a

GAO

United States Government Accountability Office

Report to Congressional Committees

July 2005 DISTRICT OF 

COLUMBIA

Federal Funds for 

Foster Care 

Improvements Used to 

Implement New 

Programs, but 

Challenges Remain

GAO-05-787
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

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

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Jeanette 

Franzel at (202) 512-9471 or 

franzelj@gao.gov. 

Highlights of GAO-05-787, a report to 

congressional committees 

July 2005

DISTRICT OF COLUMBIA 

Federal Funds for Foster Care 

Improvements Used to Implement New 

Programs, but Challenges Remain 

The District and COG have used the federal funds for foster care 

improvements as intended by the Congress and as described in their 

respective spending plans. As of March 31, 2005, about $13.2 million of the 

funds provided had been obligated, about $6.2 million of the obligated funds 

had been expended, and about $722,524 remained unobligated. The 

unobligated funds for CFSA and DMH, in the amounts of $588,859 and 

$30,545 respectively, ceased to be available for new obligations after 

September 30, 2004, and should revert to the general fund of the U.S. 

Treasury. However, there is no such fiscal limitation on COG’s use of the 

funds it received; thus, its unobligated $103,120 remains available for its 

foster care improvement program. 

Internal controls were generally operating effectively over obligations 

related to the federal funds at CFSA and DMH. Overall, we found that 

authorized personnel were processing and approving transactions and 

transactions were adequately supported. However, we found three instances 

worth discussion. These involved the need for sufficient documentation, 

better adherence to operating procedures and greater control over physical 

assets. 

CFSA, DMH, and COG have implemented the programs and initiatives 

specified in the appropriations act and spending plans; however, it is too 

early to assess the effectiveness of some and challenges remain for others. 

Although implementation of the early intervention program was delayed, this 

program helped about 150 families. Also, the emergency support fund 

helped about 100 kinship families—relatives who provide foster care. 

However, it will be a challenge for CFSA to reduce the number of unlicensed 

kinship homes—one program goal. Although most of CFSA’s unlicensed 

homes are not kinship homes, 265 of the 300 unlicensed homes are not in the 

District and officials from other jurisdictions will play a role in the licensing 

process. About 70 percent of CFSA’s eligible caseworkers participated in the 

agency’s student loan repayment program. This program was intended to 

help recruit and retain caseworkers, but CFSA’s attrition rate increased from 

about 15 percent in 2003 to about 18 percent in 2004. CFSA developed an 

information technology plan that indicates the system upgrades will be 

completed by the end of 2005, and provided laptops to some caseworkers. 

DMH increased mental health services available to foster care children; 

however, it faces ongoing challenges in building its capacity to provide 

assessments and in securing long-term funding for treatment services. COG 

established a respite program for foster parents, but few families completed 

the required licensing process, and fewer placements were made than 

anticipated. It may be a challenge for COG to recruit, train, and license 

enough respite providers and convince foster parents to participate. 

To help improve foster care in the 

District of Columbia, the Congress 

provided $14 million for fiscal year 

2004 to the Child and Family 

Services Agency (CFSA), the 

Department of Mental Health 

(DMH), and the Metropolitan 

Washington Council of 

Governments (COG). These funds 

were for programs for early 

intervention, emergency support, 

and student loan repayments; 

computer technology upgrades, 

mental health services, and respite 

care (short-term care to provide 

relief for foster parents). GAO was 

asked to (1) assess whether the 

federal funds were being obligated 

and expended by the District 

government and COG consistent 

with provisions in the District of 

Columbia Appropriations Act, 2004, 

and the spending plans that were 

submitted to the Congress; 

(2) determine whether internal 

controls were operating effectively 

over the obligations and 

disbursements; and (3) assess the 

extent to which the District 

government and COG have 

implemented the foster care 

improvement programs and 

initiatives specified in the act and 

spending plans. 

GAO received written comments 

from CFSA, DMH, and COG. The 

agencies generally agreed with 

GAO’s findings and conclusions. 
Page i GAO-05-787 District of Columbia

Contents

Letter 1

Results in Brief 4

Background 6

CFSA, DMH, and COG Obligated and Spent Funds for Purposes 

Consistent with the Appropriations Act and Spending Plans, but 

Some Funds Were Not Used 11

Internal Controls Are Generally Operating Effectively 13

New Programs Have Been Implemented to Improve Foster Care, but 

Challenges Remain 17

Concluding Observation 30

Agency Comments and Our Evaluation 30

Appendixes

Appendix I: Scope and Methodology 33

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

Agency 36

Appendix III: Comments from the District’s Department of Mental 

Health 40

Appendix IV: Comments from the Metropolitan Washington Council of 

Governments 43

Appendix V: GAO Contacts and Staff Acknowledgments 44

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

Improvement Funds 10

Table 2: Funds Received, Obligated, and Unobligated by CFSA, 

DMH, and COG, as of March 31, 2005 13

Table 3: Eligible Services and Supports Provided through the Early 

Intervention Program 18

Table 4: Key Steps in CFSA’s Information Technology Plan, as of 

June 15, 2005 25

Table 5: Foster Care Children Receiving Mental Health 

Treatment 27

Figures Figure 1: Types and Numbers of Services Provided to Families with 

Early Intervention Program Funds 19

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

Emergency Support Funds 21

Figure 3: Distribution of Student Loan Repayment Amounts 23
Contents

Page ii GAO-05-787 District of Columbia

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Abbreviations

BSW bachelors of social work

CFSA Child and Family Services Agency

COG Metropolitan Washington Council of Governments

CSSP Center for the Study of Social Policy

DMH Department of Mental Health

FACES CFSA's automated case management system

FAPAC Foster and Adoptive Parents Advocacy Center

FBI Federal Bureau of Investigation

FFTM Facilitated Family Team Meeting

ICPC Interstate Compact on the Placement of Children

ILP Independent Living Placements

IT information technology

MRSS Mobile Response and Service Stabilization

MSW masters of social work

PASS Procurement Automated Support System

SOAR System of Accounting and Reporting
Page 1 GAO-05-787 District of Columbia

United States Government Accountability Office

Washington, D.C. 20548

A

July 22, 2005 Letr

The Honorable Sam Brownback

Chairman

The Honorable Mary Landrieu 

Ranking Minority Member

Subcommittee on the District of Columbia

Committee on Appropriations

United States Senate

The Honorable Joe Knollenberg

Chairman

The Honorable John W. Olver

Ranking Minority Member

Subcommittee on Transportation, Treasury, and 

Housing and Urban Development, The Judiciary, 

District of Columbia, and Independent Agencies

Committee on Appropriations

House of Representatives

In fiscal year 2003, about 3,000 children in the District of Columbia (the 

District) were under the care of the city’s Child and Family Services Agency 

(CFSA). Most of these children had been removed from their homes 

because of abuse or neglect and were being cared for by foster parents or 

relatives, known as kinship families. These foster children and the families 

that care for them need various services and support. CFSA is the District 

government agency with primary responsibility for ensuring the proper 

care of these children, and it works with several other District agencies to 

provide essential services to the children and their families. One of these is 

the Department of Mental Health (DMH), which provides comprehensive 

mental health services to foster children as well as to other children, 

teenagers, adults, and families. Mental health services are considered 

critical for children who have suffered abuse or neglect. Organizations 

outside the District government also help to support the foster care system. 

One such organization is the Metropolitan Washington Council of 

Governments (COG), which works across jurisdictions to address issues 

facing the metropolitan area, such as an insufficient number of foster 

parents. 

Because CFSA had a history of mismanagement and failed to protect some 

of the children under its care, the Congress enacted laws and provided 

funds to help improve the city’s foster care system. The District of 
Page 2 GAO-05-787 District of Columbia

Columbia Appropriations Act, 2004,1 included a federal payment of $14 

million for foster care improvements in the District. Funds were provided 

for (1) CFSA to establish an early intervention program to help reduce the 

number of children coming into foster care, an emergency support fund to 

help reduce the number of unlicensed kinship homes, and a loan 

repayment program to help recruit and retain caseworkers, as well as to 

upgrade its automated case management system and provide caseworkers 

with computer technology to help improve case management and 

caseworkers’ productivity; (2) DMH to provide all court-ordered or agencyrequired mental health screenings, assessments, and treatments to children 

in CFSA’s care; and (3) COG to develop a program with the Foster and 

Adoptive Parent Advocacy Center (FAPAC)2

 to aid in recruitment of foster 

parents and provide them with respite care (short-term care provided by 

individuals licensed to care for foster children when the foster family needs 

to take a break or attend to other matters). On March 17, 2004, the District 

received the $14 million federal payment, less a 0.59 percent rescission, for 

a total of about $13.9 million.3

In September 2004,4 we reported on several CFSA and DMH management 

issues related to the District’s foster care system and the District’s and 

COG’s plans for and use of the federal foster care improvement funds. We 

found that CFSA, DMH, and COG had spending plans that were consistent 

with the statutory language providing these federal funds and that only a 

small portion of the foster care improvement funds had been obligated or 

spent as of June 2004, in part because CFSA, DMH, and COG did not 

receive the funds until March 2004. Most of the expenditures outlined in 

the spending plans were for operating costs that would continue 

indefinitely once the programs were established. At that time, it was 

uncertain how the District and COG planned to fund some of these 

initiatives in the long term. We also reported that many steps had been 

1

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

2

The Foster and Adoptive Parents Advocacy Center is an organization that assists foster, 

kinship, and adoptive parents of children in the District of Columbia.

