Testimony 

Before the Subcommittee on Human 

Resources, Committee on Ways and 

Means, House of Representatives 

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 10:30 a.m. EST 

Wednesday, January 28, 2004 CHILD WELFARE

Improved Federal Oversight 

Could Assist States in 

Overcoming Key Challenges 

Statement of Cornelia M. Ashby, Director 

Education, Workforce, and Income Security Issues 

GAO-04-418T 
www.gao.gov/cgi-bin/getrpt?GAO-04-418T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Cornelia M. 

Ashby at (202) 512-8403 or 

ashbyc@gao.gov. 

Highlights of GAO-04-418T, a testimony 

before the Subcommittee on Human 

Resources, Committee on Ways and 

Means, House of Representatives 

January 28, 2004

CHILD WELFARE 

Improved Federal Oversight Could Assist 

States in Overcoming Key Challenges 

States use of Title IV-B funds to provide a wide variety of services to prevent 

the occurrence of abuse, neglect, and foster care placements, as well as to 

provide other child welfare services. According to GAO’s Title IV-B survey 

data for fiscal year 2002, states spent about 60 percent of subpart 1 funds on 

the salaries of child welfare agency staff, administration and management 

expenses, and child protective services, while about 10 percent were used to 

provide family support and family preservation services. In comparison, 

states spent about 62 percent of their subpart 2 funds on family support and 

preservation services. 

Child welfare agencies face a number of challenges related to staffing and 

data management that impair their ability to protect children from abuse and 

neglect. Low salaries hinder agencies’ ability to attract potential child 

welfare workers and retain those already in the profession. According to 

caseworkers GAO interviewed, high turnover rates and staffing shortages 

leave remaining staff with insufficient time to establish relationships with 

families and make the necessary decisions to ensure safe and stable 

permanent placements. States also face challenges developing appropriate 

information systems needed to track abuse or neglect reports and monitor 

children in foster care. In addition, several factors affect states’ ability to 

collect and report reliable adoption, foster care, and child abuse and neglect 

data, including insufficient caseworker training, inaccurate and incomplete 

data entry, and technical challenges reporting the data. 

HHS plays a role in helping states overcome some of the challenges they face 

in operating their child welfare programs, but additional oversight or 

technical assistance could assist states in meeting the needs of children 

served by child welfare agencies. HHS’s oversight of Title IV-B focuses 

primarily on states’ overall child welfare systems and outcomes, but the 

agency provides relatively little oversight specific to Title IV-B subpart 1. In 

addition, HHS plays a limited role in states’ workforce activities by offering 

partial reimbursement for training expenses and managing discretionary 

grant programs. The agency monitors states’ information systems 

development and data reporting, but despite the availability of technical 

assistance, states reported ongoing challenges reporting reliable data. 

In the related reports, GAO made several recommendations to HHS. GAO 

recommended that HHS provide the necessary guidance to ensure that 

regional offices monitor states’ use of Title IV-B subpart 1 and to consider 

gathering additional information on its use. GAO also recommended that 

HHS take actions that may help child welfare agencies address recruitment 

and retention challenges. Last, GAO recommended that HHS consider ways 

to enhance the guidance and assistance offered to help states overcome key 

data challenges. HHS generally agreed with GAO’s findings and 

recommendations, except that it noted that its level of oversight of Title IV-B 

was commensurate with the program’s scope and intent. 

Title IV-B of the Social Security 

Act, comprised of two subparts, is 

the primary source of federal 

funding for services to help 

families address problems that lead 

to child abuse and neglect and to 

prevent the unnecessary separation 

of children from their families; 

however, a number of challenges 

exist that impair states’ ability to 

deliver and track these services. 

This testimony is based on findings 

from three reports issued in 2003 

and addresses the following: (1) 

states’ use of Title IV-B funds in 

providing a wide array of services 

to prevent the occurrence of abuse, 

neglect, and unnecessary foster 

care placements, as well as in 

providing other child welfare 

services; (2) factors that hinder 

states’ ability to protect children 

from abuse and neglect; and (3) the 

Department of Health and Human 

Services’ (HHS) role in helping 

states to overcome these 

challenges. Findings are based on 

multiple methodologies, including a

survey to child welfare directors on 

states’ use of Title IV-B funds; an 

analysis of nearly 600 exit 

interview documents completed by 

staff who severed their 

employment from 17 state, 40 

county, and 19 private child welfare 

agencies; and a survey of all 50 

states and the District of Columbia 

regarding their experiences in 

developing and using information 

systems and their ability to report 

data to HHS. In each case, GAO 

also conducted multiple site visits 

to selected states and interviewed 

child welfare experts and HHS 

headquarters and regional officials. 
Page 1 GAO-04-418T 

Mr. Chairman and Members of the Subcommittee: 

Thank you for inviting me here today to discuss several issues related to 

the oversight of child welfare programs across the nation. As you are 

aware, state child welfare agencies determined that over 900,000 children 

had been the victims of abuse or neglect by their parents or other 

caretakers in 2001. Additionally, more than 800,000 children are estimated 

to spend some time in foster care each year, with the federal government 

allocating approximately $7 billion each year to investigate abuse and 

neglect, provide placements to children outside their homes, and deliver 

services to help keep families together. Title IV-B of the Social Security 

Act, comprised of two subparts, is the primary source of federal funding 

for services to help families address problems that lead to child abuse and 

neglect and to prevent the unnecessary separation of children from their 

families. Funding under Title IV-E of the Social Security Act is used 

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

1994, designated federal matching funds have been available to states to 

develop and implement comprehensive case management systems—

statewide automated child welfare information systems (SACWIS)—to 

manage their child welfare cases as well as to report child abuse and 

neglect, foster care, and adoption information to the federal government. 

In addition to this funding, the Department of Health and Human Services’ 

(HHS) Administration for Children and Families (ACF) monitors states’ 

compliance with key federal goals, specified in part by the Adoption and 

Safe Families Act (ASFA) of 1997, to keep children safe and ensure their 

placement in stable and permanent homes. Through its formal review 

process, known as the Child and Family Services Review (CFSR), HHS 

uses specific assessment measures, such as agencies’ ability to conduct 

timely abuse and neglect investigations and regularly visit children in their 

homes, to assess the performance of states’ child welfare systems. 

My testimony today will focus on three key issues: (1) states’ use of Title 

IV-B funds in providing a wide array of services to prevent the occurrence 

of abuse, neglect, and foster care placements, as well as other child 

welfare services; (2) factors that hinder states’ ability to protect children 

from abuse and neglect; and (3) HHS’s role in helping states to overcome 

the challenges they face in protecting children from abuse and neglect. My 
Page 2 GAO-04-418T 

comments are based primarily on the findings from three reports:1 U.S. 

General Accounting Office, Child Welfare: HHS Could Play a Greater Role 

in Helping Child Welfare Agencies Recruit and Retain Staff. GAO-03-357. 

Washington, D.C.: March 31, 2003; Child Welfare: Most States Are 

Developing Statewide Information Systems, but the Reliability of Child 

Welfare Data Could Be Improved. GAO-03-809. Washington, D.C.: July 31, 

2003; and Child Welfare: Enhanced Federal Oversight of Title IV-B Could 

Provide States Additional Information to Improve Services. GAO-03-956. 

Washington, D.C.: September 12, 2003. Those findings were based on 

multiple methodologies, including a survey of child welfare directors on 

states’ use of Title IV-B funds; an analysis of 600 exit interview documents 

completed by staff who severed their employment from 17 state, 40 

county, and 19 private child welfare agencies; and a survey of all 50 states 

and the District of Columbia regarding their experiences in developing and 

using information systems and their ability to report data to HHS. In each 

case, we supplemented these surveys and analyses by conducting multiple 

site visits to selected states and by interviewing child welfare experts and 

HHS headquarters and regional officials. 

