Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

TRENDS IN FOSTER CARE 

Richard P. Kusserow 

INSPECTOR GENERAL 

OEI-01-90-00490 
EXECUTIVE SUMMARY 

PURPOSE 

In this study we indicate recent trends concerning the number of children in foster 

care caseloads, their age, and their placement status (group homes or foster family 

homes). 

BACKGROUND 

On a nationwide basis, there is little timely and reliable information available on 

children in foster care. This situation exists despite more than a decade of Federal 

deliberations concerning the establishment and operation of a foster care and 

adoption data collection system. 

In the informational void, national policymakers find that many vital questions cannot 

be answered with much certainty. One such set of questions involves the number and 

age of foster care children being placed in group care facilities as opposed to 

individual foster family homes. 

To help answer such questions, we conducted a telephone and follow-up mail survey 

of State child welfare officials in the 50 States and the District of Columbia. In 

addition, we (1) conducted on-site interviews with public and private sector officials 

involved with the delivery of child welfare services in the nation’s two most heavily 

populated States, California and New York, and (2) reviewed much literature and 

many documents concerning foster care. 

FINDINGS 

l&e Number of Children in Foster Care Has Been Increasing 

After years of apparently little or no growth, the national foster care caseload 

increased substantially in the last half of the 1980’s. From 1985 to 1989, for 38 

reporting States, the caseload rose by 33 percent, from 228,155 to 304,431. 

b Eighty-six percent of the growth occurred in only 11 States. California and 

New York together accounted for 65 percent of the growth. 

b In both California and New York, a rise in caseload admissions in relation to 

discharges has propelled the growth. 

I 
lk hmndon of Ihdtook and Infan& in Fader Care Has Been Inching. 

From 1985 to 1989, for 15 reporting States, the proportion of infants and preschoolers 

in the foster care caseload increased from 22 percent to 31 percent. During the same 

period, the proportion of 15- to 18-year-olds declined from 32 percent to 22 percent. 

b In California and New York, these trends were slightly more pronounced. The 

proportion of infants and preschoolers rose from 22 percent to 34 percent as 

the proportion of 15- to 18-year-olds declined from 31 percent to 18 percent. 

From 1985 to 1989, for 33 reporting States, the number of foster children in group 

homes increased by 16 percent, from 44,226 to 51,189. California and New York 

accounted for 57 percent of this growth. 

During the same period, however, the proportion of foster children in group care in 

these 33 States declined slightly but steadily from 21 percent to 18 percent. 

During the last half of the 1980’s, infants and preschoolers accounted for a small but 

increasing proportion of group home caseloads. From 1985 to 1989, for 11 reporting 

States, the proportion increased from 2.7 percent to 5.4 percent, in contrast to the 

proportion of 15- to 18-year-olds, which decreased from 58 percent to 53 percent. 

b For California and New York, the data we obtained are not exactly 

comparable. It is apparent, however, that in those States during the 1985-1989 

period, the small proportion of very young children in the group home caseload 

increased at an especially sharp rate. 

RECOMMENDATION 

The Administration for Children and Families (ACF) should specify its plans for the 

preparation and regular distribution of policy-relevant tables and for special analyses 

concerning the data in the proposed foster care and adoption data collection system. 

It should indicate these plans in the preamble to the regulations to be issued 

concerning the system. 

CoMMEm 

We received comments on the draft report from the ACF and the Assistant Secretary 

for Planning and Evaluation (ASPE). Both ACF (in oral comments) and ASPE (in 

written comments) expressed concern about our draft report recommendation calling 

for immediate implementation of essential aspects of the foster care and adoption 

data collection system. Because of our understanding that ACF has removed 

ii 
duplicative and unnecessary data elements included in its earlier proposal, we have 

dropped that recommendation. 

On our only remaining recommendation, which calls for ACF to specify its plans for 

the preparation and regular distribution of policy relevant tables and for special 

analyses concerning the data collection system, ACF agreed to take the 

recommendations “under advisement” and respond “to the extent possible.” 

... 111 
TABLE OF CONTENTS 

APPENDIX c 

Tables Derived From OIG Survey 

of Child Welfare Agencies s ea+- - - - - - as - - - - s s - q 

APPENDIX D 

Detailed Comments on the Draft Report 

and OIG Response to the Comments - - - - - - - - - - m-
INTRODUCTION 

For many governmental programs, national information on the number, age, and, 

where applicable, placement status of clients can be regarded as a given. For the 

Federal-State foster care program, that is not the case. On a nationwide basis, there 

is little information available on the foster care caseload, a fact that seriously limits 

policymakers’ understanding of the program’s effectiveness. 

PURPOSE 

The purpose of our study is to provide information on the foster care caseload that 

will help policymakers assessthe program. Toward that end, this report focuses on 

three basic questions: How many children are in foster care? How old are they? In 

what kind of settings are they being placed?’ 

In addressing these questions, we emphasize the changes that have occurred during 

the last half of the 1980’s. To the limited extent our information allows, we also 

address the factors that appear to be responsible for these changes. 

METHODOLOGY 

Our methodology (see appendix B) is based on three major data-gathering 

approaches: (1) a telephone and follow-up mail survey with State child welfare 

officials in the 50 States and the District of Columbia, (2) on-site interviews with 

public and private sector officials involved with the delivery of child welfare services in 

* California and New York, and (3) a review of literature and documents concerning 

child welfare services in general and foster care in particular. 

Most of the trend data set forth is based on our State survey. In collecting, analyzing, 

and presenting these data, we faced a number of methodological problems associated 

with the varied and often incomplete nature of the State data systems. In appendix B, 

we indicate how we addressed these problems. 

Throughout the report, we regard the universe of foster care children to include all 

children who are placed away from their parents or guardians and are the 

responsibility of the State child welfare agencies, whether or not they have been 

placed by private service agencies. These children may be placed in foster family 

homes or group homes. We define the former to include homes where foster parents 

care for foster children and receive payments for board and care and other necessary 

living expenses associated with these children. We define group homes as facilities 

that are operated by a group or organization and are managed on a 24-hour basis by 

caregivers who are paid staff. 

1 
THE PROGRAMMA TIC CONTEXT 

In 1980, Congress passed the Adoption Assistance and Child Welfare Amendments 

Act (P.L. 96-272). The law called for considerable reform in the nation’s foster care 

system. It sought to (1) decrease the need for out-of-home placement of children by 

making services available to children at risk and (2) reduce the length of stay in foster 

care by offering more extensive case management and “permanency planning.” 

The centerpiece of the legislation was a new Title IV-E of the Social Security Act.2 

This title mandated procedural standards, case planning and review activities, and 

record-keeping requirements for a system that has been the nearly exclusive purview 

of State governments. Moreover, it authorized open-ended Federal funding to the 

States for certain administrative and training activities and for foster care maintenance 

payments for children, from birth to 18 years of age, who meet eligibility criteria based 

in part on the child’s eligibility under the Aid to Families with Dependent Children 

(AFDC) program. In addition, it authorized adoption assistance payments for “special 

needs” children , children who originate from families eligible for AFDC who are 

physically or emotionally disabled, adolescents, or members of a sibling or ethnic 

minority group. 