3

Section 168 of Division H of the Consolidated Appropriations Act, 2004, Pub. L. No. 108-199, 

included a provision for an across-the-board 0.59 percent rescission to be deducted from the 

budget authority provided for any discretionary accounting in the act.

4

GAO, D.C. Child and Family Services Agency: More Focus Needed on Human Capital 

Management Issues for Caseworkers and Foster Parent Recruitment and Retention, GAO04-1017 (Washington, D.C.: Sept. 24, 2004). 
Page 3 GAO-05-787 District of Columbia

taken to improve the District’s foster care system, but that most of the 

programs and initiatives would need sustained attention and ongoing 

support to achieve the intended results. 

Since the issuance of our September 2004 report, we have, as called for by 

the appropriations act, reviewed the obligations and expenditures of the 

fiscal year 2004 federal funds provided for foster care improvements. As 

you subsequently requested, we have also assessed the status of the 

programs supported by the foster care improvement funds. Specifically, 

our objectives were to (1) assess whether the federal funds were being 

obligated and expended by the District government and COG in a manner 

consistent with the act’s provisions and the spending plans that were 

submitted to the Congress, (2) determine whether internal controls are 

operating effectively over obligations related to the federal funds for foster 

care improvements received by the District and COG, and (3) assess the 

extent to which CFSA, DMH, and COG have implemented the foster care 

improvement programs and initiatives specified in the act and spending 

plans.

To analyze CFSA, DMH, and COG’s use of their fiscal year 2004 federal 

funds for foster care improvements, we reviewed the agencies’ spending 

plans, budget data, and internal reports of obligations and expenditures for 

the period March 2004 through March 2005. We interviewed financial and 

program personnel from all three organizations and from the District 

government’s central Office of the Chief Financial Officer to obtain an 

understanding of the procedures and controls over the use of the funds. In 

addition, we selected a statistical sample of CFSA and DMH obligation 

transactions covering the period March 17, 2004, through September 30, 

2004, from total obligations to test whether procedures were properly 

implemented to provide internal control over the use of the funds.5

 We 

reviewed COG’s fiscal year 2004 financial statements audit opinion, 

conducted walk-throughs of the accounting, payroll, procurement, and 

payments processes in place, and analyzed its spending plans, budget, and 

financial documents. To assess the extent to which CFSA, DMH, and COG 

had implemented the foster care improvement programs specified in the 

appropriations act, we interviewed knowledgeable officials, reviewed 

related program policies and protocols, and analyzed program data. We 

took several steps to assess the reliability and reasonableness of the 

program data. Overall, we found the data to be sufficiently reliable for the 

5

See appendix I for statistical sampling details.
Page 4 GAO-05-787 District of Columbia

purpose of assessing the status of the foster care improvement programs. 

We conducted our work from October 2004 through June 2005 in 

accordance with U.S. generally accepted government auditing standards. 

See appendix I for more details on our scope and methodology.

Results in Brief The District and COG have obligated and expended federal funds for 

purposes consistent with the provisions of the appropriations act and their 

respective spending plans. As of March 31, 2005, about $13.2 million of the 

funds provided had been obligated; about $6.2 million of the obligated 

funds had been expended, and about $722,524 remained unobligated. The 

unobligated funds for CFSA and DMH, in the amounts of $588,859 and 

$30,545 respectively, ceased to be available for new obligations after 

September 30, 2004, and should revert to the general fund of the U.S. 

Treasury. When funds were disbursed to COG from the District, these 

funds lost their federal payment character; thus, there is no fiscal limitation 

on COG’s use of its $103,120 in unobligated funds.

Internal controls were generally operating effectively over obligations 

related to the foster care improvement funds at CFSA and DMH. Overall, 

we found that authorized personnel were processing and approving 

transactions in accordance with District policies and procedures, and that 

transactions were adequately supported at CFSA and DMH. However, in 

our testing at these two agencies, we found three instances worth 

discussion. These involved the need for sufficient documentation, better 

adherence to operating procedures, and greater control over physical 

assets. We did not conduct detailed transaction testing at COG because it 

received an unqualified opinion on its fiscal year 2004 financial statements 

and the auditor did not identify any reportable instances of internal control 

weaknesses or noncompliance with laws and regulations under 

Government Auditing Standards.

6

 

CFSA, DMH, and COG have implemented the programs and initiatives 

specified in the appropriations act and the spending plans; however, there 

has not been enough time to assess the effectiveness of some of them and 

challenges remain that could affect the success of others. 

6

GAO, Government Auditing Standards 2003 Revision, GAO-03-673G (Washington, D.C.: 

June 2003). 
Page 5 GAO-05-787 District of Columbia

• CFSA’s early intervention program and its emergency support fund 

helped about 150 families by providing funds to pay rental fees and 

utilities and buy furniture and other items. However, implementation of 

the early intervention program was delayed due to the need to train the 

parties involved with the family meeting component of the program and, 

according to agency officials, there has not been enough time to 

determine whether the program has been effective. 

• One goal of the emergency support fund is to help CFSA reduce the 

number of unlicensed kinship foster homes. As of April 2005, CFSA had 

children in more than 300 unlicensed foster homes, just as it did in 2003, 

but according to agency officials most of these were not kinship homes. 

Nonetheless, because most of the unlicensed homes are located outside 

the District, it will be a challenge for CFSA to ensure that managers in 

other jurisdictions take timely and adequate steps to help license them. 

• About 140 of the 190 eligible caseworkers participated in CFSA’s student 

loan repayment program; however, $400,000 was not used because, 

according to agency officials, the federal funds were not available until 

after the height of their recruitment season and some caseworkers were 

reluctant to commit to working at CFSA for several years, as required by 

the program. It is too soon to tell whether the student loan repayment 

program will help improve retention in the long-term, but CFSA’s 

attrition rates increased from 15 percent in 2003 to nearly 18 percent in 

fiscal year 2004.

• CFSA developed an information technology plan and purchased and 

distributed laptops to some caseworkers. The system upgrades will not 

be completed until December 2005 and it is not clear when all 

caseworkers will receive laptops. 

• DMH has increased the mental health services available to foster care 

children, including the number of assessments completed and the 

treatment services offered through the mental health system. However, 

the department faces ongoing challenges in building the capacity to 

provide needed assessments and in securing long-term funding for 

treatment. 

• COG worked with FAPAC to establish a respite program, but its 

implementation was hampered because the plans did not factor in 

enough time for training families or completing background checks. As 

of June 2005, while 106 children had participated in six Saturday day-
Page 6 GAO-05-787 District of Columbia

time respite programs, only seven families had completed the licensing 

process and were therefore eligible to provide overnight respite. COG 

has taken steps to improve the program, but the organization may find it 

a challenge to recruit, train, and license enough qualified persons to 

volunteer to serve as respite providers and to convince foster parents to 

participate. 

We received written comments from CFSA, DMH, and COG. CFSA agreed 

in general with our findings and provided comments and additional 

information. DMH’s comments addressed information on delays in 

assessments and service delivery capacity. In its comments, COG said that 

recruiting the families to provide respite has not been a challenge. COG 

also said that the challenge has been keeping volunteers’ level of 

enthusiasm through the arduous and lengthy licensing process. In addition, 

CFSA and FAPAC provided technical comments to clarify the report. We 

have incorporated this information as appropriate. See appendixes II, III, 

and IV, respectively, for the written comments from the CFSA, DMH, and 

COG. 

Background The child welfare system is designed to promote the well-being of children 

by ensuring their safety and by strengthening families to enable them to 

successfully care for their children. Generally, families become involved 

with the child welfare system after a report of abuse or neglect has been 

made and confirmed. When agency officials determine that a child may be 

further harmed or mistreated if left in the home, the child is placed in foster 

care.

The federal government has allocated about $7 billion each year to 

investigate abuse and neglect of children in this country, provide 

placements to children outside their homes, and deliver services to help 

keep families together. Part E of title IV of the Social Security Act (title IVE), as amended, is a major source of federal funding and is primarily used 

to pay for the room and board of children in foster care. 

Child welfare caseworkers are at the core of the child welfare system. 

They are responsible for overseeing individual cases and for performing 

many critical tasks such as arranging placements when children must be 

removed from their homes, visiting children and foster families, 

maintaining records on each case, and coordinating with other agencies to 

obtain services for the children and their families. Child welfare agencies 

face challenges in recruiting and retaining caseworkers. We previously 
Page 7 GAO-05-787 District of Columbia

reported that low salaries hinder agencies’ abilities to attract and retain 

them.7

 We also found that high caseloads, administrative burdens, a lack of 

supervisory support, and insufficient time for training were issues that 

affected caseworkers’ abilities to work effectively and their decisions to 

stay in or leave the child welfare profession. 