In summary, we found that states use Title IV-B funds to provide a wide 

variety of services to prevent the occurrence of abuse, neglect, and foster 

care placements, as well as to provide other child welfare services. 

Subpart 1 dollars were most frequently used to fund staff salaries, with 

almost half of these funds designated for the salaries of child protective 

services (CPS) 2 social workers. In comparison, states spent half of their 

subpart 2 funds on family support or prevention programs and another 12 

percent on family preservation services. CFSR results for the past 2 years, 

however, indicate that states have not performed strongly in terms of 

assessing the services families need and providing those services. Child 

welfare agencies face a number of issues related to staffing and data 

management that impair their ability to protect children from abuse and 

neglect. In particular, low salaries hinder agencies’ ability to attract 

potential child welfare workers and to retain those already in the 

profession. Our analysis of CFSRs in 27 states indicated that large 

 1

We also recently testified on one of these reports. See U.S. General Accounting Office, 

Child Welfare: States Face Challenges in Developing Information Systems and Reporting 

Reliable Child Welfare Data. GAO-04-267T. (Washington, D.C.: Nov. 19, 2003). 

2

Child protective services activities typically include reviewing reports of alleged child 

abuse and neglect, investigating those that meet the state’s criteria as a potential incident 

of abuse or neglect to determine if the alleged incident occurred, and, in some cases, 

referring families to needed services and removing the child from the home, if necessary. 
Page 3 GAO-04-418T 

caseloads and worker turnover delay the timeliness of investigations and 

limit the frequency of worker visits with children, hampering agencies’ 

attainment of some key federal safety and permanency outcomes. 

Furthermore, states face challenges developing appropriate information 

systems needed to track abuse or neglect reports and monitor children in 

foster care, with many states reporting development delays. In addition, 

several factors affect the states’ ability to collect and report reliable 

adoption, foster care, and child abuse and neglect data, including 

insufficient caseworker training, inaccurate and incomplete data entry, 

and technical challenges reporting the data. Although HHS plays a role in 

monitoring child welfare programs, additional oversight or technical 

assistance could assist states in meeting the needs of children served by 

child welfare agencies. For example, HHS’s oversight of Title IV-B focuses 

primarily on states’ overall child welfare systems and outcomes, but the 

agency provides relatively little oversight specific to the services provided 

under Title IV-B subpart 1.3

 In addition, HHS plays a limited role in states’ 

workforce activities by offering partial reimbursement for training 

expenses and managing discretionary grant programs. The agency 

monitors SACWIS development and data reporting, but despite the 

availability of technical assistance, states reported ongoing challenges 

reporting reliable data. 

ACF is responsible for the administration and oversight of federal funding 

to states for child welfare services under Titles IV-B and IV-E. HHS 

headquarters staff are responsible for developing appropriate policies and 

procedures for states to follow in terms of obtaining and using federal 

child welfare funds, while staff in HHS’s 10 regional offices and 10 national 

resource centers provide guidance and technical assistance to improve 

child welfare services nationwide. HHS compiles state-reported child 

welfare data in two databases: the Adoption and Foster Care Analysis and 

Reporting System (AFCARS) and the National Child Abuse and Neglect 

Data System (NCANDS). HHS relies on the information available in its 

databases to analyze and track children’s experiences in the child welfare 

system, to determine states’ performance on federal child welfare outcome 

measures, and to report to Congress on children’s well being and child 

welfare experiences. However, the monitoring of children served by state 

 3

Our September 2003 report on Title IV-B focused primarily on subpart 1 because little, if 

any, research has been conducted on how subpart 1 funds have been spent on child welfare 

services. In contrast, a number of studies have been conducted on the services provided 

under subpart 2. 

Background 
Page 4 GAO-04-418T 

child welfare agencies is the responsibility of the state agencies that 

provide the services to these children and their families. Child welfare 

caseworkers at the county or local level are the key personnel responsible 

for documenting the wide range of services offered to children and 

families, such as investigations of abuse and neglect; treatment services 

offered to families to keep them intact and prevent the need for foster 

care; and arrangements made for permanent or adoptive placements when 

children must be removed from their homes. Most states and counties 

provide some child welfare services directly and provide others through 

contracts with private agencies. National survey data confirm that both 

state and private child welfare agencies are experiencing similar 

challenges recruiting and retaining qualified caseworkers. For instance, 

turnover of child welfare staff has been estimated at between 30 percent 

and 40 percent annually nationwide, with the average tenure for child 

welfare workers being less than 2 years. 

In 2000, HHS established a new federal review system to monitor state 

compliance with federal child welfare laws. One component of this system 

is the CFSR, which assesses state performance in achieving safety and 

permanency for children, along with well-being for children and families. 

The CFSR process includes a self-assessment by the state, an analysis of 

state performance in meeting national standards established by HHS, and 

an on-site review by a joint team of federal and state officials. Based on 

the results of this process, HHS determines whether a state achieved 

substantial conformity with (1) outcomes related to safety, permanency, 

and well-being, such as keeping children protected from abuse and neglect 

and achieving permanent and stable living situations for children and (2) 

key systemic factors, such as having an adequate case review system and 

an adequate array of services. States are required to develop program 

improvement plans to address all areas of nonconformity. 

Two titles of the Social Security Act provide federal funding targeted 

specifically to foster care and related child welfare services.4

 Title IV-E5

provides an open-ended individual entitlement for foster care maintenance 

 4

In addition, Title XX provides funds under the social services block grant that may be used 

for many purposes, including child welfare. 

5

In fiscal year 2002, total Title IV-E spending was approximately $6.1 billion. The state 

matching rate for these payments is based on a state’s per capita income and ranges from 

50 percent to 83 percent. 

Federal Funding of Child 

Welfare Services and 

Programs 
Page 5 GAO-04-418T 

payments to cover a portion of the food, housing, and incidental expenses 

for all foster children whose parents meet certain federal eligibility 

criteria.6

 Title IV-E also provides payments to adoptive parents of eligible 

foster children with special needs.7

 To qualify for federal IV-E funding for 

SACWIS, states must prepare and submit an advance planning document 

(APD) to ACF’s Children’s Bureau, in which they describe the state’s plan 

for managing the design, development, implementation, and operation of a 

SACWIS that meets federal requirements and state needs in an efficient, 

comprehensive, and cost-effective manner. Since the administration and 

structure of state child welfare agencies vary across the nation, states can 

design their SACWIS to meet their state needs, as long as states meet 

certain federal requirements. 

Title IV-B of the Social Security Act, established in 1935, authorizes funds 

to states to provide a wide array of services to prevent the occurrence of 

abuse, neglect, and foster care placements.8

 In 1993, the Congress created 

a new program as subpart 2 of Title IV-B (now known as Promoting Safe 

and Stable Families), which funds similar types of services but is more 

prescriptive in how states can spend the funds. 9 No federal eligibility 

criteria apply to the children and families receiving services funded by 

Title IV-B. 

 6

States are entitled to Title IV-E reimbursement on behalf of children who would have been 

eligible for Aid to Families with Dependent Children (AFDC) (as AFDC existed on July 16, 

1996), but for the fact that they were removed from the home of certain specified relatives. 

While the AFDC program was replaced by the Temporary Assistance for Needy Families 

Program in 1996, eligibility for Title IV-E payments remains tied to the income eligibility 

requirements of the now defunct AFDC program. In addition, certain judicial findings must 

be present, and all other requirements included in section 472 (a) and (b) of the Social 

Security Act must be met, in order for the child to be eligible for Title IV-E foster care 

maintenance payments. 

