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Improvements Used to Implement New Programs, but Challenges Remain' 
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Report to Congressional Committees: 

July 2005: 

District Of Columbia: 

Federal Funds for Foster Care Improvements Used to Implement New 
Programs, but Challenges Remain: 

GAO-05-787: 

GAO Highlights: 

Highlights of GAO-05-787, a report to congressional committees: 

Why GAO Did This Study: 

To help improve foster care in the District of Columbia, the Congress 
provided $14 million for fiscal year 2004 to the Child and Family 
Services Agency (CFSA), the Department of Mental Health (DMH), and the 
Metropolitan Washington Council of Governments (COG). These funds were 
for programs for early intervention, emergency support, and student 
loan repayments; computer technology upgrades, mental health services, 
and respite care (short-term care to provide relief for foster 
parents). GAO was asked to (1) assess whether the federal funds were 
being obligated and expended by the District government and COG 
consistent with provisions in the District of Columbia Appropriations 
Act, 2004, and the spending plans that were submitted to the Congress; 
(2) determine whether internal controls were operating effectively over 
the obligations and disbursements; and (3) assess the extent to which 
the District government and COG have implemented the foster care 
improvement programs and initiatives specified in the act and spending 
plans. 

GAO received written comments from CFSA, DMH, and COG. The agencies 
generally agreed with GAOs findings and conclusions. 

What GAO Found: 

The District and COG have used the federal funds for foster care 
improvements as intended by the Congress and as described in their 
respective spending plans. As of March 31, 2005, about $13.2 million of 
the funds provided had been obligated, about $6.2 million of the 
obligated funds had been expended, and about $722,524 remained 
unobligated. The unobligated funds for CFSA and DMH, in the amounts of 
$588,859 and $30,545 respectively, ceased to be available for new 
obligations after September 30, 2004, and should revert to the general 
fund of the U.S. Treasury. However, there is no such fiscal limitation 
on COGs use of the funds it received; thus, its unobligated $103,120 
remains available for its foster care improvement program. 

Internal controls were generally operating effectively over obligations 
related to the federal funds at CFSA and DMH. Overall, we found that 
authorized personnel were processing and approving transactions and 
transactions were adequately supported. However, we found three 
instances worth discussion. These involved the need for sufficient 
documentation, better adherence to operating procedures and greater 
control over physical assets. 

CFSA, DMH, and COG have implemented the programs and initiatives 
specified in the appropriations act and spending plans; however, it is 
too early to assess the effectiveness of some and challenges remain for 
others. Although implementation of the early intervention program was 
delayed, this program helped about 150 families. Also, the emergency 
support fund helped about 100 kinship familiesrelatives who provide 
foster care. However, it will be a challenge for CFSA to reduce the 
number of unlicensed kinship homesone program goal. Although most of 
CFSAs unlicensed homes are not kinship homes, 265 of the 300 
unlicensed homes are not in the District and officials from other 
jurisdictions will play a role in the licensing process. About 70 
percent of CFSAs eligible caseworkers participated in the agencys 
student loan repayment program. This program was intended to help 
recruit and retain caseworkers, but CFSAs attrition rate increased 
from about 15 percent in 2003 to about 18 percent in 2004. CFSA 
developed an information technology plan that indicates the system 
upgrades will be completed by the end of 2005, and provided laptops to 
some caseworkers. DMH increased mental health services available to 
foster care children; however, it faces ongoing challenges in building 
its capacity to provide assessments and in securing long-term funding 
for treatment services. COG established a respite program for foster 
parents, but few families completed the required licensing process, and 
fewer placements were made than anticipated. It may be a challenge for 
COG to recruit, train, and license enough respite providers and 
convince foster parents to participate. 

www.gao.gov/cgi-bin/getrpt?GAO-05-787. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Jeanette Franzel at (202) 
512-9471 or franzelj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

CFSA, DMH, and COG Obligated and Spent Funds for Purposes Consistent 
with the Appropriations Act and Spending Plans, but Some Funds Were Not 
Used: 

Internal Controls Are Generally Operating Effectively: 

New Programs Have Been Implemented to Improve Foster Care, but 
Challenges Remain: 

Concluding Observation: 

Agency Comments and Our Evaluation: 

Appendixes: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the District's Child and Family Services 
Agency: 

Appendix III: Comments from the District's Department of Mental Health: 

Appendix IV: Comments from the Metropolitan Washington Council of 
Governments: 

Appendix V: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Purposes and Plans for the Fiscal Year 2004 Foster Care 
Improvement Funds: 

Table 2: Funds Received, Obligated, and Unobligated by CFSA, DMH, and 
COG, as of March 31, 2005: 

Table 3: Eligible Services and Supports Provided through the Early 
Intervention Program: 

Table 4: Key Steps in CFSA's Information Technology Plan, as of June 
15, 2005: 

Table 5: Foster Care Children Receiving Mental Health Treatment: 

Figures: 

Figure 1: Types and Numbers of Services Provided to Families with Early 
Intervention Program Funds: 

Figure 2: Number and Types of Services Provided to Families with 
Emergency Support Funds: 

Figure 3: Distribution of Student Loan Repayment Amounts: 

Letter July 22, 2005: 

The Honorable Sam Brownback: 
Chairman: 
The Honorable Mary Landrieu: 
Ranking Minority Member: 
Subcommittee on the District of Columbia: 
Committee on Appropriations: 
United States Senate: 

The Honorable Joe Knollenberg: 
Chairman: 
The Honorable John W. Olver: 
Ranking Minority Member: 
Subcommittee on Transportation, Treasury, and Housing and Urban 
Development, The Judiciary, District of Columbia, and Independent 
Agencies: 
Committee on Appropriations: 
House of Representatives: 

In fiscal year 2003, about 3,000 children in the District of Columbia 
(the District) were under the care of the city's Child and Family 
Services Agency (CFSA). Most of these children had been removed from 
their homes because of abuse or neglect and were being cared for by 
foster parents or relatives, known as kinship families. These foster 
children and the families that care for them need various services and 
support. CFSA is the District government agency with primary 
responsibility for ensuring the proper care of these children, and it 
works with several other District agencies to provide essential 
services to the children and their families. One of these is the 
Department of Mental Health (DMH), which provides comprehensive mental 
health services to foster children as well as to other children, 
teenagers, adults, and families. Mental health services are considered 
critical for children who have suffered abuse or neglect. Organizations 
outside the District government also help to support the foster care 
system. One such organization is the Metropolitan Washington Council of 
Governments (COG), which works across jurisdictions to address issues 
facing the metropolitan area, such as an insufficient number of foster 
parents. 

Because CFSA had a history of mismanagement and failed to protect some 
of the children under its care, the Congress enacted laws and provided 
funds to help improve the city's foster care system. The District of 
Columbia Appropriations Act, 2004,[Footnote 1] included a federal 
payment of $14 million for foster care improvements in the District. 
Funds were provided for (1) CFSA to establish an early intervention 
program to help reduce the number of children coming into foster care, 
an emergency support fund to help reduce the number of unlicensed 
kinship homes, and a loan repayment program to help recruit and retain 
caseworkers, as well as to upgrade its automated case management system 
and provide caseworkers with computer technology to help improve case 
management and caseworkers' productivity; (2) DMH to provide all court- 
ordered or agency-required mental health screenings, assessments, and 
treatments to children in CFSA's care; and (3) COG to develop a program 
with the Foster and Adoptive Parent Advocacy Center (FAPAC)[Footnote 2] 
to aid in recruitment of foster parents and provide them with respite 
care (short-term care provided by individuals licensed to care for 
foster children when the foster family needs to take a break or attend 
to other matters). On March 17, 2004, the District received the $14 
million federal payment, less a 0.59 percent rescission, for a total of 
about $13.9 million.[Footnote 3]

In September 2004,[Footnote 4] we reported on several CFSA and DMH 
management issues related to the District's foster care system and the 
District's and COG's plans for and use of the federal foster care 
improvement funds. We found that CFSA, DMH, and COG had spending plans 
that were consistent with the statutory language providing these 
federal funds and that only a small portion of the foster care 
improvement funds had been obligated or spent as of June 2004, in part 
because CFSA, DMH, and COG did not receive the funds until March 2004. 
Most of the expenditures outlined in the spending plans were for 
operating costs that would continue indefinitely once the programs were 
established. At that time, it was uncertain how the District and COG 
planned to fund some of these initiatives in the long term. We also 
reported that many steps had been taken to improve the District's 
foster care system, but that most of the programs and initiatives would 
need sustained attention and ongoing support to achieve the intended 
results. 

Since the issuance of our September 2004 report, we have, as called for 
by the appropriations act, reviewed the obligations and expenditures of 
the fiscal year 2004 federal funds provided for foster care 
improvements. As you subsequently requested, we have also assessed the 
status of the programs supported by the foster care improvement funds. 
Specifically, our objectives were to (1) assess whether the federal 
funds were being obligated and expended by the District government and 
COG in a manner consistent with the act's provisions and the spending 
plans that were submitted to the Congress, (2) determine whether 
internal controls are operating effectively over obligations related to 
the federal funds for foster care improvements received by the District 
and COG, and (3) assess the extent to which CFSA, DMH, and COG have 
implemented the foster care improvement programs and initiatives 
specified in the act and spending plans. 

To analyze CFSA, DMH, and COG's use of their fiscal year 2004 federal 
funds for foster care improvements, we reviewed the agencies' spending 
plans, budget data, and internal reports of obligations and 
expenditures for the period March 2004 through March 2005. We 
interviewed financial and program personnel from all three 
organizations and from the District government's central Office of the 
Chief Financial Officer to obtain an understanding of the procedures 
and controls over the use of the funds. In addition, we selected a 
statistical sample of CFSA and DMH obligation transactions covering the 
period March 17, 2004, through September 30, 2004, from total 
obligations to test whether procedures were properly implemented to 
provide internal control over the use of the funds.[Footnote 5] We 
reviewed COG's fiscal year 2004 financial statements audit opinion, 
conducted walk-throughs of the accounting, payroll, procurement, and 
payments processes in place, and analyzed its spending plans, budget, 
and financial documents. To assess the extent to which CFSA, DMH, and 
COG had implemented the foster care improvement programs specified in 
the appropriations act, we interviewed knowledgeable officials, 
reviewed related program policies and protocols, and analyzed program 
data. We took several steps to assess the reliability and 
reasonableness of the program data. Overall, we found the data to be 
sufficiently reliable for the purpose of assessing the status of the 
foster care improvement programs. We conducted our work from October 
2004 through June 2005 in accordance with U.S. generally accepted 
government auditing standards. See appendix I for more details on our 
scope and methodology. 

Results in Brief: 

The District and COG have obligated and expended federal funds for 
purposes consistent with the provisions of the appropriations act and 
their respective spending plans. As of March 31, 2005, about $13.2 
million of the funds provided had been obligated; about $6.2 million of 
the obligated funds had been expended, and about $722,524 remained 
unobligated. The unobligated funds for CFSA and DMH, in the amounts of 
$588,859 and $30,545 respectively, ceased to be available for new 
obligations after September 30, 2004, and should revert to the general 
fund of the U.S. Treasury. When funds were disbursed to COG from the 
District, these funds lost their federal payment character; thus, there 
is no fiscal limitation on COG's use of its $103,120 in unobligated 
funds. 