CFSA is responsible for managing the child welfare system for the District 

and it relies on services provided by other District government agencies in 

order to achieve its mission. For example, the Fire Department and the 

Health Department inspect homes and facilities where foster children are 

placed as part of the licensing process to ensure these homes are safe, and 

the Department of Mental Health provides mental health services to 

children in CFSA’s care. In addition, CFSA works with child welfare 

agencies in other states to arrange for placements of the District’s children 

in cases where the most appropriate foster or adoptive family lives outside 

the District. CFSA also works with private agencies to place children in 

foster and adoptive homes, and with private vendors to obtain needed 

services and supplies. CFSA uses an automated case management system, 

known as FACES, to track each child’s case, including services rendered or 

supplies obtained. FACES is also used to record and authorize payments 

for such services through an interface with the District’s core financial 

management system, known as SOAR. CFSA receives title IV-E funding as 

well as other federal, local, and private funds to support its programs. 

CFSA had a history of managerial deficiencies that led the U.S. District 

Court for the District of Columbia to issue a remedial order in 1991 to 

improve the performance of the agency, and then in 1995, due to 

insufficient evidence of program improvement, the agency was placed in 

receivership.8

 After almost 6 years of federal receivership, CFSA was 

reorganized as a District cabinet-level agency. Since that time, it has 

worked to improve services and promote the safety and well-being of 

children and families. The U.S. District Court appointed the Center for the 

Study of Social Policy (CSSP) to monitor and assess CFSA’s performance. 

CSSP and we have reported that the management and operations of CFSA 

7

GAO, Child Welfare: HHS Could Play a Greater Role in Helping Child Welfare Agencies 

Recruit and Retain Staff, GAO-03-357 (Washington, D.C.: Mar. 31, 2003).

8

The receivership was an arrangement in which the U.S. District Court appointed a person 

to temporarily manage the agency with broad authority to ensure full and expeditious 

compliance with requirements established by the court.
Page 8 GAO-05-787 District of Columbia

have improved since the receivership, but also found that matters of 

concern remained.9

The District’s mental health agency was similarly placed in receivership for 

over 5 years, from 1997 to 2002.10 As originally established, the District’s 

mental health system was not organized or funded to meet the particular 

needs of children, youth, and their families. When DMH took the place of 

the Commission on Mental Health Services in 2001, it had too few providers 

to accommodate the needs of the District’s foster care children. Mental 

health services—both assessments and treatment—are considered critical 

for children who have suffered abuse or neglect; therefore, to better 

connect foster care children with such services, CFSA began to contract 

directly with mental health providers. 

Over the years, the Congress has enacted laws and provided funds to help 

improve the District’s child welfare system. For example, the District of 

Columbia Family Court Act of 200111 established the D.C. Family Court 

dedicated solely to matters concerning the District’s children and families. 

The D.C. Family Court has jurisdiction over cases involving alleged child 

abuse and neglect, juvenile delinquency, domestic violence, child support, 

and other family matters. In addition to establishing the Family Court, the 

Congress authorized funds to the District in fiscal year 2002 for the 

completion of a plan to integrate the District’s computer systems with 

those of the D.C. Family Court and for CFSA’s caseworkers to help 

9

GAO, D.C. Child and Family Services: Better Policy Implementation and Documentation 

of Related Activities Would Help Improve Performance, GAO-03-646 (Washington, D.C.: 

May 27, 2003); Center for the Study of Social Policy, LaShawn A. v. Williams: An 

Assessment of the District of Columbia’s Progress as of September 30, 2003 in Meeting the 

Implementation and Outcome Benchmarks for Child Welfare Reform (Washington, D.C.: 

Feb. 9, 2004).

10The U.S. District Court for the District of Columbia placed the D.C. Commission on Mental 

Health Services, DMH’s predecessor agency, in receivership in 1997. The first receiver 

began his appointment in October 1997 and resigned in March 2000. The court then issued a 

consent order establishing a transitional receiver to develop a plan for the District to resume 

full control of its mental health system. This transitional receivership was terminated in 

May 2002, and the court appointed a monitor to oversee the District’s implementation of the 

plan.

11Pub. L. No. 107-114, 115 Stat. 2100 (Jan. 8, 2002).
Page 9 GAO-05-787 District of Columbia

implement family court reform.12 Also, the District of Columbia 

Appropriations Act, 2004,13 included a fiscal year 2004 federal payment of 

$14 million to CFSA, DMH, and COG for improvements to specific foster 

care programs.14 The federal funds were supplemented by private funds for 

CFSA’s early intervention program and COG’s respite care and foster parent 

recruitment program. In February 2004, the District and COG submitted 

their respective plans to the Congress, outlining how they intended to use 

the foster care improvement funds. Table 1 summarizes the purposes for 

the funds as designated in the appropriations act and the planned 

expenditures as listed in the spending plans.

12Pub. L. No. 107-96, 115 Stat. 923, 929 (Dec. 21, 2001). For more details on the planned 

reform practices in the District’s Family Court, see GAO, D.C. Family Court: Additional 

Actions Should Be Taken to Fully Implement Its Transition, GAO-02-584 (Washington, 

D.C.: May 6, 2002).

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

14Subsequently, for fiscal year 2005, the Congress provided about $5 million in additional 

funding for foster care improvements in the District. These federal funds were made 

available for specific programs to CFSA, DMH, and COG until expended. The 

appropriations act provided (1) $3,250,000 for CFSA’s early intervention program, the 

emergency support fund, and technology upgrades; (2) $1,250,000 for DMH to provide all 

court-ordered or agency-required mental health screenings, assessments, and treatments for 

children under the supervision of CFSA; and (3) $500,000 for COG to continue a program in 

conjunction with the Foster and Adoptive Parents Advocacy Center, to provide respite care 

for and recruitment of foster parents. Pub. L. No. 108-335, 118 Stat. 1322, 1326 (Oct. 18, 

2004).
Page 10 GAO-05-787 District of Columbia

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

Public law 108-199 Spending plans

Organization and total 

funding Purpose of funding

Federal

funds

Proposed

expenditures Description

Child and Family 

Services Agency

$9 million

To establish an early 

intervention program to provide 

intensive and immediate 

services to foster children.

$2 million $700,000 Personnel costs (salaries & benefits)

500,000 Training and communications

200,000 Meeting expenses (e.g., facilities & 

transportation)

530,000 Services for children and families that are 

not currently available at sufficient levels 

(e.g., substance abuse treatment)

70,000 Overhead

To establish an emergency 

support fund to purchase 

necessary items to allow 

children to remain in the care of 

a licensed, approved family 

member.

$1 million $920,000 Emergency expenses for relatives (e.g., 

furnishings & home repairs)

73,000 Personnel costs (salaries & benefits)

7,000 Overhead

To establish a loan repayment 

program for caseworkers.

$3 million $2,750,000 Student loan repayments for qualified 

caseworkers with master’s and bachelor’s 

degrees to accept and extend their tenure 

with the District

250,000 Contract for loan repayment program 

design and administration

To upgrade (FACES) computer 

database and technology as 

well as to provide computer 

technology for caseworkers.

$3 million $2,170,000 Upgrade FACES to Web-based 

architecture

830,000 Computer technology for social workers 

(e.g., new laptops or tablet PCs)

Department of Mental 

Health 

$3.9 million

 $300,000 Staffing of project team to oversee the 

implementation and coordination of all 

program services outlined below

To provide all court-ordered or 

agency-required mental health 

screenings and assessments 

for children under the 

supervision of CFSA.

1,030,000 Costs for expanded hours of psychiatrists 

and psychologists
Page 11 GAO-05-787 District of Columbia

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

CFSA, DMH, and COG 

Obligated and Spent 

Funds for Purposes 

Consistent with the 

Appropriations Act and 

Spending Plans, but 

Some Funds Were Not 

Used

We found that CFSA, DMH, and COG obligated and expended the federal 

funds provided for foster care improvement for purposes consistent with 

the appropriations act and organizations’ spending plans. The funds were 

used for authorized expenses such as repairs for foster homes, student loan 

repayments, psychiatric evaluations, staff salaries for the family team 

meeting project, and training and education materials. For a comparison of 

agency spending plans to provisions of the appropriations act, see table 1. 

Additional information about the programs is provided in later sections of 

this report.

70,000 Staff and home visits/assessments

47,000 Supplies and materials

1,725,000 Mobile crisis and community-based 

intervention teams to provide immediate 

assistance

Community support teams to provide a 

range of interventions to high risk children 

involved in multiple systems

Community treatment setting for older 

adolescents who are aging out of care

Specialized therapy and child traumatic 

stress treatment

150,000 Staffing coordination between DMH and 

CFSA

578,000 Training

Washington 

Metropolitan Council of 

Governments

$1.1 million

To develop a program in 

conjunction with the Foster and 

Adoptive Parents Advocacy 

Center to provide respite care 

for and recruitment of foster 

parents.

