Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JUNE GIBBS BROWN 

Inspector General 

MARCH 1999 

OEI-02-95-00044 

Interstate Compact on the Placement of 

Children: Implementation 
OFFICE OF INSPECTOR GENERAL 

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

protect the integrity of the Department of Health and Human Services programs as well as the 

health and welfare of beneficiaries served by them. This statutory mission is carried out through a 

nationwide program of audits, investigations, inspections, sanctions, and fraud alerts. The 

Inspector General informs the Secretary of program and management problems and recommends 

legislative, regulatory, and operational approaches to correct them. 

Office of Evaluation and Inspections 

The Office of Evaluation and Inspections (OEI) is one of several components of the Office of 

Inspector General. It conducts short-term management and program evaluations (called 

inspections) that focus on issues of concern to the Department, the Congress, and the public. The 

inspection reports provide findings and recommendations on the efficiency, vulnerability, and 

effectiveness of departmental programs. 

OEI's New York Office prepared this report under the direction of John I. Molnar, Regional 

Inspector General and Renee C. Dunn, Deputy Regional Inspector General. Principal OEI staff 

included: 

REGION HEADQUARTERS 

Nancy Harrison, Project Leader Alan Levine, Program Specialist

Miriam Gareau

Judy Lin

To obtain copies of this report, please call the New York Regional Office at (212) 264-2000. 

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

http://www.dhhs.gov/progorg/oei 
EXECUTIVE SUMMARY

PURPOSE 

The purpose of this inspection is to identify the strengths and weaknesses in the implementation of 

the Interstate Compact on the Placement of Children. 

BACKGROUND 

The Administration for Children and Families (ACF) has asked the Office of Inspector General 

(OIG) to look at interstate compacts that affect children placed or moved across State lines. The 

OIG has completed two other inspections in this area. Interstate Compact on Adoption and 

Medical Assistance assesses how membership in this compact affects States’ efforts to protect the 

interests of adopted special needs children who move interstate. The Interstate Compact on the 

Placement of Children: State Structure and Process describes how States have implemented the 

Interstate Compact on the Placement of Children (the Compact); in particular, how States 

structure their Compact function, States’ Compact procedures, and the number of children placed 

through the Compact. Currently, ACF is interested in the Compact’s strengths and weaknesses. 

This inspection addresses these issues. 

Sometimes the most suitable placement for a child is out of their own State. The reasons for such 

placements include adoptions by a family in another State, placement into foster care out of State, 

and reunification with a parent who has moved while the child was in State custody. 

The Interstate Compact on the Placement of Children is a contract among the States intended 

to ensure that children placed across States lines receive adequate protection and services. The 

Compact outlines the steps necessary to place a child out of State. For example, the State the 

child is in (the sending State) asks the State in which the child is to be placed (the receiving 

State) to conduct a home study to evaluate the suitability of the potential placement. If a 

placement is actually made, the receiving State supervises the placement and the sending State 

maintains financial responsibility for the child. All States, the District of Columbia, and the U.S. 

Virgin Islands are members of the Compact. 

We gathered information from three separate sources: compact administrators in the 10 States 

with the highest population under age 18, local workers in those States, and other involved 

parties. We used consensus within and among the groups as a cross check to confirm our 

findings. We also reviewed State policies and procedures with respect to residential placements. 

FINDINGS 

The Compact Facilitates Interstate Placements 

The Compact facilitates interstate placements in four main ways. First, the Compact increases 

placement options available for children. Second, the child’s safety is guarded through services 

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and protections offered by the receiving States. Third, the Compact ensures that the appropriate 

laws are followed before a placement is made. Fourth, the Compact has created a network 

through which States cooperate in making placements and exchanging information. 

States Are Fulfilling Their Obligations Under the Compact 

States seem to be meeting the basic requirements of the Compact. States are conducting home 

studies, providing for children financially, and supervising the placements. 

