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

Better Policy Implementation and Documentation of Related Activities 
Would Help Improve Performance:

D.C. Child and Family Services:

Report to the Chairman, Committee on Government Reform, House of 
Representatives:

United States General Accounting Office:

GAO:

May 2003:

GAO-03-646:

GAO Highlights:

Highlights of GAO-03-646, a report to the Chairman, Committee on 
Government Reform, House of Representatives 

Why GAO Did This Study:

The District of Columbia (D.C.) Child and Family Services Agency 
(CFSA) is responsible for protecting children at risk of abuse and 
neglect and ensuring that services are provided for them and their 
families. GAO was asked to discuss the extent to which CFSA has (1) 
met requirements of the Adoption and Safe Families Act (ASFA) of 1997 
and other selected performance criteria, (2) adopted and implemented 
child protection and foster care placement policies, and (3) enhanced 
its working relationship with the D.C. Family Court. 

To address these questions, GAO analyzed data from CFSA’s child 
welfare information system, known as FACES; reviewed laws, 
regulations, and reports; examined case files; and interviewed 
officials.


What GAO Found:

CFSA’s performance relative to three sets of measures—nine ASFA 
requirements, eight selected performance criteria and six of the 
agency’s foster care policies—has been mixed. The agency took actions 
to implement six of the nine ASFA requirements related to the safety 
and well-being of foster children and met or exceeded four of the 
eight selected foster care performance criteria, but its plans did not 
address all requirements not fully implemented and unmet performance 
criteria. CSFA has established many foster care policies, but 
caseworkers did not consistently implement the six GAO examined. In 
addition, FACES lacked data related to four of the policies reviewed 
for at least 70 percent of its active foster care cases. The following 
table summarizes the percentage of cases for which the data indicated 
the policy was implemented.

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

[See PDF for image]

[End of figure]

CFSA has enhanced its working relationship with the D.C. Family Court, 
but several factors hindered this relationship. For example, CFSA’s 
top management and Family Court judges talk frequently about foster 
care case issues. However, differing opinions among CFSA caseworkers 
and judges about their responsibilities have hindered the 
relationships. CFSA officials and Family Court judges have been 
working together to address these hindrances.  

What GAO Recommends:

To improve CFSA’s performance GAO recommends that the Mayor require 
the Director of CFSA to (1) develop plans to fully implement all ASFA 
requirements, (2) establish procedures to ensure caseworkers 
consistently implement all foster care policies, and (3) document in 
FACES all activities related to active foster care cases.  

In commenting on the draft, the Director of CFSA generally agreed with 
our findings. Although she did not directly address the 
recommendations, she generally agreed with the areas we identified for 
continued improvement. 

www.gao.gov/cgi-bin/getrpt?GAO-03-646.

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

[End of section]

Contents:

Letter:

Results in Brief:

Background:

CFSA Undertook Actions to Implement Most ASFA Requirements Reviewed and 
Met Half of the Selected Performance Criteria for Child Safety and 
Well-Being:

CFSA Has Established Many Foster Care Policies but Lacks Others, and 
the Extent of Implementation and Documentation Varies:

CFSA Has Enhanced Its Working Relationship with the D.C. Family Court 
by Working Collaboratively, but Hindrances Remain:

Conclusions:

Recommendations:

Agency Comments and Our Evaluation:

Appendix I: Scope and Methodology:

Appendix II: Comments from the Director of the Child and Family 
Services Agency:

Appendix III: GAO Contacts and Acknowledgments:

GAO Contacts:

Acknowledgments:

Related GAO Products:

Tables:

Table 1: CFSA's Progress in Implementing Nine ASFA Requirements:

Table 2: Analysis of Selected Foster Care Performance Criteria:

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

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

Figure:

Figure 1: CFSA Responsibilities Related to Permanency Goals:

Abbreviations:

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

United States General Accounting Office:

Washington, DC 20548:

May 27, 2003:

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

Dear Mr. Chairman:

The District of Columbia's Child and Family Services Agency (CFSA) is 
responsible for protecting foster care children who have been at risk 
of abuse and neglect and ensuring that critical services are provided 
to them and their families. In 2002, CFSA had about 3,000 children in 
foster care. as a result of a history of poor performance, the U.S. 
District Court for the District of Columbia placed CFSA in receivership 
in 1995.[Footnote 1] To help improve its performance during 
receivership, CFSA made several changes, including establishing an 
automated case management system, FACES. In 2000, the District Court 
issued a consent order establishing a process by which the agency's 
receivership could be terminated. The order also established a 
probationary period, which would begin when the receivership ended and 
identified performance criteria CFSA had to meet in order to end the 
probationary period. In April 2001, CFSA became a cabinet-level agency 
within the government of the District of Columbia, in June 2001 the 
court removed CFSA from receivership, and in October 2001 
responsibility for child abuse investigations was transferred from the 
District's Metropolitan Police Department to CFSA. Additionally, new 
legislation established requirements that CFSA had to meet. The 
Adoption and Safe Families Act (ASFA) of 1997 mandated that all child 
welfare agencies achieve timely placement of children in permanent 
homes. The U.S. Department of Health and Human Services (HHS) is 
responsible for setting standards and monitoring the nation's child 
welfare programs, including assessing compliance with ASFA requirements 
through its Child and Family Services Reviews. [Footnote 2] In 
addition, the District of Columbia Family Court Act of 2001 required 
CFSA to work closely with the Family Division of the D.C. Superior 
Court and the District's Office of Corporation Counsel (OCC).[Footnote 
3] In September 2002, the court-appointed monitor reported that a child 
was abused by two children in a group home licensed by CFSA. According 
to the monitor, this incident, together with the history of inadequate 
care and attention given this child by CFSA, indicated that its 
operations and policies, especially those regarding foster care cases, 
may still need improvement.