During the 1980’s, Federal expenditures for Title IV-E rose substantially. From fiscal 

year 1981 to fiscal year 1988, the Federal share of administrative and training costs 

climbed from $30.4 million to $352.5 million and the Federal share of foster care 

maintenance costs increased from $278.4 million to $520.7 million. The estimated 

expenditures for fiscal year 1991 suggest even greater increases, to $949.2 million for 

Federal administrative and training costs and $927.4 million for Federal foster care 

maintenance costs.3 

In recent years, as the costs of the foster care program have mounted, many policy 

officials at Federal and State levels have expressed concern about the adequacy of the 

care being provided to some of the children. Of particular note has been concern 

about a perceived growth in the group home population. This seems to have been 

exacerbated by press accounts of the emergence of some large orphanage-type 

facilities where, because of shortages of foster families and caseworkers, children are 

said to be “warehoused.” 

Such practices, to the extent they exist, seem to conflict with the social work principle 

of making foster care placement choices on the basis of the individual needs of each 

child and raise questions about the adequacy of services being extended to foster 

children. Yet because there is little current, reliable data on the foster care caseload 

for all the States, any analysis of this kind is seriously constrained. 

2 
THE DATA COLTECI-‘ION SYSTEM CONTEXT 

Congress first addressed the need for a national data collection system more than a 

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

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

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

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

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

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

children in foster care. 

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

the American Public Welfare Association to establish and run the Voluntary 

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

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

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

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

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

reflects inconsistent reporting periods and methodologies. 

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

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

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

to Congress a plan, based on the advisory committee’s report, for establishing and 

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

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

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

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

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

1991. 

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

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

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

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

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

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

will be $1 million. 

3 
FINDINGS 

JWMBER OF CHILDREN IN CASELOAD 

Afret years of ap~rently little or no growth, the nationa! fartercarecask iracmzd 

substantiaLly in the last half of the 1980’s. Rvm I985 to 1989, for 38 rqpdng States, the 

casebad me by 33Fm fiurn 22&155 to 304,431. 

Although definitive assessmentsare not possible, it appears that in the early 1980’s 

there was little if any growth in the national foster care population. In fact, it is 

possible that at mid-decade that population was somewhat less than in the late 1970’s? 

FIGURE 1 

TOTAL FOSTER CARE CASELOAD 1985-1989 

38 STATES 

Thousands 

I I 1 

1oe85 1986 1987 1988 1989 

- 98 Reporting States --e “Top Eleven” 

* CA and NY - Other Stater 

SOURC8: State Child Tellare A#cnclcr 

.‘ reported to OIC 

It is clear, however, that in the last half of the 1980’s the national foster care caseload 

increased significantly. In our national sample, 38 States provided data on the size of 

their caseload for 1985 and each of the subsequent 4 years.6 Together, they showed a 

prominent increase, beginning in 1986 and intensifying between 1988 and 1989 

(figure 1). 

4 
b Eighty-six percent of the growth occurred in only 11 States. California and 

New York together accounted for 65 percent of the growth. 

When one analyzes the 38-State data, it is readily apparent that the growth is 

concentrated in 11 States, especially California and New York (figure 1). These two 

States, together with Illinois, Ohio, Pennsylvania, Michigan, Massachusetts, Florida, 

New Jersey, Washington, and Georgia constitute the ‘Top Eleven.” 

b In both California and New York, a rise in caseload admissions in relation to 

discharges has propelled the growth. 

Caseload size is a function of changes occurring in admissions, on the one hand, and 

discharges, on the other. Thus, for instance, a caseload can increase with no increase 

in admissions as long as discharges decrease. Conversely, a caseload can decrease 

with no decrease in admissions as long as discharges increase. 

FIGURE 2 

FOSTER CARE CASELOAD ADMISSIONS AND DISCHARGES 1985-1989 

New York California 

Thouundr Thouund, 

a0 . 40 

26 -

*o- . 

-

16 -

10 -

10 - _ _^_, .._ _ ..__.___ ..___ . . 

6-

0 

PO66 1066 1667 1666 1666 1666 1866 1907 1988 (818 

Year Year 

- Adml*donr + Dlrchw6.a - Admlulonr + Dkchrrg6r 

COUICEI C1~1~ Child *.I,.,* A,.“.,., 

. . 1*,01w4 t. 010 

To assesssuch caseload dynamics, we asked each State for data on admissions and 

discharges for each of the 5 years studied. Only 6 of the Top Eleven and 15 other 

States were able to provide us with that data. California and New York were among 

5 
-- --- -- 

-- 

-- 

-- 

those providing the data, and in both States it emerges that admissions was the 

propelling force behind the caseload growth, albeit with somewhat different patterns 

(figure 2). In California, the growth in admissions was accompanied each year by an 

increase in discharges. In New York, both admissions and discharges decreased from 

1985 to 1986. Then admissions rose each subsequent year, while discharges first 

declined from 1986 to 1988 and then increased between 1988 and 1989. The 

substantial growth in admissions was primarily attributable to kinship or “approved 

relative home placements” called for by a New York State court ruling.’ 

hving the late 1980’S, the growth in the fbster care cad&d outpaced the ovudl 

hcreuse in thenumberof childrenin thegenemlpopuhio~hm 1985to 1989,for38 

reporting Stateq the number of placements per I,NM children aged I8 and uder me by 

31 pemaq from 3.85 to 5.04. 

FIGURE 3 

TOTAL FOSTER CARE PLACEMENT 1985-1989 

PER 1000 CHILDREN (~=38) 

Placement per 1000 chlldrcn WC O-16 

10, I 

8 _ _- _.._ - __._ _ ---_ -. -..- . - . -...... _ ._ _ ___.. 

‘ 

6 -._._ . .._ ._.__ _ - __._ - .._ -._ 

46 

4 _.-._ 

2 -..-.- ..____ .._ ..__ -.-. ___-..-- __..._-_ _..... -. ---_ 

I I I 

Pees 1986 1987 1988 1989 

98 Reporting States + CA and NY 

- “Top Eleven” - Other statea 

The growth in the foster care population, as the above data indicate, is not just a 

reflection of the increased number of children in the general population. For each of 

the last 5 years of the decade, it also reflects an increased proportion of children in 

the United States who are in a foster care status (figure 3). Indeed, by the end of the 

1980’s a higher proportion of children were in foster care than at anytime in at least 

the last three decades.’ 

6 
b The increase in the 1985 to 1989 period was especial@pronounced in 

California and New York In those States together, the number of placements 

per 1,OCKIchildren aged 18 and under jumped by 62 percent, from 5.74 to 9.32. 

The jump was greatest in New York, where the rate rose from 5.60 to 10.08; in 

California the increase was from 5.83 to 8.88. Among the other Top Eleven States, 7 

also had increases, though typically less pronounced. Two actually had small 

decreases. In Massachusetts, the placement rate per 1,000 children declined from 6.83 

in 1985 to 6.59 in 1989; in New Jersey, from 4.51 to 4.29. 

