oversight

Child Welfare: Enhanced Federal Oversight of Title IV-B Could Provide States Additional Information to Improve Services

Published by the Government Accountability Office on 2003-09-10.

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

                 United States General Accounting Office

GAO              Report to the Chairman, Subcommittee
                 on Human Resources, Committee on
                 Ways and Means, House of
                 Representatives

September 2003
                 CHILD WELFARE

                 Enhanced Federal
                 Oversight of Title IV-B
                 Could Provide States
                 Additional
                 Information to
                 Improve Services




GAO-03-956
                                                September 2003


                                                CHILD WELFARE

                                                Enhanced Federal Oversight of Title IV-B
Highlights of GAO-03-956, a report to the       Could Provide States Additional
Chairman, Subcommittee on Human
Resources, Committee on Ways and                Information to Improve Services
Means, House of Representatives




In 2001, states determined that over            On a national level, GAO’s survey showed that the primary emphases of
900,000 children were the victims               subparts 1 and 2 vary somewhat, but the range of services offered and the
of abuse or neglect. In fiscal year             types of families served overlap significantly. No single category of service
2003, subparts 1 and 2 of Title IV-B            was funded solely by either subpart. In fiscal year 2002, states used subpart 1
of the Social Security Act provided             funds most frequently for the salaries of child welfare agency staff,
$697 million in federal funding for
services to help families address
                                                administrative and managerial expenses, child protective services, and foster
problems that lead to child abuse               care maintenance payments. Subpart 2 primarily funded family support,
and neglect. This report describes              family preservation, family reunification, and adoption support services.
(1) the services provided and                   Programs funded by the two subparts served similar types of populations—
populations served under subparts               predominantly children at risk of being abused or neglected and their
1 and 2; (2) federal oversight of               parents, as well as children in foster care and their parents.
subpart 1; and (3) existing research
on the effectiveness of services                HHS’s oversight focuses primarily on states’ overall child welfare systems
unique to subpart 1—that is, when               and outcomes, but the agency provides relatively little oversight specific to
states used subpart 1, but not                  subpart 1. For example, HHS works with states to establish goals to improve
subpart 2, to fund programs in a                the safety and well-being of children and measure progress toward those
particular service category. The
report focuses primarily on subpart
                                                goals. However, HHS has limited knowledge about how states spend subpart
1 because little research exists on             1 funds. States submit an annual estimate about how they plan to use their
this subpart, while studies have                subpart 1 funds in the upcoming year, but provide no data on actual
been conducted on subpart 2.                    expenditures. HHS reports that it reviews these estimates for relatively
                                                limited purposes. We also found that HHS regional offices pay little attention
                                                to statutory limits on the use of subpart 1 funds for foster care maintenance
                                                and adoption assistance payments. For example, 9 of the 10 HHS regional
GAO recommends that the                         offices do not monitor states’ compliance with these limits. As a result, HHS
Secretary of the Department of
                                                approved projected 2002 spending plans for 15 states that reported
Health and Human Services (HHS)
(1) provide guidance to ensure that             estimated spending amounts that exceeded the limits by over $30 million in
HHS regional offices provide                    total.
appropriate oversight of subpart 1;
(2) consider the feasibility of                 While GAO’s survey data revealed no unique service categories funded by
collecting data on states’ use of               subpart 1 on a national level, 37 states reported unique subpart 1 service
these funds to facilitate program               categories within their state. Little research is available on the effectiveness
oversight; and (3) use the                      of the services in these categories, such as hotlines to report child abuse and
information gained through                      emergency shelter services. No states conducted rigorous evaluations of
enhanced oversight of subpart 1 in              these services, although several states provided some information on
designing its proposed child                    outcomes.
welfare option, which would allow
states to use other federal child               Examples of Services Funded by Title IV-B
welfare funds for services allowed
under Title IV-B. HHS generally
agreed with GAO’s findings, but did
not fully concur with these
recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-03-956.

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


Letter                                                                                                1
                       Results in Brief                                                               3
                       Background                                                                     5
                       The Primary Emphases of These Subparts Vary Somewhat, but the
                         Range of Services and Types of Families Served Overlap
                         Significantly                                                              12
                       HHS Focuses Oversight on Overall Child Welfare System, but Has
                         Limited Knowledge about States’ Use of Subpart 1 Funds                     26
                       Some Unique Subpart 1 Service Categories Exist at the State Level,
                         but Little Research Exists on the Effectiveness of These Services          36
                       Conclusions                                                                  41
                       Recommendations                                                              41
                       Agency Comments                                                              42

Appendix I             Scope and Methodology                                                        45



Appendix II            Comments from the Department of Health and
                       Human Services                                                               50



Appendix III           GAO Contacts and Acknowledgments                                             54
                       GAO Contacts                                                                 54
                       Acknowledgments                                                              54

Related GAO Products                                                                                55



Tables
                       Table 1: Selected Requirements to Obtain Grants under Subparts 1
                                and 2 of Title IV-B                                                 11
                       Table 2: Fiscal Year 2002 Expenditures for Subparts 1 and 2 Service
                                Categories                                                          14
                       Table 3: Populations Targeted by Services Funded by Subparts 1
                                and 2 of Title IV-B in Fiscal Year 2002                             20
                       Table 4: Number of States Using Funds from Each Subpart of Title
                                IV-B to Target Specific Populations                                 21




                       Page i                              GAO-03-956 Title IV-B Child Welfare Services
Figures
          Figure 1: Percentage of Subpart 1 Funds Used for Staff Salaries
                   Dedicated to Each Type of Staff Position in Fiscal Year
                   2002                                                                             16
          Figure 2: Survey Data on States’ Preferences between Subparts 1
                   and 2 of Title IV-B for Different Program Components                             24
          Figure 3: Fifteen States with Approved CFS-101s with Fiscal Year
                   2002 Subpart 1 Spending Estimates that Exceeded Limits
                   for Foster Care Maintenance and Adoption Assistance
                   Payments                                                                         33
          Figure 4: Ten States That Reported Fiscal Year 2002 Subpart 1
                   Expenditures Exceeding Limits for Foster Care
                   Maintenance and Adoption Assistance Payments                                     35




          Abbreviations

          ACF                        Administration for Children and Families
          APSR                       Annual Progress and Services Report
          CFSR                       Child and Family Services Review
          CPS                        child protective services
          HHS                        Health and Human Services
          HIPPY                      Home Instruction for Parents of Preschool
                                       Youngsters




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          Page ii                                     GAO-03-956 Title IV-B Child Welfare Services
United States General Accounting Office
Washington, DC 20548




                                   September 12, 2003

                                   The Honorable Wally Herger
                                   Chairman
                                   Subcommittee on Human Resources
                                   Committee on Ways and Means
                                   House of Representatives

                                   Dear Mr. Chairman:

                                   In 2001, child protective services (CPS) staff in state child welfare
                                   agencies determined that over 900,000 children had been the victims of
                                   abuse or neglect by their parents or other caretakers.1 Title IV-B of the
                                   Social Security Act is the primary source of federal funding for services to
                                   help families address problems that lead to child abuse and neglect and to
                                   prevent the unnecessary separation of children from their families. Title
                                   IV-B is divided into two parts. States can use subpart 1 funds on almost
                                   any child welfare activity. Subpart 2 provides grants to states for similar
                                   types of child welfare services, such as family support services to enhance
                                   family stability and services to help parents reunify with a child in foster
                                   care, but is more restrictive in how the funds can be spent. In fiscal year
                                   2003, appropriations were $292 million for subpart 1 and $405 million for
                                   subpart 2.2

                                   Title IV-B represents a small percentage of total federal spending on child
                                   welfare activities. Most federal funding for these activities comes from
                                   Title IV-E of the Social Security Act and is devoted primarily to paying for
                                   the room and board of children in foster care—known as foster care
                                   maintenance payments. Title IV-B dollars can also be used for foster care
                                   maintenance payments, but are more frequently used for other types of
                                   services. As the Congress has enacted various pieces of legislation to help
                                   move children from foster care into permanent homes more quickly, it has
                                   emphasized the need for states to use Title IV-B funding to provide



                                   1
                                     Child protective services activities typically include reviewing reports of alleged child
                                   abuse and neglect, investigating those that meet the state’s criteria as a potential incident
                                   of abuse or neglect to determine if the alleged incident occurred, and, in some cases,
                                   referring families to needed services and removing the child from the home, if necessary.
                                   2
                                       States are required to provide matching funds in order to receive federal Title IV-B dollars.



                                   Page 1                                           GAO-03-956 Title IV-B Child Welfare Services
supportive services needed to preserve and reunify families. In 1980, for
example, the Congress increased appropriations for subpart 1, but enacted
limits on the use of these funds for foster care maintenance payments and
adoption assistance payments to encourage states to use the additional
funding for services to families.3 In addition, while states could already use
subpart 1 funds for services targeted in the new subpart 2 program, the
creation of subpart 2 was motivated in part by the fact that few states used
a significant share of their subpart 1 funds for these types of services. The
Department of Health and Human Services’ (HHS) Administration for
Children and Families is currently developing a child welfare option that
would allow states to use Title IV-E funds for the same range of services
allowed under Title IV-B.

Because of your interest in the services states are providing to meet the
needs of families,4 you asked us to examine the following: (1) How do the
services provided and populations served under subpart 1 compare with
those under subpart 2? (2) What has the federal government’s role been in
overseeing the use of Title IV-B subpart 1 funds? (3) What does the
research say about the effectiveness of services unique to subpart 1?

To answer these questions, we sent two surveys to child welfare directors
to obtain information on how they use Title IV-B funds. To obtain a
breakdown of state spending for subparts 1 and 2, we sent the first survey
to all 50 states and the District of Columbia and received responses from
47 states.5 We sent the second survey to the 30 states that provided
sufficient data on their first survey within the timeframe that allowed us to
conduct the second survey. We received responses from 17 states,
providing detailed information on the 3 services they reported as receiving
the most subpart 1 funding and the 3 services they reported as receiving
the most subpart 2 funding. Because the data from these states may not be
representative of all states, we have used data from the second survey to
provide examples of the types of children and families served by


3
  Adoption assistance payments are provided to parents adopting a child with special needs,
such as a physical or mental disability, to assist with the costs of services required to meet
the child’s needs. The subpart 1 limits also apply to child care services to support a parent’s
employment or training.
4
  This report focuses primarily on subpart 1 because little, if any, research has been
conducted on how subpart 1 funds have been spent on child welfare services. In contrast, a
number of studies have been conducted on the services provided under subpart 2.
5
We did not receive responses from the District of Columbia, Indiana, Kentucky, or
Montana.




Page 2                                        GAO-03-956 Title IV-B Child Welfare Services
                   Title IV-B. We also conducted site visits in California, New Jersey, Ohio,
                   and Washington, where we interviewed state and local officials and
                   service providers to obtain more in-depth information on the services
                   provided and the types of children and families served. These states
                   represent both geographic diversity and diversity in how states used
                   subpart 1 funds. In addition, these states were identified as using
                   innovative CPS tools or processes. Further, we reviewed applicable laws
                   and regulations; interviewed HHS central and regional office officials
                   about their oversight activities with regard to Title IV-B; reviewed results
                   from HHS’s assessments of state child welfare agencies, known as Child
                   and Family Services Reviews (CFSR); reviewed the literature assessing the
                   effectiveness of child welfare services; and interviewed child welfare
                   experts.


                   On a national level, our survey showed that the primary emphases of
Results in Brief   subparts 1 and 2 vary somewhat, but the range of services offered and the
                   types of families served overlap significantly. Our survey found that no
                   single category of service was funded solely by subpart 1 or subpart 2 in
                   fiscal year 2002. In response to our survey, states reported spending about
                   28 percent of subpart 1 funds on the salaries of child welfare agency
                   staff—primarily social work staff who can provide a variety of services,
                   including CPS investigations, recruiting foster parents, and referring
                   families for needed services. The next three largest spending categories—
                   administration and management expenses, such as rent and utilities; CPS
                   services; and foster care maintenance payments—accounted for about
                   43 percent of subpart 1 spending. In comparison, states spent over
                   80 percent of subpart 2 dollars on the four mandated service categories—
                   family support, family preservation, family reunification, and adoption
                   promotion and support services. States reported funding services with
                   subparts 1 and 2 that serve similar populations—primarily children at risk
                   of abuse and neglect and their parents, as well as children living in foster
                   care and their parents. While none of the four states we visited could
                   provide data on the extent to which the same families participated in
                   services funded by subparts 1 and 2, officials in three of these states
                   believed that the two subparts generally served the same types of children
                   and families. Officials in almost all HHS regional offices said that they
                   believe that the two subparts offer a good balance in allowing states some
                   flexibility to address state needs and targeting some federal funds toward
                   services to keep families together.

