Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JUNE GIBBS BROWN 

Inspector General 

NOVEMBER 1998 

OEI-02-95-00041 

The Interstate Compact on the Placement 

of Children 

State Structure and Process 
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 Regional 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

Daniel Ginsberg

Judy Lin

To obtain copies of this report, please call the New York Regional Office at (212) 264-1998. 

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 describe how States have implemented the Interstate 

Compact on the Placement of Children and to report on the number of children who are 

affected by the Compact. 

BACKGROUND 

The Administration for Children and Families (ACF) has asked the Inspector General (OIG) to 

look at a number of issues regarding interstate compacts. Currently, the ACF is interested in 

how the Interstate Compact on the Placement of Children (the Compact) is implemented by 

States, and the Compact’s strengths and weaknesses. This inspection addresses how States 

have structured their Compact function. The Compact’s strengths and weaknesses will be 

explored in a subsequent inspection. 

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. The Compact began in 1959 and all States, the 

District of Columbia, and the U.S. Virgin Islands had joined by 1990. 

This inspection is based on three data sets: responses to telephone interviews with compact 

administrators from each State, State policies and procedures, and placement data collected 

from the States. 

FINDINGS 

States Have Policies And Procedures That Are Generally Uniform And Comprehensive 

The vast majority of 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 two decentralized States handle all Compact cases at the county level.

States report using the same general procedures. Accordingly, placements usually follow the

same path: local office to State office in the sending State, then State office to local office in the

receiving State. Adoption and foster care placements generally follow the same path, but the

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process differs depending on who initiates the placement. It could be the court, an agency, a 

parent or guardian. Although similar in many ways, States do have some notable differences. 

These differences include the extent of contracting out compact administration and the number of 

residential treatment centers in States. 

States Are Sometimes Unaware That Children Are Placed in Their Jurisdiction 

Many States believe that children have probably been placed in their State without their 

knowledge. This can happen under two circumstances: 1) children placed through the Compact 

but the receiving State does not know the placement has been finalized; and 2) placements that 

ignore the Compact. States disagree about the implications of the first instance. Some States feel 

that these children are vulnerable because the placement may not be supervised. Other States say 

the local office knows about the placement, even if the State does not, and will supervise it. For 

placements that ignore the compact, the situation may be more serious because it is likely that 

neither the State nor its local office knows the child is there. 

Half of the States Do Not Know How Many Children They Placed Through The Compact 

in 1997 

State placement information is incomplete, but it indicates that many thousands of children are 

placed across State lines each year. Only 27 of the 52 Compact States were able to report the 

number of adoption, foster care, and residential placements into and out of their State in 1997. 

The total number of placements into these 27 States is 12,615. The total number of placements 

out of these 27 States is 11,827. The other 25 States are unable to report the actual number of 

adoption, foster care, and residential placements that occurred into or out of their States in 1997. 

The two main reasons that the quality of State data is poor and inconsistent are differing standards 

among States and ineffective tracking techniques. 

CONCLUSION 

Clearly the Interstate Compact on the Placement of Children has been successful in establishing 

procedures for the interstate placement of children. Needless to say, States have obligations to 

the children they place across State lines and it appears the compact system is a promising and 

viable way to fulfill these obligations. Nonetheless, weaknesses in the overall structure are 

apparent and some children may be vulnerable. We are continuing our work in this area and will 

analyze in greater detail how well this system is being implemented. 

We encourage States to abide by the principles of the Compact. The ACF should be prepared 

where necessary to provide technical assistance on how to more effectively implement the 

Compact, especially in regard to placement notification and uniform data collection. 

We received comments from ACF and from the American Public Human Services Association 

(APHSA). The ACF stated that the report presents information important to their agency, which 

is responsible for the Federal programs for foster care and adoption assistance. The ACF also 

expressed interest in information on the timeliness of interstate placements. This issue will be 

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addressed in a subsequent report. In addition, ACF made a number of technical comments that 

we incorporated into the report when appropriate. 

