issued later
this month. We conducted our work between September 2002 and May
2003 in accordance with generally accepted government auditing
standards.




Page 1                                                            GAO-03-758T
             In summary, CFSA has taken actions to implement various ASFA
             requirements and met several selected foster care performance criteria,1
             established child protection and foster care placement policies and
             procedures, and enhanced its working relationship with the D.C. Family
             Court; however, much remains to be done. CFSA took actions to
             implement two-thirds of the ASFA requirements and met or exceeded half
             of the selected foster care performance criteria we used and developed
             written plans to address two of the three ASFA requirements not fully met
             and three of the four unmet foster care performance criteria. In addition,
             CFSA has adopted child protection and foster care placement policies and
             procedures that are comparable to most, but not all, of those
             recommended by organizations that develop standards applicable to child
             welfare programs. However, CFSA has not adopted some key policies and
             procedures for ensuring the safety and permanent placement of children,
             and caseworkers have not consistently implemented or documented some
             of the policies and procedures that have been adopted. While timeframes
             for implementing certain policies, such as initiating investigations and
             completing safety assessments have improved since 2000, caseworkers
             still take considerably longer than the prescribed time limits to complete
             these critical tasks, thereby increasing the potential risks posed to the
             safety and well-being of the District’s children. In addition, CFSA has
             developed an automated child welfare data system to help manage its
             caseload, among other initiatives to help improve its performance.
             However, detailed information for the data elements related to four of the
             six policies reviewed had not been entered into the system for at least 70
             percent of its active foster care cases. Further, CFSA has improved its
             working relationship with the Family Court through improved
             communication and support from top CFSA managers and Family Court
             judges; however, both CFSA and the Family Court still need to overcome
             barriers that continue to hinder this relationship.


             While CFSA is responsible for protecting children at risk of abuse and
Background   neglect, many children in CFSA’s care languished for extended periods of
             time due to managerial shortcomings and long-standing organizational
             divisiveness in the District of Columbia. As a result of these deficiencies,
             the U.S. District Court for the District of Columbia issued a remedial order


             1
              These performance criteria were among those included in the performance standards that
             CFSA had to meet in order to end the probationary period following the general
             receivership. We selected those performance criteria that in our judgment most directly
             relate to the safety and permanent placement of children.



             Page 2                                                                    GAO-03-758T
in 1991 to improve the performance of the agency. Under a modified final
order established by the court in 1993, CFSA was directed to comply with
many requirements. In 1995, lacking sufficient evidence of program
improvement, the agency was removed from the District’s Department of
Human Services and placed in receivership.2 Among its efforts to improve
agency performance, CFSA established an automated system, FACES, to
manage its caseload. The District Court issued a consent order in 2000
establishing a process by which the agency’s receivership could be
terminated. The order also established a probationary period, which would
commence upon termination of the receivership, and identified
performance standards CFSA had to meet in order to end the probationary
period. The court-appointed monitor, the Center for the Study of Social
Policy, was to assess CFSA’s performance and had the discretion to
modify the performance standards. In June 2001, the court removed CFSA
from receivership. In September 2002, the court-appointed monitor
reported that a 7-year old child was abused by two children in a group
home licensed by CFSA. This incident, according to the monitor, together
with the history of inadequate care and attention given this child by CFSA,
indicated that its operations and policies, especially those regarding foster
care cases, may still need improvement.

CFSA operates in a complex child welfare system.3 Several federal laws,
local laws, and regulations established goals and processes under which
CFSA must operate. ASFA, with one of its goals to place children in
permanent homes in a timelier manner, placed new responsibilities on all
child welfare agencies nationwide. ASFA introduced new time periods for
moving children toward permanent, stable care arrangements and
established penalties for noncompliance. For example, ASFA requires
child welfare agencies to hold a permanency planning hearing—during
which the court determines the future plans for a child, such as whether
the state should continue to pursue reunification with the child’s family or
some other permanency goal—not later than 12 months after the child
enters foster care. The District of Columbia Family Court Act of 2001 (P.L.
107-114) established the District’s Family Court and placed several
requirements on the District’s Mayor and various District agencies,



2
  The receivership was an arrangement in which the court appointed a person to
temporarily manage the agency with broad authority to ensure full compliance with the
court order in an expeditious manner.
3
 We issued several reports that addressed CFSA operations and program plans. For more
information see related GAO products.



Page 3                                                                     GAO-03-758T
including CFSA and the Office of Corporation Counsel (OCC).4 The
District of Columbia Family Court Act of 2001 requires the Mayor, in
consultation with the Chief Judge of the Superior Court, to ensure that
CFSA and other D.C. government offices coordinate the provision of social
services and other related services to individuals served by the Family
Court.