However, Some Weaknesses Are Acknowledged 

Although all ten State compact administrators believe that children are better off because of the 

Compact, they also acknowledge there are weaknesses in the Compact’s implementation. State 

administrators, local workers, and other involved parties report four main weaknesses: lack of 

knowledge about the Compact among judges, attorneys, and caseworkers; placements in violation 

of the Compact; the lengthy process; and differing adoption laws among States that may hinder 

placements. 

The Compact Plays a Smaller Role in Residential Placements 

Receiving States do not conduct home studies to assess placement suitability for residential 

placements, nor do they supervise residential placements. Documents for these placements 

sometimes bypass Compact offices. Further, most States do not have written policies for 

residential placements. And lastly, States also define residential care facilities differently. 

OPPORTUNITIES FOR IMPROVEMENT 

Based on this inspection and our previous study, we conclude that, overall, children are better off 

because of the Compact. However, we believe that there is a need to strengthen its 

implementation. We offer the following recommendations for those individuals and entities that 

have a role in the Compact. 

Awareness 

We learned that many individuals who work in the child welfare system are still unaware of the 

Compact. Clearly, more dissemination of Compact information is needed. We suggest that the 

States improve and increase the information about the Compact available to local workers, 

judges, attorneys, placement agencies and parents. This can be accomplished through increased 

opportunities for training for professionals, circulation of pamphlets among agencies and local 

workers, and the creation of a web site that would explain the purpose of the Compact and the 

process in simple language. Increased awareness and familiarity with the Compact may help 

reduce the number of violations that occur. 

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Timeliness 

We heard that one of the chief complaints of our respondents is the length of the Compact 

process. Border State agreements may be a viable method to reduce the lengthiness of the 

Compact process. The Association of Administrators and the States are currently discussing the 

implementation of border state agreements. Such agreements, usually between two bordering 

States, could allow local workers from one State to enter the other State to complete home 

studies or supervision. We encourage the Association and the States to continue these 

discussions. 

State Level Coordination 

We are aware that local workers do not always communicate formally through the State Compact 

offices. States' inability to account for all interstate placements noted in our earlier study, The 

Interstate Compact on the Placement of Children: State Structure and Process (OEI-95-02-

00041), may in part be due to this failure. It is important that the State Compact offices continue 

to be the official contact point between States. We are encouraged that local workers often 

communicate directly for matters other than emergencies or problems. This contact is clearly in 

the best interest of the children. 

Training and Technical Assistance 

We believe there is opportunity for ACF to participate in strengthening the implementation of the 

Compact. The ACF can make training and technical assistance available to States. Further, ACF 

can support the efforts of the States and the Association to increase information dissemination 

about the Compact’s purpose, importance and process. 

Residential Placements 

We recognize that residential placements are treated differently under the Compact and may be a 

potential vulnerability. We are continuing to look at the broader area of residential placements. 

We also encourage the States and the Association to examine how the Compact handles 

placements into residential care facilities. 

COMMENTS 

We received comments from the Administration for Children and Families (ACF) and from the 

American Public Human Services Association (APHSA). They both agree that there is 

opportunity for ACF to work with the Compact to provide necessary training. The full text of 

these comments can be found in Appendix A. 

The ACF plans to work with national resource centers, the Association of Administrators of the 

Interstate Compact on the Placement of Children, and the States to determine how it can promote 

awareness of the Compact, provide training to State agency staff who implement the Compact, 

and support the development of model procedures to help the Compact operate more effectively. 

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The APHSA comments include the comments of the Executive Committee of the Association of 

Administrators. They strongly endorse the idea of ACF providing assistance to the States to 

strengthen the implementation of the Compact as well as training. In addition, they offered 

technical comments and we modified the report where appropriate. 

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TABLE OF CONTENTS

PAGE 

EXECUTIVE SUMMARY 

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

FINDINGS ................................................................ 6

Compact Facilitates Interstate Placement .......................................... 6

States are Fulfilling Their Obligations ............................................ 6

Weaknesses Are Acknowledged ................................................ 7

Smaller Role in Residential Placements ........................................... 9

OPPORTUNITIES FOR IMPROVEMENT ...................................... 11

APPENDIX 

A: Comments ........................................................... A-1
INTRODUCTION

PURPOSE 

The purpose of this inspection is to identify the strengths and weaknesses in the implementation of 

the Interstate Compact on the Placement of Children. 