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

Administrators of the Interstate Compact for the Placement of Children. They stated that the 

report can serve as a foundation for a better understanding of what the Compact is today, how it 

works, and how it can function more effectively in the future. The Association welcomes efforts 

by ACF to work with the States and the Secretariat. The APHSA made a number of technical 

comments that we included in the report when appropriate. The actual comments received are 

included in Appendix B. 

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TABLE OF CONTENTS

PAGE 

EXECUTIVE SUMMARY

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

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

States Have Uniform Policies and Procedures ..................................... 6

States are Sometimes Unaware that Children are Placed ............................. 9

Half the States Cannot Report Placement Data .................................... 9

CONCLUSION ........................................................... 12

APPENDIX

A: 1997 Placement Data ................................................... A-1

B: Comments ........................................................... B-1
INTRODUCTION

PURPOSE 

The purpose of this inspection is to describe how States have implemented the Interstate 

Compact on the Placement of Children and to report on the number of children who are 

affected by the Compact. 

BACKGROUND 

The Administration for Children and Families (ACF) has asked the Inspector General (OIG) to 

look at a number of issues regarding interstate compacts and what happens when children are 

placed or moved across State lines. The OIG has completed an inspection, Interstate Compact 

on Adoption and Medical Assistance (OEI-02-95-00040), that assessed 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. Currently, 

the ACF is interested in how the Interstate Compact on the Placement of Children (the 

Compact) is implemented by States, and the Compact’s strengths and weaknesses. This 

inspection addresses how States have structured their Compact function. The Compact’s 

strengths and weaknesses will be explored in a subsequent inspection. 

Sometimes circumstances are such that the most suitable placement for a child is out of their 

own State. These out of State placements are made for a variety of reasons. They include 

adoptions across State lines, foster care placements 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, during pre-inspection, 

experts told us that the number of children placed across State lines is increasing. 

The Interstate Compact on the Placement of Children 

An interstate compact, such as the Interstate Compact on the Placement of Children, is a 

contract among and between States. To participate in the Compact, a State must enact into law 

the text of the Compact. It is 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. 

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 

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

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. 

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 placement into a group home, 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, adoptions 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, a form of foster care, 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 Association, under the terms of the Compact, can pass regulations. The 

American Public Human Services Association (APHSA) 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. ACF funded the Association until 1985. 

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Federal Role in Interstate Placements 

As the Federal agency with formal responsibility for supporting State Child Welfare activities, 

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. 

Adoption and Foster Care Analysis and Reporting System 

Under a Federal mandate, States are required to collect and report case-specific data on all 

children in foster care under the responsibility of the child welfare agencies and the children 

adopted with the involvement of these agencies. This data collection system is known as the 

Adoption and Foster Care Analysis and Reporting System (AFCARS). The first reporting 

period began October 1,1994. According to ACF, State submission of data has been 

inconsistent. Not all States are reporting data and some States are submitting data that is of 

poor quality. 

Statewide Automated Child Welfare Information Systems 

In 1993, a federal grant was set up to fund the Statewide Automated Child Welfare Information 

Systems program to update States’ child welfare information systems. The improved systems will 

have database, reporting and inquiry capabilities, and will be able to track the progress of children 

in both public and private child welfare service agencies. In the past five years, the majority of 

States have implemented or are in the process of developing these systems. 

The Adoption and Safe Families Act of 1997 

The Adoption and Safe Families Act of 1997 prohibits States from delaying or denying 

adoptive placements when an approved family is available in another jurisdiction. The Act 

establishes safety, permanency, and well-being as the Federal goals for children in the child 

welfare system. States are also required to develop plans for the effective use of cross­

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jurisdictional resources to facilitate timely adoptive or permanent placements for waiting 

children. The Act furthers the Federal initiative to double the annual number of children 

adopted from the foster care system by the year 2002. In addition, the Act requires the 

General Accounting Office to study and report to Congress on how to improve procedures and 

policies to facilitate timely adoptions across State and county lines. 

