Report to the Chairman, Subcommittee 

on Human Resources, Committee on 

Ways and Means, House of 

Representatives 

United States General Accounting Office 

GAO 

September 2003 CHILD WELFARE

Enhanced Federal 

Oversight of Title IV-B 

Could Provide States 

Additional 

Information to 

Improve Services 

GAO-03-956 
On a national level, GAO’s survey showed that the primary emphases of 

subparts 1 and 2 vary somewhat, but the range of services offered and the 

types of families served overlap significantly. No single category of service 

was funded solely by either subpart. In fiscal year 2002, states used subpart 1 

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

administrative and managerial expenses, child protective services, and foster 

care maintenance payments. Subpart 2 primarily funded family support, 

family preservation, family reunification, and adoption support services. 

Programs funded by the two subparts served similar types of populations—

predominantly children at risk of being abused or neglected and their 

parents, as well as children in foster care and their parents. 

HHS’s oversight focuses primarily on states’ overall child welfare systems 

and outcomes, but the agency provides relatively little oversight specific to 

subpart 1. For example, HHS works with states to establish goals to improve 

the safety and well-being of children and measure progress toward those 

goals. However, HHS has limited knowledge about how states spend subpart 

1 funds. States submit an annual estimate about how they plan to use their 

subpart 1 funds in the upcoming year, but provide no data on actual 

expenditures. HHS reports that it reviews these estimates for relatively 

limited purposes. We also found that HHS regional offices pay little attention 

to statutory limits on the use of subpart 1 funds for foster care maintenance 

and adoption assistance payments. For example, 9 of the 10 HHS regional 

offices do not monitor states’ compliance with these limits. As a result, HHS 

approved projected 2002 spending plans for 15 states that reported 

estimated spending amounts that exceeded the limits by over $30 million in 

total. 

While GAO’s survey data revealed no unique service categories funded by 

subpart 1 on a national level, 37 states reported unique subpart 1 service 

categories within their state. Little research is available on the effectiveness 

of the services in these categories, such as hotlines to report child abuse and 

emergency shelter services. No states conducted rigorous evaluations of 

these services, although several states provided some information on 

outcomes. 

Examples of Services Funded by Title IV-B 

In 2001, states determined that over

900,000 children were the victims 

of abuse or neglect. In fiscal year 

2003, subparts 1 and 2 of Title IV-B 

of the Social Security Act provided 

$697 million in federal funding for 

services to help families address 

problems that lead to child abuse 

and neglect. This report describes 

(1) the services provided and 

populations served under subparts 

1 and 2; (2) federal oversight of 

subpart 1; and (3) existing research 

on the effectiveness of services 

unique to subpart 1—that is, when 

states used subpart 1, but not 

subpart 2, to fund programs in a 

particular service category. The 

report focuses primarily on subpart 

1 because little research exists on 

this subpart, while studies have 

been conducted on subpart 2. 

GAO recommends that the 

Secretary of the Department of 

Health and Human Services (HHS) 

(1) provide guidance to ensure that 

HHS regional offices provide 

appropriate oversight of subpart 1; 

(2) consider the feasibility of 

collecting data on states’ use of 

these funds to facilitate program 

oversight; and (3) use the 

information gained through 

enhanced oversight of subpart 1 in 

designing its proposed child 

welfare option, which would allow 

states to use other federal child 

welfare funds for services allowed 

under Title IV-B. HHS generally 

agreed with GAO’s findings, but did 

not fully concur with these 

recommendations. 

www.gao.gov/cgi-bin/getrpt?GAO-03-956.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Cornelia Ashby 

at (202) 512-8403 or ashbyc@gao.gov. 

