Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JANET REHNQUIST 

Inspector General 

MARCH 2003 

OEI-07-01-00660 

Adoption and Foster Care Analysis 

and Reporting System (AFCARS): 

Challenges and Limitations 
OFFICE OF INSPECTOR GENERAL

http://www.oig.hhs.gov/ 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as amended 

by Public Law 100-504, is to protect the integrity of the Department of Health and Human Services 

(HHS) programs, as well as the health and welfare of beneficiaries served by those programs. This 

statutory mission is carried out through a nationwide network of audits, investigations, and inspections 

conducted by the following operating components: 

Office of Audit Services 

The OIG's Office of Audit Services (OAS) provides all auditing services for HHS, either by conducting 

audits with its own audit resources or by overseeing audit work done by others. Audits examine the 

performance of HHS programs and/or its grantees and contractors in carrying out their respective 

responsibilities and are intended to provide independent assessments of HHS programs and operations in 

order to reduce waste, abuse, and mismanagement and to promote economy and efficiency throughout the 

Department. 

Office of Evaluation and Inspections 

The OIG's Office of Evaluation and Inspections (OEI) conducts short-term management and program 

evaluations (called inspections) that focus on issues of concern to the Department, the Congress, and the 

public. The findings and recommendations contained in the inspections reports generate rapid, accurate, 

and up-to-date information on the efficiency, vulnerability, and effectiveness of departmental programs. 

Office of Investigations 

The OIG's Office of Investigations (OI) conducts criminal, civil, and administrative investigations of 

allegations of wrongdoing in HHS programs or to HHS beneficiaries and of unjust enrichment by 

providers. The investigative efforts of OI lead to criminal convictions, administrative sanctions, or civil 

monetary penalties. The OI also oversees State Medicaid fraud control units which investigate and 

prosecute fraud and patient abuse in the Medicaid program. 

Office of Counsel to the Inspector General 

The Office of Counsel to the Inspector General (OCIG) provides general legal services to OIG, rendering 

advice and opinions on HHS programs and operations and providing all legal support in OIG’s internal 

operations. The OCIG imposes program exclusions and civil monetary penalties on health care providers 

and litigates those actions within the Department. The OCIG also represents OIG in the global settlement 

of cases arising under the Civil False Claims Act, develops and monitors corporate integrity agreements, 

develops model compliance plans, renders advisory opinions on OIG sanctions to the health care 

community, and issues fraud alerts and other industry guidance. 
EXECUTIVE SUMMARY 

OBJECTIVE 

To identify the challenges and limitations associated with reporting Adoption and Foster Care 

Analysis and Reporting System (AFCARS) information. 

BACKGROUND 

Foster care and adoption information reported to the Administration for Children and Families 

(ACF) through AFCARS is the only federal national data available regarding the children in 

foster care and the children adopted under the auspices of a state agency. All states are 

required to report child-specific information to ACF semiannually through AFCARS. Based 

on the most recent AFCARS data available, there were an estimated 565,000 children in foster 

care on September 30, 2001, and 51,000 children adopted during fiscal year 2000. 

It is important that information reported through AFCARS is timely and accurate. The 

AFCARS provides ACF with data necessary to comply with congressionally-mandated 

reporting requirements, to measure the performance of state child welfare agencies, and to 

allocate incentive and formula grant funds (i.e., adoption incentive funds and Chaffee Foster 

Care Independence Program funds, respectively). The ACF, Congress, state child welfare 

agencies, and national child welfare organizations also use AFCARS data to make national 

policy and program decisions. Federal requirements placed on states to report AFCARS data 

have served to enhance national child welfare data collection. 

In conducting this inspection, we systematically collected information from foster care and 

adoption program managers and information systems staff from the 50 states, the District of 

Columbia, and Puerto Rico. We also held in-depth discussions with child welfare managers 

and staff, and reviewed state processes and procedures for collecting AFCARS information in 

five states. 

FINDINGS 

The ACF has Failed to Meet Mandated Time Frames for Submitting Annual 

Reports to Congress 

The ACF has not met the mandated deadlines for submission of annual reports to Congress. 

The first annual report, due May 1999, was published in August 2000, 15 months late. The 

second annual report, due May 2000, was published in January 2002, 19 months late. At the 

time of our review, the third and fourth annual reports had not been published and were 

overdue. Published data do not reflect states’ 

AFCARS: Challenges and Limitations i OEI-07-01-00660 
recent efforts to promote permanency or changes in the status of foster care and adoption. 

Published information is also inconsistent and incomplete. 

States Reported That Key AFCARS Data Elements Are Not Clearly and 

Consistently Defined, Resulting in Inconsistent Reporting 

Our analysis of ACF guidance on reporting AFCARS data supports states’ beliefs that the lack 

of clear definitions leads to inconsistent reporting. States believed AFCARS data elements 

were not clearly and consistently defined and expressed concerns about foster care placement 

definitions, which potentially affect child welfare performance measures. In addition, 

differences in states’ methods of reporting dates of discharge and juvenile justice populations 

may further inhibit uniform performance measures. 