METHODOLOGY 

This inspection is based on three data sets: responses to telephone interviews with compact 

administrators, placement data, and State policies and procedures. 

State Interviews 

We conducted telephone interviews with all 52 member States (50 States, the District of 

Columbia, and the U.S. Virgin Islands). We spoke with each compact administrator or a 

representative designated to speak on the administrator’s behalf. We asked each State about the 

structure of the State’s Compact function, Compact staffing levels, and Compact procedures. 

We also asked about satisfaction with these structures and procedures. Finally, we gathered 

suggestions for improvement at both the State and national levels. 

Some concerns about illegal placements and improper use of the Compact placement forms 

were raised during the initial interviews with all the States. To learn more about these issues 

and to collect missing placement numbers, we called back a purposive sample of 17 States. 

We asked the 17 States questions about the use of the Compact’s notification form that reports 

a child’s placement status and the possibility of placements made in violation of the Compact. 

Placement Numbers 

We sent a letter to each State requesting the number of adoption, foster care, and residential 

Compact placements into and out of the State in calendar year 1997. We collected these 

numbers during the telephone interviews and through several follow-up calls. When these 

numbers were unavailable, we asked for estimates. Adoptions include placements through 

public agencies, private agencies, and independent agents, such as attorneys. Foster care is 

defined as placements in paid foster homes, with unpaid relatives, and with parents. 

Residential placements include residential treatment centers, group homes, and child care 

institutions. 

Residential care is generally considered a form of foster care. We chose to collect data for 

residential placements separately from other forms of foster care because our pre-inspection 

research indicated that residential numbers would vary widely among States. We did not, 

however, separate residential placements from foster care in our discussion of structure or 

procedures with States. 

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Policies and Procedures 

We asked each State to provide us with any written policies and procedures they use in the 

processing of interstate cases. Thirty-nine States sent written materials. We reviewed each 

State’s written policies and procedures to determine their clarity, thoroughness, and degree of 

detail. We also asked for any other tools used in Compact cases, such as information 

checklists attached to placement requests. A number of States also sent us training material 

used to train local case workers. We reviewed these materials for consistency with the text of 

the Compact and the APWA’s 1990 “Guide to the Interstate Compact on the Placement of 

Children.” 

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

States Have Policies And Procedures That Are Generally Uniform And Comprehensive 

Most States have a centralized structure 

The vast majority (50) of States have centralized their Compact function. They have a Compact 

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

This State office works with their own local offices and other States’ Compact offices. The 

majority of the centralized States (35) are satisfied with the way their State’s Compact function is 

structured. 

Only two States have decentralized their Compact function. That is, the counties in these States 

each have a liaison who acts in the same way compact administrators act in other States. 

Placements go through the county level, not State level. The decentralized States are also 

satisfied with their Compact structure. Several centralized States, however, complain that it is 

difficult placing children in decentralized States because of the burden of finding the appropriate 

people to contact. 

States report following the same general procedures 

Overall, States’ procedures appear to be consistent with the original Compact laws and with the 

Guide to the Interstate Compact on the Placement of Children written by the Secretariat. 

Usually placements follow the general path of sending local office o sending State office o

receiving State office o receiving local office. See the flow chart on the following page for a 

detailed illustration of the placement process. The flow chart does not include the supervision of 

the placement. 

As the flow chart shows, the typical interstate foster care placement originates with the local case 

worker in the sending State. The local worker in the sending State identifies a possible placement 

in another State, fills out an ICPC-100A Interstate Compact Placement Request and sends it, 

along with any other necessary information including medical and financial information, to the 

sending State Compact office. The sending State Compact office reviews the packet received 

from the local worker and makes sure it is complete. The compact administrator or representative 

signs the completed request and mails it to the receiving State Compact office. 

