a

GAO

United States General Accounting Office

Report to the Chairman, Committee on 

Government Reform, U.S. House of 

Representatives

May 2003 D.C. CHILD AND 

FAMILY SERVICES

Better Policy 

Implementation and 

Documentation of 

Related Activities 

Would Help Improve 

Performance

GAO-03-646
CFSA’s performance relative to three sets of measures—nine ASFA 

requirements, eight selected performance criteria and six of the agency’s foster 

care policies—has been mixed. The agency took actions to implement six of the 

nine ASFA requirements related to the safety and well-being of foster children 

and met or exceeded four of the eight selected foster care performance criteria, 

but its plans did not address all requirements not fully implemented and unmet 

performance criteria. CSFA has established many foster care policies, but 

caseworkers did not consistently implement the six GAO examined. In addition, 

FACES lacked data related to four of the policies reviewed for at least 70 

percent of its active foster care cases. The following table summarizes the 

percentage of cases for which the data indicated the policy was implemented. 

Implementation of Selected CFSA Foster Care Policies as Documented in FACES 

CFSA policy

Foster care cases for which 

the policy was implementeda, b

 

Initiate face-to-face investigation of alleged child abuse or 

neglect within 24 hours of receiving an allegation on CFSA’s 

child abuse hotline. 26%

Complete a safety assessment within 24 hours of face-to-face 

contact with the child. 13%

Complete a risk assessment within 30 days of receiving an 

allegation on the hotline. 73%

Complete an initial case plan within 30 days of a child’s entry 

into foster care. 9%

Arrange needed services for foster care children or their 

families. 83%

Source: FACES and GAO analysis. 

a

With the exception of the policy to arrange needed services, the analysis is based on 943 foster 

care cases that were at least 6 months old, as of Nov. 30, 2002. These cases were initiated after 

FACES came on-line in Oct. 1999. The analysis of the policy to arrange for needed services is 

based on 1,837 foster care cases and includes cases that pre-dated FACES but for which services 

were provided after FACES came on-line. Data show the percentage of cases for which 

caseworkers arranged at least one service. 

b

CFSA counted cases that had missing data as instances of caseworker noncompliance with the 

applicable policy. 

CFSA has enhanced its working relationship with the D.C. Family Court, but 

several factors hindered this relationship. For example, CFSA’s top 

management and Family Court judges talk frequently about foster care case 

issues. However, differing opinions among CFSA caseworkers and judges 

about their responsibilities have hindered the relationships. CFSA officials 

and Family Court judges have been working together to address these 

hindrances. 

The District of Columbia (D.C.) 

Child and Family Services Agency 

(CFSA) is responsible for 

protecting children at risk of abuse 

and neglect and ensuring that 

services are provided for them and 

their families. GAO was asked to 

discuss the extent to which CFSA 

has (1) met requirements of the 

Adoption and Safe Families Act 

(ASFA) of 1997 and other selected 

performance criteria, (2) adopted 

and implemented child protection 

and foster care placement policies, 

and (3) enhanced its working 

relationship with the D.C. Family 

Court. 

To address these questions, GAO 

analyzed data from CFSA’s child 

welfare information system, known 

as FACES; reviewed laws, 

regulations, and reports; examined 

case files; and interviewed officials. 

To improve CFSA’s performance 

GAO recommends that the Mayor 

require the Director of CFSA to (1) 

develop plans to fully implement all 

ASFA requirements, (2) establish 

procedures to ensure caseworkers 

consistently implement all foster 

care policies, and (3) document in 

FACES all activities related to 

active foster care cases. 

In commenting on the draft, the 

Director of CFSA generally agreed 

with our findings. Although she did 

not directly address the 

recommendations, she generally 

agreed with the areas we identified 

for continued improvement. 

D.C. CHILD AND FAMILY SERVICES

Better Policy Implementation and 

Documentation of Related Activities 

Would Help Improve Performance 

www.gao.gov/cgi-bin/getrpt?GAO-03-646.

To view the full report, 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-03-646, a report to the 

Chairman, Committee on Government 

Reform, House of Representatives 

May 2003
Page i GAO-03-646 D.C. Child and Family Services 

Letter 1

Results in Brief 3

Background 5

CFSA Undertook Actions to Implement Most ASFA Requirements 

Reviewed and Met Half of the Selected Performance Criteria for 

Child Safety and Well-Being 9

CFSA Has Established Many Foster Care Policies but Lacks Others, 

and the Extent of Implementation and Documentation Varies 15

CFSA Has Enhanced Its Working Relationship with the D.C. Family 

Court by Working Collaboratively, but Hindrances Remain 22

Conclusions 23

Recommendations 23

Agency Comments and Our Evaluation 24

Appendix I Scope and Methodology 26 

Appendix II Comments from the Director of the Child andFamily 

Services Agency 28 

Appendix III GAO Contacts and Acknowledgments 32 

GAO Contacts 32

Acknowledgments 32

Related GAO Products 33 

Tables 

Table 1: CFSA’s Progress in Implementing Nine ASFA 

Requirements 10

Table 2: Analysis of Selected Foster Care Performance Criteria 12

Table 3: Implementation of Selected CFSA Foster Care Policies as 

Documented in FACES 16

Table 4: Number of Cases Taking 5 or More Days to Implement 

Policy (2000-2002) 17

Contents 
Page ii GAO-03-646 D.C. Child and Family Services 

Figure 

Figure 1: CFSA Responsibilities Related to Permanency Goals 8

Abbreviations 

ASFA Adoption and Safe Families Act 

CFSA Child and Family Services Agency 

HHS U.S. Department of Health and Human Services 

OCC Office of Corporation Counsel 

SACWIS Statewide Automated Child Welfare Information System 

TPR Termination of Parental Rights 

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Page 1 GAO-03-646 D.C. Child and Family Services 

May 27, 2003 

The Honorable Tom Davis 

Chairman 

Committee on Government Reform 

House of Representatives 

Dear Mr. Chairman: 

The District of Columbia’s Child and Family Services Agency (CFSA) is 

responsible for protecting foster care children who have been at risk of 

abuse and neglect and ensuring that critical services are provided to them 

and their families. In 2002, CFSA had about 3,000 children in foster care. As 

a result of a history of poor performance, the U.S. District Court for the 

District of Columbia placed CFSA in receivership in 1995.1

 To help 

improve its performance during receivership, CFSA made several changes, 

including establishing an automated case management system, FACES. In 

2000, the District Court issued a consent order establishing a process by 

which the agency’s receivership could be terminated. The order also 

established a probationary period, which would begin when the 

receivership ended and identified performance criteria CFSA had to meet 

in order to end the probationary period. In April 2001, CFSA became a 

cabinet-level agency within the government of the District of Columbia, in 

June 2001 the court removed CFSA from receivership, and in October 2001 

responsibility for child abuse investigations was transferred from the 

District’s Metropolitan Police Department to CFSA. Additionally, new 

legislation established requirements that CFSA had to meet. The Adoption 

and Safe Families Act (ASFA) of 1997 mandated that all child welfare 

agencies achieve timely placement of children in permanent homes. The 

U.S. Department of Health and Human Services (HHS) is responsible for 

setting standards and monitoring the nation’s child welfare programs, 

including assessing compliance with ASFA requirements through its Child 

 1

The receivership was an arrangement in which the court appointed a person to 

temporarily manage the agency with broad authority to ensure full compliance with the 

court order in an expeditious manner. 

