Department  of  Health  and Human  Services 
OFFICE  OF 
INSPECTOR  GENERAL 
TRENDS  IN  FOSTER  CARE 

Richard  P.  Kusserow 
INSPECTOR  GENERAL 
OEI-01-90-00490  EXECUTIVE  SUMMARY 
PURPOSE 
In this study we indicate recent trends concerning the number  of children  in foster 
care caseloads, their  age, and their  placement status (group homes or foster family 
homes). 
BACKGROUND 
On a nationwide  basis, there is little  timely  and reliable  information  available on 
children  in foster care.  This situation  exists despite more than a decade of Federal 
deliberations  concerning the establishment and operation  of a foster care and 
adoption  data collection  system. 
In the informational  void, national  policymakers  find  that many vital  questions cannot 
be answered with  much certainty.  One such set of questions involves the number  and 
age of foster care children  being placed in group care facilities  as opposed to 
individual  foster family  homes. 
To help answer such questions, we conducted a telephone  and follow-up  mail  survey 
of State child welfare  officials  in the 50 States and the District  of Columbia.  In 
addition,  we (1) conducted on-site interviews with  public  and private  sector officials 
involved with  the delivery of child welfare  services in the nations two most heavily 
populated  States, California  and New York,  and (2) reviewed much literature  and 
many documents concerning foster care. 
FINDINGS 
l&e  Number  of  Children  in Foster  Care Has  Been Increasing 
After  years of apparently  little  or no growth, the national  foster care caseload 
increased substantially in the last half of the 1980s. From  1985 to 1989, for  38 
reporting  States, the caseload rose by 33 percent, from  228,155 to 304,431. 
Eighty-six percent of the growth occurred in only  11 States.  California  and 
b 	
New York  together  accounted for 65 percent of the growth. 
In both  California  and New York,  a rise in caseload admissions in relation  to 
b 	
discharges has propelled  the growth. 
I  lk  hmndon  of Ihdtook  and  Infan&  in Fader  Care Has  Been  Inching. 
From  1985 to 1989, for  15 reporting  States, the proportion  of infants and preschoolers 
in the foster care caseload increased from  22 percent to 31 percent.  During  the same 
period,  the proportion  of 15-to 18-year-olds declined from  32 percent to 22 percent. 
In California  and New York,  these trends were slightly more pronounced.  The 
b 	
proportion  of infants and preschoolers rose from  22 percent to 34 percent as 
the proportion  of 15-to 18-year-olds declined from  31 percent to  18 percent. 
From  1985 to 1989, for  33 reporting  States, the number  of foster children  in group 
homes increased by 16 percent, from  44,226 to 51,189.  California  and New York 
accounted for 57 percent of this growth. 
During  the same period,  however, the proportion  of foster children  in group care in 
these 33 States declined slightly but steadily from  21 percent to  18 percent. 
During  the last half of the 1980s, infants and preschoolers accounted for  a small but 
increasing proportion  of group home caseloads. From  1985 to 1989, for  11 reporting 
States, the proportion  increased from  2.7 percent to 5.4 percent, in contrast to the 
proportion  of 15-to 18-year-olds, which decreased from  58 percent to 53 percent. 
For California  and New York,  the data we obtained  are not exactly 
b 	
comparable.  It is apparent, however, that in those States during  the 1985-1989 
period,  the small proportion  of very young children  in the group home caseload 
increased at an especially sharp rate. 
RECOMMENDATION 
The Administration  for  Children  and Families  (ACF)  should specify its plans for the 
preparation  and regular distribution  of policy-relevant  tables and for  special analyses 
concerning the data in the proposed foster care and adoption  data collection  system. 
It  should indicate these plans in the preamble  to the regulations  to be issued 
concerning the system. 
CoMMEm 
We received comments on the draft  report  from  the ACF  and the Assistant Secretary 
for Planning and Evaluation  (ASPE).  Both ACF  (in oral comments)  and ASPE  (in 
written  comments) expressed concern about our draft  report  recommendation  calling 
for immediate  implementation  of essential aspects of the foster care and adoption 
data collection  system.  Because of our understanding that ACF  has removed 
ii  duplicative  and unnecessary data elements included in its earlier  proposal, we have 
dropped  that recommendation. 
On our only remaining  recommendation,  which calls for ACF  to specify its plans for 
the preparation  and regular distribution  of policy relevant tables and for special 
analyses concerning the data collection  system, ACF  agreed to take the 
recommendations  under advisement and respond to the extent possible. 
... 
111  TABLE  OF  CONTENTS 

APPENDIX  c 
Tables Derived  From  OIG  Survey 
of Child  Welfare  Agencies s ea+- - - - - - as - - - - s s - q 
APPENDIX  D 
Detailed  Comments  on the Draft  Report 
and OIG  Response to the Comments  - - - - - - - - - - m- INTRODUCTION 
For many governmental  programs, national  information  on the number,  age, and, 
where applicable,  placement  status of clients can be regarded as a given.  For the 
Federal-State  foster care program,  that is not the case. On a nationwide  basis, there 
is little  information  available on the foster care caseload, a fact that seriously limits 
policymakers  understanding of the programs effectiveness. 
PURPOSE 
The purpose of our study is to provide information  on the foster care caseload that 
will  help policymakers  assessthe program.  Toward  that end, this report  focuses on 
three basic questions:  How  many children  are in foster care?  How  old are they?  In 
what kind  of settings are they being placed? 
In addressing these questions, we emphasize the changes that have occurred during 
the last half of the 1980s. To the limited  extent our information  allows, we also 
address the factors that appear to be responsible for these changes. 
METHODOLOGY 
Our methodology  (see appendix B) is based on three major  data-gathering 
approaches:  (1) a telephone  and follow-up  mail  survey with  State child welfare 
officials  in the 50 States and the District  of Columbia,  (2) on-site interviews with 
public  and private  sector officials  involved with  the delivery of child welfare  services in 
* 	 California  and New York,  and (3) a review of literature  and documents concerning 
child welfare  services in general and foster care in particular. 
Most  of the trend  data set forth  is based on our State survey.  In collecting,  analyzing, 
and presenting these data, we faced a number  of methodological  problems  associated 
with  the varied and often incomplete  nature of the State data systems. In appendix B, 
we indicate  how we addressed these problems. 
Throughout  the report,  we regard the universe of foster care children  to include  all 
children  who are placed away from  their  parents or guardians and are the 
responsibility  of the State child welfare  agencies, whether  or not they have been 
placed by private  service agencies. These children  may be placed in foster family 
homes or group homes.  We define the former  to include homes where foster parents 
care for foster children  and receive payments for board and care and other necessary 
living expenses associated with  these children.  We define group homes as facilities 
that are operated  by a group or organization  and are managed on a 24-hour basis by 
caregivers who are paid staff. 
1 
 THE  PROGRAMMA  TIC  CONTEXT 
In  1980, Congress passed the Adoption  Assistance and Child  Welfare  Amendments 
Act  (P.L. 96-272).  The law called for considerable reform  in the nations foster care 
system.  It  sought to (1) decrease the need for out-of-home  placement  of children  by 
making  services available to children  at risk and (2) reduce the length of stay in foster 
care by offering  more extensive case management and permanency planning. 
The centerpiece of the legislation was a new Title  IV-E  of the Social Security Act.2 
This title  mandated procedural  standards, case planning  and review activities, and 
record-keeping  requirements  for a system that has been the nearly exclusive purview 
of State governments.  Moreover,  it authorized  open-ended Federal funding  to the 
States for  certain administrative  and training  activities and for foster care maintenance 
payments for children,  from  birth  to 18 years of age, who meet eligibility  criteria  based 
in part on the childs eligibility  under the Aid  to Families with  Dependent  Children 
(AFDC)  program.  In addition,  it authorized  adoption  assistance payments for special 
needs children  , children who originate  from  families  eligible  for AFDC  who are 
physically or emotionally  disabled, adolescents, or members of a sibling or ethnic 
minority  group. 
During  the 1980s, Federal expenditures for Title  IV-E  rose substantially.  From  fiscal 
year 1981 to fiscal year 1988, the Federal share of administrative  and training  costs 
climbed  from  $30.4 million  to $352.5 million  and the Federal share of foster care 
maintenance  costs increased from  $278.4 million  to $520.7 million.  The estimated 
expenditures for  fiscal year 1991 suggest even greater increases, to $949.2 million  for 
Federal administrative  and training  costs and $927.4 million  for Federal foster care 
maintenance  costs.3 
In recent years, as the costs of the foster care program  have mounted,  many policy 
officials  at Federal and State levels have expressed concern about the adequacy of the 
care being provided  to some of the children.  Of particular  note has been concern 
about a perceived growth  in the group home population.  This seems to have been 
exacerbated by press accounts of the emergence of some large orphanage-type 
facilities  where, because of shortages of foster families  and caseworkers, children  are 
said to be warehoused. 
Such practices, to the extent they exist, seem to conflict  with  the social work  principle 
of making foster care placement  choices on the basis of the individual  needs of each 
child and raise questions about the adequacy of services being extended to foster 
children.  Yet  because there is little  current, reliable  data on the foster care caseload 
for all the States, any analysis of this kind is seriously constrained. 
2 
 THE  DATA  COLTECI-ION  SYSTEM  CONTEXT 
Congress first  addressed the need for a national  data collection  system more than a 

decade ago.4 In  1978, in the Child  Abuse Prevention and Treatment  and Adoption 