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

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




4
 Among other responsibilities, OCC provides legal support to CFSA in its handling of foster
care cases.
5
  Independent living arrangements may be attained once a child, who has not been reunified
with his family or adopted, reaches the age of 18 or, in some jurisdictions, 21 and is no
longer eligible to receive federal reimbursement for foster care expenditures.



Page 4                                                                       GAO-03-758T
                       of September 2002, a child’s length of stay in the District’s foster care
                       program averaged 2.8 years.

                       HHS is responsible for setting standards and monitoring the nation’s child
                       welfare programs. In fiscal year 2001, about $6.2 billion in federal funds
                       were appropriated to HHS for foster care and related child welfare
                       services. HHS’s monitoring efforts include periodic reviews of the
                       operations, known as Child and Family Services Reviews,6 and of the
                       automated systems, known as Statewide Automated Child Welfare
                       Information System (SACWIS) Reviews, in the states and the District of
                       Columbia. HHS last reviewed CFSA’s child welfare information system in
                       2000 and its overall program in 2001.


                       CFSA undertook actions to implement six of the nine ASFA requirements
CFSA Undertook         we reviewed and met or exceeded four of the eight performance criteria
Actions to Implement   we included in our study, but CFSA’s plans to improve its performance do
                       not include all unmet ASFA requirements or selected performance criteria.
Most ASFA              Table 1 summarizes CFSA’s progress in implementing the nine ASFA
Requirements           requirements that we reviewed.
Reviewed and Met
Half of the Selected
Performance Criteria
for Child Safety and
Well-Being




                       6
                         Child and Family Services Reviews, conducted by HHS, cover a range of child and family
                       service programs funded by the federal government, including child protective services,
                       foster care, adoption, independent living, and family support and preservation services. The
                       2001 review evaluated seven specific safety, permanency, and well-being outcomes for
                       services delivered to children and families served by CFSA.



                       Page 5                                                                       GAO-03-758T
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
arrangements for a child, and provide for health insurance coverage for children with special needs—
is based on data and information provided to us. Our assessment of CFSA’s progress in
implementing the remaining ASFA requirements is based on HHS’s review of CFSA.


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




Page 6                                                                              GAO-03-758T
communication in notifying caregivers and prospective caregivers of the
time and place of a hearing, if such notification took place at all.

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




Page 7                                                            GAO-03-758T
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, 46 percent of foster care cases had
     cases.                                                               current case plans.
       Forty-five percent of foster care cases have
       current case plans.
 2. Visitation between children in foster care and           Not met      As of November 30, 2002, 1 percent of children with a return
    their parents                                                         home goal had parental visits at least every 2 weeks.
       Thirty-five percent of cases in which children have
       a permanency goal of return home have parental
       visits at least every 2 weeks.
 3. Social worker visitation with children in foster         Not met      As of November 30, 2002, no children had weekly visits and at
    care                                                                  least 98 percent of children did not have monthly visits with a
       Twenty-five percent of children in foster care have                caseworker.a
       weekly visits with social workers in their first 8
       weeks of care; 35 percent of all children in foster
       care have at least monthly visits with a social
       worker.
 4. Appropriate legal status for children in foster care     Met          As of November 30, 2002, no children in emergency care more
       No child in emergency care for more than 90 days.                  than 90 days.
 5. Current and valid foster home licenses                   Not met      As of November 30, 2002, 47 percent of children were in foster
       Seventy-five percent of children are placed in                     homes with valid licenses.
       foster home with valid licenses.
 6. Progress toward permanency                               Not met      As of November 30, 2002, 30 percent of children had
       No more than 10 percent of children in foster care                 permanency goal of return home more than 18 months.
       have a permanency goal of return home for more
       than 18 months.
 7. Foster care placement with siblings                      Met          As of November 30, 2002, 63 percent of children were placed
       Sixty percent of children in foster care are placed                with one or more siblings.
       with one or more of their siblings.
 8. Placement stability                                      Met          As of November 30, 2002, 21 percent of children had three or
       No more than 25 percent of children in foster care                 more placements.
       as of May 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 for the performance measure to this criterion do not allow for the
                                             determination of whether caseworkers visited children each month they were in foster care.