United States General Accounting Office

Washington, DC 20548 
Page 2 GAO-03-646 D.C. Child and Family Services 

and Family Services Reviews. 2 In addition, the District of Columbia Family 

Court Act of 2001 required CFSA to work closely with the Family Division 

of the D.C. Superior Court and the District’s Office of Corporation Counsel 

(OCC).3 In September 2002, the court-appointed monitor reported that a 

child was abused by two children in a group home licensed by CFSA. 

According to the monitor, this incident, together with the history of 

inadequate care and attention given this child by CFSA, indicated that its 

operations and policies, especially those regarding foster care cases, may 

still need improvement. 

You asked us to address the following questions: (1) To what extent did 

CFSA address the requirements of the Adoption and Safe Families Act of 

1997 and meet selected foster care performance criteria and what plans 

does it have to address unmet requirements and criteria? (2) To what 

extent has CFSA adopted and implemented foster care policies that are 

comparable to those generally accepted in the child welfare community, 

and how has implementation affected foster care children? (3) What has 

CFSA done to enhance its working relationship with the D.C. Family Court 

and what factors have affected these efforts? 

To address these questions, we selected three sets of measures to assess 

CFSA’s performance. First, we examined CFSA’s progress in implementing 

nine ASFA requirements that were related to the safety and well-being of 

foster children. Second, we assessed the extent to which CFSA met or 

exceeded eight selected performance criteria established during its 

probationary period. Third, we assessed the extent to which caseworkers 

implemented six foster care policies related to their day-to-day 

responsibilities. We analyzed data in the District’s automated child welfare 

information system, known as FACES; reviewed laws, regulations, and 

 2

Child and Family Services Reviews, conducted by HHS, cover a range of child and family 

service programs funded by the federal government, including child protective services, 

foster care, adoption, independent living, and family support and preservation services. The 

2001 review evaluated seven specific safety, permanency, and well-being outcomes for 

services delivered to children and families served by CFSA. As part of its review, HHS 

randomly selected 50 active child welfare cases from the period between April 2000 and 

July 2001. 

3

The District of Columbia Family Court Act of 2001 (P.L. 107-114), established the Family 

Court as part of the D.C. Superior Court. The Family Court replaced the Family Division of 

the D.C. Superior Court. Among other responsibilities, the Family Court handles child 

abuse and neglect cases, court hearings, and other proceedings for the District’s foster 

children and their families. OCC, among its other responsibilities, provides legal support to 

CFSA on foster care cases. 
Page 3 GAO-03-646 D.C. Child and Family Services 

reports; examined case files; and interviewed officials. We obtained and 

analyzed automated data from FACES on all foster care cases that were at 

least 6 months old as of November 30, 2002. We selected ASFA 

requirements and CFSA policies directly related to the safety and wellbeing of foster children. We selected foster care performance criteria from 

among those CFSA had to meet in order to end the probationary period 

that, in our judgment, most directly related to the safety and permanent 

placement of children in foster care. We reviewed federal and local laws, 

regulations, foster care policies recommended by various organizations, 

and reports on CFSA’s implementation of the District’s foster care 

program and selected CFSA policies that covered several key foster care 

management functions. We included HHS’s evaluation of how CFSA 

implemented ASFA requirements in our assessment of the agency’s 

performance. We independently verified the reliability of data in FACES; 

however, CFSA had not entered into FACES detailed information on the 

data elements we needed for our analysis with respect to about two-thirds 

of the District’s active foster care cases—mostly cases that originated 

prior to FACES going on-line in October 1999. To obtain information on 

policy implementation, we also examined foster care case files. We 

interviewed CFSA executives, managers, and supervisors; Family Court 

judges, attorneys from OCC; and officials from organizations that 

recommend policies applicable to child welfare programs. We conducted 

our work between September 2002 and May 2003 in accordance with 

generally accepted government auditing standards. See appendix I for 

additional information on our scope and methodology. 

CFSA undertook actions to implement six of nine ASFA requirements 

directly related to the safety and well-being of foster care children and met 

or exceeded four of eight selected foster care performance criteria, but its 

plans do not address all requirements that were not fully implemented and 

selected performance criteria that were not met. For example, CFSA 

signed an interim border agreement to help achieve timelier placement of 

District children in Maryland, which addresses ASFA’s requirement to use 

cross-jurisdictional resources to facilitate timely adoptive or permanent 

placements for waiting children. However, HHS’s review of the District 

found that CFSA did not fully implement ASFA’s requirements to initiate 

or join proceedings to terminate the rights of parents whose children are 

in foster care, conduct annual hearings to review permanency goals for 

children every 12 months, and provide participants a notice of reviews and 

hearings. The selected foster care performance criteria CFSA met or 

exceeded included the criteria that prohibit leaving children in emergency 

care for more than 90 days and that require placing children in foster care 

Results in Brief 
Page 4 GAO-03-646 D.C. Child and Family Services 

with one or more of their siblings. The criteria that CFSA did not meet 

included the requirements regarding the frequency of caseworker visits 

with children in foster care and the minimum percentage of foster care 

children that must be placed in foster homes with valid licenses. CFSA has 

written plans that address most of the unmet ASFA requirements and 

selected performance criteria. The unmet requirements and performance 

criteria not addressed in the plans are those related to providing timely 

notification of all reviews and hearings to families with children in foster 

care and to reducing the number of children in foster care who, for 

18 months or more, have had a permanency goal to return home. Agency 

officials cited staffing shortages and external demands, such as 

coordinating work with other agencies, as factors that hindered the 

agency’s ability to fully meet the ASFA requirements and performance 

criteria. However, unless these requirements and criteria are met a child’s 

safety may be jeopardized, the time a child spends in foster care may be 

prolonged, or the best decisions regarding a child’s future well-being may 

not be reached. 

While CSFA has adopted many foster care policies similar to those 

recommended for child welfare programs, caseworkers did not 

consistently implement the six we examined, potentially leaving children 

subject to continued abuse or neglect or delaying efforts to achieve 

permanent and safe placements. In those cases for which data were 

available, we found that the extent to which CFSA implemented selected 

foster care policies varied. For example, caseworkers implemented the 

policy requiring initial case plans to be completed within 30 days of a 

child’s entry into foster care in 9 percent of the cases, and they 

implemented the policy that children and their families receive needed 

services in 83 percent of the cases. While timeframes for initiating 

investigations and completing safety assessments improved between 

2000 and 2002, caseworkers still took considerably longer than the 

prescribed time limits to complete these tasks. Caseworkers and managers 

said that the policies were not always implemented because of limited 

staff and competing demands, such as making visits to children or 

participating in court proceedings. In addition, CFSA’s automated system 

lacked data on four of the six policies for at least 70 percent of its active 

foster care cases. Complete, accurate, and timely case management data 

enables caseworkers to quickly learn about new cases, supervisors to 

know the extent to which caseworkers are completing their tasks, and 

managers to know whether any aspects of the agency’s operations are in 

need of improvement. Without information on all cases, caseworkers do 

not have a readily available summary of the child’s history, which may be 

critical to know when making plans about the child’s care. Additionally, 
Page 5 GAO-03-646 D.C. Child and Family Services 

without information on all cases, managers do not have information 

needed to assess program operations and make improvements, if needed. 

CFSA has enhanced its working relationship with the D.C. Family Court by 

working more collaboratively, and several factors have strengthened or 

hindered these relationships. For example, CFSA, the Family Court, and 

other District agencies have participated on various committees to address 

interagency operations affecting children and families served by CFSA and 

involved in cases before the court. In addition, since 2002, attorneys from 

OCC have been located at CFSA and work closely with caseworkers to 

help them prepare for court appearances. Support from top CFSA 

management and Family Court judges has been a key factor in improving 

these relationships. However, CFSA officials and Family Court judges 

noted several hindrances that constrain CFSA’s efforts to enhance its 

working relationship with the Family Court. These hindrances include the 

need for caseworkers to balance court appearances with other case 

management responsibilities, an insufficient number of caseworkers, 

caseworkers who are unfamiliar with cases that have been transferred to 

them, and differing opinions about the responsibilities of CFSA 

caseworkers and judges. 