Although COG presented a detailed spending plan, it did not include a 

breakdown of expenditures. The plan indicated that COG would (1) 

provide services for resource parents caring for children in the D.C. child 

welfare system, (2) recruit and train respite care families to care for foster 

children covering emergency, planned, or ongoing respite care situations, 

and (3) assist CFSA in developing a recruitment video and purchasing 

media ads targeted to demographics most likely to look after special needs 

children in foster care. 

(Continued From Previous Page)

Public law 108-199 Spending plans

Organization and total 

funding Purpose of funding

Federal

funds

Proposed

expenditures Description
Page 12 GAO-05-787 District of Columbia

On March 17, 2004, the District received the $14 million federal payment, 

less a 0.59 percent rescission, for a total of about $13.9 million.15 The 

District sent COG a payment of $1,093,510, as specified by the 

appropriations act. The availability of the federal payment of funds 

received by the District for foster care improvements was limited to fiscal 

year 2004. Any unobligated balances of funds after September 30, 2004, 

were no longer available for the District’s use and should revert to the 

general fund of the U.S. Treasury. When the District disbursed funds to 

COG for its use, the funds lost their federal payment character; thus there is 

no fiscal time limitation on the use of the federal funds provided to COG.

As we previously reported,16 only a small portion of the federal funds for 

foster care improvements had been obligated or spent as of June 30, 2004.17 

At that time, over $12.4 million of the $13.9 million provided remained 

unobligated. However, as of September 30, 2004, the District agencies and 

COG had obligated about $12.6 million of their funds. Since then COG has 

obligated an additional $599,000, bringing the total amount of funds 

obligated as of March 31, 2005, to $13.2 million. As of March 31, 2005, about 

$6.2 million of the total obligated funds had been expended and about 

$722,524 remained unobligated. The unobligated funds for CFSA and DMH, 

in the amounts of $588,859 and $30,545 respectively, ceased to be available 

for new obligations after September 30, 2004, and should revert to the 

general fund of the U.S. Treasury. COG’s $103,120 in federal funding 

remains available for use in the respite program for foster parents of 

District children. Table 2 provides details on the amounts of the 

organization’s obligations as of March 31, 2005.

15Section 168 of Division H of the Consolidated Appropriations Act, 2004, Pub. L. No. 108-

199, included a provision for an across-the-board 0.59 percent rescission to be deducted 

from the budget authority provided for any discretionary accounting in the act.

16GAO-04-1017.

17GAO-04-1017.
Page 13 GAO-05-787 District of Columbia

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

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

a

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

rounding.

Internal Controls Are 

Generally Operating 

Effectively 

In our testing at CFSA and DMH, we concluded that internal controls were 

in place over obligations of the funding provided to both District agencies 

to ensure that the federal funds were expended appropriately for their 

intended purposes. Consistent with standards for internal control in 

government,18 the agencies’ internal controls comprise a series of 

appropriate actions and activities conducted throughout the agencies’ 

operations on an ongoing basis. Internal control activities we tested 

include (1) adequate segregation of duties so that no one person can 

approve as well as execute a transaction, (2) approval of transactions by 

appropriate supervisory officials, (3) sufficient documentation of 

transactions, and (4) physical control over negotiable assets. Agency fiscal 

officers are charged with providing oversight to ensure that controls are 

adequate to provide reasonable assurance19 that funds obligated and 

expended are used effectively and as intended, according to the spending 

plans and the appropriations act. 

Organization Funds received

Total funds

obligated

Obligations as a

percentage of

funds received Funds not obligated

Funds

unobligated as a

percentage of

funds received

CFSA $8,946,900 $8,358,041 93.4% $588,859 6.6%

DMH 3,876,990 3,846,445 99.2 30,545 0.8

COG 1,093,510 990,390 90.6 103,120 9.4

Totala $13,917,400 $13,194,876 94.8% $722,524 5.2%

18Internal control is an integral component of an organization’s management that provides 

reasonable assurance that the following objectives are being achieved—effectiveness and 

efficiency of operations, reliability of financial reporting, and compliance with applicable 

laws and regulations. GAO, Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).

19No matter how well designed and operated, internal controls cannot provide absolute 

assurance that all agency objectives will be met. Management should design and implement 

internal controls based on the related cost and benefits. Therefore, internal control 

provides reasonable, but not absolute assurance of meeting agency objectives. GAO/AIMD00-21.3.1.
Page 14 GAO-05-787 District of Columbia

To test specific control activities at CFSA and DMH, we selected a 

statistical sample of obligation transactions covering the period March 17, 

2004, through September 30, 2004, in the sum of about $11.9 million20 from 

foster care improvement obligations of about $12.2 million. In addition, we 

tested the District’s supporting documentation for the $1.1 million transfer 

to COG. Based on the results of our tests, we concluded that internal 

controls are generally operating effectively.21 Two key internal control 

activities were built into the requisition and purchasing processes by the 

Office of the Chief Financial Officer and Office of Contracts and 

Procurement. We found that key duties and responsibilities associated 

with the sample transactions were divided (segregated) among different 

staff members so that no one person could both approve and fully execute 

a transaction. Moreover, we found that key documents, such as requisition 

and purchase orders, were authorized and executed by staff members 

acting within the scope of their authority, and that the documents 

supported the purpose and amount of the transaction. However, in 

conducting our tests, we found three instances worth discussion. These 

involved the need for sufficient documentation, better adherence to 

operating procedures, and greater control over physical assets.

The first instance involved documentation that did not fully describe the 

transaction and a negotiable asset that was potentially vulnerable to misuse 

or fraud. In the transaction we tested, CFSA had recorded an obligation in 

the emergency support fund in the amount of $9,375 for the purchase of gift 

cards to be used to purchase clothing for foster children. The transaction 

was part of a requisition that totaled about $99,000 for the purchase of gift 

cards from several vendors. While the approval of the gift card purchase 

was adequately documented, it was unclear whether the gift cards were 

ever received because the District did not provide us documentation of 

their receipt of the cards during the time of our review. We were also 

unable to determine, based on District records, whether the District had 

paid for the cards. District officials told us that the gift cards had been 

received, paid for, and had not been activated for use. However, without an 

invoice or receiving document, we could not verify that the gift cards were 

20The sample was selected based on a dollar-unit sampling methodology which, by its 

nature, will tend to select large dollar unit items. See appendix I for statistical sampling 

details.

21We are 95 percent confident that the upper error limit overstatement of obligation 

transactions with ineffective controls is not more than $1.2 million. This estimate does not 

exceed the tolerable amount in error of $2.0 million.
Page 15 GAO-05-787 District of Columbia

received or paid for, or whether the cards had been activated. In its 

comments on a draft of this report, CFSA provided additional 

documentation, including the vendor invoice and financial system reports 

showing receipt of the gift cards and the payment made. 

While gift cards provide the flexibility to respond quickly to emergency 

needs, adequate documentation and sufficient physical controls are 

essential to provide accountability over their use and to ensure the 

propriety of transactions. Gift cards, similar to cash, can easily be used for 

improper purchases—such as purchases excessive in cost, for purposes 

other than that stated, or for personal use. Purchased gift cards need to be 

properly inventoried and stored, similar to the cash in an imprest fund.22 

When the gift cards are distributed, the number and dollar amount of the 

cards taken from the inventory should be noted as should the identities of 

the employees who received the cards. Employees should be required to 

provide receipts for items purchased with gift cards. Periodic surprise 

audits of the gift card funds would also help to safeguard the gift cards 

inventory. In its comments on a draft of this report, CFSA described its 

procedures to track, monitor, and manage the distribution process of the 

gift cards, including several actions recently taken and planned actions 

designed to improve procedures in this area. 

In the second instance, on September 28, 2004, DMH generated and issued 

a purchase order for professional consulting services in the amount of 

$221,637; however, a detailed contract was not executed until February 2, 

2005. District officials told us that, according to operating procedures, 

there should have been an approved purchase order and signed contract 

before obligating funds. However, in order to obligate funds by September 

30, 2004, the District told us that they issued a purchase order to which the 

consultant agreed and both parties agreed to finalize the contract later. 

District officials told us that they believe they had a valid obligation based 

on the approved purchase order as agreed to by the vendor, provided the 

vendor could meet all the detailed requirements specified in the purchase 

order. They further explained that during the months following the 

recording of the obligation, DMH officials negotiated the final detailed 

deliverables with the vendor and signed the contract in February 2005. 

22An imprest fund is a fixed-cash or petty cash fund in the form of currency or coin. The 

funds are charged against a government appropriation by an agency official and advanced to 

an authorized cashier. The fund may be revolving, replenished to the level of a fixed amount 

as spent or used, or stationary such as a change-making fund. 
Page 16 GAO-05-787 District of Columbia

However, the District did not provide us with evidence that the vendor 

agreed to the purchase order. This type of procurement procedure 

increases the risk that the District might lose obligated funds if it were to 

later determine that the vendor could not meet the requirements indicated 

in the purchase order. While the purchase order could be later cancelled, 

expiration of the funds would prevent their reobligation. This type of 

practice increases the risk to DMH that it may improperly record an 

obligation where no binding agreement may exist at the time of recording 

the obligation, as required by 31 U.S.C. § 1501(a). See 34 Comp. Gen. 459 

(1955).