Technical Assistance Is Effective, but Difficult to Access 

The ACF has developed technical assistance to address many of the difficulties associated with 

AFCARS reporting. Overall, states rated the technical assistance they received highly. 

However, states reported that attending national sessions is difficult, due to state travel 

restrictions and limited state budgets. 

Mandated Penalties Were an Incentive to Report AFCARS Data, but Were Not 

Commensurate with Non-Compliance 

Even though federally-mandated penalties, designed to ensure reliable and consistent AFCARS 

reporting, have been withdrawn, states reported that the penalties served as an incentive for 

accurate reporting. However, only 15 percent of state respondents believed the penalties, as 

defined, were commensurate with non-compliance. 

CONCLUSION and RECOMMENDATIONS 

Annual reports to Congress are not published timely. As such, published data do not reflect 

recent changes in child welfare populations. Also, states are reporting incomplete and 

inconsistent data. These data are used in developing national standards by which states are 

evaluated. Technical assistance designed to address the difficulties associated with the 

collection and reporting of AFCARS information, while highly rated, is difficult to access. 

Furthermore, the penalties that served as an incentive for accurate reporting have been 

withdrawn. 

As such, we make the following recommendations to ACF to enhance the usefulness of 

AFCARS data. 

• Make up-to-date child welfare statistics reported through AFCARS available to 

program officials and other decision-makers by publishing annual reports within 

congressionally-mandated time frames and posting current information on the Internet, 

issue precise definitions for data elements to prevent states from 

AFCARS: Challenges and Limitations ii OEI-07-01-00660 
interpreting them differently, and issue a definitive policy statement to address 

inconsistencies in state AFCARS reporting of juvenile justice populations. 

• Increase the accessibility of technical assistance resources through the development of 

regional data conferences, utilization and training of regional office staff to provide 

increased support to states, posting more current and comprehensive AFCARS 

information on the ACF website, and exploring ways to expedite discretionary 

AFCARS reviews. 

• Develop incentives to help ensure state compliance with AFCARS regulations by 

documenting states’ past compliance with AFCARS requirements to establish a 

baseline for reporting, monitor future AFCARS reporting, and develop incentives or 

new penalties, commensurate with varying levels of compliance. 

Agency Comments 

The ACF supports our recommendations and indicates that it is assessing internal agency 

processes for analyzing data and meeting required reporting time frames. The ACF referenced 

recently issued policy guidance regarding trial home visits and indicated that it will consider 

issuing clarifying guidance to alleviate inconsistent reporting of foster children included in 

juvenile justice populations. The ACF also stated that it will support ACF regional meetings 

focused on data-related issues, provide training to and utilize regional office staff in providing 

technical support to states, and explore ways to expedite AFCARS assessment reviews. The 

ACF will monitor and document compliance with AFCARS standards and seek ways to 

encourage timely and accurate reporting of AFCARS data. The full text of the comments 

provided by ACF is contained in Appendix C of the report. 

AFCARS: Challenges and Limitations iii OEI-07-01-00660 
TABLE OF CONTENTS 

PAGE

EXECUTIVE SUMMARY ...................................................... i

INTRODUCTION ............................................................. 1

FINDINGS 

The ACF has Failed to Meet Mandated Time Frames for Submitting Annual Reports to

Congress ................................................................ 4

States Reported That Key AFCARS Data Elements Are Not Clearly and Consistently Defined,

Resulting in Inconsistent Reporting ............................................. 7

Technical Assistance Is Effective, but Difficult to Access ............................ 9

Mandated Penalties Were an Incentive to Report AFCARS Data, but 

Were Not Commensurate with Non-compliance .................................. 10

CONCLUSION AND RECOMMENDATIONS ................................... 12

APPENDICES 

A: History of Foster Care and Early Data Collection Efforts ......................... 14

B: Statewide Automated Child Welfare Information Systems ......................... 16

C. Agency Comments ..................................................... 17

ACKNOWLEDGMENTS ..................................................... 22
INTRODUCTION 

PURPOSE 

To identify the challenges and limitations associated with reporting Adoption and Foster Care 

Analysis and Reporting System (AFCARS) information. 

BACKGROUND 

State child welfare agencies are responsible for protecting children from abuse and neglect,

which sometimes requires that children be removed from their homes and placed in foster care. 

These children remain in foster care until they can be reunited with their families, placed with a

guardian, adopted, or emancipated. Based on the most recent published national data available,1

there were an estimated 565,000 children in foster care on September 30, 2001, and state child

welfare agencies were involved in the adoption of 51,000 children in federal fiscal year (FY)

2000.