Reform  Act,  it called for the Department  of Health  and Human  Services (HHS)  to 

provide for the establishment and operation  of a national  foster care and adoption 

data collection  system.  And  then, in  1980, in the Adoption  Assistance and Child 

Welfare  Act,  it authorized  HHS  to call on the States to submit statistical reports 

addressing the legal status, demographic  characteristics, location,  and length of stay of 

children  in foster care. 

In  1982, in response to these congressional enactments, the Department  began funding 

the American  Public Welfare  Association to establish and run the Voluntary 

Cooperative  Information  System.  That  system, which continues to operate, collects 

information  from  State child welfare  agencies on foster care children  and special needs 

children who are adopted.  But the system, which is based on the voluntary 

participation  of the States, is of relatively  little  value to researchers or policymakers. 

It  is in many respects incomplete;  it lacks common definitions  for data elements; and it 

reflects inconsistent reporting  periods and methodologies. 

In  1986, Congress once again called for the establishment of a foster care and 

adoption  data collection  system.  Toward  that end, it mandated that HHS  (1) form  an 

advisory committee  to determine  the kind  of system that should be set up, (2) submit 

to Congress a plan, based on the advisory committees  report,  for establishing and 

running  the system, and (3) promulgate  the necessary regulations. 

Each of these steps has been carried out.  In October  1987, the advisory committee 

submitted  its report  to Congress and HHS.  In May  1989, HHS  presented its plan to 

Congress; and, in September  1990, it issued a proposed notice of rulemaking  for the 

data collection  system, which Congress expects to be fully  implemented  by October 

1991. 

The system proposed by HHS  is a comprehensive one, calling for  States to submit 

data electronically  on a quarterly  basis.  It allows for Federal reimbursement,  at a 50 

percent matching rate, for a portion  of the State costs of the system.  On the basis of 

the advisory groups inquiry  in  1987, it estimates that State and local costs will  be $40 

million  over 3 years for the purchase of hardware and software and $6 million  yearly 

for administration.  Annual  Federal costs for administering  the system, it estimates, 

will  be $1 million. 

3 
 FINDINGS 

JWMBER  OF CHILDREN  IN  CASELOAD 
fartercarecask  iracmzd 
Afret  years of ap~rently  little  or no growth,  the nationa! 
substantiaLly  in the last half  of the 1980s.  Rvm  I985  to 1989, for  38 rqpdng  States, the 
casebad  me  by 33Fm  fiurn  22&155  to 304,431. 
Although  definitive  assessmentsare not possible, it appears that in the early 1980s 
there was little  if any growth in the national  foster care population.  In fact, it is 
possible that at mid-decade that population  was somewhat less than in the late  1970s? 
FIGURE  1 
TOTAL  FOSTER  CARE CASELOAD 1985-1989 
38  STATES 
Thousands 
I  I  1 
1oe85  1986  1987  1988  1989 
- 98  Reporting  States  --e  Top  Eleven 
*  CA and  NY  - Other  Stater 
SOURC8:  State  Child  Tellare  A#cnclcr 
.  reported  to  OIC 
It is clear, however, that in the last half of the 1980s the national  foster care caseload 
increased significantly.  In our national  sample, 38 States provided  data on the size of 
their  caseload for  1985 and each of the subsequent 4 years.6  Together,  they showed a 
prominent  increase, beginning in 1986 and intensifying  between  1988 and 1989 
(figure  1). 
4 
 Eighty-six percent of the growth  occurred in only 11 States.  California  and 
b 	
New York  together accounted for 65 percent of the growth. 
When one analyzes the 38-State data, it is readily apparent  that the growth  is 
concentrated in 11 States, especially California  and New York  (figure  1).  These two 
States, together with  Illinois,  Ohio, Pennsylvania, Michigan,  Massachusetts, Florida, 
New Jersey, Washington, and Georgia constitute the Top  Eleven. 
b 	 In both California  and New York,  a rise in caseload admissions in relation  to 
discharges has propelled  the growth. 
Caseload size is a function  of changes occurring in admissions, on the one hand, and 
discharges, on the other.  Thus, for instance, a caseload can increase with  no increase 
in admissions as long as discharges decrease.  Conversely, a caseload can decrease 
with  no decrease in admissions as long as discharges increase. 
FIGURE  2 
FOSTER  CARE  CASELOAD  ADMISSIONS  AND  DISCHARGES  1985-1989 
New  York  California 
Thouundr  Thouund, 
a0  .  40 
26  -
*o- . 
-
16  -
10  -
10  - _ _^_,  .._  _  ..__..___  ..___  .  . 
6-
0 
PO66  1066  1667  1666  1666  1666  1866  1907  1988  (818 
Year  Year 
- Adml*donr  +  Dlrchw6.a  - Admlulonr  +  Dkchrrg6r 
COUICEI  C1~1~  Child  *.I,.,*  A,..,., 
. .  1*,01w4  t.  010 
To assesssuch caseload dynamics, we asked each State for data on admissions and 
discharges for each of the 5 years studied.  Only 6 of the Top  Eleven and 15 other 
States were able to provide us with  that data.  California  and New York  were among 
5 
 those providing  the data, and in both States it emerges that admissions was the 
propelling  force behind the caseload growth, albeit with  somewhat different  patterns 
(figure  2).  In California,  the growth in admissions was accompanied each year by an 
increase in discharges.  In New York,  both admissions and discharges decreased from 
1985 to 1986. Then  admissions rose each subsequent year, while  discharges first 
declined from  1986 to 1988 and then increased between 1988 and 1989.  The 
substantial growth in admissions was primarily  attributable  to kinship  or approved 
relative home placements called for by a New York  State court ruling. 
hving  the late  1980S, the growth  in the fbster  care cad&d  outpaced  the ovudl 
in thenumbeorf childrenin thegenemlpopuhio~hm  1985to 1989f,or38 
hcreuse 
reporting  Stateq  the number  of placements  per  I,NM  children  aged I8  and  uder  me  by 
31 pemaq  from  3.85  to 5.04. 
FIGURE  3 
TOTAL  FOSTER  CARE PLACEMENT  1985-1989 
PER  1000  CHILDREN  (~=38) 
Placement  per  1000  chlldrcn  WC  O-16 
10,  I 
8  _  _- _.._  - __._  _  --  ---_  ---  -. -..- .  - .  -......  _  ._  _ ___..  -- 
 
6  -._._  --  . .._  ._.__  _  - __._  - .._  -._ 
46 
4  _.-._ 
2  -..-.- ..__-_-_  .._ ..__ -.-. ___-..-- __...-__  _..... -.  ---_ 
I  I  I 