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

To address these questions, we selected three sets of measures to 
assess CFSA's performance. First, we examined CFSA's progress in 
implementing nine ASFA requirements that were related to the safety and 
well-being of foster children. Second, we assessed the extent to which 
CFSA met or exceeded eight selected performance criteria established 
during its probationary period. Third, we assessed the extent to which 
caseworkers implemented six foster care policies related to their day-
to-day responsibilities. We analyzed data in the District's automated 
child welfare information system, known as FACES; reviewed laws, 
regulations, and reports; examined case files; and interviewed 
officials. We obtained and analyzed automated data from FACES on all 
foster care cases that were at least 6 months old as of November 30, 
2002. We selected ASFA requirements and CFSA policies directly related 
to the safety and well-being of foster children. We selected foster 
care performance criteria from among those CFSA had to meet in order to 
end the probationary period that, in our judgment, most directly 
related to the safety and permanent placement of children in foster 
care. We reviewed federal and local laws, regulations, foster care 
policies recommended by various organizations, and reports on CFSA's 
implementation of the District's foster care program and selected CFSA 
policies that covered several key foster care management functions. We 
included HHS's evaluation of how CFSA implemented ASFA requirements in 
our assessment of the agency's performance. We independently verified 
the reliability of data in FACES; however, CFSA had not entered into 
FACES detailed information on the data elements we needed for our 
analysis with respect to about two-thirds of the District's active 
foster care cases--mostly cases that originated prior to FACES going 
on-line in October 1999. To obtain information on policy 
implementation, we also examined foster care case files. We interviewed 
CFSA executives, managers, and supervisors; Family Court judges, 
attorneys from OCC; and officials from organizations that recommend 
policies applicable to child welfare programs. We conducted our work 
between September 2002 and May 2003 in accordance with generally 
accepted government auditing standards. See appendix I for additional 
information on our scope and methodology.

Results in Brief:

CFSA undertook actions to implement six of nine ASFA requirements 
directly related to the safety and well-being of foster care children 
and met or exceeded four of eight selected foster care performance 
criteria, but its plans do not address all requirements that were not 
fully implemented and selected performance criteria that were not met. 
For example, CFSA signed an interim border agreement to help achieve 
timelier placement of District children in Maryland, which addresses 
ASFA's requirement to use cross-jurisdictional resources to facilitate 
timely adoptive or permanent placements for waiting children. However, 
HHS's review of the District found that CFSA did not fully implement 
ASFA's requirements to initiate or join proceedings to terminate the 
rights of parents whose children are in foster care, conduct annual 
hearings to review permanency goals for children every 12 months, and 
provide participants a notice of reviews and hearings. The selected 
foster care performance criteria CFSA met or exceeded included the 
criteria that prohibit leaving children in emergency care for more than 
90 days and that require placing children in foster care with one or 
more of their siblings. The criteria that CFSA did not meet included 
the requirements regarding the frequency of caseworker visits with 
children in foster care and the minimum percentage of foster care 
children that must be placed in foster homes with valid licenses. CFSA 
has written plans that address most of the unmet ASFA requirements and 
selected performance criteria. The unmet requirements and performance 
criteria not addressed in the plans are those related to providing 
timely notification of all reviews and hearings to families with 
children in foster care and to reducing the number of children in 
foster care who, for 18 months or more, have had a permanency goal to 
return home. Agency officials cited staffing shortages and external 
demands, such as coordinating work with other agencies, as factors that 
hindered the agency's ability to fully meet the ASFA requirements and 
performance criteria. However, unless these requirements and criteria 
are met a child's safety may be jeopardized, the time a child spends in 
foster care may be prolonged, or the best decisions regarding a child's 
future well-being may not be reached.

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

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

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

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

Background:

While CFSA is responsible for protecting thousands of foster care 
children, many children in CFSA's care languished for extended periods 
of time due to managerial shortcomings and long-standing organizational 
divisiveness in the District of Columbia. As a result of these 
deficiencies, the U.S. District Court for the District of Columbia 
issued a remedial order in 1991 to improve the performance of the 
agency. Under a modified final order established by the court in 1993, 
CFSA was directed to comply with many requirements. In 1995, lacking 
sufficient evidence of program improvement, the agency was removed from 
the District's Department of Human Services and placed in receivership. 
Among its efforts to improve agency performance, CFSA established an 
automated system, FACES, to manage its caseload. The District Court 
issued a consent order in 2000 establishing a process by which the 
agency's receivership could be ended. The order also established a 
probationary period, which began when the receivership ended, and 
identified performance standards CFSA had to meet in order to end the 
probationary period. The court-appointed monitor, the Center for the 
Study of Social Policy, was to assess CFSA's performance and had 
discretion to modify the performance standards. In April 2001, CFSA 
became a cabinet-level agency within the government of the District of 
Columbia. In June 2001, the court removed CFSA from the receivership 
and its probationary period began. In October 2001, responsibility for 
child abuse investigations was transferred to CFSA from the District's 
Metropolitan Police Department. CFSA's probationary period ended in 
January 2003.