Federal regulations require all states to report child-specific foster care and adoption data to

ACF through AFCARS. The final rule, published in the Federal Register on

December 22, 1993, requires states to collect and report specific information (66 data elements)

about all children in foster care for whom the state has responsibility for placement, care, or

supervision. The regulations also require information (37 data elements) about each child under

state jurisdiction who was adopted or for whom the state agency is providing adoption

assistance.2

The first state submission of AFCARS data was due to ACF by May 15, 1995, and

semiannually thereafter. Regulatory compliance is based on the timely submission of the data

files, the timeliness of data entry for the date of removal and the date of discharge (these dates

must be entered within 60 days of occurrence), and whether the data meet a 90 percent level of

tolerance for missing data and internal consistency checks.3 Federal regulations indicate that

states failing to meet these reporting criteria may be subject to financial penalties.4

1 Adoption and Foster Care Analysis Reporting System data for period ending September 30, 2001. 

2

 45 CFR § 1355. 

3

 45 CFR § 1355, Appendix E. 

4

 45 CFR § 1355.40(e)(1). 

AFCARS: Challenges and Limitations 1 OEI-07-01-00660 
The ACF’s administrative uses for AFCARS data include developing outcome measures to

assess state child welfare agency performance,5 determining Chafee Foster Care Independence

Program allotments,6 determining increases in adoptions for the purpose of awarding adoption

incentive payments to states,7 creating the data profiles used in the Children and Family Services

Reviews,8 and selecting sample cases to be included in Title IV-E Foster Care

Eligibility Reviews.9

In addition, AFCARS is one of the principal information sources used to prepare ACF’s child

welfare outcomes annual report. This report, required by Section 479A of the Social Security

Act, requires the Secretary of the Department of Health and Human Services (HHS) to submit a

report to Congress “on the performance of each State on each outcome measure, which shall

examine the reasons for high and low performance and, where possible, make recommendations

as to how State performance could be improved.” [emphasis added] The first annual report, for

FY 1998, was due May 1, 1999. Federal law requires that subsequent reports be submitted to

Congress annually thereafter. Information regarding the history of foster care and data collection

efforts preceding AFCARS is provided in Appendix A.

METHODOLOGY 

We used two mechanisms to conduct this inspection. We systematically collected data from 

foster care and adoption program managers and information systems staff in the 50 states, the 

District of Columbia, and Puerto Rico. Using a comprehensive mail survey, we collected 

information on the challenges and limitations associated with gathering and reporting AFCARS 

data and using the data to effectively administer child welfare programs and services. We 

achieved a 100 percent response rate. 

We judgementally selected a sample of five states (Arkansas, California, Illinois, New York, and 

Ohio) for additional data collection. We worked with ACF to select these states based on the 

following criteria: 

• Ability to comply with AFCARS regulations - For the reporting period ending 

March 31, 2001, three states were in substantial compliance with both adoption and 

foster care standards, one state was in substantial compliance with adoption standards 

only, and one state was out of substantial compliance with both adoption and foster 

care reporting requirements. 

5

 45 CFR § 1355.34(b). 

6

 Section 477 of the Social Security Act. 

7

 Section 473A of the Social Security Act. 

8

 45 CFR § 1355.33(b)(2). 

9

 45 CFR § 1356.71(c)(1). 

AFCARS: Challenges and Limitations 2 OEI-07-01-00660 
• Level of Statewide Automated Child Welfare Information System (SACWIS)10 

development - ACF classified the SACWIS in two states as operational, partially 

operational in one state, in the implementation phase in one state, and in the planning 

phase in the remaining state. An overview of SACWIS is provided in Appendix B. 

• Child welfare population - The combined child welfare populations in the 5 states 

represented 50 percent of children in foster care nationwide. The average monthly 

number of children in foster care in each of the 5 states ranged from 1,624 to 78,222 

during fiscal year 1999. 

• Program administration - The child welfare programs were state-administered in three 

states and county-administered in the other two. 

In the five states, we collected more in-depth information about state experiences reporting 

AFCARS information and the impact it had on their programs. We examined reports 

produced at the state and local levels for program management and compliance purposes, 

observed caseworkers and data entry staff enter data as they explained the features and 

limitations of their respective systems, and viewed electronic and paper versions of case files. 

The review of these reports and our observations allowed us to experience the data collection 

process from point of entry to submission. We also interviewed state child welfare supervisors, 

caseworkers, and data entry workers in a local child welfare office in each of the five states, 

and analyzed national AFCARS policy guidance provided by ACF. 

We conducted this inspection in accordance with the Quality Standards for Inspections 

issued by the President’s Council on Integrity and Efficiency. 

10 45 CFR § 1355.53(b)(1). 

AFCARS: Challenges and Limitations 3 OEI-07-01-00660
FINDINGS 

Our findings are based on a review of national policy guidance, surveys from all states, and 

observations and discussions during site visits to five states. The AFCARS data are the only 

federal national data available regarding children in foster care and children adopted under the 

auspices of a state agency. These data are used to measure state child welfare agency 

performance and to inform child welfare policy decision-makers. Therefore, it is critical that 

reported data are accurate and published in a timely manner. However, AFCARS data are not 

being published timely, and published data are incomplete and inconsistent. In addition, states 

experienced difficulties accessing technical assistance and were concerned about penalties 

associated with AFCARS reporting. 

The ACF Has Failed to Meet Mandated Time Frames for 

Submitting Annual Reports to Congress 

The ACF has not met the deadlines for submission of annual reports to Congress, as mandated 

in section 479A of the Social Security Act. This section requires the Secretary of HHS to 

submit an annual report to Congress on each state’s child welfare population. The first of these 

annual reports, due May 1999, covering FY 1998, was published in August 2000, 15 months 

late.11 The 1999 annual report, due May 2000, was published in January 2002, 19 months 

late.12 As of August 2002, ACF had not issued the reports for FY 2000 and FY 2001. The 

reports were due May 2001 and 2002, respectively. At the time of our review, the most recent 

state-specific information available on-line was an electronic copy of the FY 1999 annual 

report. 