BACKGROUND 

The Administration for Children and Families (ACF) has asked the Office of Inspector General 

(OIG) to look at a number of issues regarding interstate compacts that affect children who are 

placed or moved across State lines. The OIG has completed two other inspections in this area. 

Interstate Compact on Adoption and Medical Assistance (OEI-02-95-00040) assesses how 

membership in the Interstate Compact for Adoption and Medical Assistance affects States’ efforts 

to protect the interests of adopted special needs children who move from one State to another. 

The Interstate Compact on the Placement of Children: State Structure and Process (OEI-02-95-

00041) describes how States have implemented the Interstate Compact on the Placement of 

Children (the Compact); in particular, how States have structured their Compact function, the 

States’ Compact procedures, and the number of children who are placed through the Compact. 

Currently, the ACF is interested in an evaluation of the Compact’s strengths and weaknesses. This 

inspection addresses these issues. 

Interstate Placement of Children 

Sometimes the most suitable placement for a child is out of their own State. These out of State 

placements occur for a variety of reasons, including adoption across State lines, foster care 

placement out of State, and reunification with a parent who has moved while the child is in State 

custody. No accurate national data exists on the number or type of interstate placements that 

occur each year. However, according to experts in the field, the number of children placed across 

State lines is increasing. 

The Interstate Compact on the Placement of Children 

The Interstate Compact on the Placement of Children is a contract among and between States 

intended to ensure that children placed across State lines for adoption or for foster care receive 

adequate protection and support services. It establishes procedures for placement and compels 

the placing agency to maintain responsibility for the child. To participate in the Compact, a State 

must enact into law the text of the Compact. 

The Compact grew out of work done in the late 1950's when a group of social service 

administrators and State legislators informally looked at the problems of placing children out of 

State for adoption or foster care. Although importation and exportation statutes regulate the 

interstate movement of goods, Federal law did not provide protection for children moved between 

States. The group found that a sending State, in the absence of a compact, could not compel the 

receiving State to provide protection or support services for a child. In addition, a receiving 

State, in the absence of a compact, could not compel a sending State to remain financially 

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responsible for a child. In response to this group’s findings, the Compact was first drafted in the 

New York State Legislature and was adopted by New York in 1960. By 1990, all States, the 

District of Columbia, and the U.S. Virgin Islands had joined. 

The purpose of the Compact is for the party States to cooperate in the interstate placement of 

children so that: 

C the child is placed in a suitable environment; 

C the receiving State has the opportunity to assess the proposed placement; 

C the sending State obtains enough information to evaluate the placement; and 

C the care of the child is promoted through appropriate jurisdictional arrangements. 

The Compact outlines the many steps necessary to place a child out of State. For example, the 

State the child is in (the sending State) asks the State in which the child is to be placed (the 

receiving State) to conduct a home study to evaluate a possible placement. When a placement is 

finally made, the receiving State must continue to supervise the placement while the sending State 

provides financial support. 

The Compact has jurisdiction over the following types of interstate placements: placement 

preliminary to an adoption; placement into foster care; placement with parents and relatives when 

a parent or relative is not making the placement; and placements made into group homes, child 

care institutions, and residential treatment facilities. The Compact does not have jurisdiction over 

the following placements: placements into schools, medical and mental facilities, and placements 

made by a child’s parent, stepparent, grandparent, adult sister or brother, adult aunt or uncle, or 

non-agency guardian with any such relative or non-agency guardian. 

For the purposes of this report, placements for adoption include those made by public agencies, 

private agencies, attorneys, and birth parents. Foster care placements include placements into 

paid foster homes, into homes of unpaid relatives, and into homes of formerly non-custodial 

parents. Residential placements include placements into residential treatment centers, group 

homes, and child care institutions. 