Pees  1986  1987  1988  1989 

--  98  Reporting  States  +  CA and  NY 
- Top  Eleven  - Other  statea 
The growth  in the foster care population,  as the above data indicate, is not just a 
reflection  of the increased number  of children  in the general population.  For each of 
the last 5 years of the decade, it also reflects an increased proportion  of children  in 
the United  States who are in a foster care status (figure  3). Indeed, by the end of the 
1980s a higher proportion  of children were in foster care than at anytime in at least 
the last three decades. 
6 
 The increase in the 1985 to 1989 period was especial@pronounced  in 
b 	
California  and New York  In those States together, the number  of placements 
per 1,OCKcIhildren  aged 18 and under jumped  by 62 percent, from  5.74 to 9.32. 
The jump  was greatest in New York,  where the rate rose from  5.60 to 10.08; in 
California  the increase was from  5.83 to 8.88.  Among  the other Top  Eleven States, 7 
also had increases, though typically  less pronounced.  Two  actually had small 
decreases. In Massachusetts, the placement rate per 1,000 children  declined from  6.83 
in 1985 to 6.59 in 1989; in New Jersey, from  4.51 to 4.29. 
AGE  OF CHILDREN 
From  1985  to 1989, for  I5  reprthg  Stutces,the ptvptdon  of infants  and preschookrs  in 
the fmter  care caseload  increawd  jbn  22 pemmt  to 3I  ptmmt  bring  same 
that 
w  the proportion  of I5- to I8-year-ok.&  declhed  from  32 percent  to 22 percent. 
b 	 In California  and New York,  these trends were slighUy more pronounced.  The 
proportion  of infants and preschoolers rose from  22 percent to 34 percent as 
the proportion  of 15-to l&year+Ms  declined from  31 percent to 18 percent. 
FIGURE  4 
AGE DISTRIBUTION OF FOSTERCARE CASELOAD 
1985-1989  (15  STATES) 
Percent  of  Total  Caseload 
35  , 
1985  1986  1987  1988  1989 
m 
Infants  <  1 year  m  1-4  years  I  5-9  yearr 
IO-14  years  m  15-18  pearr 
SOURCE:  State  Child  Welfare  A~cnclca 
.a  reported  Lo OK 
7 
 As the overall number  of foster care children  has increased, the age distribution  has 
changed significantly.  During  the last 5 years of the decade, the oldest groups share 
of the caseload eroded substantially as the two youngest segments share--infants (less 
than  1 year old) and preschoolers (1 to 4 years old)--gained  substantially (figure  4). 
This was particularly  true in California  and New York  (figure  5), but the same general 
trend was found in all  15 reporting  States. 
FIGURE  5 
AGE DISTRIBUTION  OF FOSTER CARE CASELOAD 
CALIFORNIA  AND  NEW YORK  19854989 
Percent  of  Total  Cueload 
35 
1985  1986  1987  1988  1989 
I  Infants  <  1 year  0  5-9  yeara 
E2Z  IO-14  years 
What is especially striking  is the emergence of a foster care baby boom, especially, 
once again, in California  and New York.  Among  the 15 States, the number  of infants 
placed in foster care per 1,000 children  aged 18 and under rose sharply, from  2.57 to 
6.05; in California  and New York,  the number rose even more sharply, from  3.38 to 
9.67 (appendix  C).  In New York  City, between 1984 and 1988, the rate at which 
infants were placed in foster care almost tripled  from  8.7 per  1,000 live births to 25.3. 
Thus, in 1988, about 2.5 percent of all children born in New York  City were placed in 
foster care within  a year of birth.g 
PLACEMENT  STATUS  OF CH-ILDREN 
From  I985  to 1989, for  33 reporting  States, the number  of foster  children  in group  homes 
increased  by I6  percent,  from  44,226  to 51,189.  California  and  New  Yank accounted  for 
57pement  of thk  growth. 
8 
 FIGURE  6 
TOTAL GROUPHOME CASELOAD1985-1989 
33  STATES 
Thousands 
60 
50  .___. _  ._.. _ .  ._._..._..._......... . . _....__..._  -.._.....-.._...  __ __ -._-.. 
t 
*o  t  _......- . .  ..-.  . - .._._-.-..  . _....____...__-__ .  __._.__.  .-...__..__  - __._...
i 
L 
30- ..__.._-_.._ -..  .--_._-__. -.-- ..-_-.-......^-.
20  -......-....._....  .  ._-.__...--- _..-.... -.-.....  J, 
II 
I 
10  _ .._.......  -_-- -_-.___-.-
I  1  I 
1oss5  1986  1987  1988  1989 
- 33  Reporting  Slates  - Top  Eleven 
--);  CA and  NY  *  Other  States 
SOURCE:  State  Child  Kelferc  A#encies 
.,  reported  to  OIC 
From  1985 to  1987, for 33 reporting  States, the number  of foster care children  in 
group homes remained  about the same (figure  6).  During  the next 2 years, however, 
the group home caseload rose substantially, with  close to 60 percent of the growth 
occurring in California  and New York.  In view of the growth  taking place in the total 
foster care caseload, these increases would  not appear to be surprising. 
Firm  I985  to 1989, fat  33 repolrting Safer,  the pvpntiim  of fixter  children  in pup  care 
declined~but~fionr2I~toI8~a 
This finding  is perhaps more surprising, given the perceptions we noted at the outset 
of this report  about the growing number  of children  in group facilities.  Between  1985 
and 1989, the group home population  still increased at a rate greater than the increase 
in the 18-year-old-and-under  population  (appendix C).  It declined modestly as a 
proportion  of the total  caseload, however, as the number  of family  foster home 
placements rose significantly.  Overall, for the 33 reporting  States, the number  of 
foster children  in group homes rose from  207,810 to 280,187. 
9 
 . 
I 
For  California  and  New  York,  the  data  we  obtained  are  not  exactly 
b 	
comparable.  It  is apparent,  however,  that  in  those  States  during  the  198549 
period,  the  small  proportion  of very  young  children  in the  group  home  caseload 
increased  at an especially  sharp  rate. 
In  1989, as in 1985, the 15-to 18-year-olds dominated  the group home caseloads. 
Some shifting  of the distribution  occurred, however, with  the oldest groups share 
declining and the youngest two groups share increasing. 
Among  the 11 reporting  States, which do not include New York,  the increase is 
concentrated in California,  where between  1985 and 1989, the number  of infants in 
group care increased from  74 to 243 and preschoolers from  241 to 820.  In contrast, 2 
of the States began and ended the period with  no infants and preschoolers in group 
care, 4 experienced a modest increase, and 4 had a decline (in 2 casesa substantial 
decline). 
In New York,  a compilation  by the State Department  of Social Services indicates that 
the proportionate  increase has been greatest there.  In  1985, 4.1 percent of children  in 
group care were 5 years old or younger and 2.1 percent were under  1 year old; by 
1988, the corresponding numbers increased to 19.6 percent and 8.0 percent. 
In explaining  such increases, policy officials  in California  and New York  told  us that 
because they had not expected the baby boom in foster care, they did not have 
enough foster family  homes for infants to meet the accelerated demand. 
Exacerbating the problem,  they added, was that a number  of the infants admitted  to 
foster care during this period  had special health problems associated with  human 
immunodeficiency  virus (HIV)  infection  or fetal exposure to drugs.  Recruitment  and 
support of families  to care for such children  often require  extraordinary  efforts. 
It is a generally accepted principle  that the most therapeutically  desirable placement 
for infants is with  families  rather  than in group facilities.  In attempting  to adhere to 
this principle,  California  and New York  officials have intensified  their  recruitment  and 
family  support efforts.  Although  it is too soon to know for sure, there are signs that 
these efforts may be having some success. In New York,  State officials  reported  that 
they have developed a waiting  list of families willing  to care for infants with  HIV 
infection,  and incomplete  data for  1989 indicate some reduction  in the proportion  of 
infants in group care.  Similarly,  Los Angeles County officials  reported  significant 
recent reductions in the number  of infants placed in their  county-run  receiving center. 
10 
 . 