The 2-year-old Published Data Do Not Reflect Some States’ Recent Efforts to 

Promote Permanency or Changes in the Status of Foster Care and Adoption 

The latest state-specific data published by ACF may not reflect current trends. We compared 

data reported in ACF’s published annual reports with more recent data for three of the five 

states we visited. These states comprised 36 percent of the children in out-of-home placements 

and 30 percent of the adoptions nationwide in FY 1999. The ACF’s annual reports indicate 

the number of children in out-of-home placements increased 3.75 percent from FY 1998 to FY 

1999, from 560,000 to 581,000. These reports represent the latest published federal data 

available. Yet, our examination of more recent data for three of the five states included in this 

study - unpublished state data obtained from ACF - shows that some states’ efforts, focused 

on permanency, are having a dramatic effect on the number of children in out-of-home 

placements in these states. 

11 Child Welfare Outcomes 1998: Annual Report. 

12 Safety, Permanency, Well-being: Child Welfare Outcomes 1999: Annual Report. 

AFCARS: Challenges and Limitations 4 OEI-07-01-00660
• Illinois: The ACF annual report, reflecting FY 1999 data, indicates 40,270 children 

were in foster care in Illinois on September 30, 1999. State data for FY 2000 indicate 

that, one year later, the number had decreased to 33,125. Data for FY 2001 show a 

continuing decline to 29,278 in the foster care population on September 30, 2001, a 27 

percent decrease over 2 years. The number of adoptions in Illinois also decreased by 

44 percent during this time period, dropping from 7,028 in FY 1999 to 4,234 in FY 

2000, then decreasing again to 3,934 in FY 2001. 

• New York: The ACF annual report, reflecting FY 1999 data, indicates 

52,762 children in New York were in foster care on September 30, 1999. State data 

for FY 2000 indicate that one year later that number had decreased to 47,208. Data 

for FY 2001 show a continuing decline to 43,365 in the foster care population on 

September 30, 2001, an 18 percent decrease over 2 years. 

• California: The ACF annual report, reflecting FY 1999 data, indicates 

117,937 children were in foster care in California on September 30, 1999. State data 

for FY 2000 indicate that one year later that number had decreased to 112,807. Data 

for FY 2001 show a continuing decline to 107,168 in the foster care population on 

September 30, 2001, a 9 percent decrease over 2 years. 

While these changes represent the experiences of only 3 states, these states represent a 

substantial percentage (36 percent) of children in out-of-home placements nationally. 

The change in the number of out-of-home placements could be even more significant if other 

states are experiencing similar reductions. Conversely, if the number of children in out-of-home 

placements nationally remains stable, other states may be experiencing substantial increases in 

children entering foster care. However, because ACF has not issued the 2000 and 2001 

annual reports, it is not possible for program managers and other decision-makers to make this 

determination. 

Published Reports Contain Incomplete Data 

In the annual report due May 1999, representing FY 1998, no data were reported for 10 states 

and selected data were missing for 8 additional states. In the annual report due May 2000, 

representing FY 1999, no data were reported for 2 states and 10 states had data missing from 

their profiles. These gaps occurred despite the amount of time allowed by ACF for states to 

report corrected AFCARS data. 

State AFCARS data submissions are due to ACF by May 15 and November 14 of each year, 

45 days after the end of each 6-month reporting period. The data submitted must be extracted 

from state data systems on the last day of the reporting period and should reflect child-specific 

data. States are allowed to resubmit corrected AFCARS data anytime thereafter, and ACF 

reports spending a considerable amount of time “cleaning” the data. Once ACF begins 

preparing the annual report to Congress, it notifies each state of the most current reported 

information that it has on file. States are then officially afforded 

AFCARS: Challenges and Limitations 5 OEI-07-01-00660 
45 days to rectify incorrect or incomplete data prior to publication, a time frame that ACF 

reported has historically stretched beyond 45 days. 

For the reporting period ending March 31, 1998, all states submitted AFCARS data to ACF, 

but 25 were out of substantial compliance with AFCARS standards. For the reporting period 

ending March 31, 2001, 13 states remained out of substantial compliance. 

States Reported a Variety of Factors Impact Their Ability to Capture and Report 

AFCARS Data 

Caseworker Priorities Affect Data Collection and Systems Entry 

Caseworkers are responsible for the collection and often the systems entry of AFCARS data. 

Most of the required AFCARS data are collected routinely as part of ongoing foster care and 

adoption case management. However, states reported that the collection and data entry of 

some AFCARS information were often a low priority for caseworkers. Large caseloads force 

caseworkers to focus on the immediate needs of children, such as removing children from 

harmful environments, locating appropriate care and needed services, attending court hearings, 

or working to meet the needs of foster and adoptive families; the need to focus on providing 

services limits the amount of time caseworkers spend on data gathering and data systems entry. 