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

CFSA operates in a complex child welfare system.[Footnote 4] Several 
federal laws, local laws, and regulations established goals and 
processes under which CFSA must operate. ASFA, with one of its goals to 
place children in permanent homes in a timelier manner, placed new 
responsibilities on all child welfare agencies nationwide. ASFA 
introduced new time periods for moving children toward permanent, 
stable care arrangements and established penalties for noncompliance. 
For example, ASFA requires child welfare agencies to hold a permanency 
planning hearing--during which the court determines the future plans 
for a child, such as whether the state should continue to pursue 
reunification with the child's family or some other permanency goal--
not later than 12 months after the child enters foster care. The 
District of Columbia Family Court Act of 2001 established the 
District's Family Court and placed several requirements on the 
District's Mayor and various District government agencies, including 
CFSA and OCC. The District of Columbia Family Court Act requires the 
Mayor, in consultation with the Chief Judge of the Superior Court, to 
ensure that CFSA and other District government agencies coordinate the 
provision of social services and other related services to individuals 
served by the Family Court.

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

The management of foster care cases involves several critical steps 
required by CFSA policy. (See fig. 1.) Typically, these cases begin 
with an allegation of abuse or neglect reported to the CFSA child abuse 
hot line. CFSA staff are required to investigate the allegations 
through direct contact with the reported victim. If required, the child 
may be removed from his or her home, necessitating various court 
proceedings handled by the District's Family Court. CFSA caseworkers 
are responsible for managing foster care cases by developing case 
plans; visiting the children; participating in administrative review 
hearings involving CFSA officials, children, parents, and other 
officials; attending court hearings; and working with other District 
government agencies. CFSA caseworkers are also responsible for 
documenting the steps taken and decisions made related to a child's 
safety, well-being, and proper foster care placement, as well as those 
related to developing the most appropriate goal for permanency. 
Depending on their circumstances, children leave foster care and 
achieve permanency through reunification with their birth or legal 
parents, adoption, legal guardianship with a relative, or 
independence.[Footnote 5] As of September 2002, a child's length of 
stay in the District's foster care program averaged 2.8 years.

Figure 1: CFSA Responsibilities Related to Permanency Goals:

[See PDF for image]

[End of figure]

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

CFSA Undertook Actions to Implement Most ASFA Requirements Reviewed and 
Met Half of the Selected Performance Criteria for Child Safety and 
Well-Being:

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

Table 1: CFSA's Progress in Implementing Nine ASFA Requirements:

ASFA requirements CFSA has implemented: 1. Include the safety of the 
child in state case planning and in a case review system; 
ASFA requirements CFSA has not fully implemented: 1. Initiate or join 
proceedings to terminate parental rights for certain children in foster 
care--such as those who have been in foster care for 15 of the most 
recent 22 months of care.

ASFA requirements CFSA has implemented: 2. Comply with requirements for 
criminal background clearances and have procedures for criminal record 
checks; ASFA requirements CFSA has not fully implemented: 2. 
Provide participants a notice of reviews and hearings and an 
opportunity to be heard.

ASFA requirements CFSA has implemented: 3. Develop a case plan 
documenting steps taken to provide permanent living arrangements for a 
child; ASFA requirements CFSA has not fully implemented: 3. 
Conduct mandatory permanency hearings every 12 months for a child in 
foster care.

ASFA requirements CFSA has implemented: 4. Develop plans for the 
effective use of cross-jurisdictional resources to facilitate timely 
adoptive or permanent placements for waiting children.

ASFA requirements CFSA has implemented: 5. Provide for health insurance 
coverage for children with special needs in state plans for foster care 
and adoption assistance.

ASFA requirements CFSA has implemented: 6. Incorporate standards to 
ensure quality services for children in foster care in state plans.

Source: ASFA and HHS's CSFR and GAO analysis.

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

[End of table]

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

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

Table 2: Analysis of Selected Foster Care Performance Criteria:

Foster care performance criteria: Current case plans for foster care 
cases; Forty-five percent of foster care cases have current case 
plans; Analysis: Met; Analysis: As of September 30, 2002, 46 percent 
of foster care cases had current case plans.

Foster care performance criteria: Visitation between children in foster 
care and their parents; Thirty-five percent of cases in which children 
have a permanency goal of return home have parental visits at least 
every 2 weeks; Analysis: Not met; Analysis: As of November 30, 2002, 1 
percent of children with a return home goal had parental visits at 
least every 2 weeks.

