CHILD WELFARE

Steps Have Been 

Taken to Address 

Unregulated Custody 

Transfers of Adopted 

Children

Report to Congressional Requesters

September 2015

GAO-15-733

United States Government Accountability Office
Highlights of GAO-15-733, a report to 

congressional requesters

September 2015

CHILD WELFARE

Steps Have Been Taken to Address Unregulated 

Custody Transfers of Adopted Children

Why GAO Did This Study

Parents have the legal responsibility to 

protect and care for their children. 

However, recent media reports have 

illuminated a practice involving 

unregulated custody transfers of 

adopted children. Commonly referred 

to as “rehoming,” this practice involves 

parents who turn to the internet or 

other unregulated networks to find a 

new home for their child. These media 

reports found instances in which 

adopted children were placed in 

dangerous situations where they were

harmed by the adults who received 

them. GAO was asked to review issues 

related to unregulated transfers of 

adopted children.

GAO examined (1) the reasons 

adoptive families consider unregulated 

child custody transfers, and services 

that exist to support these families

before they take such an action; (2) 

what is known about the prevalence of 

these transfers; and (3) actions 

selected states and federal agencies 

have taken to address such transfers. 

GAO reviewed relevant federal laws, 

regulations, and policies and selected 

state laws and proposed legislation. 

GAO also interviewed officials from 

federal agencies, 19 child welfare and

adoption organizations, 15 adoption 

agencies, and 7 states selected 

primarily because of legislative activity

on unregulated transfers. GAO also 

searched online activity on selected 

social media sites to find illustrative 

examples of families who may be 

considering unregulated transfers.

The Departments of Health and 

Human Services, Homeland Security, 

and State provided technical 

comments. The Department of Justice 

had no comments.

What GAO Found

Some adoptive families may consider giving their children to another family 

outside of the courts and child welfare system—an “unregulated child custody

transfer”—because of a crisis within the adoptive family and difficulties accessing 

support services, according to officials GAO interviewed from selected states, 

child welfare and adoption organizations, and adoption agencies. Children 

adopted internationally or from foster care may need special care or counseling 

because of a history of institutionalization and trauma. Some parents, particularly 

those who adopted internationally, may not be prepared to deal with their 

adopted child’s complex needs. Federal regulations require agencies facilitating

international adoptions to provide parents with at least 10 hours of pre-adoption 

training. In contrast, about half of the states require agencies facilitating foster 

care adoptions to provide at least 27 hours of training, according to data obtained 

from Department of Health and Human Services (HHS) officials in May 2015. 

Many officials said adoptive parents may experience challenges finding mental 

health services for their families, such as therapists familiar with adoption issues. 

Many officials also said parents who adopt children with more severe needs may 

have difficulty finding and paying for intensive services such as residential 

treatment, which can cost thousands of dollars per month. Officials said these 

challenges may lead families to seek out unregulated transfers.

Little is known about the prevalence of unregulated transfers. Because they

happen without any oversight, these transfers are difficult to track and no federal 

agency keeps statistics on their occurrence. GAO’s observations of social media 

sites found that some parents have been using online forums to seek new homes 

for their adopted children. During a 15-month period, GAO identified 23 instances 

in which a parent posted that they were seeking a new family for their child.

Because GAO did not investigate these posts and because discussions between 

online participants can be continued privately, GAO was unable to determine 

whether these participants intended to pursue a legal placement or an 

unregulated transfer, or whether such a transfer actually took place.

Selected states and federal agencies have taken some steps to address 

unregulated transfers. GAO identified at least 15 states in which there was 

legislative and other activity in recent years intended to address these transfers. 

Seven of the 15 states had enacted legislation and 3 made changes to state child

welfare programs as of July 2015. The most common approaches were

criminalizing unregulated transfers or actions that may lead to these transfers,

and restricting the advertisement of children for placement. In addition, activity in 

several states involved improving post-adoption services, which many officials 

said was a key need for families who resort to unregulated transfers. However,

federal officials and others said addressing service needs can be difficult and 

time-consuming, and funding for these services is limited. At the federal level, 

several agencies established an interagency working group on unregulated 

transfers in October 2013. Officials from the Department of State said they plan

to revise international pre-adoption training requirements that may include an 

increased number of minimum hours. HHS issued a memorandum in May 2014 

encouraging states to promote post-adoption services and to review their policies 

to address unregulated transfers.

View GAO-15-733. For more information, 

contact Kay E. Brown at (202) 512-7215 or 

brownke@gao.gov.

United States Government Accountability Office
Letter 1

Background 5

Families May Choose an Unregulated Child Custody Transfer Due 

to an Adoption in Crisis and Challenges Accessing Services 16

Little Is Known about the Prevalence of Unregulated Transfers 26

Selected States and Federal Agencies Have Taken Some Steps 

to Address Unregulated Transfers 30

Agency Comments and Our Evaluation 41

Appendix I Objectives, Scope, and Methodology 43

Interviews of Child Welfare and Adoption Stakeholders 43

Review of Federal and Selected State Laws, Regulations, and 

Policies 46

Literature Search 46

Searches of Online Forums on Selected Social Media Sites 47

Appendix II GAO Contact and Staff Acknowledgments 48

Tables

Table 1: Summary of Federal Funding Available to States for 

Adoption Services, Fiscal Year 2015 10

Table 2: Pre-Adoption Training Requirements in GAO’s Seven 

Selected States, Reported as of July 2015 19

Table 3: Activity in the 15 States GAO Reviewed to Address 

Unregulated Child Custody Transfers, as of July 2015 30

Table 4: Approaches to Address Unregulated Child Custody 

Transfers in the 15 States GAO Reviewed, as of July 

2015 32

Table 5: Examples of Actions Taken by Federal Agencies and 

Their Partners to Address Unregulated Child Custody 

Transfers, as of July 2015 37

Figure

Figure 1: Number and Age of Internationally Adopted Children, 

Fiscal Years 2004 through 2013 14

Contents

Page i GAO-15-733 Unregulated Child Custody Transfers
Abbreviations

HHS Department of Health and Human Services 

Justice Department of Justice 

MAPP Model Approach to Partnerships in Parenting 

PRIDE Parent Resources for Information, Development, 

and Education

State Department Department of State

USCIS U.S. Citizenship and Immigration Services 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately.

Page ii GAO-15-733 Unregulated Child Custody Transfers
441 G St. N.W.

Washington, DC 20548

September 16, 2015

The Honorable Lloyd Doggett

Ranking Member

Subcommittee on Human Resources

Committee on Ways and Means

House of Representatives

The Honorable Jim Langevin

House of Representatives

Recent media reports have illuminated a practice involving transfers of 

adopted children to new homes outside of the courts or child welfare 

system. Commonly referred to as “rehoming,” this practice involves 

parents who turn to the internet or other unregulated networks to find new 

homes for their children.1 These media reports highlighted cases of 

parents of adopted children who engaged in these unregulated child 

custody transfers because they were unable or unwilling to meet the 

complex emotional and behavioral needs of their children. The reports 

found that unregulated transfers occurred without background checks of 

the new families, and that in some instances, children were placed in 

dangerous situations without the knowledge of child welfare officials or 

other authorities. For example, one media report found that a child was 

placed in a home with an adult convicted of possessing child 

pornography. Another media report described a case where two young 

girls adopted from foster care were placed by their adoptive parents in the 

home of a family friend. One of the adults in the new home was 

subsequently convicted of sexually assaulting one of the girls, according 

to the media report.

In some instances, parents used online forums on social media sites to 

seek new homes for their children, according to media reports. For 

example, Reuters News reported following a bulletin board on such a site 

1

Following the media reports, the term “rehoming” became widely used to describe the 

behavior of parents seeking new homes for their children, biological and adopted, outside 

the purview of the courts or the public child welfare system. For the purposes of our 

report, we refer to rehoming as an unregulated child custody transfer and we focused on 

how this practice relates to adopted children. 

Letter

Page 1 GAO-15-733 Unregulated Child Custody Transfers 

 
for 5 years during which new homes were sought for 261 adopted 

children. It found that at least 70 percent of these children had been 

adopted internationally. The remaining children were adopted 

domestically from foster care or through private adoption agencies and 

other means, such as private attorneys.

Parents have a legal responsibility to protect and care for their children, 

and unregulated transfers can put children in dangerous situations when 

they are placed with unfit adults. While many requirements related to child 

welfare and adoptions are determined by states, federal law requires 

states to establish systems for reporting and responding to cases of child 

abuse and neglect.2 Several federal agencies may also play a role with 

respect to children who could be subject to unregulated transfers. The 

Department of State (State Department) conducts some oversight 

activities for international adoptions (also called intercountry adoptions), 

including serving as the U.S. Central Authority for the Hague Adoption 

Convention,3 collecting data on children adopted into the United States, 

and setting requirements for agencies that want to be accredited to 

conduct international adoptions. The Department of Homeland Security’s 

U.S. Citizenship and Immigration Services (USCIS) issues federal 

regulations, forms, and policy guidance related to international adoption 

and adjudicates immigration applications. The Department of Health and 

Human Services (HHS) oversees federal programs that support child 

2

As a condition of receiving federal funding under the Child Abuse Prevention and 

Treatment Act, as amended, states must comply with these and other requirements. See 

42 U.S.C. § 5106a(b)(2). The Act defines child abuse and neglect as, at a minimum, any 

recent act or failure to act on the part of a parent or caretaker, which results in death, 

serious physical or emotional harm, sexual abuse or exploitation, or an act or failure to act 

which presents an imminent risk of serious harm. 42 U.S.C. § 5101 note. Consistent with 

this definition, states define what constitutes abuse, neglect, abandonment, or exploitation 

of children. It is possible that parents could be charged under state laws if a child is 

harmed as the result of an unregulated child custody transfer.

3

The Hague Convention on Protection of Children and Co-operation in Respect of 

Intercountry Adoption (Hague Adoption Convention) is an international agreement to 

establish safeguards to ensure that international adoptions take place in the best interests 

of the child. The Intercountry Adoption Act of 2000 implements the Hague Adoption 

Convention in the United States by setting accreditation and other requirements for 

entities facilitating international adoptions of children from countries that are parties to the 

Convention. Pub. L. No. 106-279,114 Stat. 825 (codified at 42 U.S.C. §§ 14904-14954). 

The Intercountry Adoption Universal Accreditation Act of 2012 extends these requirements 

to entities facilitating international adoptions of children from countries that are not parties 

to the Convention. Pub. L. No.112-276, § 2, 126 Stat. 2466 (2013) (codified at 42 U.S.C. §

14925). 

Page 2 GAO-15-733 Unregulated Child Custody Transfers 

 
welfare services, including adoption support, and provides some financial 

assistance for certain adoptions, primarily from foster care. HHS also 

collects some data on children adopted from or relinquished to the child 

welfare system. However, requirements for domestic adoptions, including 

those from foster care, are generally set by individual states. The 

Department of Justice (Justice) is involved in enforcing applicable federal 

criminal laws to protect children and supporting law enforcement 

agencies in investigating child exploitation, internet crimes against 

children, or other relevant crimes.

You asked us to explore issues related to unregulated child custody 

transfers. This report examines:

1. the reasons adoptive families consider unregulated child custody 

transfers, and services that exist to support these families before they 

take such an action;

2. what is known about the prevalence of these transfers; and

3. actions selected states and federal agencies have taken to help 

address such transfers.

To address our objectives, we reviewed relevant federal laws, 

regulations, and policies; conducted a search of related literature; and 

conducted interviews with 45 agencies, states, and organizations to 

acquire a range of perspectives on this topic. Those we interviewed 

included officials from the State Department, USCIS, HHS, and Justice; 

representatives from 19 organizations that work on child welfare and 

adoption issues; officials from state child welfare and other relevant 

offices in 7 selected states; and representatives from 15 international and 

domestic adoption agencies. The 7 states selected for in-person and 

phone interviews were chosen based on factors such as the presence of 

legislative activity within the state related to unregulated transfers and a 

state’s post-adoption programs.4 These states are Colorado, Florida, 

Illinois, Louisiana, Ohio, Virginia, and Wisconsin. We reviewed relevant 

documents to corroborate information obtained in our interviews. In 

4

In this report, we define legislative activity within a state to include enacted laws as well 

as proposed legislation that has been introduced in the state legislature, even if not 

enacted. To identify states that had a variety of post-adoption programs, we asked 

representatives from child welfare and adoption organizations that we interviewed to 

identify states that, in their opinion, had comprehensive programs. 