Highlights of GAO-03-956, a report to the 

Chairman, Subcommittee on Human 

Resources, Committee on Ways and 

Means, House of Representatives 

September 2003

CHILD WELFARE

Enhanced Federal Oversight of Title IV-B 

Could Provide States Additional 

Information to Improve Services 
Page i GAO-03-956 Title IV-B Child Welfare Services 

Letter 1

Results in Brief 3

Background 5

The Primary Emphases of These Subparts Vary Somewhat, but the 

Range of Services and Types of Families Served Overlap 

Significantly 12

HHS Focuses Oversight on Overall Child Welfare System, but Has 

Limited Knowledge about States’ Use of Subpart 1 Funds 26

Some Unique Subpart 1 Service Categories Exist at the State Level, 

but Little Research Exists on the Effectiveness of These Services 36

Conclusions 41

Recommendations 41

Agency Comments 42

Appendix I Scope and Methodology 45 

Appendix II Comments from the Department of Health and 

Human Services 50 

Appendix III GAO Contacts and Acknowledgments 54 

GAO Contacts 54

Acknowledgments 54

Related GAO Products 55 

Tables 

Table 1: Selected Requirements to Obtain Grants under Subparts 1 

and 2 of Title IV-B 11

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

Categories 14

Table 3: Populations Targeted by Services Funded by Subparts 1 

and 2 of Title IV-B in Fiscal Year 2002 20

Table 4: Number of States Using Funds from Each Subpart of Title 

IV-B to Target Specific Populations 21

Contents 
Page ii GAO-03-956 Title IV-B Child Welfare Services 

Figures 

Figure 1: Percentage of Subpart 1 Funds Used for Staff Salaries 

Dedicated to Each Type of Staff Position in Fiscal Year 

2002 16

Figure 2: Survey Data on States’ Preferences between Subparts 1 

and 2 of Title IV-B for Different Program Components 24

Figure 3: Fifteen States with Approved CFS-101s with Fiscal Year 

2002 Subpart 1 Spending Estimates that Exceeded Limits 

for Foster Care Maintenance and Adoption Assistance 

Payments 33

Figure 4: Ten States That Reported Fiscal Year 2002 Subpart 1 

Expenditures Exceeding Limits for Foster Care 

Maintenance and Adoption Assistance Payments 35

Abbreviations 

ACF Administration for Children and Families 

APSR Annual Progress and Services Report 

CFSR Child and Family Services Review 

CPS child protective services 

HHS Health and Human Services 

HIPPY Home Instruction for Parents of Preschool 

 Youngsters 

This is a work of the U.S. government and is not subject to copyright protection in the 

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other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-03-956 Title IV-B Child Welfare Services 

September 12, 2003 

The Honorable Wally Herger 

Chairman 

Subcommittee on Human Resources 

Committee on Ways and Means 

House of Representatives 

Dear Mr. Chairman: 

In 2001, child protective services (CPS) staff in state child welfare 

agencies determined that over 900,000 children had been the victims of 

abuse or neglect by their parents or other caretakers.1

 Title IV-B of the 

Social Security Act 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. Title 

IV-B is divided into two parts. States can use subpart 1 funds on almost 

any child welfare activity. Subpart 2 provides grants to states for similar 

types of child welfare services, such as family support services to enhance 

family stability and services to help parents reunify with a child in foster 

care, but is more restrictive in how the funds can be spent. In fiscal year 

2003, appropriations were $292 million for subpart 1 and $405 million for 

subpart 2.2

Title IV-B represents a small percentage of total federal spending on child 

welfare activities. Most federal funding for these activities comes from 

Title IV-E of the Social Security Act and is devoted primarily to paying for 

the room and board of children in foster care—known as foster care 

maintenance payments. Title IV-B dollars can also be used for foster care 

maintenance payments, but are more frequently used for other types of 

services. As the Congress has enacted various pieces of legislation to help 

move children from foster care into permanent homes more quickly, it has 

emphasized the need for states to use Title IV-B funding to provide 

 1

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. 

2

States are required to provide matching funds in order to receive federal Title IV-B dollars. 

United States General Accounting Office

Washington, DC 20548 
Page 2 GAO-03-956 Title IV-B Child Welfare Services 

supportive services needed to preserve and reunify families. In 1980, for 

example, the Congress increased appropriations for subpart 1, but enacted 

limits on the use of these funds for foster care maintenance payments and 

adoption assistance payments to encourage states to use the additional 

funding for services to families.3

 In addition, while states could already use 

subpart 1 funds for services targeted in the new subpart 2 program, the 

creation of subpart 2 was motivated in part by the fact that few states used 

a significant share of their subpart 1 funds for these types of services. The 

Department of Health and Human Services’ (HHS) Administration for 

Children and Families is currently developing a child welfare option that 

would allow states to use Title IV-E funds for the same range of services 

allowed under Title IV-B. 