Internal controls were generally operating effectively over obligations 
related to the foster care improvement funds at CFSA and DMH. Overall, 
we found that authorized personnel were processing and approving 
transactions in accordance with District policies and procedures, and 
that transactions were adequately supported at CFSA and DMH. However, 
in our testing at these two agencies, we found three instances worth 
discussion. These involved the need for sufficient documentation, 
better adherence to operating procedures, and greater control over 
physical assets. We did not conduct detailed transaction testing at COG 
because it received an unqualified opinion on its fiscal year 2004 
financial statements and the auditor did not identify any reportable 
instances of internal control weaknesses or noncompliance with laws and 
regulations under Government Auditing Standards.[Footnote 6]

CFSA, DMH, and COG have implemented the programs and initiatives 
specified in the appropriations act and the spending plans; however, 
there has not been enough time to assess the effectiveness of some of 
them and challenges remain that could affect the success of others. 

* CFSA's early intervention program and its emergency support fund 
helped about 150 families by providing funds to pay rental fees and 
utilities and buy furniture and other items. However, implementation of 
the early intervention program was delayed due to the need to train the 
parties involved with the family meeting component of the program and, 
according to agency officials, there has not been enough time to 
determine whether the program has been effective. 

* One goal of the emergency support fund is to help CFSA reduce the 
number of unlicensed kinship foster homes. As of April 2005, CFSA had 
children in more than 300 unlicensed foster homes, just as it did in 
2003, but according to agency officials most of these were not kinship 
homes. Nonetheless, because most of the unlicensed homes are located 
outside the District, it will be a challenge for CFSA to ensure that 
managers in other jurisdictions take timely and adequate steps to help 
license them. 

* About 140 of the 190 eligible caseworkers participated in CFSA's 
student loan repayment program; however, $400,000 was not used because, 
according to agency officials, the federal funds were not available 
until after the height of their recruitment season and some caseworkers 
were reluctant to commit to working at CFSA for several years, as 
required by the program. It is too soon to tell whether the student 
loan repayment program will help improve retention in the long-term, 
but CFSA's attrition rates increased from 15 percent in 2003 to nearly 
18 percent in fiscal year 2004. 

* CFSA developed an information technology plan and purchased and 
distributed laptops to some caseworkers. The system upgrades will not 
be completed until December 2005 and it is not clear when all 
caseworkers will receive laptops. 

* DMH has increased the mental health services available to foster care 
children, including the number of assessments completed and the 
treatment services offered through the mental health system. However, 
the department faces ongoing challenges in building the capacity to 
provide needed assessments and in securing long-term funding for 
treatment. 

* COG worked with FAPAC to establish a respite program, but its 
implementation was hampered because the plans did not factor in enough 
time for training families or completing background checks. As of June 
2005, while 106 children had participated in six Saturday day-time 
respite programs, only seven families had completed the licensing 
process and were therefore eligible to provide overnight respite. COG 
has taken steps to improve the program, but the organization may find 
it a challenge to recruit, train, and license enough qualified persons 
to volunteer to serve as respite providers and to convince foster 
parents to participate. 

We received written comments from CFSA, DMH, and COG. CFSA agreed in 
general with our findings and provided comments and additional 
information. DMH's comments addressed information on delays in 
assessments and service delivery capacity. In its comments, COG said 
that recruiting the families to provide respite has not been a 
challenge. COG also said that the challenge has been keeping 
volunteers' level of enthusiasm through the arduous and lengthy 
licensing process. In addition, CFSA and FAPAC provided technical 
comments to clarify the report. We have incorporated this information 
as appropriate. See appendixes II, III, and IV, respectively, for the 
written comments from the CFSA, DMH, and COG. 

Background: 

The child welfare system is designed to promote the well-being of 
children by ensuring their safety and by strengthening families to 
enable them to successfully care for their children. Generally, 
families become involved with the child welfare system after a report 
of abuse or neglect has been made and confirmed. When agency officials 
determine that a child may be further harmed or mistreated if left in 
the home, the child is placed in foster care. 

The federal government has allocated about $7 billion each year to 
investigate abuse and neglect of children in this country, provide 
placements to children outside their homes, and deliver services to 
help keep families together. Part E of title IV of the Social Security 
Act (title IV-E), as amended, is a major source of federal funding and 
is primarily used to pay for the room and board of children in foster 
care. 

Child welfare caseworkers are at the core of the child welfare system. 
They are responsible for overseeing individual cases and for performing 
many critical tasks such as arranging placements when children must be 
removed from their homes, visiting children and foster families, 
maintaining records on each case, and coordinating with other agencies 
to obtain services for the children and their families. Child welfare 
agencies face challenges in recruiting and retaining caseworkers. We 
previously reported that low salaries hinder agencies' abilities to 
attract and retain them.[Footnote 7] We also found that high caseloads, 
administrative burdens, a lack of supervisory support, and insufficient 
time for training were issues that affected caseworkers' abilities to 
work effectively and their decisions to stay in or leave the child 
welfare profession. 

CFSA is responsible for managing the child welfare system for the 
District and it relies on services provided by other District 
government agencies in order to achieve its mission. For example, the 
Fire Department and the Health Department inspect homes and facilities 
where foster children are placed as part of the licensing process to 
ensure these homes are safe, and the Department of Mental Health 
provides mental health services to children in CFSA's care. In 
addition, CFSA works with child welfare agencies in other states to 
arrange for placements of the District's children in cases where the 
most appropriate foster or adoptive family lives outside the District. 
CFSA also works with private agencies to place children in foster and 
adoptive homes, and with private vendors to obtain needed services and 
supplies. CFSA uses an automated case management system, known as 
FACES, to track each child's case, including services rendered or 
supplies obtained. FACES is also used to record and authorize payments 
for such services through an interface with the District's core 
financial management system, known as SOAR. CFSA receives title IV-E 
funding as well as other federal, local, and private funds to support 
its programs. 

CFSA had a history of managerial deficiencies that led the U.S. 
District Court for the District of Columbia to issue a remedial order 
in 1991 to improve the performance of the agency, and then in 1995, due 
to insufficient evidence of program improvement, the agency was placed 
in receivership.[Footnote 8] After almost 6 years of federal 
receivership, CFSA was reorganized as a District cabinet-level agency. 
Since that time, it has worked to improve services and promote the 
safety and well-being of children and families. The U.S. District Court 
appointed the Center for the Study of Social Policy (CSSP) to monitor 
and assess CFSA's performance. CSSP and we have reported that the 
management and operations of CFSA have improved since the receivership, 
but also found that matters of concern remained.[Footnote 9]

The District's mental health agency was similarly placed in 
receivership for over 5 years, from 1997 to 2002.[Footnote 10] As 
originally established, the District's mental health system was not 
organized or funded to meet the particular needs of children, youth, 
and their families. When DMH took the place of the Commission on Mental 
Health Services in 2001, it had too few providers to accommodate the 
needs of the District's foster care children. Mental health services-- 
both assessments and treatment--are considered critical for children 
who have suffered abuse or neglect; therefore, to better connect foster 
care children with such services, CFSA began to contract directly with 
mental health providers. 

Over the years, the Congress has enacted laws and provided funds to 
help improve the District's child welfare system. For example, the 
District of Columbia Family Court Act of 2001[Footnote 11] established 
the D.C. Family Court dedicated solely to matters concerning the 
District's children and families. The D.C. Family Court has 
jurisdiction over cases involving alleged child abuse and neglect, 
juvenile delinquency, domestic violence, child support, and other 
family matters. In addition to establishing the Family Court, the 
Congress authorized funds to the District in fiscal year 2002 for the 
completion of a plan to integrate the District's computer systems with 
those of the D.C. Family Court and for CFSA's caseworkers to help 
implement family court reform.[Footnote 12] Also, the District of 
Columbia Appropriations Act, 2004,[Footnote 13] included a fiscal year 
2004 federal payment of $14 million to CFSA, DMH, and COG for 
improvements to specific foster care programs.[Footnote 14] The federal 
funds were supplemented by private funds for CFSA's early intervention 
program and COG's respite care and foster parent recruitment program. 
In February 2004, the District and COG submitted their respective plans 
to the Congress, outlining how they intended to use the foster care 
improvement funds. Table 1 summarizes the purposes for the funds as 
designated in the appropriations act and the planned expenditures as 
listed in the spending plans. 

Table 1: Purposes and Plans for the Fiscal Year 2004 Foster Care 
Improvement Funds: 

Organization: Child and Family Services Agency; 
Total funding: $9 million; 
Public law 108-199: Purpose of funding: To establish an early 
intervention program to provide intensive and immediate services to 
foster children; 
Public law 108-199: Federal funds: $2 million; 
Spending plans: Proposed expenditures: $700,000; 
Spending plans: Description: Personnel costs (salaries & benefits). 

Organization: Child and Family Services Agency; 
Spending plans: Proposed expenditures: $500,000; 
Spending plans: Description: Training and communications. 

Organization: Child and Family Services Agency; 
Spending plans: Proposed expenditures: $200,000; 
Spending plans: Description: Meeting expenses (e.g., facilities & 
transportation). 

Organization: Child and Family Services Agency; 
Spending plans: Proposed expenditures: $530,000; 
Spending plans: Description: Services for children and families that 
are not currently available at sufficient levels (e.g., substance abuse 
treatment). 

Organization: Child and Family Services Agency; 
Spending plans: Proposed expenditures: $70,000; 
Spending plans: Description: Overhead. 

Organization: Child and Family Services Agency; 
Public law 108-199: Purpose of funding: To establish an emergency 
support fund to purchase necessary items to allow children to remain in 
the care of a licensed, approved family member; 
Public law 108-199: Federal funds: $1 million; 
Spending plans: Proposed expenditures: $920,000; 
Spending plans: Description: Emergency expenses for relatives (e.g., 
furnishings & home repairs). 

Organization: Child and Family Services Agency; 
Spending plans: Proposed expenditures: $73,000; 
Spending plans: Description: Personnel costs (salaries & benefits). 

Organization: Child and Family Services Agency; 
Spending plans: Proposed expenditures: $7,000; 
Spending plans: Description: Overhead. 

Organization: Child and Family Services Agency; 
Public law 108-199: Purpose of funding: To establish a loan repayment 
program for caseworkers; 
Public law 108-199: Federal funds: $3 million; 
Spending plans: Proposed expenditures: $2,750,000; 
Spending plans: Description: Student loan repayments for qualified 
caseworkers with masters and bachelors degrees to accept and extend 
their tenure with the District. 

Organization: Child and Family Services Agency; 
Spending plans: Proposed expenditures: $250,000; 
Spending plans: Description: Contract for loan repayment program design 
and administration. 

Organization: Child and Family Services Agency; 
Public law 108-199: Purpose of funding: To upgrade (FACES) computer 
database and technology as well as to provide computer technology for 
caseworkers; 
Public law 108-199: Federal funds: $3 million; 
Spending plans: Proposed expenditures: $2,170,000; 
Spending plans: Description: Upgrade FACES to Web-based architecture. 

Organization: Child and Family Services Agency; 
Spending plans: Proposed expenditures: $830,000; 
Spending plans: Description: Computer technology for social workers 
(e.g., new laptops or tablet PCs). 

Organization: Department of Mental Health; 
Total funding: $3.9 million ; 
Spending plans: Proposed expenditures: $300,000; 
Spending plans: Description: Staffing of project team to oversee the 
implementation and coordination of all program services outlined below. 