Page 3 GAO-15-733 Unregulated Child Custody Transfers 

 
addition, we searched online forums on selected social media sites to find 

illustrative examples of families who may be considering unregulated 

transfers. These online forums focused on dissolutions of adoptions, 

behavioral challenges of adopted children, and related issues. We 

identified online activity on these forums, and reviewed materials that 

were posted over a 15-month period (January 1, 2014, through April 1, 

2015). The online posts we identified did not provide sufficient information 

to determine whether the posters intended to pursue an unregulated 

transfer, or to pursue an adoption or other legal placement. We did not 

further investigate or otherwise attempt to verify the accuracy of these 

posts. Because of our methodology for reviewing these forums and 

because discussions between online participants can be continued 

privately, we were unable to determine whether a child was actually 

transferred to another family and, if so, whether it was done through a 

court-approved process or through an unregulated transfer.5

Through our interviews with representatives from child welfare and 

adoption organizations and others, we identified at least eight additional 

states that had legislative activity related to unregulated transfers since 

we began our review: Arkansas, Maine, Maryland, Massachusetts, 

Nebraska, New York, North Carolina, and South Carolina. We reviewed 

information on relevant laws and other activity provided by child welfare 

and other agency officials in our seven selected states as well as these 

eight identified states. Since we did not attempt to identify all relevant 

activity in all states, there may be other states with legislative or other 

activity that are not included in our review. To examine federal efforts 

related to unregulated transfers, we reviewed relevant documents 

obtained in our interviews with federal officials. We also reviewed relevant 

federal laws, regulations, and policies as well as GAO criteria on internal 

controls.6 Because children adopted domestically as infants and those in 

biological families may be less likely to have mental health issues due to 

trauma and institutionalization, and reports of unregulated transfers have 

primarily pertained to children adopted internationally or from foster care, 

our report will focus on international and foster care adoptions. See

5

Our review was not designed to determine the legality of the posters’ actions. However, 

we provided the information we collected to the Department of Justice, and in cases 

where sufficient information was available, to state law enforcement.

6

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1, 1999).

Page 4 GAO-15-733 Unregulated Child Custody Transfers 

 
appendix I for additional information on our objectives, scope, and 

methodology.

We conducted this performance audit from October 2014 to September 

2015 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

An unregulated child custody transfer, commonly referred to as rehoming, 

is not an adoption. It is a practice in which parents seek new homes for 

their children and place them without the safeguards and oversight of the 

courts or the child welfare system.7 This practice does not pertain 

exclusively to adopted children; biological children may also be subject to 

unregulated transfers. However, media reports and child welfare and 

adoption organizations have focused on unregulated transfers of adopted 

children that involve families who may be unable or unwilling to deal with 

the emotional and behavioral challenges that may be caused by a child’s 

pre-adoption conditions. For example, some adopted children may have 

histories of long-term institutionalization (e.g., orphanages), abuse, or 

other traumatic experiences that affect their behavior.

An adoption may be terminated as a result of a disruption, which occurs 

before the adoption is finalized, or a dissolution, which occurs after the 

adoption has been finalized, generally in a legal proceeding. Under these 

circumstances, the child would go into the child welfare system or be 

7

The State Department refers to an unregulated child custody transfer as an “informal 

secondary placement.” The department uses this term to describe the transfer of legal 

custody, or attempt thereof, without professional involvement, and to a family that 

potentially has not been approved to adopt.

Background

Unregulated Child 

Custody Transfers

Page 5 GAO-15-733 Unregulated Child Custody Transfers 

 
legally adopted by another family.8 In contrast, unregulated transfers 

occur when parents intend to permanently transfer custody of their child 

to a new family without following these steps. Sometimes the parents will 

use a document called a power of attorney to delegate to the new family 

certain authority for the care and control of the child, although such 

documents do not terminate the legal relationship between the adoptive 

parents and the child. Because power of attorney arrangements are 

generally not overseen by any state or federal agency, information on the 

whereabouts of a child subject to an unregulated transfer using a power 

of attorney can be limited or unknown. In addition, because families who 

engage in an unregulated transfer do not follow the steps required for a 

legally recognized adoption, there may be no checks to ensure that the 

new home is an appropriate place for the child.

There are different ways that a child can be adopted in the United States. 

International adoptions involve a child who was born in another country. 

Domestic adoptions can be adoptions from foster care, which involve 

children in the child welfare system whose biological parents have had 

their parental rights terminated. Other domestic adoptions include those 

conducted through private adoption agencies, attorneys, and others. Most 

domestic adoptions handled through private adoption agencies, 

attorneys, and others primarily involve infants or adoptions by a 

stepparent.

Unregulated transfers do not follow the adoption process, which generally 

involves many steps to help ensure that the child is legally adopted and 

placed in an appropriate and permanent home. While the adoption 

process can be different depending on the state and type of adoption, it 

typically consists of:

• a home study performed by a licensed professional to assess the 

suitability of the prospective parents, such as their health, finances, 

and criminal history;

8

According to State Department officials, the term “secondary placement” describes cases 

in which parents work with appropriate professionals (e.g., doctors, counselors, social 

workers, and attorneys) to transfer legal custody of an adopted child to another family that 

has been approved to adopt. State Department officials said in some cases, when a 

child’s needs exceed the parents’ ability to provide appropriate support, a secondary 

placement can be in the child’s best interests as long as it involves appropriate authorities, 

such as social services, medical professionals, counselors, and the court. 

The Adoption Process and 

Roles of Federal, State, 

and Other Agencies

Page 6 GAO-15-733 Unregulated Child Custody Transfers 

 
• an immigration application and petition, in the case of an international 

adoption;

• pre-adoption training for prospective parents, either online or inperson, for a specified number of hours on topics such as the 

adoption process and issues related to attachment and bonding;

• final approval of the adoption by a court, either in the United States or 

the child’s country of origin; and

• post-placement or post-adoption services, in some cases, which can 

range from information and referral services and peer support groups 

to more intensive services for children with severe behavioral needs.9

For example, these intensive services can include mental health 

counseling, respite care programs to provide temporary relief for 

caregivers by placing children in short-term accommodations outside 

the home, and residential treatment, which involves extended 

treatment services to children while they reside outside the home.

Multiple federal, state, and other agencies can be involved in different 

stages of the adoption process, depending on the type of adoption. Fees 

also vary by type of adoption; while foster care adoptions may not have 

any fees, international adoptions can involve substantial financial 

investments from families.10

International adoptions. As required under federal law and State 

Department regulations, international adoptions are generally conducted 

9

According to State Department officials, post-placement services are provided to families 

after a child is placed with the family and before the adoption is finalized, while postadoption services are provided after the adoption is finalized. These officials also said 

that, with respect to international adoptions, U.S. accrediting regulations do not require 

international adoption agencies to provide specific post-adoption services, although these 

agencies must notify prospective adoptive parents in the adoption contract of whether 

such services are included or available for additional fees.

10According to State Department data, international adoption agencies reported charging 

up to $64,357 for all services for an adoption, with half charging less than $31,120 and 

half charging more in fiscal year 2014. 

Page 7 GAO-15-733 Unregulated Child Custody Transfers 

 
through accredited adoption agencies or approved persons.11 USCIS is 

involved in adjudicating immigration petitions for these children as well as 

setting federal home study requirements for international adoptions and 

determining the suitability and eligibility of prospective adoptive parents.

12

The State Department also sets requirements for pre-adoption training 

that international adoption agencies and approved persons must provide 

for prospective parents. There are no federal requirements for postadoption monitoring for international adoptions, according to State 

Department officials.13 However, officials said some countries of origin 

require adoptive families to provide periodic reports (e.g., according to the 

State Department’s website, one country requires families to provide 

reports every 6 months for 2 years following an international adoption). 

Individual states may also have separate licensing requirements for 

international adoption agencies operating in their state.

Foster care adoptions. Foster care adoptions are typically conducted by 

state, county, and local child welfare agencies or private adoption 

agencies with which they contract. For these adoptions, states set 

requirements for home studies, pre-adoption training, and post-adoption

services.

11Under the Intercountry Adoption Act of 2000, as amended, the State Department sets 

accreditation requirements for those facilitating international adoptions. See 42 U.S.C. §§ 

14901-14954, 22 C.F.R. pt. 96. For example, the State Department generally requires 

these entities to be approved or accredited by the Council on Accreditation, a non-profit 

organization. See Memorandum of Agreement Between the U.S. Department of State and 

the Council on Accreditation Regarding Performance of Duties as an Accrediting Entity 

Under the Intercountry Adoption Act of 2000, 74 Fed. Reg. 40,771 (July 18, 2006) and 

Extension of Agreement Between the United States Department of State and the Council 

on Accreditation, 76 Fed. Reg. 42,761 (July 19, 2011).

12See generally 8 C.F.R. pt. 204 (immigrant petitions).

13State Department officials said the Intercountry Adoption Act of 2000, as amended, 

gives limited authority to the department to regulate international adoption agency 

practices after an adoption has been finalized. However, officials said State Department 

regulations do require certain activities for international adoption agencies after a child is 

placed with a family until the adoption is finalized. For example, during this period they 

said agencies are required to monitor and supervise the placement, provide or arrange for 

counseling if the placement is in crisis, and facilitate a safe disruption should the adoption 

not be finalized. See 22 C.F.R. § 96.50.

Page 8 GAO-15-733 Unregulated Child Custody Transfers 

 
Private domestic adoptions. States also set requirements for home 

studies, pre-adoption training, and post-adoption services for private 

domestic adoptions, generally through state licensing standards and other 

requirements for private adoption agencies, attorneys, and others.

Some federal funding is available for adoption services, in addition to any 

funding from state, local, or other sources. Funding appropriated for Title 

IV-E of the Social Security Act14 makes up the large majority of federal 

funding dedicated to child welfare, comprising about 89 percent of federal 

child welfare appropriations (approximately $7.4 billion of nearly $8.3 

billion) in fiscal year 2015, according to the Congressional Research 

Service.15 While the majority of these Title IV-E funds support children in 

the foster care system, the Title IV-E Adoption Assistance program 

provides grants to states for a portion of their costs to support families 

who adopted children with special needs, generally from foster care. For 

example, states provide ongoing monthly Adoption Assistance payments 

(subsidies) to eligible families that can be used to help pay for the costs of 

care for the child, which might include therapy and other post-adoption 

services. Funds appropriated for this program totaled about $2.5 billion in 

fiscal year 2015, comprising about 34 percent of Title IV-E program 

funding.

In addition, Title IV-B of the Social Security Act, which is the primary 

source of federal child welfare funding available for child welfare services, 

also provides funds that states can use to support adoptions by any 

14Title IV-E is codified at 42 U.S.C. §§ 670-679c. Title IV-E programs include Foster Care, 

Adoption Assistance, Kinship Guardianship Assistance, Title IV-E Plan Development and 

Technical Assistance, Chaffee Foster Care Independence Program, Chaffee Educational 

and Training Vouchers, and Adoption and Legal Guardianship Incentive Payments.

15Congressional Research Service, Child Welfare: An Overview of Federal Programs and 

Their Current Funding, R43458 (Washington, D.C.: Feb. 12, 2015). According to the 

Congressional Research Service, the $8.3 billion in dedicated federal child welfare funding 

includes funding provided through multiple programs, including those under Title IV-E and 

IV-B of the Social Security Act, the Child Abuse Prevention and Treatment Act, the Victims 

of Child Abuse Act of 1990, and others. 

Federal Funding That 

States May Use for 

Adoption Services

Page 9 GAO-15-733 Unregulated Child Custody Transfers 

 
family.16 For example, states may use funds to support pre- and postadoption services, although funds can also be used for a variety of other 

purposes to keep children safe and in stable families. Federal 

appropriations for Title IV-B comprised about 8 percent of dedicated 

federal child welfare appropriations (approximately $664 million of nearly 

$8.3 billion) in fiscal year 2015. Table 1 provides a summary of federal 

child welfare funding that states can use for adoption services, including 

programs under Title IV-E and IV-B of the Social Security Act.

Table 1: Summary of Federal Funding Available to States for Adoption Services, Fiscal Year 2015

Federal program

FY 2015 

funding level Program description

Adoption Assistance program under 

Title IV-E of the Social Security Act

$2.5 billion Provides funds to states for a portion of their costs to support the adoption of 

children with special needs.a Funds are available for a one-time payment to 

assist with the costs of adopting a child and for monthly subsidies to 

adoptive families to assist with the care of an eligible child. Additionally, 

funds are available for program administrative costs; training for staff and 

adoptive parents; adoptive parent recruitment; and other related expenses.