                   HHS’s oversight focuses primarily on states’ overall child welfare systems
                   and outcomes, but the agency provides relatively little oversight specific to


                   Page 3                               GAO-03-956 Title IV-B Child Welfare Services
subpart 1. For example, HHS regional offices work with states to establish
overall goals to improve the safety, permanency, and well-being of
children and measure progress toward those goals. Using its CFSR
process, HHS also evaluates how well states are achieving positive
outcomes for children and has found that many states do not have strong
outcomes with regard to providing the services families need. However,
HHS has limited knowledge about how states spend their subpart 1 funds.
HHS does not collect data on subpart 1 expenditures, requiring instead
that states submit annual estimates about how they plan to use their
subpart 1 funds in the upcoming year. HHS regional offices reported that
they review these estimates for relatively limited purposes, such as
ensuring that states provide required matching funds. Several HHS
officials noted that they do not review the spending plans for subpart 1 as
closely as subpart 2 because subpart 1 has few restrictions on how funds
can be used. We also found that HHS regional offices pay little attention to
statutory limits on the use of subpart 1 funds for foster care maintenance
and adoption assistance payments.6 For example, 9 of HHS’s 10 regional
offices do not monitor states’ compliance with these limits. As a result,
HHS approved projected 2002 spending plans for 15 states with planned
spending amounts that exceeded these limits. In response to our survey,
10 states reported a total of over $15 million in actual 2002 subpart 1
expenditures that exceeded the spending limits and were thus out of
compliance with the law.

Little research is available on the effectiveness of unique services funded
by subpart 1 at the state level because few states have evaluated these
services. While our survey data reveal no unique categories of services
funded by subpart 1 on a national level, 37 states generally reported 1 or
2 categories of services that were uniquely funded by subpart 1 within
their state—that is, they used subpart 1, but not subpart 2, to fund services
in particular categories. The most common unique categories were CPS,
foster care maintenance payments, and staff salaries. Within the CPS
category, for example, unique services include professional assessments of
a caregiver’s parenting skills, telephone hotlines to report child abuse and
neglect, and short-term shelter placement services. We contacted the



6
 The statutory limit also includes payments for child care services required due to a
parent’s employment or training needs. However, only 2 states reported any planned
subpart 1 spending on this type of child care service for fiscal year 2002. For this report, we
mention only foster care maintenance and adoption assistance payments when referring to
subpart 1 limits, although we did include planned spending on child care in our analyses of
states’ planned subpart 1 spending.




Page 4                                        GAO-03-956 Title IV-B Child Welfare Services
             states with unique service categories other than administration, salaries,
             and foster care maintenance and adoption assistance payments and none
             of these states had conducted rigorous evaluations of these services,
             although several states provided some outcomes data for the services
             included in these categories. Our literature review on the effectiveness of
             child welfare practices identified research for some of these unique
             service categories, such as certain family preservation programs, but only
             two specific services included in a unique subpart 1 category were
             identified in the research. For example, research on a service that works
             with parents to prepare their children for school and to enhance parent-
             child interactions has shown mixed results.

             We are recommending that the Secretary of HHS (1) provide the necessary
             guidance to ensure that HHS regional offices are providing appropriate
             oversight of subpart 1, (2) consider the feasibility of collecting basic data
             on states’ use of these funds to facilitate its oversight of the program and
             to provide guidance to help states determine appropriate services to fund,
             and (3) use the information gained through enhanced oversight of subpart
             1 to inform its design of the child welfare option that would allow states to
             use Title IV-E funds for the same range of services allowed under
             Title IV-B. HHS’s Administration for Children and Families (ACF)
             generally agreed with our findings, but did not fully concur with our
             recommendations. While ACF agreed with our recommendation to provide
             the necessary guidance to ensure that its regional offices monitor states’
             use of Title IV-B subpart 1 funds, it said that these limits no longer serve a
             useful purpose. ACF disagreed with our recommendation to consider
             collecting data on subpart 1 expenditures. ACF believes its current level of
             oversight is commensurate with the scope and intent of subpart 1, noting
             that its oversight efforts are more appropriately focused on the CFSR
             process. We believe, however, that assessing the feasibility of collecting
             some basic data on states’ subpart 1 expenditures could enhance ACF’s
             overall oversight of states’ child welfare operations and outcomes. ACF
             did not comment on our recommendation to use such data to inform the
             design of its child welfare option.


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


             Page 5                                GAO-03-956 Title IV-B Child Welfare Services
Title IV-B. The amount of subpart 1 funds a state receives is based on its
population under the age of 21 and the state per capita income, while
subpart 2 funding is determined by the percentage of children in a state
who receive food stamps.

In fiscal year 2003, the Congress appropriated $292 million for subpart 1
and $405 million for subpart 2. These federal funds cover 75 percent of
states’ total Title IV-B expenditures because states must provide an
additional 25 percent using nonfederal dollars. Title IV-B funding is
relatively small compared with the other federal and state funds used for
child welfare services. According to the most recent data available, states
spent an estimated $10.1 billion7 in state and local funds for child welfare
services in state fiscal year 2000, while federal Title IV-E expenditures in
federal fiscal year 2000 were $5.3 billion. In comparison, Title IV-B
appropriations in federal fiscal year 2000 were $587 million. Title IV-E8
provides an open-ended individual entitlement for foster care maintenance
payments to cover a portion of the food, housing, and incidental expenses
for all foster children whose parents meet certain federal eligibility
criteria.9 Title IV-E also provides payments to adoptive parents of eligible
foster children with special needs.10 States may choose to use Title IV-B
funds to provide foster care maintenance or adoption assistance payments




7
 Urban Institute, The Cost of Protecting Vulnerable Children III: What Factors Affect
States’ Fiscal Decisions? (Washington, D.C.: n.d.).
8
 In fiscal year 2002, total Title IV-E spending was approximately $6.1 billion. The state
matching rate for these payments is based on a state’s per capita income and ranges from
50 percent to 83 percent.
9
  States are entitled to Title IV-E reimbursement on behalf of children who would have been
eligible for Aid to Families with Dependent Children (AFDC) (as AFCD existed on July 16,
1996), but for the fact that they were removed from the home of certain specified relatives.
While the AFDC program was replaced by the Temporary Assistance for Needy Families
program in 1996, eligibility for Title IV-E payments remains tied to the income eligibility
requirements of the now defunct AFDC program. In addition, certain judicial findings must
be present for the child, and all other requirements included in section 472 (a) and (b) of
the Social Security Act must be met, in order for the child to be eligible for Title IV-E foster
care maintenance payments.
10
  Special needs are characteristics that can make it difficult for a child to be adopted and
may include emotional, physical, or mental disabilities, emotional disturbance, age, or
being a member of a minority race. To qualify for an adoption subsidy under Title IV-E, a
state must determine that the child cannot or should not return home; a state must make a
reasonable, but unsuccessful effort to place the child without the subsidy; and a specific
factor or condition must exist that makes it difficult to place the child without a subsidy.




Page 6                                         GAO-03-956 Title IV-B Child Welfare Services
                for children without regard to their eligibility for these payments under
                Title IV-E.11

                The Administration for Children and Families within HHS is responsible
                for the administration and oversight of federal funding to states for child
                welfare services under Titles IV-B and IV-E. HHS headquarters staff are
                responsible for developing appropriate policies and procedures for states
                to follow in terms of obtaining and using federal child welfare funds, while
                staff in HHS’s 10 regional offices are responsible for providing direct
                oversight of state child welfare systems.

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


Subpart 1       Subpart 1 provides grants to states for child welfare services, which are
                broadly defined. Subpart 1 funds are intended for services that are
                directed toward the accomplishment of the following purposes:

            •   protect and promote the welfare of all children;

            •   prevent or remedy problems that may result in the abuse or neglect of
                children;




                11
                 Foster care maintenance payments funded by Title IV-B would require 25 percent in
                matching state funds.




                Page 7                                     GAO-03-956 Title IV-B Child Welfare Services
            •   prevent the unnecessary separation of children from their families by
                helping families address problems that can lead to out-of-home
                placements;

            •   reunite children with their families;

            •   place children in appropriate adoptive homes when reunification is not
                possible; and

            •   ensure adequate care to children away from their homes in cases in which
                the child cannot be returned home or cannot be placed for adoption.

                When the Congress enacted the Adoption Assistance and Child Welfare
                Act of 1980, it established a dollar cap on the amount of subpart 1 funds
                that states could use for certain services and created Title IV-E of the
                Social Security Act. This legislation limited the total subpart 1 funds states
                could use for three categories of services: foster care maintenance
                payments, adoption assistance payments, and child care related to a
                parent’s employment or training. While appropriations for subpart 1
                increased from $56.5 million in 1979 to $163.6 million in 1981, the law
                requires that the total of subpart 1 funds used for foster care maintenance,
                adoption assistance, and child care payments cannot exceed a state’s total
                1979 subpart 1 expenditures for all types of services. The intent of this
                restriction, according to a congressional document, was to encourage
                states to devote increases in subpart 1 funding as much as possible to
                supportive services that could prevent the need for out-of-home
                placements.12 However, this restriction applies only to the federal portion
                of subpart 1 expenditures, as the law notes that states may use any or all
                of their state matching funds for foster care maintenance payments.


Subpart 2       In 1993, the Congress established the family preservation and family
                support program under Title IV-B subpart 2, authorizing grants to states to
                provide two categories of services: family preservation and community-
                based family support services. The Adoption and Safe Families Act of
                1997 reauthorized the program, renaming it Promoting Safe and Stable
                Families and adding two new service categories: adoption promotion and
                support services and time-limited family reunification services. Through


                12
                 Staff of the House Committee on Ways and Means, 106th Congress, Background Material
                and Data on Programs Within the Jurisdiction of the Committee on Ways and Means
                (Comm. Print 2000).




                Page 8                                   GAO-03-956 Title IV-B Child Welfare Services
    fiscal year 2006, the Congress has authorized $305 million in mandatory
    funding for subpart 2 and up to $200 million annually in additional
    discretionary funding. In fiscal year 2002, the Congress appropriated
    $70 million in discretionary funding for the program.13

    The definitions of the four subpart 2 service categories are:

•   Family preservation services: Services designed to help families at risk or
    in crisis, including services to (1) help reunify children with their families
    when safe and appropriate; (2) place children in permanent homes
    through adoption, guardianship, or some other permanent living
    arrangement; (3) help children at risk of foster care placement remain
    safely with their families; (4) provide follow-up assistance to families
    when a child has been returned after a foster care placement; (5) provide
    temporary respite care; and (6) improve parenting skills.

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

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

•   Adoption promotion and support services: Services designed to
    encourage more adoptions of children in foster care when adoption is in
    the best interest of the child, including services to expedite the adoption
    process and support adoptive families.

    These services are similar to those allowed under subpart 1, although the
    range of services allowed under subpart 2 is more limited in some cases.


    13
      Some subpart 2 funds are reserved for specific activities. For example, $10 million in
    mandatory funds and 3.3 percent of discretionary funds in each fiscal year are reserved for
    grants to state courts to improve child welfare proceedings. In addition, 1 percent of
    mandatory funds and 2 percent of discretionary funds are reserved for grants to Indian
    tribes.




    Page 9                                       GAO-03-956 Title IV-B Child Welfare Services
                          For example, time-limited family reunification services can only be
                          provided during a child’s first 15 months in foster care, while no such
                          restriction is placed on the use of subpart 1 funds. In addition, states must
                          spend a “significant portion” of their subpart 2 funds on each of the four
                          service categories. HHS program instructions require states to spend at
                          least 20 percent of their subpart 2 funds on each of the four service
                          categories, unless a state has a strong rationale for some other spending
                          pattern. By statute, states can spend no more than 10 percent of
                          subpart 2 funds on administrative costs. A congressional document notes
                          that states already had the flexibility to use subpart 1 funds for family
                          support and family preservation services, but that few states used a
                          significant share of these funds for these services.14 In creating
                          subpart 2, the Congress did not revise any components of subpart 1.

State Plan Requirements   To receive Title IV-B funds, states are required to submit a 5-year child and
for Subparts 1 and 2      family services plan to HHS. These plans have a number of specific
                          reporting and procedural requirements. While several of the requirements
                          are similar for subparts 1 and 2, states are required to provide information
                          about more aspects of their child welfare systems under subpart 1. Some
                          of the major requirements are outlined in table 1.




                          14
                           Staff of the House Committee on Ways and Means, 106th Congress, Background Material
                          and Data on Programs Within the Jurisdiction of the Committee on Ways and Means
                          (Comm. Print 2000).