The Compact is managed in each State by a compact administrator. In 1974, the compact 

administrators formed the Association of Administrators of the Interstate Compact on the 

Placement of Children (the Association) to provide technical and support services to its members. 

The American Public Human Services Association (APHSA), formerly the American Public 

Welfare Association, acts as the Secretariat to the Association of Administrators. The APHSA is 

a non-profit organization that represents a variety of State interests in the field of health and 

human services. The Secretariat is funded through dues paid by member States. The ACF has 

not funded the Association since 1985. 

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Federal Role in Interstate Placements 

As the Federal agency with formal responsibility for supporting State child welfare activities, the 

Administration for Children and Families (ACF) administers the Federal programs that fund State 

foster care and adoption initiatives. 

The Federal funding of State foster care and adoption is authorized under the Social Security Act. 

Title IV-E of the Act reimburses a portion of State expenditure for foster care maintenance 

payments for eligible children and adoption assistance for eligible special needs children. Federal 

reimbursement is also available for certain administrative and training costs associated with both 

programs. Title IV-B, as amended by the Adoption and Safe Families Act of 1997, provides 

funding for ‘adoption promotion and support services’ and ‘time-limited reunification services,’ 

along with family preservation and support. In order to receive a grant under Title IV-B, States 

are required to provide specific protections. These protections include developing a case plan for 

each child in foster care and conducting a court or administrative review of the status of each 

child at least every 6 months. In addition, a hearing must be held within 12 months of the child’s 

entry into foster care by a court or court-approved administrative body to determine the 

permanency plan of each child. 

States’ Implementation of the Compact 

Fifty of the States have centralized their Compact function. This means they have a Compact 

office at the State level that handles all Compact cases coming into and going out of the State. 

The only two decentralized States handle all Compact cases at the county level. 

The Compact outlines the many steps necessary to place a child out of State. For example, a 

caseworker finds a potential placement for a child with the child’s grandmother out of State. The 

worker completes a placement request and sends it to her Compact office (the sending State). 

They ask the State in which the grandmother lives (the receiving State) to conduct a home study 

to evaluate the possible placement. The receiving State sends the request to a worker in the 

grandmother’s local jurisdiction. The worker completes the home study and makes a 

recommendation as to whether the placement should be approved. He sends this information to 

his Compact office (the receiving State). The Compact office, based on information from the 

home study, decides to approve the placement or not. The office sends the packet to the sending 

State’s Compact office. They forward the packet to the child’s caseworker. She reviews the 

information and, if the placement has been approved by the receiving State, she makes the final 

decision to place the child or not. Assuming she decides to make the placement, she arranges for 

the child’s transportation and at the same time, notifies her Compact office of the placement. The 

office contacts the receiving State’s Compact office, who forwards the decision to the worker in 

the grandmother’s jurisdiction. He then begins to supervise the placement with visits to the 

grandmother’s home. 

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METHODOLOGY 

This inspection is based on information gathered from three separate sources: compact 

administrators in the 10 States with the highest population under age 18, local workers in those 

States, and other involved parties. We selected these three groups for their different perspectives 

on the Compact. In our analysis we paid special attention to consensus within and among the 

groups. We used consensus as a cross check to confirm our findings. For example, we analyzed 

State administrators’ viewpoints as both sending and receiving States and we compared their 

comments with those we received from local workers and national experts. We also reviewed 

State policies and procedures with respect to residential placements. We did not review or 

compare individual case files of children placed across State lines. 

Compact Administrators 

We conducted interviews with the compact administrator or a designated representative from 

each of the ten States with the highest population under 18 years of age (CA, FL, GA, IL, MI, 

NJ, NY, OH, PA, TX). Combined, these States represent more than 50 percent of the national 

population under 18 in 1997. We interviewed each State as both a sending State and a receiving 

State. Questions focused on their experiences and opinions of the Compact and of other States. 