Organization: Department of Mental Health; 
Public law 108-199: Purpose of funding: To provide all court-ordered or 
agency-required mental health screenings and assessments for children 
under the supervision of CFSA; 
Spending plans: Proposed expenditures: $1,030,000; 
Spending plans: Description: Costs for expanded hours of psychiatrists 
and psychologists. 

Organization: Department of Mental Health; 
Spending plans: Proposed expenditures: $70,000; 
Spending plans: Description: Staff and home visits/assessments. 

Organization: Department of Mental Health; 
Spending plans: Proposed expenditures: $47,000; 
Spending plans: Description: Supplies and materials. 

Organization: Department of Mental Health; 
Spending plans: Proposed expenditures: $1,725,000; 
Spending plans: Description: Mobile crisis and community-based 
intervention teams to provide immediate assistance. 

Organization: Department of Mental Health; 
Spending plans: Description: Community support teams to provide a range 
of interventions to high risk children involved in multiple systems. 

Organization: Department of Mental Health; 
Spending plans: Description: Community treatment setting for older 
adolescents who are aging out of care. 

Organization: Department of Mental Health; 
Spending plans: Description: Specialized therapy and child traumatic 
stress treatment. 

Organization: Department of Mental Health; 
Spending plans: Proposed expenditures: $150,000; 
Spending plans: Description: Staffing coordination between DMH and 
CFSA. 

Organization: Department of Mental Health; 
Spending plans: Proposed expenditures: $578,000; 
Spending plans: Description: Training. 

Organization: Washington Metropolitan Council of Governments; 
Total funding: $1.1 million; 
Public law 108-199: Purpose of funding: To develop a program in 
conjunction with the Foster and Adoptive Parents Advocacy Center to 
provide respite care for and recruitment of foster parents; 
Spending plans: Description: Although COG presented a detailed spending 
plan, it did not include a breakdown of expenditures. The plan 
indicated that COG would (1) provide services for resource parents 
caring for children in the D.C. child welfare system, (2) recruit and 
train respite care families to care for foster children covering 
emergency, planned, or ongoing respite care situations, and (3) assist 
CFSA in developing a recruitment video and purchasing media ads 
targeted to demographics most likely to look after special needs 
children in foster care. 

Source: District of Columbia government and the Metropolitan Washington 
Council of Governments. 

[End of table]

CFSA, DMH, and COG Obligated and Spent Funds for Purposes Consistent 
with the Appropriations Act and Spending Plans, but Some Funds Were Not 
Used: 

We found that CFSA, DMH, and COG obligated and expended the federal 
funds provided for foster care improvement for purposes consistent with 
the appropriations act and organizations' spending plans. The funds 
were used for authorized expenses such as repairs for foster homes, 
student loan repayments, psychiatric evaluations, staff salaries for 
the family team meeting project, and training and education materials. 
For a comparison of agency spending plans to provisions of the 
appropriations act, see table 1. Additional information about the 
programs is provided in later sections of this report. 

On March 17, 2004, the District received the $14 million federal 
payment, less a 0.59 percent rescission, for a total of about $13.9 
million.[Footnote 15] The District sent COG a payment of $1,093,510, as 
specified by the appropriations act. The availability of the federal 
payment of funds received by the District for foster care improvements 
was limited to fiscal year 2004. Any unobligated balances of funds 
after September 30, 2004, were no longer available for the District's 
use and should revert to the general fund of the U.S. Treasury. When 
the District disbursed funds to COG for its use, the funds lost their 
federal payment character; thus there is no fiscal time limitation on 
the use of the federal funds provided to COG. 

As we previously reported,[Footnote 16] only a small portion of the 
federal funds for foster care improvements had been obligated or spent 
as of June 30, 2004.[Footnote 17] At that time, over $12.4 million of 
the $13.9 million provided remained unobligated. However, as of 
September 30, 2004, the District agencies and COG had obligated about 
$12.6 million of their funds. Since then COG has obligated an 
additional $599,000, bringing the total amount of funds obligated as of 
March 31, 2005, to $13.2 million. As of March 31, 2005, about $6.2 
million of the total obligated funds had been expended and about 
$722,524 remained unobligated. The unobligated funds for CFSA and DMH, 
in the amounts of $588,859 and $30,545 respectively, ceased to be 
available for new obligations after September 30, 2004, and should 
revert to the general fund of the U.S. Treasury. COG's $103,120 in 
federal funding remains available for use in the respite program for 
foster parents of District children. Table 2 provides details on the 
amounts of the organization's obligations as of March 31, 2005. 

Table 2: Funds Received, Obligated, and Unobligated by CFSA, DMH, and 
COG, as of March 31, 2005: 

Organization: CFSA; 
Funds received: $8,946,900; 
Total funds obligated: $8,358,041; 
Obligations as a percentage of funds received: 93.4%; 
Funds not obligated: $588,859; 
Funds unobligated as a percentage of funds received: 6.6%. 

Organization: DMH; 
Funds received: $3,876,990; 
Total funds obligated: $3,846,445; 
Obligations as a percentage of funds received: 99.2%; 
Funds not obligated: $30,545; 
Funds unobligated as a percentage of funds received: 0.8%. 

Organization: COG; 
Funds received: $1,093,510; 
Total funds obligated: $990,390; 
Obligations as a percentage of funds received: 90.6%; 
Funds not obligated: $103,120; 
Funds unobligated as a percentage of funds received: 9.4%. 

Total[A]; 
Funds received: $13,917,400; 
Total funds obligated: $13,194,876; 
Obligations as a percentage of funds received: 94.8%; 
Funds not obligated: $722,524; 
Funds unobligated as a percentage of funds received: 5.2%. 

Source: GAO analysis of data from the District of Columbia government 
and the Metropolitan Washington Council of Governments. 

[A] Numbers do not sum to totals because of rounding. Percentages may 
not sum to 100 because of rounding. 

[End of table]

Internal Controls Are Generally Operating Effectively: 

In our testing at CFSA and DMH, we concluded that internal controls 
were in place over obligations of the funding provided to both District 
agencies to ensure that the federal funds were expended appropriately 
for their intended purposes. Consistent with standards for internal 
control in government,[Footnote 18] the agencies' internal controls 
comprise a series of appropriate actions and activities conducted 
throughout the agencies' operations on an ongoing basis. Internal 
control activities we tested include (1) adequate segregation of duties 
so that no one person can approve as well as execute a transaction, (2) 
approval of transactions by appropriate supervisory officials, (3) 
sufficient documentation of transactions, and (4) physical control over 
negotiable assets. Agency fiscal officers are charged with providing 
oversight to ensure that controls are adequate to provide reasonable 
assurance[Footnote 19] that funds obligated and expended are used 
effectively and as intended, according to the spending plans and the 
appropriations act. 

To test specific control activities at CFSA and DMH, we selected a 
statistical sample of obligation transactions covering the period March 
17, 2004, through September 30, 2004, in the sum of about $11.9 
million[Footnote 20] from foster care improvement obligations of about 
$12.2 million. In addition, we tested the District's supporting 
documentation for the $1.1 million transfer to COG. Based on the 
results of our tests, we concluded that internal controls are generally 
operating effectively.[Footnote 21] Two key internal control activities 
were built into the requisition and purchasing processes by the Office 
of the Chief Financial Officer and Office of Contracts and Procurement. 
We found that key duties and responsibilities associated with the 
sample transactions were divided (segregated) among different staff 
members so that no one person could both approve and fully execute a 
transaction. Moreover, we found that key documents, such as requisition 
and purchase orders, were authorized and executed by staff members 
acting within the scope of their authority, and that the documents 
supported the purpose and amount of the transaction. However, in 
conducting our tests, we found three instances worth discussion. These 
involved the need for sufficient documentation, better adherence to 
operating procedures, and greater control over physical assets. 

The first instance involved documentation that did not fully describe 
the transaction and a negotiable asset that was potentially vulnerable 
to misuse or fraud. In the transaction we tested, CFSA had recorded an 
obligation in the emergency support fund in the amount of $9,375 for 
the purchase of gift cards to be used to purchase clothing for foster 
children. The transaction was part of a requisition that totaled about 
$99,000 for the purchase of gift cards from several vendors. While the 
approval of the gift card purchase was adequately documented, it was 
unclear whether the gift cards were ever received because the District 
did not provide us documentation of their receipt of the cards during 
the time of our review. We were also unable to determine, based on 
District records, whether the District had paid for the cards. District 
officials told us that the gift cards had been received, paid for, and 
had not been activated for use. However, without an invoice or 
receiving document, we could not verify that the gift cards were 
received or paid for, or whether the cards had been activated. In its 
comments on a draft of this report, CFSA provided additional 
documentation, including the vendor invoice and financial system 
reports showing receipt of the gift cards and the payment made. 

While gift cards provide the flexibility to respond quickly to 
emergency needs, adequate documentation and sufficient physical 
controls are essential to provide accountability over their use and to 
ensure the propriety of transactions. Gift cards, similar to cash, can 
easily be used for improper purchases--such as purchases excessive in 
cost, for purposes other than that stated, or for personal use. 
Purchased gift cards need to be properly inventoried and stored, 
similar to the cash in an imprest fund.[Footnote 22] When the gift 
cards are distributed, the number and dollar amount of the cards taken 
from the inventory should be noted as should the identities of the 
employees who received the cards. Employees should be required to 
provide receipts for items purchased with gift cards. Periodic surprise 
audits of the gift card funds would also help to safeguard the gift 
cards inventory. In its comments on a draft of this report, CFSA 
described its procedures to track, monitor, and manage the distribution 
process of the gift cards, including several actions recently taken and 
planned actions designed to improve procedures in this area. 

In the second instance, on September 28, 2004, DMH generated and issued 
a purchase order for professional consulting services in the amount of 
$221,637; however, a detailed contract was not executed until February 
2, 2005. District officials told us that, according to operating 
procedures, there should have been an approved purchase order and 
signed contract before obligating funds. However, in order to obligate 
funds by September 30, 2004, the District told us that they issued a 
purchase order to which the consultant agreed and both parties agreed 
to finalize the contract later. District officials told us that they 
believe they had a valid obligation based on the approved purchase 
order as agreed to by the vendor, provided the vendor could meet all 
the detailed requirements specified in the purchase order. They further 
explained that during the months following the recording of the 
obligation, DMH officials negotiated the final detailed deliverables 
with the vendor and signed the contract in February 2005. However, the 
District did not provide us with evidence that the vendor agreed to the 
purchase order. This type of procurement procedure increases the risk 
that the District might lose obligated funds if it were to later 
determine that the vendor could not meet the requirements indicated in 
the purchase order. While the purchase order could be later cancelled, 
expiration of the funds would prevent their reobligation. This type of 
practice increases the risk to DMH that it may improperly record an 
obligation where no binding agreement may exist at the time of 
recording the obligation, as required by 31 U.S.C.  1501(a). See 34 
Comp. Gen. 459 (1955). 

Finally, a vendor's invoice billed the District for 248 laptop 
computers. Initial documentation provided to us by CFSA showed a 
handwritten notation on the invoice by the head of CFSA's Information 
Technology branch acknowledged receipt of only 247 computers at a cost 
of $510,796. District officials could not provide documentation to 
support the number of computers received. Thus, we could not verify the 
number actually received. Additional documentation provided with CFSA's 
comments on a draft of this report show that the agency purchased 247 
computers with the federal funds for foster care improvements and 1 
computer with local funds, for a total of 248 laptop computers. While 
we did not test the physical control environment at the District, our 
Standards of Internal Control requires agencies to establish physical 
control to secure and safeguard vulnerable assets to establish 
accountability, and to properly record transactions. 