                          Page 10                                  GAO-03-956 Title IV-B Child Welfare Services
Table 1: Selected Requirements to Obtain Grants under Subparts 1 and 2 of Title IV-B

 Subpart 1                                                                             Subpart 2
 To receive subpart 1 funding, states must submit to HHS a 5-                          •   To receive subpart 2 funding, states must submit to HHS a 5-year
 year plan outlining the goals of the child welfare agency and                             plan outlining the goals of the child welfare agency and annual
 annual reports describing the progress made toward those                                  reports describing the progress made toward those goals. In this
 goals. In this plan, states must:                                                         plan, states must:
 • Specify the goals that will be accomplished by the end of                           •   Specify the goals that will be accomplished by the end of the 5-year
   the 5-year plan, specific and measurable objectives that will                           plan, specific and measurable objectives that will be undertaken to
   be undertaken to achieve each goal, and describe the                                    achieve each goal, and describe the methods to be used in
   methods to be used in measuring annual progress in                                      measuring annual progress in meeting these goals.
   meeting these goals.
 •   Describe the child welfare services provided and the                              •   Describe the child welfare services provided and the geographic
     geographic areas where they are available.                                            areas where they are available and the populations to be served.
 •   Describe the steps taken to provide child welfare services                        •   Describe how subpart 2 funds will be used to develop or expand
     and to make progress in developing new services and                                   services covered by subpart 2.
     expanding access to services.
 •   Consult with appropriate public and community-based                               •   Consult with appropriate public and community-based
     organizations in designing programs.                                                  organizations in designing programs.
 •   Ensure that the state will administer the plan in accordance                      •   Ensure that the state will administer the plan in accordance with
     with methods determined by HHS to be proper and                                       methods determined by HHS to be proper and efficient.
     efficient.
 •   Provide reports and participate in evaluations as required                        •   Provide reports and participate in evaluations as required by HHS.
     by HHS.
 •   Describe activities undertaken for children adopted from                          •   Ensure that the safety of children will be the paramount
     other countries and report certain data on those children                             concern in administering and conducting services.
     who enter state custody due to the disruption or dissolution
     of such an adoption.
 •   Ensure that the state will develop plans for the effective use                    •   Ensure that, at the end of the 5-year period covered by the
     of cross-jurisdictional resources to facilitate timely                                state’s child welfare plan, states review with appropriate public
     adoptions for children waiting to be adopted.                                         and community-based organizations the progress made
                                                                                           toward goals, publish a report on the progress, and develop
                                                                                           new goals for the program.
 •   Provide for the diligent recruitment of foster and adoptive                       •   Ensure that federal funds provided under subpart 2 will not
     families that reflect the racial and ethnic diversity of children                     supplant federal or nonfederal funds for existing services that
     in the state who need foster or adoptive homes.                                       promote the purposes of subpart 2.
 •   Describe specific measures taken to comply with the Indian                        •   Ensure that no more than 10 percent of expenditures will be
     Child Welfare Act.                                                                    used for administrative costs.
 •   Ensure that the state has implemented policies and                                •   Explain how organizations were selected to provide family
     procedures that allow expeditious decisions about                                     support services and how these organizations meet the
     permanent placement for children who are abandoned at                                 requirement that family support services be community based.
     birth.
 •   Ensure that the state operates a case review system for
     each child in state-supervised foster care.
 •   Ensure that the state operates a statewide information
     system to provide information about children in foster care.
Source: Title IV-B of the Social Security Act and 45 CFR 1357.

                                                                 Note: Bolded text indicates where subpart 2 requirements differ from those pertaining to subpart 1.




                                                                 Page 11                                           GAO-03-956 Title IV-B Child Welfare Services
Alternative Financing   Federal child welfare funding has long been criticized for entitling states
Mechanisms for Child    to reimbursement for foster care placements, while providing little funding
Welfare Services        for services to prevent such placements. HHS is currently developing a
                        legislative proposal to give states more flexibility in using Title IV-E foster
                        care funds for such preventive services. Under this new proposal, states
                        could voluntarily choose to receive a fixed IV-E foster care allocation
                        (based on historic expenditure rates) over a 5-year period, rather than
                        receiving a per child allocation. The fixed allocation would be an estimate
                        of how much a state would have received in Title IV-E foster care
                        maintenance funds. States could use this allocation for any services
                        provided under Titles IV-B and IV-E, but would also have to fund any
                        foster care maintenance payments and associated administrative costs
                        from this fixed grant or use state funds.

                        Since 1994, HHS has also been authorized to establish child welfare
                        demonstrations that waive certain restrictions in Titles IV-B and IV-E and
                        allow states a broader use of federal funds. States with an approved
                        waiver must conduct a formal evaluation of the project’s effectiveness and
                        must demonstrate the waiver’s cost neutrality—that is, a state cannot
                        spend more in Title IV-B and IV-E funds than it would have without the
                        waiver. Projects generally are to last no more than 5 years. HHS’s authority
                        to approve these waivers is scheduled to expire at the end of fiscal year
                        2003.


                        On a national level, our survey showed that the primary emphases of
The Primary             subparts 1 and 2 vary somewhat, but the range of services offered and the
Emphases of These       types of families served overlap significantly. According to our survey data
                        for fiscal year 2002, states spent subpart 1 funds most frequently on the
Subparts Vary           salaries of child welfare agency staff—primarily social work staff who can
Somewhat, but the       provide a variety of services, such as CPS investigations, recruiting foster
                        parents, and referring families for needed services. The next three largest
Range of Services and   categories—administration and management expenses, CPS services, and
Types of Families       foster care maintenance payments—accounted for about 43 percent of
Served Overlap          subpart 1 funding. Subpart 2 funds, in comparison, were used primarily to
                        fund programs within its required service categories—family support,
Significantly           family preservation, family reunification, and adoption promotion and
                        support services. Some social work staff whose salaries were funded with
                        subpart 1 may provide similar services to families as the staff in these
                        programs funded by subpart 2. On a national basis, however, no service
                        category was solely funded by either subparts 1 or 2. The programs funded
                        by subpart 1 and 2 dollars served similar types of children and families.
                        States used the majority of funds from each subpart to provide services to


                        Page 12                               GAO-03-956 Title IV-B Child Welfare Services
                            children at risk of abuse and neglect and their parents, as well as foster
                            children and their parents. Officials in most HHS regional offices said that
                            they believe that the current structure of Title IV-B offers a good balance
                            in allowing states some flexibility to address state needs and targeting
                            some federal funds toward services to keep families together and prevent
                            children from entering foster care.


While the Distribution of   Although no category of service is funded solely by either subparts 1 or
Funds Differs Somewhat,     2 dollars, somewhat different spending patterns emerged with regard to
Some Overlap in Service     the distribution of these funds among the categories. The states
                            responding to our survey reported spending about 28 percent of subpart 1
Categories Exists           funds in fiscal year 2002 on the salaries of child welfare agency staff, with
                            an additional 43 percent used for administration and management
                            expenses, foster care maintenance payments, and direct CPS services (see
                            table 2). In comparison, states used over 80 percent of subpart 2 dollars to
                            fund services in its mandated service categories—family support, family
                            preservation, family reunification, and adoption promotion and support
                            services.15 However, neither subparts 1 nor 2 funded a unique category of
                            service at the national level.16 For example, states typically reported using
                            subpart 1 to fund CPS programs; however, 5 states used subpart 2 dollars
                            to fund programs in this category.




                            15
                              The adoption promotion and support services category includes the recruitment and
                            training of foster and adoptive parents, adoption support services, and adoption
                            preservation services.
                            16
                             Although no unique service categories are funded exclusively by either subpart at the
                            national level, states did report individual service categories that were funded by subpart 1,
                            but not subpart 2. However, no national trend emerged among the types of services that
                            were funded uniquely by subpart 1.




                            Page 13                                       GAO-03-956 Title IV-B Child Welfare Services
Table 2: Fiscal Year 2002 Expenditures for Subparts 1 and 2 Service Categories

                                             Subpart 1                                                     Subpart 2
                                                              Percentage of                                                  Percentage of
                           Number of        Amount of             subpart 1         Number of       Amount of subpart            subpart 2
                                                      a                                                              a                    b
 Service category             states subpart 1 funding             funding             states              2 funding              funding
 Staff positions                  25          $70,965,578                 27.6                17              $6,229,058                   2.4
 Administration and
 management                       16           43,143,097                 16.8                18              11,614,667                   4.5
 Child protective
 services                         17           40,543,000                 15.8                 5               2,248,690                   0.9
 Foster care
 maintenance payments             17           27,890,783                 10.8                 2                 647,154                   0.3
 Multiple responsesc               8           25,806,347                 10.0                 4               3,503,585                   1.4
 Family
 support/prevention               17           19,840,891                   7.7               28            127,430,496                  49.8
 Counseling and mental
 health services                   2            8,350,562                   3.2                 5              1,354,763                   0.5
 Family preservation               7            5,986,045                   2.3               23              30,308,896                 11.8
 Adoption subsidy
 payments                          7            4,657,546                   1.8                2                 737,412                   0.3
 Family reunification              4            2,446,570                   1.0               26              23,625,973                   9.2
 Recruitment and
 training for
 foster/adoptive parents           9            2,260,061                   0.9               16               6,828,885                   2.7
 Adoption support and
 preservation services             2               446,877                  0.2               27              28,481,585                 11.1
 Other                            11            4,817,180                   1.9               15              12,795,915                   5.0
         d
 Total                                       $257,154,537              100.0%                              $255,807,079               100.0%
Source: GAO survey.

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

                                         Data on subpart 1 expenditures are based on survey responses from 46 states and data on subpart 2
                                         expenditures are based on survey responses from 44 states. While Pennsylvania responded to our
                                         survey, it did not provide expenditure data for subparts 1 or 2.
                                         a
                                          When providing data for our survey, states were asked to indicate the single service category that
                                         best described the type of program funded by subparts 1 and 2. Thus, programs that fall into multiple
                                         service categories may not be fully captured. For example, one state indicated it funded a family
                                         support program, which includes some family preservation and reunification services. In addition,
                                         states may not have been consistent in categorizing services. For example, several HHS officials told
                                         us that the delineation between family support and family preservation services is not clear, so that
                                         two states providing the same services to the same types of families may report them in different
                                         categories. Inconsistencies such as these could have an effect on any measured differences among
                                         service categories.




                                         Page 14                                          GAO-03-956 Title IV-B Child Welfare Services
b
 States may spend less than 20 percent of their subpart 2 funds on any of the required service
categories if they have a strong rationale. Some HHS regional officials said that they approve
exceptions to the 20 percent requirement if a state is spending a significant amount of nonfederal
funds on a subpart 2 service category.
c
 Although states were asked to indicate the single service category that best described the type of
program funded by subparts 1 and 2, several states selected multiple program categories when
responding to our survey. For example, Rhode Island reported that it funded a home visitation
program and indicated that this program includes family support, health, and family reunification
services. Thus, the responses from states that reported multiple categories for a program are
represented by this category.
d
 The aggregate dollars reported in the service categories do not match the total allocations for
subparts 1 and 2 in fiscal year 2002. States have 2 years to spend their Title IV-B allocations; as a
result, expenditures in fiscal year 2002 may include dollars from a state’s fiscal year 2001 Title IV-B
allocation, as well as its fiscal year 2002 Title IV-B allocation. Similarly, some fiscal year 2002
allocations may not have been spent until fiscal year 2003.


Subpart 1 dollars were most frequently used to fund staff salaries, with
almost half of these funds designated for the salaries of CPS social
workers. Another 20 percent of these funds were used for the salaries of
other social workers (see fig. 1).17 During our site visit, Washington child
welfare officials told us that they used over 50 percent of the state’s
subpart 1 funds for salaries of staff providing direct services, including
CPS social workers, social workers who provide ongoing case
management and support services to families involved with the child
welfare agency due to concerns about abuse or neglect, social work
supervisors, and clerical support staff. While states also reported using
subpart 2 funds for staff salaries, only 2 percent of subpart 2 dollars were
used for this purpose. This comparison may underestimate the overlap in
services funded by subparts 1 and 2, however, because much of the costs
of programs funded by subpart 2 is likely attributable to staff salaries.
Similarly, some social work staff whose salaries are funded by subpart 1
likely provide a variety of services, such as family preservation services,
recruiting foster families, and referring families for needed services, some
of which may be similar to services funded by subpart 2.




17
 The survey data reported in this category reflect the salaries of staff affiliated with the
child welfare agency. These figures do not include the salaries of child welfare agency staff
dedicated to a specific program, which may be embedded within some of the other direct
service categories, such as family support and family preservation. In addition, a state may
use Title IV-B funds to contract with an organization to provide a particular program, which
may include salary expenses as well as direct service expenditures.




Page 15                                            GAO-03-956 Title IV-B Child Welfare Services
Figure 1: Percentage of Subpart 1 Funds Used for Staff Salaries Dedicated to Each
Type of Staff Position in Fiscal Year 2002

                                                           CPS social workers/staff
                                                           3%
                                                           Supervisory social workers
                                                           3%
                                                           Legal services staff
                                                           4%
                                                           Administrative staff

                           • •   •
                                      •                    4%
                                                           Management staff
          •
         47%
                                     20% •                 Other staff




                            20% •                          All other social workers



Source: GAO survey data.

Notes: Some states spent subpart 1 funds on salaries, but could not provide information on the types
of staff positions included.

Percentages do not total to 100 due to rounding.


Administration and management comprised the second largest category of
service, accounting for almost 17 percent of subpart 1 dollars. These
services included rent and utilities for office space, travel expenses for
agency staff, and staff training.18 Ohio, for example, used most of its
subpart 1 dollars to fund state and county child welfare agency
administrative expenses. In contrast, states spent less than 5 percent of
their subpart 2 funds on administration and management.

CPS represents the third largest category of services that states funded
with subpart 1. States used about 16 percent of their subpart 1 funds to
provide a variety of CPS services, such as telephone hotlines for the public


18
  This amount may be underestimated, since some states may not have separately reported
administrative expenses associated with a specific program. For example, officials in one
state reported that the total spending for a family support program included salaries for
agency staff, overhead expenses, and related staff travel.




Page 16                                            GAO-03-956 Title IV-B Child Welfare Services
to report instances of child abuse and neglect, emergency shelters for
children who needed to be removed from their homes, and investigative
services. During our site visit to California, for example, officials reported
using about 40 percent of their subpart 1 dollars to fund staff salaries and
operating expenses associated with a variety of shelter care services
provided by counties, such as emergency shelters and foster homes. A
child is placed in one of these shelters when no other placement option is
immediately available—for example, when an investigation in the middle
of the night determines that the child is at immediate risk of harm or when
a child runs away from a foster home. In comparison to states’ use of
subpart 1 funds, states reported using less than 1 percent of their
subpart 2 dollars to fund programs within this service category.