While we did not attempt to identify or quantify AFCARS reporting errors specifically 

attributable to caseworkers, 80 percent (41) of the program managers surveyed indicated that 

caseworker workloads, turnover, and lack of training had an effect on the collection of 

AFCARS data, and 73 percent (38) reported that caseworkers entered data in an untimely 

manner. In addition, 61 percent (32) of the program managers surveyed indicated that the lack 

of complete information from local child welfare offices affected the reporting of AFCARS data 

in their states. 

System Limitations Affect Reporting 

For states to meet AFCARS requirements, they must be able to convert data in their systems 

into the format that ACF requires. However, in addition to the challenges that states face in 

capturing and entering data, they have also experienced difficulty matching their own state data 

to the data element formats required by AFCARS. Many of the reporting problems are a result 

of the transferring or “mapping” data from the state’s system to ACF’s required format. For 

example, the AFCARS data element “Foster Family Structure” requires one state to transfer 

information captured in the state system as “Aunt and Uncle” to “Married Couple.” If 

information is “mis-mapped,” erroneous data can result. 

States that continue to capture foster care and adoption data using computer systems created 

prior to the advent of AFCARS are at an added disadvantage because these systems are often 

difficult or impossible to reprogram to conform to current data 

AFCARS: Challenges and Limitations 6 OEI-07-01-00660 
collection standards. In some instances, these antiquated systems lack the capacity to collect 

key pieces of information, such as previous adoption and caretaker background information. 

In an effort to assist states with systems issues, ACF voluntarily initiated AFCARS data 

systems reviews in 1996. The ACF is conducting these reviews in addition to federallymandated reviews (e.g., Children and Family Services Reviews, IV-E Foster Care Eligibility 

Reviews) as resources become available. The ACF conducted 3 AFCARS data systems 

reviews in 2001, and had performed 11 at the time of this study. Respondents in states where 

these reviews have been conducted indicated that they found the reviews beneficial. A “State 

Guide to an AFCARS Assessment Review” was posted on the ACF website in April 2002. 

States Reported That Key AFCARS Data Elements Are Not 

Clearly and Consistently Defined, Resulting in Inconsistent 

Reporting 

Although ACF provides definitions of all AFCARS data elements, 60 percent (31) of the state 

respondents believed AFCARS data elements are not clearly and consistently defined. Most 

commonly, states noted problems with placement and date-of-discharge definitions. In 

addition, 71 percent (37) of states reported that unique state child welfare program 

characteristics result in the reporting of AFCARS data that are inconsistent among states. 

However, ACF aggregates data from all states in its annual report to Congress. Furthermore, 

AFCARS is one of the data sources used to create national standards against which ACF 

evaluates individual state performance. 

States Expressed Concerns About Placement Definitions, Potentially Affecting 

Performance Measures 

Twenty-one of the 31 respondents who believed definitions are not clearly defined indicated 

that placement definitions were problematic, making it the most commonly cited source of 

confusion. The performance measure specifically related to placements tracks the number of 

children who are placed in two or fewer placement settings. At the time of our review, ACF 

policy guidance regarding foster care placements stated “placement occurs after removal and is 

the physical setting in which a child finds himself or herself, that is, the resultant foster care 

setting. A new placement setting results when the foster care setting changes, for example, 

when a child moves from one foster family home to another or to a group home or institution.”13 

13 Child Welfare Policy Manual, Section 1 AFCARS. 

AFCARS: Challenges and Limitations 7 OEI-07-01-00660
Identical placements, like the example shown

in the text box to the right, were reported

differently by states. For example, some

states would report the number of placement

settings in the example as three. Other states

would report this as one foster home

placement and one trial home visit, or two

placement settings overall because the child

was returned to the same foster home. Other

states would report only one placement setting

because they do not count trial home visits as

placements.

Although 45 CFR §1355, Appendix A

indicates that trial home visits should not be

counted as a placement, at the time of our review, guidance provided in ACF’s Child Welfare

Policy Manual did not specifically exclude any of the three interpretations mentioned above, nor

did it support any one of the three interpretations over the others. Any variation in

interpretation makes evaluating states against a single national standard – percentage of children

served with no more than two placements – problematic.

Dates of Discharge may Impact Performance Measures Related to Time-in-Care 

The performance measure specifically related to time-in-care tracks the number of children who 

have been reunited with their parents or caretakers in less than 12 months. At the time of our 

review, the ACF policy guidance for date of discharge stated that the date should be recorded 

as “The month, day and year the child was discharged from foster care.” States defined end of 

placement differently. State definitions included when the child returns home for a trial home 

visit, a few days after a trial home visit begins, or when the state’s legal responsibility ends -

which could be weeks after the child is returned home. 

Similar to placement definitions above, any of the state interpretations fell within the guidance 

ACF provided. According to one respondent, summarizing the concerns of many, the definition 

associated with the date of discharge “is so critical to the Child and Family Service Reviews’ 

national standard measures, and so far from common understanding and use, that it dominates 

all of the useful data that might otherwise be provided.” 