To improve CFSA’s management of the foster care program and outcomes 

for children in the District of Columbia, we recommend that the Mayor 

require the Director of CFSA to (1) develop plans to fully implement all 

unmet ASFA requirements, (2) establish procedures to ensure that 

caseworkers consistently implement all foster care policies, and 

(3) document in FACES all events related to active foster care cases. 

The Director of CFSA, on behalf of the District’s Deputy Mayor for 

Children, Youth, Families, and Elders provided written comments on a 

draft of this report. In commenting on the draft, the Director generally 

agreed with our findings. Although the CFSA Director did not directly 

address the recommendations, she generally agreed with the areas we 

identified for continued improvement. Additionally, she suggested several 

changes to help clarify the report, which we incorporated as appropriate. 

The comments are discussed in the report and are shown in appendix II. 

While CFSA is responsible for protecting thousands of foster care 

children, many children in CFSA’s care languished for extended periods of 

time due to managerial shortcomings and long-standing organizational 

divisiveness in the District of Columbia. As a result of these deficiencies, 

the U.S. District Court for the District of Columbia issued a remedial order 

in 1991 to improve the performance of the agency. Under a modified final 

Background 
Page 6 GAO-03-646 D.C. Child and Family Services 

order established by the court in 1993, CFSA was directed to comply with 

many requirements. In 1995, lacking sufficient evidence of program 

improvement, the agency was removed from the District’s Department of 

Human Services and placed in receivership. Among its efforts to improve 

agency performance, CFSA established an automated system, FACES, to 

manage its caseload. The District Court issued a consent order in 2000 

establishing a process by which the agency’s receivership could be ended. 

The order also established a probationary period, which began when the 

receivership ended, and identified performance standards CFSA had to 

meet in order to end the probationary period. The court-appointed 

monitor, the Center for the Study of Social Policy, was to assess CFSA’s 

performance and had discretion to modify the performance standards. In 

April 2001, CFSA became a cabinet-level agency within the government of 

the District of Columbia. In June 2001, the court removed CFSA from the 

receivership and its probationary period began. In October 2001, 

responsibility for child abuse investigations was transferred to CFSA from 

the District’s Metropolitan Police Department. CFSA’s probationary period 

ended in January 2003. 

However, in September 2002, the court-appointed monitor reported that a 

7-year old boy was abused by two children in a group home that CFSA had 

licensed to provide care for 9-21 year olds. The report also identified 

several actions CFSA took or failed to take and concluded that the child 

was not adequately protected or served by CFSA. For example, contrary to 

its policies, CFSA did not place the child with his sibling, and there was no 

evidence that CFSA assessed his social, emotional, or behavioral needs. 

According to the court-appointed monitor, these events indicated that 

CFSA’s operations and policies may still need improvement. 

CFSA operates in a complex child welfare system.4

 Several federal laws, 

local laws, and regulations established goals and processes under which 

CFSA must operate. ASFA, with one of its goals to place children in 

permanent homes in a timelier manner, placed new responsibilities on all 

child welfare agencies nationwide. ASFA introduced new time periods for 

moving children toward permanent, stable care arrangements and 

established penalties for noncompliance. For example, ASFA requires 

child welfare agencies to hold a permanency planning hearing—during 

which the court determines the future plans for a child, such as whether 

 4

We issued several reports that addressed CFSA operations and program plans. For more 

information, see related GAO products at the end of this report. 
Page 7 GAO-03-646 D.C. Child and Family Services 

the state should continue to pursue reunification with the child’s family or 

some other permanency goal—not later than 12 months after the child 

enters foster care. The District of Columbia Family Court Act of 2001 

established the District’s Family Court and placed several requirements on 

the District’s Mayor and various District government agencies, including 

CFSA and OCC. The District of Columbia Family Court Act requires the 

Mayor, in consultation with the Chief Judge of the Superior Court, to 

ensure that CFSA and other District government agencies coordinate the 

provision of social services and other related services to individuals 

served by the Family Court. 

CFSA relies on services provided by other District government agencies. 

For example, both the Fire Department and the Health Department inspect 

facilities where children are placed, and D.C. Public Schools prepare 

individual education plans for some foster care children. CFSA also works 

with agencies in Maryland, Virginia, and other states to arrange for 

placements of District children and also works with private agencies to 

place children in foster and adoptive homes. In addition, CFSA is 

responsible for licensing and monitoring organizations with which it 

contracts, including group homes that house foster care children. 

The management of foster care cases involves several critical steps 

required by CFSA policy. (See fig. 1.) Typically, these cases begin with an 

allegation of abuse or neglect reported to the CFSA child abuse hot line. 

CFSA staff are required to investigate the allegations through direct 

contact with the reported victim. If required, the child may be removed 

from his or her home, necessitating various court proceedings handled by 

the District’s Family Court. CFSA caseworkers are responsible for 

managing foster care cases by developing case plans; visiting the children; 

participating in administrative review hearings involving CFSA officials, 

children, parents, and other officials; attending court hearings; and 

working with other District government agencies. CFSA caseworkers are 

also responsible for documenting the steps taken and decisions made 

related to a child’s safety, well-being, and proper foster care placement, as 

well as those related to developing the most appropriate goal for 

permanency. Depending on their circumstances, children leave foster care 

and achieve permanency through reunification with their birth or legal 

parents, adoption, legal guardianship with a relative, or independence.5

 As 

 5

Independent living arrangements may be attained once a child, who has not been reunified 

with his family or adopted, reaches the age of 18 or, in some jurisdictions, 21 and for whom 

federal reimbursement for foster care expenditures is no longer available. 
Page 8 GAO-03-646 D.C. Child and Family Services 

of September 2002, a child’s length of stay in the District’s foster care 

program averaged 2.8 years. 

Figure 1: CFSA Responsibilities Related to Permanency Goals 
Page 9 GAO-03-646 D.C. Child and Family Services 

HHS is responsible for setting standards and monitoring the nation’s child 

welfare programs. In fiscal year 2001, about $6.2 billion in federal funds 

were appropriated to HHS for foster care and related child welfare 

services. HHS’s monitoring efforts include periodic reviews of the 

operations, known as Child and Family Services Reviews, and of the 

automated systems, known as Statewide Automated Child Welfare 

Information System (SACWIS) Reviews, in the states and the District of 

Columbia. HHS last reviewed CFSA’s child welfare information system in 

2000 and its overall program in 2001. 

CFSA undertook actions to implement six of the nine ASFA requirements 

we reviewed and met or exceeded four of the eight performance criteria 

included in our study, but as of March 2003, its plans to improve its 

performance did not include all ASFA requirements not fully implemented 

or selected performance criteria. With regard to implementing ASFA 

requirements, for example, CFSA signed a border agreement to achieve 

more timely placement of District children in Maryland, which addresses 

the ASFA requirement to use cross-jurisdictional resources to facilitate 

timely adoptive or permanent placements for waiting children. Table 1 

summarizes CFSA’s progress in implementing the nine ASFA requirements 

that we reviewed. 