We asked about the home studies, supervision, and financial support provided to children placed 

across State lines. We also discussed the Compact’s strengths and weaknesses and their 

experiences with residential placements. 

We analyzed the State responses in many ways, taking into account when the administrators were 

speaking as sending States and when they were speaking as receiving States. We considered not 

only what they said happens in their own State, but what they have seen in other States. A 

consensus among these different points of view supported our findings. We compared the 

information provided by the administrators to information provided by local workers and other 

involved parties. 

Local Workers 

We conducted interviews with 19 local workers who have participated in the Compact process 

from the ten selected States. We asked them about their experiences placing and receiving 

children interstate, as well as their opinions on the Compact’s effectiveness. At least one local 

worker from each State was interviewed. Additional workers were interviewed if a State had 

separate units for sending and receiving or for home studies and supervision. Up to three workers 

were interviewed in some States. We looked at the local workers’ responses as a whole and we 

compared their responses to the responses of their respective State administrators. We also 

compared the information they provided to information from the group of State administrators 

and other involved parties. 

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Other Involved Parties 

We also conducted interviews with individuals who have had direct experience dealing with the 

Compact. These discussions included two family court judges, three attorneys, two adoption 

agency directors, and three children’s advocates and focused on the strengths and weaknesses of 

the Compact. We compared their responses within and among the different professions. We also 

compared their responses to responses of the State administrators and local workers. 

Policies and Procedures 

We reviewed the written policies and procedures submitted by 43 of the 52 Compact States for 

information concerning residential placements. 

This inspection was conducted in accordance with the Quality Standards for Inspections issued 

by the President’s Council on Integrity and Efficiency. 

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FINDINGS

The Compact Facilitates Interstate Placements 

The Compact facilitates adoption and foster care placements in four main ways, according to 

compact administrators, local workers, and other involved parties. First, the Compact increases 

placement options available for children. This is especially important for children with special 

needs who may only be able to find necessary services outside of their State. One local worker 

notes that the Compact in effect makes the resources of the other 49 States available in the search 

for a home for these vulnerable children. Also, the best place for some children may be with a 

close relative who happens to live in another State. The Compact makes these placements 

possible. Second, the child’s safety is guarded through services and protections offered by the 

receiving States, such as home studies and post-placement supervision. Third, the Compact 

ensures that the appropriate laws are followed before a placement is made. Therefore, disruptions 

of placements based on legal reasons may be avoided. Fourth, the Compact has created a 

network through which States communicate and cooperate in making placements and exchanging 

information about placement resources and States’ laws. Moreover, all ten State compact 

administrators believe that children are better off because of the Compact. Almost all of the local 

workers agree and are satisfied with the Compact. 

States Are Fulfilling Their Obligations Under the Compact 

States seem to be meeting the basic requirements of the Compact meant to safeguard children 

placed interstate. These requirements include conducting home studies to evaluate possible 

placements, providing for the child financially, and supervising the placement. 

States Are Conducting Home Studies 

States are conducting home studies before Compact placements are made. In addition, most 

States conduct a criminal and/or child abuse check on prospective families. Nine of the ten State 

compact administrators, as well as many local workers, are satisfied with the quality of the home 

studies. One administrator is concerned, however, that home studies have no national standards 

so workers receive different information of varying quality with each State. 

Local workers report it takes an average of one month to complete a home study. State compact 

administrators report waiting an average of three to four months for the entire home study 

process to be completed, which is similar to the average three month wait States report for 

placements made within their own State. 

Eight of the ten State compact administrators are satisfied with Regulation 7 of the Compact, 

which outlines the procedures to be used in urgent cases. In these cases, the receiving State must 

respond to the sending State’s request for placement within 20 business days, as opposed to the 

recommended 30 business days in other cases. One administrator who is not satisfied reports that 

Regulation 7 is vague about which cases are eligible for its use. The other administrator says that 

foster care and adoption home studies cannot be completed in 20 days because of required 

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6 
background checks. Some local workers agree, saying they find it difficult to meet the tight time 

frame. 