Foster care performance criteria: Social worker visitation with 
children in foster care; Twenty-five percent of children in foster 
care have weekly visits with social workers in their first 8 weeks of 
care; 35 percent of all children in foster care have at least monthly 
visits; Analysis: Not met; Analysis: As of November 30, 2002, no 
children had weekly visits and at least 98 percent of children did not 
have monthly visits with a caseworker.[A].

Foster care performance criteria: Appropriate legal status for children 
in foster care; No child in emergency care for more than 90 days; 
Analysis: Met; Analysis: As of November 30, 2002, no children in 
emergency care more than 90 days.

Foster care performance criteria: Current and valid foster home 
licenses; Seventy-five percent of children are placed in foster homes 
with valid licenses; Analysis: Not met; Analysis: As of November 30, 
2002, 47 percent of children were in foster homes with valid licenses.

Foster care performance criteria: Progress toward permanency; No more 
than 10 percent of children in foster care have a permanency goal of 
return home for more than 18 months; Analysis: Not met; Analysis: As 
of November 30, 2002, 30 percent of children had a permanency goal of 
return home more than 18 months.

Foster care performance criteria: Foster care placement with siblings; 
Sixty percent of children in foster care are placed with one or more of 
their siblings; Analysis: Met; Analysis: As of November 30, 2002, 63 
percent of children were placed with one or more siblings.

Foster care performance criteria: Placement stability; No more than 25 
percent of children in foster care as of May 31, 2002, have had three 
or more placements; Analysis: Met; Analysis: As of November 30, 2002, 
21 percent of children had three or more placements.

Source: GAO analysis.

[A] For 2 percent of the children, caseworker visits equaled or 
exceeded the number of months in placement. However, CFSA's data did 
not allow us to determine when caseworkers visited children or if they 
visited children each month.

[End of table]

CFSA's Program Improvement Plan, a plan required by HHS to address 
those areas determined not met in a CFSR, identifies how it will 
address two of the unmet ASFA requirements--(1) to initiate or join 
proceedings to terminate parental rights (TPR) of certain children in 
foster care and (2) to ensure that children have a permanency hearing 
every 12 months after entering foster care. For example, CFSA has 
outlined steps to improve its filings of TPR petitions with the Family 
Court. To help facilitate this process, CFSA hired additional attorneys 
to expedite the TPR proceedings. The new attorneys have been trained in 
ASFA requirements and in the process for referring these cases to the 
Family Court. CFSA is also developing a methodology for identifying and 
prioritizing cases requiring TPR petitions. In another plan, the April 
2003 Implementation Plan, CFSA states that it will redesign its 
administrative review process to improve, among other things, 
notification and attendance of relevant parties and to provide for a 
comprehensive review of case progress, permanency goals, and adequacy 
of services. However, this plan does not make it clear whether all 
applicable hearings and proceedings will be included, such as 
permanency hearings.

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

CFSA officials cited several factors that hindered their ability to 
fully implement the ASFA requirements and meet the selected performance 
criteria, including court-imposed requirements, staffing shortages, 
and high caseloads. For example, program managers and supervisors said 
that the new court-imposed mediation process intended to address family 
issues without formal court hearings places considerable demands on 
caseworkers' time. The time spent in court for mediation proceedings, 
which can be as much as 1 day, reduces the time available for 
caseworkers to respond to other case management duties, such as 
visiting with children in foster care. Furthermore, managers and 
supervisors reported that staffing shortages have contributed to delays 
in performing critical case management activities, such as identifying 
cases for which attorneys need to file TPR petitions. However, staffing 
shortages are not a unique problem to CFSA. We recently reported that 
caseworkers in other states said that staffing shortages and high 
caseloads had detrimental effects on their abilities to make well-
supported and timely decisions regarding children's safety.[Footnote 6] 
We also reported that as a result of these shortages, caseworkers have 
less time to establish relationships with children and their families, 
conduct frequent and meaningful home visits, and make thoughtful and 
well-supported decisions regarding safe and stable permanent 
placements.

CFSA Has Established Many Foster Care Policies but Lacks Others, and 
the Extent of Implementation and Documentation Varies:

CSFA has established many foster care policies, but caseworkers did not 
consistently implement the six we selected. These policies covered the 
range of activities involved in a foster care case, but did not 
duplicate those examined in our review of the AFSA requirements or the 
selected foster care performance criteria. In addition, CFSA's 
automated system lacked data on four of the six policies we examined 
for at least 70 percent of its active foster care cases. Without 
information on all cases, caseworkers do not have a readily available 
summary of the child's history needed to make decisions about a child's 
care and managers do not have information needed to assess and improve 
program operations.

CSFA Has Established Many Foster Care Policies, but Caseworkers Did Not 
Consistently Implement Those We Selected:

While we previously reported in 2000[Footnote 7] that CFSA lacked some 
important child protection and foster care placement policies, CFSA has 
now established many such policies and most are comparable to those 
recommended by organizations that develop standards applicable to child 
welfare programs. For example, CFSA has policies for investigating 
allegations of child abuse, developing case plans, and establishing 
permanency goals for foster children. In addition, one policy is more 
rigorous than suggested standards. Specifically, CFSA's policy requires 
an initial face-to-face meeting with children within 24 hours of 
reported abuse or neglect, while the suggested standard is 24 to 48 
hours or longer, depending on the level of risk to the child's safety 
and well-being. However, CFSA does not have some recommended policies, 
namely those addressing (1) written time frames for arranging needed 
services for children and families (e.g., tutoring for children and 
drug treatment for family members); (2) limits on the number of cases 
assigned to a caseworker, based on case complexity and worker 
experience; and (3) procedures for providing advance notice to each 
person involved in a case about the benefits and risks of services 
planned for a child and alternatives to those services. CFSA managers 
said that the agency had not established these policies because agency 
executives gave priority to complying with court-ordered requirements.