                                             CFSA’s Program Improvement Plan, a plan required by HHS to address
                                             those areas determined not met by HHS, identifies how it will address two
                                             of the unmet ASFA requirements—(1) to initiate or join proceedings to
                                             terminate parental rights (TPR) of certain children in foster care and (2) to
                                             ensure that children in foster care have a permanency hearing every 12
                                             months. For example, CFSA has outlined steps to improve its filings of
                                             TPR petitions with the Family Court. To help facilitate this process, CFSA
                                             hired additional attorneys to expedite the TPR proceedings. The new
                                             attorneys have been trained in ASFA requirements and in the process for


                                             Page 8                                                                              GAO-03-758T
referring these cases to the Family Court. CFSA is also developing a
methodology for identifying and prioritizing cases requiring TPR petitions.
While CFSA’s updated Program Improvement Plan states its intent to
provide notification of hearings to all participants, this plan does not make
it clear whether all applicable reviews and hearings will be included.

Another CFSA plan—the Interim Implementation Plan—includes
measures that were developed to show the agency’s plans for meeting the
requirements of the modified final order issued by the U.S. District Court
for the District of Columbia.7 This plan includes actions to address three of
the four performance criteria CFSA did not meet—visits between children
in foster care and their parents, social worker visitation with children in
foster care, and placement of children in foster homes with current and
valid licenses. The plan states that, for new contracts, CFSA will require its
contactors to identify community sites for parental visits to help facilitate
visits between children in foster care and their parents. The plan also
indicates that CFSA will concentrate on the recruitment and retention of
caseworkers. According to CFSA officials, caseworkers would have more
time for quality casework, including visitation with children, parents, and
caregivers, once they hire more caseworkers. Additionally, the plan
established a goal to have 398 unlicensed foster homes in Maryland
licensed by December 31, 2002. However, CFSA does not have written
plans that address the performance criterion to reduce the number of
children in foster care who, for 18 months or more, have had a
permanency goal to return home. Without complete plans for improving
performance for all measures, CFSA’s ability to comply with the ASFA
requirements and meet the selected performance criteria may be difficult.
Furthermore, unless these requirements and criteria are met, the time a
child spends in foster care may be prolonged, or the best decisions
regarding a child’s future well-being may not be reached.

CFSA officials cited several factors that hindered their ability to fully meet
the ASFA requirements and the selected performance criteria, including
court-imposed requirements, staffing shortages, and high caseloads. For
example, program managers and supervisors said that the new court-
imposed mediation process intended to address family issues without
formal court hearings places considerable demands on caseworkers’ time.


7
 In April 2003, the court-appointed monitor submitted a final implementation plan
containing additional performance measures to the U.S. District Court for the District of
Columbia for its approval. Once approved, this plan will establish goals CFSA must meet by
2006.



Page 9                                                                     GAO-03-758T
                       The time spent in court for mediation proceedings, which can be as much
                       as 1 day, reduces the time available for caseworkers to respond to other
                       case management duties, such as visiting with children in foster care.
                       Furthermore, managers and supervisors reported that staffing shortages
                       have contributed to delays in performing critical case management
                       activities, such as identifying cases for which attorneys need to file TPR
                       petitions. However, staffing shortages are not a unique problem to CFSA.
                       We recently reported that caseworkers in other states said that staffing
                       shortages and high caseloads had detrimental effects on their abilities to
                       make well-supported and timely decisions regarding children’s safety. 8 We
                       also reported that as a result of these shortages, caseworkers have less
                       time to establish relationships with children and their families, conduct
                       frequent and meaningful home visits, and make thoughtful and well-
                       supported decisions regarding safe and stable permanent placements.


                       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 policy implementation for at least 70 percent of its active
                       foster care cases. Without information on all cases, caseworkers do not
Extent of              have a readily available summary of the child’s history needed to make
Implementation and     decisions about a child’s care, and managers do not have information
Documentation          needed to assess and improve program operations.

Varies




                       8
                         U.S. General Accounting Office, Child Welfare: HHS Could Play a Greater Role in
                       Helping Child Welfare Agencies Recruit and Retain Staff, GAO-03-357 (Washington, D.C.:
                       Mar. 31, 2003).




                       Page 10                                                                  GAO-03-758T
CSFA Has Established         While we previously reported in 20009 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 covered the range of activities involved in a
                             foster care case, but did not duplicate those examined in our review of the
                             AFSA requirements or the selected foster care performance criteria. CFSA
                             could not provide automated data regarding the implementation of one
                             policy requiring administrative review hearings every 6 months.10 As for
                             the remaining five policies, data in FACES indicate that caseworkers’
                             implementation of them varied considerably. Table 3 summarizes these
                             five policies and the percentage of cases for which the data indicated the
                             policy was implemented.