CFSA Undertook 

Actions to Implement 

Most ASFA 

Requirements 

Reviewed and Met 

Half of the Selected 

Performance Criteria 

for Child Safety and 

Well-Being 
Page 10 GAO-03-646 D.C. Child and Family Services 

Table 1: CFSA’s Progress in Implementing Nine ASFA Requirements 

ASFA requirements CFSA has 

implemented 

ASFA requirements CFSA has not fully 

implemented 

1. Include the safety of the child in state 

 case planning and in a case review 

 system. 

1. Initiate or join proceedings to terminate 

 parental rights for certain children 

 in foster care—such as those who have 

 been in foster care for 15 of the most 

 recent 22 months of care. 

2. Comply with requirements for criminal 

 background clearances and have 

 procedures for criminal record checks. 

2. Provide participants a notice of reviews 

 and hearings and an opportunity to be 

 heard. 

3. Develop a case plan documenting steps 

 taken to provide permanent living 

 arrangements for a child. 

3. Conduct mandatory permanency 

 hearings every 12 months for a child in 

 foster care. 

4. Develop plans for the effective use of 

 cross-jurisdictional resources to 

 facilitate 

 timely adoptive or permanent 

 placements for waiting children. 

5. Provide for health insurance coverage 

 for children with special needs in state 

 plans for foster care and adoption 

 assistance. 

6. Incorporate standards to ensure quality 

 services for children in foster care in 

 state plans. 

Source: ASFA and HHS’s CSFR and GAO analysis. 

Note: Our assessment of CFSA’s progress in implementing three requirements—include the safety of 

the child in case planning, develop a case plan documenting steps taken to provide permanent living 

arrangement for a child, and provide for health insurance coverage for children with special needs—is 

based on data and information provided to us. Our assessment of CFSA’s progress in implementing 

the remaining ASFA requirements is based on HHS’s review of CFSA. 

HHS’s review of CFSA found that the agency did not meet three 

requirements. CFSA did not consistently petition the Family Court to 

terminate parental rights when returning the child to his or her family had 

been deemed inappropriate and the child had been in foster care for 15 of 

the last 22 months. Based on its review of 50 foster care cases, HHS 

reported that 54 percent of the children who were in care longer than 

15 months did not have hearings initiated for the termination of parental 

rights and reasons for not initiating such hearings were not documented in 

the case plan or court order. HHS also found that not all cases had 

hearings to review a child’s permanency goal within the timeframe 

prescribed by ASFA. In addition, foster parents, relative caretakers, and 

pre-adoptive parents were not consistently notified of reviews or hearings 

held on behalf of the foster child. HHS found that not all caregivers and 

prospective caregivers were notified of the time and place of a hearing, if 

such notification took place at all. 
Page 11 GAO-03-646 D.C. Child and Family Services 

We also analyzed automated data from FACES related to eight foster care 

performance criteria and found that CFSA met or exceeded four of them. 

For example, one criterion requires 60 percent of children in foster care to 

be placed with one or more of their siblings; we found that as of November 

30, 2002, 63 percent of children were placed with one or more siblings. The 

areas in which CFSA’s performance fell short were the criteria related to 

(1) caseworker visitation with children in foster care, (2) placement of 

children in foster homes with valid licenses, (3) progress toward 

permanency for children in foster care, and (4) parental visits with 

children in foster care who had a goal of returning home. For example, 

none of the 144 children placed in foster care during the 2-month period 

prior to November 30, 2002, received required weekly visits by a CFSA 

caseworker. Table 2 summarizes our analysis of the selected foster care 

performance criteria. 
Page 12 GAO-03-646 D.C. Child and Family Services 

Table 2: Analysis of Selected Foster Care Performance Criteria 

Foster care performance criteria Analysis 

1. Current case plans for foster care 

 cases. 

Forty-five percent of foster care 

cases have current case plans. 

Met As of September 30, 2002, 

46 percent of foster care 

cases had current case 

plans. 

2. Visitation between children in foster 

care and their parents. 

Thirty-five percent of cases in 

which children have a permanency 

goal of return home have parental 

visits at least every 2 weeks. 

Not met As of November 30, 2002, 1 

percent of children with a 

return home goal had 

parental visits at least every 2 

weeks. 

3. Social worker visitation with children in 

foster care. 

Twenty-five percent of children in 

foster care have weekly visits with 

social workers in their first 8 

weeks of care; 35 percent of all 

children in foster care have at least 

monthly visits. 

Not met As of November 30, 2002, no 

children had weekly visits 

and at least 98 percent of 

children did not have monthly 

visits with a caseworker.a

4. Appropriate legal status for children in 

foster care. 

No child in emergency care for 

more than 90 days. 

Met As of November 30, 2002, no 

children in emergency care 

more than 90 days. 

5. Current and valid foster home licenses. 

Seventy-five percent of children are 

placed in foster homes with valid 

licenses. 

Not met As of November 30, 2002, 47 

percent of children were in 

foster homes with valid 

licenses. 

6. Progress toward permanency. 

No more than 10 percent of 

children in foster care have a 

permanency goal of return home 

for more than 18 months. 

Not met As of November 30, 2002, 30 

percent of children had a 

permanency goal of return 

home more than 18 months. 

7. Foster care placement with siblings. 

Sixty percent of children in foster 

care are placed with one or more of 

their siblings. 

Met As of November 30, 2002, 63 

percent of children were 

placed with one or more 

siblings. 

8. Placement stability. 

No more than 25 percent of 

children in foster care as of May 

31, 2002, have had three or more 

placements. 

Met As of November 30, 2002, 21 

percent of children had three 

or more placements. 

Source: GAO analysis. 

a

For 2 percent of the children, caseworker visits equaled or exceeded the number of months in 

placement. However, CFSA’s data did not allow us to determine when caseworkers visited children or 

if they visited children each month. 

CFSA’s Program Improvement Plan, a plan required by HHS to address 

those areas determined not met in a CFSR, identifies how it will address 

two of the unmet ASFA requirements—(1) to initiate or join proceedings 
Page 13 GAO-03-646 D.C. Child and Family Services 

to terminate parental rights (TPR) of certain children in foster care and 

(2) to ensure that children have a permanency hearing every 12 months 

after entering foster care. For example, CFSA has outlined steps to 

improve its filings of TPR petitions with the Family Court. To help 

facilitate this process, CFSA hired additional attorneys to expedite the 

TPR proceedings. The new attorneys have been trained in ASFA 

requirements and in the process for referring these cases to the Family 

Court. CFSA is also developing a methodology for identifying and 

prioritizing cases requiring TPR petitions. In another plan, the April 2003 

Implementation Plan, CFSA states that it will redesign its administrative 

review process to improve, among other things, notification and 

attendance of relevant parties and to provide for a comprehensive review 

of case progress, permanency goals, and adequacy of services. 6 However, 

this plan does not make it clear whether all applicable hearings and 

proceedings will be included, such as permanency hearings. 

Another CFSA plan, the Interim Implementation Plan, includes measures 

that were developed to show the agency’s plans for meeting the 

requirements of the modified final order issued by the U.S. District Court 

for the District of Columbia. This plan includes actions to address three of 

the four performance criteria the agency did not meet—visits between 

children in foster care and their parents, social worker visitation with 

children in foster care, and placement of children in foster homes with 

current and valid licenses. The plan states that, for new contracts, CFSA 

will require its contactors to identify community sites for parental visits to 

help facilitate visits between children in foster care and their parents. The 

plan also indicates that CFSA will concentrate on the recruitment and 

retention of caseworkers. According to CFSA officials, caseworkers would 

have more time for quality casework, including visitation with children, 

parents, and caregivers, once they hire more caseworkers. Additionally, 

the plan established a goal to have 398 unlicensed foster homes in 

Maryland licensed by December 31, 2002. According to an agency official, 

104 of these foster homes remained unlicensed as of May 14, 2003. 