CFSA did not consistently implement the policies we examined. We 
selected six policies that did not duplicate those examined in our 
review of the AFSA requirements or the selected foster care performance 
criteria in order to cover most of the case management duties and 
responsibilities. CFSA could not provide automated data regarding the 
implementation of one policy requiring administrative review hearings 
every 6 months.[Footnote 8] As for the remaining five policies, data in 
FACES indicate that caseworkers' implementation of them varied 
considerably. Table 3 summarizes these five policies and the percentage 
of cases for which the data indicated the policy was implemented.

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

Policy: Initiate face-to-face investigation of alleged child abuse or 
neglect within 24 hours of receiving an allegation on CFSA's child 
abuse hotline; Percent of foster care cases for which the policy was 
implemented[A, B]: 26.

Policy: Complete a safety assessment within 24 hours of face-to-face 
contact with the child; Percent of foster care cases for which the 
policy was implemented[A, B]: 13.

Policy: Complete a risk assessment within 30 days of receiving an 
allegation on the hotline; Percent of foster care cases for which the 
policy was implemented[A, B]: 73.

Policy: Complete an initial case plan within 30 days of a child's entry 
into foster care; Percent of foster care cases for which the policy 
was implemented[A, B]: 9.

Policy: Arrange needed services for foster care children or their 
families; Percent of foster care cases for which the policy was 
implemented[A, B]: 83.

Source: FACES data and GAO analysis.

[A] With the exception of the policy to arrange needed services, the 
analysis is based on 943 foster care cases that were at least 6 months 
old, as of November 30, 2002. These cases were initiated after FACES 
came on-line in October 1999. The analysis of the policy to arrange for 
needed services is based on 1,837 foster care cases and includes cases 
that predated FACES but for which services were provided after FACES 
came on-line. Data show the percentage of cases for which caseworkers 
arranged at least one service.

[B] CFSA counted cases that had missing data as instances of caseworker 
noncompliance with the applicable policy.

[End of table]

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

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

Policy: Initiate face-to-face investigation of alleged child abuse or 
neglect within 24 hours of receiving an allegation; Fiscal Year: 2000: 
61; Fiscal Year: 2001: 66; Fiscal Year: 2002: 16; Total: 
143.

Policy: Complete a safety assessment within 24 hours of face-to-face 
contact with child; Fiscal Year: 2000: 101; Fiscal Year: 2001: 122; 
Fiscal Year: 2002: 50; Total: 273.

Source: FACES data and GAO analysis.

[End of table]

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

We also found that for almost half of the cases we examined 
administrative review hearings, which are held to ensure that key 
stakeholders are involved in decisions about a child's permanent 
placement, were rescheduled, resulting in their being held less 
frequently than required by CFSA policy. CFSA policy requires that 
these hearings be held every 6 months, and FACES automatically 
schedules them to occur 6 months after the most recent hearing. 
However, CFSA officials are unable to track how frequently they are 
rescheduled or the length of time between hearings because the system 
overrides the dates of prior hearings. Agency officials explained that 
changes have been made to FACES to enable them to track how many times 
an administrative review is re-scheduled. Long delays between 
administrative review hearings could mean delays in getting children 
into permanent placement. As for arranging needed services, we could 
not determine from case files or FACES whether services recommended by 
caseworkers were approved by supervisors or if all needed services were 
provided. The FACES data indicate that at least one service was 
provided for 83 percent of the cases, but do not include a complete 
record of all services caseworkers determine to be needed, nor do they 
indicate whether the services were provided on a timely basis.

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

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

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

CFSA Has Established Policies and Goals for Group Homes:

In addition to its policies for managing cases, CFSA has policies for 
licensing and monitoring group homes, plans for training staff in group 
homes, and a goal to reduce the number of young children in group 
homes. CFSA's policies for group homes are based primarily on District 
regulations that went into effect July 1, 2002. For example, the 
regulations prohibited CFSA from placing children in an unlicensed 
group home as of January 1, 2003. According to CFSA officials, as of 
March 2003, all CFSA group homes were licensed, except one, and CFSA 
was in the process of removing children from that home. CFSA plans to 
monitor group homes by assessing their compliance with contractual 
provisions and licensing requirements. CFSA also plans to provide 
training to group home staff to make it clear that, as District 
regulations require, any staff member who observes or receives 
information indicating that a child in the group home has been abused 
must report it. Further, CFSA has a goal to reduce the number of 
children under 13 who are placed in group homes. According to agency 
officials, CFSA has reduced the number of children under 13 in group 
homes from 128 in August 2002 to 70 as of February 2003 and has plans 
to reduce that number even further by requiring providers of group home 
care to link with agencies that seek foster care and adoptive families.