7

Special needs are characteristics that can make it difficult for a child to be adopted and 

may include emotional, physical, or mental disabilities, emotional disturbance, age, or 

being a member of a minority race. To qualify for an adoption subsidy under Title IV-E, a 

state must determine that the child cannot or should not return home; a state must make a 

reasonable, but unsuccessful effort to place the child without the subsidy; and a specific 

factor or condition must exist that makes it difficult to place the child without a subsidy. 

8

In fiscal year 2003, the Congress appropriated $292 million for subpart 1 and $405 million 

for subpart 2. These federal funds cover 75 percent of states’ total Title IV-B expenditures 

because states must provide an additional 25 percent using nonfederal dollars. 

9

States must spend a “significant portion” of their subpart 2 funds on each of the four 

service categories. HHS program instructions require states to spend at least 20 percent of 

their subpart 2 funds on each of the four service categories, unless a state has a strong 

rationale for some other spending pattern. 
Page 6 GAO-04-418T 

Title IV-B subpart 1 provides grants to states for child welfare services, 

which are broadly defined. Subpart 1 funds are intended for services that 

are directed toward the accomplishment of the following purposes: (1) 

protect and promote the welfare of all children; (2) prevent or remedy 

problems that may result in the abuse or neglect of children; (3) prevent 

the unnecessary separation of children from their families by helping 

families address problems that can lead to out-of-home placements; (4) 

reunite children with their families; (5) place children in appropriate 

adoptive homes when reunification is not possible; and (6) ensure 

adequate care to children away from their homes in cases in which the 

child cannot be returned home or cannot be placed for adoption. 

In 1980, the Congress enacted legislation that limited the total subpart 1 

funds states could use for three categories of services: foster care 

maintenance payments, adoption assistance payments, and child care 

related to a parent’s employment or training.10 The total of subpart 1 funds 

used for these purposes cannot exceed a state’s total 1979 subpart 1 

expenditures for all types of services. The intent of this restriction, 

according to a congressional document, was to encourage states to devote 

increases in subpart 1 funding as much as possible to supportive services 

that could prevent the need for out-of-home placements.11 However, this 

restriction applies only to the federal portion of subpart 1 expenditures, as 

the law notes that states may use any or all of their state matching funds 

for foster care maintenance payments. 

Subpart 2 authorizes grants to states to provide four categories of services, 

which are defined below: 

• Family preservation services: Services designed to help families at risk or 

in crisis, including services to (1) help reunify children with their families 

when safe and appropriate; (2) place children in permanent homes 

through adoption, guardianship, or some other permanent living 

arrangement; (3) help children at risk of foster care placement remain 

safely with their families; (4) provide follow-up assistance to families 

 10For our September 2003 report on Title IV-B and in this testimony, we mention only foster 

care maintenance and adoption assistance payments when referring to subpart 1 limits, 

although we did include planned spending on child care in our analyses of states’ planned 

subpart 1 spending. 

11Staff of the House Committee on Ways and Means, 106th Congress, Background Material 

and Data on Programs Within the Jurisdiction of the Committee on Ways and Means 

(Comm. Print 2000). 
Page 7 GAO-04-418T 

when a child has been returned after a foster care placement; (5) provide 

temporary respite care; and (6) improve parenting skills. 

• Family support services: Community-based services to promote the safety 

and well-being of children and families designed to increase the strength 

and stability of families, to increase parental competence, to provide 

children a safe and supportive family environment, to strengthen parental 

relationships, and to enhance child development. Examples of such 

services include parenting skills training and home visiting programs for 

first time parents of newborns. 

• Time-limited family reunification services: Services provided to a child 

placed in foster care and to the parents of the child in order to facilitate 

the safe reunification of the child within 15 months of placement. These 

services include: counseling, substance abuse treatment services, mental 

health services, and assistance to address domestic violence. 

• Adoption promotion and support services: Services designed to encourage 

more adoptions of children in foster care when adoption is in the best 

interest of the child, including services to expedite the adoption process 

and support adoptive families. 

In our September 2003 report on Title IV-B, we found that states use these 

funds to provide a wide variety of services to prevent the occurrence of 

abuse, neglect, and foster care placements, as well as services to help 

children in foster care and their parents; however, relatively few subpart 1 

dollars are used to provide family support and family preservation 

services, while the majority of subpart 2 funds are used for these purposes. 

According to our survey data for fiscal year 2002,12 states spent subpart 1 

funds most frequently on the salaries of child welfare agency staff, 

administration and management expenses, CPS services, and foster care 

maintenance payments. In comparison, states spent half of their subpart 2 

funds on family support or prevention programs and another 12 percent on 

family preservation services. CFSR results for the past 2 years, however, 

indicate that states have not performed strongly in terms of assessing the 

services families need and providing those services. 

 12To obtain a breakdown of state spending for subparts 1 and 2 for the Title IV-B report, we 

sent a survey to all 50 states and the District of Columbia and received responses from 47 

states. 

States Spend IV-B 

Funds on A Variety of 

Services, With 

Subpart 2 Focusing 

More on Prevention 
Page 8 GAO-04-418T 

Relatively few subpart 1 dollars were used for family support or family 

preservation services; instead, they were most frequently used to fund 

staff salaries, with almost half of these funds designated for the salaries of 

CPS social workers. Another 20 percent of these funds were used for the 

salaries of other social workers.13 During a site visit to the state of 

Washington for the Title IV-B report,14 child welfare officials told us that 

they used over 50 percent of the state’s subpart 1 funds for salaries of staff 

providing direct services, including CPS social workers, other types of 

social workers, social work supervisors, and clerical support staff. 

Administration and management comprised the second largest category of 

service, accounting for almost 17 percent of subpart 1 dollars. This 

category included rent and utilities for office space, travel expenses for 

agency staff, and staff training.15

CPS represents the third largest category of services that states funded 

with subpart 1. States used about 16 percent of their subpart 1 funds to 

provide a variety of CPS services, such as telephone hotlines for the public 

to report instances of child abuse and neglect, emergency shelters for 

children who needed to be removed from their homes, and investigative 

services. During our site visit to California, for example, officials reported 

using about 40 percent of their subpart 1 dollars to fund staff salaries and 

operating expenses associated with a variety of shelter care services 

provided by counties, such as emergency shelters and foster homes. A 

child is placed in one of these shelters when no other placement option is 

immediately available—for example, when an investigation in the middle 

of the night determines that the child is at immediate risk of harm. States 

also used nearly 11 percent of their subpart 1 funds to make recurring 

payments for the room and board of foster children who are not eligible 

 13The survey data reported in this category reflect the salaries of staff affiliated with the 

child welfare agency. These figures do not include the salaries of child welfare agency staff 

dedicated to a specific program, which may be embedded within some of the other direct 

service categories, such as family support and family preservation. In addition, a state may 

use Title IV-B funds to contract with an organization to provide a particular program, which 

may include salary expenses as well as direct service expenditures. 

14For the Title IV-B report, we conducted site visits in California, New Jersey, Ohio, and 

Washington to obtain more in-depth information on the services provided and the types of 

children and families served. These states represent both geographic diversity and diversity 

in how states used subpart 1 funds. 

15This amount may be underestimated, since some states may not have separately reported 

administrative expenses associated with a specific program. For example, officials in one 

state reported that the total spending for a family support program included salaries for 

agency staff, overhead expenses, and related staff travel. 

States Use Subpart 1 

Funds Primarily for Staff 

Salaries 
Page 9 GAO-04-418T 

for reimbursement through Title IV-E. About 10 percent of subpart 1 

dollars were used to provide family support and family preservation 

services. 