Because of your interest in the services states are providing to meet the 

needs of families,4

 you asked us to examine the following: (1) How do the 

services provided and populations served under subpart 1 compare with 

those under subpart 2? (2) What has the federal government’s role been in 

overseeing the use of Title IV-B subpart 1 funds? (3) What does the 

research say about the effectiveness of services unique to subpart 1? 

To answer these questions, we sent two surveys to child welfare directors 

to obtain information on how they use Title IV-B funds. To obtain a 

breakdown of state spending for subparts 1 and 2, we sent the first survey 

to all 50 states and the District of Columbia and received responses from 

47 states.5

 We sent the second survey to the 30 states that provided 

sufficient data on their first survey within the timeframe that allowed us to 

conduct the second survey. We received responses from 17 states, 

providing detailed information on the 3 services they reported as receiving 

the most subpart 1 funding and the 3 services they reported as receiving 

the most subpart 2 funding. Because the data from these states may not be 

representative of all states, we have used data from the second survey to 

provide examples of the types of children and families served by 

 3

Adoption assistance payments are provided to parents adopting a child with special needs, 

such as a physical or mental disability, to assist with the costs of services required to meet 

the child’s needs. The subpart 1 limits also apply to child care services to support a parent’s 

employment or training. 

4

This report focuses 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. 

5

We did not receive responses from the District of Columbia, Indiana, Kentucky, or 

Montana. 
Page 3 GAO-03-956 Title IV-B Child Welfare Services 

Title IV-B. We also conducted site visits in California, New Jersey, Ohio, 

and Washington, where we interviewed state and local officials and 

service providers 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. In addition, these states were identified as using 

innovative CPS tools or processes. Further, we reviewed applicable laws 

and regulations; interviewed HHS central and regional office officials 

about their oversight activities with regard to Title IV-B; reviewed results 

from HHS’s assessments of state child welfare agencies, known as Child 

and Family Services Reviews (CFSR); reviewed the literature assessing the 

effectiveness of child welfare services; and interviewed child welfare 

experts. 

On a national level, our survey showed that the primary emphases of 

subparts 1 and 2 vary somewhat, but the range of services offered and the 

types of families served overlap significantly. Our survey found that no 

single category of service was funded solely by subpart 1 or subpart 2 in 

fiscal year 2002. In response to our survey, states reported spending about 

28 percent of subpart 1 funds on the salaries of child welfare agency 

staff—primarily social work staff who can provide a variety of services, 

including CPS investigations, recruiting foster parents, and referring 

families for needed services. The next three largest spending categories—

administration and management expenses, such as rent and utilities; CPS 

services; and foster care maintenance payments—accounted for about 

43 percent of subpart 1 spending. In comparison, states spent over 

80 percent of subpart 2 dollars on the four mandated service categories—

family support, family preservation, family reunification, and adoption 

promotion and support services. States reported funding services with 

subparts 1 and 2 that serve similar populations—primarily children at risk 

of abuse and neglect and their parents, as well as children living in foster 

care and their parents. While none of the four states we visited could 

provide data on the extent to which the same families participated in 

services funded by subparts 1 and 2, officials in three of these states 

believed that the two subparts generally served the same types of children 

and families. Officials in almost all HHS regional offices said that they 

believe that the two subparts offer a good balance in allowing states some 

flexibility to address state needs and targeting some federal funds toward 

services to keep families together. 