! 
RECOMMENDATION 
Among  the trends identified  in the preceding pages, three that stand out are the 
recent increases that have occurred in:  (1) the total  number  of children  in foster care 
in the United  States, (2) the number  and proportion  of them who are infants and 
preschoolers, and (3) the number  and proportion  of these infants and preschoolers 
who have been placed in group homes. 
What accounts for these trends?  To what degree and how might  they be attributable 
to: 
. 	 intensified  social  roblems, such as poverty, homelessness,family  instability,  and 
P
substance abuse; 
.  increased reporting  of child abuse cases;13 
.  higher numbers of foster care kinship placements; 
. 	 more restrictive  funding  for mental health, juvenile justice, and social service 
programs than for Title  IV-E  foster care services; 
. 	 poor  coordination  between mental  health, juvenile justice, and child welfare 
systems; andi 
.  inadequate  or nonexistent standards guiding placement  decisions? 
Questions concerning these and other such factors are of increasing urgency to the 
entire  child welfare  system.  That  sense of urgency is most readily  conveyed by the 
operating  reality  guiding placement  choices in large metropolitan  areas such as New 
York  City and Los Angeles.  In virtually  every interview we conducted with 
caseworkers in those cities, the same scenario was described:  Children  become 
available for placement with  little  notice to the agency.  Workers  then begin searching 
for an available slot.  Placement workers who have never met these children  and who 
typically  have only age, race, and gender information  staff a phone bank to find  bed 
assignments.  Although  there is no formal  policy to that effect, nearly all adolescents 
are placed in group facilities.  Others are placed in the first bed available.  Many must 
be placed in emergency facilities  and/or as nomad children  are subjected to a series 
of one-night  placements. 
To help address the limitations  of the foster care system on a national  basis, it is vital 
that a national  data collection  system be established and that data be widely 
distributed  and carefully  analyzed.  For the more than 300,000 children  in the United 
States who are in foster care, we have no recent and reliable  information  on who they 
are or on the key factors affecting their well-being.  In contrast, for  example, for the 
11  150,000 to 160,000 people in the country who have end-stage renal disease, we can 
.. 	 draw upon timely  and highly credible data offering  considerable details on their 
demographics, health status, and even treatment  outcomes. 
Foster care children  are no less important  than those with  kidney failure.  To develop 
appropriate  policies, we must as a start know more about them.  For more than a 
decade, the Federal Government  has been deliberating  on how to develop a system 
that would  provide  such knowledge.  It is time to act to establish a workable  and 
useful foster care and adoption  data collection  system. 
Toward  that end, we offer  one recommendation  to the Administration  for Children 
and Families  (ACF).  It  is intended  to help the newly established data system be as 
helpful  as possible to policymakers  at different  levels of government. 
7%eACF  shod  specify &Yplans  for  the prqmation  and  regula  ckkbibution  ofpdicy
fe 
relevant  tables  and for  special  analyses concemihg  the data  in  the prvpmed  care 
and  adapt&m  data  coUection  system  It  shoukl  indicate  thesepihs  in  thepmzmble  to the 
regdatiom  to be iwed  concemihg  the systm 
In the February  1990 notice of proposed rulemaking,  ACF  says little  about what it will 
do with  the data once it receives and checks them--only  that it will  produce some 
standard descriptive reports that are routinely  processed and that the data will  be 
available to provide  reports back to the States and to support special analyses. 
This is inadequate for a system that is expected to cost more than $50 million  in the 
first 3 years and to contribute  to more effective policymaking. 
The ACF  should specify the kind  of tables it will  prepare, indicating  how it will 
present information  on demographics, circumstances of removal, type of placement, 
and the like.  It should also provide for frequent  and widespread distribution  and 
indicate the kind  of special analyses of the data it will  undertake.  Such actions, we 
believe, are vital  if the benefits associated with  such a system are to outweigh  the 
costs. 
12 
 COMMENTS  ON  THE  DRAFI  REPORT 
We received comments on the draft  report  from  the Administration  for  Children  and 
Families  (ACF)  and the Assistant Secretary for Planning and Evaluation  (ASPE).  In 
appendix D, we present their  comments in full  and our detailed  response to them. 
The ASPE comments, which were the most extensive, involved three major  concerns. 
The first  of these was directed to our recommendation  that ACF  implement 
immediately  the most essential aspects of the foster care and adoption  data collection 
system.  We made that recommendation  because of our concerns about the many 
complexities  and costs associated with  the comprehensive system envisioned by the 
Department  of Health  and Human  Services. The ASPE opposed any partial 
implementation,  as we suggested, because many of the duplicative  and unnecessary 
data elements initially  proposed by the Department  had been eliminated. 
The ASPEs second major  concern involved our lack of recommendations  addressing 
larger foster care policy issues, such as those addressing alternative  program  models 
and the Federal requirement  that reasonable efforts must be made before  removing 
a child from  a family.  The third  was that the report  should state more strongly and 
regularly  that the numbers presented are estimates. 
The brief  ACF  written  comments supplement  an earlier  discussion we had with  ACF 
staff.  In that discussion, the staff also raised some questions about the necessity and 
practicality  of the first recommendation.  In its written  comments, ACF  indicated  that 
it would  take our second recommendation  under advisement and would  respond to 
the extent possible.  That  recommendation  called for ACF  to specify its plans for  the 
preparation  of policy-relevant  tables and for special analyses concerning data to be 
obtained  under the new system. 
Our major  response to these comments was to eliminate  our first  recommendation 
calling for immediate  implementation  of essential aspects of the foster care adoption 
and data collection  system.  We did that because of our understanding  that ACF  has 
addressed some of our concerns about the complexity  and constraints of the system 
and has removed certain unnecessary and duplicative  data elements proposed earlier. 
We have not addressed larger policy issues because we believe the data obtained  for 
this study do not give us an adequate basis to address them.  Further,  we have not 
added further  emphasis to the limitations  of our numbers because upon review, we 
found those limitations  adequately explained.  We also note that even with  the stated 
limitations,  the trend  data presented in the report  help provide  a clearer picture  of 
recent developments concerning foster care children  in the United  States. 
13 
 APPENDIX  A 
ENDNOli??S 
1. 	 We recognize that there are many other important  questions that might  be 
posed.  Such questions might  address other demographic  characteristics as well 
as factors such as length of stay in foster care and circumstances of removal 
from  home.  We chose the four  areas identified  because they are particularly 
important  and basic ones of much relevance to policymakers  and because we 
expected that we could obtain reasonably complete  information  in these areas. 
2. 	 There  are four  primary  mechanisms for Federal financing  of foster care 
services: 
Title  IV-B:  This provision has been part of the Social Security Act  since 
0 	
1935 and provides funding  for a broad range of preventive and 
protective  services to abused, neglected, and exploited  children.  It  is a 
formula  grant program  that reimburses States 75 percent of qualifying 
foster care expenses up to an allotted  total.  Amended  in  1980, Section 
427 earmarks a portion  of total  appropriations  for States that: 
.  conduct an inventory  of all children  in foster care; 
.  implement  a statewide tracking  system for  children  in care; 
.  implement  a review system with  case review for  each child 
every 6 months and judicial  review within  6 months of 
initial  placement;  and 
.  implement  a service plan to place each child in a permanent 
home. 
The Department  is required  to conduct Section 427 reviews in each 
participating  State to ensure that it meets these requirements.  (Only 
three have opted out of 427 participation:  Massachusetts, Wyoming,  and 
Puerto Rico.) 
Title  IV-E:  (Described in text) 
0 
Title  XX:  Since 1974 this provision has been the major  source of funds 
0 	
for a range of social services including  child daycare, protective  services, 
community  services for people with  disabilities, homemaker  and chore 
services, and services for the elderly.  Title  XX  was amended in  1981 to 
create a block grant for social services. Many States Title  XX  funds are 
expended for some foster care services. 
A -1 
 Indenendent  Living  Program:  Enacted in 1986, the ILP  funds State 
0 	
services that assist AFDC-eligible  children  aged 16 and over to make the 
transition  from  foster care to successful independent  living at age 18. 
No State matching funds are required.  In  1988 the law was amended to 
include non-income-eligible  children  and to permit  extension of services 
to youths for up to 6 months after they are emancipated  from  care. 
Of these four  major  Federal funding sources, three have experienced either 
modest growth  or level funding  in recent years.  From  1985 to  1989, 
Title  IV-B  funding  levels have increased from  $200 million  to $239 million. 
Annual  increases in the Title  XX  Social Services Block  Grant  since 1974 
peaked in 1981 at $2.9 billion.  Although  P.L. 96-272 authorized  annual $100 
million  increases through  1985 to facilitate  the goals of the statute, the SSBG 
was subsequently capped at $2.7 billion.  The ILP  has been reauthorized  each 
year since its enactment and has been level funded at $45 million  each year. 
3. 	 See Committee  on Finance, United  States Senate, Foster Care, Adoption 