In contrast to subpart 1, states used over 80 percent of their subpart 2 

dollars to fund services in its four mandated service categories—family 

support, family preservation, family reunification, and adoption promotion 

and support services (see app. I for additional information on states’ 

comparative expenditures on subparts 1 and 2). For example, states 

reported using half of their subpart 2 dollars to fund family support and 

prevention services. These services included mentoring programs to help 

pregnant adolescents learn to be self-sufficient; financial assistance to lowincome families to help with rent and utility payments; and parenting 

classes, child care, and support groups provided by a community-based 

resource center. Washington funded a network of public health nurses and 

social service agencies to provide support services to families that are the 

subject of a report of abuse or neglect—these services are provided in lieu 

of, or following, a formal investigation when the level of risk to the child is 

not considered high. 

Family preservation services—designed to keep families together and 

prevent the need to place a child in foster care—represented the second 

largest service category funded by subpart 2. Washington used subpart 2 

funds for its statewide family preservation program, which offers 

counseling and parent training services for up to 6 months to families with 

children who are at risk of being placed in foster care. 

In addition, states reported using about 11 percent of their subpart 2 funds 

for adoption support and preservation services. With these funds, states 

provided services such as counseling for children who are going to be 

adopted, family preservation services to adoptive families, and respite 

care16 for adoptive families. Officials in Ohio reported using almost half of 

its subpart 2 dollars for adoption services, including post adoption 

services and services to recruit families for children in need of adoptive 

homes. 

 16Respite care refers to the temporary care of children that can provide a break for the 

families from the daily demands of caring for their children or respite during times of 

emergencies. 

Subpart 2 Most Frequently 

Funds Family Support and 

Family Preservation 

Services 
Page 10 GAO-04-418T 

Finally, states spent about 9 percent of their subpart 2 dollars on family 

reunification services. States funded a diverse array of family reunification 

programs, such as supervised visitation centers for parents to visit with 

their children and coordinators for alcohol and drug treatment services for 

families whose primary barrier to reunification is substance abuse. New 

Jersey funded a supervised visitation program that offers parenting 

education, counseling, transportation, and support groups and is located 

in a private home, allowing families to visit together in a homelike setting 

and engage in more natural interactions. 

While states are using Title IV-B funds to provide this array of services, 

CFSR results for the past 2 years indicate that states have not performed 

strongly in terms of assessing the services families need and providing 

those services. When HHS reviewed case files it determined that 31of the 

32 states that underwent a CFSR in 2001 or 2002 needed improvement in 

terms of assessing family needs and providing services to meet those 

needs. While 21 of the 32 states were considered to have an appropriate 

array of services for families, HHS found that the accessibility of services 

was a particular weakness in that many services were either not available 

statewide or had long waiting lists or other barriers to accessibility. 

Child welfare agencies face a number of issues related to staffing and data 

management that impair their ability to protect children from abuse and 

neglect. In particular, low salaries hinder agencies’ ability to attract 

potential child welfare workers and to retain those already in the 

profession. Additionally, caseworkers in the four states we visited for the 

March 2003 child welfare workforce report17 cited high caseloads and a 

lack of supervisory support as issues impacting their ability to work 

effectively. According to these caseworkers, high turnover rates and 

staffing shortages leave remaining staff with insufficient time to establish 

relationships with children and families and make the necessary decisions 

to ensure safe and stable permanent placements. Furthermore, our July 

2003 report found that states face challenges developing appropriate 

information systems needed to track abuse or neglect reports and monitor 

 17For this report, we conducted site visits in California, Illinois, Kentucky, and Texas to 

obtain more in-depth information on workforce issues and their effect on children’s safety 

and permanency outcomes. Among other factors, these states represent geographic 

diversity and diversity in the practices they have implemented to address their recruitment 

and retention challenges. 

CFSRs Find States Are 

Weak in Assessing 

Families’ Service Needs 

Staff and Data Issues 

Affect States’ Ability 

to Protect Children 

From Abuse and 

Neglect 
Page 11 GAO-04-418T 

children in foster care. While 47 states are developing or operating a 

SACWIS, many states18 reported that the development of their SACWIS is 

delayed. Most states responding to our survey faced challenges to SACWIS 

development, such as obtaining state funding and developing a system that 

met the child welfare agency’s needs statewide. In addition, several factors 

affect states’ ability to collect and report reliable adoption, foster care, and 

child abuse and neglect data, including insufficient caseworker training, 

inaccurate and incomplete data entry, and technical challenges reporting 

the data. 

In our report on the child welfare workforce, we found that public and 

private child welfare agencies face a number of challenges recruiting and 

retaining qualified caseworkers and supervisors. Low salaries, in 

particular, hinder agencies’ ability to attract potential staff and to retain 

those already in the profession. For example, caseworkers in each of the 

four states we visited said that many of their former child welfare 

colleagues pursued positions in the education field where they could not 

only make more money but also work with children without risking their 

own safety. For example, the Bureau of Labor Statistics’ national wages 

survey19 reports that elementary and middle school teachers earn, on 

average, about $42,000 annually while social workers earn about $33,000.20

Additionally, high caseloads, administrative burdens, limited supervision, 

and insufficient training reduce the appeal of child welfare work. 

Caseworkers and supervisors in all four states we visited cited demanding 

 18These reports were obtained through both site visit interviews and survey responses. For 

the child welfare information systems and data report, we conducted site visits in 

Colorado, Iowa, New York, North Carolina, and Oklahoma to obtain more in-depth 

information on states’ experiences developing SACWIS and reporting data to HHS. These 

states represent both geographic diversity and different stages of SACWIS implementation. 

In addition, we surveyed all 50 states and the District of Columbia regarding their 

experiences in developing and using information systems and their ability to report data to 

HHS. We received responses from 49 states and the District of Columbia, although some 

states did not respond to every question. Forty-six of these states reported that they are 

developing or operating a SACWIS. Nevada, which HHS reported has an operational 

SACWIS, did not respond to our survey. Throughout this testimony, references to state 

survey responses for our July 2003 report include the District of Columbia. 

19U.S. Department of Labor, Bureau of Labor Statistics, 2000 National Occupational 

Employment and Wage Estimates. 

20This amount is specific to child, family, and school social workers (the occupation under 

which caseworkers would likely be classified). 

Recruitment and Retention 

Challenges May Hamper 

Agencies’ Attainment of 

Federal Child Welfare 

Outcomes 
Page 12 GAO-04-418T 

and complex caseloads and related administrative requirements, such as 

casework documentation, as factors affecting retention. Some of the 

caseworkers we interviewed handled double the number of cases 

recommended by advocacy organizations,21 and one study found that 

caseloads for individual child welfare workers ranged from 10 to 110 

children,22 with workers handling an average of about 24 to 31 children 

each. Furthermore, some of the caseworkers we interviewed told us that 

they spent between 50 and 80 percent of their time completing paperwork, 

thereby limiting their time to assist children and families. 

Caseworkers told us that their desire to stay in the child welfare 

profession was influenced by high-quality supervision and adequate onthe-job training; however, these elements were often lacking. According to 

supervisors in one city we visited, about half of new trainees left their jobs 

before completing 1 year, in part, because these newly hired caseworkers 

were not sufficiently trained to do their jobs. Furthermore, some newly 

promoted supervisors have requested demotions because they felt 

unprepared to meet job demands, and the caseworkers they supervised 

complained of poor management and insufficient support. 

There is some evidence to suggest how recruitment and retention 

challenges affect the safety and permanency of children in care, but the 

magnitude of this effect is unknown. Caseworkers in the four states that 

we visited said that high turnover rates and staffing shortages leave 

remaining staff with insufficient time to conduct the types of home visits 

necessary to assess children’s safety and to make well-supported decisions 

to ensure safe and stable permanent placements. For example, when staff 

change, caseworkers may have to reestablish information to update the 

case record and families may become hesitant to work with unfamiliar 

caseworkers, making it difficult to learn the history of the case. Worker 

turnover also disrupts the continuity of services, particularly when newly 

assigned caseworkers have to conduct or reevaluate educational, health, 

and safety assessments due to poor or insufficient information in case files 

left behind by others. Furthermore, caseworkers explained that high 

caseloads require them to limit the number and quality of the home visits 

 21The Child Welfare League of America suggests a caseload ratio of 12 to 15 children per 

caseworker, and the Council on Accreditation for Children and Family Services suggests 

that caseloads not exceed 18 children per caseworker. 