Child Welfare Services program under 

Title IV-B of the Social Security Act, 

Subpart I

$269 million Provides funds to states to: (1) protect and promote the welfare of all 

children, (2) prevent the abuse, neglect, and exploitation of children, (3) 

support at-risk families through family preservation and unification services, 

(4) promote the safety, permanence, and well-being of children in foster care 

and adoptive families, and (5) provide training, professional development 

and support to ensure a well-qualified child welfare workforce.

Promoting Safe and Stable Families 

program under Title IV-B of the Social 

Security Act, Subpart II

$380 millionb Provides funds to states to: (1) provide supportive services to prevent child 

maltreatment among at-risk families, (2) assure children’s safety at home 

and preserve intact families in which children have been maltreated, when 

the family’s problems can be addressed effectively, (3) address problems of 

families whose children have been placed in foster care so that reunification 

may occur in a safe and stable manner, and (4) provide support services as 

necessary to adoptive families so that they can make a lifetime commitment 

to their children. HHS expects states to spend 20 percent of this funding on 

adoption promotion and support services.

16Title IV-B is codified at 42 U.S.C. §§ 621-629m. For purposes of Title IV-B, HHS 

regulations define child welfare services as public social services directed to accomplish 

the following purposes: protecting and promoting the welfare and safety of all children, 

preventing or remedying child neglect, abuse, exploitation, or delinquency, preventing the 

unnecessary separation of children from their families, restoring children safely to their 

families, assuring that children are adequately cared for while away from their homes, and 

placing children in suitable adoptive homes when returning them to their families is not 

possible. 45 C.F.R. § 1357.10(c). Title IV-B programs include Stephanie Tubbs Jones 

Child Welfare Services, Promoting Safe and Stable Families Program, Family Connection 

Grants, Child Welfare Research, Training, or Demonstration Projects, and the National 

Survey of Child and Adolescent Well-Being.

Page 10 GAO-15-733 Unregulated Child Custody Transfers 

 
Federal program

FY 2015 

funding level Program description

Adoption and Legal Guardianship 

Incentive Payments program under 

Title IV-E of the Social Security Act

$38 million Provides funding incentives to eligible states that increase the number of 

adoptions and legal guardianships of children from foster care.

Adoption Opportunities program under 

the Child Abuse Prevention and 

Treatment Act

$39 million Provides grants for projects designed to eliminate barriers to adoption and to 

help find permanent families for children who would benefit from adoption, 

particularly children with special needs. Major program areas include 

improving information on adoptions, increasing placements of children in 

foster care, post-adoption services, and others. 

Source: GAO summary of information from federal laws and agency documents, including Department of Health and Human Services budget documents. | GAO-15-733

Note: Funding level refers to enacted budget authority for fiscal year 2015, as described in HHS 

budget documents. This table is not intended to be an exhaustive list of federal funding available to 

states for adoption services; other federal funding sources may be available for this purpose that are

not included here. In addition, funding may also be available from state or other sources for adoption 

services.

a

Each state determines whether a particular child has special needs, in accordance with the statutory 

definition. 42 U.S.C. § 673. Often the child must be older, a member of a minority group, a member of 

a sibling group, or have physical, mental, or emotional disabilities.

b

According to HHS officials, $404.8 million was appropriated for the Promoting Safe and Stable 

Families program in fiscal year 2015, including $345 million in mandatory funds that were subject to a 

7.3 percent reduction due to sequestration. After this reduction, officials said $380 million was 

available for the program in fiscal year 2015. 

In addition to these programs, states may use savings generated from 

changes made to the eligibility criteria for the Title IV-E Adoption 

Assistance program for adoption services. These changes made 

additional children eligible for federal Title IV-E Adoption Assistance 

payments, thereby potentially freeing up state funds previously used for 

this purpose.17 The Preventing Sex Trafficking and Strengthening 

Families Act requires states to use 30 percent of these savings for postadoption and related services.18 In addition, states may use different 

combinations of federal funds not specifically dedicated to child welfare to 

17The Fostering Connections to Success and Increasing Adoptions Act of 2008 phases 

out income eligibility requirements for the Title IV-E Adoption Assistance program and 

requires states to spend an amount equal to any savings resulting from this change on 

services authorized under Title IV-B or IV-E. Pub. L. No. 110-351, § 402, 122 Stat. 3949, 

3975-79 (amending 42 U.S.C. § 673).

18Pub. L. No. 113-183, § 206, 128 Stat. 1919, 1939-40 (2014) (amending 42 U.S.C. § 

673(a)(8)). Specifically, the Act requires that states spend no less than 30 percent of any 

such savings on post-adoption services, post-guardianship services, and services to 

support and sustain positive permanent outcomes for children who otherwise might enter 

into foster care under the responsibility of the state. At least two-thirds of this amount is 

required to be spent on post-adoption and post-guardianship services.

Page 11 GAO-15-733 Unregulated Child Custody Transfers 

 
support adoption services, such as funds available under the Temporary 

Assistance to Needy Families block grants, Medicaid, and Social Services 

Block Grants.19 While states can use federal funds to support adoption 

services for families, we reported in January 2013 that federal funding for 

services designed to prevent children from entering foster care—such as 

adoption support services—can be limited.20

HHS does not collect information on how much states spend in federal 

funds specifically for post-adoption services. In addition, our prior work 

has shown that some states may not have information on the extent to 

which they use these federal funds for adoption services. Although states 

are to use savings generated from changes to the Title IV-E Adoption 

Assistance program for child welfare services, we reported in May 2014 

that only 21 states reported calculating these savings for fiscal year 2012, 

and 20 states reported difficulties performing the calculations.21 In 2014, 

the Donaldson Adoption Institute attempted to collect information on 

states’ annual post-adoption service budgets, excluding Title IV-E 

19Temporary Assistance to Needy Families is a federal block grant that supports four 

overarching goals, one of which is to provide assistance to needy families so that children 

can live in their homes or the homes of relatives. The goals of the Social Services Block 

Grant program include preventing or remedying child abuse, among others, and a wide 

variety of services, including counseling and referrals to services, may be supported with 

these funds. Medicaid is a joint federal-state program that finances health care services 

for certain low-income individuals, nearly half of whom are children. We previously 

reported that in spring 2011, 31 states reported spending Temporary Assistance to Needy 

Families funds, and in fiscal year 2010, 44 states reported spending Social Services Block 

Grant funds for purposes covered under Title IV-B. See GAO, Child Welfare: States Use 

Flexible Federal Funds, but Struggle to Meet Service Needs, GAO-13-170 (Washington, 

D.C.: Jan. 30, 2013).

20GAO-13-170.

21GAO, Foster Care: HHS Needs to Improve Oversight of Fostering Connections Act 

Implementation, GAO-14-347 (Washington, D.C.: May 29, 2014). In this report, we 

recommended that HHS provide guidance on how states could calculate savings resulting 

from changes to federal Title IV-E Adoption Assistance eligibility criteria. The Preventing 

Sex Trafficking and Strengthening Families Act, enacted in September 2014, requires 

states to calculate the savings resulting from the Title IV-E Adoption Assistance program 

changes for each fiscal year and report annually to HHS the methodology used to make 

the calculation, the amount of any savings, and how such savings were spent. HHS 

issued guidance to states in May 2015 that provides a standard methodology for 

calculating these savings and instructions on how to submit an alternative methodology for 

HHS approval. See Department of Health and Human Services, Adoption Savings 

Calculation Methodology, ACYF-CB-PI-15-06 (Washington, D.C.: May 22, 2015).

Page 12 GAO-15-733 Unregulated Child Custody Transfers 

 
Adoption Assistance program subsidies.22 However, it reported that some 

states were unable to distinguish this budget item, especially when the 

primary programs that served adoptive families also served other families. 

It also reported that states with county-administered child welfare 

programs were unable to report total state budgets for post-adoption 

services. The Institute reported that annual budgets for these services 

ranged from $85,000 to $11.2 million in the 21 states that provided 

responses to the survey it conducted.

International adoptions in the United States have changed over time from 

a system that predominantly involved the adoption of infants and toddlers 

to one that has involved an increasing proportion of older children and 

those with special needs. According to State Department data, less than 

8 percent of children adopted internationally in fiscal year 2013 were 

younger than 1 year compared to over 40 percent in fiscal year 2004. In 

addition, one study reported in 2013 that nearly half of more than 1,000 

parents surveyed who adopted internationally said their children had 

diagnosed special needs.23

The State Department, HHS, and others have reported that the changing 

landscape of international adoptions is attributable to many different 

factors, including positive cultural factors and socio-economic conditions 

in other countries that have made it easier for biological families to take 

care of their children or to adopt domestically—decisions that have 

impacted the number of children eligible for adoption by U.S. families. 

About 7,000 children were adopted internationally in fiscal year 2013 

compared to nearly 23,000 in fiscal year 2004 (see fig. 1).

22The Donaldson Adoption Institute is a research organization that focuses on four areas: 

the adoption experience, foster care adoptions, adoption support services, and the 

modern family. See S. Livingston Smith, Supporting and Preserving Adoptive Families: 

Profiles of Publically-Funded Post-Adoption Services (New York, NY: The Donaldson 

Adoption Institute, April 2014).

23E. Pinderhughes, J. Matthews, G. Deoudes, and A. Pertman, A Changing World: 

Shaping Best Practices Through Understanding Of the New Realities of Intercountry 

Adoption (New York, NY: The Donaldson Adoption Institute, October 2013). In this study, 

surveyed parents selected from the following categories of special needs: physical or 

medical need, growth delay, mental or emotional need, other developmental delay, or 

other.

Characteristics of Children 

Adopted Internationally 

and from Foster Care

Page 13 GAO-15-733 Unregulated Child Custody Transfers 

 
Figure 1: Number and Age of Internationally Adopted Children, Fiscal Years 2004 

through 2013

Children in foster care may also be more likely to have special needs than 

children in the general population. According to a national survey 

conducted in 2008 and 2009, more than 42 percent of children ages 18 

months to 17 years who were placed in a foster family home following an 

investigation of abuse and neglect were found to be at risk for an 

Page 14 GAO-15-733 Unregulated Child Custody Transfers 
emotional or behavioral problem and potentially in need of mental health 

services.24

Multiple studies have shown that abuse and other maltreatment can 

cause changes in the brain development of children, and these changes 

may leave them more vulnerable to depression, post-traumatic stress 

disorder, and other behavioral or mental health issues.25 Studies show 

that children who are institutionalized—for example, in orphanages prior 

to being adopted by a family—are often subject to deprivation and 

neglect. Young children with a history of institutional care often show poor 

attention, hyperactivity, difficulty with emotion regulation, elevated levels 

of anxiety, and increased rates of attachment disorders. For example, 

they may develop Reactive Attachment Disorder, which is characterized 

by serious problems in emotional attachments to others. The physical, 

emotional, and social problems associated with this disorder may persist 

as the child grows older.

Families who adopt children with severe behavioral or mental health 

issues may face situations which can put the family in crisis. For example, 

the adopted child may be violent toward siblings or parents. One study 

reported in 2014 that in 23 percent of cases where adoptions were 

dissolved, the adopted child was a threat to the safety of other children in 

the home.26

24H. Ringeisen, C. Casanueva, K. Smith, and M. Dolan, National Survey of Child and 

Adolescent Well-Being II Baseline Report: Children’s Services, OPRE Report #2011-27f 

(Washington, D.C.: Office of Planning, Research and Evaluation, Administration for 

Children and Families, U.S. Department of Health and Human Services, November 2011).

25See, for example, F. Juffer, J. Palacios, L. Le Mare, E. J. Sonuga-Barke, W. Tieman, 

M.J. Bakermans-Kranenburg, P. Vorria, M. van IJzendoorn, and F. Verhulst, 

“Development of Adopted Children with Histories of Early Adversity,” Monographs of the 

Society for Research in Child Development, vol. 76, no. 4 (2011), and D. Johnson and M. 

R. Gunnar, “Growth Failure in Institutionalized Children,” Monographs of the Society for 

Research in Child Development, vol. 76, no. 4 (2011).

26S. Livingston Smith, Keeping the Promise: The Case for Adoption Support and 

Preservation (New York, NY: The Donaldson Adoption Institute, March 2014).