The receiving State Compact office reviews the request and forwards it to the local office where 

the child will be placed. The local office in the receiving States conducts a home study, 

recommends to approve or deny the placement, and forwards all the information to the receiving 

State Compact office. The receiving State compact administrator or representative then makes 

the decision to approve or deny the placement and sends all the information back to the sending 

State Compact office. If the placement has been approved, the local worker in the sending States 

will then decide whether or not to place the child. 

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6 
Interstate Compact on the Placement of Children Process - Foster Care Placement 

Local sending worker fills out 100A 

and sends it with a request packet 

to the sending State Compact office 

Local sending worker finds 

possible out of State placement 

Sending State Compact office reviews 

the 100A and request packet 

Sending State compact administrator 

signs the 100A and sends it to the 

receiving State Compact office 

No 

Yes 

Receiving State Compact office 

receives and reviews the100A 

and placement request packet 

Is 

more information 

needed? 

Receiving State Compact office sends the 

packet to the receiving local office 

No 

Local receiving office reviews 

packet and completes home study 

Yes 

Is the packet complete? Local 

packet with completed home study 

and recommendation to receiving 

State Compact office 

Is the placement approved 

by the receiving State 

compact administrator? 

Receiving State Compact 

office notifies the 

sending State Compact 

Sending State Compact notifies 

local sending office 

Local sending office reviews 

the home study 

Does the local sending 

worker decide to place 

the child? 

Child placed 

Receiving State Compact office 

notifies the sending State Compact 

Sending State Compact notifies 

local sending office 

Child is not placed 

Yes 

No 

Yes 

No 

Local Office recommends to approve 

or deny the placement. 

receiving office sends 

Local Office in Sending State 

State Compact Office in Sending State 

State Compact Office in Receiving State 

Local Office in Receiving State 

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7 
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Adoption placements generally follow the same path as foster care placements, except that 

adoptions originate from different sources. A public adoption, that is, a placement of a child 

usually under State custody by a public agency, goes through the same channels as a foster care 

placement. The process for private and independent adoptions differ from foster care placements 

and public adoptions mainly at the local level. For example, in a private adoption the private 

agency completes the 100A, prepares the packet requesting placement, and forwards it to the 

sending State Compact office. For independent adoptions, either an attorney or the birth 

mother/parents, depending on State law, acts as the sending agent and completes the 100A to 

request out of State placement. (All but six States allow independent adoptions.) After a 

placement has been approved, it is the private agency or birth parent/attorney who makes the final 

decision whether or not to send the child. 

One other significant difference was reported in the processing of private and independent 

adoptions. States report that home studies are usually completed by private caseworkers prior to 

the submission of the 100A. Therefore, one less step is followed in the Compact process. Rather 

then forwarding a 100A to a caseworker for a home study, a receiving State Compact office will 

usually make the decision to approve or deny the placement soon after receiving the request. 

States have some notable differences 

Six States contract out part of their Compact process and one State is considering this option to 

speed processing time. Both decentralized States contract out the processing of private adoption 

requests. That is, these agencies take on the responsibilities of the compact administrator. 

Centralized States sometimes contract out services done at the local level. Four States contract 

out foster care home studies. Two of them also contract out home studies for public adoptions 

and one contracts for post-placement supervision. In some cases, only specific geographic areas 

of the State contracts out services, usually in the region that contains the State’s largest urban 

area. 

Residential placements vary widely among States. Some States have no residential facilities so 

those States must use residential facilities in other States. Therefore, all their residential 

placements must go through the Compact. The States with facilities may receive very large 

numbers of residential placements through the Compact. Three of these States report receiving in 

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

other States. See Appendix A for a complete listing of State reported data. 

States’ written policies and procedures are generally uniform and comprehensive 

States have developed written procedures and several tools to aid the Compact process.