22American Public Human Services Association, Report from the Child Welfare Workforce 

Survey: State and County Data and Findings, May 2001. 
Page 13 GAO-04-418T 

they conduct, forcing them to focus only on the most serious 

circumstances of abuse and neglect. One caseworker in Texas noted that 

when she does make a home visit, the visit is quick and does not enable 

her to identify subtle or potential risks to the child’s well-being. 

Our analysis of federal CFSRs corroborated caseworker accounts,23

showing that large caseloads and worker turnover delay the timeliness of 

investigations and limit the frequency of worker visits with children, 

thereby hampering agencies’ attainment of some key federal safety and 

permanency goals. Although identifying workforce deficiencies is not an 

objective of the CFSR process, in all 27 CFSRs we analyzed, HHS explicitly 

cited workforce deficiencies—high caseloads, training deficiencies, and 

staffing shortages—that affected the attainment of at least one assessment 

measure. While the number of affected assessment measures varied by 

state, we found that HHS cited these factors for an average of nine 

assessment measures per state, with more than half of the 27 states 

exceeding this average. For example, in New Mexico’s CFSR, reviewers 

cited staff turnover and vacancies as impairing workers’ ability to 

investigate child maltreatment reports, provide appropriate services for 

families, and establish timely permanency goals. Furthermore, the District 

of Columbia’s CFSR describes heavy workloads, high staff turnover, and a 

climate in which supervisors often call new workers out of training to 

handle ongoing caseload activities. 

In addition to performing a wide range of services to protect children, 

child welfare caseworkers are the key personnel who collect and 

document information on children and families served by children welfare 

agencies. Case file documentation is generally captured in state computer 

systems. In our July 2003 report, HHS reported that 47 states are using 

targeted federal funds to develop or operate their child welfare computer 

systems—known as SACWIS—but many continue to face challenges 

completing their systems. In our November 2003 testimony on SACWIS,24

we reported on the costs associated with developing SACWIS and the 

associated barriers, such as development delays and difficulties in 

 23At the time of the original study, CFSR final reports were available for only 27 states; as of 

January 28, 2004, HHS had released reports for an additional 14 states. 

24See U.S. General Accounting Office, Child Welfare: States Face Challenges in Developing 

Information Systems and Reporting Reliable Child Welfare Data, GAO-04-267T

(Washington, D.C.: Nov. 19, 2003). 

Delays in SACWIS 

Completion and 

Challenges with Data 

Collection Affect States’ 

Ability to Ensure Reliable 

Data on Children’s 

Experiences 
Page 14 GAO-04-418T 

receiving state funding approval, creating a system that reflects child 

welfare work processes, and securing contractors knowledgeable about 

child welfare. Many state officials said that they recognize the benefit their 

state will achieve by developing SACWIS, such as contributing to the 

timeliness of child abuse and neglect investigations. In Oklahoma, for 

example, caseworkers and state officials noted that they believe their 

children are safer since the implementation of SACWIS simply because the 

information on the children is easily accessible to the caseworkers and 

their supervisors. According to our survey results, automated systems 

provided easier access to data and allowed caseworkers to better monitor 

children in their care, which may contribute to additional child welfare 

and administrative benefits, such as decreased incidences of child abuse 

and neglect, shortened length of time to achieve adoption, timeliness of 

payments to foster families, and timeliness of payments to foster facilities. 

Some of the data captured in case file records are reported to two HHS 

databases that compile child welfare data—AFCARS and NCANDS. We 

found that several factors affect states’ ability to collect and report reliable 

data to HHS on children served by state child welfare agencies. Almost all 

of the states responding to our survey25 reported that insufficient 

caseworker training and inaccurate and incomplete data entry into their 

information system affect the quality of AFCARS and NCANDS data. 

Although most states reported these as separate factors, HHS and the 

states we visited found that insufficient training and inaccurate and 

incomplete data entry are often linked. Caseworkers, supervisors, and 

managers in the five states that we visited reported that additional factors, 

such as difficulties balancing data entry with the time that they spend with 

the families and children, contributed to inaccurate or incomplete data 

entry. Supervisors in Iowa explained that since caseworkers are 

responsible for ensuring that children and their families receive the 

services they need, the caseworkers tend to initially limit data entry to the 

information that is necessary to ensure timely payment to foster care 

providers, and complete all other data elements when the caseworkers 

have time. In addition, caseworkers in Colorado said that they are between 

30 and 60 days behind in their data entry, so the information in the 

automated system may not accurately reflect the current circumstances of 

children in care. 

 25The analysis of survey responses about reporting data to HHS is based on responses from 

49 states and the District of Columbia. All states, regardless of SACWIS development, were 

asked to complete these questions. 
Page 15 GAO-04-418T 

We also reported in our July 2003 report and November 2003 testimony 

that many states experienced technical challenges reporting their data to 

HHS. The problems reported by states are typically a result of challenges 

associated with data “mapping”—matching state data elements to the 

federal data elements. For example, 36 states reported in our survey that 

matching their state-defined data to HHS’s definitions affected the quality 

of the data reported to NCANDS and AFCARS. In addition to the 

challenges reported in our survey, HHS reported that transferring data 

from older data systems into SACWIS affects the quality of the data 

reported to AFCARS and NCANDS. 

HHS plays a role in helping states implement their child welfare programs, 

but in some cases, additional federal oversight or technical assistance 

could help states provide more effective services. In terms of child welfare 

funding, HHS focuses its programmatic oversight on the overall child 

welfare system in each state and provides relatively little oversight specific 

to Title IV-B subpart 1. HHS’s role in assisting states overcome the child 

welfare workforce challenges is limited to partial federal reimbursement 

for training expenses and management of discretionary grant programs, 

such as the Child Welfare Training Program. HHS also monitors SACWIS 

development and data reporting and provides assistance to states to 

address some of the associated challenges; however, states reported 

ongoing challenges, such as the lack of clear and documented guidance on 

how to report child welfare data, despite the availability of this assistance. 

HHS focuses much of its programmatic oversight on the overall child 

welfare system in each state, rather than focusing specifically on subpart 1 

or any other federal funding source. A major component of HHS’s subpart 

1 oversight is having the regional offices actively work with states to 

develop appropriate goals for their child welfare systems and ensure that 

available funds are used to support those goals. To receive Title IV-B 

funding, HHS requires states to submit a Child and Family Services Plan, 

which covers a 5-year period and describes the state’s goals and objectives 

toward improving outcomes related to the safety, permanency, and wellbeing of children and families, as well as the services and programs the 

state will pursue to achieve these goals. In addition to the 5-year plan, HHS 

requires states to submit an update each year to discuss their progress in 

meeting the goals outlined in their plans. Some regional officials noted 

that states are still struggling to use these documents appropriately for 

planning purposes and frequently just describe their current programs, 

Improvements in 

HHS’S Oversight of 

Child Welfare 

Programs Could Help 

States Overcome 

Some Challenges 

HHS Focuses Oversight on 

the Overall Child Welfare 

System, but Has Limited 

Knowledge about States’ 

Use of Subpart 1 Funds 
Page 16 GAO-04-418T 

rather than focusing on outcomes and collecting data to measure progress 

toward those outcomes. 