However, CFSA does not have written plans that address the performance 

criterion to reduce the number of children in foster care who, for 

18 months or more, have had a permanency goal to return home. Without 

complete plans for improving performance for all measures, CFSA’s ability 

 6

In April 2003, the court-appointed monitor submitted an implementation plan containing 

additional performance measures to the U.S. District Court for its approval. The plan 

established goals CFSA must meet by 2006. The U.S. District Court approved the plan in 

May 2003. 
Page 14 GAO-03-646 D.C. Child and Family Services 

to comply with the ASFA requirements and meet the selected performance 

criteria may be difficult. Furthermore, unless these requirements and 

criteria are met, the time a child spends in foster care may be prolonged, 

or the best decisions regarding a child’s future well-being may not be 

reached. 

CFSA officials cited several factors that hindered their ability to fully 

implement the ASFA requirements and meet the selected performance 

criteria, including court-imposed requirements, staffing shortages, and

high caseloads. For example, program managers and supervisors said that 

the new court-imposed mediation process intended to address family 

issues without formal court hearings places considerable demands on 

caseworkers’ time. The time spent in court for mediation proceedings, 

which can be as much as 1 day, reduces the time available for caseworkers 

to respond to other case management duties, such as visiting with children 

in foster care. Furthermore, managers and supervisors reported that 

staffing shortages have contributed to delays in performing critical case 

management activities, such as identifying cases for which attorneys need 

to file TPR petitions. However, staffing shortages are not a unique problem

to CFSA. We recently reported that caseworkers in other states said that 

staffing shortages and high caseloads had detrimental effects on their 

abilities to make well-supported and timely decisions regarding children’s 

safety.

7

 We also reported that as a result of these shortages, caseworkers 

have less time to establish relationships with children and their families, 

conduct frequent and meaningful home visits, and make thoughtful and 

well-supported decisions regarding safe and stable permanent placements.

 7

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.: 

Mar. 31, 2003). 
Page 15 GAO-03-646 D.C. Child and Family Services 

CSFA has established many foster care policies, but caseworkers did not 

consistently implement the six we selected. These policies covered the 

range of activities involved in a foster care case, but did not duplicate 

those examined in our review of the AFSA requirements or the selected 

foster care performance criteria. In addition, CFSA’s automated system 

lacked data on four of the six policies we examined for at least 70 percent 

of its active foster care cases. Without information on all cases, 

caseworkers do not have a readily available summary of the child’s history 

needed to make decisions about a child’s care and managers do not have 

information needed to assess and improve program operations. 

While we previously reported in 20008

 that CFSA lacked some important 

child protection and foster care placement policies, CFSA has now 

established many such policies and most are comparable to those 

recommended by organizations that develop standards applicable to child 

welfare programs. For example, CFSA has policies for investigating 

allegations of child abuse, developing case plans, and establishing 

permanency goals for foster children. In addition, one policy is more 

rigorous than suggested standards. Specifically, CFSA’s policy requires an 

initial face-to-face meeting with children within 24 hours of reported abuse 

or neglect, while the suggested standard is 24 to 48 hours or longer, 

depending on the level of risk to the child’s safety and well-being. 

However, CFSA does not have some recommended policies, namely those 

addressing (1) written time frames for arranging needed services for 

children and families (e.g., tutoring for children and drug treatment for 

family members); (2) limits on the number of cases assigned to a 

caseworker, based on case complexity and worker experience; and 

(3) procedures for providing advance notice to each person involved in a 

case about the benefits and risks of services planned for a child and 

alternatives to those services. CFSA managers said that the agency had not 

established these policies because agency executives gave priority to 

complying with court-ordered requirements. 

CFSA did not consistently implement the policies we examined. We 

selected six policies that did not duplicate those examined in our review 

of the AFSA requirements or the selected foster care performance criteria 

in order to cover most of the case management duties and responsibilities. 

 8

U.S. General Accounting Office, District of Columbia Child Welfare: Long-Term 

Challenges in Ensuring Children’s Well-Being, GAO-01-191 (Washington, D.C.: Dec. 29, 

2000) and Foster Care: Status of the District of Columbia’s Child Welfare System Reform 

Efforts, GAO/T-HEHS-00-109 (Washington, D.C.: May 5, 2000). 

CFSA Has Established 

Many Foster Care 

Policies but Lacks 

Others, and the 

Extent of 

Implementation and 

Documentation Varies 

CSFA Has Established 

Many Foster Care Policies, 

but Caseworkers Did Not 

Consistently Implement 

Those We Selected 
Page 16 GAO-03-646 D.C. Child and Family Services 

CFSA could not provide automated data regarding the implementation of 

one policy requiring administrative review hearings every 6 months.9

 As 

for the remaining five policies, data in FACES indicate that caseworkers’ 

implementation of them varied considerably. Table 3 summarizes these 

five policies and the percentage of cases for which the data indicated the 

policy was implemented. 

Table 3: Implementation of Selected CFSA Foster Care Policies as Documented in 

FACES 

Policy 

Percent of foster care cases 

for which the policy was 

implementeda, b

Initiate face-to-face investigation of alleged child abuse 

or neglect within 24 hours of receiving an allegation on 

CFSA’s child abuse hotline. 26 

Complete a safety assessment within 24 hours of faceto-face contact with the child. 13 

Complete a risk assessment within 30 days of receiving 

an allegation on the hotline. 73 

Complete an initial case plan within 30 days of a child’s 

entry into foster care. 9 

Arrange needed services for foster care children or their 

families. 83 

Source: FACES data and GAO analysis. 

a

With the exception of the policy to arrange needed services, the analysis is based on 943 foster care 

cases that were at least 6 months old, as of November 30, 2002. These cases were initiated after 

FACES came on-line in October 1999. The analysis of the policy to arrange for needed services is 

based on 1,837 foster care cases and includes cases that predated FACES but for which services 

were provided after FACES came on-line. Data show the percentage of cases for which caseworkers 

arranged at least one service. 

b

CFSA counted cases that had missing data as instances of caseworker noncompliance with the 

applicable policy. 

The policies related to initiating face-to-face investigations and completing 

safety assessments are particularly critical to ensuring children’s safety. 

CFSA’s policy requires caseworkers to initiate an investigation of alleged 

child abuse or neglect within 24 hours of the call to CFSA’s hot line 

through face-to-face contact with the child. Also, caseworkers are required 

to complete a safety assessment within 24 hours of the face-to-face 

contact with the child. While it took CFSA caseworkers considerably 

 9

Administrative review hearings are held to make decisions about a child’s permanent 

placement. They generally involve foster care children, family members, CFSA 

caseworkers, attorneys, and others with a role in the future well-being of the child. 
Page 17 GAO-03-646 D.C. Child and Family Services 

longer than the time specified in the policy to take these actions in some 

cases, CFSA’s performance has improved. CFSA has reduced the average 

time it takes to make contacts and complete the assessments. In 2000, it 

took caseworkers an average of 18 days to initiate a face-to-face 

investigation, whereas in 2002 the average was 2 days. Similarly, 

caseworkers took an average of 30 days to complete safety assessments in 

2000, whereas the average time declined to 6 days in 2002. Although there 

were cases that took much longer than the 24-hour limits, there were 

fewer in 2002 than in 2000. CFSA caseworkers took 5 or more days to 

initiate a face-to-face investigation for 61 cases in 2000, and for 16 cases in 

2002. Table 4 summarizes the number of cases for which caseworkers took 

5 or more days to initiate investigations and complete safety assessments 

from 2000 through 2002. 