Of the 39 written State policies and procedures that we reviewed, 34 are comprehensive

descriptions of implementation of the Compact and five cover most, but not all, steps in the

placement process. The descriptions are fairly uniform and present similar policies and

procedures in similar terms. Almost all States (48) are satisfied with their procedures. States do

note, however, that they could use more staff, more training, and better automation.

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Some States have developed tools to facilitate case processing. For instance, some States have 

created sample transmittal, request, and response letters for interstate communication. Some use 

checklists to make sure all the necessary information, such as the financial and medical plan and 

social assessment of the child and family, is included in a placement request. States have also 

developed forms and letters to be used when they must return an incomplete request to the 

sending State. One State has made special arrangements with the police to handle criminal record 

checks for potential caregivers in priority placement cases. Another State has developed a memo 

for State child care institutions and judges that explains the legal requirements of the Compact. 

States Are Sometimes Unaware That Children Are Placed in Their Jurisdiction 

Many States believe that children have probably been placed in their State without their 

knowledge. This can happen under two circumstances: 1) children placed through the Compact 

but the receiving State does not know the placement has been finalized; and 2) placements that 

ignore the Compact. In the first instance, the Compact may be followed correctly during the 

placement but the receiving State is not formally notified by the sending State that the placement 

has occurred. Under the Compact, the 100B form is used by the sending State to tell the 

receiving State that a child has been placed. Although the States developed this form themselves 

through the Association, the form is not consistently used. Of the seventeen States asked whether 

they use the 100B Compact form as notification of placement, seven States say that they always 

use the 100B, eight States report sometimes using it and two say they do not use it at all. Most of 

the States say they do not receive 100B forms regularly. 

States disagree about the implications of not receiving 100B forms. Some States feel that even 

though the State Compact office may not be notified of a placement, the local office responsible 

for supervising the placement is probably aware of the situation so the child is not at risk. There 

is no way to verify this. Other States, however, feel that a child placed without the State’s 

knowledge may not be supervised. 

The situation may be more serious when a child is placed in violation of the Compact. This can 

happen when a court, attorney, or member of the general public is unaware of the Compact’s 

existence or knows about it but for some reason chooses to ignore it. In this instance, it is likely 

that neither the State nor the local office is notified. This issue will be examined more thoroughly 

in our next report. 

Half of The States Do Not Know How Many Children They Placed Through The Compact 

in 1997 

Although State placement information is incomplete, it indicates that many thousands of children 

are involved 

Only 27 States were able to report the number of adoption, foster care, and residential placements 

into and out of their State in 1997. Hence, we cannot report the aggregate number of children 

who are placed through the Compact annually. The total number of placements into the 27 States 

that submitted actual placement data is 12,615. This sum includes 2,468 adoption, 6,392 foster 

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care, and 3,755 residential placements. The total number of placements out of the 27 States is 

11,827. This sum includes 3,103 adoption, 7,036 foster care, and 1,688 residential placements. 

As noted in the methodology section, foster care numbers include placements with paid foster 

homes, unpaid relatives, and parents. Residential placements include residential treatment centers, 

group homes, and child care institutions. An analysis of the 27 reporting States revealed no 

common characteristics or defining patterns. 

The placement numbers vary among States. The sending and receiving adoption and residential 

placements range from none to several hundred. The sending and receiving foster care 

placements each range from just a few in some small States to over 1,200 in larger States. State 

population accounts for approximately 50 percent of the variance of placement numbers. Another 

factor that may contribute to this variance is the sharing of a metropolitan area between States. 

Data provided by the 27 States show that kinship (non-parent relative) is the most common type 

of foster care placement, followed by parental and paid foster home. Private agencies place more 

children into adoption through the Compact than public agencies. Independent adoptions are the 

least common type of Compact adoption placements. 