The CFSR process is an additional tool HHS uses to ensure that states 

conform to federal child welfare requirements and to help states improve 

their child welfare services. Staff at one regional office described the 

CFSR as a thorough review of the services funded by different federal 

programs, such as Title IV-B, providing an opportunity to determine 

whether states are providing the services they report in their planning 

documents and whether those services are adequate and appropriate to 

meet the needs of the state’s children and families. When asked about 

HHS’s role in guiding states’ use of subpart 1 funds to address weaknesses 

identified by the CFSRs, an HHS official told us that the agency provides 

technical assistance to states to help them determine the most effective 

use of their resources, while giving states much latitude to determine the 

most appropriate use of their subpart 1 funds. 

HHS does not require states to provide any data about their use of subpart 

1 funds, such as their subpart 1 expenditures for specific services.26 As a 

result, several regional offices noted that they have no way of knowing 

how states actually spend their subpart 1 funds. Instead, HHS requires 

states to submit annual estimates of the amount of subpart 1, subpart 2, 

and other federal funds the state plans to spend in the upcoming year on 

different categories of services (such as family support or CPS). However, 

these estimates may not provide reliable data as to how states are using 

subpart 1 funds. HHS officials explained that states’ actual expenditures 

may vary from these estimates, as they address unforeseen circumstances. 

 26States are required to submit general reports on their total subpart 1 expenditures, but 

these provide no data on how the funds are actually used. Per instructions from the Office 

of Management and Budget, agencies must require states receiving federal grants to 

complete a financial status report (SF 269), providing general information on state 

expenditures. For example, the form might indicate that a state spent $10 million in subpart 

1 funds in a specific fiscal quarter, but it provides no details on how the $10 million was 

used. 
Page 17 GAO-04-418T 

In addition, HHS requires states to submit their estimates before the final 

spending amounts have been appropriated.27

The descriptions provided by regional office staff of their review of these 

estimates indicate that they review them for relatively limited purposes. As 

a result, most HHS regional offices do not review the annual estimates for 

compliance with the statutory limits. In addition, HHS’s annual program 

instruction, which details what information states must include in their 

estimates and serves as the basis for the regional offices’ review of subpart 

1 spending, does not mention the subpart 1 limits. Five regional offices 

were unaware that any limits on the use of subpart 1 funds existed. Four 

other regional offices were aware of the limits, but did not ensure that 

states complied with the limits. 

This lack of review led HHS to approve spending plans for 15 states that 

reported fiscal year 2002 planned subpart 1 expenditures for foster care 

maintenance and adoption assistance payments that exceeded the 

statutory limits.28 The dollar amounts by which the subpart 1 spending 

estimates surpassed the limits were small in some cases, but large in 

others. For example, Georgia reported that it planned to spend $1,497,000 

of subpart 1 funds for these purposes in 2002, which would exceed its 

statutory limit by $1,558. At the other extreme, Florida’s estimate indicated 

that it planned to spend over $9 million, which was more than $7 million 

over the maximum allowable spending of $1.9 million. In total, these 15 

states submitted planned subpart 1 spending estimates for foster care 

maintenance and adoption assistance payments that would exceed the 

statutory limits by over $30 million. 

 27HHS requires states to submit their annual estimates for the upcoming fiscal year on a 

form CFS-101. For example, for fiscal year 2002, the CFS-101 was due by June 30, 2001. 

Because they are submitted before final appropriations have been enacted, a state might 

not request the full amount of funds to which it is entitled, if the final appropriation is 

greater than the state’s initial estimate. States must submit a revised CFS-101 by June 30, 

2002, to request any additional fiscal year 2002 Title IV-B funds that might be available to 

them once appropriations are finalized. In addition, states can request additional Title IV-B 

funds if other states do not use the total funds to which they are entitled. 

28In most cases, we reviewed the final revised CFS-101 approved by HHS. For 1 state, 

however, we used the initial CFS-101 approved by HHS because it included planned 

subpart 1 expenditures that exceeded the limits for foster care and adoption assistance 

payments. Although the revised CFS-101 did not show that the state planned to exceed the 

limit, we used the initial CFS-101 to show that HHS had previously approved a spending 

plan that did not comply with the statutory limits. 
Page 18 GAO-04-418T 

Several regional offices said that they are not concerned about a state 

planning to spend significant proportions of its subpart 1 funds on foster 

care maintenance and adoption assistance payments if they believed the 

state had a strong child welfare system with an appropriate array of 

services. Regional office staff said that they would, however, ask a state to 

reconsider its funding strategy if the state were performing poorly. 

However, many of the states with approved subpart 1 estimates above the 

statutory ceilings did not achieve strong outcomes on their CFSR 

evaluations with regard to providing needed services and having an 

appropriate array of services. HHS has conducted CFSRs on 13 of the 15 

states with approved annual estimates over the subpart 1 spending limits 

and determined that appropriately assessing family needs and providing 

services to address those needs was an area needing improvement in 12 of 

the 13 states. In addition, 7 of the 13 states were also determined to need 

improvement in terms of having an appropriate array of services to meet 

the needs of families in the state.29

In discussing the current structure of Title IV-B, officials in all of HHS’s 

regional offices told us that they believe states need some flexibility to use 

Title IV-B funds to address state-specific child welfare needs as is 

currently the case under subpart 1. At the same time, officials in 8 of HHS’s 

10 regional offices also stressed the importance of subpart 2 to ensure that 

states use some funds on family support services and prevention activities 

to help preserve families and keep children from entering foster care. 

Several regional offices expressed concern that, in the absence of the 

minimum spending requirements outlined in subpart 2, states would 

neglect preventive services, while using Title IV-B funds for more urgent 

services, such as CPS or foster care. State and local child welfare officials 

in one state we visited, along with officials at 2 HHS regional offices, said 

that states need more federal funds to provide services to prevent foster 

care placements, such as an increase in funds available under Title IV-B or 

more flexibility to use Title IV-E funds to provide services. HHS is 

currently developing a legislative proposal to give states more flexibility in 

using Title IV-E foster care funds for such preventive services.30

 29Ten of the 13 states were also cited as needing improvement in ensuring that needed 

services are accessible to families in all areas of the state and 9 of the 13 states were 

categorized as needing improvement in terms of individualizing services to meet the unique 

needs of individual families. 

30Under this new proposal, states could voluntarily choose to receive a fixed IV-E foster 

care allocation, which could be used for any services provided under Titles IV-B and IV-E. 
Page 19 GAO-04-418T 

HHS’s primary connection to the child welfare workforce has been 

through partial federal reimbursement—75 percent—of states’ training 

funds to implement educational programs for current child welfare staff 

and to enhance the child welfare curriculum of undergraduate and 

graduate social work programs to better educate and prepare potential 

caseworkers.31 This funding may also be used for curriculum development, 

materials and books, support for current workers to obtain a social work 

degree, and incentives to induce entry to the child welfare field. During 

fiscal year 2002, 49 states received $286 million in title IV-E training 

reimbursements.32 These reimbursements ranged from a low of 

approximately $10,400 in Alaska to a high of more than $79 million in 

California, with the median reimbursement approximating $2.7 million. 

In addition, ACF’s Children’s Bureau manages six discretionary grant 

programs through which it funds various activities related to 

improvements in the child welfare system. One of these programs—the 

Child Welfare Training Program, authorized by Section 426 of Title IV of 

the Social Security Act—awards grants to public and private nonprofit 

institutions of higher learning to develop and improve the education, 

training, and resources available for child welfare service providers.33 This 

is the only program of the six with a specific emphasis on staff training;34

however, in fiscal year 2003, it received the second smallest share—8 

percent—of the Children’s Bureau’s total discretionary funds. 

According to HHS officials, HHS has no authority to require states to 

address caseload issues in their CFSR-related program improvement plans 

or to enforce any caseload standards. Furthermore, HHS officials said that 

states have made few requests of HHS’s national resource centers for 

assistance with child welfare staff recruitment and retention. Although 

 31As authorized under Title IV-E of the Social Security Act, the federal government 

reimburses 75 percent of states’ training expenditures related to foster care and adoption 

services. States providing training for contracted private agency staff can receive 50 

percent federal reimbursement for this purpose. 