CFSA's Automated System Lacked Data on Many Foster Care Cases:

In our efforts to assess CFSA's implementation of the selected foster 
care policies related to the safety and well-being of children as shown 
in table 3, we determined that FACES lacked data on many active foster 
care cases. In December 2000, we reported that FACES lacked complete 
case information, and caseworkers had not fully used it in conducting 
their daily casework.[Footnote 9] During our most recent review, we 
determined that FACES lacked data on four of six foster care policies 
for at least 70 percent of its active foster care cases.[Footnote 10] 
Of the 2,510 foster care cases at least 6 months old as of November 30, 
2002, data were not available for 1,763. CFSA officials explained that 
all of these cases predated FACES, and the previous system was used 
primarily to capture information for accounting and payroll purposes, 
not for case management. Top agency managers said that CFSA does not 
plan to make it an agency priority to transfer information kept in 
paper files for cases that predated FACES into the system. 
Additionally, FACES reports show that data were not available on many 
of the cases that entered the foster care system after FACES came on 
line. For example, complete data on the initiation of investigations 
and completion of safety assessments were not available for about half 
of the 943 cases that entered the foster care system after FACES came 
on line. CFSA officials explained that they intend to focus on 
improving a few data elements at a time for current and future events.

Having systems that provide complete and accurate data is an important 
aspect of effective child welfare programs. HHS requires all states and 
D.C. to have an automated child welfare information system. These 
systems, known as SACWIS, must be able to record data related to key 
child welfare functions, such as intake management, case management, 
and resource management. In its review of FACES, HHS found CFSA's 
system was in compliance with most of the requirements and identified 
several that needed improvement, including the requirements to prepare 
and document service/case plans and to conduct and record the results 
of case reviews.[Footnote 11] According to a CFSA official, D.C. 
responded to the HHS report and made changes to address most of the 
findings. He said that the changes included redesigning the FACES 
screens documenting service/case plans and the results of case reviews. 
These changes were made in collaboration with caseworkers to help 
improve usability.

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

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

CFSA Has Enhanced Its Working Relationship with the D.C. Family Court 
by Working Collaboratively, but Hindrances Remain:

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

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

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

Conclusions:

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

Recommendations:

To improve CFSA's performance and outcomes for foster care children in 
the District of Columbia, we recommend that the Mayor require the 
Director of CFSA to (1) develop plans to fully implement all ASFA 
requirements; (2) establish procedures to ensure that caseworkers 
consistently implement foster care policies; and (3) document in FACES 
all activities related to active foster care cases, including 
information from paper case files related to the history of each active 
foster care case.

Agency Comments and Our Evaluation:

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

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

The CFSA Director also made several detailed comments. As she 
suggested, we added language to clarify the requirement for a 
permanency hearing, included information on changes made to FACES 
regarding rescheduling administrative reviews and corrected the number 
of CFSA staff assigned to the Family Court. We did not include the 
March 2003 data listed in the comments because we could not verify the 
accuracy of the data.

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

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

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

Sincerely yours,

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

Signed by Cornelia M. Ashby:

[End of section]

Appendix I: Scope and Methodology:

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

To perform our assessment of CFSA's performance with regard to the 
selected performance criteria established during its probationary 
period, we obtained and analyzed relevant automated data from 
FACES[Footnote 12] on all active foster care cases as of November 30, 
2002, the last complete month for which data were available at the time 
of our work. We analyzed these data for six of the eight criteria. For 
the other two criteria, we analyzed data on all foster homes as of 
November 30, 2002, and data on case plans as of September 30, 2002. 
Additionally, we obtained and analyzed automated FACES data for 943 
foster care cases that were at least 6 months old as of November 30, 
2002, to assess how CFSA caseworkers implemented foster care policies 
that covered several key functions from investigations through the 
delivery of services to foster children and their families. Many of the 
active foster care cases began prior to October 1999.

We also obtained and analyzed reports by the court-appointed monitor to 
assess CFSA's performance relative to the specified requirements and 
criteria. In addition, we reviewed and included relevant information 
from several of our prior reports on CFSA and the District's Family 
Court. In addition, we independently verified the reliability of 
automated data by reviewing related reports on the data maintained in 
FACES and by assessing the degree to which FACES contained erroneous or 
illogical data entries. To obtain additional information on policy 
implementation and documentation, we reviewed case files for children 
who entered the foster care system at different times. Our case file 
review included analyses of data contained in FACES and in paper case 
files for selected foster care cases. We pretested our data collection 
instrument for collecting case file information and received training 
in the content and use of FACES. In addition, while FACES did not 
contain all data on the implementation of the policies we selected, we 
analyzed information on CFSA's most recent performance to provide a 
comprehensive assessment of various agency initiatives intended to 
improve implementation of foster care policies. We also reviewed 
federal and local laws, regulations, and selected CFSA policies. Using 
interview protocols, we interviewed CFSA executives, managers, and 
supervisors; OCC officials; the Office of the Deputy Mayor for 
Children, Youth, Families, and Elders; Family Court judges and other 
court officials; and child welfare experts in organizations that 
recommend policies applicable to child welfare programs.