Finally, a vendor’s invoice billed the District for 248 laptop computers. 

Initial documentation provided to us by CFSA showed a handwritten 

notation on the invoice by the head of CFSA’s Information Technology 

branch acknowledged receipt of only 247 computers at a cost of $510,796. 

District officials could not provide documentation to support the number 

of computers received. Thus, we could not verify the number actually 

received. Additional documentation provided with CFSA’s comments on a 

draft of this report show that the agency purchased 247 computers with the 

federal funds for foster care improvements and 1 computer with local 

funds, for a total of 248 laptop computers. While we did not test the 

physical control environment at the District, our Standards of Internal 

Control requires agencies to establish physical control to secure and 

safeguard vulnerable assets to establish accountability, and to properly 

record transactions. 

We did not conduct detailed tests of transactions at COG because those 

transactions were included in COG’s financial statement audit performed 

by an independent public accounting firm who audits COG’s financial 

statements annually. COG received an unqualified, “clean,” opinion for 

fiscal years ended June 30, 2004, and June 30, 2003. In COG’s 2004 

financial statements, the Foster Care Improvements federal funding of 

$1.1 million was recorded in the supplementary information—Project 

Statement of Revenues, Expenditures, and Changes in Net Assets—and 

audited as part of the financial audit. Furthermore, the independent auditor 

did not identify any internal control weaknesses over financial reporting 

and operations or any instances of noncompliance for purposes of the 

reports on internal controls and compliance that are required by 

Government Auditing Standards.

23 

23GAO-03-673G.
Page 17 GAO-05-787 District of Columbia

New Programs Have 

Been Implemented to 

Improve Foster Care, 

but Challenges Remain

CFSA, DMH, and COG have implemented the programs and initiatives 

specified in the appropriations act and spending plans, and some foster 

families have received needed services. CFSA began its early intervention 

program a few months later than it had planned. Nonetheless, funds from 

this program, as well as the emergency support program funds have 

provided needed services to some families. CFSA also established a 

student loan repayment program, developed an information technology 

plan, and provided laptops to some caseworkers. DMH increased the 

mental health services available to foster care children, and COG and 

FAPAC worked together to develop a respite program. 

However, it is too early to assess the effectiveness of some programs, and 

challenges remain for others. The long-term effectiveness of the early 

intervention and student loan programs cannot yet be assessed and the 

information technology improvements have not been completed. 

Furthermore, challenges remain that could affect the success of CFSA’s 

emergency support fund initiative, as well as DMH’s ability to build 

capacity to provide needed assessments and to secure long-term funding 

for treatment. Also, the future success of COG’s respite program depends 

on some factors beyond the organization’s control.

Implementation of the Early 

Intervention Program Was 

Delayed, Nevertheless 

Needed Services Were 

Provided to Some Families 

The early intervention program included two key components—the 

Facilitated Family Team Meeting (FFTM) initiative and funds for various 

services and supports. According to agency officials, the FFTM initiative is 

the core of the program. These meetings are intended to give families a 

voice in decisions about removing a child from the home or changing his or 

her placement. CFSA planned to begin holding meetings in the summer of 

2004, but implementation was delayed until September. CFSA officials 

stated that much of the delay was the result of time needed to train the 

parties involved in the program, including caseworkers, judges, and foster 

parents. CFSA operated a pilot program from September to December 

2004 for selected high-risk cases. In January 2005, CFSA began conducting 

FFTMs for all cases, and as of March 2005, CFSA had held 47 FFTMs for 85 

children. Based on the outcome of the FFTMs, CFSA officials are to assess 

the families’ needs and identify services and supports that may enable 

children to remain safely in their own homes or with their current foster 

families. Table 3 lists services and supports eligible for program funds. 
Page 18 GAO-05-787 District of Columbia

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

Program

Source: CFSA program data.

Program data show that as of April 2005, CFSA provided 207 services and 

supports to 151 families and 386 children with the early intervention 

program funds.24 Most of the services provided were related to housing 

needs such as rent, utility payments, and furniture, as shown in figure 1. 

Category Eligible services/supports

Social services • Substance abuse treatment

• Intensive, home-based services, such as but not limited to: 

parenting support, behavioral management, homemaker 

services, crisis intervention, and or medical/behavioral support 

• Job training and support

Support services • Equipment to care for disabled children

• Temporary transportation of children

• Temporary child care

• Temporary food assistance

• Furniture

• Clothing 

Housing • A one-time security deposit or up to 3 months of rental 

assistance

• Temporary assistance with utility bills

• Lead abatement

• Home repair or maintenance

Special services • Individualized services that do not fall into one of the categories 

above but that are necessary to minimize trauma for the children

24CFSA transferred $75,000 from this fund to DMH for the Mobile Response and Service 

Stabilization (MRSS) program. The MRSS program provides services to manage crises and 

prevent children from moving from their biological family or a kinship caregiver into foster 

care.
Page 19 GAO-05-787 District of Columbia

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

Intervention Program Funds

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

truck.

The early intervention program has been operating for several months, but 

officials said that the effectiveness of the program cannot yet be 

determined. Agency officials said that CFSA has developed a tracking 

system to follow the progress of FFTM participants and will have data to 

determine whether the program has reduced the number of children 

coming into CFSA’s care or the number of times a child’s placement is 

changed. 

Source: GAO analysis based on CFSA program data.

34.3%

25.1%

24.6%

15.9%

Utility

(71 of 207)

Rent

(52 of 207)

Furniture

(51 of 207)

Other

(33 of 207)
Page 20 GAO-05-787 District of Columbia

Emergency Support Fund 

Provided Critical Services, 

but the Number of 

Unlicensed Homes 

Remained the Same

One goal of the emergency support fund is to help facilitate the licensing of 

family members who are willing to provide kinship homes25 to care for 

children who would otherwise go into traditional foster homes or 

congregate care.26 According to CFSA officials, the funds could be used to 

help homes meet established standards by paying for expenses such as lead 

abatement, home repairs, and renovation. In addition, the funds could be 

used to purchase services and items such as child care services or clothing, 

as well as to provide housing assistance in the form of monthly rent (not 

more than three months) or one-time security deposits. 

Although efforts to advertise the funds were limited, several families 

learned about and received services from this program. Kinship families 

learned about the availability of funds through information provided by 

caseworkers, word of mouth from other parents, and announcements in 

FAPAC’s newsletters for foster parents. As of April 2005, 99 families and 

189 children had been helped by the emergency support fund and 152 

services had been provided. Furniture, rent, and utility assistance were 

most often provided; however, families received other services as shown in 

figure 2. FAPAC officials said that the program has been helpful and 

beneficial in helping kinship foster families become and remain licensed 

foster families.

25Kinship homes are those in which a relative or unrelated person with long-standing ties to 

the child provides care for a child that has been neglected, abused, or is at risk for neglect 

and abuse.

26Congregate care homes include group homes, independent living placements (ILPs), and 

therapeutic facilities. Group homes provide services to children in large family-type 

settings, ILPs are monitored apartments for teens who are preparing to live independently, 

and therapeutic facilities offer specialized medical and mental health care for children and 

teens. Congregate care facilities are designed to provide placement for children who have 

not done well in the family setting or for those awaiting placement with traditional foster 

families. 
Page 21 GAO-05-787 District of Columbia

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

Support Funds 

Note: The “other” category includes a wide variety of services such as home repairs, summer camp, 

CPR/First Aid Certification, vehicle repairs, clothing, and day care services.

While the emergency support fund has assisted some families, the number 

of unlicensed homes has not changed in the last year. We previously 

reported27 that CFSA had taken a number of steps to ensure that children 

are placed in licensed homes, but as of May 2004, 495 children, or 22 

percent of the children in CFSA’s care, were in 308 unlicensed homes. At 

that time, CFSA officials told us that the majority of unlicensed homes 

entered the foster care program before new licensing standards were 

issued, many were kinship homes, and many homes were located in 

Maryland. Agency officials also said that CFSA was working to correct this 

situation by examining these homes on a case-by-case basis to identify the 

specific barrier each home faced in becoming licensed and, if possible, to 

resolve the issue. As of April 30, 2005, CFSA had children in 309 unlicensed 

homes. CFSA officials explained that most of the unlicensed homes were 

27GAO-04-1017.

Source: GAO analysis based on CFSA program data.