States Are Fulfilling Their Financial Obligations 

States are fulfilling their Compact financial obligations to remain financially responsible for 

children they send out of State. In fact, compact administrators report that sending States rarely 

fail to meet their obligations. When a failure occurs, it is usually due to a misunderstanding, in 

part, of what services will be paid for by the sending State. Receiving States say they contact the 

compact administrator in the sending State to resolve these problems. 

Placements Are Being Supervised 

According to administrators, placements are being supervised. Local workers in receiving States 

are supervising placements and writing progress reports for typical interstate placements. Overall, 

most State compact administrators and local workers are satisfied with the quality of progress 

reports. The reports are generally forwarded to the sending State quarterly, but a few 

administrators and local workers say they have to request reports, otherwise they are not sent. 

The Compact requires that reports go from the local worker in the receiving State to the local 

worker in the sending State through the two State offices. A number of compact administrators 

and local workers say that this process is not always followed. Instead, reports are sometimes 

sent directly from one worker to another without involving the two State offices. 

In addition to the reports, all local workers say they usually communicate directly with the other 

State’s worker on routine matters. This communication between the two local workers 

establishes a relationship which may enhance the well-being of the child. Ultimately, the State 

Compact offices are responsible for the placement. 

However, Some Weaknesses Are Acknowledged 

Although all ten State compact administrators believe that children are better off because of the 

Compact, they also acknowledge there are weaknesses in the Compact’s implementation. In fact, 

six administrators are not completely satisfied with the way the Compact is working and believe 

that it needs improvement. State, local, and other involved parties report four main weaknesses: 

lack of knowledge about the Compact, violations of the Compact, timeliness of placement 

documents, and differing adoption laws. 

Some Are Unaware of the Compact 

Some respondents feel there is a lack of knowledge about the Compact among judges, attorneys, 

and caseworkers. Both judges we contacted stress the need for more education about the 

Compact among their peers, specifically with regard to Regulation 7 of the Compact. One judge 

reports that attorneys also need more training about the Compact. An attorney concurs and 

believes some of his peers are not aware of the Compact. In addition, a few State compact 

administrators and involved parties believe that local workers may be reluctant to use the 

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7 
Compact because they do not understand it or do not know about it. Only half of the local 

workers say that they have received any training on Compact procedures. 

Violations Occur and May Lead to Placement Problems 

All ten State compact administrators believe placements occur in violation of the Compact, 

although they are unsure of the numbers involved. One reason States are unable to provide 

numbers is because violations usually go unnoticed unless a problem occurs and a public agency is 

notified. 

State compact administrators and other involved parties report that Compact violations can occur 

in several instances. According to the State compact administrators, the most frequent example 

of this is where a judge disregards the Compact when making a placement. Other reported 

instances include: local workers’ ignorance of the Compact, interstate visitations that eventually 

become permanent placements, and placements by individuals who are unaware of the Compact 

or choose to ignore it. One administrator feels there is an unwillingness on the part of agencies 

and courts to abide by the laws and wait for the process to be completed. All the administrators 

believe these violations are a problem because children placed outside of the Compact are not 

assured the same services and legal protection as those who are placed through the Compact. 

The majority of local workers know of situations where violations have occurred. They often cite 

agencies that place a child into their jurisdiction without notification or a home study request. 

They only become aware of a violation when they are asked to conduct a post-placement home 

study. Unlike the States, just a few local workers feel these violations are a problem because 

children are more vulnerable without the protection of the Compact. Those who feel violations 

are not a problem say violations are not major or widespread. 

Four State compact administrators and some other involved parties believe a major problem with 

the Compact is that it is not enforceable. Under Article IV of the Compact, any violation “shall 

constitute full and sufficient grounds for the suspension or revocation of any license, permit, or 

other legal authorization held by the sending agency which empowers or allows it to place, or 

care, for children.” Although these sanctions are available, respondents say they are not used. 