Page 15 GAO-15-733 Unregulated Child Custody Transfers 

 
Families may choose an unregulated child custody transfer because they 

were not sufficiently prepared for the challenges they experienced in their 

adoption, according to many child welfare and adoption stakeholders we 

interviewed.27 This lack of preparation may include inadequate 

information about the child’s health, an insufficient home study to make a 

good match, and minimal pre-adoption training for parents.

Many stakeholders we interviewed—including officials from selected 

states, child welfare and adoption organizations, and adoption agencies—

expressed concern with the adequacy of the information provided to 

prospective parents on the behavioral and mental health conditions of a 

child adopted internationally. Access to accurate information is critical to 

ensuring that a family is aware of the type of ongoing support they may 

need for the child. However, officials from 11 of 19 child welfare and 

adoption organizations and 5 of 15 adoption agencies said families who 

adopt internationally often do not receive complete information on a 

child’s medical and behavioral needs before adopting. State Department 

officials explained that some low-income countries lack sufficient mental 

health care providers, making it difficult for international adoption 

agencies to ensure that children are accurately evaluated prior to 

27In this report, we refer to different types of organizations when reporting information from 

our interviews with 7 selected states, 19 child welfare and adoption organizations, and 15 

adoption agencies. References to “stakeholders” include responses from officials in all 

three of these groups. We interviewed these stakeholders using a semi-structured 

interview protocol, which included open-ended questions on the reasons that families may 

consider unregulated transfers, among other topics. The reasons provided by these 

stakeholders were volunteered in response to open-ended questions and thus, the counts 

of organizations citing such responses vary. In addition, in this report we use qualifiers, 

such as “several” and “many,” in some cases to quantify responses from stakeholders 

across these three groups. For additional information on these qualifiers, see appendix I. 

Families May Choose 

an Unregulated Child 

Custody Transfer Due 

to an Adoption in 

Crisis and Challenges 

Accessing Services

Families May Be 

Unprepared for the 

Challenges of Adopting 

Children with Special 

Needs, Particularly for 

International Adoptions

Page 16 GAO-15-733 Unregulated Child Custody Transfers 

 
adoption. USCIS officials also said some countries do not allow 

prospective adoptive parents to review medical history documents until 

after an adoption is finalized for privacy reasons.

Many stakeholders also expressed concern that families may not have 

undergone an adequate home study to ensure they are a good match for 

their adopted child, and several noted that the home study is a critical 

point in the pre-adoption process, when social workers or adoption 

agency staff try to determine how families will handle challenges when 

parenting their adopted child. According to HHS officials, requirements for 

what should be assessed during a home study are determined by 

individual states for foster care adoptions. Home study requirements are 

determined by USCIS and the State Department for international 

adoptions.28 However, officials from 4 of 7 selected states and 8 of the 15 

adoption agencies we interviewed expressed concerns about 

inconsistencies in the quality of home studies conducted by child welfare 

and adoption agencies across states. For example, Ohio officials said all 

child welfare and adoption agencies in their state are required to use a 

detailed home study format. They said they may not accept home studies 

conducted in other states that have less stringent requirements unless 

additional supporting documentation is provided, such as a background 

check and safety check of the home.

Families also may not have received sufficient or targeted pre-adoption 

training to ensure they were prepared for their child’s specific needs, 

particularly for international adoptions, according to most stakeholders we 

interviewed. For foster care adoptions, states each set their own training 

requirements for prospective parents, according to HHS officials. About 

half of all states require agencies facilitating these adoptions to provide 

prospective parents with at least 27 hours of training, according to data 

obtained from HHS officials in May 2015. Our seven selected states have 

requirements of 18 to 47 hours of training for foster care adoptions with 

some in-person required training in each state, according to state officials. 

Many of our selected states also use similar training models for foster 

care adoptions, including Parent Resources for Information, 

Development, and Education (PRIDE) and Model Approach to 

Partnerships in Parenting (MAPP), which were developed by various child 

28See 22 C.F.R. § 96.47, 8 C.F.R. § 204.311.

Page 17 GAO-15-733 Unregulated Child Custody Transfers 

 
welfare organizations.29 In contrast, State Department regulations require 

10 hours of training for international adoptions, all of which can be online. 

This training must cover topics defined by the federal regulations.30

Officials we interviewed from 5 of our selected states, 12 child welfare 

and adoption organizations, and 11 adoption agencies told us that this 

training may be insufficient, particularly since an increasing proportion of 

children adopted internationally are older and have special needs due to 

an extensive history of institutionalization and trauma. State Department 

officials told us they are considering revisions to pre-adoption training 

requirements for international adoptions, which we discuss later in the 

report.

States may set training requirements for international adoptions above 

the 10-hour minimum or may have required training topics. Two of our 

seven selected states require more than 10 hours of training, according to 

state officials. For example, Wisconsin officials told us the state requires 

18 hours of training, and the same topics are required for international 

and foster care adoptions. This training covers issues such as attachment 

in adoptive placement, the effects of abuse and neglect, and cultural 

sensitivity. In addition, this training includes opportunities to cover issues 

specific to the individual child (see table 2).

29The PRIDE training model was created by the Child Welfare League of America. The 

PRIDE model has 14 specific steps with a focus on planning, development, and support. 

The MAPP training model was created by the California Evidence-Based Clearinghouse 

for Child Welfare. All MAPP programs are based on core concepts including safety, wellbeing, and permanence, and include trauma-informed practice methods. 

30The Intercountry Adoption Act of 2000, as amended, requires international adoption 

agencies to provide prospective parents with a training program that includes counseling 

and guidance for the purpose of promoting a successful international adoption. 42 U.S.C. 

§ 14923(b)(1)(A)(iii). State Department regulations set forth the minimum required hours 

and topics to be covered, as well as how the training may be delivered. See 22 C.F.R. § 

96.48. Training topics include, among other things, the international adoption process, the 

conditions of the country the prospective parent wishes to adopt from, the effects of 

malnutrition, institutionalization, attachment disorders, and other factors that may affect 

internationally adopted children, and raising a multicultural family. Although the regulations 

allow for training to be delivered online, they also require that the adoption agency provide 

“additional in-person, individualized counseling and preparation, as needed, to meet the 

needs of the prospective adoptive parent(s) in light of the particular child to be adopted 

and his or her special needs, and any other training or counseling needed in light of the 

child background study or the home study.” 

Page 18 GAO-15-733 Unregulated Child Custody Transfers 

 
Table 2: Pre-Adoption Training Requirements in GAO’s Seven Selected States, Reported as of July 2015

Source: GAO analysis of information provided by officials from selected state child welfare agencies. | GAO-15-733

a

Agencies or persons providing adoption services for international adoptions are subject to State 

Department regulations, which set forth the minimum required hours (10 hours) and topics to be 

covered, as well as how the training may be delivered. See 22 C.F.R. § 96.48. State requirements 

may vary. We did not attempt to determine the extent to which any state requirements in this table 

overlap with the federal requirements.

State Foster care adoptions International adoptionsa

Colorado • Minimum training: 47 hours

• Content: Required topics

• Delivery: In-person, online, and independent components

• Minimum training: State requirement 

of 20 hours total

• Content: State required topics

• Delivery: In-person component

Florida • Minimum training: 21 hours

• Content: Required topics; Parent Resources for Information, 

Development, and Education (PRIDE) and Model Approach to 

Partnerships in Parenting (MAPP) models

• Delivery: In-person component

• Minimum training: No state 

requirement (10 hours under federal 

requirement)

• Content: No state requirements

• Delivery: Can be fully online

Illinois • Minimum training: 42 hours

• Content: PRIDE model

• Delivery: In-person and online components

• Minimum training: No state 

requirement (10 hours under federal 

requirement)

• Content: No state requirements

• Delivery: Can be fully online

Louisiana • Minimum training: 30 hours

• Content: MAPP model

• Delivery: In-person and independent components

• Minimum training: No state 

requirement (10 hours under federal 

requirement)

• Content: State required topics

• Delivery: Can be fully online

Ohio • Minimum training: 36 hours

• Content: Required topics similar to MAPP model

• Delivery: In-person component

• Minimum training: No state 

requirement (10 hours under federal 

requirement)

• Content: State required topics

• Delivery: Can be fully online

Virginia • Minimum training: 27 hours

• Content: PRIDE model or other curricula pre-approved by the state

• Delivery: In-person and online components

• Minimum training: No state 

requirement (10 hours under federal 

requirement)

• Content: State required topics

• Delivery: Can be fully online

Wisconsin • Minimum training: 18 hours

• Content: Curriculum based on PRIDE and other models

• Delivery: In-person and online components

• Minimum training: State requirement 

of 18 hours total

• Content: State required topics

• Delivery: Can be fully online

Page 19 GAO-15-733 Unregulated Child Custody Transfers 
State Department officials said international adoption agencies may also 

have their own training requirements beyond those of federal and state 

agencies. For example, officials from one international adoption agency 

said they require 30 hours of training for parents wishing to adopt abroad. 

This includes training on grief and loss, the child’s country of origin and 

cultural differences, the impact of institutionalization, and potential 

challenges and service needs. These officials said this expanded training 

is more costly for both the agency and prospective parents, and that 

some prospective parents thought the training was too cumbersome or 

expensive.

Officials in most of the selected states, child welfare and adoption 

organizations, and adoption agencies we interviewed expressed concern 

that families may choose an unregulated transfer when they cannot 

access post-adoption services to help them cope with or avoid reaching a 

crisis point in their adoption. Several of these stakeholders explained that 

an adopted child may deal with continuing issues of attachment, identity, 

and loss of previous caregivers or biological parents.31 While services to 

help adoptive families can include information, referrals, and peer support 

groups, families who adopted children with severe behavioral needs may 

need more intensive services, such as mental health counseling, respite 

care, and residential treatment.32 Many stakeholders we interviewed 

suggested that families considering unregulated transfers may particularly 

need these intensive services.

31Stakeholders noted that some adoptive parents need post-adoption services to deal with 

issues such as attachment and loss over their inability to have a biological child.

32In our report, “intensive services” refers to advocacy services, case management, 

clinical services, counseling, crisis intervention, home-based services, psychological 

evaluations, respite care, and residential treatment. Respite care provides parents with 

short-term, out-of-home child care services that offer temporary relief for families. 

Residential treatment facilities provide a range of long-term, out-of-home services 

including educational, medical, psychiatric, and mental health services, and can serve as 

an alternative to hospitalization or incarceration for youth who cannot live at home and 

receive services in their communities. However, there is no uniform definition of residential 

treatment facilities, and HHS reported in 2006 that states identified at least 71 different 

types of residential facilities treating children with mental illness. See GAO, Residential 

Facilities: Improved Data and Enhanced Oversight Would Help Safeguard the Well-Being 

of Youth with Behavioral and Emotional Challenges, GAO-08-346 (Washington, D.C.: May 

13, 2008) and Department of Health and Human Services, State Regulation of Residential 

Facilities for Children with Mental Illness, DHHS Pub. No. (SMA) 06-4167 (Rockville, Md.: 

Center for Mental Health Services, Substance Abuse and Mental Health Services 

Administration, 2006).

Families May Have 

Difficulties Accessing 

Needed Post-Adoption 

Services

Page 20 GAO-15-733 Unregulated Child Custody Transfers 

 
All seven of our selected states provide some kind of post-adoption 

services for families who adopted from foster care and internationally.33

For example, Wisconsin officials said the state provides parent training, a 

24-hour information hotline, referral services, and mechanisms to link 

families to support groups and mentors, which are available to all 

adoptive families. Other types of services these selected states provide 

include lending libraries, newsletters, and brochures for parents. 

However, the seven selected states offered limited intensive services, 

particularly for international adoptions, according to our analysis of the 

information gathered from selected state officials. Officials from three 

states said their state offers counseling and other intensive services, such 

as case management and crisis intervention, to both families who 

adopted from foster care and internationally. However, officials from the 

six states that offer respite care and the four states that provide 

residential treatment told us their states provide these services 

exclusively to families who adopted from foster care. Some of these 

services have maximum time limits or are offered on a case-by-case 

basis. For example, Louisiana officials said their state offers respite care 

for up to 1 month, and Florida and Illinois officials said their states offer 

residential treatment services to families who adopted from foster care on 

a case-by-case basis.