AGE OF CHILDREN 

From 1985 to 1989, for I5 reprthg Stutces,the ptvptdon of infants and preschookrs in 

the fmter care caseload increawd jbn 22 pemmt to 3I ptmmt bring that same 

w the proportion of I5- to I8-year-ok.& declhed from 32 percent to 22 percent. 

b In California and New York, these trends were slighUy more pronounced. The 

proportion of infants and preschoolers rose from 22 percent to 34 percent as 

the proportion of 15- to l&year+Ms declined from 31 percent to 18 percent. 

FIGURE 4 

AGE DISTRIBUTION OF FOSTERCARE CASELOAD 

1985-1989 (15 STATES) 

Percent of Total Caseload 

35 , 

1985 1986 1987 1988 1989 

m Infants < 1 year m 1-4 years I 5-9 yearr 

IO-14 years m 15-18 pearr 

SOURCE: State Child Welfare A~cnclca 

.a reported Lo OK 

7 
As the overall number of foster care children has increased, the age distribution has 

changed significantly. During the last 5 years of the decade, the oldest group’s share 

of the caseload eroded substantially as the two youngest segments’ share--infants (less 

than 1 year old) and preschoolers (1 to 4 years old)--gained substantially (figure 4). 

This was particularly true in California and New York (figure 5), but the same general 

trend was found in all 15 reporting States. 

FIGURE 5 

AGE DISTRIBUTION OF FOSTER CARE CASELOAD 

CALIFORNIA AND NEW YORK 19854989 

Percent of Total Cueload 

35 

1985 1986 1987 1988 1989 

I Infants < 1 year 0 5-9 yeara 

E2Z IO-14 years 

What is especially striking is the emergence of a foster care baby boom, especially, 

once again, in California and New York. Among the 15 States, the number of infants 

placed in foster care per 1,000 children aged 18 and under rose sharply, from 2.57 to 

6.05; in California and New York, the number rose even more sharply, from 3.38 to 

9.67 (appendix C). In New York City, between 1984 and 1988, the rate at which 

infants were placed in foster care almost tripled from 8.7 per 1,000 live births to 25.3. 

Thus, in 1988, about 2.5 percent of all children born in New York City were placed in 

foster care within a year of birth.g 

PLACEMENT STATUS OF CH-ILDREN 

From I985 to 1989, for 33 reporting States, the number of foster children in group homes 

increased by I6 percent, from 44,226 to 51,189. California and New Yank accounted for 

57pement of thk growth. 

8 
_ 

FIGURE 6 

TOTAL GROUPHOME CASELOAD1985-1989 

33 STATES 

Thousands 

60 

-. 50 .__._ ._.. _ . ._._...._.._......... . . _....__..._ -.._......_... __ __ -._-.. 

t *o t _......- . . ..-. . - .._._-.-.. . _....____...___ -_. __._.__. .-...__..__ - __._...

i 

L 

30- ..__.._.. -__-.. .--_.__ -.-.-- ..-_-.-......^.-

20 -..........._.... . ._-.__...--- _..-.... -.-..... J, 

I II 

10 _ .._....... -_-- -_-.___-.-

I 1 I 

1oss5 1986 1987 1988 1989 

-

- 33 Reporting Slates - “Top Eleven” 

--); CA and NY * Other States 

SOURCE: State Child Kelferc A#encies 

., reported to OIC 

From 1985 to 1987, for 33 reporting States, the number of foster care children in 

group homes remained about the same (figure 6). During the next 2 years, however, 

the group home caseload rose substantially, with close to 60 percent of the growth 

occurring in California and New York. In view of the growth taking place in the total 

foster care caseload, these increases would not appear to be surprising. 

Firm I985 to 1989, fat 33 repolrting Safer, the pvpntiim of fixter children in pup care 

declined~but~fionr2I~toI8~a 

This finding is perhaps more surprising, given the perceptions we noted at the outset 

of this report about the growing number of children in group facilities. Between 1985 

and 1989, the group home population still increased at a rate greater than the increase 

in the 18-year-old-and-under population (appendix C). It declined modestly as a 

proportion of the total caseload, however, as the number of family foster home 

placements rose significantly. Overall, for the 33 reporting States, the number of 

foster children in group homes rose from 207,810 to 280,187. 

9 
I . 

b For California and New York, the data we obtained are not exactly 

comparable. It is apparent, however, that in those States during the 198549 

period, the small proportion of very young children in the group home caseload 

increased at an especially sharp rate. 

In 1989, as in 1985, the 15- to 18-year-olds dominated the group home caseloads. 

Some shifting of the distribution occurred, however, with the oldest group’s share 

declining and the youngest two groups’ share increasing. 

Among the 11 reporting States, which do not include New York, the increase is 

concentrated in California, where between 1985 and 1989, the number of infants in 

group care increased from 74 to 243 and preschoolers from 241 to 820. In contrast, 2 

of the States began and ended the period with no infants and preschoolers in group 

care, 4 experienced a modest increase, and 4 had a decline (in 2 casesa substantial 

decline). 

In New York, a compilation by the State Department of Social Services indicates that 

the proportionate increase has been greatest there. In 1985, 4.1 percent of children in 

group care were 5 years old or younger and 2.1 percent were under 1 year old; by 

1988, the corresponding numbers increased to 19.6 percent and 8.0 percent.” 

In explaining such increases, policy officials in California and New York told us that 

because they had not expected the baby boom in foster care, they did not have 

enough foster family homes for infants to meet the accelerated demand. 

Exacerbating the problem, they added, was that a number of the infants admitted to 

foster care during this period had special health problems associated with human 

immunodeficiency virus (HIV) infection or fetal exposure to drugs. Recruitment and 

support of families to care for such children often require extraordinary efforts. 

It is a generally accepted principle that the most therapeutically desirable placement 

for infants is with families rather than in group facilities. In attempting to adhere to 

this principle, California and New York officials have intensified their recruitment and 

family support efforts. Although it is too soon to know for sure, there are signs that 

these efforts may be having some success. In New York, State officials reported that 

they have developed a waiting list of families willing to care for infants with HIV 

infection, and incomplete data for 1989 indicate some reduction in the proportion of 

infants in group care.” Similarly, Los Angeles County officials reported significant 

recent reductions in the number of infants placed in their county-run receiving center. 

10 
! . 

RECOMMENDATION 

Among the trends identified in the preceding pages, three that stand out are the 

recent increases that have occurred in: (1) the total number of children in foster care 

in the United States, (2) the number and proportion of them who are infants and 

preschoolers, and (3) the number and proportion of these infants and preschoolers 

who have been placed in group homes. 

What accounts for these trends? To what degree and how might they be attributable 

to: 

. intensified social Problems, such as poverty, homelessness,family instability, and 

substance abuse;’ 

. increased reporting of child abuse cases;13 

. higher numbers of foster care kinship placements;” 

. more restrictive funding for mental health, juvenile justice, and social service 

programs than for Title IV-E foster care services;” 

. poor coordination between mental health, juvenile justice, and child welfare 

systems; andi 

. inadequate or nonexistent standards guiding placement decisions?” 

Questions concerning these and other such factors are of increasing urgency to the 

entire child welfare system. That sense of urgency is most readily conveyed by the 

operating reality guiding placement choices in large metropolitan areas such as New 

York City and Los Angeles. In virtually every interview we conducted with 

caseworkers in those cities, the same scenario was described: Children become 

available for placement with little notice to the agency. Workers then begin searching 

for an available slot. Placement workers who have never met these children and who 

typically have only age, race, and gender information staff a phone bank to find bed 

assignments. Although there is no formal policy to that effect, nearly all adolescents 

are placed in group facilities. Others are placed in the first bed available. Many must 

be placed in emergency facilities and/or as “nomad children“ are subjected to a series 

of one-night placements. 

