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March 11, 2008

Kathleen McHugh, Director

Division of Policy -- Children's Bureau

Administration for Children and Families

U.S. Department of Health and Human Services

1250 Maryland Avenue SW, Suite 800

Washington, DC 20024

[Re: January 11, 2008 Notice of Proposed Rulemaking Concerning the
Adoption and Foster Care Analysis and Reporting System ("AFCARS"); 72
Federal Register 2082-2142]{.underline}

Dear Ms. McHugh:

By this letter, the Council of Family & Child Caring Agencies (COFCCA)
submits comments on the Notice of Proposed Rulemaking (NPRM) concerning
the Adoption and Foster Care Analysis and Reporting System (AFCARS),
published in the Federal Register on January 11, 2008 at 72 Federal
Register pages 2082-2142. COFCCA represents over 100 not-for-profit
agencies in New York State that contract with all of the counties
including New York City to provide foster care and preventive services;
approximately 24,500 New York State youth are in placement at a private
agency under contract with a New York State county. Given the number and
proportion of the state's foster care youth being served by our
agencies, and given the all-encompassing nature of the services provided
to these children and families, we submit that New York State contract
agencies are a significant group of stakeholders in the proposed changes
to AFCARS. We have organized our comments on the changes as delineated
by the categories in the NPRM Overview:

1.  Restructuring Data

2.  Expanding Reporting Populations

3.  Capturing Greater Detail

4.  Improving Data Quality

5.  Eliminating Unnecessary Features

1\. Restructuring Data

We found this section to be somewhat disingenuous, since the
"restructuring" as described is not a mere adjustment to the data but in
fact the collection of considerably more data than is being collected
presently and which is not being captured by CONNECTIONS, the current
New York State Statewide Automated Child Welfare Information System
(SACWIS). Our agencies have some experience with working with
longitudinal data, as we track youth placements over time for billing
purposes. A software program or data system collecting even simple
longitudinal data for billing is highly complex, creates vast amounts of
data to be stored and managed, and takes considerable manpower in data
entry and maintenance. While we can understand its usefulness for
academic and research purposes, it requires a considerable lift for New
York State and its agencies at a time when it cannot absorb these types
of financial and staffing costs.

2\. Expanding Reporting Populations

While we appreciate the intent of the idea to expand the populations
about which states might report, we question the usefulness of
collecting data on youth being served in non-foster care placements and
combining it with foster care data. Of course there can be, and often
is, overlap between foster care and the juvenile justice, mental health,
and other youth systems, but there are enough differences between the
populations that we posit combining the data would not lead to increased
clarity about *any* of the groups. Additionally, each of these systems
already has its own reporting methodology as required by various
Federal, state, and local laws; in New York State these systems are not
in any way connected, do not share common data definitions, and are used
by entirely different sets of personnel in both the public and private
sectors. We do not believe the outcome of collecting and analyzing this
data along with foster care data would create enough added value to
justify the incredible cost and staff energy we anticipate it would take
to retool the existing systems, link them together, and retrain
thousands of staff across the state.

3\. Capturing Greater Detail

Currently, case- and child-specific detail is captured in CONNECTIONS by
line workers in both the public and private agencies of New York.
Generally, we have found that if the public agency worker is not able to
collect needed data at the time of a child removal, it becomes the
responsibility of the contract agency case worker to go back and fill in
any information gaps. Because of poor funding and other issues, we are
already burdening our line workers with too many cases, too many
documentation responsibilities, and too little time to do actual work
with the families in our care. Recent data audits conducted by OCFS and
our largest local district, the New York City Administration for
Children's Services, have shown us that line staff workers are already
having a very difficult time meeting all the data collection needs of
those who regulate and fund our agencies. OCFS conducted a study in 2006
to analyze how line workers use their time; the results detailed that
the case planners responsible for helping families safely to
reunification, terminating parental rights and effecting children's
adoptions, and preparing older youth for adulthood have face-to-face
contact with their clients a dismal average of *54 minutes a month*.

Again we are faced with what is cost-effective and what is a value-added
activity when looking at the big picture: creating safe and permanent
outcomes for children. We at COFCCA understand the value of research --
we encourage our agencies to participate in research, we follow research
studies and report the results to our members, and we seek out those who
would conduct research that lead us to better case practice. We have
found that our agencies have participated in or performed their own
research and trend analyses, usually based on what dynamics they are
seeing in their regional environment or within the population they
serve. These types of studies can often have increased value for
informing agency practice and advocacy over and above what national or
statewide studies provide because of their small, specific focus and
consistency of controlled variables.

We assert that imposing greater data collection demands on our line
staff will decrease their ability to serve families, while not providing
them with sufficient reciprocal benefits.

4\. Improving Data Quality

We find ourselves agreeing with the principles put forth in the NPRM
regarding clarifying the data element descriptions. Many of the terms
used now can be confusing or counter-intuitive to workers, especially
since the terms being used in an AFCARS context may be similar to terms
being used in practice but with different meaning. We do not believe
this will be a cost-neutral transition, though, and are interested in
hearing details of what funding will be made available to the states to
re-train the thousands of New York State caseworkers who will be charged
with entering this important data.

5\. Eliminating Unnecessary Features

On this we can wholeheartedly agree. While the specific items being
slated for elimination (e.g. submission of summary adoption and foster
care files) do not directly affect our agencies, we are always happy to
support discontinuing an activity when it no longer makes sense to do
it. We support this change, and recommend that the Administration for
Children and Families continue their efforts to seek out and eliminate
other requirements that may have outlived their usefulness.

We encourage ACF to take these comments, and the observations of other
stakeholders directly affected by the changes to AFCARS, and give
careful thought to what will eventually be implemented. We implore you
to recognize that there are substantial costs involved in data
collection, and that in almost every instance it is the front line
caseworkers -- both public and private sector -- who must take the time
to gather and enter this data. ACF is responsible for justifying the
costs of such efforts against the limited time already available to
these workers to engage directly with the children and families we
serve. Consider which changes will and which will not best support the
permanency, safety, and well-being of children in foster care, and move
cautiously instead of swiftly when making your decision and implementing
your plans.

Thank you for this opportunity to submit comments.

Very truly yours,

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James F. Purcell

CEO