HHS’s oversight focuses primarily on states’ overall child welfare systems 

and outcomes, but the agency provides relatively little oversight specific to 

Results in Brief 
Page 4 GAO-03-956 Title IV-B Child Welfare Services 

subpart 1. For example, HHS regional offices work with states to establish 

overall goals to improve the safety, permanency, and well-being of 

children and measure progress toward those goals. Using its CFSR 

process, HHS also evaluates how well states are achieving positive 

outcomes for children and has found that many states do not have strong 

outcomes with regard to providing the services families need. However, 

HHS has limited knowledge about how states spend their subpart 1 funds. 

HHS does not collect data on subpart 1 expenditures, requiring instead 

that states submit annual estimates about how they plan to use their 

subpart 1 funds in the upcoming year. HHS regional offices reported that 

they review these estimates for relatively limited purposes, such as 

ensuring that states provide required matching funds. Several HHS 

officials noted that they do not review the spending plans for subpart 1 as 

closely as subpart 2 because subpart 1 has few restrictions on how funds 

can be used. We also found that HHS regional offices pay little attention to 

statutory limits on the use of subpart 1 funds for foster care maintenance 

and adoption assistance payments.6

 For example, 9 of HHS’s 10 regional 

offices do not monitor states’ compliance with these limits. As a result, 

HHS approved projected 2002 spending plans for 15 states with planned 

spending amounts that exceeded these limits. In response to our survey, 

10 states reported a total of over $15 million in actual 2002 subpart 1 

expenditures that exceeded the spending limits and were thus out of 

compliance with the law. 

Little research is available on the effectiveness of unique services funded 

by subpart 1 at the state level because few states have evaluated these 

services. While our survey data reveal no unique categories of services 

funded by subpart 1 on a national level, 37 states generally reported 1 or 

2 categories of services that were uniquely funded by subpart 1 within 

their state—that is, they used subpart 1, but not subpart 2, to fund services 

in particular categories. The most common unique categories were CPS, 

foster care maintenance payments, and staff salaries. Within the CPS 

category, for example, unique services include professional assessments of 

a caregiver’s parenting skills, telephone hotlines to report child abuse and 

neglect, and short-term shelter placement services. We contacted the 

 6

The statutory limit also includes payments for child care services required due to a 

parent’s employment or training needs. However, only 2 states reported any planned 

subpart 1 spending on this type of child care service for fiscal year 2002. For this report, 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. 
Page 5 GAO-03-956 Title IV-B Child Welfare Services 

states with unique service categories other than administration, salaries, 

and foster care maintenance and adoption assistance payments and none 

of these states had conducted rigorous evaluations of these services, 

although several states provided some outcomes data for the services 

included in these categories. Our literature review on the effectiveness of 

child welfare practices identified research for some of these unique 

service categories, such as certain family preservation programs, but only 

two specific services included in a unique subpart 1 category were 

identified in the research. For example, research on a service that works 

with parents to prepare their children for school and to enhance parentchild interactions has shown mixed results. 

We are recommending that the Secretary of HHS (1) provide the necessary 

guidance to ensure that HHS regional offices are providing appropriate 

oversight of subpart 1, (2) 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, 

and (3) use the information gained through enhanced oversight of subpart 

1 to inform its design of the child welfare option that would allow states to 

use Title IV-E funds for the same range of services allowed under 

Title IV-B. HHS’s Administration for Children and Families (ACF) 

generally agreed with our findings, but did not fully concur with our 

recommendations. While ACF agreed with our recommendation to provide 

the necessary guidance to ensure that its regional offices monitor states’ 

use of Title IV-B subpart 1 funds, it said that these limits no longer serve a 

useful purpose. ACF disagreed with our recommendation to consider 

collecting data on subpart 1 expenditures. ACF believes its current level of 

oversight is commensurate with the scope and intent of subpart 1, noting 

that its oversight efforts are more appropriately focused on the CFSR 

process. We believe, however, that assessing the feasibility of collecting 

some basic data on states’ subpart 1 expenditures could enhance ACF’s 

overall oversight of states’ child welfare operations and outcomes. ACF 

did not comment on our recommendation to use such data to inform the 

design of its child welfare option. 

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. 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. No federal eligibility 

criteria apply to the children and families receiving services funded by 

Background 
Page 6 GAO-03-956 Title IV-B Child Welfare Services 

Title IV-B. The amount of subpart 1 funds a state receives is based on its 

population under the age of 21 and the state per capita income, while 

subpart 2 funding is determined by the percentage of children in a state 

who receive food stamps. 