To help address the limitations of the foster care system on a national basis, it is vital 

that a national data collection system be established and that data be widely 

distributed and carefully analyzed. For the more than 300,000 children in the United 

States who are in foster care, we have no recent and reliable information on who they 

are or on the key factors affecting their well-being. In contrast, for example, for the 

11 
150,000 to 160,000 people in the country who have end-stage renal disease, we can 

.. draw upon timely and highly credible data offering considerable details on their 

demographics, health status, and even treatment outcomes. 

Foster care children are no less important than those with kidney failure. To develop 

appropriate policies, we must as a start know more about them. For more than a 

decade, the Federal Government has been deliberating on how to develop a system 

that would provide such knowledge. It is time to act to establish a workable and 

useful foster care and adoption data collection system. 

Toward that end, we offer one recommendation to the Administration for Children 

and Families (ACF). It is intended to help the newly established data system be as 

helpful as possible to policymakers at different levels of government. 

7%eACF shod specify &Yplans for the prqmation and regula ckkbibution ofpdicyrelevant tables and for special analyses concemihg the data in the prvpmed fe care 

and adapt&m data coUection system It shoukl indicate thesepihs in thepmzmble to the 

regdatiom to be iwed concemihg the systm 

In the February 1990 notice of proposed rulemaking, ACF says little about what it will 

do with the data once it receives and checks them--only that it will “produce some 

standard descriptive reports that are routinely processed” and that the data will be 

“available to provide reports back to the States and to support special analyses.” 

This is inadequate for a system that is expected to cost more than $50 million in the 

first 3 years and to contribute to more effective policymaking. 

The ACF should specify the kind of tables it will prepare, indicating how it will 

present information on demographics, circumstances of removal, type of placement, 

and the like. It should also provide for frequent and widespread distribution and 

indicate the kind of special analyses of the data it will undertake. Such actions, we 

believe, are vital if the benefits associated with such a system are to outweigh the 

costs. 

12 
COMMENTS ON THE DRAFI’ REPORT 

We received comments on the draft report from the Administration for Children and 

Families (ACF) and the Assistant Secretary for Planning and Evaluation (ASPE). In 

appendix D, we present their comments in full and our detailed response to them. 

The ASPE comments, which were the most extensive, involved three major concerns. 

The first of these was directed to our recommendation that ACF implement 

immediately the most essential aspects of the foster care and adoption data collection 

system. We made that recommendation because of our concerns about the many 

complexities and costs associated with the comprehensive system envisioned by the 

Department of Health and Human Services. The ASPE opposed any partial 

implementation, as we suggested, because many of the duplicative and unnecessary 

data elements initially proposed by the Department had been eliminated. 

The ASPE’s second major concern involved our lack of recommendations addressing 

larger foster care policy issues, such as those addressing alternative program models 

and the Federal requirement that “reasonable efforts” must be made before removing 

a child from a family. The third was that the report should state more strongly and 

regularly that the numbers presented are estimates. 

The brief ACF written comments supplement an earlier discussion we had with ACF 

staff. In that discussion, the staff also raised some questions about the necessity and 

practicality of the first recommendation. In its written comments, ACF indicated that 

it would take our second recommendation “under advisement” and would respond “to 

the extent possible.” That recommendation called for ACF to specify its plans for the 

preparation of policy-relevant tables and for special analyses concerning data to be 

obtained under the new system. 

Our major response to these comments was to eliminate our first recommendation 

calling for immediate implementation of essential aspects of the foster care adoption 

and data collection system. We did that because of our understanding that ACF has 

addressed some of our concerns about the complexity and constraints of the system 

and has removed certain unnecessary and duplicative data elements proposed earlier. 

We have not addressed larger policy issues because we believe the data obtained for 

this study do not give us an adequate basis to address them. Further, we have not 

added further emphasis to the limitations of our numbers because upon review, we 

found those limitations adequately explained. We also note that even with the stated 

limitations, the trend data presented in the report help provide a clearer picture of 

recent developments concerning foster care children in the United States. 

13 
APPENDIX A 

ENDNOli??S 

1. We recognize that there are many other important questions that might be 

posed. Such questions might address other demographic characteristics as well 

as factors such as length of stay in foster care and circumstances of removal 

from home. We chose the four areas identified because they are particularly 

important and basic ones of much relevance to policymakers and because we 

expected that we could obtain reasonably complete information in these areas. 

2. There are four primary mechanisms for Federal financing of foster care 

services: 

0 Title IV-B: This provision has been part of the Social Security Act since 

1935 and provides funding for a broad range of preventive and 

protective services to abused, neglected, and exploited children. It is a 

formula grant program that reimburses States 75 percent of qualifying 

foster care expenses up to an allotted total. Amended in 1980, Section 

427 earmarks a portion of total appropriations for States that: 

. conduct an inventory of all children in foster care; 

. implement a statewide tracking system for children in care; 

. implement a review system with case review for each child 

every 6 months and judicial review within 6 months of 

initial placement; and 

. implement a service plan to place each child in a permanent 

home. 

The Department is required to conduct Section 427 reviews in each 

participating State to ensure that it meets these requirements. (Only 

three have opted out of 427 participation: Massachusetts, Wyoming, and 

Puerto Rico.) 

0 Title IV-E: (Described in text) 

0 Title XX: Since 1974 this provision has been the major source of funds 

for a range of social services including child daycare, protective services, 

community services for people with disabilities, homemaker and chore 

services, and services for the elderly. Title XX was amended in 1981 to 

create a block grant for social services. Many States’ Title XX funds are 

expended for some foster care services. 

A -1 
0 Indenendent Living Program: Enacted in 1986, the ILP funds State 

services that assist AFDC-eligible children aged 16 and over to make the 

transition from foster care to successful independent living at age 18. 

No State matching funds are required. In 1988 the law was amended to 

include non-income-eligible children and to permit extension of services 

to youths for up to 6 months after they are emancipated from care. 

Of these four major Federal funding sources, three have experienced either 

modest growth or level funding in recent years. From 1985 to 1989, 

Title IV-B funding levels have increased from $200 million to $239 million. 

Annual increases in the Title XX Social Services Block Grant since 1974 

peaked in 1981 at $2.9 billion. Although P.L. 96-272 authorized annual $100 

million increases through 1985 to facilitate the goals of the statute, the SSBG 

was subsequently capped at $2.7 billion. The ILP has been reauthorized each 

year since its enactment and has been level funded at $45 million each year. 

3. See Committee on Finance, United States Senate, “Foster Care, Adoption 

Assistance, and Child Welfare Services,” Washington, D.C., September 1990, p. 

9. 

4. For a review of past and current foster care data collection efforts, see Federal 

Register 55, no. 288 (September 27, 1990): 39541-42. 

5. See Committee on Finance, pp. 32-33. 

6. In appendix C, we list the 38 States included in figure 1 and the States included 

in the subsequent figures. 