We did not conduct detailed tests of transactions at COG because those 
transactions were included in COG's financial statement audit performed 
by an independent public accounting firm who audits COG's financial 
statements annually. COG received an unqualified, "clean," opinion for 
fiscal years ended June 30, 2004, and June 30, 2003. In COG's 2004 
financial statements, the Foster Care Improvements federal funding of 
$1.1 million was recorded in the supplementary information--Project 
Statement of Revenues, Expenditures, and Changes in Net Assets--and 
audited as part of the financial audit. Furthermore, the independent 
auditor did not identify any internal control weaknesses over financial 
reporting and operations or any instances of noncompliance for purposes 
of the reports on internal controls and compliance that are required by 
Government Auditing Standards.[Footnote 23]

New Programs Have Been Implemented to Improve Foster Care, but 
Challenges Remain: 

CFSA, DMH, and COG have implemented the programs and initiatives 
specified in the appropriations act and spending plans, and some foster 
families have received needed services. CFSA began its early 
intervention program a few months later than it had planned. 
Nonetheless, funds from this program, as well as the emergency support 
program funds have provided needed services to some families. CFSA also 
established a student loan repayment program, developed an information 
technology plan, and provided laptops to some caseworkers. DMH 
increased the mental health services available to foster care children, 
and COG and FAPAC worked together to develop a respite program. 

However, it is too early to assess the effectiveness of some programs, 
and challenges remain for others. The long-term effectiveness of the 
early intervention and student loan programs cannot yet be assessed and 
the information technology improvements have not been completed. 
Furthermore, challenges remain that could affect the success of CFSA's 
emergency support fund initiative, as well as DMH's ability to build 
capacity to provide needed assessments and to secure long-term funding 
for treatment. Also, the future success of COG's respite program 
depends on some factors beyond the organization's control. 

Implementation of the Early Intervention Program Was Delayed, 
Nevertheless Needed Services Were Provided to Some Families: 

The early intervention program included two key components--the 
Facilitated Family Team Meeting (FFTM) initiative and funds for various 
services and supports. According to agency officials, the FFTM 
initiative is the core of the program. These meetings are intended to 
give families a voice in decisions about removing a child from the home 
or changing his or her placement. CFSA planned to begin holding 
meetings in the summer of 2004, but implementation was delayed until 
September. CFSA officials stated that much of the delay was the result 
of time needed to train the parties involved in the program, including 
caseworkers, judges, and foster parents. CFSA operated a pilot program 
from September to December 2004 for selected high-risk cases. In 
January 2005, CFSA began conducting FFTMs for all cases, and as of 
March 2005, CFSA had held 47 FFTMs for 85 children. Based on the 
outcome of the FFTMs, CFSA officials are to assess the families' needs 
and identify services and supports that may enable children to remain 
safely in their own homes or with their current foster families. Table 
3 lists services and supports eligible for program funds. 

Table 3: Eligible Services and Supports Provided through the Early 
Intervention Program: 

Category: Social services; 
Eligible services/supports: 
* Substance abuse treatment; 
* Intensive, home-based services, such as but not limited to: parenting 
support, behavioral management, homemaker services, crisis 
intervention, and or medical/behavioral support; 
* Job training and support. 

Category: Support services; 
Eligible services/supports: 
* Equipment to care for disabled children; 
* Temporary transportation of children; 
* Temporary child care; 
* Temporary food assistance; 
* Furniture; 
* Clothing. 

Category: Housing; 
Eligible services/supports: 
* A one-time security deposit or up to 3 months of rental assistance; 
* Temporary assistance with utility bills; 
* Lead abatement; 
* Home repair or maintenance. 

Category: Special services; 
Eligible services/supports: 
* Individualized services that do not fall into one of the categories 
above but that are necessary to minimize trauma for the children. 

Source: CFSA program data. 

[End of table]

Program data show that as of April 2005, CFSA provided 207 services and 
supports to 151 families and 386 children with the early intervention 
program funds.[Footnote 24] Most of the services provided were related 
to housing needs such as rent, utility payments, and furniture, as 
shown in figure 1. 

Figure 1: Types and Numbers of Services Provided to Families with Early 
Intervention Program Funds: 

[See PDF for image] - graphic text: 

Pie chart with four items.

Utility (71 of 207): 34.3%; 
Rent (52 of 207): 25.1%; 
Furniture (51 of 207): 24.6%; 
Other (33 of 207): 15.9%. 

Source: GAO analysis based on CFSA program data. 

Note: Other services provided included food, clothing, day care, 
transportation, school supplies, one-time emergency room and board, 
summer camp, vouchers for a baby monitor, and a U-Haul rental truck. 

[End of figure] 

The early intervention program has been operating for several months, 
but officials said that the effectiveness of the program cannot yet be 
determined. Agency officials said that CFSA has developed a tracking 
system to follow the progress of FFTM participants and will have data 
to determine whether the program has reduced the number of children 
coming into CFSA's care or the number of times a child's placement is 
changed. 

Emergency Support Fund Provided Critical Services, but the Number of 
Unlicensed Homes Remained the Same: 

One goal of the emergency support fund is to help facilitate the 
licensing of family members who are willing to provide kinship 
homes[Footnote 25] to care for children who would otherwise go into 
traditional foster homes or congregate care.[Footnote 26] According to 
CFSA officials, the funds could be used to help homes meet established 
standards by paying for expenses such as lead abatement, home repairs, 
and renovation. In addition, the funds could be used to purchase 
services and items such as child care services or clothing, as well as 
to provide housing assistance in the form of monthly rent (not more 
than three months) or one-time security deposits. 

Although efforts to advertise the funds were limited, several families 
learned about and received services from this program. Kinship families 
learned about the availability of funds through information provided by 
caseworkers, word of mouth from other parents, and announcements in 
FAPAC's newsletters for foster parents. As of April 2005, 99 families 
and 189 children had been helped by the emergency support fund and 152 
services had been provided. Furniture, rent, and utility assistance 
were most often provided; however, families received other services as 
shown in figure 2. FAPAC officials said that the program has been 
helpful and beneficial in helping kinship foster families become and 
remain licensed foster families. 

Figure 2: Number and Types of Services Provided to Families with 
Emergency Support Funds: 

[See PDF for image] - graphic text: 

Pie chart with five items. 

Other (51 of 152): 33.6%; 
Furniture (24 of 152): 22.4%; 
Rent (30 of 152): 19.7%; 
Utility (22 of 152): 14.5%; 
One time room and board payment (15 of 152): 9.7%. 

Source: GAO analysis based on CFSA program data. 

Note: The "other" category includes a wide variety of services such as 
home repairs, summer camp, CPR/First Aid Certification, vehicle 
repairs, clothing, and day care services. 

[End of figure] 

While the emergency support fund has assisted some families, the number 
of unlicensed homes has not changed in the last year. We previously 
reported[Footnote 27] that CFSA had taken a number of steps to ensure 
that children are placed in licensed homes, but as of May 2004, 495 
children, or 22 percent of the children in CFSA's care, were in 308 
unlicensed homes. At that time, CFSA officials told us that the 
majority of unlicensed homes entered the foster care program before new 
licensing standards were issued, many were kinship homes, and many 
homes were located in Maryland. Agency officials also said that CFSA 
was working to correct this situation by examining these homes on a 
case-by-case basis to identify the specific barrier each home faced in 
becoming licensed and, if possible, to resolve the issue. As of April 
30, 2005, CFSA had children in 309 unlicensed homes. CFSA officials 
explained that most of the unlicensed homes were not kinship homes and 
therefore federal funds were not available to facilitate licensing of 
these homes.[Footnote 28] Further, according to CFSA officials, most of 
the unlicensed homes were in other jurisdictions--232 in Maryland and 
33 in other states. CFSA, like child welfare agencies in other 
jurisdictions, is faced with challenges when trying to ensure the 
quality of homes outside their respective jurisdiction. When children 
are placed in homes in other jurisdictions, the home study 
process[Footnote 29] is complicated because the two states' laws and 
policies must be taken into consideration and there must be 
coordination between the jurisdictions. The Interstate Compact on the 
Placement of Children[Footnote 30] is the bridge that facilitates this 
process by providing a legal and administrative framework for placing 
children across state lines for foster care or adoption. However, 
concerns have been raised by state child welfare officials about the 
timeliness of home studies and the quality of background checks done by 
staff in other jurisdictions. 

Most Eligible Caseworkers Participated in the Student Loan Repayment 
Program, but More Could Have Been Supported: 

About 70 percent of CFSA's eligible caseworkers participated in the 
student loan repayment program and most were approved for payments of 
more than $10,000. CFSA determined that only those caseworkers who 
managed cases were eligible to apply for the program. As of August 
2004, CFSA had 310 caseworkers, and according to agency officials, 190 
of them managed cases. CFSA officials reported that 138 of its 190 
caseworkers and nine of its contractors signed student loan repayment 
agreements. Most program participants, 99, had fewer than 3 years of 
service and 48 had 3 years or more of service. The repayment amounts 
ranged from about $3,000 to about $18,000 with the average at about 
$15,000. According to CFSA documents, the first payment will be made in 
July 2005 for those who have met the service requirements.[Footnote 31] 
Figure 3 summarizes the distribution of these loans. 

Figure 3: Distribution of Student Loan Repayment Amounts: 

[See PDF for image] - graphic text: 

Bar graph with four items. 

$5,000 or less; 
Number of caseworkers: 4. 

$5,001 - 10,000; 
Number of caseworkers: 17. 

$10,001 - 15,000; 
Number of caseworkers: 102. 

$15,001 - 18,000; 
Number of caseworkers: 24. 

Source: GAO analysis based on CFSA program data. 

[End of figure] 

Although 138 of 190 caseworkers were approved for loan repayments, more 
could have been supported with the funds available. At the end of the 
fiscal year, CFSA had about $408,000 remaining of the $3 million 
designated for the program. CFSA could have entered into agreements 
with more than 40 caseworkers with bachelor's degrees in social work 
(BSW) or more than 20 with master's degrees in social work (MSW) or 
some combination of both. According to agency officials, the agency 
took several steps to make certain that all eligible caseworkers were 
aware of the program, and they modified the program in an effort to 
maximize participation. CFSA launched the program in June 2004. CFSA 
advertised the program through weekly e-mail messages to all 
caseworkers, distributed flyers, printed notifications in an agencywide 
newsletter, posted fact sheets on the District government's intranet, 
and placed notices in local newspapers, including the Washington Post. 
CFSA extended the application deadline by a month and increased the 
maximum amount of the loan repayment from $5,000 to $10,000 for 
caseworkers with BSWs and from $10,000 to $18,000 for those with MSWs. 
As the program is structured, if a caseworker who was approved to 
receive a loan repayment leaves CFSA before the end of his or her 
commitment, the agency will have to return the funds to the U.S. 
Treasury. Agency officials said that one reason more caseworkers did 
not participate in the program was their hesitance to commit to working 
for CFSA on a long-term basis. In commenting on a draft of the report, 
agency officials also said that all of the funds for the student loan 
repayments were not used because the agency could neither advertise the 
program nor enroll participants until after March 2004 when the funds 
were made available, which was after the height of its spring 
recruitment season at colleges and universities. 