In addition, our seven selected states provide varying levels of financial 

support to eligible adoptive families through subsidies and cash 

assistance programs, according to the information gathered from selected 

state officials.34 For example, Ohio officials described a state program 

that uses Title IV-B and state revenue funds to provide up to $10,000 per 

child per year to pay service providers in 2014, with an additional $5,000 

available per year if the child is recommended for residential treatment by 

a mental health provider. In addition, all of our selected states received 

federal funds under the Title IV-E Adoption Assistance program to provide 

33Colorado officials told us that the state supports post-adoption services for families 

adopting internationally. However, Colorado does not directly fund those services. Instead, 

the state partners with private organizations that fund post-adoption services for families 

adopting internationally. 

34States can use various federal and state funding sources to provide financial assistance 

to adoptive families, including funds under Title IV-B and IV-E of the Social Security Act, 

Social Services Block Grants, Temporary Assistance for Needy Families, and state 

revenue. In addition, some children, particularly those adopted from foster care, may be 

eligible for Medicaid, which may cover the cost of some post-adoption services.

Page 21 GAO-15-733 Unregulated Child Custody Transfers 

 
subsidies to eligible adoptive families; the maximum subsidy amounts 

ranged from $400 to $2,700 per month in 2014.35 However, they are 

generally only available to eligible families who adopted children with 

special needs from foster care, and information is limited on how much 

families use their subsidies for services, such as counseling, versus other 

expenses for their adopted child, such as food, clothing, and day care. 

The Donaldson Adoption Institute reported in April 2014 on a variety of 

post-adoption services provided by 49 states that responded to survey 

questions about such services. It found that about one-third of these 

states offered almost no post-adoption services other than a subsidy for 

adoptive families.36 In addition, the report found that the majority of these 

states had services that were open exclusively to families who adopted 

from foster care.

Officials in four of our seven selected states told us that the need for postadoption services exceeded the funding available from state and federal 

programs. Our prior work has shown that child welfare agencies have 

struggled to meet the service needs of families. Our 2013 report found 

that local child welfare officials in four states we reviewed reported 

service gaps in multiple areas, including counseling and mental health 

services.37 We also reported that state and local child welfare agencies 

may face difficult decisions when determining which activities—aimed at 

preserving families and preventing a child from entering foster care—to 

prioritize and fund, particularly in light of the ongoing fiscal challenges 

these agencies face.

35According to selected state officials, the maximum amount that a family receives may be 

dependent on the child’s age, as determined by each state. Under the Title IV-E Adoption 

Assistance program, the amount of each subsidy is to be determined through an 

agreement between the adoptive parents and the state child welfare agency, which shall 

take into consideration the circumstances of the adopting parents and the needs of the 

child being adopted. However, the amount may not exceed the amount of the foster care 

maintenance payment that would have been paid if the child had been in a foster family 

home. 42 U.S.C. § 673(a)(3). 

36Smith, Supporting and Preserving Adoptive Families, 16. The report found that 17 states 

had post-adoption programs that provided several services, including some type of 

specialized counseling; 19 states had programs that provided some mid-level services, 

such as training or support groups; and 13 states had almost no programs other than an 

adoption subsidy.

37GAO-13-170. 

Page 22 GAO-15-733 Unregulated Child Custody Transfers 

 
Similar to our selected states, officials from 12 of the 15 adoption 

agencies we interviewed said they provide some level of post-adoption 

services to families, such as information and referrals. Officials in 4 of the 

15 adoption agencies said they provide intensive services, ranging from 

trauma-focused therapy to a weekend respite care program. Officials from 

six adoption agencies noted that resource constraints have affected their 

ability to provide post-adoption services. Officials from the Council on 

Accreditation—the organization responsible for accrediting agencies for 

international adoptions—said some international adoption agencies have 

struggled to maintain their businesses due to the decrease in the number 

of international adoptions overall (a decrease of 70 percent between fiscal 

years 2003 and 2014). They said while some larger agencies have been 

better able to provide services because they are financially stable, this 

can be a challenge for other agencies.

Another limitation to accessing post-adoption services that many 

stakeholders expressed concern about was the cost of intensive services, 

which can be expensive for all families. Officials in 3 of 7 selected states, 

6 of 19 child welfare and adoption organizations, and 5 of the 15 adoption 

agencies we interviewed said services can be expensive, particularly 

intensive services such as mental health counseling and residential 

treatment. We have previously reported that the cost to support a youth in 

a residential setting can amount to thousands of dollars per month.38

In addition to cost, adoptive families may have challenges finding mental 

health providers that are “adoption competent”—that is, knowledgeable 

about adoption-related issues, according to officials from five selected 

states, seven child welfare and adoption organizations, and eight 

adoption agencies. These stakeholders said mental health providers who 

do not understand issues unique to adoptive families will likely be less 

effective in helping these families work through issues. For example, one 

official told us adoptive families need therapists who can distinguish 

between normal adolescent behavior and a child acting out due to grief 

and loss resulting from his or her adoption. Several stakeholders also 

noted that families in rural areas may have even more difficulty accessing 

effective mental health providers. We reported in 2013 that a Florida 

behavioral health service provider had been advertising a child 

38GAO-08-346.

Page 23 GAO-15-733 Unregulated Child Custody Transfers 

 
psychiatrist position for 5 years without success.39 In a 2011 report, we 

found that child psychiatrists and psychologists were among the most 

difficult specialist referrals to obtain for children in low-income families 

covered by Medicaid and the Children’s Health Insurance Program, both 

of which can cover children adopted from foster care and internationally.40

Lastly, families may not know about available services from their child 

welfare or adoption agency, and therefore do not seek help when needed, 

according to officials from four selected states and five adoption 

agencies. For example, Virginia officials said families that did not adopt 

from foster care may not know about support services they can access 

through their local child welfare agency. Wisconsin officials also said they 

struggle to find sufficient resources to provide outreach to all adoptive 

parents about state resources. Officials from two selected states also 

raised concerns that families may not remember whether their adoption 

agency provides post-adoption services. They explained that some 

families may not need services for years after an adoption is final 

because issues may not arise until the child reaches adolescence. By that 

point, families may no longer have contact with their adoption agency.

Families in need of help may be reluctant to ask child welfare agencies 

for assistance, according to officials from three child welfare and adoption 

organizations and four adoption agencies. For example, these officials 

noted that there is a stigma associated with contacting child welfare 

agencies since those agencies are also generally responsible for 

investigating cases of child abuse. A few of these officials further noted 

that families, including those who adopted from foster care and 

internationally, may fear that contacting an agency will prompt an 

investigation into how they care for all of their children. They also said 

families may be afraid that they will not be able to adopt again if they are 

involved with a child welfare agency.

39GAO-13-170.

40The Children’s Health Insurance Program is a federal-state program that provides health 

care coverage to children 18 years of age and younger living in low-income families 

whose incomes exceed the eligibility requirements for Medicaid. For a discussion on 

children served by Medicaid and the Children’s Health Insurance Program, see GAO, 

Medicaid and CHIP: Most Physicians Serve Covered Children but Have Difficulty 

Referring Them for Specialty Care, GAO-11-624 (Washington, D.C.: June 30, 2011).

Families May Be Reluctant 

to Seek Help for Fear of 

Repercussions and 

Associated Stigma

Page 24 GAO-15-733 Unregulated Child Custody Transfers 

 
Officials in five of our seven selected states acknowledged the dilemma 

that families face if they contact child welfare agencies for services. In 

addition, officials in one selected state said parents cannot voluntarily 

relinquish custody of a child in their state (e.g., for care or services) 

without being charged with child abandonment. Officials in all seven 

selected states said families who decide to relinquish custody to the state 

may be required to pay ongoing child support.

Similarly, families who adopted internationally may also be hesitant to 

reach out to their adoption agency. Representatives from 9 of the 15 

adoption agencies we interviewed told us that families may be ashamed 

or embarrassed to contact the agency to discuss problems. 

Representatives from one adoption agency explained that families have 

gone through a rigorous home study process to prove that they will 

provide a good home to an adopted child. Thus, they said these families 

may be reluctant to contact their agency and admit that that they are 

facing challenges in their adoptions.

Page 25 GAO-15-733 Unregulated Child Custody Transfers 
Because unregulated child custody transfers are an underground practice 

that happens outside the purview of the courts and the child welfare 

system, they are difficult to track, and no federal agency keeps statistics 

on their occurrence.41 These transfers may involve an exchange of a 

power of attorney that may not be filed with or approved by a court of law, 

although it may be signed by both parties and notarized. State laws vary, 

but generally a parent may use a power of attorney to temporarily grant 

another person certain powers regarding their child’s care and physical 

custody, such as the authority to make medical and educational 

decisions.42 For example, a military service member may sign a power of 

attorney to allow a family member or friend to take care of and make 

medical decisions for his or her child while he or she is deployed. 

However, because a power of attorney does not terminate the legal 

parent-child relationship, the adoptive parent still retains certain rights and 

responsibilities. For example, according to HHS, delegating responsibility 

41Given the lack of data on unregulated transfers, several stakeholders we interviewed 

suggested that federal and state child welfare agencies examine data on adoption 

dissolutions. While adoption dissolutions—the termination of the legal parent-child 

relationship after the adoption is finalized, which typically involves a court—and 

unregulated transfers are different practices, these stakeholders noted that dissolution 

data could provide information on the number of families who have encountered 

significant challenges with their adoptions. However, data on adoption dissolutions are 

also limited. To improve knowledge about these issues, section 208 of the Preventing Sex 

Trafficking and Strengthening Families Act requires HHS to promulgate regulations to 

collect data on children who enter foster care after finalization of an adoption. Pub. L. No. 

111-183, § 208, 128 Stat. 1919, 1940-41 (2014) (codified at 42 U.S.C. § 679(d)). HHS 

proposed regulations in February 2015 to require states to collect information on whether 

children entering the child welfare system have been previously adopted, among other 

things. Adoption and Foster Care Analysis and Reporting System, 80 Fed. Reg. 7132 

(Feb. 9, 2015). 

42The specific powers that can be granted to another person depend on state law and the 

content of the power of attorney document. State laws may limit what parental authority 

may be delegated. For example, some states will not allow a parent to delegate the power 

to consent to a minor child’s marriage or adoption.

Little Is Known about 

the Prevalence of 

Unregulated 

Transfers

Unregulated Child 

Custody Transfers Are 

Difficult to Track

Page 26 GAO-15-733 Unregulated Child Custody Transfers 

 
for a child through a power of attorney does not insulate adoptive parents 

from state laws regarding imminent risk of serious harm.

State laws determine any time limits (e.g., 1 year) for grants of power of 

attorney, and also establish the procedures required to make such an 

arrangement effective. For example, officials in three of our seven 

selected states told us their state laws do not require power of attorney 

documents to be approved by a court, and officials in one selected state 

said their laws require court approval in certain circumstances.43

However, officials in three of these selected states said they were not 

aware of any mechanisms in their states to track expired power of 

attorney documents to determine if families are attempting to use them to 

permanently transfer custody.

Unregulated transfers are also difficult to track because many adoptions 

are not monitored after the adoption is finalized. For those international 

adoptions subject to reporting requirements set by individual countries, 

reporting may occur for a limited time. For example, according to the 

State Department website, one country requires adoptive parents to 

provide information about the adoption at certain time intervals for the first 

2 years. Officials from the State Department and several adoption 

agencies we interviewed told us that while parents may sign a contract 

when they adopt a child saying they will report the required information to 

the adoption agency, parents may not comply with post-adoption 

reporting requirements, and agencies have little leverage to enforce 

compliance. In addition, officials in our seven selected states said their 

state does not specifically monitor whether adopted children remain with 

their families after the adoption is finalized.44

43Officials in the remaining three states either did not provide us with this information or 

said their state does not have a power of attorney process for child custody. 

44Families who receive a Title IV-E Adoption Assistance subsidy may be required to 

submit an annual affidavit stating that the child is still in their care, according to selected 

state officials. However, HHS officials said that under federal law and HHS policy, child 

welfare agencies may not terminate or suspend these subsidies solely because adoptive 

parents do not submit an annual affidavit, letter, or other certification stating that the child 

is still in their care. HHS published a Federal Register notice in March 2015 to solicited 

public comment on its policies on suspending and terminating Title IV-E Adoption 

Assistance subsidies. Notice for Public Comment on the Title IV-E Adoption Assistance 

Program’s Suspension and Termination Policies, 80 Fed. Reg. 17,058 (March 31, 2015). 

See table 5 for more information on this effort.