States used nearly 11 percent of their subpart 1 funds to make recurring
payments for the room and board of foster children who are not eligible
for reimbursement through Title IV-E. For instance, New Jersey officials
reported spending over 50 percent of the state’s subpart 1 funds on foster
care maintenance payments. Seventeen states spend subpart 1 funds on
foster care maintenance payments, while only 2 states reported using
subpart 2 funds for this purpose, accounting for less than 1 percent of total
subpart 2 expenditures.

States reported using half of their subpart 2 dollars to fund family support
services. These services included mentoring programs to help pregnant
adolescents learn to be self-sufficient, financial assistance to low-income
families to help with rent and utility payments, and parenting classes, child
care, and support groups provided by a community-based resource center.
One California county we visited used subpart 2 to fund a network of
family support services with the goal of strengthening communities and
keeping families from becoming involved with the child welfare system.
Funds were granted to community groups to provide support and improve
the healthy development of families for different populations, such as
grandparent caregivers and adolescent mothers. Washington funded a
network of public health nurses and social service agencies to provide
support services to families that are the subject of a report of abuse or
neglect—these services are provided in lieu of, or following, a formal
investigation when the level of risk to the child is not considered high.
Over one-third of the states responding to our survey also reported using
subpart 1 funds to provide family support services similar to those funded
by subpart 2, although family support services only accounted for
8 percent of subpart 1 expenditures. For example, New Jersey transferred
about 27 percent of its subpart 1 funds to local child welfare agencies to



Page 17                               GAO-03-956 Title IV-B Child Welfare Services
provide family support services, which included parent education classes,
transportation, and mentoring for children.

Family preservation services—designed to keep families together and
prevent the need to place a child in foster care—represented the second
largest service category funded by subpart 2. Washington used
subpart 2 funds for its statewide family preservation program, which
offers counseling and parent training services for up to 6 months to
families with children who are at risk of being placed in foster care. In
some cases, services provided in this category were similar to those in the
family support category, but were intended to help keep families together.
For example, Florida funded several neighborhood resource centers,
which provide child care, parenting classes, adult education and training
opportunities, mental health services, transportation services, and a food
pantry. Although states primarily used subpart 2 dollars to provide these
services, states also reported using approximately 2 percent of subpart 1
funds on family preservation services.

In addition, states reported using about 11 percent of their subpart 2 funds
for adoption support and preservation services. With these funds, states
provided services such as counseling for children who are going to be
adopted, family preservation services to adoptive families, and respite care
for adoptive parents. Officials in Ohio reported using almost half of its
subpart 2 dollars for adoption services, including post adoption services
and services to recruit families for children in need of adoptive homes.
Similarly, Florida funded adoption support services for children with
special needs who are awaiting adoption, including counseling, behavior
modification, tutoring, and other services to expedite the adoption
process. In contrast, less than 1 percent of subpart 1 dollars were used to
provide adoption support and preservation services.

Finally, states spent about 9 percent of their subpart 2 dollars on family
reunification services. States funded a diverse array of family reunification
programs, such as supervised visitation centers for parents to visit with
their children and coordinators for alcohol and drug treatment services for
families whose primary barrier to reunification is substance abuse. New
Jersey funded a supervised visitation program that offers parenting
education, counseling, transportation, and support groups and is located
in a private home, allowing families to visit together in a homelike setting
and engage in more natural interactions. One county we visited in
California used subpart 2 funds for a shared family care program, in which
the parent and child are placed together in a mentor home. The mentor
provides a role model for good parenting behavior and provides hands-on


Page 18                              GAO-03-956 Title IV-B Child Welfare Services
                             parenting guidance to keep the family together, while a case manager
                             ensures that family members receive services to address problems that
                             could lead to the removal of the child, such as substance abuse or
                             homelessness. Subpart 1 funds were used much less frequently for family
                             reunification services; states reported using 1 percent of subpart 1 funds
                             for these services.


Significant Overlap Exists   Significant overlap exists among the types of children and families served
among the Types of           by these subparts, although certain populations are more closely
Children and Families        associated with a particular subpart. Services funded by each subpart
                             predominantly targeted children at risk of abuse or neglect and their
Served by Subparts 1 and 2   parents, as well as children in foster care and their parents. States
                             responding to our survey reported that services funded by subpart 1 in
                             fiscal year 2002 most frequently served children living in foster care and/or
                             their parents, while 9 percent of subpart 2 funds are used for services that
                             target the same population (see table 3). Similarly, while subpart 2
                             services most commonly targeted children at risk of abuse and neglect
                             and/or their parents, about 17 percent of subpart 1 funds were also used
                             for services aimed at this population. In addition, 9 percent of subpart 1
                             funds and 11 percent of subpart 2 funds were used to fund services
                             intended for both of these types of families.




                             Page 19                              GAO-03-956 Title IV-B Child Welfare Services
Table 3: Populations Targeted by Services Funded by Subparts 1 and 2 of Title IV-B in Fiscal Year 2002

                                                   Subpart 1                                                      Subpart 2
                                                     Amount of                                                      Amount of
                                                      subpart 1          Percent of                                  subpart 2           Percent of
 Population served           No. of services           funding             funding        No. of services             funding              funding
 Children in foster care
 and/or their parents                    33         $34,732,673                    42                     46       $15,218,065                         9
 Children at risk of child
 abuse and neglect
 and/or their parents                    28          13,751,328                    17                   133         73,996,404                     44
 Programs serving
 multiple populations                    21          11,949,444                    14                     43        18,119,756                     11
 Children at risk of child
 abuse or neglect and/or
 their parents and
 children living in foster
 care and/or their parents               12           7,077,448                     9                     39        17,606,172                     11
 Programs serving all
 populations                              5           7,513,368                     9                      7        11,028,464                         7
 Children waiting for
 adoption, adopted
 children, and adoptive
 parents                                  9           4,153,271                     5                     54        27,340,372                     16
 Other populations, such
 as delinquent teens and
 foster parents                          10           3,492,142                     4                     16          3,336,070                        2
         a
 Total                                  118         $82,669,674                100%                     338      $166,645,301                  100%
Source: GAO survey.

                                               Note: This analysis is based on survey responses from 35 states with state-administered child welfare
                                               systems that provided population data for their subpart 1 services and 39 states with state-
                                               administered child welfare systems that provided population data for their subpart 2 services.
                                               Therefore, these data can only be generalized to states with state-administered child welfare
                                               systems.
                                               a
                                                The dollar totals in this table do not match those in table 2 because we do not have population data
                                               from states that completed the county-administered survey. Due to the differences in information
                                               available from states with county-administered child welfare systems, we did not request data in the
                                               first county-administered survey on the types of children and families who received services funded
                                               by Title IV-B—these data were to have been obtained on the second survey. In addition, we did not
                                               collect data on the populations served for the category of staff salaries, and we excluded population
                                               data for the category of administration and management expenses since these expenses are not
                                               targeted to a particular population of children and families.




                                               The overlap in populations observed at the national level can also be seen
                                               when looking at the children and families targeted by individual states. We
                                               found that individual states frequently funded programs with each subpart
                                               that served the same types of children and families. For example, all



                                               Page 20                                           GAO-03-956 Title IV-B Child Welfare Services
                                              20 states that used subpart 1 dollars to fund services for children at risk of
                                              abuse or neglect and/or their parents also used subpart 2 dollars to fund a
                                              program serving this same population type (see table 4). Alaska, for
                                              instance, used subpart 1 dollars to fund a broad family support program,
                                              which provided services to children at risk of abuse and neglect and their
                                              parents. The state also used subpart 2 funds to provide another family
                                              support program, which provides similar services to the same types of
                                              children and families. In addition, 17 states funded one or more individual
                                              services with funds from both subparts, so that subparts 1 and 2 were
                                              serving the same children and families.

Table 4: Number of States Using Funds from Each Subpart of Title IV-B to Target Specific Populations

                                                                                                   Number of states       Number of states
                                                                                                  providing services providing services for
                                                           Number of states providing             for this population  this population type
                                                           services for this population          type with subpart 2    with both subpart 1
 Population type                                            type with subpart 1 fundsa                        fundsa   and subpart 2 funds
 Children in foster care or parents with children
 living in foster care                                                                    20                          29                           15
 Children at risk of child abuse or neglect and
 parents with children at risk of child abuse and
 neglect                                                                                  20                          34                           20
 Children waiting for adoption, adopted children,
 and adoptive parents                                                                       8                         26                               5
 Foster parents                                                                             5                          7                               3
Source: GAO survey.

                                              Note: This analysis is based on survey responses from 35 states with state-administered child welfare
                                              systems that provided population data for their subpart 1 services and 39 states with state-
                                              administered child welfare systems that provided population data for their subpart 2 services.
                                              Therefore, these data can only be generalized to states with state-administered child welfare
                                              systems. Due to the differences in information available from states with county-administered child
                                              welfare systems, we did not request data in the first county-administered survey on the types of
                                              children and families who received services funded by Title IV-B—these data were to have been
                                              obtained on the second survey.
                                              a
                                               We did not collect data on the populations served for the category of staff salaries. In addition, we
                                              excluded population data for the category of administration and management expenses since these
                                              expenses are not targeted to a particular population of children and families.




                                              In our second survey, we requested more detailed information about the
                                              populations served by programs funded by subparts 1 and 2, such as
                                              demographic and socioeconomic characteristics. However, few of the
                                              17 states responding to the second survey were able to provide this kind of
                                              data. When asked about selected subpart 1 services, 10 of the 17 states
                                              were able to estimate the extent to which the same children and families



                                              Page 21                                            GAO-03-956 Title IV-B Child Welfare Services
    receiving the identified service funded by subpart 1 also received services
    funded by subpart 2. Of children and families receiving the identified
    subpart 1 service,

•   four states reported that generally none or almost none of the recipients
    also received a service funded by subpart 2,

•   three states reported that generally less than half of the recipients received
    subpart 2 services,

•   one state reported that all or almost all recipients received subpart 2
    services, and

•   two states provided varying estimates for different subpart 1 services.19

    While none of the states we visited were able to provide data about the
    extent to which the same children and families were receiving services
    funded by both subparts 1 and 2, state officials in each of these states
    recognized some overlap among the types of populations participating in
    these services. Officials in California and New Jersey told us that they use
    subpart 1 for services to families that are involved with the child welfare
    agency due to a report of abuse or neglect, while services funded by
    subpart 2 target a broader population, including families who are at risk of
    abusing their children. However, while some of the subpart 2 programs
    these officials described focused on this at risk population, many of them
    were targeted to families who were already involved with the agency.
    Officials at a California child welfare agency told us that all of the services
    provided by subparts 1 and 2 are targeted toward the same high-risk
    communities in which many people are involved with the agency, and they
    considered it likely that families receiving subpart 1 services have also
    received subpart 2 services in the past or will at some time in the future.
    Washington officials noted that children and families involved with the
    child welfare agency may receive multiple services, some of which may be
    funded by subpart 1 and some of which may be funded by subpart 2.
    Finally, although Ohio does not track clients served, one state official
    estimated that the types of children and families served by the programs
    funded by subparts 1 and 2 overlap by 100 percent.


    19
     The second survey requested information about the three services receiving the largest
    portions of subpart 1 funding, so states generally only estimated the extent to which
    recipients of these services also received services funded by subpart 2. These data are not
    necessarily representative of other subpart 1 services or other states.




    Page 22                                      GAO-03-956 Title IV-B Child Welfare Services
                              One New Jersey state official described the services funded by subparts 1
                              and 2 as part of a continuum of child welfare services, such that some
                              population overlap is to be expected. In New Jersey, services funded by
                              subpart 1 target families who are experiencing difficulties that may
                              jeopardize the safety and well-being of their children. Programs funded by
                              subpart 2 may also serve these families. However, they also target families
                              who are not currently having difficulties, but who could become involved
                              with the child welfare agency in the future. In addition, some subpart 2
                              programs serve adopted children, many of whom were previously involved
                              with the child welfare agency and received services funded by subpart 1.
                              None of the states we visited could provide data on the numbers of
                              children and families who participated in services funded by subparts 1
                              and 2 dollars.


HHS Officials Believe Title   Given the overlap observed between the two subparts, we discussed the
IV-B Offers Flexibility       potential advantages and disadvantages of consolidation with HHS
While Targeting Prevention    regional officials and asked states for their perspective on our survey.
                              Officials in almost all of HHS’s regional offices said that Title IV-B should
Activities, and States        maintain its current balance between allowing states some flexibility and
Emphasize the Need for        targeting some resources toward prevention. Officials in all regional
Flexibility                   offices told us that they believe states need some flexibility to use Title IV-
                              B funds to address state specific child welfare needs as is currently the
                              case under subpart 1. One regional office noted that subpart 1 gives states
                              the flexibility to address unexpected circumstances affecting the child
                              welfare system—for example, by developing substance abuse treatment
                              programs to address the needs of parents affected by the cocaine epidemic
                              of the 1980s. Similarly, officials in three states we visited felt strongly that
                              the flexibility to direct the use of subpart 1 funds for state priorities was
                              important and they would not want to lose this flexibility in any
                              consolidated program. Our survey results also indicate that the flexibility
                              to use subpart 1 to meet the needs of their child welfare systems is
                              important to states. For example, when asked about their preference
                              between subparts 1 and 2 with regard to different program components,
                              24 and 26 states, respectively, reported that they preferred subpart 1 when
                              considering (1) spending restrictions on the percentage of funds that can
                              be used for specific services and (2) allowable spending categories (see
                              fig. 2). When asked about the advantages and disadvantages of Title IV-B’s
                              current structure, several states cited the spending restrictions of subpart
                              2 as a disadvantage, while a couple of states mentioned the flexibility
                              associated with subpart 1 as an advantage.