7. The 1987 case, known as the Eugene F. Case, required the State child welfare 

agency to provide relatives who are not parents the reimbursement and services 

provided to other foster parents. Prior to that case, children in custody of the 

State and placed with relatives were typically eligible only for AFDC payments 

and were not classified as foster children. The families are now referred to as 

kinship or approved relative home (ARH) placements. Children in relative 

placements increased from an average of 520 in 1985 to 15,500 in 1989. (Data 

compiled by the New York State Department of Social Services and presented 

in working papers for a conference held by the Department and the New York 

Community Trust on February 27, 1990 and entitled ‘The Changing Face of 

Foster Care in New York State.“) 

8. See Committee on Finance, pp. 32-33. The Committee presents data on 

children in foster care per 1,000 in the population dating back to 1962, when it 

reports that 3.9 children per 1,000 were in foster care. 

9. See “The Changing Face of Foster Care.” 

A -2 
10. See ‘The Changing Face of Foster Care.” 

11. For the first nine months of 1989, the New York Department of Social Services 

reports that children under 1 year of age accounted for 8.0 percent of the 

group care caseload and those 5 years or younger accounted for 17.9 percent. 

The comparable numbers for 1988, as we reported, were 8.6 percent and 29.6 

percent. See ‘The Changing Face of Foster Care.” 

12. A study of the child welfare system in New York City, for instance, found that 

between 1985 and 1989, the number of children who were admitted to foster 

care because they lacked food, clothing, or shelter increased by 40 percent. See 

Report of the Manhattan Borough President’s Advisory Council on Child 

Welfare, Failed Promises: Child Welfare in New York Citv: A Look at the 

Past. Vision for the Future, July 1989, pp. 20, 25. 

For relevant recent studies by the Office of Inspector General, Office of 

Evaluation and Inspections, see Crack Babies, OEI-03-89-01540, June 1990; 

Boarder Babies, OEI-03-89-01541, June 1990; and Barriers to Freeing Children 

for Adontion, OEI-06-89-01640. 

Also relevant is a recent New England Journal of Medicine article. In it, the 

authors report on research that concludes that the use of illegal drugs is 

common among pregnant women regardless of race and socioeconomic status. 

They address a number of reasons why newborn children of poor and black 

women tend to be tested and reported to public health authorities more 

frequently. See I. J. Chasnoff, H.J. Landress, and M.E. Barrett, ‘The 

Prevalence of Illicit Drug or Alcohol Use During Pregnancy and Discrepancies 

in Mandatory Reporting in Pinellas County, Florida,” New EnPland Journal of 

Medicine 322, No. 17 (April 26, 1990): 1202-06. 

13. The increases in California and New York are substantial. In California, the 

average number of monthly child abuse reports rose from about 15,000 in 1983 

to about 39,000 in 1990. Similarly, in New York, the total number of reports 

filed in the State grew from 55,937 in 1980 to 122,498 in 1988. 

14. Kinship placements appear to be much more common for infants and 

preschoolers than for adolescents. In New York City, in 1986, about 10 percent 

of all infant admissions to foster care were placed with relatives. By 1988, that 

figure was about 33 percent. See ‘The Changing Face of Foster Care.” 

15. In the 1980’s, Federal funding for Title IV-B preventive and protective services 

has risen much more slowly than Title IV-E foster care services. Similarly, in 

the last half of the 1980’s Federal funding for mental health and juvenile justice 

systems has declined in constant dollars while that for the Titles IV-B and E 

funded child welfare system has increased, thereby encouraging the shifting of 

children from the former systems to the latter. See Select Committee on 

A -3 
Children, Youth, and Families, U.S. House of Representatives, “No Place to 

Call Home: Discarded Children in America,” Washington, D.C., 1990, 

pp. 65-77. 

16. The reality of the situation was recently reflected in a study which found that 

State child welfare representatives from 74 percent of the States regarded a 

lack of coordination between the three systems to be a major problem in 

delivering services to families and children in need. See S. Robison, Putting the 

Pieces Together: Survev of State Systems for Children in Crisis, National 

Conference of State Legislatures, Washington, D.C., July 1990, p. ix. 

Another study, focusing on the California child welfare system, underscored the 

depth of the problem. It concluded that “tenacious collaboration alone will not 

make up for societal underinvestment in children. . . . But without 

collaboration, more investment would not be much help. The system as a 

whole is so fundamentally flawed that huge amounts of dollars dumped in 

wouldn’t do much good.” See Sid Gardner, “Failure by Fragmentation,” 

California Tomorrow 4, no. 4 (Fall 1989): 20. 

17. In our survey, only three States--Idaho, Missouri, and Texas--reported that they 

have formally established standards of practice to guide foster care placement 

decisions. The Child Welfare League of America has had standards of this 

kind for years and is now engaged in an effort to reexamine them. 

A -4 
I . 

APPENDIX B 

STAItlXf7CAL METHODOLOGYAND NOZl!?S 

The data presented in our report emerge from our survey of State child welfare 

agencies. That survey encompassed each of the States and the District of Columbia 

(hereafter referred to as a State). 

Our survey consisted of two parts. The first involved a telephone interview with a 

senior State child welfare official in each State. In that interview we sought to obtain 

a clear understanding of the State’s policies, practices, and trends concerning foster 

care placements. (We conducted interviews with representatives of all 51 States.) 

The second part of the survey was conducted by mail. We sought data involving 

demographic characteristics, placement status, and admissions and discharges of 

children in foster care. We asked for such data for each quarter for every year from 

1985 through 1989. 

Our efforts to collect such data ran into the same constraints that have inhibited the 

development of a national foster care and adoption data collection system. From 

State to State, definitions of terms often varied, and the quarter-by-quarter data fields 

requested were often not available at all or only for certain periods. 

As a result, we had to make some decisions about which data fields were reliable and 

complete enough to use in developing and discussing our findings. We also had to 

determine how best to present the data in these fields. 

The data fields chosen concern the numbers of children in foster care, their ages 

broken down by the age categories used in the text, the numbers of children in group 

care and foster family care, and their ages. 

For every year, we asked for the data by quarter. If a State provided fourth quarter 

data for each of the 5 years surveyed, we used that quarter’s data for the year-to-year 

comparison. If it did not have fourth quarter data, we would use the third quarter; if 

it did not have the fourth or third, we would use the second; and, finally, if it did not 

have any of the last three quarters, we would use the first. In all cases,for each State, 

we would use the same quarter for the year-to-year comparison. 

In presenting the data, we chose to include, for each data field, only those States for 

which we had year-by-year data for each year from 1985 through 1989. Even though 

this meant that our universe of reporting States would always be less than the 51 

surveyed, and in a few instances substantially less, we determined that it was the most 

responsible, clear-cut, and consistent way to report the data. Thus, in our tables the 

B-l 
universe of reporting States ranges from a high of 38 to a low of 11. (In each case the 

States included are presented in appendix C.) 

This approach to presenting the data raises the question of whether the trends we 

identify for the States included in our tables would also apply for the States not 

included. Although we make no particular claim in this regard, it would appear that 

the trends identified for our reporting States would also apply if all 51 States were 

included in our data bases. 