States’ Reporting of Juvenile Justice Populations Potentially Affects Placement 

Performance Measures 

Forty-two percent (22) of the survey respondents included some or all of their juvenile justice 

populations in child welfare data reported through AFCARS. Policies regarding the movement 

of juvenile justice children to increasingly less restrictive placements 

Example of Common Placements 

During a Child’s Stay in Foster Care 

Child is removed from their home and 

• placed in a foster home, 

• returned home for a trial home 

visit, and 

• returned to the same foster home. 

AFCARS: Challenges and Limitations 8 OEI-07-01-00660 
(e.g., moving a child from a detention facility to a mental health treatment facility and then to a 

foster home) may result in an inflated number of placements for some states. Because these 

“additional” placements are often attempts to return a child to their own home or improve the 

child’s well-being, they are not necessarily an indication of poor child welfare practice. 

The ACF guidance regarding the inclusion of children in juvenile justice facilities was not 

definitive and contains subjective criteria for determining whether or not these children should 

be included in AFCARS reported data.14 For example, ACF guidance instructs states to 

include in reported AFCARS data “children in a foster care setting who are moved to a juvenile 

justice facility and who are expected to be returned to a foster care setting.” As a result, 

state-reported data for this population is inconsistent and may skew states’ performance related 

to the number of foster care placements for these children. The ambiguity of ACF guidance 

regarding the inclusion of children in juvenile justice facilities in reported AFCARS data may 

result in an inflated number of foster care placements for some states, and the inability to 

reliably compare states against national placement standards. 

Technical Assistance Is Effective, but Difficult to Access 

The ACF has developed technical assistance to address many of the difficulties associated with 

AFCARS reporting. These efforts include, but are not limited to 

• national data conferences where presentations and materials are offered to assist states 

with AFCARS reporting, 

• AFCARS reviews in which ACF staff visit a state to perform an extensive review of its 

data system to identify problems associated with AFCARS data collection and 

reporting, and to verify the accuracy of data in the system, 

• Children’s Bureau headquarters staff providing extensive telephone and electronic mail 

support to states, 

• Children’s Bureau headquarters staff providing on-site and telephone support to states 

through the National Resource Center on Information Technology in Child Welfare, 

and 

• technical bulletins15 and program policy16 related to AFCARS available on the Internet. 

14 Child Welfare Policy Manual, Section 1 AFCARS. 

15 http://www.acf.dhhs.gov/programs/cb/dis/afcars/tbs.html 

16 Child Welfare Policy Manual, http://www.acf.hhs.gov/programs/cb/laws/cwpm/index.jsp. 

AFCARS: Challenges and Limitations 9 OEI-07-01-00660 
The number of states out of compliance with AFCARS reporting decreased from 25 in 1998 to 

13 in 2001, and states reported that technical assistance proved valuable in facilitating states’ 

reporting of AFCARS data. States rated this assistance highly. However, states also report 

that some assistance is difficult to access. State program managers indicated travel restrictions 

and budget constraints often prevented them from attending conferences and meetings where 

technical assistance was offered. For example, only half of the states attended the User’s 

Group meetings in May and November of 2001. For each meeting, half of those that did not 

attend noted they were unable to attend due to budget constraints or state travel restrictions. 

Respondents also noted that, although ACF headquarters staff were very helpful, they 

were sometimes difficult to reach. They indicated that ACF staff were especially difficult to 

reach immediately prior to AFCARS reporting period deadlines when many states are 

simultaneously requesting assistance from a limited number of ACF headquarters staff. 

Respondents also revealed that it was difficult or impossible to access updated and current 

AFCARS information. They believed more current policy and regulatory information available 

on the Internet would serve as an important reference source for state foster care, adoption, 

and systems staff. Specific suggestions for improvement offered by states included adding more 

detailed and user-friendly descriptions of foster care and adoption data elements to the ACF 

AFCARS website, notifying relevant state staff when new technical bulletins are posted on the 

Internet and when policy changes occur, and posting more helpful “frequently asked questions” 

to the website than those currently available. 

Mandated Penalties Were an Incentive to Report AFCARS 

Data, but Were Not Commensurate with Non-compliance 

Section 479 of the Social Security Act states that ACF shall “utilize appropriate requirements 

and incentives to ensure that the [child welfare reporting] system functions reliably throughout 

the United States.” The Department issued regulations stating that “penalties shall be invoked” 

for “failure by a state to meet any of the [AFCARS] standards described” and that such failure 

is “considered a substantial failure to meet the requirements of the Title IV-E [Foster Care 

Program].”17 However, the Department rendered a decision to withdraw the penalties 

associated with failure to comply with AFCARS reporting requirements on January 27, 2002. 

Therefore, no penalty for failure to comply with AFCARS reporting requirements currently 

exists.18 It is too early to tell whether removal of penalties will impact the timeliness and 

completeness of state data submissions, or whether states will choose to report at all. 

When asked if they believed the penalties served as an incentive for accurate AFCARS 

reporting, 85 percent (44) of the respondents said “yes.” However, only 15 percent (8) of 

17 45 CFR § 1355.40(e). 

18 ACYF-CB-IM-02-03, dated April 8, 2002. 

AFCARS: Challenges and Limitations 10 OEI-07-01-00660
the respondents believed the penalties, as defined, were commensurate with non-compliance. 