Even with this program, attrition rates at CFSA increased. Like other 
child welfare agencies, CFSA has faced ongoing challenges in efforts to 
retain caseworkers. In fiscal year 2003, CFSA's attrition rate for 
caseworkers was about 15 percent. In fiscal year 2004, the rate had 
increased to about 18 percent. In our September 2004 report,[Footnote 
32] we found a consensus among the caseworkers we interviewed that 
deficiencies in CFSA's management practices[Footnote 33] hindered their 
performance and lowered their morale. In that report, we recommended 
changes to CFSA management practices. CFSA generally agreed with our 
recommendations and developed a work plan that included strategies to 
help retain qualified caseworkers. We have not assessed whether the 
agency has begun to implement the recommendations. Although the 
attrition rate has increased, it is too soon to tell whether the 
student loan repayment program will be effective in the long-term, 
particularly since all participants had to remain at CFSA at least 
until July 2005. 

Implementation of CFSA's Information Technology Plan Is Not Yet 
Completed: 

CFSA developed an information technology plan to upgrade its child 
welfare information system, known as FACES, to a Web-based system. The 
information technology plan indicates that the FACES software upgrade 
component is scheduled to be completed in December 2005. In addition, 
the contractor may provide maintenance and support services for the new 
system through September 29, 2008. Table 4 summarizes the key steps in 
the plan and the related time frames. 

Table 4: Key Steps in CFSA's Information Technology Plan, as of June 
15, 2005: 

Task: Consulting contract for FACES software upgrade; 
Planned initiation: 3/30/04; 
Planned completion: 12/20/05. 

Task: Web application servers and hardware; 
Planned initiation: 9/20/04; 
Planned completion: 12/20/05. 

Task: Web development software; 
Planned initiation: 9/20/04; 
Planned completion: 12/20/05. 

Task: Staff training and materials; 
Planned initiation: 9/20/04; 
Planned completion: 12/20/05. 

Task: Purchase laptops for social workers; 
Planned initiation: 5/28/04; 
Planned completion: 9/30/04. 

Task: Security enhancements; 
Planned initiation: 9/20/04; 
Planned completion: 12/20/05. 

Task: Business continuity enhancements; 
Planned initiation: 7/15/04; 
Planned completion: 9/30/04. 

Source: CFSA program data. 

[End of table]

Also, CFSA's information technology plan includes the purchase of 
laptops for its caseworkers. These laptops are intended to help improve 
caseworkers' productivity and effectiveness because caseworkers can 
enter case information data when away from the office. According to the 
spending plan, CFSA would initially purchase laptops for 75 percent of 
its caseworkers and in phase two, laptops would be purchased for the 
remaining 25 percent who had less critical need for field access. 
However, it is not clear when all caseworkers will receive laptops 
because the date for beginning of phase two is not listed in either the 
spending plan or the information technology plan and CFSA officials 
could not provide a date for this phase. 

CFSA purchased and received the initial order of laptops as planned, 
but the distribution process has taken months. The final contract, 
signed on September 29, 2004, allowed for CFSA to purchase laptops and 
related services at a cost of about $2,000 per laptop. On January 27, 
2005, documents showed that 247 laptops had been purchased with federal 
funds--9 for FFTM caseworkers that manage the early intervention 
program and the remaining 238 to be distributed among CFSA's 310 
caseworkers. According to CFSA officials, as of May 2005, 119 laptops 
had been issued to caseworkers and they expected that all laptops would 
be distributed by June 2005. CFSA explained that distribution was 
delayed because initially the laptops did not meet the requested memory 
specifications. CFSA further explained that after the contractor 
replaced the memory modules, the agency had to load the software before 
the laptops were distributed. 

Mental Health Assessments and Treatments Were Provided, but DMH Faces 
Ongoing Challenges: 

DMH provides assessments for children referred to the agency by CFSA 
and the Family Court. From August 2004 through February 2005, DMH 
reported completing 351 assessments of foster care children referred by 
CFSA. During the same period, CFSA increased the number of cases 
referred to DMH for assessment from 15 in August 2004 to 68 in February 
2005, for a total of 292 referrals over the 7-month period.[Footnote 
34] According to DMH officials, this sharp increase in referrals has 
raised the average number of days to complete an assessment--beginning 
with the appointment request and ending with the delivery of a report 
to the Family Court--above the statutory time frame of 23 days as 
indicated in the appropriations act.[Footnote 35] DMH reviewed 82 cases 
completed from August 2004 through February 2005 and found that their 
evaluators took an average of 33.5 days--approximately 10 days longer 
than the statutory time frame--to complete assessments. According to 
DMH officials, some cases increased the average time frame for 
completion. For example, one case took 192 days. However, officials 
also acknowledged that the remaining assessments, while sometimes 
taking as little as 1 day to complete, were, on average, not being 
completed within the statutory time frame. 

Since our September 2004 report, DMH has continued to build its 
capacity to provide treatment to foster care children referred by 
CFSA.[Footnote 36] DMH has increased the number of outside providers it 
has certified to deliver treatment to foster care children from 13 in 
September 2004 to 20 in February 2005. From August 2004 through 
February 2005, CFSA referred 430 cases to providers in the DMH network. 
In January 2005, DMH providers began delivering three new types of 
treatment to foster care children, (1) multisystemic therapy, (2) 
intensive home-and community-based services, and (3) mobile response 
and stabilization services.[Footnote 37] DMH previously anticipated 
that 300 to 500 children would receive these three types of treatment 
within 1 year of the date of the signed agreements with 
providers.[Footnote 38] Agreements for these treatment services were 
signed in late September 2004. As of April 2005, 3 months into 
implementation of the new types of treatment, 31 children had received 
multisystemic therapy, 37 had received intensive home-and community- 
based services, and 24 had received some type of mobile mental health 
services (see table 5). According to a DMH official, the department 
expects 300 children to receive services by January 2006. 

Table 5: Foster Care Children Receiving Mental Health Treatment: 

Mental health treatment: Multisystemic therapy; 
Number of foster care children served: As of April 2005: 31; 
Number of foster care children served: Anticipated by January 2006: 64 
to 96. 

Mental health treatment: Intensive home-and community-based services; 
Number of foster care children served: As of April 2005: 37; 
Number of foster care children served: Anticipated by January 2006: 72 
to 90. 

Mental health treatment: Mobile response and stabilization services; 
Number of foster care children served: As of April 2005: 20 calls 
(emergency assistance); 4 families (stabilization); 
Number of foster care children served: Anticipated by January 2006: 12 
to 14 calls per week (emergency assistance); up to 10 cases at one time 
(stabilization). 

Source: DMH and documents from U.S. District Court for the District of 
Columbia. 

[End of table]

In addition to adding providers and new types of treatment, DMH began 
its initiative to train providers in trauma treatment in March 2005. 
The first phase of this initiative included a baseline assessment of 
whether providers use treatment practices that reflect current 
research. In the second phase, DMH began offering training sessions on 
those treatment practices for DMH's certified providers. 

DMH faces ongoing challenges in building the mental health system's 
capacity to provide timely assessments and in securing long-term 
funding for treatment services for foster care children. As of April 
2005, DMH officials reported that it did not have the capacity to 
respond to the growing number of referrals for assessments from 
CFSA.[Footnote 39] To address this issue, DMH officials stated that the 
agency was expanding its current contracts with providers and 
recruiting new providers. However, according to DMH's director, meeting 
the demand for assessments will remain an ongoing concern. With regard 
to treatment, DMH is in the process of securing long-term financing for 
the new services implemented with the federal funds. DMH officials 
stated that the agency can obtain funds for mobile response and 
stabilization through the District's Medicaid program.[Footnote 40] 
Officials also expect that, upon approval of a requested change to the 
Medicaid program, DMH will be able to obtain reimbursements for 
intensive home-and community-based services and mobile response and 
stabilization services. The director said that, even with the federal 
funds available through Medicaid, local funds may not be sufficient to 
meet the treatment needs of foster care children. 

COG's Respite Program Was More Challenging to Implement Than Expected: 

COG, in conjunction with CFSA and FAPAC, developed a respite program 
for foster parents of the District's children. Under this program, 
known as "Work of Heart," COG recruited and trained families from the 
District and other surrounding jurisdictions to provide volunteer 
respite care. The program was designed to include overnight respite 
care provided by licensed foster parents, as well as daytime respite 
programs on Saturdays and Sundays provided by licensed organizations. 

COG used various avenues to recruit parents to serve as respite 
providers and made several efforts to inform foster parents about the 
respite program. According to agency officials, to recruit respite 
providers COG staff attended 10 community fairs, made 11 presentations 
at churches and businesses, hosted bimonthly informational meetings, 
and explained the program to CFSA caseworkers. In addition, COG 
distributed more than 50,000 recruitment brochures and flyers and 
advertised through local radio, local journals, and newspapers to 
recruit respite providers. COG also conducted outreach efforts to 
inform current foster families about the availability of respite 
services. They sent four mailings to all of CFSA's foster families and 
instituted an application and approval process. Current foster parents 
had to complete the application and be approved in order to receive 
respite services. Furthermore, FAPAC officials coordinated the 
identification and approval of four licensed organizations to provide 
the daytime respite programs. 

Some respite services have been provided; however, COG's initial goal 
was not met. We reported in September 2004[Footnote 41] that COG had 
set as its goal to provide 700 respite care placements by March 2005, 
but officials did not know how many parents would need to be licensed 
to reach that goal or how many children would need care. As of June 
2005, 62 respite foster parents had been trained, and 7 had completed 
the licensing process. Also as of June 2005, 44 foster families and 86 
foster children--their ages ranged from 6 months to 17 years of age-- 
had been approved to receive respite. According to COG officials, six 
Saturday respite programs were held and 106 children participated. For 
overnight respite, 26 placements were requested and 9 were completed as 
of June 2005. COG officials said that the other requests were cancelled 
by the foster parents for various reasons. 

COG's initial plan did not adequately consider several factors that 
hindered the program's implementation. For example, COG officials 
stated that the initial program goal was overly optimistic because it 
was based on a long-running program operating in another state but did 
not account for differences between the District's needs and 
demographics and those of that state. The COG officials also said that 
the District's training requirements were longer than projected and 
some parents who were interested in serving as respite volunteers were 
hesitant to complete the lengthy application and licensing process. 
Furthermore, COG officials stated that a major barrier to the program 
was the 3 to 4 month waiting period for FBI clearances, part of the 
licensing process. A COG official explained that they were working with 
the Washington FBI field office and the Metropolitan Washington Police 
Department to finalize a memorandum of understanding that could reduce 
the time for clearances to 4 to 5 weeks. While this step may help 
improve the process, the future success of the program depends on some 
factors beyond COG's control such as the number of qualified people who 
volunteer to serve as respite providers and the number of foster 
parents who will participate. 

Concluding Observation: 

CFSA, DMH, and COG have obligated federal funds for purposes intended 
by the Congress to address long-standing problems in the District's 
foster care system. The agencies and COG appear to have exercised 
effective internal controls over the use of those federal funds. All 
programs called for in the legislation have been implemented to some 
degree, and services have been provided to some foster children and 
families in the District. As in child welfare systems across the 
country, the agencies and organizations working for the welfare of 
children in foster care face a complex set of challenges. Whether these 
programs are effective and help improve foster care in the District may 
not be known for several years. 

Agency Comments and Our Evaluation: 

We received written comments on a draft of this report from CFSA, DMH, 
and COG. These comments are reprinted in appendixes II, III, and IV, 
respectively. CFSA and FAPAC also provided technical comments, which we 
incorporated where appropriate. 