Beginning with the universe of 51 States, 1 (Arizona) failed to provide any caseload 

information and 12 were unable to provide caseload information for all 5 years. 

Additionally, of the 38 remaining States, 5 were unable to provide a breakdown of 

caseload between group homes and foster family placements. Among the 5, the only 

Top Eleven State was Florida. 

We are confident that our findings are representative of the foster care caseload 

because the 12 States we excluded due to incomplete data (1) had smaller caseloads 

than any of the Top Eleven States, and (2) showed trends in their incomplete 

information that paralleled those of our findings. In fact, for 1987 through 1989, 

where we had complete information for 48 States, the percentage changes in caseload 

from year-to-year were equivalent to that of the 38 included States. Similarly, the 

excluded States in the group home versus foster family placement analysis exhibited 

parallel trends to those included in our findings. 

The wider applicability of the age-related findings is less certain since these are based 

on only 15 States that provided complete age breakdown for the 5 years. Five 

of the Top Eleven States are included in this analysis. Only 21 States provided any 

age breakdown of their foster care caseload. The six States that were excluded 

showed trends in their caseloads (higher proportions of preschoolers, smaller 

proportions of older children) that were similar to those in the 15 States providing 

complete data. 

B-2 
APPENDIX C 

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

I. FOSTER CARE PLACEMENTS 

1985 1986 1987 1988 1989 

38 STATES 228,155 233,427 244,584 266,045 304,431 

CALIFORNIA & NEW YORK 68,755 73,004 79,964 92,886 118,661 

TOP ELEVEN 

OTHER STATES (N=27) 152,176 

75,979 

155,859 

77,568 

166,458 

78,126 

185,009 

81,036 

218,083 

86,348 

A. GROUP HOME PLACEMENTS 

33 STATES 44,226 CALIFORNIA &I NEW YORK 16,264 

TOP ELEVEN (N=lO) 29,633 

OTHER STATES (N=23) 14,593 

44,579 

16,426 

29,483 

15,096 

44,561 

16,171 

29,383 

15,178 

48,527 

18,734 

32,998 

15,529 

51,189 

20,249 

34,701 

16,488 

B. FOSTER FAMILY PLACEMENTS 

33 STATES 163,584 CALIFORNIA & NEW YORK 52,491 

TOP ELEVEN (N=lO) 115,624 

OTHER STATES (N=23) 47,960 

168,556 

56,578 

119,467 

49,089 

179,601 

63,793 

129,779 

49,822 

196,088 

74,152 

144,131 

51,957 

228,998 

98,412 

173,546 

55,452 

II. FOSTER CARE PLACEMENTS PER 1,000 CHILDREN AGE 18 AND UNDER 

1985 1986 1987 1988 1989 

38 STATES 3.85 3.92 4.09 4.43 5.04 

CALIFORNIA 61 NEW YORK 5.74 6.02 6.49 7.41 9.32 

TOP ELEVEN 4.60 4.69 4.97 5.48 6.39 

OTHER STATES (N=27) 2.90 2.95. 2.97 3.08 3.29 

A. GROUP HOME PLACEMENTS PER 1,000 CHILDREN AGE 18 AND UNDER 

33 STATES 0.84 0.84 0.84 0.91 0.95 

CALIFORNIA & NEW YORK 1.36 1.35 1.31 1.50 1.59 

TOP ELEVEN (N=lO) 0.98 0.97 0.96 1.07 1.12 

OTHER STATES (N=23) 0.65 0.67 0.67 0.68 0.73 

B. FOSTER FAMILY PLACEMENTS PER 1,000 CHILDREN AGE 18 AND UNDER 

33 STATES 3.09 3.18 3.37 3.66 4.26 

CALIFORNIA &I NEW YORK 4.38 4.66 5.18 5.92 7.73 

TOP ELEVEN (N=lO) 3.81 3.92 4.24 4.68 5.59 

OTHER STATES (N=23) 2.13 2.17 2.20 2.29 2.45 

C-l 
III. FOSTER CARE PLACEMENT PER 1,000 CHILDREN AGE 18 AND UNDER, BY AGE 

1985 1986 1987 1988 1989 

15 STATES 

INFANTS < 1 2.57 2.90 3.41 4.32 6.05 

l-4 YEARS 3.85 4.23 4.84 5.73 7.40 

5-9 YEARS 3.65 3.91 4.34 4.92 6.02 

lo-14 YEARS 4.44 4.65 4.91 5.34 6.07 

15-18 YEARS 6.42 6.43 6.32 6.54 7.00 

CA AND NY 

INFANTS < 1 3.38 4.00 4.72 6.48 9.67 

l-4 YEARS 4.80 5.43 6.37 7.82 10.88 

5-9 YEARS 4.97 5.32 5.94 6.82 8.79 

lo-14 YEARS 5.77 6.07 6.55 7.40 8.85 

15-18 YEARS 8.13 7.90 7.70 8.02 8.58 

A. GROUP HOME PLACEMENT PER 1,000 CHILDREN AGES 18 AND UNDER, BY AGE 

1985 1986 1987 1988 1989 

11 STATES 

INFANTS < 1 0.09 0.11 0.08 0.14 0.22 

l-4 YEARS 0.09 0.11 0.09 0.14 0.20 

5-9 YEARS 0.25 0.27 0.27 0.30 0.36 

lo-14 YEARS 1.17 1.19 1.26 1.35 1.42 

15-18 YEARS 2.46 2.55 2.51 2.72 2.85 

B. FOSTER FAMILY PLACEMENT PER 1,000 CHILDREN AGES 18 AND UNDER, BY AGE 

1985 1986 1987 1988 1989 

11 STATES 

INFANTS < 1 2.47 2.94 3.62 4.13 5.21 

l-4. YEARS 3.86 4.30 5.06 5.80 6.83 

5-9 YEARS 3.55 3.90 4.39 4.88 5.54 

lo-14 YEARS 3.43 3.70 3.94 4.25 4.69 

15-18 YEARS 3.87 3.89 3.94 4.07 4.36 

c-2 
IV. STATES INCLUDED IN TABLES 

A. 38 STATES WITH 

ALABAMA 

ARKANSAS 

CALIFORNIA 

COLORADO 

CONNECTICUT 

FLORIDA 

GEORGIA 

HAWAII 

ILLINOIS 

INDIANA 

KANSAS 

KENTUCKY 

LOUISIANA 

B. THE TOP ELEVEN 

CALIFORNIA 

FLORIDA 

GEORGIA 

ILLINOIS 

MASSACHUSETTS 

MICHIGAN 

C. 33 STATES WITH 

COMPLETE DATA ON TOTAL PLACEMENTS 

MASSACHUSETTS 

MAINE 

MICHIGAN 

MINNESOTA 

MISSOURI 

MISSISSIPPI 

NORTH DAKOTA 

OKLAHOMA 

OREGON 

PENNSYLVANIA 

SOUTH DAKOTA 

TENNESSEE 

TEXAS 

UTAH 

VIRGINIA 

VERMONT 

WASHINGTON 

WISCONSIN 

WEST VIRGINIA 

NEBRASKA 

NEW JERSEY 

NEW MEXICO 

NEVADA 

NEW YORK 

OHIO 

NEW JERSEY 

NEW YORK 

OHIO 

PENNSYLVANIA 

WASHINGTON 

COMPLETE DATA FOR 

FAMILY PLACEMENTS 

ALABAMA 

ARKANSAS 

CALIFORNIA 

COLORADO 

CONNECTICUT 

GEORGIA 

HAWAII 

ILLINOIS 

INDIANA 

KANSAS 

LOUISIANA 

MASSACHUSETTS 

MAINE 

MICHIGAN 

MISSOURI 

MISSISSIPPI 

NORTH DAKOTA 

NEW JERSEY 

NEW MEXICO 

NEVADA 

NEW YORK 

OHIO 

OREGON 

PENNSYLVANIA 

GROUP HOME AND FOSTER 

SOUTH DAKOTA 

TENNESSEE 

TEXAS 

UTAH 

VIRGINIA 

VERMONT 

WASHINGTON 

WISCONSIN 

WEST VIRGINIA 

D. 15 STATES WITH COMPLETE AGE DATA ON PLACEMENTS PER 1,000

CHILDREN AGED 18 AND UNDER, BY AGE 

CALIFORNIA INDIANA OHIO 

COLORADO MISSOURI OKLAHOMA 

FLORIDA NEBRASKA OREGON 

HAWAII NEW MEXICO VERMONT 

ILLINOIS NEW YORK WISCONSIN 

c-3 
E. 11 STATES WITH COMPLETE AGE DATA FOR GROUP HOME AND FOSTER 

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

BY AGE 

CALIFORNIA 

COLORADO 

HAWAII 

ILLINOIS 

INDIANA 

MISSOURI 

NEW MEXICO 

OHIO 

OREGON 

VERMONT 

WISCONSIN 

c-4 
APPENDIX D 

DETAILED COMMENl3 ON THE DRAPTREPORTAND 

OIG RESPONSE TO THE COMMENTS 

In this appendix, we present in full the comments on the draft 

report offered by the Administration for Children and Families 

and the Assistant Secretary for Planning and Evaluation. In 

each case, we also include our brief response to the comments. 

D-l 
L 

l *- -t .* 