Page 27 GAO-15-733 Unregulated Child Custody Transfers 

 
Our observations of forums on social media websites indicate that some 

parents have been using these venues to seek new homes for their 

children. We observed posts in five social media forums and found a total 

of 23 posts in which a person wrote that they were seeking a new family 

for their child.45 Among the 9 posts that included information on a child’s 

age, those ages ranged from 7 to 16. Generally, parents in these forums 

who said they wanted to transfer a child indicated that they were in 

distress or crisis, and most often said they were seeking a new home 

because of the child’s behavioral issues or severe mental illness. These 

children included those who were adopted from foster care and 

internationally. For example, one post asked for a new home for a 7-yearold boy who had been diagnosed with numerous mental illnesses, 

including Reactive Attachment Disorder, Oppositional Defiance Disorder, 

and autism, and who was physically abusive to his siblings and family 

pets. Several posters responded with information about their family and 

location or said that they had sent the poster a private message. Another 

poster wrote that her son, who she adopted internationally, had been 

diagnosed with multiple mental illnesses and was currently hospitalized 

for psychiatric reasons, and she was seeking a new home for him.

In addition, we found 40 cases in which a person posted that they wanted 

to adopt a child. In some cases, posters wrote that they had successfully 

completed a home study. In other cases it was not clear whether they had 

undergone a home study. For example, only a third of the posts we 

observed in one online forum referenced a home study—either that the 

person seeking to adopt had completed one or the person seeking a new 

home for the child required one. Some posters said they had adopted 

children already in the home, and some wrote they had adopted a 

previously adopted child, although it was unclear whether they had legally 

adopted the child or whether the child was transferred without court 

oversight.

It is possible that conversations on the specifics of transferring a child 

were held either through private messages within the social media 

platform or by another means, such as email or phone. Because we did 

not investigate these posts further and because discussions between 

online participants can be continued privately, we were unable to 

45The online posts did not provide sufficient information to determine whether the posters 

intended to pursue an unregulated transfer, or to pursue an adoption or other legal 

placement.

Observations of Social 

Media Sites Found 

Families Seeking New 

Homes for Their Adopted 

Children

Page 28 GAO-15-733 Unregulated Child Custody Transfers 

 
determine whether a child was actually transferred to another family. 

Similarly, we were unable to determine, if such a transfer occurred, 

whether it was done through official means or an unregulated transfer.

Page 29 GAO-15-733 Unregulated Child Custody Transfers 
We identified 15 states in which laws were enacted, proposed legislation

was introduced, or recent changes had been made to child welfare 

programs that were intended to safeguard children who may be subject to 

unregulated transfers. These included the seven states we selected for 

interviews as well as eight states recommended by representatives from 

child welfare and adoption organizations because of legislative activity 

initiated in these states during the course of our review.46 Of these 15 

states, 7 enacted legislation and 3 made changes to child welfare 

programs. In addition, legislators in 10 of the 15 states introduced 

proposed legislation that had not been enacted as of July 2015 (see table 

3).

Table 3: Activity in the 15 States GAO Reviewed to Address Unregulated Child 

Custody Transfers, as of July 2015

State Enacted laws

Made changes to state 

child welfare programs

Proposed legislation 

introduced

Arkansas X

Colorado X

Florida X X

Illinois X

Louisiana X

Maine X

Maryland X

Massachusetts X

46Legislative and other activity to address unregulated transfers began to emerge in states 

after media reports brought attention to the practice in 2013. We reviewed activity in the 

15 states as of July 2015. 

Selected States and 

Federal Agencies 

Have Taken Some 

Steps to Address 

Unregulated 

Transfers

Activity in the 15 States 

GAO Reviewed Mainly 

Involved Efforts to Deter 

Unregulated Transfers

Page 30 GAO-15-733 Unregulated Child Custody Transfers 

 
State Enacted laws

Made changes to state 

child welfare programs

Proposed legislation 

introduced

Nebraska X

New York X X

North Carolina X

Ohio X

South Carolina X

Virginia X X X

Wisconsin X X

Source: GAO analysis of relevant state laws, proposed legislation, and other information provided by state child welfare and other state 

agency officials. | GAO-15-733

Note: GAO did not attempt to identify all relevant legislative and other activity in all 50 states. Thus, 

there may be other states with such activity not included in this table. In addition, some proposed 

legislation included in the table may no longer be pending.

These selected laws, proposed legislation, and other actions within the 15 

states reflect a variety of approaches to addressing unregulated 

transfers.47 The most common approaches were to criminalize 

unregulated transfers or actions that may lead to these transfers, and to 

restrict the advertising of children or potential homes for placement. Other 

approaches may deter unregulated transfers by requiring that parents or 

certain other individuals report cases in which custody of a child may 

have been transferred. Some approaches may help prevent transfers 

from occurring. These included revising requirements for preparing 

prospective parents for adoption and increasing outreach about services 

available to families after adopting (see table 4).

47As described in table 4, some of these approaches have been adopted, while others 

have been proposed but not adopted.

Page 31 GAO-15-733 Unregulated Child Custody Transfers 

 
Table 4: Approaches to Address Unregulated Child Custody Transfers in the 15 States GAO Reviewed, as of July 2015 

Approach States with activity involving this approach

Deter unregulated transfers

Criminalize unregulated transfers or actions that may lead to unregulated 

transfers

Enacted laws: Arkansas, Florida, Louisiana, Maine, 

and Wisconsin

Proposed legislation introduced: Maryland, 

Massachusetts, Nebraska, New York, North 

Carolina, Ohio, South Carolina, and Virginia

Restrict advertising of children or potential homes for placement, and/or 

provide for penalties for violations

Enacted laws: Arkansas, Colorado, Florida, 

Louisiana, Maine, and Wisconsin

Proposed legislation introduced: Maryland, 

Massachusetts, Nebraska, New York, North 

Carolina, and Ohio

Provide information to new adoptive parents on legal implications of 

engaging in unregulated transfers

Enacted laws: Louisiana and Maine

Proposed legislation introduced: Florida and 

Massachusetts

Require certain adoptive parents to notify the state child welfare agency or

their placement agency when they feel they cannot care or are no longer 

caring for an adopted child

Enacted laws: Arkansas

Proposed legislation introduced: Massachusetts

Require certain individuals (e.g., teachers and medical practitioners) to 

report to the child welfare agency in specified circumstances that may

indicate possible unregulated child custody transfers (e.g., if they suspect 

the child is not living with his or her family)

Enacted laws: Maine

Proposed legislation introduced: Ohio

Provide local child welfare agencies and service providers with guidance 

on unregulated transfers (e.g., how to prevent such transfers and what to 

do when a case is identified)

Made changes to state child welfare programs: New 

York

Improve adoption policies and pre- and post-adoption services to prevent unregulated transfers 

Revise requirements for home studies Proposed legislation introduced: Wisconsin

Revise pre-adoption training requirements for prospective parents Proposed legislation introduced: Massachusetts and 

Wisconsin

Require agencies to provide information on a child’s health conditions to 

prospective parents for certain types of adoptions

Proposed legislation introduced: Florida and 

Massachusetts

Improve post-adoption services, including increased outreach to 

families about available services

Enacted laws: Arkansas and Virginia

Made changes to state child welfare programs: 

Illinois, New York, and Virginia

Proposed legislation introduced: Florida, 

Massachusetts, South Carolina, and Wisconsin

Other

Study options to address unregulated transfers and adoption disruptions and 

dissolutions

Enacted laws: Wisconsin

Made changes to state child welfare programs: New 

York and Virginia

Proposed legislation introduced: Ohio

Require the state child welfare agency to review and determine whether to 

terminate adoption subsidies for adoptive parents no longer responsible for 

providing care and support to the child

Enacted laws: Arkansas

Page 32 GAO-15-733 Unregulated Child Custody Transfers 
Approach States with activity involving this approach

Require parents who adopted a child in another country to re-adopt in state 

court

Proposed legislation introduced: Wisconsin

Collect information on whether certain children in the child welfare and 

juvenile justice systems had been adopted before

Proposed legislation introduced: Wisconsin

Set additional requirements for international adoption agencies and attorneys 

(e.g., licensing standards and records to be kept) 

Proposed legislation introduced: Florida, South 

Carolina, and Wisconsin

Source: GAO analysis of relevant state laws, proposed legislation, and other information provided by state child welfare and other state agency officials. | GAO-15-733

Note: This table is intended to be illustrative and not present an exhaustive list of all actions taken by 

these states to address unregulated child custody transfers.

The five states that enacted laws to criminalize unregulated transfers or 

actions that could lead to these transfers made the following changes:

• Arkansas and Louisiana enacted laws that define the practice of “rehoming” and impose criminal penalties for those engaging in it. The 

laws provide that those who commit the offense of re-homing, which 

each state defines differently but generally includes transferring 

physical custody of a child to a non-relative without court approval 

with the intent of avoiding permanent parental responsibility (or 

assisting in such a transfer), will be subject to a fine of up to $5,000 

and imprisonment for up to 5 years.48

• Similarly, Florida enacted a law establishing the crime of “unlawful 

desertion of a child,” which provides that a caregiver who deserts a 

child (leaves the child with a non-relative with the intent to not return 

and provide for the child’s care) under circumstances in which the 

caregiver knew or should have known that the child would be exposed 

to unreasonable risk of harm commits a third degree felony.49

• Maine also enacted a similar law, modifying its definition of 

“abandonment of a child.” This law provides that a person is guilty of 

child abandonment if they transfer physical custody of a child to a 

non-relative without court approval with the intent to avoid or divest 

48Ark. Code Ann. § 5-27-211; La. Rev. Stat. Ann. § 14:46.4. In Arkansas, re-homing 

applies only to adopted minors. The laws in Arkansas and Louisiana outline certain 

exceptions, such as placements made by or with state child welfare agencies or licensed 

adoption agencies. 

49Fla. Stat. § 827.10.

Page 33 GAO-15-733 Unregulated Child Custody Transfers 

 
themselves of permanent parental responsibility. The law specifies 

that violation of this provision constitutes different classes of crimes, 

depending on the age of the child.50

• Wisconsin enacted a law that placed parameters on parental 

delegations made through a power of attorney, and established

criminal penalties for unauthorized transfers of children across state 

lines. This law provides that delegations to a non-relative of a child’s 

care and custody under a power of attorney may be effective for no 

longer than 1 year unless approved by a juvenile court, and those who 

violate this provision are subject to a fine of up to $10,000 and/or 

imprisonment for up to 9 months. In addition, the law states that any 

person who sends a child out of the state, brings a child into the state, 

or causes such actions to occur for the purpose of permanently 

transferring physical custody of the child to a non-relative is guilty of a 

misdemeanor.51

Six states enacted laws to restrict the advertising of children or potential 

homes for adoption or other permanent placement. Specifically, 

Arkansas, Colorado, Florida, Louisiana, Maine, and Wisconsin created or 

expanded prohibitions on who can place such advertisements, limited the 

purposes for which these advertisements can be placed, restricted the 

public media that can be used (e.g., the internet), and/or provided 

penalties for violations.52

Officials from selected states, child welfare and adoption organizations, 

and adoption agencies we interviewed discussed some trade-offs and 

considerations in implementing these approaches to deterring 

unregulated transfers. For example, several stakeholders said a power of 

attorney can be used for legitimate purposes, such as a military parent 

50To be codified at Me. Rev. Stat. Ann. tit. 17-A, § 553. The law provides for an affirmative 

defense if a person temporarily transferred physical custody of the child for a designated 

short-term period due to incarceration, military service, medical treatment, or incapacity, 

with a specific intent and time period for the return of the child.

51Wis. Stat. §§ 48.979 (delegation of power by parent), 948.25 (unauthorized interstate 

placements of children). The law in Wisconsin outlines certain exceptions to the interstate 

placement penalties, such as placements of children approved by a court in the sending or 

receiving state. 

52Ark. Code Ann. 5-27-211; Colo. Rev. Stat. § 19-5-213.5; Fla. Stat. § 63.212; La. Rev. 

Stat. Ann. 14:46.4; to be codified at Me. Rev. Stat. Ann. tit. 18-A, § 9-313; Wis. Stat. § 

48.825. 

Page 34 GAO-15-733 Unregulated Child Custody Transfers 

 
transferring custody of their child to a trusted friend while on deployment. 

They noted that placing additional conditions on power of attorney 

transfers can create a burden for these families. In addition, officials from 

three selected states and three child welfare and adoption organizations 

questioned how states could enforce the use of a power of attorney. 

Officials from one national organization specializing in adoption law said 

courts that may be involved in approving power of attorney agreements 

have other priorities and may not have time to monitor these agreements. 

Several stakeholders also said families often go online to access adoption 

resources and peer support forums. They said states need to consider 

the information that these online forums provide to adoptive families when 

considering laws related to the internet.