In commenting on a draft of this report, CFSA agreed in general with 
our findings and provided a number of comments and additional 
information. In response, we made several changes to the report. We 
revised the report to reflect the additional documentation provided by 
CFSA showing (1) receipt of the gift cards and the payment made and (2) 
the purchase of one additional laptop computer. CFSA also described its 
procedures to track, monitor, and manage the distribution of the gift 
cards, which we noted in the report. Also, we added a statement in the 
report explaining how the timing of the receipt of funding impacted 
CFSA's ability to use all of the funds for the student loan repayment 
program and revised the information technology section of the report 
after receiving and reviewing an updated plan from CFSA. In addition, 
CFSA's comments addressed the goals of the emergency support program 
and its unlicensed homes. CFSA stated that, while the emergency support 
funds were used to facilitate licensing of kinship homes, the primary 
goal of the emergency support program goal was to facilitate placement 
of children with kin. We did not revise the statement about the program 
goal, because the appropriations act and the related conference report 
state that the fund would be used to purchase items necessary to allow 
children to remain in the care of an approved licensed family member. 
With regard to its unlicensed homes, we revised the report to reflect 
some of the information provided by CFSA. 

We also received written comments on a draft of this report from DMH 
that addressed information on delays in assessments and the 
department's capacity to deliver treatment services. DMH generally 
agreed with our findings on the provision of assessments, but provided 
additional information on increases in referrals, delayed assessments, 
and initiatives to decrease the wait time for assessments. DMH also 
expressed the view that it has the capacity to utilize Medicaid funding 
for treatment services. We modified the report to reflect that DMH is 
in the process of securing long-term funding for treatment services. 

In its comments, COG said that recruiting the families to provide 
respite has not been a challenge. COG also said that the challenge has 
been keeping volunteers' level of enthusiasm through the arduous and 
lengthy licensing process. We modified the report to clarify that our 
conclusion included all aspects of the process associated with 
licensing respite providers. 

We will send copies of this report to the Director of CFSA, the 
Director of DMH, the Executive Director of COG, and the Chief Financial 
Officer of the District of Columbia. We are also sending copies to the 
Honorable Senator Michael DeWine, who was the Chairman of the 
Subcommittee on the District of Columbia Senate Committee on 
Appropriations when the act was passed that provided the federal funds; 
to appropriate congressional committees; and other interested parties. 
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 [Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact Jeanette Franzel, Director, Financial Management and Assurance, 
at (202) 512-9471 or [Hyperlink, FranzelJ@gao.gov], or Cornelia M. 
Ashby, Director, Education, Workforce, and Income Security Issues, at 
(202) 512-8403 or [Hyperlink, AshbyC@gao.gov]. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff that made major contributions 
to this report are listed in appendix V. 

Signed by: 

Jeanette Franzel: 
Director: 
Financial Management and Assurance: 

Signed by: 

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

[End of section]

Appendixes: 

Appendix I: Scope and Methodology: 

To assess whether the federal funds were being obligated and expended 
by the Child and Family Service Agency (CFSA), Department of Mental 
Health (DMH) and the Metropolitan Washington Council of Governments 
(COG) consistent with the provisions in the District of Columbia 
Appropriations Act, 2004, and the spending plans that were submitted to 
the Congress, we interviewed District and COG officials responsible for 
overseeing, monitoring, and tracking the federal funds received for 
foster care improvements. We reviewed and analyzed the District and COG 
spending plans and budgets, and internal reports of obligations and 
expenditures. 

To determine whether internal controls are operating effectively, we 
interviewed financial and program personnel from CFSA, DMH, COG, and 
from the District government's central Office of the Chief Financial 
Officer. We reviewed operating procedures and flowcharts to understand 
the procedures and controls over the use of the funds. To further 
understand the District's processes for obligating and disbursing 
funds, we conducted walk-throughs of the procedures with CFSA and DMH 
financial officials. 

We assessed the reliability of the District's foster care obligations 
data by (1) reviewing existing documentation related to the data 
sources, (2) testing the data to identify obvious problems with 
completeness or accuracy, and (3) interviewing knowledgeable agency 
officials about the data. We determined that the data were sufficiently 
reliable for the purposes of this report. 

We selected a dollar-unit sample at a 95 percent confidence level of 
CFSA and DMH obligation transactions covering the period March 17, 
2004, through September 30, 2004, totaling about $11.9 million from 
obligations of about $12.2 million to test specific control activities, 
such as segregation of duties, evidence of approving official review 
and approval, and adequacy of supporting documentation.[Footnote 42]

We also reviewed contract files to validate that the responsible 
designated officials within the agency provided the appropriate budget 
authorizations to purchase and receive goods and services consistent 
with the appropriations act and whether the goods or services rendered 
were properly obtained and the quantity and quality of services were 
verified. 

We did not conduct detailed tests of transactions for COG. An 
independent public accounting firm audits the financial statements of 
COG annually and the federal funds provided to COG were included in its 
fiscal year 2004 audit. COG received an unqualified, "clean," opinion 
for fiscal years ended June 30, 2004, and June 30, 2003. COG's fiscal 
year 2004 foster care improvements funds were recorded in the 
supplementary information to its fiscal year 2004 financial statements, 
specifically its Project Statement of Revenues, Expenditures, and 
Changes in Net Assets--and audited as part of the financial audit. 
Furthermore, the independent auditor did not identify any internal 
control weaknesses over financial reporting and operations or any 
instances of noncompliance for purposes of the reports on internal 
controls and compliance that are required by Government Auditing 
Standards.[Footnote 43] We did conduct walk-throughs of COG's 
accounting, payroll, procurement, and payment processes. In addition, 
we obtained and analyzed the COG spending plans, and budget and 
financial documents related to their portion of the federal funds. 

To assess the extent to which CFSA, DMH, and COG have implemented the 
foster care improvement programs and initiatives specified in the 
appropriations act and spending plans, we gathered and analyzed data 
from various sources. We interviewed agency officials from CFSA, DMH, 
COG, and Foster and Adoptive Parents Advocacy Center (FAPAC) that were 
responsible for each of the programs and initiatives. Several of these 
officials also responded via e-mail to several questions regarding the 
program. In addition, officials from CFSA, DMH, and FAPAC prepared 
written statements for congressional hearings that addressed these 
programs, and we obtained and analyzed these statements. We reviewed 
program policies, protocols, and plans as well as the legislation and 
the spending plans. Generally, the legislation or the plans identified 
CFSA's goals and desired outcomes for the programs. Data on the number 
of participants in the student loan repayment program was as of 
September 2004, which was the deadline for the program. We obtained 
program information on the status of the other programs as of April 
2005 or June 2005. This information included budget documents, 
expenditure reports, and data on services provided to children and 
families. We compared this information to the programs' plans and goals 
in order to assess the extent to which the programs and initiatives 
were implemented, achieved established goals, or led to other outcomes. 

We took several steps to assess the reliability and reasonableness of 
program data and found the program data to be reasonable and 
sufficiently reliable for the purposes of providing information on the 
status of the programs and initiatives supported by the federal foster 
care improvement funds provided in fiscal year 2004. To assess the data 
on the services provided by the early intervention program and 
emergency support fund, we interviewed officials responsible for 
compiling the data and compared it to relevant financial transaction 
records. We did not contact individual families to determine whether 
they received the services or products, but we asked officials from 
FAPAC about the foster and adoptive parents' views about the programs 
in general and the services provided. To evaluate the student loan 
repayment data, we interviewed program officials and compared the data 
to the numbers previously reported by CFSA and determined that the 
various subcategories--such as the number of participants by loan 
repayment amounts and by years of service--equaled the total. We also 
compared the totals to the financial obligations but could not compare 
the data to individual payments because CFSA had not made any payments 
to caseworkers as of the date of our review. To corroborate the data on 
mental health services provided to foster care children reported by 
DMH, we interviewed the officials from the department who were 
responsible for compiling the data. In addition, we checked the 
reported data against information provided in DMH testimony before the 
Senate Committee on Appropriations, reports submitted to the U.S. 
District Court for the District of Columbia by the monitor of the 
District's mental health system, DMH grant agreements, and data 
provided by CFSA. Finally, we interviewed Family Court officials to 
corroborate assessment time frames reported by DMH. Data on the respite 
program were generally provided by COG and corroborated by officials 
from FAPAC. Upon completion of these steps, we determined that the 
above-mentioned data were sufficiently reliable for the purposes of 
this report. 

We conducted our work from October 2004 to June 2005 in accordance with 
U.S. generally accepted government auditing standards. 

[End of section]

Appendix II: Comments from the District's Child and Family Services 
Agency: 

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

Office of the Director: 

June 20, 2005: 

Jeanette Franzel: 
Director: 
Financial Management Assurance: 
Government Accountability Office: 
Washington, D.C. 20548: 

Dear Ms. Franzel: 

Thank you for the opportunity to provide comments on the draft report 
titled District of Columbia: Foster Care Improvements Funds Used to 
Implement New Programs but Challenges Remain (GAO-05-787). We are 
pleased that the GAO has found that the District appropriately used the 
federal funds that were provided for foster care improvements and that 
internal controls at Child and Family Services Agency (CFSA) were 
effective in managing the federal dollars. We agree in general with the 
findings of the report, but do have a number of comments. 

First, it is important for the report to emphasize at the outset that, 
due to delays in passage of the District of Columbia's budget, the 
federal dollars were not made available to the District until mid 
March, more than six months into the fiscal year, and that the dollars 
provided to the District could not carry over into FY 05. This created 
significant challenges to the District, and is largely the reason CFSA 
was not able to obligate all its funds. 

This is particularly true in the area of student loan repayment 
program, where the District did not obligate about $400,000 (or 
approximately 67%) of the total amount unobligated by CFSA. Thus, we 
believe that rather than attributing return of some of the loan 
repayment program funds solely to the reluctance of workers to commit 
to a specific tenure with CFSA (Draft Report at pps. 5, and 21-23), the 
report should be modified to reflect what is the more significant 
reason: We could neither advertise the program nor enroll participants 
in it until after the funds were made available. This meant we could 
not advertise the program to candidates during the height of our spring 
recruitment season in colleges and universities. Additionally, workers 
who were already on board at the Agency were forced to make relatively 
quick decisions about their willingness to commit for a four-year term, 
and others who may have wanted to participate were unable to get the 
necessary proof of outstanding loans in the time available. While we 
would have liked to utilize all of the funds, we believe enrolling 70% 
(140 of 190) of eligible social workers in under six months, when 
Congress anticipated we would have almost 12 months to do so, is a 
tremendous accomplishment. Further, had we been able to carry over the 
funds to FY05, we would have been able to use the program as part of 
our current recruitment efforts. For these reasons, we request that the 
draft report at pages 5 and 21-23 be revised to reflect these comments. 

Second, we believe some corrections need to be made in the sections of 
the report surrounding the technology dollars (pages 5, 14-15 and 23- 
25). Pages 5 and 25 of the report incorrectly report that the upgrade 
project continues until September, 2008, when the Plan calls for the 
technology upgrades to be completed by September, 2006. Similarly, our 
contract has a detailed timeline for the deliverables, and the business 
continuity enhancements have been completed with the exception of the 
installation of new switches at one of three locations. The database 
software upgrade to Oracle Version 9i is complete, new KMV switches and 
racks have been installed, new network testing software is in use, and 
most of joint work with the District's Technology Office has been 
completed to install new switches and routers. The only exception is a 
delay in installing new switches in one of three locations because of 
complications with procuring the necessary cooling equipment. Planning 
is proceeding for the installation of the emergency power at the data 
center, but is should be emphasized that actual installation was never 
planned to be funded with the FY 04 federal appropriations. 