14.5%

19.7%

22.4%

33.6%

9.7%

Utility

(22 of 152)

Rent

(30 of 152)

Furniture

(34 of 152)

Other

(51 of 152)

One time room and board payment

(15 of 152)
Page 22 GAO-05-787 District of Columbia

not kinship homes and therefore federal funds were not available to 

facilitate licensing of these homes. 28 Further, according to CFSA officials, 

most of the unlicensed homes were in other jurisdictions—232 in Maryland 

and 33 in other states. CFSA, like child welfare agencies in other 

jurisdictions, is faced with challenges when trying to ensure the quality of 

homes outside their respective jurisdiction. When children are placed in 

homes in other jurisdictions, the home study process29 is complicated 

because the two states’ laws and policies must be taken into consideration 

and there must be coordination between the jurisdictions. The Interstate 

Compact on the Placement of Children30 is the bridge that facilitates this 

process by providing a legal and administrative framework for placing 

children across state lines for foster care or adoption. However, concerns 

have been raised by state child welfare officials about the timeliness of 

home studies and the quality of background checks done by staff in other 

jurisdictions. 

Most Eligible Caseworkers 

Participated in the Student 

Loan Repayment Program, 

but More Could Have Been 

Supported 

About 70 percent of CFSA’s eligible caseworkers participated in the student 

loan repayment program and most were approved for payments of more 

than $10,000. CFSA determined that only those caseworkers who managed 

cases were eligible to apply for the program. As of August 2004, CFSA had 

310 caseworkers, and according to agency officials, 190 of them managed 

cases. CFSA officials reported that 138 of its 190 caseworkers and nine of 

its contractors signed student loan repayment agreements. Most program 

participants, 99, had fewer than 3 years of service and 48 had 3 years or 

more of service. The repayment amounts ranged from about $3,000 to 

about $18,000 with the average at about $15,000. According to CFSA 

documents, the first payment will be made in July 2005 for those who have 

28CFSA issues temporary licenses to kinship homes in the District; therefore, these homes 

are counted as licensed.

29A home study is the process of assessing and preparing families to determine their 

potential to become either foster or adoptive parents.

30Interstate Compact on the Placement of Children (ICPC) is a uniform law, enacted in all 50 

states, the District of Columbia, and the U.S. Virgin Islands, that governs the interstate 

placement of children in foster and adoptive homes. Under ICPC, the state from which a 

child is sent retains jurisdiction over the child and his or her placement. ICPC ensures that 

children placed from one state into another receive adequate protections, services, and 

supervision.
Page 23 GAO-05-787 District of Columbia

met the service requirements.31 Figure 3 summarizes the distribution of 

these loans.

Figure 3: Distribution of Student Loan Repayment Amounts 

Although 138 of 190 caseworkers were approved for loan repayments, 

more could have been supported with the funds available. At the end of the 

fiscal year, CFSA had about $408,000 remaining of the $3 million designated 

for the program. CFSA could have entered into agreements with more than 

40 caseworkers with bachelor’s degrees in social work (BSW) or more than 

20 with master’s degrees in social work (MSW) or some combination of 

both. According to agency officials, the agency took several steps to make 

certain that all eligible caseworkers were aware of the program, and they 

modified the program in an effort to maximize participation. CFSA 

31According to the terms of the program, CFSA pays one-half of the repayment amounts at 

the end of the caseworkers’ 3rd year and the remaining half at the end of the 4th year. Those 

with more than 4 years of service must agree to remain with the agency at least 1 more year.

0

20

40

60

80

100

120

 

$15,001 - 18,000

$10,001 - 15,000

$5,001 - 10,000

$5,000 or less

Number of caseworkers

Source: GAO analysis based on CFSA program data.

4

17

102

24
Page 24 GAO-05-787 District of Columbia

launched the program in June 2004. CFSA advertised the program through 

weekly e-mail messages to all caseworkers, distributed flyers, printed 

notifications in an agencywide newsletter, posted fact sheets on the 

District government’s intranet, and placed notices in local newspapers, 

including the Washington Post. CFSA extended the application deadline 

by a month and increased the maximum amount of the loan repayment 

from $5,000 to $10,000 for caseworkers with BSWs and from $10,000 to 

$18,000 for those with MSWs. As the program is structured, if a caseworker 

who was approved to receive a loan repayment leaves CFSA before the end 

of his or her commitment, the agency will have to return the funds to the 

U.S. Treasury. Agency officials said that one reason more caseworkers did 

not participate in the program was their hesitance to commit to working for 

CFSA on a long-term basis. In commenting on a draft of the report, agency 

officials also said that all of the funds for the student loan repayments were 

not used because the agency could neither advertise the program nor enroll 

participants until after March 2004 when the funds were made available, 

which was after the height of its spring recruitment season at colleges and 

universities. 

Even with this program, attrition rates at CFSA increased. Like other child 

welfare agencies, CFSA has faced ongoing challenges in efforts to retain 

caseworkers. In fiscal year 2003, CFSA’s attrition rate for caseworkers was 

about 15 percent. In fiscal year 2004, the rate had increased to about 18 

percent. In our September 2004 report,32 we found a consensus among the 

caseworkers we interviewed that deficiencies in CFSA’s management 

practices33 hindered their performance and lowered their morale. In that 

report, we recommended changes to CFSA management practices. CFSA 

generally agreed with our recommendations and developed a work plan 

that included strategies to help retain qualified caseworkers. We have not 

assessed whether the agency has begun to implement the 

recommendations. Although the attrition rate has increased, it is too soon 

to tell whether the student loan repayment program will be effective in the 

long-term, particularly since all participants had to remain at CFSA at least 

until July 2005. 

32GAO-04-1017. 

33Deficient management practices cited were poor communication, a lack of resources, poor 

supervision, and no program for rewards and recognition.
Page 25 GAO-05-787 District of Columbia

Implementation of CFSA’s 

Information Technology 

Plan Is Not Yet Completed 

CFSA developed an information technology plan to upgrade its child 

welfare information system, known as FACES, to a Web-based system. 

The information technology plan indicates that the FACES software 

upgrade component is scheduled to be completed in December 2005. In 

addition, the contractor may provide maintenance and support services for 

the new system through September 29, 2008. Table 4 summarizes the key 

steps in the plan and the related time frames.

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

Source: CFSA program data.

Also, CFSA’s information technology plan includes the purchase of laptops 

for its caseworkers. These laptops are intended to help improve 

caseworkers’ productivity and effectiveness because caseworkers can 

enter case information data when away from the office. According to the 

spending plan, CFSA would initially purchase laptops for 75 percent of its 

caseworkers and in phase two, laptops would be purchased for the 

remaining 25 percent who had less critical need for field access. However, 

it is not clear when all caseworkers will receive laptops because the date 

for beginning of phase two is not listed in either the spending plan or the 

information technology plan and CFSA officials could not provide a date 

for this phase. 

CFSA purchased and received the initial order of laptops as planned, but 

the distribution process has taken months. The final contract, signed on 

September 29, 2004, allowed for CFSA to purchase laptops and related 

services at a cost of about $2,000 per laptop. On January 27, 2005, 

documents showed that 247 laptops had been purchased with federal 

funds—9 for FFTM caseworkers that manage the early intervention 

Task Planned initiation Planned completion

Consulting contract for FACES software 

upgrade

3/30/04 12/20/05

Web application servers and hardware 9/20/04 12/20/05

Web development software 9/20/04 12/20/05

Staff training and materials 9/20/04 12/20/05

Purchase laptops for social workers 5/28/04 9/30/04

Security enhancements 9/20/04 12/20/05

Business continuity enhancements 7/15/04 9/30/04
Page 26 GAO-05-787 District of Columbia

program and the remaining 238 to be distributed among CFSA’s 310 

caseworkers. According to CFSA officials, as of May 2005, 119 laptops had 

been issued to caseworkers and they expected that all laptops would be 

distributed by June 2005. CFSA explained that distribution was delayed 

because initially the laptops did not meet the requested memory 

specifications. CFSA further explained that after the contractor replaced 

the memory modules, the agency had to load the software before the 

laptops were distributed. 

Mental Health Assessments 

and Treatments Were 

Provided, but DMH Faces 

Ongoing Challenges 

DMH provides assessments for children referred to the agency by CFSA 

and the Family Court. From August 2004 through February 2005, DMH 

reported completing 351 assessments of foster care children referred by 

CFSA. During the same period, CFSA increased the number of cases 

referred to DMH for assessment from 15 in August 2004 to 68 in February 

2005, for a total of 292 referrals over the 7-month period.34 According to 

DMH officials, this sharp increase in referrals has raised the average 

number of days to complete an assessment—beginning with the 

appointment request and ending with the delivery of a report to the Family 

Court—above the statutory time frame of 23 days as indicated in the 

appropriations act.35 DMH reviewed 82 cases completed from August 2004 

through February 2005 and found that their evaluators took an average of 

33.5 days—approximately 10 days longer than the statutory time frame—to 

complete assessments. According to DMH officials, some cases increased 

the average time frame for completion. For example, one case took 192 

days. However, officials also acknowledged that the remaining 

assessments, while sometimes taking as little as 1 day to complete, were, 

on average, not being completed within the statutory time frame.

Since our September 2004 report, DMH has continued to build its capacity 

to provide treatment to foster care children referred by CFSA.36 DMH has 

increased the number of outside providers it has certified to deliver 

34CFSA contractors continued to provide some needed assessments. From August 2004 

through February 2005, approximately 40 percent of referrals for assessments were sent to 

CFSA contractors.