Assistance, and Child  Welfare  Services,  Washington, D.C., September  1990, p. 
9. 
4. 	 For a review of past and current  foster care data collection  efforts, see Federal 
Register 55, no. 288 (September 27, 1990):  39541-42. 
5.  See Committee  on Finance, pp. 32-33. 
6. 	 In appendix C, we list the 38 States included in figure  1 and the States included 
in the subsequent figures. 
7. 	 The  1987 case, known  as the Eugene F. Case, required  the State child welfare 
agency to provide  relatives who are not parents the reimbursement  and services 
provided  to other foster parents.  Prior  to that case, children  in custody of the 
State and placed with  relatives were typically  eligible  only for AFDC  payments 
and were not classified as foster children.  The families  are now referred  to as 
kinship  or approved relative  home (ARH)  placements.  Children  in relative 
placements increased from  an average of 520 in 1985 to  15,500 in  1989.  (Data 
compiled  by the New York  State Department  of Social Services and presented 
in working  papers for  a conference held by the Department  and the New York 
Community  Trust  on February  27, 1990 and entitled  The  Changing Face of 
Foster Care in New York  State.) 
8. 	 See Committee  on Finance, pp. 32-33.  The Committee  presents data on 
children  in foster care per  1,000 in the population  dating back to 1962, when it 
reports that 3.9 children  per  1,000 were in foster care. 
9.  See The Changing Face of Foster Care. 
A -2 
 10.  See The  Changing Face of Foster Care. 
11. 	 For the first  nine months of 1989, the New York  Department  of Social Services 
reports that children  under  1 year of age accounted for  8.0 percent of the 
group care caseload and those 5 years or younger accounted for  17.9 percent. 
The comparable  numbers for  1988, as we reported, were 8.6 percent and 29.6 
percent.  See The  Changing Face of Foster Care. 
12. 	 A study of the child welfare  system in New York  City, for instance, found that 
between  1985 and 1989, the number  of children who were admitted  to foster 
care because they lacked food, clothing, or shelter increased by 40 percent.  See 
Report  of the Manhattan  Borough Presidents Advisory  Council  on Child 
Welfare,  Failed  Promises:  Child  Welfare  in New York  Citv:  A Look  at the 
Past. Vision  for the Future, July 1989, pp. 20, 25. 
For relevant recent studies by the Office  of Inspector  General, Office  of 
Evaluation  and Inspections, see Crack Babies, OEI-03-89-01540, June 1990; 
Boarder  Babies, OEI-03-89-01541, June 1990; and Barriers  to Freeing Children 
for Adontion,  OEI-06-89-01640. 
Also relevant is a recent New England Journal of Medicine  article.  In it, the 
authors report  on research that concludes that the use of illegal  drugs is 
common among pregnant women regardless of race and socioeconomic status. 
They address a number  of reasons why newborn children  of poor  and black 
women tend to be tested and reported  to public  health authorities  more 
frequently.  See I. J. Chasnoff, H.J. Landress, and M.E.  Barrett,  The 
Prevalence of Illicit  Drug  or Alcohol  Use During  Pregnancy and Discrepancies 
in Mandatory  Reporting  in Pinellas County, Florida,  New EnPland Journal of 
Medicine  322, No.  17 (April  26, 1990):  1202-06. 
13. 	 The increases in California  and New York  are substantial.  In California,  the 
average number  of monthly  child abuse reports rose from  about  15,000 in 1983 
to about 39,000 in 1990.  Similarly,  in New York,  the total  number  of reports 
filed  in the State grew from  55,937 in 1980 to 122,498 in 1988. 
14. 	 Kinship  placements appear to be much more common for infants and 
preschoolers than for  adolescents.  In New York  City, in 1986, about  10 percent 
of all infant  admissions to foster care were placed with  relatives.  By 1988, that 
figure was about 33 percent.  See The  Changing Face of Foster Care. 
15. 	 In the 1980s, Federal funding  for Title  IV-B  preventive and protective  services 
has risen much more slowly than Title  IV-E  foster care services.  Similarly,  in 
the last half of the 1980s Federal funding  for mental  health and juvenile  justice 
systems has declined in constant dollars while  that for the Titles  IV-B  and E 
funded  child welfare  system has increased, thereby encouraging the shifting  of 
children  from  the former  systems to the latter.  See Select Committee  on 
A -3  Children,  Youth,  and Families, U.S. House of Representatives, No Place to 
Call Home:  Discarded Children  in America,  Washington, D.C.,  1990, 
pp. 65-77. 
16. 	 The reality  of the situation was recently reflected  in a study which found that 
State child welfare  representatives from  74 percent of the States regarded a 
lack of coordination  between the three systems to be a major  problem  in 
delivering  services to families  and children  in need.  See S. Robison, Putting  the 
Pieces Together:  Survev of State Systems for Children  in Crisis,  National 
Conference of State Legislatures, Washington, D.C., July 1990, p. ix. 
Another  study, focusing on the California  child welfare  system, underscored the 
depth of the problem.  It  concluded that tenacious collaboration  alone will  not 
make up for societal underinvestment  in children.  . . .  But without 
collaboration,  more investment would  not be much help.  The system as a 
whole  is so fundamentally  flawed that huge amounts of dollars dumped  in 
wouldnt  do much good.  See Sid Gardner, Failure  by Fragmentation, 
California  Tomorrow  4, no. 4 (Fall  1989):  20. 
17. 	 In our survey, only three States--Idaho, Missouri,  and Texas--reported  that they 
have formally  established standards of practice to guide foster care placement 
decisions.  The Child  Welfare  League of America  has had standards of this 
kind  for years and is now engaged in an effort  to reexamine them. 
A -4 
 . 
I 
APPENDIX  B 
STAItlXf7CAL  METHODOLOGYAND  NOZl!?S 
The data presented in our report  emerge from  our survey of State child welfare 
agencies.  That  survey encompassed each of the States and the District  of Columbia 
(hereafter  referred  to as a State). 
Our survey consisted of two parts.  The first involved a telephone  interview  with  a 
senior State child welfare  official  in each State.  In that interview  we sought to obtain 
a clear understanding  of the States policies, practices, and trends concerning foster 
care placements.  (We conducted interviews with  representatives of all 51 States.) 
The second part  of the survey was conducted by mail.  We sought data involving 
demographic  characteristics, placement status, and admissions and discharges of 
children  in foster care.  We asked for such data for each quarter  for  every year from 
1985 through  1989. 
Our efforts to collect such data ran into the same constraints that have inhibited  the 
development  of a national  foster care and adoption  data collection  system.  From 
State to State, definitions  of terms often varied, and the quarter-by-quarter  data fields 
requested were often not available at all or only for certain periods. 
As a result, we had to make some decisions about which data fields were reliable  and 
complete  enough to use in developing and discussing our findings.  We also had to 
determine  how best to present the data in these fields. 
The data fields chosen concern the numbers of children  in foster care, their  ages 
broken  down by the age categories used in the text, the numbers of children  in group 
care and foster family  care, and their  ages. 
For every year, we asked for the data by quarter.  If a State provided  fourth  quarter 
data for  each of the 5 years surveyed, we used that quarters data for the year-to-year 
comparison.  If  it did not have fourth  quarter  data, we would  use the third  quarter;  if 
it did not have the fourth  or third, we would  use the second; and, finally,  if it did not 
have any of the last three quarters, we would  use the first.  In all cases,for each State, 
we would  use the same quarter  for the year-to-year comparison. 
In presenting the data, we chose to include, for each data field,  only those States for 
which we had year-by-year data for each year from  1985 through  1989.  Even though 
this meant that our universe of reporting  States would  always be less than the 51 
surveyed, and in a few instances substantially less, we determined  that it was the most 
responsible, clear-cut, and consistent way to report  the data.  Thus, in our tables the 
B-l  universe of reporting  States ranges from  a high of 38 to a low of 11.  (In  each case the 
States included  are presented in appendix C.) 
This approach to presenting the data raises the question of whether  the trends we 
identify  for the States included in our tables would  also apply for the States not 
included.  Although  we make no particular  claim in this regard, it would  appear that 
the trends identified  for our reporting  States would  also apply if all 51 States were 
included in our data bases. 
Beginning with  the universe of 51 States, 1 (Arizona)  failed  to provide  any caseload 
information  and 12 were unable to provide caseload information  for all 5 years. 
Additionally,  of the 38 remaining  States, 5 were unable to provide  a breakdown  of 
caseload between group homes and foster family  placements.  Among  the 5, the only 
Top  Eleven State was Florida. 
We are confident  that our findings are representative of the foster care caseload 
because the 12 States we excluded due to incomplete  data (1) had smaller caseloads 
than any of the Top  Eleven States, and (2) showed trends in their  incomplete 
information  that paralleled  those of our findings.  In fact, for  1987 through  1989, 
where we had complete  information  for 48 States, the percentage changes in caseload 
from  year-to-year were equivalent to that of the 38 included States.  Similarly,  the 
excluded States in the group home versus foster family  placement  analysis exhibited 
parallel  trends to those included in our findings. 
The wider  applicability  of the age-related findings is less certain since these are based 
on only  15 States that provided  complete age breakdown  for the 5 years.  Five 
of the Top  Eleven States are included in this analysis.  Only 21 States provided  any 
age breakdown  of their  foster care caseload.  The six States that were excluded 
showed trends in their  caseloads (higher proportions  of preschoolers, smaller 
proportions  of older children)  that were similar  to those in the 15 States providing 
complete  data. 
B-2 
 APPENDIX  C 