Many Believe the Process is Too Lengthy 

Almost half of all respondents feel that the Compact process is lengthy. Local workers say they 

wait too many weeks for home studies and supervision reports from the receiving States. They 

also complain that procedures in their own Compact offices contribute to delays. One local 

worker recalls a time when her Compact office sent back her documents because she had not 

made triplicate copies. She says that the case was held up for a week. A few State compact 

administrators note there is a reluctance among workers to use the Compact, in part because of 

the time delays. One judge believes that the delays were worse before the enactment of 

Regulation 7 of the Compact, but now the time frames are improving. 

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Differing State Adoption Laws May Hinder Placements 

A few administrators report that placing a child for adoption in another State can be difficult when 

the two States’ adoption laws differ. The two adoption attorneys are concerned that conflicting 

State adoption laws not only make placement difficult, but also make the placement vulnerable to 

disruption at a later date. They feel that the adoption may be vulnerable because it is impossible 

to comply with both the sending and receiving States’ laws when the laws conflict. One attorney 

believes the Compact has great potential and could be the central entity to resolve conflicts of 

laws between States. 

The Compact Plays a Smaller Role in Residential Placements 

Residential Placements Vary Widely Among States 

Some States have no or few residential facilities and must use residential facilities in other States. 

As a result, States with facilities may receive very large numbers of residential placements from 

other States. As reported in our previous inspection, one of the ten States reports receiving in 

excess of 700 children each in 1997 into residential placements. This is several hundred more 

than other States. 

States Do Not Conduct Home Studies for Residential Placements 

Although the Compact covers foster care, adoption, and residential placements, it plays a smaller 

role in residential than in the other interstate placements. States do not conduct home studies to 

assess placement suitability for children placed through the Compact into a residential facility. It 

appears that States place children only in licensed facilities, and State compact administrators 

report they recognize the licensing so home studies are not conducted. One State, however, 

reports it sends its own licensing staff into potential receiving States to verify the licensing and 

standards of residential facilities. 

Receiving States Do Not Supervise Residential Placements 

Receiving States do not supervise interstate residential placements. As noted earlier, in a typical 

interstate foster care placement, supervision reports are generally completed quarterly by a local 

worker in the receiving State. This is not the case for placements into residential facilities. Over 

half of the State compact administrators say that they receive supervision reports on children 

placed in residential facilities. However, these reports are not completed by the receiving State. 

The staff from the residential facilities completes the reports. A few States express concern with 

supervision reports that are completed by facility staff. As one State stresses, it may be hard for 

employees to be objective. 

It is reported that children placed in-State have more supervision than those placed out of State. 

For instance, when a facility is in a child’s home State, his own local worker would check on the 

child. This would involve visiting and calling the facility to ask how the child is doing. In 

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contrast, no local workers, either from the sending or receiving State, visit out of State children in 

facilities. 

Documents for these Placements Sometimes Bypass Compact Offices 

Usually documents for interstate placements flow from the local worker in one State to the local 

worker in the other State through the two State offices. Documents for residential placements, 

however, sometimes does not follow the same path. Four of the ten State compact administrators 

report they do not receive residential supervision reports regularly from their own State facilities. 

Instead, the reports are sent directly to the local sending agencies. 

Most States Do Not have Written Policies for Residential Placements 

Although in practice residential placements are treated differently, State Compact policies make 

no distinction between residential and other placements. In a review of policies from 43 of the 52 

Compact States we found the majority of State policies do not have a section dedicated to 

residential placements describing how these types of placements should be handled. In fact, many 

State policies fail to note any difference in procedures for residential placements. Six of the 52 

States, however, have detailed instructions for residential placements into and out of their State. 

These detailed policies include instructions for approving residential placements, verifying the 

facility acceptance of a child, and establishing that no appropriate in-State placement is available. 

Some State policies indicate that it is the responsibility of the sending agent to monitor the 

placement via quarterly supervision reports prepared by the facility staff. 