                              Page 23                                GAO-03-956 Title IV-B Child Welfare Services
Figure 2: Survey Data on States’ Preferences between Subparts 1 and 2 of Title IV-B
for Different Program Components


Number of states expressing a preference
30


25


20


15


10


 5


 0
     Formula for           Allowable    Spending           Federal        Reporting      Formula for
     state grant           spending     restrictions       set asides     requirements   Indian tribe
                           categories                                                    grants

              Subpart 1 preferred
              Subpart 2 preferred

              Equally preferred

              Not applicable

Source: GAO survey data.

Note: Data on state preferences are based on responses from 46 states, although they did not all
respond to each item.


At the same time, officials in 8 of HHS’s 10 regional offices also stressed
the importance of subpart 2 to ensure that states use some funds on family
support services and prevention activities to help preserve families and
keep children from entering foster care. Several regional offices expressed
concern that, in the absence of the minimum spending requirements
outlined in subpart 2, states would neglect preventive services, while using
Title IV-B funds for more urgent services, such as CPS or foster care. One
state we visited expressed opposition to consolidation for this reason,
arguing that keeping a separate subpart 2 was important to ensure that
states fund some prevention services. State and county officials in this
state noted that subpart 2 represents an important federal investment in
prevention services and expressed concern that states would use all
available funds to provide services to families already involved with the
child welfare agency unless funds were specifically targeted for services to
support families at risk of abusing or neglecting their children. In addition,




Page 24                                                GAO-03-956 Title IV-B Child Welfare Services
on our survey, several states cited the prevention focus of subpart 2 as an
advantage of Title IV-B’s current structure.

Officials in 8 of HHS’s regional offices said that they believe that the
current structure of Title IV-B offers a good balance between flexibility
and targeting resources toward prevention.20 Officials in the other
2 regional offices told us that Title IV-B provides a good mix of flexibility
and a focus on services considered to be federal priorities. One regional
office noted that a consolidated Title IV-B program could be structured to
offer this balance. For example, a consolidated program could require
some minimum spending levels for the current subpart 2 categories, but
also set aside some funds that states could use for a broader array of child
welfare services. In addition, most of the regional offices did not believe
that consolidation would lead to any significant administrative savings.
For example, several regional offices explained that consolidating the
subparts would not reduce HHS’s oversight responsibilities, while another
noted that consolidation would have little impact on HHS regional or state
offices, which are staffed and organized to manage multiple sources of
funding. Another regional office noted that the planning and reporting
requirements for the two subparts are already consolidated in the planning
documents states submit to HHS.

State and local child welfare officials in one state, along with officials at
2 HHS regional offices, commented that increasing the funds available for
service provision was more critical than consolidating the two subparts.
They believe that states need more federal funds to provide services to
prevent foster care placements, such as an increase in funds available
under Title IV-B or more flexibility to use Title IV-E funds to provide
services, rather than paying primarily for foster care maintenance
payments as it currently does. Since 1994, states have been able to apply
for demonstration waivers to use federal child welfare funds to test
innovative foster care and adoption practices without regard to certain
restrictions in Titles IV-B and IV-E. For example, four states are using
demonstration waivers to create fixed Title IV-E budgets for counties
within the state in which funds can be used more flexibly for prevention
and community-based services not traditionally reimbursed by Title IV-E.


20
  Several officials noted that allowing a little more flexibility with the 20 percent spending
requirement for subpart 2 could provide some additional flexibility to states without having
to seek approval from HHS. For example, staff in one regional office suggested that
requiring states to spend no less than 10 percent and no more than 40 percent of subpart 2
funds in any service category would offer this additional flexibility.




Page 25                                       GAO-03-956 Title IV-B Child Welfare Services
                          However, HHS’s authority to approve such waivers is scheduled to expire
                          at the end of fiscal year 2003. States may soon have another mechanism to
                          use Title IV-E funds to provide preventive services through the child
                          welfare option HHS is currently proposing.


                          HHS’s oversight focuses primarily on states’ overall child welfare systems
HHS Focuses               and outcomes, but the agency provides relatively little oversight specific to
Oversight on Overall      subpart 1. For example, HHS regional offices work with states to establish
                          overall goals to improve the safety, permanency, and well-being of
Child Welfare System,     children and measure progress toward those goals. However, HHS has
but Has Limited           limited knowledge about how states use their subpart 1 funds. HHS does
                          not collect data on subpart 1 expenditures and instead requires states to
Knowledge about           submit annual estimates about how they plan to use their subpart 1 funds
States’ Use of Subpart    in the upcoming year. HHS regional offices reported that they review these
1 Funds                   estimates for relatively limited purposes, with several HHS officials noting
                          that they do not review the spending plans for subpart 1 as closely as
                          subpart 2 because subpart 1 has few restrictions as to how these funds can
                          be used. We also found that HHS regional offices pay little attention to
                          statutory limits on the use of subpart 1 funds for foster care maintenance
                          and adoption assistance payments.21 As a result, HHS approved projected
                          2002 spending plans for 15 states that reported planned spending amounts
                          that exceeded these spending limits. In response to our survey, 10 states
                          reported actual 2002 subpart 1 expenditures that exceeded the spending
                          limits by over $15 million in total.


HHS Focuses Much of Its   HHS focuses much of its programmatic oversight on the overall child
Oversight on States’      welfare system in each state, rather than focusing specifically on subpart 1
Overall Child Welfare     or any other federal funding source. In discussing their oversight of
                          subpart 1, several HHS officials at headquarters and in the regional offices
Systems and Outcomes      emphasized the importance of reviewing the overall child welfare system
                          and the outcomes achieved, rather than scrutinizing individual programs
                          outside of that context. A major component of HHS’s subpart 1 oversight
                          is having the regional offices actively work with states to develop



                          21
                            The statutory limit also includes payments for child care services required due to a
                          parent’s employment or training needs. However, only two states reported any planned
                          subpart 1 spending on this type of child care service for fiscal year 2002. For the purposes
                          of this report, we mention only foster care maintenance and adoption assistance payments
                          when referring to subpart 1 limits, although we did include planned spending on child care
                          in our analyses of states’ planned subpart 1 spending.




                          Page 26                                      GAO-03-956 Title IV-B Child Welfare Services
appropriate goals for their child welfare systems and ensure that available
funds, including subpart 1, are used to support those goals. To receive
Title IV-B funding, HHS requires states to submit a Child and Family
Services Plan, which covers a 5-year period and describes the state’s goals
and objectives toward improving outcomes related to the safety,
permanency, and well-being of children and families. This 5-year plan
includes a description of services and programs the state will pursue to
achieve these goals.

In addition to the 5-year plan, HHS requires states to submit an Annual
Progress and Services Report (APSR) each year to discuss their progress
in meeting the goals outlined in their plans and revise the goals as
necessary. Regional HHS staff review this planning document to ensure
that they meet all the technical requirements outlined in the annual
program instructions issued by HHS. For example, states must certify that,
in administering and conducting services under the 5-year plan, the safety
of the children to be served shall be of paramount concern. In addition,
some regional offices reported that they review the state’s objectives and
goals to determine if they are reasonable, assess the progress the state has
made in achieving these goals and objectives, and determine whether child
welfare services are coordinated with the efforts of other agencies serving
children. Some regional officials noted that states are still struggling to use
these documents appropriately for planning purposes. These officials told
us that instead of focusing on outcomes and collecting data to measure
progress toward those outcomes, frequently states simply describe their
current programs.

In addition to reviewing planning documents, all of the regional offices
consult regularly with states to discuss child welfare issues and provide
technical assistance.22 For example, the regional office may provide
guidance on how to comply with specific program regulations or how to
develop a 5-year plan that will function as a strategic plan for the state’s
child welfare agency. Two regional offices told us that they also conduct
site visits to states as part of their oversight. One regional office reported
visiting states in its region to gain a better understanding of each state’s
child welfare services. This allows the regional office to share good ideas
with other states and to ensure that states are working on areas the


22
  In addition, HHS funds eight national resource centers to disseminate information on best
practices and provide technical assistance to help states implement federal legislation
intended to ensure the safety, permanent placement, and well-being of children who enter
the child welfare system.




Page 27                                     GAO-03-956 Title IV-B Child Welfare Services
                             regional office has identified as in need of improvement. Other regional
                             offices reported that they would like to conduct site visits to states under
                             their purview, but a lack of travel funds prevented them from doing so.

                             The CFSR process is an additional tool HHS uses to ensure that states
                             conform with federal child welfare requirements and to help states
                             improve their child welfare services. Staff at one regional office described
                             the CFSR as a thorough review of the services funded by different federal
                             programs, such as Title IV-B. They consider the CFSR an important
                             complement to a state’s planning documents—it gives them an
                             opportunity to determine whether states are providing the services they
                             report in their planning documents and whether those services are
                             adequate and appropriate to meet the needs of the state’s children and
                             families.

                             CFSR results for the past 2 years indicate that states have not performed
                             strongly in terms of assessing families to determine what services they
                             need and providing those services. While 21 of the 32 states that
                             underwent a CFSR in 2001 or 2002 were considered to have an appropriate
                             array of services for families, HHS found that the accessibility of services
                             was a particular weakness in that many services were either not available
                             statewide or had long waiting lists or other barriers to accessibility. When
                             HHS reviewed case files, however, it determined that 31 of these states
                             needed improvement in terms of assessing family needs and providing
                             services to meet those needs. When asked about HHS’s role in guiding
                             states’ use of subpart 1 funds to address weaknesses identified by the
                             CFSRs, an HHS official told us that the agency provides technical
                             assistance to states to help them determine the most effective use of their
                             resources. However, the official also pointed out that HHS gives states a
                             lot of latitude to determine the most appropriate use of their subpart 1
                             funds and that the agency cannot become too involved in state budget
                             decisions given the complexities of the budget processes for states.


HHS Has Little Information   HHS has little information about states’ use of subpart 1 funds. Each year,
about States’ Use of         HHS requires states to submit a form CFS-101, which includes state
Subpart 1 Funds              estimates of the amount of subpart 1, subpart 2, and other federal funds
                             the state plans to spend in the upcoming year on different categories of
                             services (such as family support or CPS). The descriptions provided by
                             regional office staff of their review of these estimates indicate that they
                             review them for relatively limited purposes. Officials in 4 of the regional
                             offices told us that they generally use the CFS-101 data to ensure that
                             states request the total amount of subpart 1 funds to which they are


                             Page 28                               GAO-03-956 Title IV-B Child Welfare Services
entitled and that they comply with the requirement to match 25 percent of
subpart 1 funds with state funds. Most regional offices indicated that their
reviews of the CFS-101s focus more on subpart 2 than subpart 1. For
example, they reported that they review states’ planned subpart 2
spending more closely to ensure that states are meeting the requirement
that they spend at least 20 percent of funds on each of the service
categories and spend no more than 10 percent of funds for administrative
purposes. Several HHS officials reported that they do not monitor the use
of subpart 1 funds as closely as other federal child welfare funds due to
the relatively small funding amount and the lack of detailed requirements
about how the funds can be used.

Moreover, the CFS-101 estimates may not provide reliable data as to how
states are using subpart 1 funds. HHS officials explained that the
CFS-101 data are estimates and that states’ actual expenditures may vary
from these estimates, as they address unforeseen circumstances. The
timing for submitting the CFS-101 also affects how well states can
estimate their planned subpart 1 spending. HHS requires states to submit
their initial CFS-101 for the upcoming fiscal year by June 30, which forces
states to estimate their planned spending before the final spending
amounts for Title IV-B and other federal funds have been appropriated.23
Some regional officials indicated that they did not know how well states’
CFS-101 estimates reflect their actual subpart 1 spending. We did not
conduct a review of the reasonableness of the data states submit on their
CFS-101s, but we did identify a few instances that suggested that the data
are not always accurate. Two states with county-administered child
welfare systems told us that they do not have reliable data to allow them
to accurately estimate planned spending.24 A child welfare official in one of
these states told us that its CFS-101 data represented its “best guess” as to
how subpart 1 funds will be used, because the state distributes these funds
to county child welfare agencies and does not collect any data on how the


23
  For example, the CFS-101 for fiscal year 2002 was due by June 30, 2001. Because they are
submitted before final appropriations have been enacted, a state might not request the full
amount of funds to which it is entitled, if the final appropriation is greater than the state’s
initial estimate. States must submit a revised CFS-101 by June 30, 2002, to request any
additional fiscal year 2002 Title IV-B funds that might be available to them once
appropriations are finalized. In addition, states can request additional Title IV-B funds if
other states do not use the total funds to which they are entitled.
24
  While most states administer their child welfare systems at the state level, a handful of
states delegate administrative responsibility and substantial control to counties or other
local entities. Several large states, such as California, New York, Ohio, and Pennsylvania,
are county-administered.




Page 29                                        GAO-03-956 Title IV-B Child Welfare Services
                            counties use these funds. The other state told us that its current
                            CFS-101 data are most likely based on county data from several years
                            ago and that counties may now be spending subpart 1 funds on different
                            services.