TABLES  DERIVED  FROM  OIG  SURK??Y OF  CHD  WELJMRE  AGENCIES 

I.  FOSTER CARE PLACEMENTS 
1985  1986  1987  1988  1989 
38  STATES  228,155  233,427  244,584  266,045  304,431 
CALIFORNIA  & NEW YORK  68,755  73,004  79,964  92,886  118,661 
TOP ELEVEN  152,176  155,859  166,458  185,009  218,083 
OTHER STATES  (N=27)  75,979  77,568  78,126  81,036  86,348 
A.  GROUP HOME PLACEMENTS 
33  STATES  44,226  44,579  44,561  48,527  51,189 
CALIFORNIA  &I NEW YORK  16,264  16,426  16,171  18,734  20,249 
TOP ELEVEN  (N=lO)  29,633  29,483  29,383  32,998  34,701 
OTHER STATES  (N=23)  14,593  15,096  15,178  15,529  16,488 
B.  FOSTER FAMILY  PLACEMENTS 
33  STATES  163,584 168,556  179,601  196,088  228,998 
CALIFORNIA  & NEW YORK  52,491  56,578  63,793  74,152  98,412 
TOP ELEVEN  (N=lO)  115,624  119,467  129,779  144,131  173,546 
OTHER STATES  (N=23)  47,960  49,089  49,822  51,957  55,452 
II.  FOSTER CARE PLACEMENTS PER  1,000  CHILDREN  AGE  18  AND UNDER 
1985  1986  1987  1988  1989 
38  STATES  3.85  3.92  4.09  4.43  5.04 
CALIFORNIA  61 NEW YORK  5.74  6.02  6.49  7.41  9.32 
TOP ELEVEN  4.60  4.69  4.97  5.48  6.39 
OTHER STATES  (N=27)  2.90  2.95.  2.97  3.08  3.29 
A.  GROUP HOME PLACEMENTS PER  1,000  CHILDREN  AGE  18  AND UNDER 
33  STATES  0.84  0.84  0.84  0.91  0.95 
CALIFORNIA  & NEW YORK  1.36  1.35  1.31  1.50  1.59 
TOP ELEVEN  (N=lO)  0.98  0.97  0.96  1.07  1.12 
OTHER STATES  (N=23)  0.65  0.67  0.67  0.68  0.73 
B.  FOSTER FAMILY  PLACEMENTS PER  1,000  CHILDREN  AGE  18  AND UNDER 
33  STATES  3.09  3.18  3.37  3.66  4.26 
CALIFORNIA  &I NEW YORK  4.38  4.66  5.18  5.92  7.73 
TOP ELEVEN  (N=lO)  3.81  3.92  4.24  4.68  5.59 
OTHER STATES  (N=23)  2.13  2.17  2.20  2.29  2.45 
C-l  III.  FOSTER CARE PLACEMENT PER  1,000  CHILDREN  AGE  18  AND UNDER,  BY  AGE 
1985  1986  1987  1988  1989 
15  STATES 
INFANTS  <  1  2.57  2.90  3.41  4.32  6.05 
l-4  YEARS  3.85  4.23  4.84  5.73  7.40 
5-9  YEARS  3.65  3.91  4.34  4.92  6.02 
lo-14  YEARS  4.44  4.65  4.91  5.34  6.07 
15-18  YEARS  6.42  6.43  6.32  6.54  7.00 
CA AND NY 
INFANTS  <  1  3.38  4.00  4.72  6.48  9.67 
l-4  YEARS  4.80  5.43  6.37  7.82  10.88 
5-9  YEARS  4.97  5.32  5.94  6.82  8.79 
lo-14  YEARS  5.77  6.07  6.55  7.40  8.85 
15-18  YEARS  8.13  7.90  7.70  8.02  8.58 
A.  GROUP HOME PLACEMENT PER  1,000  CHILDREN  AGES  18  AND UNDER,  BY  AGE 
1985  1986  1987  1988  1989 
11  STATES 
INFANTS  <  1  0.09  0.11  0.08  0.14  0.22 
l-4  YEARS  0.09  0.11  0.09  0.14  0.20 
5-9  YEARS  0.25  0.27  0.27  0.30  0.36 
lo-14  YEARS  1.17  1.19  1.26  1.35  1.42 
15-18  YEARS  2.46  2.55  2.51  2.72  2.85 
B.  FOSTER FAMILY  PLACEMENT PER  1,000  CHILDREN  AGES  18  AND UNDER,  BY  AGE 
1985  1986  1987  1988  1989 
11  STATES 
INFANTS  <  1  2.47  2.94  3.62  4.13  5.21 
l-4.  YEARS  3.86  4.30  5.06  5.80  6.83 
5-9  YEARS  3.55  3.90  4.39  4.88  5.54 
lo-14  YEARS  3.43  3.70  3.94  4.25  4.69 
15-18  YEARS  3.87  3.89  3.94  4.07  4.36 
c-2  IV.  STATES  INCLUDED  IN  TABLES 
A.  38  STATES  WITH  COMPLETE DATA ON TOTAL  PLACEMENTS 

ALABAMA  MASSACHUSETTS 
 OKLAHOMA 

ARKANSAS  MAINE 
 OREGON 

CALIFORNIA  MICHIGAN 
 PENNSYLVANIA 

COLORADO  MINNESOTA 
 SOUTH DAKOTA 

CONNECTICUT  MISSOURI 
 TENNESSEE 

FLORIDA  MISSISSIPPI 
 TEXAS 

GEORGIA  NORTH DAKOTA 
 UTAH 

HAWAII  NEBRASKA  VIRGINIA 

ILLINOIS  NEW JERSEY  VERMONT 

INDIANA  NEW MEXICO  WASHINGTON 

KANSAS  NEVADA  WISCONSIN 

KENTUCKY  NEW YORK  WEST VIRGINIA 

LOUISIANA  OHIO 
B.  THE  TOP  ELEVEN 
CALIFORNIA  NEW JERSEY 
FLORIDA  NEW YORK 
GEORGIA  OHIO 
ILLINOIS  PENNSYLVANIA 
MASSACHUSETTS  WASHINGTON 
MICHIGAN 
C.  33  STATES  WITH  COMPLETE DATA  FOR GROUP HOME AND FOSTER 
FAMILY  PLACEMENTS 

ALABAMA 
 MAINE 
 SOUTH DAKOTA 

ARKANSAS 
 MICHIGAN 
 TENNESSEE 

CALIFORNIA 
 MISSOURI 
 TEXAS 

COLORADO 
 MISSISSIPPI 
 UTAH 

CONNECTICUT 
 NORTH DAKOTA 
 VIRGINIA 

GEORGIA 
 NEW JERSEY 
 VERMONT 

HAWAII 
 NEW MEXICO 
 WASHINGTON 

ILLINOIS 
 NEVADA 
 WISCONSIN 

INDIANA 
 NEW YORK 
 WEST VIRGINIA 

KANSAS 
 OHIO 

LOUISIANA 
 OREGON 

MASSACHUSETTS 
 PENNSYLVANIA 

D.  15  STATES  WITH  COMPLETE AGE DATA 
ON PLACEMENTS PER  1,000
CHILDREN  AGED 18  AND UNDER,  BY  AGE 

CALIFORNIA  INDIANA  OHIO 
COLORADO  MISSOURI  OKLAHOMA 
FLORIDA  NEBRASKA  OREGON 
HAWAII  NEW MEXICO  VERMONT 
ILLINOIS  NEW YORK  WISCONSIN 
c-3  E.  11  STATES  WITH  COMPLETE AGE DATA  FOR GROUP HOME AND FOSTER 