On page 14 of the draft report, also dealing with the technology 
dollars, GAO states that the vendor billed the District for 248 
computers, but that we only received 247 computers. As explained by 
email dated June 6, 2005, CFSA ordered 247 laptops with the federal 
dollars, received 247 laptops and paid for 247 laptops. We also 
purchased one laptop with local dollars, for a total of 248 laptops. 
See attachments 1-6, faxed to Norma Samuels. These records from our 
PASS contract system clearly show 247 computers were ordered, received 
and paid for with federal dollars, and that 1 additional computer was 
ordered, purchased and paid for with local dollars. Therefore, we 
believe, pages 14, 24 should be corrected to reflect the foregoing. 

Turning now to the emergency support program, draft report at pages 5 
and 19-21, the report states that one of the goals of the emergency 
support fund was to help CFSA reduce the number of unlicensed homes, 
but that little progress has been made on that issue. [NOTE] We believe 
that it is more accurate to state that the primary goal of the 
emergency support fund was to facilitate placement of children with 
kin, as reflected in both the language of the appropriations as well as 
in the Mayor's Plan. Certainly, some of the funds were used to 
facilitate licensing of kin, but because many of the still unlicensed 
homes are non-kin homes, the federal funds were not available to 
facilitate licensing of those homes. Importantly, for at least the last 
several years CFSA has not placed children in unlicensed homes, absent 
a specific court order, and we have made significant progress in 
licensing homes. Our management reports show that in June 2003, only 
56% of our foster homes were licensed, whereas now 78% of our foster 
homes are licensed. The report is correct in acknowledging the 
difficulties we are having in getting Maryland homes licensed as we do 
not have licensing authority there: In the District, 90% of foster 
homes are licensed, whereas only 73% are licensed in Maryland. 

The draft report also at page 15 raises a concern about the clothing 
voucher cards purchased with federal dollars. As a part of the FY 2004 
Federal Funds for Foster Care Improvements, the Agency obligated 
approximately $99,000 to nine (9) different vendors to purchase 
clothing cards in an effort to assist the Agency in responding quickly 
to emergency needs. Included in the obligations was a purchase order to 
Sears for $24,675 for several different denominations of clothing 
cards, one of which was $9,375 for 75 gift cards at $125.00. 

NOTE: It should be noted that the majority of currently unlicensed 
homes are homes that had been licensed but which license was not timely 
renewed. In contrast, in 2003, the majority of the unlicensed homes had 
never been licensed. 

The report states that GAO was unable to determine if the cards were 
received and paid for. Attached for your review are the following 
items, which establish the cards were bought and paid for: 

l. PASS print out reflecting that the purchase order was approved in 
PASS, the dollar amount, the vendor, and the different denomination of 
gift cards purchased, attachment 7;

2. PASS print out reflecting that the gift cards were received in PASS, 
which authorizes the finance office to pay, attachment 8;

3. Invoice from Sears, attachment 9;

4. SOAR print out reflecting the check number and check date paying 
SEARS for the gift cards, attachment 10. 

Further, we have to following systemic procedures in place to track, 
monitor and manage the distribution process of the gift cards. (See 
page 15 of the draft report). The request for a gift card is initiated 
by the social worker who completes the spending application after the 
need is identified, and in some cases is reflected in a court order. 
For those applications for amounts up to $1000, the social worker's 
supervisor reviews and approves the application. For amounts between 
$1001-$5000, the application must be reviewed by, and approved by, the 
Program Manager, and for amounts, between $5001 to $10,000, approval is 
required by the Program Administrator. For all applications over 
$10,000 approval of the Deputy Director for Program Operations is 
required. 

Once the appropriate level of review and approval is obtained, the 
spending application is reviewed against the federal criteria by one of 
two trained program staff. Following the review, if approved, the 
application is forwarded to the Finance Office staff, who again review 
it against the federal criteria. They check for accuracy and compliance 
with flex funds and if approved, they issue gift card. We plan to 
reassign responsibility for issuing the gift cards to specifically 
designated Program staff this month, so Program staff have ready 
access. Gift cards are recorded according to the case name and number 
associated with each request, the vendor, number on each gift card, the 
full amount as well as the worker who received them. The requesting 
social worker is required to provide a signature, authorizing the 
receipt of the gift cards. The gift cards at this time are temporarily 
maintained within the Finance Office in a safe designated for gift 
cards whose sole purpose is for use with the Flex Funds Spending. As of 
last week the Agency was provided with a key to secure gift cards 
separately and to allow the approver of the applications within the 
Office of the Deputy Director of Program Operations (ODDPO) to 
distribute. The same procedures conducted within the Finance Office 
will take place within ODDPO for distribution of gift cards. There is 
only one designated person with a key who has access to the safe and 
will track all use of agency gift cards. 

Finally, we have the following specific suggested language changes to 
the draft: 

* On page 2, at the top, we believe the reference to the Agency's 
history of mismanagement should be revised to reflect more clearly that 
the mismanagement is historical and not current, thus we suggest the 
phrase be revised to state "Because CFSA had a history of mismanagement 
and failed to protect some of the children under its care which led to 
the appointment by the federal court of a receiver ..";

* On page 5, the third bullet, second last line, the number 18% should 
be changed to 17%. Further it should be noted that some of this 
attrition was desirable as some low performing workers were terminated 
or encouraged to resign;

* On page 7, the first full paragraph is a bit confusing, and the last 
sentence is an overstatement. We think this paragraph needs to clarify 
the time frame in which that earlier assessment was made. Further, the 
last sentence is no longer accurate, and therefore could be misleading, 
so we request that this sentence be stricken. This is particularly true 
since caseloads now have been significantly reduced, for an average 
caseload in Investigation of 1:13.2; in adoptions, 1:9.6; and in In- 
Home/Reunification, 1:15, though we recognize that we are not yet at 
court mandated levels for every worker. Further, our Training Program 
is now consistently viewed by workers as an agency strength. (The 
content is essentially repeated on page 23 and we believe changes are 
needed there as well.)

We thank you for the opportunity to submit these comments and 
additional documentation, which we expect will meet the GAO's needs. 
Please contact my Chief of Staff, Janet Maher, at 442-6160, if you need 
additional information. 

Sincerely,

Signed by Janet Maher for: 

Brenda Donald Walker: 
Director, CFSA: 

Cc: Neil Albert, Deputy Mayor for Children, Youth and Elders; 
Janet Maher: 

[End of section]

Appendix III Comments from the District's Department of Mental Health: 

GOVERNMENT OF THE DISTRICT OF COLUMBIA: 
DEPARTMENT OF MENTAL HEALTH: 

Office of the Director: 

64 New York Avenue, NE, 4th Floor: 
Washington, DC 20002: 

(202) 673-1934 (voice): 
(202) 673-3433 (fax): 

June 20, 2005: 

Ms. Jeanette Franzel: 
Director: 
Finance Management Assurance: 
United States Government Accountability Office: 
441 G Street, NW, Room 5017B: 
Washington, DC 20548: 

RE: Comments Concerning GAO Draft Report: DISTRICT OF COLUMBIA: Foster 
Care Improvement Funds Used to Implement New Programs but Challenges 
Remain (GAO-05-787): 

Dear Ms. Franzel: 

Thank you for the opportunity to provide written comments on the above- 
referenced draft report of June 13, 2005 concerning the federal payment 
for foster care improvements in the District of Columbia. 

On behalf of the Department of Mental Health (DMH), I want to address 
two items in the report: delays in assessments at DMH's Youth Forensic 
Service Division/Outpatient Clinic (referred to hereinafter as the 
"Assessment Center") and service delivery capacity. 

The GAO's report accurately reflects "the sharp increase in referrals 
at the Assessment Center," but it is important to record that the 
Assessment Center experienced a 72% increase in assessments, increasing 
from the monthly average of 26 assessments during 2004 to an average of 
74 assessments per month during the period covered in your report 
(October through April 2005). With this increase, the average 
turnaround time (time from appointment request to report to Court) rose 
from 22 days in October 2004 to a high of 58 days in February 2005, 
with an average of 33.5 days. 

A small number of cases tipped this average unfavorably. For example, 
delays in the case you referenced (192 days) were caused by the fact 
that the client missed two scheduled appointments, which meant that the 
case went through three scheduling cycles. The Assessment Center staff 
reschedule appointments at the request of the client, social worker or 
judge. The request could come immediately after the missed appointment, 
weeks after or at the next court hearing, all of which affect the wait 
time. During the report period, there were a total of 10 cases where 
there was at least one missed appointment and most of those with more 
than one appointment missed. 

DMH has undertaken several initiatives to bring the wait time down to 
the reasonable and mandated 23-day turnaround. DMH is recruiting a 
fulltime staff psychiatrist who will have dedicated hours at the 
Assessment Center and help to assure both continuity and availability 
of adequate psychiatric coverage. In addition, DMH has retained an 
expert forensic psychiatrist who has, this week, conducted an on-site 
review of related processes and will shortly be making recommendations 
concerning potential opportunities for increased efficiency. 

We would like to clarify several points concerning the GAO's references 
on page 27 of the report about the challenges that DMH faces in 
building capacity to deliver services. DMH already has the capacity to 
utilize Medicaid funding for the new services once the providers become 
certified as Medicaid providers. All three new providers have made 
application to become certified and we are fairly confident they will 
be certified by October 1, 2005. However while the Congressional 
appropriation could not have been used as "local match" for these 
services, it was used very successfully for "start-up" funding for the 
three new services. DMH is pleased that Mayor Williams included "local 
funds" in his budget for FY 2006 so that DMH can successfully bill 
Medicaid for these services in FY 2006. DMH is also in the process of 
revising its service regulations to take advantage of new knowledge 
about how best to organize service arrangements for these clinical 
services. 

Further, as you have stated, DMH will need additional local funding for 
match if it is to expand the services started with this federal 
appropriation. These local funds are needed to meet the projected long- 
term needs of youth in foster care who could benefit from the Multi 
Systemic and Intensive In Home Therapies and the mobile crisis and 
stabilization services. 

We would like to thank the GAO staff for their thoroughness and 
professionalism in their review of this new program over the past year. 
DMH is strongly committed to the programs started with the funds 
provided by Congress. While it is early, perhaps too early to determine 
the long-term success of the program, the GAO has helped us assess our 
progress and challenges in a very focused manner that in turn will help 
us reach our two long-term goals. Our long term goals are for DMH to 
expand critical services and provide highly valued assessments to help 
the Family Court Judges render better decisions about the lives of 
children and families. 

Thank you for the opportunity to provide additional background on our 
utilization of these funds. Please feel free to direct any questions 
you have regarding these comments to Marcia Jones, my Chief of Staff at 
(202) 673-3538 or Marcia.Jones@dc.gov. 