Table 4: Number of Cases Taking 5 or More Days to Implement Policy (2000-2002) 

Fiscal Year 

Policy 2000 2001 2002 Total

Initiate face-to-face investigation of alleged child 

abuse or neglect within 24 hours of receiving an 

allegation. 61 66 16 143

Complete a safety assessment within 24 hours of 

face-to-face contact with child. 101 122 50 273

Source: FACES data and GAO analysis. 

We also reviewed case files and examined related data from FACES for 

30 foster care cases to assess compliance with policies requiring timely 

case planning, periodic administrative review hearings, and arrangements 

for needed services. The case files we reviewed were often voluminous, 

inconsistently organized, and contained information that was not always 

traceable to data entered in FACES. Our review found that case plans 

were not routinely completed within 30 days, as required by CFSA policy. 

The FACES data provided subsequent to our case file review supported 

this assessment. 

We also found that for almost half of the cases we examined 

administrative review hearings, which are held to ensure that key 

stakeholders are involved in decisions about a child’s permanent 

placement, were rescheduled, resulting in their being held less frequently 

than required by CFSA policy. CFSA policy requires that these hearings be 

held every 6 months, and FACES automatically schedules them to occur 

6 months after the most recent hearing. However, CFSA officials are 

unable to track how frequently they are rescheduled or the length of time 

between hearings because the system overrides the dates of prior 
Page 18 GAO-03-646 D.C. Child and Family Services 

hearings. Agency officials explained that changes have been made to 

FACES to enable them to track how many times an administrative review 

is re-scheduled. Long delays between administrative review hearings could 

mean delays in getting children into permanent placement. As for 

arranging needed services, we could not determine from case files or 

FACES whether services recommended by caseworkers were approved by 

supervisors or if all needed services were provided. The FACES data 

indicate that at least one service was provided for 83 percent of the cases, 

but do not include a complete record of all services caseworkers 

determine to be needed, nor do they indicate whether the services were 

provided on a timely basis. 

Officials said that several factors affected the implementation of some of 

the policies we reviewed. Caseworkers’ supervisors and managers 

explained that, generally, the policies were not always implemented 

because of limited staff and competing demands, and the policies were not 

documented because some caseworkers did not find FACES to be user 

friendly. Agency officials explained that, in part, the data on the 

implementation of the initial investigations and safety assessment 

reflected a change in who was responsible for the initial investigation of 

child abuse cases. Until October 2001, the District’s Metropolitan Police 

Department had this responsibility and data on initial investigations were 

not entered into FACES. CFSA now has responsibility for both child abuse 

and neglect investigations. Further, program managers and supervisors 

said that several factors contributed to the time frames required to initiate 

face-to-face investigations, including difficulty in finding the child’s correct 

home address, contacting the child if the family tries to hide the child from 

investigators, and even obtaining vehicles to get to the location. Regarding 

administrative review hearings, the records indicate that they were 

rescheduled for a variety of reasons, such as the caseworker needing to 

appear at a hearing for another case or the attorney not being able to 

attend the hearing. Managers also said that the data on service delivery 

was not always entered into FACES because caseworkers sometimes 

arranged services by telephone and did not enter the data into FACES. 

CFSA officials said that they recently made changes to help improve the 

implementation of some of the policies we reviewed. They said that CFSA 

has focused on reducing the number of cases for which a risk assessment 

had not been completed and has reduced the number of these 

investigations open more than 30 days from 807 in May 2001 to 263 in May 

2002. CFSA officials said that they also anticipate a reduction in the 

number of administrative review hearings that are rescheduled. They said 

the responsibility for notifying administrative review hearing participants 
Page 19 GAO-03-646 D.C. Child and Family Services 

about a scheduled hearing was transferred from caseworkers to staff in 

CFSA’s administrative review unit, and they intend to provide notification 

well in advance of the hearings. Additionally, another official said that 

CFSA has begun testing a process to ensure that all needed services are 

provided within 45 days. 

Such improvements are needed because without consistently 

implementing policies for timely investigations and safety and risk 

assessments, a child may be subject to continued abuse and neglect. 

Delays in case plan preparation and in holding administrative review 

hearings delay efforts to place children in permanent homes or reunite 

them with their families. Further, without knowing whether children or 

families received needed services, CFSA cannot determine whether steps 

have been taken to resolve problems or improve conditions for children in 

its care, which also delays moving children toward their permanency 

goals. 

In addition to its policies for managing cases, CFSA has policies for 

licensing and monitoring group homes, plans for training staff in group 

homes, and a goal to reduce the number of young children in group homes. 

CFSA’s policies for group homes are based primarily on District 

regulations that went into effect July 1, 2002. For example, the regulations 

prohibited CFSA from placing children in an unlicensed group home as of 

January 1, 2003. According to CFSA officials, as of March 2003, all CFSA 

group homes were licensed, except one, and CFSA was in the process of 

removing children from that home. CFSA plans to monitor group homes 

by assessing their compliance with contractual provisions and licensing 

requirements. CFSA also plans to provide training to group home staff to 

make it clear that, as District regulations require, any staff member who 

observes or receives information indicating that a child in the group home 

has been abused must report it. Further, CFSA has a goal to reduce the 

number of children under 13 who are placed in group homes. According to 

agency officials, CFSA has reduced the number of children under 13 in 

group homes from 128 in August 2002 to 70 as of February 2003 and has 

plans to reduce that number even further by requiring providers of group 

home care to link with agencies that seek foster care and adoptive 

families. 

CFSA Has Established 

Policies and Goals for 

Group Homes 
Page 20 GAO-03-646 D.C. Child and Family Services 

In our efforts to assess CFSA’s implementation of the selected foster care 

policies related to the safety and well-being of children as shown in table 

3, we determined that FACES lacked data on many active foster care 

cases. In December 2000, we reported that FACES lacked complete case 

information, and caseworkers had not fully used it in conducting their 

daily casework.10 During our most recent review, we determined that 

FACES lacked data on four of six foster care policies for at least 

70 percent of its active foster care cases.11 Of the 2,510 foster care cases at 

least 6 months old as of November 30, 2002, data were not available for 

1,763. CFSA officials explained that all of these cases predated FACES, 

and the previous system was used primarily to capture information for 

accounting and payroll purposes, not for case management. Top agency 

managers said that CFSA does not plan to make it an agency priority to 

transfer information kept in paper files for cases that predated FACES into 

the system. Additionally, FACES reports show that data were not available 

on many of the cases that entered the foster care system after FACES 

came on line. For example, complete data on the initiation of 

investigations and completion of safety assessments were not available for 

about half of the 943 cases that entered the foster care system after 

FACES came on line. CFSA officials explained that they intend to focus on 

improving a few data elements at a time for current and future events. 

Having systems that provide complete and accurate data is an important 

aspect of effective child welfare programs. HHS requires all states and 

D.C. to have an automated child welfare information system. These 

systems, known as SACWIS, must be able to record data related to key 

child welfare functions, such as intake management, case management, 

and resource management. In its review of FACES, HHS found CFSA’s 

system was in compliance with most of the requirements and identified 

several that needed improvement, including the requirements to prepare 

and document service/case plans and to conduct and record the results of 

 10U.S. General Accounting Office, District of Columbia Child Welfare: Long-Term 

Challenges to Ensuring Children’s Well-Being, GAO-01-191 (Washington, D.C.: Dec. 29, 

2000). 

11The four polices for which FACES lacked data included (1) initiate face-to-face 

investigation of alleged child abuse or neglect within 24 hours of receiving an allegation on 

CFSA’s child abuse hotline, (2) complete a safety assessment within 24 hours of face-toface contact with the child, (3) complete a case plan within 30 days of a child’s entry into 

foster care, and (4) schedule and attend administrative review hearings every 6 months. 