FAMILY  PLACEMENTS PER  1,000  CHILDREN  AGED 18  AND UNDER, 

BY  AGE 
CALIFORNIA  NEW MEXICO 
COLORADO  OHIO 
HAWAII  OREGON 
ILLINOIS  VERMONT 
INDIANA  WISCONSIN 
MISSOURI 
c-4  APPENDIX  D 
DETAILED  COMMENl3  ON  THE  DRAPTREPORTAND 
OIG  RESPONSE  TO  THE  COMMENTS 
In  this  appendix,  we  present  in  full  the  comments  on  the  draft 
report  offered  by  the  Administration  for  Children  and  Families 
and  the  Assistant  Secretary  for  Planning  and  Evaluation.  In 
each  case,  we  also  include  our  brief  response  to  the  comments. 
D-l  L 
l *- -t
.* 
ADMINISTRATION  FOR  CitlLDREN  AND  FAMILIES 
Office  of the  Ak%tanP;Sedr~tfq,  suite  600 
October  8,  1991  370  LEnfant  Promenp&, 
Washington,  D.C.  204Hm 
TO: 	 Richard  P.  Kusserow 
Inspector  General 
FROM: 	 Jo  Anne  B.  Barnhart 
Assistant  Secretary
for  Children  and  Fa  ilies 
P 
-
SUBJECT: 	 Comments  on  OIG  Draft  Report:  "Trends  in  Foster  Care," 
OEI-01-90-00490 
We have  reviewed-the  draft  of  the  Office  of  Inspector  General 
report  entitled  "Trends  in  Foster  Care."  We believe  that  the 
study  provides  reliable  information  on  current  trends  in  foster 
care.  It  agrees  with  other  information  available  to  us  which 
indicates  that  the  use  of  foster  family  care  and  group  care  has 
been  increasing.  Members  of  my  staff  have  previously  provided 
At  this 
oral  comments  on  the  draft  in  a  meeting  with  the  OIG. 
time,  we  have  an  additional  comment  on  one  recommendation. 
GIG  Recommendation 
The  ACF  should  specify  its  plans  for  the  preparation  and  regular
distribution  of  policy-relevant  tables  and  for  special  analyses
concerning  the  [foster  care  and  adoption]  data  collection  system.
It  should  indicate  these  plans  in  the  preamble  to  the  regulations 
. 
to  be  issued  concerning  the  system. 
&CF  Comment 
. 
The  development  of  a  national  foster  care  and  adoption  data 
system  is  currently  under  way.  We anticipate  that  it  will 
provide  the  information  which  is  needed  for  improved  policy  and 
program  planning.  Concerning  the  description  and  distribution 
plan  for  policy-relevant  tables,  we  will  take  this  recommendation 
under  advisement  and,  to  the  extent  possible,  include  a 
description  of  them  in  the  preamble. 
Technical  Comment 
On  page  12,  para  4,  the  word  "adaption"  should  be  changed  to 
ltadoption.tl 
Thank  you  for  the  opportunity  to  comment  on  the  draft  report.  If 
I  may  be  of  further  assistance,  please  do  not  hesitate  to  contact 
me. 
D-2 
 OIG  RESPONSE  TO ACF  coMMEN?s 
In accord with  the oral comments of ACF  staff, the comments of ASPE, and actions 
recently take by ACF,  we have eliminated  the first recommendation  presented in our 
draft  report.  That  recommendation  called for ACF  to implement  immediately  the 
most essential aspects of the foster care and adoption  data collection  system. 
We made that recommendation  because of our concerns about the complexity  and 
scope of the system proposed by the Department  of Health  and Human  Services in 
the September  1990 proposed notice of rulemaking.  As we indicated  on page 12 of 
the draft  report,  the proposed system involved imposing  constraints that could delay 
and undermine  the establishment of the comprehensive system set forth.  We 
concluded at that point  that the comprehensive system should remain  as a goal, but 
that ACF  could best get the process started by identifying  the most essential data 
elements and requiring  States at the outset to submit data only on them. 
We retracted  the recommendation  because we understand that ACF  already has 
moved in the direction  noted above, by removing duplicative  and unnecessary data 
elements and providing  for more flexibility  on various matters.  We still urge ACF 
sensitivity to the implementation  difficulties  many States will  face, but because of the 
changes it has made, concur with  ACF  and ASPE, which in its response says we must 
press ahead and finish the job we set out to do as quickly  as possible. 
D-3 
 DEPARTMENTOF HEAITH  8. HUMAN SERVICES  fifficegf  the  Secretary 
- -
~--
Warhintxon.  D.C.  20201 
SEP  I3  1991 
TO: 	 Richard  P.  Kusserow 
Inspector  General 
FROM: 	 Assistant  Secretary  for 
Planning  and  Evaluation 
SUBJECT: 	 Review  and  Comment  on  OIG  Draft  Report:  "Trends  in 
Foster  Care,"  OEI-3$-90-00490--CONDITIONAL  CONCURRENCE 
I  concur  with  the  above  report  sent  for  my  review  provided  that 
the  comments  contained  in  this  memorandum  are  addressed. 
Following  are  three  major  concerns,  as  well  as  a  number  of  other 
comments  and  some  suggested  editorial  changes. 
Baior  Concerns: 
First,  I  appreciate  the  Inspector  General's  efforts  to  provide 
new  information  in  an  area  that  is  especially  lacking  in  quality,
reliable  data.  You  summarize  this  point  well  in  the  following 
statement: 
IFor  the  more  than  300,000  children  in  foster  care,  we  have 
no  reliable  information  on  who  they are  or  on  the  key 
factors  affecting  their  well-being. In  contrast,  for 
example,  for  the  150,000  to  160,000  people  in  the  country 
who  have  end-stage  renal  disease  ,,we can  draw  upon  timely
and  highly  credible  details  on  their  demographics,  health 
status,  and  even  treatment  outcomes.t8 
I  strongly  concur  with  your  recommendation  that  ACF  move  quickly
to  implement  the  Adoption  and  Foster  Care  Data  Collection  System
(AFCARS)  to  help  fill  this  void.  However,  I  also  think  it  is 
important  to  implement  the  system  in  its  entirety.  My  office  has
been  directly  involved  with  ACF  in  the  final  design  of  the 
AFCARS.  Based  on  the  comments  received  in  response  to  the  Notice 
of  Proposed  Rulemaking  (NPRM),  many  duplicative  and  unnecessary
data  elements  have  now  been  eliminated.  It  is  important  to 
realize  that  states  have  repeatedly  informed  the  Department  that 
if  we  require  that  they  implement  a  data  collection  system,  it 
should  not  be  one  that  changes  from  year-to-year.  Therefore,  I  do 
not  agree  with  your  recommendation  that  the  essential  AFCARS data 
elements  be  implemented  immediately  and  that  the  system  then  be 
expanded  in  subsequent  years.  Admittedly,  the  AFCARS  development
has  been  too  slow,  but  we  are  at  an  end  stage  now  where  we  must 
press  ahead  and  finish  the  job  we  set  out  to  do  as  quickly  as 
possible. 
D-4 
 . 
Page  2. --Richard  P.  Kusserow 
Second,  while  I  appreciate  the  draft  report's  focus  on  the  need 
to  develop  our  data  capabilities  in  this  area,  I  am  concerned 
that  this  is  the  sole  recommendation  to  come  from  your  analysis.
In  particular,  aside  from  providing  more  accurate  information  on 
the  subject,  I  am perplexed  how  the  AFCARS will  really  inform  us 
of  ways  to  address  the  trends  specified  in  the  report: 
a  general  increase  in  the  foster  care  caseload; 
0 
a  rapidly  growing  proportion  of  infants  and  pre-schodlers  in 
0 	
the  foster  care  caseload; 
0 	 an  increase  in  the  number  and  proportion  of  these  infants 
and  pre-schoolers  who  are  placed  in  group  homes. 
Although  we  may  not  know  their  exact  magnitude,  I  think  that  it 
is  obvious  that  these  trends  are  taking  place.  I  also  think  that 
we  cannot  wait  for  more  exact  data  to  begin  addressing  these 
trends.  One  strategy  we  can  pursue  immediately  is  to  test 
alternative  program  models  on  a  demonstration  basis  and  evaluate 
their  effectiveness.  My  office  is  involved  with  several  exciting
projects  designed  to  develop  the  research  capabilities  of  the 
child  welfare  services  area  in  preparation  for  the  evaluation  of 
demonstration  programs. 
Another  area  in  which  we  could  act  now  would  be  to  embark  on  an 
effort  to  provide  states  additional  guidance  on  placement
practices.  Specifically,  I  am  referring  to  the  Veasonable 
efforts"  provision  of  P.L.  96-272  which  specifies  that  before 
children  are  placed  in  foster  care,  18reasonable  efforts"  must  be 
made  to  avoid  removing  the  child  from  the  family.  This  provision
also  mandates  that  once  children  are  in  foster  care,  reasonable 
efforts  must  be  made  to  reunify  the  child  with  his  or  her  family
thereby  avoiding  the  termination  of  parental  rights.  While 
safeguards  of  this  type  are  necessary,  there  is  much  evidence 
that  many  agencies  are  over-interpreting  these  requirements  due 
to  a  number  of  reasons  including:  fear  of  adverse  legal  action,
limited  availability  of  caseworker  time  and  agency  resources, 
bureaucratic  inertia,  poorly  coordinated  social  service  systems,
and/or  poorly  administered  practices.  Many  of  these  problems 
were  elaborated  in  the  recent  OIG  report  "Barriers  to  Freeing
Children  for  Adoption.ll 
The  results  of  misinterpreting  reasonable  efforts  can  be 
devastating  to  a  child.  For  instance,  an  abandoned  infant  can 
sit  for  months  or  even  years  in  a  hospital  or  group  home  before 
being  placed  in  a  foster  family  or  adoptive  home,  or  a  small 
foster  child  can  age  into  adolescence  before  becoming  eligible
for  adoption. 
The  Department  needs  to  define  reasonable  efforts  in  its 
re\g ulations  to  provide  more  meaningful  guidance  to  states.  This
D-5 
 . 
Page  3. --Richard  P.  Kusserow 

issue  has  become  more  complicated  because  of  the  large  rise  in 

infant  placements  that  took  place  in  the  late-1980's.  Many  of 

the  trends  found  in  your  analysis  could  be  addressed  by  providing 

states  guidelines.  In-fact,  your  report  briefly  alludes  to  this 

fact  in  the  final  bullet  on  page  11.  Therefore,  I  suggest  that 

you  consider  recommending  a  process  by  which  the  Department  could 

begin  to  .define  meaningful  guidelines  for  reasonable  efforts. 