32Fiscal year 2002 data are the most recent data available at the time of this testimony. The 

District of Columbia, Massachusetts, and Puerto Rico have not participated in title IV-E 

reimbursements for the last three fiscal years. 

33In fiscal year 2003, among other child welfare training project activities, HHS awarded 

grants to eight recipients for developing models of effective child welfare staff recruitment 

and retention training. 

34Although the other discretionary grant programs fund initiatives that can involve 

caseworker training, caseworker training and development is not their primary focus. 

HHS’s Involvement with 

States’ Child Welfare 

Workforce Is Limited 
Page 20 GAO-04-418T 

HHS officials told us that they plan to examine the CFSRs to better 

understand the relationship between recruitment and retention and safety 

and permanency outcomes across the states, the agency is still conducting 

these reviews and is not expected to complete them until March 2004. 

In response to some of the challenges states face in developing SACWIS 

and collecting and reporting child welfare data, HHS has conducted on-site 

reviews of information systems and provided technical assistance from a 

variety of sources. For example, at the time of our review, HHS had 

conducted on-site reviews in 26 states with operational SACWIS to ensure 

that the systems met all federal requirements and to offer assistance to 

states that faced challenges completing the development of their SACWIS. 

Few systems have been determined complete after an on-site review 

because of unresolved issues, such as not being able to build links to other 

state information systems or not implementing certain eligibility 

determination functions. To help states address some of these 

development challenges, the SACWIS review team provides the state with 

recommendations for complying with SACWIS requirements and 

schedules a conference call with the state officials to walk through the 

system’s deficiencies and offer guidance on how the state can move 

forward. In addition, in an attempt to help states comply with the 

reporting standards and address some of the factors that contribute to 

data quality problems, HHS performs comprehensive reviews of state 

information systems’ ability to capture AFCARS data to identify problems 

associated with data collection and reporting and to ensure that the 

information in the automated system correctly reflects children’s 

experiences in care. 

Other technical assistance is available to states in a variety of formats. 

HHS facilitates the sharing of information between states developing 

SACWIS through an automated system users’ group that allows state and 

federal officials to exchange information, ideas, and concerns. In addition 

to the users’ group, HHS officials sponsor a Listserv—an electronic 

mailing list—that allows state officials to exchange information, a monthly 

conference call with state information technology directors,35 an annual 

technical assistance meeting, and an NCANDS state advisory group. The 

 35In commenting on a draft of the July 2003 report, HHS indicated that a Web resource is 

available to states interested in learning about other states’ efforts to develop human 

services—child welfare, food stamps, Temporary Assistance to Needy Families, child care, 

and child support enforcement—information systems at http://www.acf.hhs.gov/nhsitrc. 

HHS Offers Assistance to 

Help States Develop 

SACWIS and Improve 

Their Data, but States 

Report Ongoing 

Challenges with Some of 

HHS’s Efforts 
Page 21 GAO-04-418T 

National Resource Center for Information Technology in Child Welfare, 

which opened in 1999, also provides assistance to states on SACWIS 

development and data issues. 

HHS has also made available to states the software it uses to examine 

states’ AFCARS and NCANDS submissions for inconsistencies and invalid 

data. Officials in all the states that we visited said that they regularly use 

this software, and an HHS official said that nearly every state has used the 

software at least once. HHS officials reported that these tests help them to 

identify some data quality errors, such as missing data, and said that they 

believe that, in general, data have improved in recent years. However, the 

officials indicated that the tests cannot pinpoint the underlying problems 

contributing to these errors. Furthermore, one official reported that no 

specific efforts have been conducted to track the individual data elements 

and, therefore, HHS cannot report on how data quality has changed over 

time. 

Although the states we visited appreciated some of HHS’s efforts to assist 

with improving state data quality, they and most states responding to our 

survey agreed that the assistance is not always consistent or easily 

accessible. The primary concerns reported by the states we visited were 

delays in receiving clear written guidance on defining and reporting 

certain data elements and the lack of state input in suggesting changes to 

AFCARS. Despite the written guidance available to states in the form of 

regulations and an online policy manual, states reported that the variation 

in state policies and practices makes it difficult to interpret how to apply 

the general guidance. As a result, states consult with HHS to ensure they 

are applying the regulations appropriately. However, in commenting on a 

draft of the July 2003 report, officials in Oklahoma told us that a common 

concern among the states is the lack of timely response from HHS when 

seeking guidance on how to report data. In commenting on a draft of the 

same report, HHS explained that it first refers states to its Web site for 

information and believes that the available guidance addresses states’ 

concerns in most instances. In addition, the states that have had an 

AFCARS review experienced delays in obtaining guidance on how to 

proceed following the on-site review. An HHS official told us that since the 

review process is relatively new, the agency is still developing a process to 

respond to the states and recognizes that it has not been responsive to the 

states already reviewed. In addition, HHS is taking steps to gather 

feedback from states and other users of AFCARS data to determine how to 

improve the system to make the data more accurate and usable. As a part 

of these efforts, HHS has published a Federal Register notice soliciting 

comments and held focus group meetings at national conferences. The 
Page 22 GAO-04-418T 

difficulties states face in receiving federal guidance and assistance, as well 

as the other challenges they face in reporting data, may negatively affect 

the reliability of the data available in AFCARS and NCANDS. 

Despite its relatively small funding level compared to other funding 

sources for child welfare services, Title IV-B represents an important 

federal commitment to states’ efforts to protect children from abuse and 

neglect. However, HHS does not provide in-depth oversight specific to 

Title IV-B subpart 1. Two key issues further compound states’ ability to 

prevent abuse and neglect. For example, given the difficulties that public 

and private child welfare agencies are experiencing in hiring, training, and 

retaining their workforces, these agencies’ ability to provide services to 

children is threatened. In addition, states face challenges in completing 

their SACWIS systems and in ensuring that caseworkers input complete 

and accurate case data in a timely manner. 

We recommended in our September 2003 report on Title IV-B that the 

Secretary of HHS provide the necessary guidance to ensure that HHS 

regional offices monitor states’ use of Title IV-B subpart 1 funds for 

compliance with statutory restrictions on the use of these funds. We also 

recommended that the Secretary consider the feasibility of collecting basic 

data on states’ use of these funds to facilitate its oversight of the program 

and to provide guidance to help states determine appropriate services to 

fund. In commenting on a draft of that report, HHS agreed with our first 

recommendation but noted that the statutory limitations on Title IV-B 

funds no longer serve a useful purpose and are incompatible with its 

current proposal to offer states much more flexibility in using other 

federal child welfare dollars. HHS disagreed with our second 

recommendation, stating that it believes that its level of oversight is 

commensurate with the scope and intent of the program and minimizes 

states’ reporting requirements. 

We recommended in our March 2003 report on child welfare worker 

recruitment and retention that, because of the reported impact staffing 

shortages and high caseloads have on the attainment of federal outcome 

measures, that the Secretary of HHS take actions that may help child 

welfare agencies address the recruitment and retention challenges they 

face. In commenting on a draft of that report, HHS generally agreed with 

our findings and concurred with our recommendation, saying that it has 

begun to explore the effectiveness of child welfare training programs, with 

an emphasis on lessons learned and best practices. However, HHS 

stressed that it has no authority to require states to address caseload 

Concluding 

Observations 
Page 23 GAO-04-418T 

issues in their CFSR program improvement plans or to enforce any 

caseload standard. 