Respondents were troubled by the “all-or-nothing” nature of penalties and argued that there 

was no incentive to improve reporting when the penalty for failure to report on a single required 

data element was the same as that for failure to report at all. They noted that a state reporting 

no AFCARS data would receive the same penalty as a state that made a concerted effort to 

improve data quality, but failed to meet just one AFCARS compliance standard. 

AFCARS: Challenges and Limitations 11 OEI-07-01-00660 
CONCLUSION AND 

RECOMMENDATIONS 

Annual reports are not issued timely and data reported are incomplete and inconsistent. The 

delayed publication of existing AFCARS data does not reflect recent changes in child welfare 

populations, and inconsistencies raise questions about its usefulness in developing national 

standards or measuring states against those standards. Technical assistance designed to 

address the difficulties associated with the collection and reporting of AFCARS information, 

while highly rated, is difficult to access. Furthermore, the penalties states reported were an 

incentive for accurate reporting have been withdrawn. 

While states are responsible for the collection of information reported through AFCARS, the 

ACF is responsible for administering the Title IV-E Foster Care Program, overseeing state 

AFCARS reporting, and publishing reported AFCARS data. As such, we make the following 

recommendations to ACF to enhance the usefulness of AFCARS data for program 

management purposes, and to make national child welfare outcome measures more reliable. 

ACF Should Work to Make AFCARS Data More Useful 

To alleviate problems associated with timeliness, comparability, and other factors which limit 

AFCARS data usefulness, we recommend that the ACF 

• make up-to-date child welfare statistics in AFCARS available to program officials and 

other decision-makers by publishing annual reports within congressionally-mandated 

time frames and posting current information on the Internet, 

• issue more precise definitions for data elements currently interpreted differently by 

states (i.e., data definitions regarding placements and dates of discharge from foster 

care), and 

• issue a definitive policy statement to address the inconsistencies in state AFCARS 

reporting of juvenile justice populations. 

ACF Should Increase the Accessibility of Technical 

Assistance Resources 

Because technical assistance has helped to improve the quality of AFCARS data, but has 

been difficult to access, the ACF should strive to increase access to and the impact of 

available assistance by 

AFCARS: Challenges and Limitations 12 OEI-07-01-00660 
• developing regional data conferences to provide the information currently presented 

only at national conferences to state staff and ACF regional office staff unable to attend 

conferences held outside their respective states or regions, 

• utilizing and training regional office staff to provide increased support to states, 

especially immediately prior to reporting deadlines, 

• posting more current and comprehensive AFCARS information on the ACF website, 

and 

• exploring ways to expedite discretionary AFCARS reviews (e.g., perhaps combine 

AFCARS data system reviews with other federally-mandated reviews) to help states 

resolve difficulties associated with data reporting. 

ACF Should Develop Incentives to Help Ensure State 

Compliance With AFCARS Regulations 

Considering the importance of accurate foster care and adoption information, ACF needs to 

have methods to help ensure that states are motivated to accurately and consistently report 

AFCARS information. The ACF should 

• document past compliance with AFCARS requirements for all states to establish a 

baseline, 

• monitor future AFCARS reporting, and 

• develop incentives or new penalties, commensurate with varying levels of compliance, 

to encourage accurate and timely reporting of AFCARS data. 

Agency Comments 

The ACF supports our recommendations and indicates that it is assessing internal agency 

processes for analyzing data and meeting required reporting time frames. The ACF referenced 

recently issued policy guidance regarding trial home visits and indicated that it will consider 

issuing clarifying guidance to alleviate inconsistent reporting of foster children included in 

juvenile justice populations. The ACF also stated that it will support ACF regional meetings 

focused on data-related issues, provide training to and utilize regional office staff in providing 

technical support to states, and explore ways to expedite AFCARS assessment reviews. The 

ACF will monitor and document compliance with AFCARS standards and seek ways to 

encourage timely and accurate reporting of AFCARS data. The full text of the comments 

provided by ACF are contained in Appendix C of the report. 

AFCARS: Challenges and Limitations 13 OEI-07-01-00660 
APPENDIX A 

History of Foster Care 

and

Early Data Collection Efforts

Federal foster care funds were first made available in 1961 to provide maintenance payments 

for children removed from Aid to Families with Dependent Children (AFDC) eligible families, in 

accordance with federal requirements. The federal role in foster care and adoption assistance 

was expanded with implementation of the Adoption Assistance and Child Welfare Act of 1980 

(Public Law 96-272). This Act amended child welfare service laws to institute financial 

incentives for states to provide certain protections for children in foster care under Section 427 

of the Social Security Act (Title IV-B) and established the IV-E Foster Care Program. The 

AFDC foster care component was transferred to the new Title IV-E foster care program in 

October 1982. In addition to maintenance payments to foster care providers, states can use 

federal funds for permanent adoption placements and transitional independent living expenses 

for foster children. 

Through the 1970s and 1980s, the Children’s Bureau within the Administration for Children 

and Families (ACF) and its predecessor agency collected data on foster care and adoption 

from states on an annual and voluntary basis. However, in the absence of federal reporting 

requirements, the reliability and consistency of the data were questionable and of concern to 

those tasked with policy development and administration of the IV-E foster care program. 