35These time frames require DMH to initiate services within 3 days of notification, complete 

assessments within 15 days of the request, and provide the Family Court with assessments 

within 5 days of completion. 118 Stat. 116.

36GAO-04-1017.
Page 27 GAO-05-787 District of Columbia

treatment to foster care children from 13 in September 2004 to 20 in 

February 2005. From August 2004 through February 2005, CFSA referred 

430 cases to providers in the DMH network. In January 2005, DMH 

providers began delivering three new types of treatment to foster care 

children, (1) multisystemic therapy, (2) intensive home- and communitybased services, and (3) mobile response and stabilization services.37 DMH 

previously anticipated that 300 to 500 children would receive these three 

types of treatment within 1 year of the date of the signed agreements with 

providers.38 Agreements for these treatment services were signed in late 

September 2004. As of April 2005, 3 months into implementation of the 

new types of treatment, 31 children had received multisystemic therapy, 37 

had received intensive home- and community-based services, and 24 had 

received some type of mobile mental health services (see table 5). 

According to a DMH official, the department expects 300 children to 

receive services by January 2006.

Table 5: Foster Care Children Receiving Mental Health Treatment 

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

In addition to adding providers and new types of treatment, DMH began its 

initiative to train providers in trauma treatment in March 2005. The first 

phase of this initiative included a baseline assessment of whether providers 

37Multisystemic therapy is treatment delivered in homes and the community for foster care 

youth with complex clinical, social, and educational problems. Intensive home- and 

community-based services are provided by a team of professionals and are available 24 

hours a day and 7 days a week. The mobile response and stabilization services are provided 

at the site of a child’s escalating behavior.

38GAO-04-1017.

Number of foster care children served

Mental health treatment As of April 2005 Anticipated by January 2006

Multisystemic therapy 31 64 to 96

Intensive home- and 

community-based 

services

37 72 to 90

Mobile response and 

stabilization services

20 calls (emergency

assistance)

4 families (stabilization)

12 to 14 calls per week (emergency

assistance)

up to 10 cases at one time

(stabilization)
Page 28 GAO-05-787 District of Columbia

use treatment practices that reflect current research. In the second phase, 

DMH began offering training sessions on those treatment practices for 

DMH’s certified providers.

DMH faces ongoing challenges in building the mental health system’s 

capacity to provide timely assessments and in securing long-term funding 

for treatment services for foster care children. As of April 2005, DMH 

officials reported that it did not have the capacity to respond to the growing 

number of referrals for assessments from CFSA.39 To address this issue, 

DMH officials stated that the agency was expanding its current contracts 

with providers and recruiting new providers. However, according to DMH’s 

director, meeting the demand for assessments will remain an ongoing 

concern. With regard to treatment, DMH is in the process of securing longterm financing for the new services implemented with the federal funds. 

DMH officials stated that the agency can obtain funds for mobile response 

and stabilization through the District’s Medicaid program. 40 Officials also 

expect that, upon approval of a requested change to the Medicaid program, 

DMH will be able to obtain reimbursements for intensive home- and 

community-based services and mobile response and stabilization services. 

The director said that, even with the federal funds available through 

Medicaid, local funds may not be sufficient to meet the treatment needs of 

foster care children.

COG’s Respite Program Was 

More Challenging to 

Implement Than Expected 

COG, in conjunction with CFSA and FAPAC, developed a respite program 

for foster parents of the District’s children. Under this program, known as 

“Work of Heart,” COG recruited and trained families from the District and 

other surrounding jurisdictions to provide volunteer respite care. The 

program was designed to include overnight respite care provided by 

licensed foster parents, as well as daytime respite programs on Saturdays 

and Sundays provided by licensed organizations. 

39According to a Family Court official, the total number of cases being referred for 

assessments and other services has been constant since receipt of the federal funds in 

March 2004; however, the number being referred to DMH has increased.

40Medicaid is a jointly funded federal-state program that pays for medical assistance for 

certain low-income families and individuals who meet certain criteria. With federal 

approval, Medicaid will reimburse states’ expenditures for certain types of rehabilitative 

services such as community-based treatment.
Page 29 GAO-05-787 District of Columbia

COG used various avenues to recruit parents to serve as respite providers 

and made several efforts to inform foster parents about the respite 

program. According to agency officials, to recruit respite providers COG 

staff attended 10 community fairs, made 11 presentations at churches and 

businesses, hosted bimonthly informational meetings, and explained the 

program to CFSA caseworkers. In addition, COG distributed more than 

50,000 recruitment brochures and flyers and advertised through local radio, 

local journals, and newspapers to recruit respite providers. COG also 

conducted outreach efforts to inform current foster families about the 

availability of respite services. They sent four mailings to all of CFSA’s 

foster families and instituted an application and approval process. Current 

foster parents had to complete the application and be approved in order to 

receive respite services. Furthermore, FAPAC officials coordinated the 

identification and approval of four licensed organizations to provide the 

daytime respite programs.

Some respite services have been provided; however, COG’s initial goal was 

not met. We reported in September 200441 that COG had set as its goal to 

provide 700 respite care placements by March 2005, but officials did not 

know how many parents would need to be licensed to reach that goal or 

how many children would need care. As of June 2005, 62 respite foster 

parents had been trained, and 7 had completed the licensing process. Also 

as of June 2005, 44 foster families and 86 foster children—their ages ranged 

from 6 months to 17 years of age—had been approved to receive respite. 

According to COG officials, six Saturday respite programs were held and 

106 children participated. For overnight respite, 26 placements were 

requested and 9 were completed as of June 2005. COG officials said that 

the other requests were cancelled by the foster parents for various reasons. 

COG’s initial plan did not adequately consider several factors that hindered 

the program’s implementation. For example, COG officials stated that the 

initial program goal was overly optimistic because it was based on a longrunning program operating in another state but did not account for 

differences between the District’s needs and demographics and those of 

that state. The COG officials also said that the District’s training 

requirements were longer than projected and some parents who were 

interested in serving as respite volunteers were hesitant to complete the 

lengthy application and licensing process. Furthermore, COG officials 

stated that a major barrier to the program was the 3 to 4 month waiting 

41GAO-04-1017.
Page 30 GAO-05-787 District of Columbia

period for FBI clearances, part of the licensing process. A COG official 

explained that they were working with the Washington FBI field office and 

the Metropolitan Washington Police Department to finalize a memorandum 

of understanding that could reduce the time for clearances to 4 to 5 weeks. 

While this step may help improve the process, the future success of the 

program depends on some factors beyond COG’s control such as the 

number of qualified people who volunteer to serve as respite providers and 

the number of foster parents who will participate. 

Concluding 

Observation 

CFSA, DMH, and COG have obligated federal funds for purposes intended 

by the Congress to address long-standing problems in the District’s foster 

care system. The agencies and COG appear to have exercised effective 

internal controls over the use of those federal funds. All programs called 

for in the legislation have been implemented to some degree, and services 

have been provided to some foster children and families in the District. As 

in child welfare systems across the country, the agencies and organizations 

working for the welfare of children in foster care face a complex set of 

challenges. Whether these programs are effective and help improve foster 

care in the District may not be known for several years. 

Agency Comments and 

Our Evaluation

We received written comments on a draft of this report from CFSA, DMH, 

and COG. These comments are reprinted in appendixes II, III, and IV, 

respectively. CFSA and FAPAC also provided technical comments, which 

we incorporated where appropriate. 

In commenting on a draft of this report, CFSA agreed in general with our 

findings and provided a number of comments and additional information. 

In response, we made several changes to the report. We revised the report 

to reflect the additional documentation provided by CFSA showing (1) 

receipt of the gift cards and the payment made and (2) the purchase of one 

additional laptop computer. CFSA also described its procedures to track, 

monitor, and manage the distribution of the gift cards, which we noted in 

the report. Also, we added a statement in the report explaining how the 

timing of the receipt of funding impacted CFSA’s ability to use all of the 

funds for the student loan repayment program and revised the information 

technology section of the report after receiving and reviewing an updated 

plan from CFSA. In addition, CFSA’s comments addressed the goals of the 

emergency support program and its unlicensed homes. CFSA stated that, 

while the emergency support funds were used to facilitate licensing of 
Page 31 GAO-05-787 District of Columbia

kinship homes, the primary goal of the emergency support program goal 

was to facilitate placement of children with kin. We did not revise the 

statement about the program goal, because the appropriations act and the 

related conference report state that the fund would be used to purchase 

items necessary to allow children to remain in the care of an approved 

licensed family member. With regard to its unlicensed homes, we revised 

the report to reflect some of the information provided by CFSA.

We also received written comments on a draft of this report from DMH that 

addressed information on delays in assessments and the department’s 

capacity to deliver treatment services. DMH generally agreed with our 

findings on the provision of assessments, but provided additional 

information on increases in referrals, delayed assessments, and initiatives 

to decrease the wait time for assessments. DMH also expressed the view 

that it has the capacity to utilize Medicaid funding for treatment services. 