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. Title IV-B funding is 

relatively small compared with the other federal and state funds used for 

child welfare services. According to the most recent data available, states 

spent an estimated $10.1 billion7

 in state and local funds for child welfare 

services in state fiscal year 2000, while federal Title IV-E expenditures in 

federal fiscal year 2000 were $5.3 billion. In comparison, Title IV-B 

appropriations in federal fiscal year 2000 were $587 million. Title IV-E8

provides an open-ended individual entitlement for foster care maintenance 

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

for all foster children whose parents meet certain federal eligibility 

criteria.9

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

foster children with special needs.10 States may choose to use Title IV-B 

funds to provide foster care maintenance or adoption assistance payments 

 7

Urban Institute, The Cost of Protecting Vulnerable Children III: What Factors Affect 

States’ Fiscal Decisions? (Washington, D.C.: n.d.). 

8

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. 

9

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 AFCD 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 for the child, 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. 

10Special 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. 
Page 7 GAO-03-956 Title IV-B Child Welfare Services 

for children without regard to their eligibility for these payments under 

Title IV-E.11

The Administration for Children and Families within HHS 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 are responsible for providing direct 

oversight of state child welfare systems. 

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 a 

review of statewide data, interviews with community stakeholders and 

some families engaged in services, and a review of a sample of cases, 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. 

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: 

• protect and promote the welfare of all children; 

• prevent or remedy problems that may result in the abuse or neglect of 

children; 

 11Foster care maintenance payments funded by Title IV-B would require 25 percent in 

matching state funds. 

Subpart 1 
Page 8 GAO-03-956 Title IV-B Child Welfare Services 

• prevent the unnecessary separation of children from their families by 

helping families address problems that can lead to out-of-home 

placements; 

• reunite children with their families; 

• place children in appropriate adoptive homes when reunification is not 

possible; and 

• 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. 

When the Congress enacted the Adoption Assistance and Child Welfare 

Act of 1980, it established a dollar cap on the amount of subpart 1 funds 

that states could use for certain services and created Title IV-E of the 

Social Security Act. This legislation 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. While appropriations for subpart 1 

increased from $56.5 million in 1979 to $163.6 million in 1981, the law 

requires that the total of subpart 1 funds used for foster care maintenance, 

adoption assistance, and child care payments 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.12 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. 

In 1993, the Congress established the family preservation and family 

support program under Title IV-B subpart 2, authorizing grants to states to 

provide two categories of services: family preservation and communitybased family support services. The Adoption and Safe Families Act of 

1997 reauthorized the program, renaming it Promoting Safe and Stable 

Families and adding two new service categories: adoption promotion and 

support services and time-limited family reunification services. Through 

 12Staff 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). 

Subpart 2 
Page 9 GAO-03-956 Title IV-B Child Welfare Services 

fiscal year 2006, the Congress has authorized $305 million in mandatory 

funding for subpart 2 and up to $200 million annually in additional 

discretionary funding. In fiscal year 2002, the Congress appropriated 

$70 million in discretionary funding for the program.13

The definitions of the four subpart 2 service categories are: 

• 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 

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. 

These services are similar to those allowed under subpart 1, although the 

range of services allowed under subpart 2 is more limited in some cases. 

 13Some subpart 2 funds are reserved for specific activities. For example, $10 million in 

mandatory funds and 3.3 percent of discretionary funds in each fiscal year are reserved for 

grants to state courts to improve child welfare proceedings. In addition, 1 percent of 

mandatory funds and 2 percent of discretionary funds are reserved for grants to Indian 

tribes. 
Page 10 GAO-03-956 Title IV-B Child Welfare Services 

For example, time-limited family reunification services can only be 

provided during a child’s first 15 months in foster care, while no such 

restriction is placed on the use of subpart 1 funds. In addition, 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. By statute, states can spend no more than 10 percent of 

subpart 2 funds on administrative costs. A congressional document notes 

that states already had the flexibility to use subpart 1 funds for family 

support and family preservation services, but that few states used a 

significant share of these funds for these services.14 In creating 

subpart 2, the Congress did not revise any components of subpart 1. 