Sincerely yours,

Signed by: 

Martha B. Knisley: 
Director: 

cc: Neil Albert, Deputy Mayor, Children, Youth, Families and Elders; 
Brenda Donald Walker, Director, DC Child and Family Services Agency; 
Shauna Spencer, Acting Director, DMH Children's Services; Kris 
Laurenti, Program Manager, DMH Assessment Center; Marcia Jones, DMH 
Chief of Staff: 

[End of section]

Appendix IV: Comments from the Metropolitan Washington Council of 
Governments: 

METROPOLITAN WASHINGTON COUNCIL OF GOVERNMENTS: 

June 20, 2005: 

District of Columbia: 
Bowie: 
College Park: 
Frederick County: 
Gaithersburg: 
Greenbelt: 
Montgomery County: 
Prince George's County: 
Rockville: 
Takoma Park: 
Alexandria: 
Arlington County: 
Fairfax: 
Fairfax County: 
Falls Church: 
Loudoun County: 
Manassas: 
Manassas Park: 
Prince William County: 

Jeanette Franzel, Director: 
United Stated Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Franzel: 

Thank you for the opportunity to respond to the report on the District 
of Columbia's Federal Funds for Foster Care Improvements. It has been a 
very challenging and exciting year for the Metropolitan Washington 
Council of Governments as we developed and implemented the respite and 
recruitment program serving the District's foster children. 

We would like to address the report's statement, "It may be a challenge 
for COG to recruit enough respite providers and convince foster parents 
to participate". Recruiting the families to provide respite has not 
been a challenge. We have been pleasantly surprised about the response 
to our recruitment efforts. To date, we have received more than 2,000 
telephone inquiries regarding the respite program. We have had six 
weekend-long training sessions in which 83 families were trained to be 
volunteer respite providers. 

The challenge has been keeping volunteers' level of enthusiasm through 
the arduous and lengthy licensing process. It has taken anywhere from 
three to six months to get background criminal clearances for the 
interested respite providers. They also must have home inspections, a 
physical examination, and other requirements that can be overwhelming 
and time-consuming to individuals who just want to help a foster child 
on a weekend. Still, we have seven families fully licensed and 40 
families just waiting for clearances, with other inspections and 
paperwork completed. 

In addition, word about COG's respite program is spreading at a swift 
pace among foster families and we have had an increase in respite 
requests. So far, more than 250 respite placements have been provided. 
This number includes overnight, enrichment and day respite programs. 

It has been a privilege to serve the District's most vulnerable 
citizens. We would like to thank the US Congress for this opportunity 
to implement this essential, effective, innovative service. We look 
forward to continuing this effort. 

Sincerely,

Signed by: 

David Robertson: 
Executive Director: 

777 North Capitol Street, N.E. Suite 300: 
Washington, D.C. 20002-4290: 
Telephone (202) 962-3200: 
Fax (202) 962-3201: 
TDD (202) 962-3213: 
Internet http://www.mwcog.org: 

[End of section]

Appendix V: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Jeanette Franzel at (202) 512-9471 or FranzelJ@gao.gov: 

Cornelia M. Ashby at (202) 512-8403 or AshbyC@gao.gov: 

Staff Acknowledgments: 

The following individuals also made important contributions to this 
report: Norma Samuel, Carolyn Taylor, Carolyn Yocom, Susan Barnidge, 
Sharon Byrd, Jacquelyn Hamilton, Maxine Hattery, Deborah Peay, Vernette 
Shaw, and Sandra Silzer. 

(194500): 

FOOTNOTES

[1] Pub. L. No. 108-199, Div. C, title 1, 118 Stat. 3, 111 (Jan. 23, 
2004). 

[2] The Foster and Adoptive Parents Advocacy Center is an organization 
that assists foster, kinship, and adoptive parents of children in the 
District of Columbia. 

[3] Section 168 of Division H of the Consolidated Appropriations Act, 
2004, Pub. L. No. 108-199, included a provision for an across-the-board 
0.59 percent rescission to be deducted from the budget authority 
provided for any discretionary accounting in the act. 

[4] GAO, D.C. Child and Family Services Agency: More Focus Needed on 
Human Capital Management Issues for Caseworkers and Foster Parent 
Recruitment and Retention, GAO-04-1017 (Washington, D.C.: Sept. 24, 
2004). 

[5] See appendix I for statistical sampling details. 

[6] GAO, Government Auditing Standards 2003 Revision, GAO-03-673G 
(Washington, D.C.: June 2003). 

[7] GAO, 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). 

[8] The receivership was an arrangement in which the U.S. District 
Court appointed a person to temporarily manage the agency with broad 
authority to ensure full and expeditious compliance with requirements 
established by the court. 

[9] GAO, D.C. Child and Family Services: Better Policy Implementation 
and Documentation of Related Activities Would Help Improve Performance, 
GAO-03-646 (Washington, D.C.: May 27, 2003); Center for the Study of 
Social Policy, LaShawn A. v. Williams: An Assessment of the District of 
Columbia's Progress as of September 30, 2003 in Meeting the 
Implementation and Outcome Benchmarks for Child Welfare Reform 
(Washington, D.C.: Feb. 9, 2004). 

[10] The U.S. District Court for the District of Columbia placed the 
D.C. Commission on Mental Health Services, DMH's predecessor agency, in 
receivership in 1997. The first receiver began his appointment in 
October 1997 and resigned in March 2000. The court then issued a 
consent order establishing a transitional receiver to develop a plan 
for the District to resume full control of its mental health system. 
This transitional receivership was terminated in May 2002, and the 
court appointed a monitor to oversee the District's implementation of 
the plan. 

[11] Pub. L. No. 107-114, 115 Stat. 2100 (Jan. 8, 2002). 

[12] Pub. L. No. 107-96, 115 Stat. 923, 929 (Dec. 21, 2001). For more 
details on the planned reform practices in the District's Family Court, 
see GAO, D.C. Family Court: Additional Actions Should Be Taken to Fully 
Implement Its Transition, GAO-02-584 (Washington, D.C.: May 6, 2002). 

[13] Pub. L. No. 108-199, Div. C, title 1, 118 Stat. 3, 111. (Jan. 23, 
2004). 

[14] Subsequently, for fiscal year 2005, the Congress provided about $5 
million in additional funding for foster care improvements in the 
District. These federal funds were made available for specific programs 
to CFSA, DMH, and COG until expended. The appropriations act provided 
(1) $3,250,000 for CFSA's early intervention program, the emergency 
support fund, and technology upgrades; (2) $1,250,000 for DMH to 
provide all court-ordered or agency-required mental health screenings, 
assessments, and treatments for children under the supervision of CFSA; 
and (3) $500,000 for COG to continue a program in conjunction with the 
Foster and Adoptive Parents Advocacy Center, to provide respite care 
for and recruitment of foster parents. Pub. L. No. 108-335, 118 Stat. 
1322, 1326 (Oct. 18, 2004). 

[15] Section 168 of Division H of the Consolidated Appropriations Act, 
2004, Pub. L. No. 108-199, included a provision for an across-the-board 
0.59 percent rescission to be deducted from the budget authority 
provided for any discretionary accounting in the act. 

[16] GAO-04-1017. 

[17] GAO-04-1017. 

[18] Internal control is an integral component of an organization's 
management that provides reasonable assurance that the following 
objectives are being achieved--effectiveness and efficiency of 
operations, reliability of financial reporting, and compliance with 
applicable laws and regulations. GAO, Standards for Internal Control in 
the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 
1999). 

[19] No matter how well designed and operated, internal controls cannot 
provide absolute assurance that all agency objectives will be met. 
Management should design and implement internal controls based on the 
related cost and benefits. Therefore, internal control provides 
reasonable, but not absolute assurance of meeting agency objectives. 
GAO/AIMD-00-21.3.1. 

[20] The sample was selected based on a dollar-unit sampling 
methodology which, by its nature, will tend to select large dollar unit 
items. See appendix I for statistical sampling details. 

[21] We are 95 percent confident that the upper error limit 
overstatement of obligation transactions with ineffective controls is 
not more than $1.2 million. This estimate does not exceed the tolerable 
amount in error of $2.0 million. 

[22] An imprest fund is a fixed-cash or petty cash fund in the form of 
currency or coin. The funds are charged against a government 
appropriation by an agency official and advanced to an authorized 
cashier. The fund may be revolving, replenished to the level of a fixed 
amount as spent or used, or stationary such as a change-making fund. 

[23] GAO-03-673G. 

[24] CFSA transferred $75,000 from this fund to DMH for the Mobile 
Response and Service Stabilization (MRSS) program. The MRSS program 
provides services to manage crises and prevent children from moving 
from their biological family or a kinship caregiver into foster care. 

[25] Kinship homes are those in which a relative or unrelated person 
with long-standing ties to the child provides care for a child that has 
been neglected, abused, or is at risk for neglect and abuse. 

[26] Congregate care homes include group homes, independent living 
placements (ILPs), and therapeutic facilities. Group homes provide 
services to children in large family-type settings, ILPs are monitored 
apartments for teens who are preparing to live independently, and 
therapeutic facilities offer specialized medical and mental health care 
for children and teens. Congregate care facilities are designed to 
provide placement for children who have not done well in the family 
setting or for those awaiting placement with traditional foster 
families. 

[27] GAO-04-1017. 

[28] CFSA issues temporary licenses to kinship homes in the District; 
therefore, these homes are counted as licensed. 

[29] A home study is the process of assessing and preparing families to 
determine their potential to become either foster or adoptive parents. 

[30] Interstate Compact on the Placement of Children (ICPC) is a 
uniform law, enacted in all 50 states, the District of Columbia, and 
the U.S. Virgin Islands, that governs the interstate placement of 
children in foster and adoptive homes. Under ICPC, the state from which 
a child is sent retains jurisdiction over the child and his or her 
placement. ICPC ensures that children placed from one state into 
another receive adequate protections, services, and supervision. 

[31] According to the terms of the program, CFSA pays one-half of the 
repayment amounts at the end of the caseworkers' 3rd year and the 
remaining half at the end of the 4th year. Those with more than 4 years 
of service must agree to remain with the agency at least 1 more year. 

[32] GAO-04-1017. 

[33] Deficient management practices cited were poor communication, a 
lack of resources, poor supervision, and no program for rewards and 
recognition. 

[34] CFSA contractors continued to provide some needed assessments. 
From August 2004 through February 2005, approximately 40 percent of 
referrals for assessments were sent to CFSA contractors. 

[35] These time frames require DMH to initiate services within 3 days 
of notification, complete assessments within 15 days of the request, 
and provide the Family Court with assessments within 5 days of 
completion. 118 Stat. 116. 

[36] GAO-04-1017. 

[37] Multisystemic therapy is treatment delivered in homes and the 
community for foster care youth with complex clinical, social, and 
educational problems. Intensive home-and community-based services are 
provided by a team of professionals and are available 24 hours a day 
and 7 days a week. The mobile response and stabilization services are 
provided at the site of a child's escalating behavior. 

[38] GAO-04-1017. 

[39] According to a Family Court official, the total number of cases 
being referred for assessments and other services has been constant 
since receipt of the federal funds in March 2004; however, the number 
being referred to DMH has increased. 

[40] Medicaid is a jointly funded federal-state program that pays for 
medical assistance for certain low-income families and individuals who 
meet certain criteria. With federal approval, Medicaid will reimburse 
states' expenditures for certain types of rehabilitative services such 
as community-based treatment. 

[41] GAO-04-1017. 

[42] We are 95 percent confident that the upper error limit 
overstatement of obligation transactions with ineffective controls is 
not more than $1.2 million. This estimate does not exceed the tolerable 
amount in error of $2.0 million. 

[43] GAO-03-673G. 

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