To improve the reliability of state-reported child welfare data, we 

recommended in our July 2003 SACWIS report that the Secretary of HHS 

consider, in addition to HHS’s recent efforts to improve AFCARS data, 

ways to enhance the guidance and assistance offered to states to help 

them overcome the key challenges in collecting and reporting child 

welfare data. HHS generally agreed with our findings and, in response to 

our recommendation, noted that the data definitions need to be updated 

and revised and said it is currently in the process of revising the AFCARS 

regulations to further standardize the information states are to report. 

More recently, HHS said that it would be creating policy guidance that will 

delineate what will happen if a state fails to complete its SACWIS within a 

reasonable time frame. 

Mr. Chairman, this concludes my prepared statement. I would be pleased 

to respond to any questions that you or other members of the 

Subcommittee may have. 

For further information regarding this testimony, please call Cornelia M. 

Ashby at (202) 512-8403. Individuals making key contributions to this 

testimony include Diana Pietrowiak, Joy Gambino, Sara Schibanoff, and 

Michelle St. Pierre. 

GAO Contact and 

Acknowledgments 
Page 24 GAO-04-418T 

Table 1: Fiscal Year 2002 Expenditures for Subparts 1 and 2 Service Categories 

Subpart 1 Subpart 2 

Service category 

Number of 

states 

Amount of 

subpart 1 

fundinga

Percentage of 

subpart 1 funding

Number of 

states 

Amount of 

subpart 2 

fundinga

Percentage of 

subpart 2 

fundingb

Staff positions 25 $70,965,578 27.6 17 $6,229,058 2.4 

Administration and 

management 

16 43,143,097 16.8 18 11,614,667 4.5 

Child protective 

services 

17 40,543,000 15.8 5 2,248,690 0.9 

Foster care 

maintenance payments 

17 27,890,783 10.8 2 647,154 0.3 

Multiple responsesc 8 25,806,347 10.0 4 3,503,585 1.4 

Family 

support/prevention 

17 19,840,891 7.7 28 127,430,496 49.8 

Counseling and mental 

health services 

2 8,350,562 3.2 5 1,354,763 0.5 

Family preservation 7 5,986,045 2.3 23 30,308,896 11.8 

Adoption subsidy 

payments 

7 4,657,546 1.8 2 737,412 0.3 

Family reunification 4 2,446,570 1.0 26 23,625,973 9.2 

Recruitment and 

training for 

foster/adoptive parents 

9 2,260,061 0.9 16 6,828,885 2.7 

Adoption support and 

preservation services 

2 446,877 0.2 27 28,481,585 11.1 

Other 11 4,817,180 1.9 15 12,795,915 5.0 

Totald $257,154,537 100.0 $255,807,079 100.0 

Source: GAO survey. 

Notes: Percentages do not always total to 100 due to rounding. 

Data on subpart 1 expenditures are based on survey responses from 46 states and data on subpart 2 

expenditures are based on survey responses from 44 states. While Pennsylvania responded to our 

survey, it did not provide expenditure data for subparts 1 or 2. 

a

When providing data for our survey, states were asked to indicate the single service category that 

best described the type of program funded by subparts 1 and 2. Thus, programs that fall into multiple 

service categories may not be fully captured. For example, one state indicated it funded a family 

support program, which includes some family preservation and reunification services. In addition, 

states may not have been consistent in categorizing services. For example, several HHS officials told 

us that the delineation between family support and family preservation services is not clear, so that 

two states providing the same services to the same types of families may report them in different 

categories. Inconsistencies such as these could have an effect on any measured differences among 

service categories. 

Appendix I: Subparts 1 and 2 Expenditures 
Page 25 GAO-04-418T 

b

States may spend less than 20 percent of their subpart 2 funds on any of the required service 

categories if they have a strong rationale. Some HHS regional officials said that they approve 

exceptions to the 20 percent requirement if a state is spending a significant amount of nonfederal 

funds on a subpart 2 service category. 

c

Although states were asked to indicate the single service category that best described the type of 

program funded by subparts 1 and 2, several states selected multiple program categories when 

responding to our survey. For example, Rhode Island reported that it funded a home visitation 

program and indicated that this program includes family support, health, and family reunification 

services. Thus, the responses from states that reported multiple categories for a program are 

represented by this category. 

d

The aggregate dollars reported in the service categories do not match the total allocations for 

subparts 1 and 2 in fiscal year 2002. States have 2 years to spend their Title IV-B allocations; as a 

result, expenditures in fiscal year 2002 may include dollars from a state’s fiscal year 2001 Title IV-B 

allocation, as well as its fiscal year 2002 Title IV-B allocation. Similarly, some fiscal year 2002 

allocations may not have been spent until fiscal year 2003. 
Page 26 GAO-04-418T 

D.C. Family Court: Progress Has Been Made in Implementing Its 

Transition. GAO-04-234. Washington, D.C.: January 6, 2004. 

Child Welfare: States Face Challenges in Developing Information 

Systems and Reporting Reliable Child Welfare Data. GAO-04-267T. 

Washington, D.C.: November 19, 2003. 

Child Welfare: Enhanced Federal Oversight of Title IV-B Could Provide 

States Additional Information to Improve Services. GAO-03-956. 

Washington, D.C.: September 12, 2003. 

Child Welfare: Most StatesAre Developing Statewide Information 

Systems, but the Reliability of Child Welfare Data Could be Improved. 

GAO-03-809. Washington, D.C.: July 31, 2003. 

D.C. Child and Family Services: Key Issues Affecting the Management of 

Its Foster Care Cases. GAO-03-758T. Washington, D.C.: May 16, 2003. 

Child Welfare and Juvenile Justice: Federal Agencies Could Play a 

Stronger Role in Helping States Reduce the Number of Children Placed 

Solely to Obtain Mental Health Services. GAO-03-397. Washington, D.C.: 

April 21, 2003. 

Foster Care: States Focusing on Finding Permanent Homes for Children, 

but Long-Standing Barriers Remain. GAO-03-626T. Washington, D.C.: 

April 8, 2003. 

Child Welfare: HHS Could Play a Greater Role in Helping Child Welfare 

Agencies Recruit and Retain Staff. GAO-03-357. Washington, D.C.: March 

31, 2003. 

Foster Care: Recent Legislation Helps States Focus on Finding 

Permanent Homes for Children, but Long-Standing Barriers Remain. 

GAO-02-585. Washington, D.C.: June 28, 2002. 

District of Columbia Child Welfare: Long-Term Challenges to Ensuring 

Children’s Well-Being. GAO-01-191. Washington, D.C.: December 29, 2000. 

Child Welfare: New Financing and Service Strategies Hold Promise, but 

Effects Unknown. GAO/T-HEHS-00-158. Washington, D.C.: July 20, 2000. 

Foster Care: States’ Early Experiences Implementing the Adoption and 

Safe Families Act. GAO/HEHS-00-1. Washington, D.C.: December 22, 1999. 

Related GAO Products 
Page 27 GAO-04-418T 

Foster Care: HHS Could Better Facilitate the Interjurisdictional 

Adoption Process. GAO/HEHS-00-12. Washington, D.C.: November 19, 

1999. 

Foster Care: Effectiveness of Independent Living Services Unknown. 

GAO/HEHS-00-13. Washington, D.C.: November 5, 1999. 

Foster Care: Kinship Care Quality and Permanency Issues. GAO/HEHS99-32. Washington, D.C.: May 6, 1999. 

Juvenile Courts: Reforms Aim to Better Serve Maltreated 

Children. GAO/HEHS-99-13. Washington, D.C.: January 11, 1999. 

Child Welfare: Early Experiences Implementing a Managed Care 

Approach. GAO/HEHS-99-8. Washington, D.C.: October 21, 1998. 

Foster Care: Agencies Face Challenges Securing Stable Homes for 

Children of Substance Abusers. GAO/HEHS-98-182. Washington, D.C.: 

September 30, 1998. 

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