                             9
                               U.S. General Accounting Office, District of Columbia Child Welfare: Long-Term
                             Challenges in Ensuring Children’s Well-Being, GAO-01-191 (Washington, D.C.: Dec. 29,
                             2000) and Foster Care: Status of the District of Columbia’s Child Welfare System Reform
                             Efforts, GAO/T-HEHS-00-109 (Washington, D.C.: May 5, 2000).
                             10
                              Administrative review hearings are held to make decisions about a child’s permanent
                             placement. They generally involve foster care children, family members, CFSA
                             caseworkers, attorneys, and others with a role in the future well-being of the child.



                             Page 11                                                                     GAO-03-758T
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 pre-dated FACES but for which services
were provided after FACES came on-line. Data show the percentage of cases for which caseworkers
arranged at least one service.
b
 CFSA counted cases that had missing data as instances of caseworker noncompliance with the
applicable policy.


The policies related to initiating face-to-face investigations and completing
safety assessments are particularly critical to ensuring children’s safety.
CFSA’s policy requires caseworkers to initiate an investigation of alleged
child maltreatment within 24 hours of the call to CFSA’s hot line through
face-to-face contact with the child. Also, caseworkers are required to
complete a safety assessment within 24 hours of the face-to-face contact
with the child. While it took CFSA caseworkers considerably longer than
the time specified in the policy to take these actions in some cases, CFSA’s
performance has improved. CFSA has reduced the average time it takes to
make contacts and complete the assessments. In 2000, it took caseworkers
an average of 18 days to initiate a face-to-face investigation, whereas in
2002 the average was 2 days. Similarly, caseworkers took an average of 30
days to complete safety assessments in 2000, whereas the average time
declined to 6 days in 2002. Although there were cases that took much
longer than the 24-hour limits, there were fewer in 2002 than in 2000. CFSA
caseworkers took 5 or more days to initiate a face-to-face investigation for
61 cases in 2000, and for 16 cases in 2002. Table 4 summarizes the number
of cases for which caseworkers took 5 or more days to initiate
investigations and complete safety assessments from 2000 through 2002.


Page 12                                                                               GAO-03-758T
Table 4: Number of Cases Taking 5 or More Days to Implement Policy (2000-2002)

                                                                     Fiscal Year
 Policy                                                       2000   2001     2002   Total
 Initiate face-to-face investigation of alleged child abuse
 or neglect within 24 hours of receiving an allegation.         61     66      16     143
 Complete a safety assessment within 24 hours of 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 the cases we examined administrative
review hearings, which are held to ensure that key stakeholders are
involved in decisions about a child’s permanent placement, were
rescheduled, resulting in their being held less frequently than required by
CFSA policy. CFSA policy requires that these hearings be held every 6
months, and FACES automatically schedules them to occur 6 months after
the most recent hearing. However, CFSA officials are unable to track how
frequently they are rescheduled or the length of time between hearings
because the system overrides the dates of prior hearings. Long delays
between administrative review hearings could mean delays in getting
children into permanent placement. As for arranging needed services, we
could not determine from case files or FACES whether services
recommended by caseworkers were approved by supervisors or if all
needed services were provided. The FACES data indicate that at least one
service was provided for 83 percent of the cases, but do not include a
complete record of all services caseworkers determine to be needed, nor
do they indicate whether the services were provided on a timely basis.

Officials said that several factors affected the implementation of some of
the policies we reviewed. Caseworkers’ supervisors and managers
explained that, generally, the policies were not always implemented
because of limited staff and competing demands, and the policies were not
documented because some caseworkers did not find FACES to be user


Page 13                                                                     GAO-03-758T
friendly. Agency officials explained that, in part, data on the
implementation of the initial investigations and safety assessment
reflected a change in who was responsible for the initial investigation of
child abuse cases. Until October 2001, the District’s Metropolitan Police
Department had this responsibility, and data on initial investigations were
not entered into FACES. CFSA now has responsibility for both child abuse
and neglect investigations. Further, program managers and supervisors
said that several factors contributed to the time frames required to initiate
face-to-face investigations, including difficulty in finding the child’s correct
home address, contacting the child if the family tries to hide the child from
investigators, and even obtaining vehicles to get to the location. Regarding
administrative review hearings, the records indicate that they were
rescheduled for a variety of reasons, such as the caseworker needing to
appear at a hearing for another case or the attorney not being able to
attend the hearing. Managers also said that the data on service delivery
was not always entered into FACES because caseworkers sometimes
arranged services by telephone and did not enter the data into FACES.