[End of section]

Appendix II: Comments from the Director of the Child and Family Services 
Agency:

GOVERNMENT OF THE DISTRICT OF COLUMBIA 
Child and Family Services Agency:

May 21, 2003:

Cornelia M. Ashby, Director:

Education, Workforce, and Income Security Issues 
United States General Accounting Office:

441 G Street, NW Washington, DC 20548:

On behalf of the Deputy Mayor Children, Youth Families and Elders, 
thank you for the opportunity to comment on the draft GAO report about 
Child and Family Services Agency progress in meeting requirements of 
the Adoption and Safe Families Act (ASFA). We appreciate your overall 
finding that CFSA has made important progress and must continue to make 
additional significant improvements. This perspective matches our own 
as well as that of other independent reviewers such as the Council for 
Court Excellence and Federal Court Monitor under the LaShawn A. v. 
Williams lawsuit.

We also appreciate your recognition of progress CFSA has made in 
improving institutional relationships (particularly with the Family 
Court), in implementation of key ASFA requirements, in policy 
development, and in improving the safety net for children through 
speedier investigations and other measurable indicators. We generally 
agree with areas GAO has identified for continued improvement.

We have three overall comments about the draft report and several 
detailed comments.

Overall Comments:

* Implementation Plan: The District has a comprehensive plan for 
addressing a vast range of child welfare reforms, including areas you 
noted as requiring improvement. That is the Implementation Plan in the 
LaShawn A. v. Williams lawsuit just approved by District Judge Thomas 
F. Hogan May 15, 2003. The District provided extensive input during 
negotiation of this plan and is committed to meeting its challenging 
requirements, which include performance benchmarks at specific 
intervals between June 30, 2003, and Dec. 31, 2006. We recommend that 
the text of the report be modified to say that the District and CFSA 
should carry out the Implementation Plan rather than develop new plans. 
Implementation Plan citations for items where GAO reports no plan:

* Timely notification is covered in Outcome 2c and Implementation 
Strategy #1e of Chapter X (Case Review System.):

* Reducing the number of children in foster care for 18 months or more 
with a permanency goal of returning home is covered under Special 
Corrective Action (Chapter XIX).

Recent Establishment of CFSA: We believe that it is important to the 
accuracy of the report to note that District statute established CFSA 
as a single Cabinet-level District agency in April 2001, that the 
Federal Court receivership ended in June 2001, and that key provisions 
of the legislation (in particular, unification of neglect and abuse 
investigations under CFSA) took effect in October 2001. This major 
statutory reform carried out as part of the consent agreement that 
returned control of CFSA to the District also, for the first time, 
created the basis for a unified safety net for District children. Under 
the previous fragmented system, no one agency had complete authority 
over basic child welfare functions, and children and families too often 
fell through the cracks. We recommend that you include this information 
in the summary of statutory changes at the beginning of the report as 
well as in the Background section. It is also key to several of the 
specific findings, as it clarifies the starting point and the speed of 
progress made by CFSA and the District.

Time Frames of Receivership vs District Control: Because the unified 
child welfare safety net is so recent, it is important to clarify 
throughout the text information that pertains to the time before June 
2001 (when the agency was still in receivership and the system was 
still fragmented, because the establishment legislation that unified 
the system had not yet taken effect) versus after that date (when child 
welfare had returned to District control) and the trend over time. We 
appreciate efforts to address these issues in the text and in the table 
on page 16. We recommend moving these findings to the Executive Summary 
at the beginning. Other places in the text where we think it would be 
helpful to clarify timing include the following.

* The HHS review in 2001 reviewed cases from the previous year. Thus, 
it did not address the current system but provided a baseline regarding 
the pre-unification system, when child welfare was divided among 
agencies, and CFSA was under Federal Court 
receivership. Wherever the HHS review is referenced, it would be 
helpful to note that this is baseline information about child welfare 
before the agency's return to District control. 

* Data collected and 
analyzed by GAO generally covered October 1999 to mid-2002. As noted 
above, we appreciate the effort on page 16 to distinguish between 
performance before the current system began and performance afterwards. 
We recommend that in each place where these data are discussed, the 
time period covered and date of the change should also be explained. 
For example: These data cover performance over the period from October 
1999 to mid-2002. CFSA returned to District control in June 2001 and 
became a unified child welfare agency in October 2001.

Specific Comments:

In the chart on page 8 and in the related text, it appears that GAO 
believes the ASFA requirement is for a permanency hearing within 12 
months of removal. In fact, ASFA requires a permanency hearing with 12 
months of "entry into foster care," which is not defined as removal but 
as the date of the first judicial finding that the child has been 
neglected (the adjudication) or 60 days after removal, whichever is 
earlier. In most cases, this means the date the first permanency 
hearing is required is actually 14 months after removal, not 12 months. 
This is significant since both CFSA and court data since October 2002 
show that in about 82 percent of cases where a child entered care in 
the last 18 months and where the permanency deadline has passed, 
permanency hearings have been timely.

* Where appropriate, we recommend that GAO include current information.. 
In March 2003, for example:

* Investigations open for less than 30 days was 77.5%. 
* Children receiving a monthly visit was 44%.