Third,  I  feel  it  is  important  that  throughout  the  report  a  number 

of  caveats  be  included  stating  that  the  numbers  presented  are 

eaimates.  It  is  important  not  to  provide  readers  with  a  false 

sense  of  security  that  there  is  not  a  lack  of  reliable  data  in 

this  area. 

Qther  Comments: 

On  pages  ii  and  seven,  the  draft  report  notes  that  the  proportion

of  very  young  children  in  the  foster  care  caseload  increased 

while  the  proportion  of  adolescents  decreased.  This  statement 

could  be  slightly  misleading  to  the  casual  reader.  Our  data  from 

New  York,  Illinois,  and  California  show  that  the  number  of  foster 

care  entrants  in  both  groups  has  increased,  although  infant  and 

pre-school  entrants  have  increased  much  more  than  adolescent 

entrants.  The  report  should  make  the  distinction  between 

increases  in  proportions  and  absolute  numbers,.more  clear. 

At  the  top  of  page  2  the  draft  report  states  that  P.L.  96-272 

sought  to  do  two  things.  I  agree  with  the  second  goal

(encouraging  case  management  and  permanency  planning)  but  I'm 

uncomfortable  with  the  first.  It  is  unclear  to  me  what 

"extensive1t  services  were  made  available  to  children  at  risk  in 

an  effort  to  reduce  foster  care  placement.  P.L.  96-272  did 

specify  that  each  state  implement  a  foster  care  prevention 

program  in  order  to  receive  certain  federal  incentive  funds,  but 

it  did  not  specify  the  parameters  of  these  programs  or  the 

proportion  of  children  that  should  be  served  in  each  state.  P.L. 

96-272  did  change  the  state  reimbursement  mechanism  for  foster 

children  from  AFDC  families  to  an  entitlement,  but  it  did  not 

make  entitlement  money  available  to  states  for  child  welfare 

services. 

The  fourth  and  fifth  paragraphs  on  the  same  page  refer  to  press 

accounts  of  group  homes  which  characterize  them  as  "large

orphanage-type  facilities  where...  children  are  said  to  be 

'warehoused'."  All  of  the  press  accounts  that  I  have  read  talk 

about  the  "newtt  group  home  as  being  very  different  than  the  old 

orphanages.  In  fact,  many  are  characterized  as  better  than  many

available  foster  family  homes.  While  there  is  a  widespread  fear 

that  group  home  placements  may  be  abused,  I  haven't  read  any 

press  accounts  that  report  such  abuse  is  currently  taking  place. 

D-6 
 . 
I 
page  4. --Richard  P.  Kusserow 

On  page  four,  the  second  paragraph  notes  that  it  is  possible  that 

in  the  mid-1980's  the  foster  care  population  was  considerably

less  than  it  was  in  the  late  1970's.  In  fact,  the  data  you  are 
referring  to  (a  sample  survey  conducted  in  1977)  is  highly
suspect  and  not  comparable  with  later  caseload  counts.  In  any 
case,  the  Senate  Finance  Committee  publication  you  list  as  a 
footnote  .for  this  assertion  does  not  report  foster  care  caseload 
data.from  1972  to  1979.  During  this  time  period  the  title  IV-E 
caseload  dropped slightly. In  sum,  there  is  no  evidence  that  a 
large  drop  in  the  entire  caseload  took  place. 
On  page  nine,  I  am  concerned  that  one  of  your  findings  may  be  a 
statistical  artifact  (the  report notes  that  from  1985  to  1989  the 
proportion  of  foster  children  in  group  homes  declined  slightly).
In  particular,  the  proportion  of  foster  care  adolescents,  who  are 
over-represented  in  group  homes,  has  been  falling  in  relation  to 
other  foster  care  sub-populations. I  realize  that  you  make 
several  subsequent  observations  that  support  your  initial 
finding,  but  I  believe  that  each  of  these  may  be  drawn  from 
different  samples  of  states.  In  summary,  there  is  a  lot  going  on 
here  and,  in  the  absence  of  better  data,  we  have  every  reason  to 
believe  that  the  group  home  population  is  increasing,  not 
decreasing. 
Suaaested  Editorial  Chanaes: 
In  addition,  I  suggest  making  the  following  editorial  additions 
that  appear  in  bold  type: 
a  (page  L  final  bullet,  and  page  five  second  bullet):  "...a 
rise  in  caseload  admissions  in  relation  to  discharges  has 
propelled  the  growth." 
0  (page  ii,  second  bullet):  'I...  the  small  proportion  of  very 
young  children  in  the  foster  care  caseload  increased  at  an 
especially  sharp  rate." 
0 	 (page  two,  second  paragraph,  last  sentence):  "...it 
authorized  adoption  assistance  payments  for  'special  needs' 
children,  children  who  originate  from  families  eligible  for
AFDC who  are  physically  or  emotionally  disabled, 
adolescents,  or  members  of  a  sibling  or  ethnic  minority 
group.1t 
i 
D-7 
 . 
. 
Page  5. --Richard  P.  Kusserow 
0 	 (page  7,  first  paragraph  of  text):  "...two  actually  had 
small  decreases.  In  Massachusetts,  the  placement  rate  per
1,000  children  declined  from  6.83  in  1985  to  6.59  in  1989; 
in  New  Jersey';  from  4.51  to  4.29." 
For  more  information  please  contact  Jane  Baird  at  (202)  245-2409. 
Martin  H.  G&y 
D-8 
 OIG  RESPONSE  TO ASPE COMMENTS 
As we explain in our response to ACFs comments, we concur with  ASPE and have 
dropped  the recommendation  calling for immediate  implementation  of the most 
essential aspects of the foster care and adoption  data collection  system.  We have also 
made numerous other minor  changes in response to ASPEs other comments and 
suggested editorial  changes. 
In regard to ASPEs second major  point  concerning the absence of recommendations 
in the report  on the larger policy issues concerning foster care, our response is that 
the underlying  data generated by the study do not provide an adequate basis to make 
those recommendations.  We do not wish to imply,  however, that policy decisions must 
be delayed pending the implementation  of the foster care and adoption  data collection 
system or that such a system in itself will  provide the basis for determining  the most 
appropriate  policies.  We do expect, however, that such a system will  be developed in 
a manner that will  be of as much policy relevance as possible. 
Concerning ASPEs second major  point  on presenting caveats that our numbers are 
estimates, we have reviewed our explanation  and use of the numbers and conclude 
that they are presented in a clear manner that is not likely  to provide readers with  a 
false sense of security that there is not a lack of reliable  data in this area.  Indeed, we 
make that very point  quite strongly. 
Finally,  ASPE suggeststhat our data indicating  that the proportion  of very young 
children  in the foster care caseload increased while  the proportion  of adolescents 
decreased could be misleading to the casual reader.  It suggested that we make the 
differences between increases in proportions  and absolute numbers clear.  It  cited 
New York,  Illinois,  and California  data showing that the absolute number  of foster 
care children  in both groups increased, even though the infant  and preschooler group 
increased at a greater rate. 
Yet,  our data indicate that for  15 reporting  States for the 1985 to 1989 period,  the 
absolute number  of 15  to-18 year-olds in the foster care caseload rose only slightly, 
from  40,982 to 42,489, while  the number of infants and preschoolers rose significantly-
from  28,835 to 60,616. 
D-9