States Define Residential Care Facilities Differently 

The Compact does not cover “any institution caring for the mentally ill, mentally defective or 

epileptic or any institution primarily educational in character, and any hospital or other medical 

facility.” States appear to interpret this law differently. Some States use the license of the 

institution to determine whether it falls under the Compact. For example, if an institution has a 

child-care license, it is covered by the Compact, but if an institution has a medical-only license, it 

is not covered. However, other States consider the services offered by the institution rather than 

the license as the basis for inclusion in the Compact. For example, one State’s policy states that 

“the type of license, if any, held by an institution is evidence of its character, but whether an 

institution is either generally exempt from the need to comply with the Interstate Compact on the 

Placement of Children or exempt in a particular instance is to be determined by the services it 

actually provides or offers to provide.” 

Differences in State definitions may make it difficult for sending States to determine whether a 

facility is a child care institution or detention center. This may become an issue for the sending 

State when a child is IV-E eligible because detention centers are not eligible to receive IV-E 

funding. 

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OPPORTUNITIES FOR IMPROVEMENT

Based on this inspection and our previous study, we conclude that, overall, children are better off 

because of the Compact. However, we believe that there is a need to strengthen its 

implementation. We offer the following recommendations for those individuals and entities that 

have a role in the Compact. 

Awareness 

We learned that many individuals who work in the child welfare system are still unaware of the 

Compact. Clearly, more dissemination of Compact information is needed. We suggest that the 

States improve and increase the information about the Compact available to local workers, 

judges, attorneys, placement agencies and parents. This can be accomplished through increased 

opportunities for training for professionals, circulation of pamphlets among agencies and local 

workers, and the creation of a web site that would explain the purpose of the Compact and the 

process in simple language. Increased awareness and familiarity with the Compact may help 

reduce the number of violations that occur. 

Timeliness 

We heard that one of the chief complaints of our respondents is the length of the Compact 

process. Border State agreements may be a viable method to reduce the lengthiness of the 

Compact process. The Association of Administrators and the States are currently discussing the 

implementation of border state agreements. Such agreements, usually between two bordering 

States, could allow local workers from one State to enter the other State to complete home 

studies or supervision. We encourage the Association and the States to continue these 

discussions. 

State Level Coordination 

We are aware that local workers do not always communicate formally through the State Compact 

offices. States' inability to account for all interstate placements noted in our earlier study, The 

Interstate Compact on the Placement of Children: State Structure and Process (OEI-95-02-

00041), may in part be due to this failure. It is important that the State Compact offices continue 

to be the official contact point between States. We are encouraged that local workers often 

communicate directly for matters other than emergencies or problems. This contact is clearly in 

the best interest of the children. 

Training and Technical Assistance 

We believe there is opportunity for ACF to participate in strengthening the implementation of the 

Compact. The ACF can make training and technical assistance available to States. Further, ACF 

can support the efforts of the States and the Association to increase information dissemination 

about the Compact’s purpose, importance and process. 

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Residential Placements 

We recognize that residential placements are treated differently under the Compact and may be a 

potential vulnerability. We are continuing to look at the broader area of residential placements. 

We also encourage the States and the Association to examine how the Compact handles 

placements into residential care facilities. 

COMMENTS 

We received comments from the Administration for Children and Families (ACF) and from the 

American Public Human Services Association (APHSA). They both agree that there is 

opportunity for ACF to work with the Compact to provide necessary training. The full text of 

these comments can be found in Appendix A. 

The ACF plans to work with national resource centers, the Association of Administrators of the 

Interstate Compact on the Placement of Children, and the States to determine how it can promote 

awareness of the Compact, provide training to State agency staff who implement the Compact, 

and support the development of model procedures to help the Compact operate more effectively. 

The APHSA comments include the comments of the Executive Committee of the Association of 

Administrators. They strongly endorse the idea of ACF providing assistance to the States to 

strengthen the implementation of the Compact as well as training. In addition, they offered 

technical comments and we modified the report where appropriate. 

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APPENDIX A

COMMENTS 

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