CFSA’s Automated System 

Lacked Data on Many 

Foster Care Cases 
Page 21 GAO-03-646 D.C. Child and Family Services 

case reviews.12 According to a CFSA official, D.C. responded to the HHS 

report and made changes to address most of the findings. He said that the 

changes included redesigning the FACES screens documenting 

service/case plans and the results of case reviews. These changes were 

made in collaboration with caseworkers to help improve usability. 

In addition to the standards and requirements established by HHS for all 

child welfare systems, the modified final order requirements established 

by the U.S. District Court for the District of Columbia direct CFSA to 

produce management data and many reports on their operations. For 

example, the modified final order requires that CFSA be able to produce a 

variety of data such as, the number of children (1) for whom a case plan 

was not developed within 30 days, (2) with a permanency goal of returning 

home for 12 months or more, and (3) placed in a foster home or facility 

who have been visited at specified intervals. 

Complete, accurate, and timely case management data enables 

caseworkers to quickly learn about new cases, supervisors to know the 

extent that caseworkers are completing their tasks, and managers to know 

whether any aspects of the agency’s operations are in need of 

improvement. Child welfare automated systems need to have complete 

case data to help ensure effective management of child welfare programs. 

A child welfare expert said that there is a great need to transfer 

information from old case records to new automated systems. For 

example, the expert said that records of older teens have been lost, and, 

with them, valuable information such as the identity of the children’s 

father. Without data in FACES, CFSA’s caseworkers will have to look for 

paper records in the case files, some of which are voluminous. This file 

review effort is much more time-consuming than reviewing an automated 

report and as a result, when cases are transferred to new caseworkers, it 

requires more time for them to become familiar with cases. 

 12HHS completed its SACWIS assessment review of FACES in June 2000. The purpose of 

this review is to assess whether the child welfare information system performs functions 

that are important to meeting the minimal requirements. 
Page 22 GAO-03-646 D.C. Child and Family Services 

CFSA has enhanced its working relationship with the D.C. Family Court by 

working more collaboratively, but several factors have hindered these 

relationships. By participating in committees and training sessions, 

collocating OCC attorneys with caseworkers, and communicating 

frequently, CFSA has enhanced its working relationship with the Family 

Court. CFSA participates in various planning committees with the Family 

Court, such as the Implementation Planning Committee, a committee to 

help implement the District of Columbia Family Court Act of 2001. CFSA 

caseworkers have participated in training sessions that include OCC 

attorneys and Family Court judges. These sessions provide all parties with 

information about case management responsibilities and various court 

proceedings, with the intent of improving and enhancing the mutual 

understanding about key issues. Additionally, CFSA assigned a liaison 

representative to the Family Court who is responsible for working with 

other District agency liaison representatives to assist social workers and 

case managers in identifying and accessing court-order services for 

children and their families at the Family Court. Also, since 2002, OCC 

attorneys have been located at CFSA and work closely with caseworkers. 

This arrangement has improved the working relationship between CFSA 

and the Family Court because the caseworkers and the attorneys are 

better prepared for court appearances. Furthermore, senior managers at 

CFSA and the Family Court communicated frequently about day-to-day 

operations as well as long-range plans involving foster care case 

management and related court priorities, and on several occasions 

expressed their commitment to improving working relationships. 

However, CFSA officials and Family Court judges also noted several 

hindrances that constrain their working relationship. These hindrances 

include the need for caseworkers to balance court appearances with other 

case management duties, an insufficient number of caseworkers, 

caseworkers who are unfamiliar with cases that have been transferred to 

them, and differing opinions about the responsibilities of CFSA 

caseworkers and judges. For example, although CFSA caseworkers are 

responsible for identifying and arranging services needed for children and 

their families, some caseworkers said that some Family Court judges 

overruled their service recommendations. Family Court judges told us 

that they sometimes made decisions about services for children because 

they believe caseworkers did not always recommend appropriate ones or 

provide the court with timely and complete information on the facts and 

circumstances of the case. Furthermore, the Presiding Judge of the Family 

court explained that it was the judges’ role to listen to all parties and then 

make the best decisions by taking into account all points of view. 

Caseworkers and judges agreed that appropriate and timely decisions 

CFSA Has Enhanced 

Its Working 

Relationship with the 

D.C. Family Court by 

Working 

Collaboratively, but 

Hindrances Remain 
Page 23 GAO-03-646 D.C. Child and Family Services 

about services for children and their families are important ones that can 

affect a child’s length of stay in foster care. 

CFSA officials and Family Court judges have been working together to 

address some of the hindrances that constrain their working relationship. 

CFSA managers said that scheduling of court hearings has improved. 

According to agency officials, in March 2003, CFSA began receiving daily 

schedules from the Family Court with upcoming hearing dates. This 

information allows caseworkers to plan their case management duties 

such that they do not conflict with court appearances. Also, as of March 

2003, court orders were scanned into FACES to help ensure that 

caseworkers and others involved with a case have more complete and 

accurate information. To help resolve conflicts about ordering services, 

CFSA caseworkers and Family Court judges have participated in sessions 

during which they share information about their respective concerns, 

priorities, and responsibilities in meeting the needs of the District’s foster 

care children and their families. 

CFSA has taken steps to implement several ASFA requirements, met 

several performance criteria, developed essential policies, and enhanced 

its working relationship with the Family Court. In addition, CFSA has 

implemented new group home policies, improved the average time 

caseworkers took to implement certain policies and undertaken initiatives, 

in conjunction with the Family Court, to improve the scheduling of court 

hearings. However, CFSA needs to make further improvements in order to 

ensure the protection and proper and timely placement of all of the 

District’s foster care children. By implementing all ASFA requirements, 

meeting the performance criteria and effectively implementing all policies, 

CFSA will improve a child’s stay in the foster care system and reduce the 

time required to attain permanent living arrangements. Furthermore, 

complete, accurate, and timely case management data will enable 

caseworkers to quickly learn about new cases and the needs of children 

and their families, supervisors to know the extent to which caseworkers 

are completing all required tasks, and managers to know whether any 

critical aspects of the agency’s operations are in need of improvement. 

Without automated information on all cases, caseworkers do not have a 

readily available summary of the child’s history, which may be critical to 

know when making plans about the child’s safety, care, and well-being. 

To improve CFSA’s performance and outcomes for foster care children in 

the District of Columbia, we recommend that the Mayor require the 

Director of CFSA to (1) develop plans to fully implement all ASFA 

Conclusions 

Recommendations 
Page 24 GAO-03-646 D.C. Child and Family Services 

requirements; (2) establish procedures to ensure that caseworkers 

consistently implement foster care policies; and (3) document in FACES 

all activities related to active foster care cases, including information from 

paper case files related to the history of each active foster care case. 

We received written comments from the Director of the District of 

Columbia’s Child and Family Services Agency who provided them on 

behalf of the Deputy Mayor for Children, Youth, Families, and Elders. 

These comments are reprinted in appendix II. The Director generally 

agreed with our findings related to the extent to which CFSA implemented 

ASFA requirements, developed policies, and improved its relationship with 

the D.C. Family Court. Although the CFSA Director did not directly 

address the recommendations, she generally agreed with the areas we 

identified for continued improvement and said that CFSA is deeply 

committed to continuing improvements in the FACES information system. 