To receive Title IV-B funds, states are required to submit a 5-year child and 

family services plan to HHS. These plans have a number of specific 

reporting and procedural requirements. While several of the requirements 

are similar for subparts 1 and 2, states are required to provide information 

about more aspects of their child welfare systems under subpart 1. Some 

of the major requirements are outlined in table 1. 

 14Staff 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). 

State Plan Requirements 

for Subparts 1 and 2 
Page 11 GAO-03-956 Title IV-B Child Welfare Services 

Table 1: Selected Requirements to Obtain Grants under Subparts 1 and 2 of Title IV-B 

Subpart 1 Subpart 2 

To receive subpart 1 funding, states must submit to HHS a 5-

year plan outlining the goals of the child welfare agency and 

annual reports describing the progress made toward those 

goals. In this plan, states must: 

• To receive subpart 2 funding, states must submit to HHS a 5-year 

plan outlining the goals of the child welfare agency and annual 

reports describing the progress made toward those goals. In this 

plan, states must: 

• Specify the goals that will be accomplished by the end of 

the 5-year plan, specific and measurable objectives that will 

be undertaken to achieve each goal, and describe the 

methods to be used in measuring annual progress in 

meeting these goals. 

• Specify the goals that will be accomplished by the end of the 5-year 

plan, specific and measurable objectives that will be undertaken to 

achieve each goal, and describe the methods to be used in 

measuring annual progress in meeting these goals. 

• Describe the child welfare services provided and the 

geographic areas where they are available. 

• Describe the child welfare services provided and the geographic 

areas where they are available and the populations to be served. 

• Describe the steps taken to provide child welfare services 

and to make progress in developing new services and 

expanding access to services. 

• Describe how subpart 2 funds will be used to develop or expand 

services covered by subpart 2. 

• Consult with appropriate public and community-based 

organizations in designing programs. 

• Consult with appropriate public and community-based 

organizations in designing programs. 

• Ensure that the state will administer the plan in accordance 

with methods determined by HHS to be proper and 

efficient. 

• Ensure that the state will administer the plan in accordance with 

methods determined by HHS to be proper and efficient. 

• Provide reports and participate in evaluations as required 

by HHS. 

• Provide reports and participate in evaluations as required by HHS. 

• Describe activities undertaken for children adopted from 

other countries and report certain data on those children 

who enter state custody due to the disruption or dissolution 

of such an adoption. 

• Ensure that the safety of children will be the paramount 

concern in administering and conducting services. 

• Ensure that the state will develop plans for the effective use 

of cross-jurisdictional resources to facilitate timely 

adoptions for children waiting to be adopted. 

• Ensure that, at the end of the 5-year period covered by the 

state’s child welfare plan, states review with appropriate public 

and community-based organizations the progress made 

toward goals, publish a report on the progress, and develop 

new goals for the program. 

• Provide for the diligent recruitment of foster and adoptive 

families that reflect the racial and ethnic diversity of children 

in the state who need foster or adoptive homes. 

• Ensure that federal funds provided under subpart 2 will not 

supplant federal or nonfederal funds for existing services that 

promote the purposes of subpart 2. 

• Describe specific measures taken to comply with the Indian 

Child Welfare Act. 

• Ensure that no more than 10 percent of expenditures will be 

used for administrative costs. 

• Ensure that the state has implemented policies and 

procedures that allow expeditious decisions about 

permanent placement for children who are abandoned at 

birth. 

• Explain how organizations were selected to provide family 

support services and how these organizations meet the 

requirement that family support services be community based. 

• Ensure that the state operates a case review system for 

each child in state-supervised foster care. 

• Ensure that the state operates a statewide information 

system to provide information about children in foster care. 

Source: Title IV-B of the Social Security Act and 45 CFR 1357. 