CFSA officials said they recently made changes to help improve the
implementation of some of the policies we reviewed. They said CFSA has
focused on reducing the number of cases for which a risk assessment had
not been completed and has reduced the number of these investigations
open more than 30 days from 807 in May 2001 to 263 in May 2002. CFSA
officials also said that they anticipate a reduction in the number of
administrative review hearings that are rescheduled. They said the
responsibility for notifying administrative review hearing participants
about a scheduled hearing was transferred from caseworkers to staff in
CFSA’s administrative review unit, and they intend to provide notification
well in advance of the hearings. Additionally, another official said that
CFSA has begun testing a process to ensure that all needed services are
provided within 45 days.

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



Page 14                                                            GAO-03-758T
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.


CFSA’s Automated System   In our efforts to assess CFSA’s implementation of the six selected foster
Lacked Data on Many       care policies related to the safety and well-being of children as shown in
Foster Care Cases         table 2, we determined that FACES lacked data on many active foster care
                          cases. In December 2000, we reported that FACES lacked complete case
                          information and caseworkers had not fully used it in conducting their daily
                          casework.11 During our most recent review, we determined that FACES
                          lacked data on four of six foster care policies for at least 70 percent of its
                          active foster care cases. Of the 2,510 foster care cases at least 6 months
                          old as of November 30, 2002, data were not available for 1,763 of them.
                          CFSA officials explained that all of these cases predated FACES, and the
                          previous system was used primarily to capture information for accounting
                          and payroll purposes, not for case management. Top agency managers said
                          that CFSA does not plan to make it an agency priority to transfer
                          information kept in paper files for cases that predated FACES into the
                          system. Additionally, FACES reports show that data were not available on



                          11
                             U.S. General Accounting Office, District of Columbia Child Welfare: Long-Term
                          Challenges to Ensuring Children’s Well-Being, GAO-01-191 (Washington, D.C.: Dec. 29,
                          2000).



                          Page 15                                                                   GAO-03-758T
many of the cases that entered the foster care system after FACES came
on line. For example, complete data on the initiation of investigations and
completion of safety assessments were not available for about half of the
943 cases that entered the foster care system after FACES came on line.
CFSA officials explained that they intend to focus on improving a few data
elements at a time for current and future events.

Having systems that provide complete and accurate data is an important
aspect of effective child welfare programs. HHS requires all states and the
District of Columbia to have an automated child welfare information
system. These systems, known as SACWIS, must be able to record data
related to key child welfare functions, such as intake management, case
management, and resource management. However, in its review of
FACES, HHS found CFSA’s system was not in full compliance with several
requirements, including the need to prepare and document service/case
plans and to conduct and record the results of case reviews.12

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

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



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



Page 16                                                                     GAO-03-758T
                        Without data in FACES, CFSA’s caseworkers will have to look for paper
                        records in the case files, some of which are voluminous. This file review
                        effort is much more time-consuming than reviewing an automated report
                        and as a result, when cases are transferred to new caseworkers, it requires
                        more time for them to become familiar with cases.


                        CFSA has enhanced its working relationship with the D.C. Family Court by
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 two
                        caseworkers who assist in arranging court-ordered services for children
                        and their families at the Family Court. Also, since 2002, OCC attorneys
                        have been located at CFSA and work closely with caseworkers. This
                        arrangement has improved the working relationship between CFSA and
                        the Family Court because the caseworkers and the attorneys are better
                        prepared for court appearances. Furthermore, senior managers at CFSA
                        and the Family Court communicated frequently about day-to-day
                        operations as well as long-range plans involving foster care case
                        management and related court priorities, and on several occasions
                        expressed their commitment to improving working relationships.

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

                        Page 17                                                        GAO-03-758T
              court with timely and complete information on the facts and
              circumstances of the case. Caseworkers and judges agreed that
              appropriate and timely decisions about services for children and their
              families are important ones that can affect a child’s length of stay in foster
              care.

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


              CFSA has taken steps to implement several ASFA requirements, met
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 in the most timely way, and managers to
              know whether any critical aspects of the agency’s operations are in need
              of improvement. Without automated information on all cases, caseworkers
              do not have a readily available summary of the child’s history, which may
              be critical to know when making plans about the child’s safety, care, and
              well-being.

              Page 18                                                            GAO-03-758T
                  Mr. Chairman, this concludes my prepared statement. I will be happy to
                  respond to any questions that you or other Subcommittee members may
                  have.


                  For further contacts regarding this testimony, please call Cornelia M.
GAO Contact and   Ashby at 202-512-8403. Individuals making key contributions to this
Acknowledgments   testimony included Carolyn M. Taylor, Mark E. Ward, Sheila Nicholson,
                  Vernette Shaw, Joel Grossman, and James Rebbe.




                  Page 19                                                       GAO-03-758T
GAO Related Products


             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 20                                                      GAO-03-758T
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