                            HHS does not require states to provide any additional data about their use
                            of subpart 1 funds, such as their subpart 1 expenditures for specific
                            services.25 As a result, several regional offices noted that they have no way
                            of knowing how states actually spend their subpart 1 funds. An official
                            from one regional office explained that the only way to determine how a
                            state actually uses its Title IV-B funds is to review its financial accounts,
                            which HHS does not do. Some regional officials suggested that it would be
                            helpful to have actual expenditure data for both Title IV-B subparts,
                            especially to determine if states were actually using 20 percent of their
                            subpart 2 funds for each of the four required service categories. Three
                            regional offices indicated that they have begun asking states to provide
                            Title IV-B expenditure data.


HHS Regional Offices Are    Given that HHS’s subpart 1 oversight focuses primarily on a state’s overall
Unaware of Subpart 1        child welfare goals and outcomes, the regional offices pay little attention
Spending Limits or Do Not   to the statutory limits on the use of federal subpart 1 funds for foster care
                            maintenance and adoption assistance payments. Most HHS regional
Enforce Them                offices do not review the CFS-101s for compliance with the statutory
                            limits. In addition, HHS’s annual program instruction, which details what
                            information states must include in their CFS-101 submittals and serves as
                            the basis for the regional offices’ review of subpart 1 spending, does not
                            mention the subpart 1 limits.

                            Only 1 of HHS’s 10 regional offices told us that it compares states’ planned
                            subpart 1 spending reported on the CFS-101 with the actual dollar limit for
                            each state to ensure that states observe the statutory limits. This office
                            used an HHS program instruction for 1979 listing each state’s subpart 1
                            allocation to determine the ceiling on foster care maintenance and



                            25
                              States are required to submit general reports on their total subpart 1 expenditures, but
                            these provide no data on how the funds are actually used. Per instructions from the Office
                            of Management and Budget, agencies must require states receiving federal grants to
                            complete a financial status report (SF 269), providing general information on state
                            expenditures. For example, the form might indicate that a state spent $10 million in
                            subpart 1 funds in a specific fiscal quarter, but it provides no details on how the $10 million
                            was used.




                            Page 30                                       GAO-03-956 Title IV-B Child Welfare Services
adoption assistance payments.26 In contrast, 5 regional offices were
unaware that any limits on the use of subpart 1 funds existed, although
1 of these offices indicated that it generally did not consider it appropriate
for states to use subpart 1 funds for foster care maintenance payments
because subpart 1 should be used to fund services for families.
Nonetheless, this office approved a CFS-101 for 1 state that exceeded the
statutory limits. Four other regional offices were aware that some
limitations with regard to foster care maintenance and adoption assistance
payments existed, but did not ensure that states complied with the limits.

These 4 regional offices provided several reasons for why they did not
monitor states’ planned spending for compliance with the subpart 1 limits.
Two regional offices indicated that HHS had provided no guidance as to
how such limits should be enforced or that no data were available to
calculate subpart 1 limits for each state. The third regional office reported
that it did not have the specific ceiling amounts for each state. However,
officials in this office said they reviewed planned subpart 1 spending for
foster care maintenance and adoption assistance payments on the
CFS-101 to determine if they had increased from the previous year. If the
amounts had not increased, the regional office assumed that someone had
checked the amounts previously and that they were within the limits. This
regional office approved CFS-101s for 2 states in the region that reported
planned subpart 1 spending for foster care maintenance and adoption
assistance payments in excess of the limits. The fourth regional office told
us that, in the past, it had a list of the maximum spending limits for each
state in its region and that it had previously checked states’ CFS-101s to
ensure that planned spending did not exceed the limits. However, the
regional office no longer conducts such reviews; regional officials said that
they consider the limits to be meaningless because state funds spent on
child welfare services greatly exceed subpart 1 funds. In other words, any
attempt to enforce the limits would only lead to changes in how states
accounted for their funds—if a state was spending $1 million in state funds
on CPS investigations and $1 million in subpart 1 funds for foster care
maintenance and adoption assistance payments, the state could simply
switch state and subpart 1 funding so that state funds paid for the foster
care maintenance and adoption assistance payments, while subpart 1
funding paid for CPS investigations.



26
 Each state’s ceiling on the use of subpart 1 funds for foster care maintenance and
adoption assistance payments is based on its total 1979 subpart 1 expenditures for all types
of services.




Page 31                                      GAO-03-956 Title IV-B Child Welfare Services
This lack of review led HHS to approve CFS-101s for 15 states that
reported fiscal year 2002 planned subpart 1 expenditures for foster care
maintenance and adoption assistance payments that exceeded the
statutory limits (see fig. 3).27 The dollar amounts by which the subpart 1
spending estimates surpassed the limits were small in some cases, but
large in others. For example, Georgia reported that it planned to spend
$1,497,000 of subpart 1 funds for these purposes in 2002, which would
exceed its statutory limit by $1,558. At the other extreme, Florida’s CFS-
101 indicated that it planned to spend over $9 million, which was more
than $7 million over the maximum allowable spending of $1.9 million. In
total, these 15 states submitted planned subpart 1 spending estimates for
foster care maintenance and adoption assistance payments that would
exceed the statutory limits by over $30 million. Moreover, 13 of these
15 states submitted fiscal year 2003 CFS-101s with planned subpart 1
spending above the statutory ceiling, which were approved by HHS.




27
  In most cases, we reviewed the final revised CFS-101 approved by HHS. For 1 state,
however, we used the initial CFS-101 approved by HHS because it included planned
subpart 1 expenditures that exceeded the limits for foster care and adoption assistance
payments. Although the revised CFS-101 did not show that the state planned to exceed the
limit, we used the initial CFS-101 to show that HHS had previously approved a spending
plan that did not comply with the statutory limits. In addition, we were unable to determine
whether the planned fiscal year 2002 subpart 1 spending for 5 other states exceeded the
limits because HHS approved their CFS-101s with flawed data. These 5 states—Iowa,
Nevada, New Hampshire, New Jersey, and New Mexico—all reported planned subpart 1
spending for foster care maintenance and adoption assistance payments in excess of the
statutory limits. However, although states are supposed to separately estimate planned
spending for the federal portion of their subpart 1 funds on the CFS-101, these 5 states
included the state match and/or other funds in their estimates. In these cases, we could not
determine whether the spending plans exceeded the statutory limits for federal subpart 1
funds. States are allowed to use all of their state matching funds for foster care
maintenance or adoption assistance payments.




Page 32                                      GAO-03-956 Title IV-B Child Welfare Services
Figure 3: Fifteen States with Approved CFS-101s with Fiscal Year 2002 Subpart 1 Spending Estimates that Exceeded Limits
for Foster Care Maintenance and Adoption Assistance Payments


Dollars in millions

$10,000,000




 $8,000,000




 $6,000,000




 $4,000,000




 $2,000,000




          $0
               Ala.        Conn.    Fla.   Ga.   Hawaii    Kans.     Md.        Mich.      Miss.     Nebr.      N.Y.       Pa.        S. Dak.    Tenn.      Wyo.

                                                           Statutory limit on total subpart 1 spending for foster care maintenance and adoption assistance payments

                                                           Combined subpart 1 planned spending for foster care maintenance and adoption assistance payments (as
                                                           reported on CFS-101)
Source: GAO analysis of HHS data.



                                                 Several regional offices noted that they judge the appropriateness of
                                                 subpart 1 spending on foster care maintenance and adoption assistance
                                                 payments in the context of a state’s overall child welfare system. For


                                                 Page 33                                                 GAO-03-956 Title IV-B Child Welfare Services
example, these regional offices said that they are not concerned about a
state planning to spend significant proportions of its subpart 1 funds on
foster care maintenance and adoption assistance payments if they believed
the state had a strong child welfare system with an appropriate array of
services. Regional office staff said they would, however, ask a state to
reconsider its funding strategy if the state were performing poorly.
However, many of the states with approved CFS-101 subpart 1 estimates
above the statutory ceilings did not achieve strong outcomes on their
CFSR evaluations with regard to providing needed services and having an
appropriate array of services. HHS has conducted CFSRs on 12 of the
15 states with approved CFS-101s over the subpart 1 spending limits and
determined that appropriately assessing family needs and providing
services to address those needs was an area needing improvement in 11 of
the 12 states. In addition, 6 of the 12 states were also determined to need
improvement in terms of having an appropriate array of services to meet
the needs of families in the state.28

We also compared our survey data on states’ fiscal year 2002 subpart 1
expenditures for foster care maintenance and adoption assistance
payments with the statutory limits and found that 10 states reported
spending subpart 1 funds on these payments that exceeded the legal limits
(see fig. 4). As with their planned spending estimates, states’ subpart 1
actual spending for foster care maintenance and adoption assistance
payments exceeded the statutory limits by varying amounts. Michigan, for
example, reported on our survey that it spent over $6 million on foster
care maintenance payments in fiscal year 2002—well over its $2.2 million
limit for such payments—while New Hampshire’s use of subpart 1 for
foster care maintenance and adoption assistance payments was only about
$27,000 above its limit. In total, these 10 states reported subpart 1
expenditures for foster care maintenance and adoption assistance
payments that exceeded the statutory limits by over $15 million. Our
survey results may underestimate the number of states with subpart 1
spending over the statutory limits, because several states reported on our
survey that they used subpart 1 for foster care maintenance or adoption
assistance payments, but were not able to identify the specific dollar
amount of subpart 1 funds used for these purposes.



28
 Nine of the 12 states were also cited as needing improvement in ensuring that needed
services are accessible to families in all areas of the state and 8 of the 12 states were
categorized as needing improvement in terms of individualizing services to meet the unique
needs of individual families.




Page 34                                     GAO-03-956 Title IV-B Child Welfare Services
Figure 4: Ten States That Reported Fiscal Year 2002 Subpart 1 Expenditures Exceeding Limits for Foster Care Maintenance
and Adoption Assistance Payments


Dollars in millions
$7,000,000




$6,000,000




$5,000,000




$4,000,000




$3,000,000




$2,000,000




$1,000,000




         $0
              Colo.            Fla.            Kans.      Mich.             Nev.             N.H.             N.J.             N. Mex.         Okla.            S. Dak.


                                                                  Statutory limit on total subpart 1 spending for foster care maintenance and adoption assistance payments

                                                                  Combined subpart 1 expenditures for foster care maintenance and adoption assistance payments (as
                                                                  reported on GAO’s survey)
Source: Analysis of GAO survey and HHS data.



                                                       Four of these 10 states with subpart 1 expenditures over the statutory
                                                       limits were also part of the 15 states with CFS-101s that indicated planned




                                                       Page 35                                                  GAO-03-956 Title IV-B Child Welfare Services
                       spending above the limits.29 The remaining 6 states did not report
                       estimated subpart 1 spending over these limits.30 For example, Colorado
                       did not report any planned subpart 1 spending for foster care maintenance
                       or adoption assistance payments. On our survey, however, the state
                       reported using over $3 million in subpart 1 funds for these purposes, well
                       over its $700,000 limit.


                       Little research is available on the effectiveness of unique services funded
Some Unique Subpart    by subpart 1 because few states have evaluated these services. While our
1 Service Categories   survey data revealed no unique categories of services funded by subpart 1
                       on a national level, 37 states reported categories of services that were
Exist at the State     uniquely funded by subpart 1—that is, the individual state used subpart 1,
Level, but Little      but not subpart 2, to fund services in a particular category. For example,
                       Delaware funded two CPS programs with subpart 1—assessments of a
Research Exists on     caregiver’s parenting ability and legal services to represent the child
the Effectiveness of   welfare agency in court cases—but did not use any subpart 2 funds for this
These Services         service category. We contacted the states with unique service categories in
                       their states (other than administration, staff salaries, adoption assistance
                       payments, or foster care maintenance payments) and none of these states
                       had conducted rigorous evaluations of these services, although several
                       states provided some data on the effectiveness of services included in
                       these categories. Our literature review on the effectiveness of child
                       welfare practices identified research for some of these unique service
                       categories, such as certain types of family preservation programs. With
                       two exceptions, however, it did not identify any evaluations of the specific
                       services included in these categories.

                       The most common service categories for which individual states used only
                       subpart 1 funds were CPS, foster care maintenance payments, and staff
                       salaries. The 37 states generally reported 1 or 2 unique categories, with
                       14 states reporting 1 unique category and 1 state reporting a high of




                       29
                         Of the 15 states with planned spending above the limits, 8 reported subpart 1
                       expenditures within the statutory limits, 4 reported subpart 1 expenditures above the
                       limits, and 3 did not separately identify foster care maintenance and adoption assistance
                       payments on their surveys.
                       30
                        Four of the 6 states included state matching funds in their CFS-101 estimates, so we could
                       not determine whether the spending plans for those states exceeded the statutory limits.




                       Page 36                                      GAO-03-956 Title IV-B Child Welfare Services
6 categories.31 Examples of unique subpart 1 services in the CPS category
include specialized investigations of reports of child abuse or neglect,
telephone hotlines to report incidents of child abuse or neglect, and
temporary shelter services for children removed from their homes at times
when no other placement option is available, such as evenings and
weekends. States also provided other types of services that were funded
uniquely by subpart 1. For example, Minnesota provided intensive in-home
services to prevent children from being placed in foster care, North
Carolina contracted for legal services with the state’s Attorney General’s
office, and Maine helped adopted youth pay for post-secondary education
costs.