* The report states: "CFSA's automated system lacked data on four of 
the six policies for at least 70 percent of its active foster care 
cases." (p.14). The report also states that detailed management 
information was missing in FACES for about two-thirds of the cases. 
Many of the cases GAO reviewed predate implementation of FACES in late 
1999, many others predate the unification of the child welfare system 
under CFSA in October 2001, and automated data that cover the 
management and process 
measures studied by GAO are not available largely for those reasons. 
The reports states that "without information on all cases, managers do 
not have information needed to assess program operations and make 
improvements, if needed." (p. 14). However, like workers in many child 
welfare agencies throughout the country, CFSA social workers use hard 
copy records to access information that predates FACES.

We want to emphasize that, as highlighted in CSFA's Congressional 
testimony, we are deeply committed to continuing improvements in our 
FACES information system, which is a strong case management system that 
meets most Federal requirements. We anticipate applying for full 
Federal certification of all requirements during the coming year, a 
status currently achieved by only four states. We are open to learning 
about strategies for remedying the specific issue raised by GAO - the 
gaps in data that come from the failure of past, less strong data 
systems - but as we have explored with other states and national 
experts the strategies that have been explored elsewhere, we found no 
state that had a solution to recommend beyond the approach that CFSA 
has already taken, which is to do a "data dump" limited to those 
elements of the old data systems that were generally of high quality.

* The report states: "The unmet requirements and performance criteria 
not addressed in the plans are those related to providing timely 
notification of all reviews and hearings . . . " (p.3). CFSA is 
preparing to implement a review notification system (mentioned briefly 
on page 18) designed to automate the notification process so that we 
are able to greatly increase 
timeliness. On a related matter, the report points out that the FACES 
system overwrites the scheduled administrative review with the re-
scheduled review. This is because we were previously unable to track 
how many times a review was re-scheduled. This issue has been resolved 
in FACES. Since drafting of the report, we are able to track how often 
an administrative review is re-scheduled.

The sentence on page 21 that begins "Additionally, CFSA assigned 
two..." should read: In addition, CFSA assigned a liaison 
representative to the Family Court who is responsible for working with 
other District agency liaison representatives to assist social workers 
and case managers in identifying and accessing court-ordered services 
for children and their families at the Family Court. ":

Olivia Golden, Director:

Child and Family Services Agency:

Signed by Olivia Golden: 

[End of section]

Appendix III: GAO Contacts and Acknowledgments:

GAO Contacts:

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

Acknowledgments:

[End of section]

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

[End of section]

Related GAO Products:

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

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

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

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

District of Columbia: More Details Needed on Plans to Integrate 
Computer Systems With the Family Court and Use Federal Funds. GAO-02-
948. Washington, D.C.: August 7, 2002.

Foster Care: Recent Legislation Helps States Focus on Finding Permanent 
Homes for Children, but Long-Standing Barriers Remain. GAO-02-585. 
Washington, D.C.: June 28, 2002.

D.C. Family Court: Progress Made Toward Planned Transition and 
Interagency Coordination, but Some Challenges Remain. GAO-02-797T. 
Washington, D.C.: June 5, 2002.

D.C. Family Court: Additional Actions Should Be Taken to Fully 
Implement Its Transition. GAO-02-584. Washington, D.C.: May 6, 2002.

D.C. Family Court: Progress Made Toward Planned Transition, but Some 
Challenges Remain. GAO-02-660T. Washington, D.C.: April 24, 2002.

District of Columbia Child Welfare: Long-Term Challenges to Ensuring 
Children's Well-Being. GAO-01-191. Washington, D.C.: December 29, 2000.

Foster Care: Status of the District of Columbia's Child Welfare System 
Reform Efforts. GAO/T-HEHS-00-109. Washington, D.C.: May 5, 2000.

FOOTNOTES

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

[2] Child and Family Services Reviews, conducted by HHS, cover a range 
of child and family service programs funded by the federal government, 
including child protective services, foster care, adoption, independent 
living, and family support and preservation services. The 2001 review 
evaluated seven specific safety, permanency, and well-being outcomes 
for services delivered to children and families served by CFSA. As part 
of its review, HHS randomly selected 50 active child welfare cases from 
the period between April 2000 and July 2001. 

[3] The District of Columbia Family Court Act of 2001 (P.L. 107-114), 
established the Family Court as part of the D.C. Superior Court. The 
Family Court replaced the Family Division of the D.C. Superior Court. 
Among other responsibilities, the Family Court handles child abuse and 
neglect cases, court hearings, and other proceedings for the District's 
foster children and their families. OCC, among its other 
responsibilities, provides legal support to CFSA on foster care cases.

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

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

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

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

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

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

[10] The four polices for which FACES lacked data included (1) initiate 
face-to-face investigation of alleged child abuse or neglect within 24 
hours of receiving an allegation on CFSA's child abuse hotline, (2) 
complete a safety assessment within 24 hours of face-to-face contact 
with the child, (3) complete a case plan within 30 days of a child's 
entry into foster care, and (4) schedule and attend administrative 
review hearings every 6 months. 

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

[12] CFSA's automated case management system.

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