The other 25 States are unable to report the actual number of adoption, foster care, and 

residential placements that occurred in and out of their States in 1997. These States include seven 

that report estimates of placements; three that are missing some categories of placements; thirteen 

that count referrals or approvals, not placements; and two States that could provide no numbers 

at all. Referrals are requests made by a sending State that the receiving State conduct a home 

study to evaluate a possible placement. Six States could provide us with actual referrals or 

estimates of referrals. Approvals are approved requests for placement. Seven States could 

provide us with actual approvals or estimates of approvals. Some of the States that submitted 

actual placement data voluntarily submitted referral or approval data as well. Analysis of these 

data reveals no relationship between referrals and approvals or between approvals and 

placements. 

Different standards and ineffective tracking techniques are the main reasons the quality of State 

data is poor and not uniform. As noted above, States use different standards, such as referrals or 

approvals in their counting. A few of the States that count referrals say referrals are a more 

accurate reflection of their workload because procedures, such as home studies, need to be 

completed whether or not the child is eventually placed. Other States say they count approvals 

because they know how many approvals they have but they do not know the number of 

placements that have resulted from the approvals. 

States most often cite difficulty with their tracking systems as the reason for not having good 

data. Many States mention that they have to manually search through each file to tally placement 

statistics. Other States are automated to some extent, but report difficulty with their computer 

programs. For example, a number of States say that their statewide computer system tracks only 

children who are in the child welfare system. Since Compact cases include private placements, 

some Compact offices do not use their statewide tracking system. 

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The fact that several States require more than a month to collect the information is evidence of 

the problems States face. Even seven of the States that could provide actual placement data say 

they had difficulty obtaining their numbers. 

The data is also unavailable at the national level. Even though information about children placed 

out of State is suppose to be reported by each State for the AFCARS system, according to ACF 

only 23 States submitted quality data in 1997. In addition, the AFCARS data element to track 

out of State placement applies only to children in foster care which accounts for only about half of 

children placed through the Compact. 

The use of computer systems to track cases is limited 

Twelve States report tracking Compact cases entirely by computer, while another twelve report 

having no automation in their tracking system. The remaining States all use a combination of 

computer and manual tracking systems. Several States say they are developing computer systems 

or improving their current systems. Although the federal government has funded the States to set 

up their own SACWIS computer systems to track children in the child welfare system, it appears 

that these systems may not have helped States to track children placed through the Compact. Of 

the 50 States with some county or regional government, 17 report that the counties are currently 

using computers to track Compact cases and three report that they are currently developing 

county computer tracking systems. 

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CONCLUSION

Clearly the Interstate Compact on the Placement of Children has been successful in establishing 

procedures for the interstate placement of children. Needless to say, States have obligations to 

the children they place across State lines and it appears the compact system is a promising and 

viable way to fulfill these obligations. Nonetheless, weaknesses in the implementation are 

apparent and some children may be vulnerable. 

We encourage States to abide by the principles of the Compact. The ACF should be prepared 

where necessary to provide technical assistance on how to more effectively implement the 

Compact, especially in regard to placement notification and uniform data collection. One 

opportunity is to explore the use of Statewide Automated Child Welfare Information Systems. 

We are continuing our work in this area and will analyze in greater detail how well this system is 

being implemented. 

COMMENTS 

We received comments from ACF and from the American Public Human Services Association 

(APHSA). The ACF stated that the report presents information important to their agency, which 

is responsible for the Federal programs for foster care and adoption assistance. The ACF also 

expressed interest in information on the timeliness of interstate placements. This issue will be 

addressed in a subsequent report. In addition, ACF made a number of technical comments that 

we incorporated into the report when appropriate. 

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

Administrators of the Interstate Compact for the Placement of Children. They stated that the 

report can serve as a foundation for a better understanding of what the Compact is today, how it 

works, and how it can function more effectively in the future. The Association welcomes efforts 

by ACF to work with the States and the Secretariat. The APHSA made a number of technical 

comments that we included in the report when appropriate. The actual comments received are 

included in Appendix B. . 