We modified the report to reflect that DMH is in the process of securing 

long-term funding for treatment services.

In its comments, COG said that recruiting the families to provide respite 

has not been a challenge. COG also said that the challenge has been 

keeping volunteers’ level of enthusiasm through the arduous and lengthy 

licensing process. We modified the report to clarify that our conclusion 

included all aspects of the process associated with licensing respite 

providers. 

We will send copies of this report to the Director of CFSA, the Director of 

DMH, the Executive Director of COG, and the Chief Financial Officer of the 

District of Columbia. We are also sending copies to the Honorable Senator 

Michael DeWine, who was the Chairman of the Subcommittee on the 

District of Columbia Senate Committee on Appropriations when the act 

was passed that provided the federal funds; to appropriate congressional 

committees; and other interested parties. We will also make copies of this 

report available to others on request. In addition, the report will be 

available at no charge on GAO’s Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

Jeanette Franzel, Director, Financial Management and Assurance, at (202) 

512- 9471 or FranzelJ@gao.gov, or Cornelia M. Ashby, Director, Education, 

Workforce, and Income Security Issues, at (202) 512-8403 or 

AshbyC@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 
Page 32 GAO-05-787 District of Columbia

GAO staff that made major contributions to this report are listed in 

appendix V.

Jeanette Franzel

Director

Financial Management and Assurance

Cornelia M. Ashby

Director

Education, Workforce, and

Income Security Issues
Page 33 GAO-05-787 District of Columbia

Appendix I

Scope and Methodology ApApenednxidexiIs

To assess whether the federal funds were being obligated and expended by 

the Child and Family Service Agency (CFSA), Department of Mental Health 

(DMH) and the Metropolitan Washington Council of Governments (COG) 

consistent with the provisions in the District of Columbia Appropriations 

Act, 2004, and the spending plans that were submitted to the Congress, we 

interviewed District and COG officials responsible for overseeing, 

monitoring, and tracking the federal funds received for foster care 

improvements. We reviewed and analyzed the District and COG spending 

plans and budgets, and internal reports of obligations and expenditures. 

To determine whether internal controls are operating effectively, we 

interviewed financial and program personnel from CFSA, DMH, COG, and 

from the District government’s central Office of the Chief Financial Officer. 

We reviewed operating procedures and flowcharts to understand the 

procedures and controls over the use of the funds. To further understand 

the District’s processes for obligating and disbursing funds, we conducted 

walk-throughs of the procedures with CFSA and DMH financial officials.

We assessed the reliability of the District’s foster care obligations data by 

(1) reviewing existing documentation related to the data sources, 

(2) testing the data to identify obvious problems with completeness or 

accuracy, and (3) interviewing knowledgeable agency officials about the 

data. We determined that the data were sufficiently reliable for the 

purposes of this report. 

We selected a dollar-unit sample at a 95 percent confidence level of CFSA 

and DMH obligation transactions covering the period March 17, 2004, 

through September 30, 2004, totaling about $11.9 million from obligations 

of about $12.2 million to test specific control activities, such as segregation 

of duties, evidence of approving official review and approval, and adequacy 

of supporting documentation.1

We also reviewed contract files to validate that the responsible designated 

officials within the agency provided the appropriate budget authorizations 

to purchase and receive goods and services consistent with the 

appropriations act and whether the goods or services rendered were 

properly obtained and the quantity and quality of services were verified. 

1

We are 95 percent confident that the upper error limit overstatement of obligation 

transactions with ineffective controls is not more than $1.2 million. This estimate does not 

exceed the tolerable amount in error of $2.0 million.
Appendix I

Scope and Methodology

Page 34 GAO-05-787 District of Columbia

We did not conduct detailed tests of transactions for COG. An independent 

public accounting firm audits the financial statements of COG annually and 

the federal funds provided to COG were included in its fiscal year 2004 

audit. COG received an unqualified, “clean,” opinion for fiscal years ended 

June 30, 2004, and June 30, 2003. COG’s fiscal year 2004 foster care 

improvements funds were recorded in the supplementary information to its 

fiscal year 2004 financial statements, specifically its Project Statement of 

Revenues, Expenditures, and Changes in Net Assets—and audited as part 

of the financial audit. Furthermore, the independent auditor did not 

identify any internal control weaknesses over financial reporting and 

operations or any instances of noncompliance for purposes of the reports 

on internal controls and compliance that are required by Government 

Auditing Standards.

2

 We did conduct walk-throughs of COG’s accounting, 

payroll, procurement, and payment processes. In addition, we obtained 

and analyzed the COG spending plans, and budget and financial documents 

related to their portion of the federal funds.

To assess the extent to which CFSA, DMH, and COG have implemented the 

foster care improvement programs and initiatives specified in the 

appropriations act and spending plans, we gathered and analyzed data from 

various sources. We interviewed agency officials from CFSA, DMH, COG, 

and Foster and Adoptive Parents Advocacy Center (FAPAC) that were 

responsible for each of the programs and initiatives. Several of these 

officials also responded via e-mail to several questions regarding the 

program. In addition, officials from CFSA, DMH, and FAPAC prepared 

written statements for congressional hearings that addressed these 

programs, and we obtained and analyzed these statements. We reviewed 

program policies, protocols, and plans as well as the legislation and the 

spending plans. Generally, the legislation or the plans identified CFSA’s 

goals and desired outcomes for the programs. Data on the number of 

participants in the student loan repayment program was as of September 

2004, which was the deadline for the program. We obtained program 

information on the status of the other programs as of April 2005 or June 

2005. This information included budget documents, expenditure reports, 

and data on services provided to children and families. We compared this 

information to the programs’ plans and goals in order to assess the extent 

to which the programs and initiatives were implemented, achieved 

established goals, or led to other outcomes. 

2

GAO-03-673G.
Appendix I

Scope and Methodology

Page 35 GAO-05-787 District of Columbia

We took several steps to assess the reliability and reasonableness of 

program data and found the program data to be reasonable and sufficiently 

reliable for the purposes of providing information on the status of the 

programs and initiatives supported by the federal foster care improvement 

funds provided in fiscal year 2004. To assess the data on the services 

provided by the early intervention program and emergency support fund, 

we interviewed officials responsible for compiling the data and compared it 

to relevant financial transaction records. We did not contact individual 

families to determine whether they received the services or products, but 

we asked officials from FAPAC about the foster and adoptive parents’ 

views about the programs in general and the services provided. To 

evaluate the student loan repayment data, we interviewed program officials 

and compared the data to the numbers previously reported by CFSA and 

determined that the various subcategories—such as the number of 

participants by loan repayment amounts and by years of service—equaled 

the total. We also compared the totals to the financial obligations but could 

not compare the data to individual payments because CFSA had not made 

any payments to caseworkers as of the date of our review. To corroborate 

the data on mental health services provided to foster care children reported 

by DMH, we interviewed the officials from the department who were 

responsible for compiling the data. In addition, we checked the reported 

data against information provided in DMH testimony before the Senate 

Committee on Appropriations, reports submitted to the U.S. District Court 

for the District of Columbia by the monitor of the District’s mental health 

system, DMH grant agreements, and data provided by CFSA. Finally, we 

interviewed Family Court officials to corroborate assessment time frames 

reported by DMH. Data on the respite program were generally provided by 

COG and corroborated by officials from FAPAC. Upon completion of these 

steps, we determined that the above-mentioned data were sufficiently 

reliable for the purposes of this report.

We conducted our work from October 2004 to June 2005 in accordance 

with U.S. generally accepted government auditing standards. 
Page 36 GAO-05-787 District of Columbia

Appendix II

Comments from the District’s Child and 

Family Services Agency ApendxiI
Appendix II

Comments from the District’s Child and 

Family Services Agency

Page 37 GAO-05-787 District of Columbia
Appendix II

Comments from the District’s Child and 

Family Services Agency

Page 38 GAO-05-787 District of Columbia
Appendix II

Comments from the District’s Child and 

Family Services Agency

Page 39 GAO-05-787 District of Columbia
Page 40 GAO-05-787 District of Columbia

Appendix III

Comments from the District’s Department of 

Mental Health ApendxiI
Appendix III

Comments from the District’s Department of 

Mental Health

Page 41 GAO-05-787 District of Columbia
Appendix III

Comments from the District’s Department of 

Mental Health

Page 42 GAO-05-787 District of Columbia
Page 43 GAO-05-787 District of Columbia

Appendix IV

Comments from the Metropolitan Washington 

Council of Governments ApendxiIV
Page 44 GAO-05-787 District of Columbia

Appendix V

GAO Contacts and Staff Acknowledgments ApendxiV

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

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

Staff 

Acknowledgments

The following individuals also made important contributions to this report: 

Norma Samuel, Carolyn Taylor, Carolyn Yocom, Susan Barnidge, Sharon 

Byrd, Jacquelyn Hamilton, Maxine Hattery, Deborah Peay, Vernette Shaw, 

and Sandra Silzer.

(194500)
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