Our review of child welfare literature and Internet sites that identified
promising child welfare practices found few studies that evaluated the
effectiveness of the specific services that states funded uniquely with
subpart 1 funds. Based on the information provided on our survey, we
identified evaluation research on two of these services. Texas used
subpart 1 to fund its Home Instruction For Parents of Preschool
Youngsters (HIPPY) Program. The goal of HIPPY is to prevent academic
underachievement of children when they enter school. HIPPY works with
parents in their homes or in parent group meetings to increase the degree
and variety of literacy experiences in the home. The program also seeks to
prevent child abuse by enhancing parent-child interactions and focuses on
economically disadvantaged parents who may not be involved in parenting
programs. While Texas has not formally evaluated this program, the model
has been evaluated in other states. Strengthening America’s Families, a
Web site about effective family programs to prevent juvenile delinquency
funded by the Office of Juvenile Justice and Delinquency Prevention, cites
HIPPY as a model program for which evaluations have shown positive
effects on children’s measured competence and classroom behavior at the
end of second grade for children who participated in HIPPY compared
with children with no formal preschool experience.32 In addition, a
1999 article summarizing research on the HIPPY program found mixed
results. For example, an evaluation in New York found that children
whose parents participated in HIPPY in 1990 outperformed control group



31
 Virginia did not provide any data on its subpart 2 spending, so we were not able to
determine whether the state uniquely funded any service categories with subpart 1.
New York does not receive any subpart 2 funds, so we considered all services funded by
subpart 1 to be unique.
32
     See http://www.strengtheningfamilies.org/html/programs_1999/22_HIPPY.html.




Page 37                                      GAO-03-956 Title IV-B Child Welfare Services
children on measures of classroom adaptation and reading scores 1 year
later, but children whose parents participated in HIPPY in 1991 had similar
outcomes as children in the control group. The article suggested that
variability in how the program is implemented and in parental
commitment to the program may explain the mixed results.33

Missouri funded an alternative response system with subpart 1 funds,
which offers assessment services (rather than an investigation) for
families that are the subject of a report of abuse or neglect when the risk
to the child is not considered high to determine if the family needs
services to reduce the risk of harm to the child. By responding to low risk
reports of abuse or neglect in a nonaccusatory manner, the goal is to
encourage families to collaborate in identifying their needs and cooperate
with supportive services. A 1998 evaluation of Missouri counties testing
the state’s alternative response system found that the safety of children
was not compromised by the lack of an investigation and that, compared
to counties that were not using the alternative response system, needed
services were delivered more quickly, subsequent reports of abuse or
neglect decreased, and the cooperation of families improved. An
evaluation of Minnesota’s alternative response systems has also shown
promising results. For example, initial results from the randomized
experimental evaluation showed an increase in the use of community
services with no increase in subsequent reports of abuse or neglect.

Of the 37 states that reported unique subpart 1 service categories, we
asked the 22 states with unique subpart 1 service categories other than
foster care maintenance payments, adoption assistance payments, staff
salaries, or administration, whether they had evaluated the effectiveness
of the programs included in their unique categories. None of these states
had conducted rigorous evaluations of the effectiveness of these services
using randomly selected control groups.34 One official explained that few
states can afford to divert resources from providing direct services to




33
 The Future of Children, “The Home Instruction Program for Preschool Youngsters
(HIPPY)” (Los Altos, CA: Spring/Summer 1999).
34
  While few states had evaluated their unique subpart 1 services, 4 of the 17 states
responding to our second survey indicated that they had evaluated other subpart 1 services
that were not unique.




Page 38                                     GAO-03-956 Title IV-B Child Welfare Services
conducting formal evaluations of programs, given the tremendous service
needs of families involved with the child welfare system.35

However, 5 states provided some information on the outcomes of the
services they funded uniquely with subpart 1. North Dakota used subpart 1
dollars to uniquely fund a component of its family preservation program—
family focused services—which the state characterized as a family
reunification service. The state provided us with a draft evaluation report
of its family preservation program, which includes this specific service.
The family preservation program is intended for families with children at
risk of being placed in foster care and offers a range of services, including
parent aides who provide hands-on parenting education and therapists
who are available 24 hours a day to work with the family in the home to
address the issues that may result in the children being removed from the
home. The evaluation of its total family preservation program found that
families receiving services and the social worker involved with the families
both reported improved family functioning upon completion of the
services compared to their functioning prior to the services. The study also
found that fewer children were at risk of being placed in foster care upon
completion of services. However, the evaluation did not include any
control group to determine if these results would have been achieved if
families had not received these services.36

Massachusetts used some of its subpart 1 funds to pay for a contractor to
operate a telephone service for reports of child abuse or neglect that are
received in the evenings and on weekends. Officials from Massachusetts
provided an internal study conducted in February 2000 that discussed
problems with this telephone service, most notably limited staff and
resources to handle an increasing volume of calls. The report
recommended several actions to improve the operation of the telephone
service, including an increase in staff to field telephone calls, upgrading



35
 Some national research exists for some of the unique service categories at the state level;
however, the extent to which the research is applicable to the specific services in the
unique subpart 1 categories is difficult to determine. For example, in some cases, the
service in a unique subpart 1 category was not based on the same model that was evaluated
or states did not provide sufficient information on our survey to determine whether the
program was based on this particular model. Therefore, we do not discuss this research in
our report.
36
 A number of evaluations of similar types of family preservation programs have found that
children in control groups also had low rates of out-of-home placement, raising questions
about the effectiveness of these services.




Page 39                                      GAO-03-956 Title IV-B Child Welfare Services
the telephone system so that fewer people receive a busy signal, and
increasing the number of beds available for emergency placements in the
evenings and on weekends. Arizona also funded its child abuse telephone
hotline uniquely with subpart 1 funds and provided the following statistics.
In fiscal year 2003, 69 percent of calls to the hotline were answered
without any wait. Of the calls that were not answered directly, the average
wait time was 3.5 minutes and about 13 percent of calls were abandoned.
In addition, quality assurance staff reviewed over 17,000 calls for which it
was determined that the report did not meet the state’s criteria for a CPS
report requiring investigation and changed only 15 of these to a CPS
report.

Missouri funded several CPS services with subpart 1 funds, including
intensive in-home services for children at imminent risk of removal from
the home- and family-centered services for families for whom an
investigation determined services are needed to eliminate the risk of harm
to the child. Missouri provided two annual reports for fiscal year 2002 that
provide some data on the outcomes of these services. Consumer surveys
indicated that many families found the intensive in-home services useful,
and the annual report on the intensive in-home services indicated that
88 percent of at-risk children were still with their families when services
ended after approximately 6 weeks. In addition, 79 percent of children
who exited the program in 2001 were still at home 1 year after services
ended. With regard to family centered services, the annual report indicated
that over 70 percent of families had achieved their goals at the time their
case was closed. Wisconsin used subpart 1 to fund a Youth Aids Program,
in which the state provides grants to counties to provide services to
prevent the placement of children in correctional facilities and other out-
of-home care. The state has not evaluated services provided by the
counties, but a 1995 report notes that in the first several years of
operation, this program produced major reductions in institutional
placements and helped encourage the development of community-based
resources.37 Over time, however, an increase in youth crime has led to
large increases in institutional and out-of-home care, so that much of
Youth Aids funding at the time was reported to be used for out-of-home
placements.




37
 Ira M. Cutler, Alexandra Tan, and Laura Downs, State Investments in Education and
Other Children’s Services: Case Studies of State Innovations (n.p.: September 1995),
http://www.financeprojectinfo.org/Publications/studies.html (downloaded Jul. 8, 2003).




Page 40                                     GAO-03-956 Title IV-B Child Welfare Services
                  Despite its relatively small funding level compared to other funding
Conclusions       sources for child welfare services, Title IV-B represents an important
                  federal commitment to providing supportive services to help preserve and
                  reunify families. The primary emphases of the two subparts vary
                  somewhat, but the range of services offered and the types of families
                  served overlap significantly. In part because of the relatively small funding
                  involved and the flexible nature of the funding, HHS does not provide in-
                  depth oversight specific to Title IV-B subpart 1. Instead, HHS focuses
                  much of its oversight efforts on states’ progress toward the overall goals of
                  their child welfare systems and the outcomes achieved by these systems.
                  While this type of oversight is appropriate, HHS could provide valuable
                  assistance to states by obtaining more concrete data about states’ use of
                  these funds and synthesizing these data with CFSR data on states’
                  outcomes with respect to properly identifying the service needs of
                  children and families and providing needed services. Such analyses could
                  allow HHS to develop information on how investments in certain types of
                  services correlate to improved outcomes for children, which could be
                  shared with states to help them more effectively target their spending.

                  HHS could also use this enhanced knowledge of Title IV-B to help develop
                  an appropriate accountability strategy for its newly proposed child welfare
                  option. If enacted, the additional spending flexibility proposed—given the
                  size of the Title IV-E allocations that would become available for spending
                  on a variety of child welfare services—could have a significant impact on a
                  state’s child welfare system. Given the limited information available about
                  the services funded with subpart 1 and the effectiveness of these services,
                  as well as HHS’s findings about the ability of states’ to meet families’
                  needs, ensuring that states use this flexibility to provide effective services
                  will be critical to the success of this option. Opportunities also exist for
                  HHS to continue to encourage states to conduct evaluations of the
                  programs the states implement.


                  We recommend that the Secretary of HHS provide the necessary guidance
Recommendations   to ensure that HHS regional offices monitor states’ use of Title IV-B
                  subpart 1 funds for compliance with statutory restrictions on the use of
                  these funds. In addition, we recommend that the Secretary consider the
                  feasibility of collecting basic data on states’ use of these funds to facilitate
                  its oversight of the program and to provide guidance to help states
                  determine appropriate services to fund. For example, an analysis of how
                  states’ spending patterns correlate to outcomes—both positive and
                  negative—from the CFSRs could yield useful information for this purpose.



                  Page 41                                GAO-03-956 Title IV-B Child Welfare Services
                  Given that HHS is currently developing the new child welfare option that
                  would allow states to use Title IV-E dollars for services similar to those
                  provided under Title IV-B subpart 1, we further recommend that the
                  Secretary use the information gained through enhanced oversight of
                  subpart 1—as well as information it may have on states’ use of subpart 2
                  funds—to inform its design of this option. For example, HHS could use
                  this information to help states determine the most appropriate services to
                  provide under this option.


                  We provided a draft of this report to HHS for comment. The Department’s
Agency Comments   Administration for Children and Families provided comments. These
                  comments are reproduced in appendix II. ACF also provided technical
                  clarifications, which we incorporated when appropriate.

                  ACF agreed with our recommendation that the Secretary of HHS provide
                  the necessary guidance to ensure that HHS regional offices monitor states’
                  use of Title IV-B subpart 1 funds for compliance with statutory restrictions
                  on the use of these funds. ACF agreed to provide guidance to the regional
                  offices to enable them to enforce the statutory limits on subpart 1 funds.
                  However, ACF also noted that this limitation no longer serves a useful
                  purpose and is incompatible with the current proposal to offer states
                  much more flexibility in using other federal child welfare dollars. ACF said
                  that it plans to explore ways to provide states flexibility with respect to
                  the subpart 1 limits.

                  ACF disagreed with our recommendation to consider the feasibility of
                  collecting basic data on states’ use of subpart 1 funds. ACF said that it
                  believes that its level of oversight is commensurate with the scope and
                  intent of the program and minimizes states’ reporting requirements.
                  Rather than using information on Title IV-B expenditures to help states
                  most effectively use their resources, ACF believes that its oversight is
                  more appropriately focused on the CFSR process, which requires states to
                  develop actions in response to weaknesses identified by the CFSR and
                  which measures the impact of these actions on actual outcomes. In ACF’s
                  opinion, analyzing how states’ spending patterns correlate to CFSR results
                  is not useful, given the lack of a direct relationship between the relatively
                  small Title IV-B funding levels and the broad outcome areas of safety,
                  permanency, and well-being. In addition, ACF noted that any data
                  collected on subpart 1 expenditures would be outdated because states
                  have 2 years to spend Title IV-B expenditures and are not required to
                  report final expenditures until 90 days after the 2-year period has ended.



                  Page 42                               GAO-03-956 Title IV-B Child Welfare Services
We believe, however, that assessing the feasibility of collecting some basic
data on states’ subpart 1 expenditures could enhance ACF’s overall
oversight of states’ child welfare operations and outcomes. While the
impact of states’ program improvement efforts under the CFSR process is
unknown because states are just getting these efforts underway, the
service deficiencies identified by the CFSRs suggest that states could
benefit from some guidance on the services that are associated with
positive CFSR outcomes. An analysis of how states’ spending patterns
correlate to CFSR outcomes need not be limited to subpart 1 spending;
such an analysis could help to identify effective services (regardless of
funding source) that are associated with positive CFSR outcomes and help
states target their subpart 1 and other funding sources more effectively.
Furthermore, we do not believe that 2-year old data on subpart 1
expenditures are necessarily outdated; rather, we believe such data would
provide better information on states’ use of subpart 1 funds than states’
current estimates of planned spending. In addition, ACF could request
expenditure data for a shorter period, such as a year or a quarter or
whatever time period best fits states’ other reporting requirements.