))))))))))) 13 
APPENDIX A: 1997 Placement Data

Sending Receiving 

State Population Adoption Foster Care Residential Adoption Foster Care Residential 

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

Delaware

District of Columbia

Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Montana

4,319,154 42 (e) 228 (e) 24 (e) 72 (e) 262 (e) 36 (e) 

609,311 32 111 23 24 80 1 

4,554,966 297 1,028 107 89 970 718 

2,522,819 44 R 301 R 143 R 74 R 481 R 56 R 

32,268,301 214 (e) - 1,068 101 (e) - 3 

3,892,644 86 230 113 71 144 258 

3,269,858 21 160 62 107 127 17 

731,581 10 81 (e) 298 (e) 26 100 (e) 25 (e) 

528,964 140 252 140 25 74 0 

14,653,945 473 1,664 62 210 1,235 43 

7,486,242 160 A 350 A 0 361 A 487 A 35 A 

1,186,602 71 144 76 76 128 0 

1,210,232 28 44 107 87 118 66 

11,895,849 - - - - - -

5,864,108 56 (e) 228 (e) 84 (e) 32 (e) 336 (e) 36 (e) 

2,852,423 81 123 52 31 99 134 

2,594,840 104 122 23 56 115 7 

3,908,124 83 182 (e) 20 (e) 82 121 (e) 1 (e) 

4,351,769 152 A 223 A 179 A (e) 47 A 294 A 45 A (e) 

1,242,051 50 13 33 24 4 2 

5,094,289 254 667 101 257 929 57 

6,117,520 80 A 149 A 0 251 A 109 A 189 A 

9,773,892 300 (e) 718 (e) 180 (e) 500 (e) 1,223 (e) (e) 

4,685,549 - 4 61 - 20 15 

2,730,501 58 184 139 81 269 0 

5,402,058 61 93 17 73 72 132 

878,810 0 93 A 57 A 0 76 A 25 A 

))))))))))) A - 1 
Sending Receiving 

State Population Adoption Foster Care Residential Adoption Foster Care Residential 

Nebraska

Nevada

New Hampshire

New Jersey

New Mexico

New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

U.S. Virgin Islands

Utah

Vermont

Virginia

Washington

West Virginia

Wisconsin

Wyoming

1,656,870 61 (e) 275 147 135 (e) 155 136 

1,676,809 258 (e) 189 (e) - 173 (e) 229 (e) -

1,172,709 39 R 112 R 58 R 75 R 172 R 7 R 

8,052,849 151 R 634 R 76 R 527 R 513 R 6 R 

1,729,751 61 63 25 51 122 15 

18,137,226 323 R 1,063 R 126 R 566 R 851 R 11 R 

7,425,183 - - - - - -

640,883 12 248 70 25 152 18 

11,186,331 149 (e) 42 (e) 60 (e) 128 (e) 51 (e) 89 (e) 

3,317,091 91 165 37 132 259 38 

3,243,487 627 624 41 158 281 9 

12,019,661 233 408 242 357 478 708 

987,429 36 84 19 25 86 3 

3,760,181 38 137 16 78 204 20 

737,973 14 41 20 51 78 325 

5,368,198 56 225 35 111 293 264 

19,439,337 749 A 447 A 119 A 257 A 714 A 284 A 

114,000 0 1 3 1 12 0 

2,059,148 113 48 79 202 64 677 

588,978 15 49 35 74 50 95 

6,733,996 69 R 384 R 4 R 197 R 476 R 288 R 

5,610,362 229 R (e) 699 R (e) 96 R (e) 299 R (e) 757 R (e) 27 R (e) 

1,815,787 47 A 63 A 212 A 30 A 56 A 0 

5,169,677 48 A 296 A 25 A 107 A 269 A 215 A 

479,743 25 44 6 33 100 134 

Note: The numbers above are actual placements unless otherwise noted. 

(e) = number is an estimate

R = number of requests (or referrals) for placement

A = number of approved requests

- = data is unavailable 

))))))))))) A - 2 
APPENDIX B

COMMENTS 

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B - 6
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B - 7
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