ADMINISTRATION FOR CitlLDREN AND FAMILIES 

Office of the Ak%tanP;Sedr~tfq, suite 600 

October 8, 1991 370 L’Enfant Promenp&, 

Washington, D.C. 204Hm 

TO: Richard P. Kusserow 

Inspector General 

FROM: Jo Anne B. Barnhart 

Assistant Secretary for Children and Fa ilies 

P -

SUBJECT: Comments on OIG Draft Report: "Trends in Foster Care," 

OEI-01-90-00490 

We have reviewed-the draft of the Office of Inspector General 

report entitled "Trends in Foster Care." We believe that the 

study provides reliable information on current trends in foster 

care. It agrees with other information available to us which 

indicates that the use of foster family care and group care has 

been increasing. Members of my staff have previously provided 

oral comments on the draft in a meeting with the OIG. At this 

time, we have an additional comment on one recommendation. 

GIG Recommendation 

The ACF should specify its plans for the preparation and regular distribution of policy-relevant tables and for special analyses concerning the [foster care and adoption] data collection system. It should indicate these plans in the preamble to the regulations . to be issued concerning the system. 

&CF Comment . 

The development of a national foster care and adoption data 

system is currently under way. We anticipate that it will 

provide the information which is needed for improved policy and 

program planning. Concerning the description and distribution 

plan for policy-relevant tables, we will take this recommendation 

under advisement and, to the extent possible, include a 

description of them in the preamble. 

Technical Comment 

On page 12, para 4, the word "adaption" should be changed to 

ltadoption.tl 

Thank you for the opportunity to comment on the draft report. If 

I may be of further assistance, please do not hesitate to contact 

me. 

D-2 
OIG RESPONSE TO ACF coMMEN?s 

In accord with the oral comments of ACF staff, the comments of ASPE, and actions 

recently take by ACF, we have eliminated the first recommendation presented in our 

draft report. That recommendation called for ACF to implement immediately the 

most essential aspects of the foster care and adoption data collection system. 

We made that recommendation because of our concerns about the complexity and 

scope of the system proposed by the Department of Health and Human Services in 

the September 1990 proposed notice of rulemaking. As we indicated on page 12 of 

the draft report, the proposed system involved “imposing constraints that could delay 

and undermine the establishment of the comprehensive system set forth.” We 

concluded at that point that the comprehensive system should remain as a goal, but 

that ACF could best get the process started by identifying the most essential data 

elements and requiring States at the outset to submit data only on them. 

We retracted the recommendation because we understand that ACF already has 

moved in the direction noted above, by removing duplicative and unnecessary data 

elements and providing for more flexibility on various matters. We still urge ACF 

sensitivity to the implementation difficulties many States will face, but because of the 

changes it has made, concur with ACF and ASPE, which in its response says “we must 

press ahead and finish the job we set out to do as quickly as possible.” 

D-3 
DEPARTMENTOF HEAITH 8. HUMAN SERVICES fifficegf the Secretary 

- - ~--

Warhintxon. D.C. 20201 

SEP I3 1991 

TO: Richard P. Kusserow 

Inspector General 

FROM: Assistant Secretary for 

Planning and Evaluation 

SUBJECT: Review and Comment on OIG Draft Report: "Trends in 

Foster Care," OEI-3$-90-00490--CONDITIONAL CONCURRENCE 

concur with the above report sent for my review provided that 

the comments contained in this memorandum are addressed. 

Following are three major concerns, as well as a number of other 

comments and some suggested editorial changes. 

Baior Concerns: 

First, I appreciate the Inspector General's efforts to provide 

new information in an area that is especially lacking in quality, reliable data. You summarize this point well in the following statement: 

‘IFor the more than 300,000 children in foster care, we have 

no reliable information on who they factors affecting their well-being. example, for the 150,000 to 160,000 

who have end-stage renal disease ,,we and highly credible details on their 

status, and even treatment outcomes.t8 

strongly concur with your recommendation 

to implement the Adoption and Foster Care 

(AFCARS) to help fill this void. However, 

important to implement the system in its 

been directly involved with ACF in the final 

are or on the key 

In contrast, for 

people in the country 

can draw upon timely demographics, health 

that ACF move quickly Data Collection System I also think it is 

entirety. My office has

design of the 

AFCARS. Based on the comments received in response to the Notice 

of Proposed Rulemaking (NPRM), many duplicative and unnecessary data elements have now been eliminated. It is important to 

realize that states have repeatedly informed the Department that 

if we require that they implement a data collection system, it 

should not be one that changes from year-to-year. Therefore, I do 

not agree with your recommendation that the essential AFCARS data 

elements be implemented immediately and that the system then be 

expanded in subsequent years. Admittedly, the AFCARS development has been too slow, but we are at an end stage now where we must 

press ahead and finish the job we set out to do as quickly as 

possible. 

D-4 

I 

I 
. 

Page 2. --Richard P. Kusserow 

Second, while I appreciate the draft report's focus on the need 

to develop our data capabilities in this area, I am concerned 

that this is the sole recommendation to come from your analysis. In particular, aside from providing more accurate information on 

the subject, I am perplexed how the AFCARS will really inform us 

of ways to address the trends specified in the report: 

0 a general increase in the foster care caseload; 

0 a rapidly growing proportion of infants and pre-schodlers in 

the foster care caseload; 

0 an increase in the number and proportion of these infants 

and pre-schoolers who are placed in group homes. 