The Adoption Assistance and Child Welfare Act of 1980 amended the Social Security Act to 

require federal foster care and adoption reporting. Section 476 of the Social Security Act 

states that “Each state shall submit statistical reports as the Secretary may require with respect 

to children for whom payments are made including information about the legal status, 

demographic characteristics, location, and length of stay of any child in foster care.” This 

reporting requirement applies to all children in foster care under the responsibility of the State 

Title IV-E foster care agency. 

The Voluntary Cooperative Information System (VCIS) 

In response to the 1980 legislation, the Department of Health and Human Services (HHS) 

contracted with the American Public Welfare Association (n.k.a. the American Public Health 

Services Association (APHSA)) to implement the Voluntary Cooperative Information System 

(VCIS). Through this system, APHSA collected annual aggregate information from state child 

welfare agencies about the children in foster care and children awaiting adoption. However, 

state definitions for data reporting elements, definitions of various child welfare services, and 

methodologies used to collect information differed among the reporting states. The data 

reported through VCIS was of limited assistance in developing child welfare policies and 

program planning. 

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Congress amended Title IV-E of the Social Security Act, based on the need for more 

consistent and useful adoption and foster care information. Amendments to Section 479 of the 

Act established an advisory committee to develop an adoption and foster care data collection 

system. This legislation reflected congressional interest in establishing a system for the 

collection of adoption and foster care data. The advisory committee was charged with 

• identifying the types of information necessary to assess the characteristics of children in 

foster care, the nationwide status of adoption and foster care, and the validity of data 

collection methods for reporting adoption and foster care information, 

• developing appropriate national adoption and foster care policies, and 

• evaluating the financial and administrative impact of various data collection methods. 

In its 1987 report to the Secretary of HHS, the advisory committee indicated that sufficient 

adoption and foster care data were not available and that all states were not providing 

information via the VCIS. They also reported those states submitting VCIS data were using 

different reporting periods, data definitions, and methodologies. As such, the advisory 

committee recommended that the VCIS be phased out and a new mandatory data collection 

system be created. The advisory committee also recommended that states report required 

adoption and foster care information to HHS on a quarterly basis and that the new data 

collection system capture 

• adoption data on all legalized adoptions, 

• foster care information about all children under the care and responsibility of the state 

child welfare systems irrespective of who is funding the care, and 

• demographic information on all foster care children, including sex, birth date, race, 

ethnicity, previous stays in foster care, service goals, availability for adoption, duration 

of care, funding sources, and outcomes. 

Adoption and Foster Care Analysis and Reporting System (AFCARS) 

In response to the advisory committee’s report, on January 21, 1994, the HHS published a 

final rule in the Federal Register implementing the AFCARS. These regulations required states 

to collect and report specific information about all children in foster care for whom the state has 

responsibility for placement, care, or supervision. Information about each child under state 

jurisdiction, who had been adopted under the auspices of a state agency, is also required. The 

first AFCARS data were to be submitted to ACF by May 15, 1995, and semi-annually 

thereafter. 

AFCARS: Challenges and Limitations 15 OEI-07-01-00660 
APPENDIX B 

Statewide Automated Child Welfare 

Information Systems

In recognition of the critical need for effective statewide automated capability to support

Title IV-E and Title IV-B programs in a comprehensive fashion, section 13713 of

Public Law 103-66 amended the funding provisions under section 474 of the Social Security

Act to provide matching federal financial participation (FFP) funding to assist states in the

planning, design, development, and installation of Statewide Automated Child Welfare

Information Systems (SACWIS). 

States were to design these systems as comprehensive case management systems that would

also collect the required adoption and foster care information for AFCARS reporting. States

were authorized 75 percent FFP for SACWIS activities for fiscal years 1994 through 1996. 

Congress extended the enhanced funding through 1997, and the federal percentage was

reduced to 50 percent thereafter. In addition, states are eligible for 50 percent FFP for the

operation of the SACWIS systems. 

As of November 15, 2002, 4 states had completed all aspects of their SACWIS, 24 states

were operational (including the District of Columbia), 10 were partially operational, 3 were in

the process of implementing their systems, and 6 states remained in the planning phase. Four

states chose not to apply for SACWIS funds. 

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APPENDIX C 

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ACKNOWLEDGMENTS 

This report was prepared under the direction of Brian T. Pattison, Regional Inspector 

General for Evaluation and Inspections and Gina Maree, Assistant Regional Inspector 

General for Evaluation and Inspections in Kansas City. Other principal Office of 

Evaluation and Inspections staff who contributed include: 

Deborah Walden, Project Leader Linda Hall, Program 

Specialist 

Mike Craig, Program Analyst 

Steve Milas, Program Analyst 

Technical Assistance

Barbara Tedesco, Technical Support Staff

For information or copies of this report, please contact

the Office of Inspector General’s

Public Affairs office at (202) 619-1343.

Reports are also available on the World Wide Web at our home page address: 

http://www.oig.hhs.gov/ 

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