Additionally the Director provided overall comments concerning the 

(1) implementation plan, (2) establishment of CFSA, and (3) timeframes of 

the receivership. CFSA suggested that we modify the report to reflect 

strategies listed in the April 2003 Implementation Plan regarding timely 

notification and reducing the number of children in foster care for 

18 months or more with a permanency goal of returning home. We 

changed the report to reflect the notification strategy but did not make 

changes regarding children and their progress towards permanency 

because the April 2003 plan did not include a relevant strategy. CFSA also 

suggested that we include the date the agency was established as a single 

cabinet-level District agency and the date the agency gained responsibility 

for abuse cases from the Metropolitan Police Department. We made these 

changes. Additionally, CFSA recommended that we discuss the policy 

implementation trends earlier in the report, and asked that we note the 

time period for the cases included in the HHS review, which we did. CFSA 

also asked that we explain that the data we collected and analyzed 

generally covered the October 1999 to mid-2002 period. We did not make 

this change. As explained in the scope and methodology section of the 

report, we reviewed and analyzed a variety of data related to all active 

foster care cases. Some of the data was as of November 2002, and some 

analyses were based on active cases that began prior to October 1999. 

The CFSA Director also made several detailed comments. As she 

suggested, we added language to clarify the requirement for a permanency 

hearing, included information on changes made to FACES regarding 

rescheduling administrative reviews and corrected the number of CFSA 

Agency Comments 

and Our Evaluation 
Page 25 GAO-03-646 D.C. Child and Family Services 

staff assigned to the Family Court. We did not include the March 2003 

data listed in the comments because we could not verify the accuracy of 

the data. 

Although the CFSA director did not directly address the 

recommendations, we continue to think that in order for CFSA to further 

improve its performance, the agency should develop plans to fully 

implement all ASFA requirements, establish procedures to ensure that 

caseworkers consistently implement all foster care policies, and document 

in FACES all activities related to active foster care cases. 

As agreed with your office, unless you publicly release its contents earlier, 

we will make no further distribution of this report until 30 days after its 

issue date. At that time, we will send copies of this report to the Mayor of 

the District of Columbia; the Deputy Mayor for Children, Youth, Families, 

and Elders; the Director of the District of Columbia Child and Family 

Services Agency; and the Chief Judge of the District of Columbia Superior 

Court. We will also make copies of this report available to others on 

request. In addition, the report will be available at no charge on GAO’s 

Web site at http://www.gao.gov. 

If you have any questions about this report, please contact me on (202) 

512-8403. Other contacts and staff acknowledgments are listed in 

appendix III. 

Sincerely yours, 

Cornelia M. Ashby 

Director, Education, Workforce, and 

 Income Security Issues
Appendix I: Scope and Methodology 

Page 26 GAO-03-646 D.C. Child and Family Services 

To provide a comprehensive assessment of the Child and Family Services 

Agency’s (CFSA) performance relative to Adoption and Safe Families Act 

of 1997 (ASFA) requirements and selected foster care performance 

criteria, we relied on several sources of information and analyses. We 

reviewed the U. S. Department of Health and Human Services’ (HHS) Child 

and Family Services Review (February 2002) and obtained and analyzed 

data to assess CFSA’s implementation of ASFA’s requirements. Our 

analysis of CFSA’s implementation of ASFA identified whether the agency 

had implemented procedures in accordance with the ASFA requirements 

and did not assess the extent to which or how well it had implemented the 

requirement across all applicable foster care cases. 

To perform our assessment of CFSA’s performance with regard to the 

selected performance criteria established during its probationary period, 

we obtained and analyzed relevant automated data from FACES1

 on all 

active foster care cases as of November 30, 2002, the last complete month 

for which data were available at the time of our work. We analyzed these 

data for six of the eight criteria. For the other two criteria, we analyzed 

data on all foster homes as of November 30, 2002, and data on case plans 

as of September 30, 2002. Additionally, we obtained and analyzed 

automated FACES data for 943 foster care cases that were at least 6 

months old as of November 30, 2002, to assess how CFSA caseworkers 

implemented foster care policies that covered several key functions from 

investigations through the delivery of services to foster children and their 

families. Many of the active foster care cases began prior to October 1999. 

We also obtained and analyzed reports by the court-appointed monitor to 

assess CFSA’s performance relative to the specified requirements and 

criteria. In addition, we reviewed and included relevant information from 

several of our prior reports on CFSA and the District’s Family Court. In 

addition, we independently verified the reliability of automated data by 

reviewing related reports on the data maintained in FACES and by 

assessing the degree to which FACES contained erroneous or illogical 

data entries. To obtain additional information on policy implementation 

and documentation, we reviewed case files for children who entered the 

foster care system at different times. Our case file review included 

analyses of data contained in FACES and in paper case files for selected 

foster care cases. We pretested our data collection instrument for 

collecting case file information and received training in the content and 

 1

CFSA’s automated case management system. 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 27 GAO-03-646 D.C. Child and Family Services 

use of FACES. In addition, while FACES did not contain all data on the 

implementation of the policies we selected, we analyzed information on 

CFSA’s most recent performance to provide a comprehensive assessment 

of various agency initiatives intended to improve implementation of foster 

care policies. We also reviewed federal and local laws, regulations, and 

selected CFSA policies. Using interview protocols, we interviewed CFSA 

executives, managers, and supervisors; OCC officials; the Office of the 

Deputy Mayor for Children, Youth, Families, and Elders; Family Court 

judges and other court officials; and child welfare experts in organizations 

that recommend policies applicable to child welfare programs. 
Appendix II: Comments from the Director of the Child and Family Services Agency 

Page 28 GAO-03-646 D.C. Child and Family Services 

Appendix II: Comments from the Director of 

the Child and Family Services Agency 
Appendix II: Comments from the Director of the Child and Family Services Agency 

Page 29 GAO-03-646 D.C. Child and Family Services 
Appendix II: Comments from the Director of the Child and Family Services Agency 

Page 30 GAO-03-646 D.C. Child and Family Services 
Appendix II: Comments from the Director of the Child and Family Services Agency 

Page 31 GAO-03-646 D.C. Child and Family Services 
Appendix III: GAO Contacts and 

Acknowledgments 

Page 32 GAO-03-646 D.C. Child and Family Services 

Carolyn M. Taylor, (202) 512-2974, taylorcm@gao.gov 

Mark E. Ward, (202) 512-7274, wardm@gao.gov 

The following individuals also made important contributions to this report: 

Sheila Nicholson, Vernette Shaw, Joel Grossman, and James Rebbe.

Appendix III: GAO Contacts and 

Acknowledgments 

GAO Contacts 

Acknowledgments 
Related GAO Products 

Page 33 GAO-03-646 D.C. Child and Family Services 

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

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

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

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

April 8, 2003. 

District of Columbia: Issues Associated with the Child and Family 

Services Agency’s Performance and Policies. GAO-03-611T. Washington, 

D.C.: April 2, 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. 

District of Columbia: More Details Needed on Plans to Integrate 

Computer Systems With the Family Court and Use Federal Funds. GAO02-948. Washington, D.C.: August 7, 2002. 

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. 

D.C. Family Court: Progress Made Toward Planned Transition and 

Interagency Coordination, but Some Challenges Remain. GAO-02-797T. 

Washington, D.C.: June 5, 2002. 

D.C. Family Court: Additional Actions Should Be Taken to Fully 

Implement Its Transition. GAO-02-584. Washington, D.C.: May 6, 2002. 

D.C. Family Court: Progress Made Toward Planned Transition, but 

Some Challenges Remain. GAO-02-660T. Washington, D.C.: April 24, 2002. 

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

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

Foster Care: Status of the District of Columbia’s Child Welfare System 

Reform Efforts. GAO/T-HEHS-00-109. Washington, D.C.: May 5, 2000. 

 Related GAO Products 

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