Although we may not know their exact magnitude, I think that it 

is obvious that these trends are taking place. I also think that 

we cannot wait for more exact data to begin addressing these 

trends. One strategy we can pursue immediately is to test 

alternative program models on a demonstration basis and evaluate 

their effectiveness. My office is involved with several exciting projects designed to develop the research capabilities of the 

child welfare services area in preparation for the evaluation of 

demonstration programs. 

Another area in which we could act now would be to embark on an 

effort to provide states additional guidance on placement practices. Specifically, I am referring to the Veasonable 

efforts" provision of P.L. 96-272 which specifies that before 

children are placed in foster care, 18reasonable efforts" must be 

made to avoid removing the child from the family. This provision also mandates that once children are in foster care, reasonable 

efforts must be made to reunify the child with his or her family thereby avoiding the termination of parental rights. While 

safeguards of this type are necessary, there is much evidence 

that many agencies are over-interpreting these requirements due 

to a number of reasons including: fear of adverse legal action, limited availability of caseworker time and agency resources, 

bureaucratic inertia, poorly coordinated social service systems, and/or poorly administered practices. Many of these problems 

were elaborated in the recent OIG report "Barriers to Freeing Children for Adoption.ll 

The results of misinterpreting reasonable efforts can be 

devastating to a child. For instance, an abandoned infant can 

sit for months or even years in a hospital or group home before 

being placed in a foster family or adoptive home, or a small 

foster child can age into adolescence before becoming eligible for adoption. 

The Department needs to define reasonable efforts in its 

regulations \ to provide more meaningful guidance to states. This

D-5 
. 

Page 3. --Richard P. Kusserow 

issue has become more complicated because of the large rise in 

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

the trends found in your analysis could be addressed by providing 

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

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

you consider recommending a process by which the Department could 

begin to .define meaningful guidelines for reasonable efforts. 

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

of caveats be included stating that the numbers presented are 

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

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

this area. 

Qther Comments: 

On pages ii and seven, the draft report notes that the proportion of very young children in the foster care caseload increased 

while the proportion of adolescents decreased. This statement 

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

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

care entrants in both groups has increased, although infant and 

pre-school entrants have increased much more than adolescent 

entrants. The report should make the distinction between 

increases in proportions and absolute numbers,.more clear. 

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

sought to do two things. I agree with the second goal (encouraging case management and permanency planning) but I'm 

uncomfortable with the first. It is unclear to me what 

"extensive1t services were made available to children at risk in 

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

specify that each state implement a foster care prevention 

program in order to receive certain federal incentive funds, but 

it did not specify the parameters of these programs or the 

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

96-272 did change the state reimbursement mechanism for foster 

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

make entitlement money available to states for child welfare 

services. 

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

accounts of group homes which characterize them as "large orphanage-type facilities where... children are said to be 

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

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

orphanages. In fact, many are characterized as better than many available foster family homes. While there is a widespread fear 

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

press accounts that report such abuse is currently taking place. 

D-6 
I . 

page 4. --Richard P. Kusserow 

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

in the mid-1980's the foster care population was considerably in the late 1970's. In fact, the data you are 

sample survey conducted in 1977) is highly comparable with later caseload In 

less than it was 

referring to (a 

suspect and not 

case, the Senate 

footnote .for this 

counts. any 

Committee publication you list as a 

does not report foster care caseload 

During this time period the title IV-E 

In sum, there is no evidence that a 

Finance 

assertion 

1979. 

slightly.

entire 

data.from 1972 to 

caseload dropped large drop in the caseload took place. 

one of your findings may be a 

notes that from 1985 to 1989 the 

group homes declined slightly). foster care adolescents, who are 

has been falling in relation to 

I realize that you make 

that support your initial 

of these may be drawn from 

there is a lot on 

On page nine, I am concerned that 

statistical artifact (the report proportion of foster children in 

In particular, the proportion of 

over-represented in group homes, 

other foster care sub-populations. several subsequent observations 

finding, but I believe that each 

different samples of states. In 

here and, in the absence of better 

summary, going 

data, we have every reason to 

believe that the group home population is increasing, not 

decreasing. 

Suaaested Editorial Chanaes: 

In addition, I suggest making the following editorial additions 

that appear in bold type: 

a (page L final bullet, and page five second bullet): "...a 

rise in caseload admissions in relation to discharges has 

propelled the growth." 

0 (page ii, second 

young children in 

especially sharp 

0 (page two, second 

authorized adoption 

bullet): 'I... the small proportion of very 

the foster care caseload increased at an 

rate." 

paragraph, last sentence): "...it 

assistance payments for 'special needs' 

children, who from families for

AFDC who 

adolescents, 

group.1t 

i 

originate eligible 

are physically or emotionally disabled, 

or members of a sibling or ethnic minority 

children 

D-7 
. 

. 

Page 5. --Richard P. Kusserow 

0 (page 7, first paragraph of text): "...two actually had 

small decreases. In Massachusetts, the placement rate per 1,000 children declined from 6.83 in 1985 to 6.59 in 1989; 

in New Jersey'; from 4.51 to 4.29." 

For more information please contact Jane Baird at (202) 245-2409. 

Martin H. G&y 

D-8 
OIG RESPONSE TO ASPE COMMENTS 

As we explain in our response to ACF’s comments, we concur with ASPE and have 

dropped the recommendation calling for immediate implementation of the most 

essential aspects of the foster care and adoption data collection system. We have also 

made numerous other minor changes in response to ASPE’s other comments and 

suggested editorial changes. 

In regard to ASPE’s second major point concerning the absence of recommendations 

in the report on the larger policy issues concerning foster care, our response is that 

the underlying data generated by the study do not provide an adequate basis to make 

those recommendations. We do not wish to imply, however, that policy decisions must 

be delayed pending the implementation of the foster care and adoption data collection 

system or that such a system in itself will provide the basis for determining the most 

appropriate policies. We do expect, however, that such a system will be developed in 

a manner that will be of as much policy relevance as possible. 

Concerning ASPE’s second major point on presenting caveats that our numbers are 

estimates, we have reviewed our explanation and use of the numbers and conclude 

that they are presented in a clear manner that is not likely “to provide readers with a 

false sense of security that there is not a lack of reliable data in this area.” Indeed, we 

make that very point quite strongly. 

Finally, ASPE suggeststhat our data indicating that the proportion of very young 

children in the foster care caseload increased while the proportion of adolescents 

decreased could be misleading to the casual reader. It suggested that we make the 

differences between increases in proportions and absolute numbers clear. It cited 

New York, Illinois, and California data showing that the absolute number of foster 

care children in both groups increased, even though the infant and preschooler group 

increased at a greater rate. 

Yet, our data indicate that for 15 reporting States for the 1985 to 1989 period, the 

absolute number of 15 to-18 year-olds in the foster care caseload rose only slightly, 

from 40,982 to 42,489, while the number of infants and preschoolers rose significantly-­

from 28,835 to 60,616. 

D-9