In addition to approaches that would deter unregulated transfers, 4 of the 

15 states we reviewed enacted laws or made changes to child welfare 

programs to improve post-adoption services for families. Specifically:

• Arkansas enacted a law that directed the state child welfare agency to 

adopt rules to ensure that post-adoptive services are provided to all 

parents who seek assistance to prevent their adoptions from being 

disrupted.53

• Virginia enacted a law and made changes to its state child welfare 

programs to improve post-adoption services based on 

recommendations from a study it conducted on unregulated 

transfers.54 The law requires the state registrar to issue, along with 

new adoptive birth certificates, a list of available post-adoption 

services, and requires the state child welfare agency to provide a list 

of such services to the registrar and publish it on its website.55 In

addition, Virginia officials said the state child welfare agency plans to 

modify the solicitation for its post-adoption services contracts to allow 

53Ark. Code Ann. § 9-9-405. Arkansas also modified its definition of “abandonment” to 

exclude situations in which a child has disrupted his or her adoption and the adoptive 

parent has exhausted the available resources. Ark. Code Ann. §§ 9-27-303, 12-18-103.

54Virginia Commission on Youth, Unlawful Adoption of a Child—Study of Senate Bill 411, 

2014 Regular Session of the Virginia General Assembly, Report Document No. 460 

(Richmond, VA: October 31, 2014). 

55Va. Code Ann. §§ 32.1-261, 63.2-1220. Virginia’s child welfare agency published a 

brochure in July 2015 that lists available post-adoption services on its website. See 

http://www.dss.virginia.gov/family/ap/. 

Page 35 GAO-15-733 Unregulated Child Custody Transfers 

 
services to be provided by multiple regional providers rather than one 

statewide provider. Virginia officials said the intent of this change is to 

increase access to services for families statewide.

• Illinois and New York also made changes to their child welfare 

programs to increase outreach specifically to new parents who 

adopted from foster care, although these states did not make statutory 

changes. Illinois developed a pilot project for agencies facilitating 

foster care adoptions to host celebrations and social events to build 

relationships with these families and connect them with other families. 

New York developed a brochure for adoption agencies to provide to 

new adoptive parents that includes information on unregulated 

transfers and possible sources of help with post-adoption needs.

While many stakeholders we spoke with highlighted families’ challenges 

with accessing pre- and post-adoption services as key reasons for 

unregulated transfers, they also commented on possible challenges in 

implementing certain policy options to improve access to and availability 

of such services. For example, officials from nearly half of the child 

welfare and adoption organizations we spoke with said building a strong 

infrastructure for adoption services can be a lengthy and costly task. They 

said states have been trying to bolster services, but have had limited 

success. Given limited funding, officials from most selected states, child 

welfare and adoption organizations, and adoption agencies we 

interviewed expressed concern about the level of support for postadoption services. Many of these stakeholders said families experiencing 

difficulties in their adoptions need services, and unregulated transfers are 

a last resort for desperate families who feel they have no other option. 

They also stated that improving access to effective services may 

ultimately help all families meet the needs of their adopted children.

Page 36 GAO-15-733 Unregulated Child Custody Transfers 
Federal agencies have made some collaborative and individual efforts to 

address unregulated transfers, mainly by raising awareness of the need 

for improved pre- and post-adoption services and by sharing information 

with states (see table 5). In some instances they have also collaborated 

with non-governmental organizations that have relationships with state 

child welfare and law enforcement agencies, such as the Association of 

Administrators of the Interstate Compact on the Placement of Children56

and the National Association of Attorneys General.57

Table 5: Examples of Actions Taken by Federal Agencies and Their Partners to Address Unregulated Child Custody 

Transfers, as of July 2015 

Action Federal agencies and partners involved Status

Established an interagency working group Department of State, Department of 

Homeland Security’s U.S. Citizenship and 

Immigration Services (USCIS), 

Department of Health and Human 

Services (HHS), and Department of 

Justice (Justice)

Began in October 2013; 

ongoing

Began efforts to revise pre-adoption training requirements 

for international adoptions

Department of State Began in November 2014; 

ongoing

Revised certain international adoption immigration 

applications and petitions to ask for information on whether 

the family previously applied or experienced a disruption or 

dissolution 

USCIS Completed February 2015

Issued a memorandum to state child welfare agencies that 

provided information on the practice of unregulated transfers, 

and encouraged states to review their laws and policies and 

promote post-adoption services

HHS Issued May 2014

Compiled information on existing state laws and pending 

legislative activity to address unregulated transfers

Justice, in collaboration with the National 

Association of Attorneys General 

Completed June 2015

56The Association of Administrators of the Interstate Compact on the Placement of 

Children is composed of members from all states (including the District of Columbia and 

the U.S. Virgin Islands) and establishes rules for carrying out the terms of the Interstate 

Compact on the Placement of Children. This compact is an agreement among all states 

that is enacted into law by each state, and establishes uniform legal and administrative 

procedures that must be followed before a child can be placed from one state to another 

for purposes of foster care, adoption, or certain other circumstances.

57The National Association of Attorneys General is an organization whose members are 

the attorneys general from all states and the District of Columbia, and the chief legal 

officers of five territories, which seeks to foster interstate cooperation on legal and law 

enforcement issues, conduct policy research and analysis of issues, conduct training, and 

facilitate communication. 

Federal Agencies Have 

Taken Steps to Improve 

Adoption Services and 

Share Information on 

Unregulated Transfers 

with States

Page 37 GAO-15-733 Unregulated Child Custody Transfers 

 
Action Federal agencies and partners involved Status

Through a cooperative agreement, provided funding to 

develop training for mental health providers on adoption 

issues

HHS Awarded in October 2014; 

completion expected in 

September 2019

Through a cooperative agreement, provided funding to 

develop evidence-based pre- and post-adoption interventions 

and services 

HHS Awarded in October 2014; 

completion expected in 

September 2019

Solicited public comment on HHS’s policies on suspending 

and terminating Title IV-E Adoption Assistance subsidies, 

noting that there currently is no recourse for state child 

welfare agencies if adoptive parents do not respond to 

requests for information about whether the parents are 

providing any support to or remain legally responsible for their 

adopted child

HHS Federal Register notice 

published March 2015; 

public comments due in 

June 2015; ongoing

Began efforts to revise federal websites to provide families 

with information on post-adoption services from state, local, 

and private resources

Department of State, in collaboration with 

USCIS, HHS, and Justice

Begin in July 2015; 

ongoing

Began efforts to raise awareness of unregulated transfers 

through public awareness and outreach campaigns 

Association of Administrators of the 

Interstate Compact on the Placement of 

Children

Began in October 2014; 

ongoing

Began efforts to track cases of child custody transfers that 

violate the Interstate Compact on the Placement of Children 

Department of State and the Association 

of Administrators of the Interstate 

Compact on the Placement of Children

Began in June 2015; and 

ongoing

Source: GAO summary of documents and information provided by the State Department, USCIS, HHS, Justice, Association of Administrators of the Interstate Compact on the Placement of Children, and 

the National Association of Attorneys General. | GAO-15-733

As shown in table 5, the State Department established an interagency 

working group in October 2013 to develop a coordinated federal response 

to unregulated transfers. Other federal agency participants are USCIS, 

HHS, and Justice. With input from the group, the State Department began 

work to revise regulations regarding international pre-adoption training 

requirements. State Department officials said the revisions may 

potentially include an increased number of minimum required hours and 

additional required content, drawing from training curriculum used by child 

welfare agencies for prospective parents in foster care adoptions. In 

addition, the revisions may include required in-person components for 

training. State Department officials said they plan to provide proposed 

revisions to the Office of Management and Budget by the end of 2015 for 

review, and the proposed regulations will be subject to a public comment 

period before being finalized. In addition, in February 2015, USCIS issued 

revised immigration applications and petitions which are used by certain 

Page 38 GAO-15-733 Unregulated Child Custody Transfers 
families applying to adopt from certain countries.58 The revisions included 

a requirement that families disclose whether they have previously filed 

international adoption applications or petitions and the result of the filings 

(i.e., approval, denial, withdrawal). Additionally, the revisions require 

families to disclose if they have experienced a disruption or dissolution of 

an international adoption in the past.

HHS has also taken a number of actions to help improve access to 

adoption services. For example, it issued a memorandum in May 2014 to 

states that encouraged them to promote services to all adoptive families 

and outlined various sources of available federal funds.59 The memo also 

shared information on how unregulated transfers may violate state laws 

and encouraged states to review their laws and policies. In addition, HHS 

awarded two cooperative agreements with 5-year project periods in 

October 2014 to national organizations to improve post-adoption services. 

The National Adoption Competency Mental Health Training Initiative aims 

to build a web-based training curriculum for child welfare professionals 

and mental health practitioners to meet the mental health needs of 

adopted children, develop a national certification process for those 

completing it, and evaluate its outcomes and effectiveness. The National 

Quality Improvement Center for Adoption/Guardianship Support and 

Preservation aims to develop evidence-based pre- and post-adoption 

interventions and services for prospective and current adoptive families. 

Interventions and services will be evaluated at six to eight selected sites 

(e.g., state, county, or tribal child welfare agencies). Both projects are 

expected to be completed in September 2019. HHS officials also noted 

that information on pre-adoption requirements and post-adoption 

services, by state, is available on HHS’s Child Welfare Information 

Gateway, a website that provides information, resources, and tools on 

child welfare, child abuse and neglect, out-of-home care, adoption, and 

other topics.60 In addition, they said HHS has been involved in 

discussions with states regarding post-adoption services over the years. 

For example, HHS hosted a conference on the needs of adopted 

58These revisions apply to immigration applications and petitions for adoptions of children 

from countries that are not parties to the Hague Adoption Convention. 

59Department of Health and Human Services, Rehoming of Adopted Children: 

Responsibilities for States and Opportunities in the Provision of Post-adoption Services, 

ACYF-CB-IM-14-02 (Washington, D.C.: May 30, 2014).

60See https://www.childwelfare.gov/. 

Page 39 GAO-15-733 Unregulated Child Custody Transfers 

 
children—including post-adoption services—in August 2012, and was 

involved in a forum on unregulated transfers and services for adoptive 

families in February 2014 through the National Association of State 

Adoption Programs, Inc.61

Because states are responsible for much of the work to improve adoption 

services, the interagency working group has collaborated with national 

organizations to share information with states. Specifically, Justice 

worked with the National Association of Attorneys General to gather 

information on existing state laws and pending legislative proposals to 

address unregulated transfers.62 Research fellows at the National 

Association compiled this information for all states. The organization also 

requested information from all state attorneys general offices, and 

received responses from six states and the District of Columbia. The 

organization completed this work in June 2015, and Justice officials said 

they are reviewing the study and will work with the interagency working 

group to determine next steps, if any, to be taken.63 In addition, the 

Association of Administrators of the Interstate Compact on the Placement 

of Children is working to develop a national outreach campaign to raise 

awareness about unregulated transfers and provide information on 

alternatives to this practice. Officials from the Association said they are in 

the process of soliciting funds from private and non-profit organizations to 

support such a campaign.

61For results from the August 2012 conference on the needs of adopted children, see 

Department of Health and Human Services, Domestic and International Adoption: 

Strategies to Improve Behavioral Health Outcomes for Youth and Their Families

(Rockville, Md.: Substance Abuse and Mental Health Services Administration, Jan. 28, 

2015). The National Association of State Adoption Programs, Inc. is a professional peer 

organization that provides a forum through which state adoption program managers can 

pool their expertise and promotes networking activities among states. 

62Information was gathered on state laws on child abuse, neglect, and abandonment, 

intrastate or interstate transfers of child custody, and voluntary relinquishment of child 

custody to the state. Information was also gathered on any legislative proposals and 

pending criminal cases involving unregulated transfers in each state. 

63In addition to efforts by the federal interagency working group, the National Conference 

of State Legislatures has also begun to compile information on states that have enacted 

laws to address unregulated transfers. This organization provides information and 

resources to all state legislators and their staff, and aims to improve the quality and 

effectiveness of state legislatures, promote policy innovation and communication among 

them, and ensure they have a strong, cohesive voice in the federal system.

Page 40 GAO-15-733 Unregulated Child Custody Transfers 

 
Despite these efforts, federal officials acknowledged that gaps in services 

for adoptive families remain, and determining how to provide them is a 

difficult task for public and private agencies working with these families. 