Note: Bolded text indicates where subpart 2 requirements differ from those pertaining to subpart 1. 
Page 12 GAO-03-956 Title IV-B Child Welfare Services 

Federal child welfare funding has long been criticized for entitling states 

to reimbursement for foster care placements, while providing little funding 

for services to prevent such placements. HHS is currently developing a 

legislative proposal to give states more flexibility in using Title IV-E foster 

care funds for such preventive services. Under this new proposal, states 

could voluntarily choose to receive a fixed IV-E foster care allocation 

(based on historic expenditure rates) over a 5-year period, rather than 

receiving a per child allocation. The fixed allocation would be an estimate 

of how much a state would have received in Title IV-E foster care 

maintenance funds. States could use this allocation for any services 

provided under Titles IV-B and IV-E, but would also have to fund any 

foster care maintenance payments and associated administrative costs 

from this fixed grant or use state funds. 

Since 1994, HHS has also been authorized to establish child welfare 

demonstrations that waive certain restrictions in Titles IV-B and IV-E and 

allow states a broader use of federal funds. States with an approved 

waiver must conduct a formal evaluation of the project’s effectiveness and 

must demonstrate the waiver’s cost neutrality—that is, a state cannot 

spend more in Title IV-B and IV-E funds than it would have without the 

waiver. Projects generally are to last no more than 5 years. HHS’s authority 

to approve these waivers is scheduled to expire at the end of fiscal year 

2003. 

On a national level, our survey showed that the primary emphases of 

subparts 1 and 2 vary somewhat, but the range of services offered and the 

types of families served overlap significantly. According to our survey data 

for fiscal year 2002, states spent subpart 1 funds most frequently on the 

salaries of child welfare agency staff—primarily social work staff who can 

provide a variety of services, such as CPS investigations, recruiting foster 

parents, and referring families for needed services. The next three largest 

categories—administration and management expenses, CPS services, and 

foster care maintenance payments—accounted for about 43 percent of 

subpart 1 funding. Subpart 2 funds, in comparison, were used primarily to 

fund programs within its required service categories—family support, 

family preservation, family reunification, and adoption promotion and 

support services. Some social work staff whose salaries were funded with 

subpart 1 may provide similar services to families as the staff in these 

programs funded by subpart 2. On a national basis, however, no service 

category was solely funded by either subparts 1 or 2. The programs funded 

by subpart 1 and 2 dollars served similar types of children and families. 

States used the majority of funds from each subpart to provide services to 

Alternative Financing 

Mechanisms for Child 

Welfare Services 

The Primary 

Emphases of These 

Subparts Vary 

Somewhat, but the 

Range of Services and 

Types of Families 

Served Overlap 

Significantly 
Page 13 GAO-03-956 Title IV-B Child Welfare Services 

children at risk of abuse and neglect and their parents, as well as foster 

children and their parents. Officials in most HHS regional offices said that 

they believe that the current structure of Title IV-B offers a good balance 

in allowing states some flexibility to address state needs and targeting 

some federal funds toward services to keep families together and prevent 

children from entering foster care. 

Although no category of service is funded solely by either subparts 1 or 

2 dollars, somewhat different spending patterns emerged with regard to 

the distribution of these funds among the categories. The states 

responding to our survey reported spending about 28 percent of subpart 1 

funds in fiscal year 2002 on the salaries of child welfare agency staff, with 

an additional 43 percent used for administration and management 

expenses, foster care maintenance payments, and direct CPS services (see 

table 2). In comparison, states used over 80 percent of subpart 2 dollars to 

fund services in its mandated service categories—family support, family 

preservation, family reunification, and adoption promotion and support 

services.15 However, neither subparts 1 nor 2 funded a unique category of 

service at the national level.16 For example, states typically reported using 

subpart 1 to fund CPS programs; however, 5 states used subpart 2 dollars 

to fund programs in this category. 

 15The adoption promotion and support services category includes the recruitment and 

training of foster and adoptive parents, adoption support services, and adoption 

preservation services. 

16Although no unique service categories are funded exclusively by either subpart at the 

national level, states did report individual service categories that were funded by subpart 1, 

but not subpart 2. However, no national trend emerged among the types of services that 

were funded uniquely by subpart 1. 