ACF did not comment on our recommendation that it use the information
gained through enhanced oversight to inform its design of its child welfare
option. However, we believe that guidance on services associated with
positive CFSR outcomes could also help states that choose to participate
in the proposed child welfare option to manage their fixed Title IV-E
funding. ACF also commented on our finding that the services provided
and families served under subparts 1 and 2 overlap to some extent.
Specifically, ACF noted that by not permitting the funds, services, and
families to overlap, ACF would significantly impede the functionality of
the continuum of child welfare services funded by Title IV-B and other
federal funding streams and possibly lead to families not receiving needed
services. While we described the overlap in services provided and families
served, we did not state or imply that such overlap was inappropriate or
unnecessary.

We also provided a draft of this report to child welfare officials in the
4 states we visited (California, New Jersey, Ohio, and Washington).
Officials from California and Washington provided a few technical
clarifications that we incorporated, while New Jersey and Ohio did not
have any comments. In addition, Washington expressed concern that our
recommendations for HHS to (1) ensure that the regional offices monitor
states’ use of subpart 1 funds for compliance with the statutory limits and
(2) consider collecting data on states’ use of these funds will add to the
reporting burden of states without providing additional funds to offset that


Page 43                              GAO-03-956 Title IV-B Child Welfare Services
burden. We recommended that HHS consider the feasibility of collecting
such data and would expect HHS to take into account the burden placed
on states in making this decision.


We are sending copies of this report to the Secretary of HHS, appropriate
congressional committees, state child welfare directors, selected county
child welfare directors, and other interested parties. We will also make
copies available to others upon 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, or wish to discuss this report further, please call
me at (202) 512-8403 or Diana Pietrowiak at (202) 512-6239. Key
contributors to this report are listed in appendix III.

Sincerely yours,




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




Page 44                               GAO-03-956 Title IV-B Child Welfare Services
             Appendix I: Scope and Methodology
Appendix I: Scope and Methodology


             To determine how the services provided and populations served under
             subpart 1 compare with those under subpart 2, we surveyed child welfare
             directors in all 50 states and the District of Columbia. We sent a survey to
             all states to obtain information on how they use Title IV-B funds. We also
             sent a second survey to certain states that responded to the first survey.
             We pretested both survey instruments in New Hampshire, Rhode Island,
             and Wisconsin and obtained input from several other states and from a
             Department of Health and Human Services (HHS) official. In January
             2003, we mailed a copy of the first survey to the states, asking for specific
             data on state spending and populations served for subparts 1 and 2, as well
             as their opinions about the current structure of Title IV-B. To address
             differences in the administrative structure and reporting systems of state
             child welfare agencies, a different version of this survey was sent to states
             with county-administered child welfare systems.1 We received responses
             from 47 states, although some states were unable to provide complete
             information.2 To encourage as many states as possible to complete the
             survey, we conducted follow-up telephone calls to states that did not
             respond to our survey by the initial deadline. After a state responded to
             the first survey, we mailed the second survey, requesting more detailed
             information on the three services receiving the largest portions of subpart
             1 funding and the three services receiving the largest portions of subpart 2
             funding. The second survey also asked for copies of any existing
             evaluations of the effectiveness of these services. We sent the second
             survey to the 30 states that provided sufficient data on their first survey by
             mid-April 2003 and received responses from 17 states.3

             We did not independently verify the information obtained through either
             survey. The responses of the 47 states to the first survey can be used to
             explain how the 50 states and the District of Columbia in general used
             Title IV-B funds. Since we received responses from only 17 states for our
             second survey, they may not be representative of all states. Consequently,
             we have used these data only as examples or for illustrative purposes. As a
             result, we based our analyses of the populations of children and families



             1
               The following 7 states completed the county-administered survey version: Colorado,
             Georgia, Maryland, Minnesota, New York, Pennsylvania, and Wisconsin.
             2
             We did not receive responses from the District of Columbia, Indiana, Kentucky, or
             Montana.
             3
              The 17 states that responded to the second survey were Arkansas, Delaware, Florida,
             Hawaii, Illinois, Kansas, Louisiana, Massachusetts, New Mexico, North Dakota, Oklahoma,
             South Dakota, Texas, Utah, Vermont, Washington, and Wyoming.




             Page 45                                     GAO-03-956 Title IV-B Child Welfare Services
Appendix I: Scope and Methodology




served on data from our first survey. However, states that completed the
county-administered version of the survey did not provide data on the
types of children and families who received services funded by Title IV-B
and were not included in these analyses. As a result, the data on
populations served by subparts 1 and 2 cannot be generalized to states
with county-administered child welfare systems.

Data from both surveys were double-keyed to ensure data entry accuracy,
and the information was analyzed using statistical software. On the first
survey, we asked states to describe the nature of each service and select
one service category that best characterized each program funded by Title
IV-B, using the following choices: child protective services (CPS), family
support/prevention programs, parent training programs, health programs,
educational programs, substance abuse programs, counseling and mental
health services, domestic violence programs, formal family preservation
programs, family reunification programs, recruitment and training for
foster/adoptive parents, adoption preservation services, administration
and management, foster care maintenance payments, adoption subsidy
payments, and other.

The data were analyzed using states’ self-identified categories except in
the following situations: (1) if a state clearly described a program as
funding salaries for staff at the child welfare agency, we included these
data under the staff category; (2) if a state used the “other” category for a
service that clearly fell into one of the existing categories (writing in
“foster care maintenance payments,” for example), we revised the survey
response to reflect the actual category; (3) if it appeared that a state
mistakenly checked the wrong box; for example, we changed the category
from CPS to family reunification if the program was described as a family
reunification service; (4) if a state checked multiple categories, we
reported these programs separately under “multiple responses;” (5) if a
state did not check any categories, we selected a service category that best
fit the description of the program and used “other” if the description did
not clearly fall into one of our categories; and finally (6) if a state clearly
described the use of Title IV-B funds as administrative, but categorized it
in another category, we revised the survey to indicate that the funds were
used for administration and management. Some states explained that Title
IV-B funds were used to cover administrative expenses for a particular
program and characterized the use of these funds based on the nature of
the program. For example, a state might have selected family preservation
program when Title IV-B funds were used for administrative expenses for
that program.



Page 46                               GAO-03-956 Title IV-B Child Welfare Services
Appendix I: Scope and Methodology




As noted earlier in the report, we recognize that some states may not have
separately identified administration or management expenses associated
with a program and may have included these expenses in the program
costs. For reporting purposes, we combined several service categories for
which states reported spending small percentages of Title IV-B funds, such
as parent training and substance abuse services, and reported these
dollars in the “other” category.

We recognize that the service categories used are not necessarily mutually
exclusive. For example, several HHS officials told us that the delineation
between family support and family preservation services is not clear, so
that 2 states providing the same services to the same types of children and
families may report them in different categories. In addition, because the
survey for states with state-administered child welfare systems asked
them to choose one service category for each program, the reported
service categories may not fully capture all relevant programs that fall into
more than one service category. Inconsistencies in how states categorized
services could have an effect on any measured differences between
service categories.

To obtain more in-depth information on the services provided and the
types of children and families served under Title IV-B, we conducted site
visits in California, New Jersey, Ohio, and Washington. We selected these
states to represent a range of geographic locations and subpart 1 spending
patterns. In addition, because preliminary data indicated that significant
subpart 1 funds were devoted to CPS, we selected states that used
innovative CPS tools or processes. However, the experiences of these
states are not necessarily representative of the experiences of any other
state. During these site visits, we interviewed state and local child welfare
officials and service providers and reviewed relevant documentation.

To learn about the federal government’s role in overseeing subpart 1, we
reviewed applicable laws and regulations and interviewed HHS central
office officials. We also conducted interviews with HHS officials in all
10 HHS regional offices to discuss their oversight activities and reviewed
results from HHS’s CFSR reports. In addition, we reviewed states’ CFS-
101s for fiscal year 2002 and compared states’ planned subpart 1 spending
for foster care maintenance, adoption assistance, and child care payments
with states’ final subpart 1 allocations for fiscal year 1979 as reported on
an HHS program instruction from that year. States are required to submit
the CFS-101 by June 30 of the preceding year—June 30, 2001, for fiscal
year 2002. At that time, federal appropriations for Title IV-B and other
federal child welfare funds often are not yet finalized, so states base their


Page 47                               GAO-03-956 Title IV-B Child Welfare Services
    Appendix I: Scope and Methodology




    estimates on the previous year’s allocation. States must submit a revised
    CFS-101 by June 30, 2002, to request any additional fiscal year 2002 Title
    IV-B funds that might be available to them once appropriations are
    finalized. In addition, states can request additional Title IV-B funds if other
    states do not use the total funds to which they are entitled. In most cases,
    we reviewed the final revised CFS-101s approved by HHS. For one state,
    we used the initial CFS-101 approved by HHS because it included planned
    subpart 1 expenditures that exceeded the limits for foster care
    maintenance and adoption assistance payments, but the revised
    CFS-101 did not. Although the revised CFS-101 did not show the state
    planned to exceed the limit, we used the initial CFS-101 to show that
    HHS had previously approved a spending plan that did not comply with
    the statutory limits.

    We used our survey results to identify services unique to subpart 1—that
    is, categories of services funded by subpart 1 that are not funded by
    subpart 2. While no category of service was unique to subpart 1 at the
    national level, some states funded unique categories of services within
    their state with subpart 1. In our second survey, we asked states to provide
    a copy of any evaluations they had conducted of the three largest services
    funded by subpart 1. If we did not have survey data for one of the
    identified services, either because we did not send a second survey to the
    state or because the second survey did not ask for data on the particular
    service, we contacted the state directly to ask if any evaluation had been
    conducted.

    In addition, to identify other evaluations on the effectiveness of the
    services in these unique categories, we conducted a literature review and
    interviewed child welfare research experts. The reports and Internet sites
    we reviewed included the following:

•   Strengthening America’s Families: Effective Family Programs for the
    Prevention of Delinquency
    (http://www.strengtheningfamilies.org/html/programs_1999/programs_list_
    1999.html).

•   Child Welfare League of America’s Research to Practice Initiative
    (http://www.cwla.org/programs/r2p/).

•   Casey Family Programs: Promising Approaches to Working with Youth
    and Families (http://www.casey.org/whatworks/).




    Page 48                               GAO-03-956 Title IV-B Child Welfare Services
    Appendix I: Scope and Methodology




•   Promising Practices Network on Children, Families, and Communities
    (http://www.promisingpractices.net/).

•   U. S. Department of Health and Human Services, “Emerging Practices In
    the Prevention of Child Abuse and Neglect” (Washington, D.C.: n.d.).

    We conducted our work between August 2002 and July 2003 in accordance
    with generally accepted government auditing standards.




    Page 49                             GAO-03-956 Title IV-B Child Welfare Services
             Appendix II: Comments from the Department of Health and Human Services
Appendix II: Comments from the Department
of Health and Human Services




             Page 50                                  GAO-03-956 Title IV-B Child Welfare Services
Appendix II: Comments from the Department of Health and Human Services




Page 51                                  GAO-03-956 Title IV-B Child Welfare Services
Appendix II: Comments from the Department of Health and Human Services




Page 52                                  GAO-03-956 Title IV-B Child Welfare Services
Appendix II: Comments from the Department of Health and Human Services




Page 53                                  GAO-03-956 Title IV-B Child Welfare Services
                  Appendix III: GAO Contacts and
Appendix III: GAO Contacts and
                  Acknowledgments



Acknowledgments

                  Diana Pietrowiak (202) 512-6239
GAO Contacts      Michelle St. Pierre (617) 788-0558


                  In addition to those named above, Melissa Mink and J. Bryan Rasmussen
Acknowledgments   made key contributions to the report. Anne Rhodes-Kline, Alison Martin,
                  Luann Moy, and George Quinn, Jr., provided key technical assistance.




                  Page 54                              GAO-03-956 Title IV-B Child Welfare Services
             Related GAO Products
Related GAO Products


             Child Welfare: Most States Are Developing Statewide Information
             Systems, but the Reliability of Child Welfare Data Could be Improved.
             GAO-03-809. Washington, D.C.: July 31, 2003.

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

             Child Welfare and Juvenile Justice: Federal Agencies Could Play a
             Stronger Role in Helping States Reduce the Number of Children Placed
             Solely to Obtain Mental Health Services. GAO-03-397. Washington, D.C.:
             April 21, 2003.

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

             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.

             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: HHS Should Ensure That Juvenile Justice Placements Are
             Reviewed. GAO/HEHS-00-42. Washington, D.C.: June 9, 2000.

             Juvenile Courts: Reforms Aim to Better Serve Maltreated Children.
             GAO/HEHS-99-13. Washington, D.C.: January 11, 2000.

             Foster Care: States’ Early Experiences Implementing the Adoption and
             Safe Families Act. GAO/HEHS-00-1. Washington, D.C.: December 22, 1999.

             Foster Care: HHS Could Better Facilitate the Interjurisdictional
             Adoption Process. GAO/HEHS-00-12. Washington, D.C.: November 19,
             1999.

             Foster Care: Effectiveness of Independent Living Services Unknown.
             GAO/HEHS-00-13. Washington, D.C.: November 5, 1999.



             Page 55                            GAO-03-956 Title IV-B Child Welfare Services
           Related GAO Products




           Child Welfare: States’ Progress in Implementing Family Preservation
           and Support Services. GAO/HEHS-97-34. Washington, D.C.: February 18,
           1997.

           Child Welfare: Opportunities to Further Enhance Family Preservation
           and Support Activities. GAO/HEHS-95-112. Washington, D.C.: June 15,
           1995.




(130177)
           Page 56                           GAO-03-956 Title IV-B Child Welfare Services
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