For example, HHS officials noted limitations to the federal government’s 

ability to support post-adoption services. They said that while all adopted 

children will need some level of support after an adoption is final, the 

main source of federal support—the Title IV-E Adoption Assistance 

program—is limited, and is generally available only to families who 

adopted eligible children from foster care. Consistent with our findings in 

previous reports, HHS officials said funds from other federal programs 

that states can use to support services for private adoptions, including 

international adoptions, are limited.64 Officials said families who cannot 

afford services on their own must often rely on services supported by 

state and local funding or those provided by private adoption agencies, 

and funds from these sources are also limited. HHS officials told us that 

the administration included in its fiscal year 2016 budget request a 

legislative proposal that would provide an increase of $587 million over 10 

years for pre- and post-adoption services. They said this funding would 

target services to families with children who may be subject to 

unregulated transfers as well as those at risk of entering foster care due 

to an adoption in crisis.

Federal officials said they will continue to examine ways to address 

unregulated transfers. For example, the State Department has developed 

a charter to outline its goals and plans for future work. State Department 

officials said they will use this charter to facilitate future efforts with the 

interagency working group.

We provided a draft of this report to the Secretaries of Health and Human 

Services, Homeland Security, and State and the Attorney General of the 

United States for review and comment. The Departments of Health and 

Human Services, Homeland Security, and State provided technical 

comments that were incorporated, as appropriate. The Department of 

Justice had no comments.

We are sending copies of this report to relevant congressional 

committees, the Secretaries of Health and Human Services, Homeland 

Security, and State, the Attorney General of the United States, and other 

64GAO-13-170.

Agency Comments 

and Our Evaluation

Page 41 GAO-15-733 Unregulated Child Custody Transfers 

 
interested parties. In addition, this report will be available at no charge on 

GAO’s website at http://www.gao.gov.

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

me at (202) 512-7215 or brownke@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff that made key contributions to this 

report are listed in appendix II.

Kay E. Brown

Director

Education, Workforce and Income Security Issues

Page 42 GAO-15-733 Unregulated Child Custody Transfers 
Appendix I: Objectives, Scope, and 

Methodology

GAO examined (1) the reasons adoptive families consider unregulated 

child custody transfers, and services that exist to support these families 

before they take such an action; (2) what is known about the prevalence 

of these transfers; and (3) actions selected states and federal agencies 

have taken to help address such transfers. To address these objectives, 

we used a variety of methods. Specifically, we 

• conducted interviews with 45 agencies and organizations, including 

officials from federal and selected state agencies, child welfare and 

adoption organizations, and adoption agencies, to acquire a range of 

perspectives on this topic;

• reviewed relevant federal laws and regulations, selected state laws, 

and federal and selected state policies;

• reviewed and analyzed documentation provided by officials we 

interviewed;

• conducted a search of related literature and reviewed relevant 

articles; and

• searched online forums on selected social media sites to find 

illustrative examples of families who may be considering unregulated 

transfers.

Because children adopted domestically as infants and those in biological 

families may be less likely to have mental health issues due to trauma 

and institutionalization, and reports of unregulated transfers have 

primarily pertained to children adopted internationally or from foster care, 

our report focuses on international and foster care adoptions.

To understand why families consider unregulated child custody transfers, 

what training and services are available to adoptive families, and actions 

selected states and federal agencies have taken to help address such 

transfers, we conducted interviews with 45 agencies, states, and 

organizations, including federal officials, representatives from national 

child welfare and adoption organizations, officials from selected states, 

and representatives from adoption agencies. Federal officials we 

interviewed included those from the Department of State (State 

Department), the Department of Homeland Security’s U.S. Citizenship 

and Immigration Services (USCIS), the Department of Health and Human 

Services (HHS), and the Department of Justice (Justice).

We interviewed representatives from 19 organizations that work on child 

welfare and adoption issues. The 19 organizations we interviewed were 

selected to represent a variety of views on adoption and child welfarerelated policy, training, and research. For example, these organizations 

Appendix I: Objectives, Scope, and 

Methodology

Interviews of Child 

Welfare and Adoption 

Stakeholders

Page 43 GAO-15-733 Unregulated Child Custody Transfers 
Appendix I: Objectives, Scope, and 

Methodology

specialized in certain aspects of adoption, including adoption law, home 

studies, pre-adoption training, and post-adoption services. We 

interviewed the following child welfare and adoption organizations and 

experts: American Academy of Adoption Attorneys; American Bar 

Association’s Center on Children and the Law; Association of 

Administrators of the Interstate Compact on the Placement of Children; 

Center for Adoption Policy; Center for Adoption Support and Education; 

Child Welfare League of America; Coalition for Children, Youth, and 

Families; Congressional Coalition on Adoption Institute; Council on 

Accreditation; the Donaldson Adoption Institute; Joint Council on 

International Children’s Services; Madeline Freundlich; Maureen Flatley; 

National Center for Missing and Exploited Children; National Center on 

Adoption and Permanency; National Conference of State Legislatures; 

North American Council on Adoptable Children; Spaulding for Children; 

and Voice for Adoption.

In addition, we interviewed officials from state child welfare agencies and 

other relevant offices in seven selected states: Colorado, Florida, Illinois, 

Louisiana, Ohio, Virginia, and Wisconsin. These states were chosen 

based on factors such as legislative activity related to unregulated 

transfers in the state, as identified by representatives from child welfare 

and adoption organizations during our initial interviews, and the state’s 

post-adoption programs.1 These states also provided variety in numbers 

of adoptions in relation to the state’s population. Interviews with officials 

were conducted through site visits to Florida and Wisconsin, and phone 

calls to the remaining states. In the states selected, the team conducted 

interviews with officials from state child welfare agencies and other 

relevant offices, such as those from state attorney general offices, 

departments of justice, and adoption agency licensing offices.

Finally, we interviewed representatives from 15 international and 

domestic adoption agencies. The adoption agencies we interviewed were 

selected from those either recommended by national organization

representatives or those licensed or accredited in the states we visited inperson to achieve variation in agency size, including budget and staff and 

1

In this report, we define legislative activity within a state to include enacted laws as well 

as proposed legislation that has been introduced in the state legislature, even if not 

enacted. To identify states that had a variety of post-adoption programs, we asked 

representatives from child welfare and adoption organizations that we interviewed to 

identify states that, in their opinion, had comprehensive programs. 

Page 44 GAO-15-733 Unregulated Child Custody Transfers 

 
Appendix I: Objectives, Scope, and 

Methodology

types of adoptions facilitated.2 For example, 11 of the 15 adoption 

agencies facilitate international adoptions.3 The remaining 4 agencies 

facilitate domestic adoptions only, such as through the child welfare 

system (through a contract with the state child welfare agency) or 

privately.

In the report we refer to different types of organizations when reporting

information from our interviews with the 7 selected states, 19 child welfare 

and adoption organizations, and 15 adoption agencies. References to 

“stakeholders” include responses from officials in all three of these 

groups. In our interviews with stakeholders, we used a semi-structured 

interview protocol that included open-ended questions about reasons that 

families may consider unregulated transfers, types of services adoptive 

families may need to prevent them from resorting to these transfers, and 

types of services that are available to adoptive families. Information was 

volunteered by officials in each interview in response to these openended questions. Thus, the counts of organizations citing such responses 

vary.

In addition, in the report we use qualifiers, such as “several” and “many,” 

in some cases to quantify responses from stakeholders across our 

interviews with the three groups (41 agencies, states, and organizations 

in total). These qualifiers are defined as follows:

• “All” stakeholders represents 41

• “Most” stakeholders represents 21-40

• “Many stakeholders” represents 10-20

• “Several” stakeholders represents 4-9

• “A few” stakeholders represents 2-3

We reviewed relevant documents to corroborate information obtained in 

our interviews.

2

Domestic adoption agencies are typically licensed by states. International adoption 

agencies are accredited by the Council on Accreditation, a nonprofit organization.

3

Nine of the 11 agencies that facilitate international adoptions also facilitate domestic 

adoptions.

Page 45 GAO-15-733 Unregulated Child Custody Transfers 

 
Appendix I: Objectives, Scope, and 

Methodology

To examine federal efforts related to unregulated transfers, we reviewed 

relevant documents obtained in our interviews with federal officials. We 

also reviewed relevant federal laws, regulations, and policies on agency 

roles and responsibilities as well as GAO criteria on internal controls.4

To examine selected state efforts related to unregulated transfers, we 

reviewed information on recently enacted laws, proposed legislation, and 

other documents provided by child welfare and other agency officials in 

our seven selected states. Through our interviews with representatives 

from child welfare and adoption organizations and others, we identified at 

least eight additional states that had initiated legislative activity related to 

unregulated transfer since we began our review: Arkansas, Maine, 

Maryland, Massachusetts, Nebraska, New York, North Carolina, and 

South Carolina. For these eight identified states, we also reviewed 

relevant laws, proposed legislation, and other documents provided by 

child welfare and other agency officials in these states. For proposed 

legislation, we reviewed only the version confirmed by the state officials. 

We did not do further research on the status of these proposals; 

therefore, additional changes may have been made that are not reflected 

in this report, and some proposed legislation included in the report may 

no longer be pending. We asked officials in the 15 selected and identified 

states to confirm whether their state had enacted a law, introduced 

proposed legislation, or took other relevant activity as of July 2015. We 

did not report on such activity after this date. Since we did not attempt to 

identify all activity related to unregulated transfers in all states, there may 

be other states with relevant legislative or other activity not included in our 

review.

We conducted a search of literature related to unregulated child custody 

transfers in order to gather information about why families may consider 

these transfers, what policies exist to safeguard children who might be 

subject to such transfers, what training is required to adopt, and what 

services are available to adoptive families. While our search resulted in 

some literature on adoption dissolutions and disruptions as well as 

services for adoptive families, we were unable to locate academic 

literature regarding unregulated transfers.

4

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1, 1999).

Review of Federal

and Selected State 

Laws, Regulations, 

and Policies

Literature Search

Page 46 GAO-15-733 Unregulated Child Custody Transfers 

 
Appendix I: Objectives, Scope, and 

Methodology

We searched online forums on selected social media sites to find 

illustrative examples of families who may be considering unregulated 

child custody transfers. Using keywords such as “rehoming” and 

“adoption disruption,” we searched selected social media sites to locate 

online forums—such as groups and message boards—that parents might 

use to seek new homes for their children. For example, these forums 

were characterized on the sites as support groups for parents who wish to 

dissolve an adoption or whose children have behavioral issues. The 

results of our searches were not exhaustive as we were unable to 

ascertain whether we identified most or all social media sites and forums 

with online activity that may relate to unregulated child custody transfers.

We observed posts by participants in eight forums on two websites over a 

15-month time period (January 1, 2014, through April 1, 2015). We 

analyzed posts on two of the eight forums that involved individuals who 

posted that they were seeking a new family for their child or who posted 

that they wanted to adopt a child. We did not find posts involving 

individuals seeking a new family for their child in the remaining six 

forums. The online posts we identified did not provide sufficient 

information to determine whether the posters intended to pursue an 

unregulated transfer, or to pursue an adoption or other legal placement.

Since we did not investigate individual cases, our approach did not allow 

us to determine whether the information posted by online participants was

accurate. Moreover, because discussions between online participants can 

be continued privately, we were unable to determine whether a child was 

actually transferred to another family and, if so, whether this was done 

through a court-approved process or through an unregulated transfer.5

One of the eight forums we observed was shut down in March 2015 by 

the social media site that hosted it.

We conducted this performance audit from October 2014 to September 

2015 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

5

Our review was not designed to determine the legality of the posters’ actions. However, 

we provided the information we collected to the Department of Justice, and in cases 

where sufficient information was available, to state law enforcement.

Searches of Online 

Forums on Selected 

Social Media Sites

Page 47 GAO-15-733 Unregulated Child Custody Transfers 

 
Appendix II: GAO Contact and Staff 

Acknowledgments

Kay E. Brown, (202) 512-7215 or brownke@gao.gov

In addition to the contact name above, the following staff members made 

key contributions to this report: Elizabeth Morrison, Assistant Director; 

Elizabeth Hartjes; Nhi Nguyen; and Amy Sweet. Also contributing to this 

report were: Susan Aschoff; Laurel Beedon; Maurice Belding; Sarah 

Cornetto; Sara Edmondson; Kirsten Lauber; Ashley McCall; Mimi 

Nguyen; Brynn Rovito; and Almeta Spencer.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(131326) Page 48 GAO-15-733 Unregulated Child Custody Transfers 
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