While the Distribution of 

Funds Differs Somewhat, 

Some Overlap in Service 

Categories Exists 
Page 14 GAO-03-956 Title IV-B Child Welfare Services 

Table 2: 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. 
Page 15 GAO-03-956 Title IV-B Child Welfare Services 

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. 

Subpart 1 dollars 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 (see fig. 1).17 During our site visit, Washington 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, social workers who provide ongoing case 

management and support services to families involved with the child 

welfare agency due to concerns about abuse or neglect, social work 

supervisors, and clerical support staff. While states also reported using 

subpart 2 funds for staff salaries, only 2 percent of subpart 2 dollars were 

used for this purpose. This comparison may underestimate the overlap in 

services funded by subparts 1 and 2, however, because much of the costs 

of programs funded by subpart 2 is likely attributable to staff salaries. 

Similarly, some social work staff whose salaries are funded by subpart 1 

likely provide a variety of services, such as family preservation services, 

recruiting foster families, and referring families for needed services, some 

of which may be similar to services funded by subpart 2. 

 17The 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. 
Page 16 GAO-03-956 Title IV-B Child Welfare Services 

Figure 1: Percentage of Subpart 1 Funds Used for Staff Salaries Dedicated to Each 

Type of Staff Position in Fiscal Year 2002 

Notes: Some states spent subpart 1 funds on salaries, but could not provide information on the types 

of staff positions included. 

Percentages do not total to 100 due to rounding. 

Administration and management comprised the second largest category of 

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

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

agency staff, and staff training.18 Ohio, for example, used most of its 

subpart 1 dollars to fund state and county child welfare agency 

administrative expenses. In contrast, states spent less than 5 percent of 

their subpart 2 funds on administration and management. 

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 

 18This 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. 

47%

CPS social workers/staff

20% All other social workers

20%

•

Other staff

• • • •

•

•

3%

Supervisory social workers

3%

Legal services staff

4%

Administrative staff

4%

Management staff

Source: GAO survey data.
Page 17 GAO-03-956 Title IV-B Child Welfare Services 

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 or when 

a child runs away from a foster home. In comparison to states’ use of 

subpart 1 funds, states reported using less than 1 percent of their 

subpart 2 dollars to fund programs within this service category. 

States 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 

for reimbursement through Title IV-E. For instance, New Jersey officials 

reported spending over 50 percent of the state’s subpart 1 funds on foster 

care maintenance payments. Seventeen states spend subpart 1 funds on 

foster care maintenance payments, while only 2 states reported using 

subpart 2 funds for this purpose, accounting for less than 1 percent of total 

subpart 2 expenditures. 

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

services. These services included mentoring programs to help pregnant 

adolescents learn to be self-sufficient, financial assistance to low-income 

families to help with rent and utility payments, and parenting classes, child 

care, and support groups provided by a community-based resource center. 

One California county we visited used subpart 2 to fund a network of 

family support services with the goal of strengthening communities and 

keeping families from becoming involved with the child welfare system. 

Funds were granted to community groups to provide support and improve 

the healthy development of families for different populations, such as 

grandparent caregivers and adolescent mothers. 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. 

Over one-third of the states responding to our survey also reported using 

subpart 1 funds to provide family support services similar to those funded 

by subpart 2, although family support services only accounted for 

8 percent of subpart 1 expenditures. For example, New Jersey transferred 

about 27 percent of its subpart 1 funds to local child welfare agencies to 
Page 18 GAO-03-956 Title IV-B Child Welfare Services 

provide family support services, which included parent education classes, 

transportation, and mentoring for children. 

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 

some cases, services provided in this category were similar to those in the 

family support category, but were intended to help keep families together. 

For example, Florida funded several neighborhood resource centers, 

which provide child care, parenting classes, adult education and training 

opportunities, mental health services, transportation services, and a food 

pantry. Although states primarily used subpart 2 dollars to provide these 

services, states also reported using approximately 2 percent of subpart 1 

funds on family preservation services. 

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 care 

for adoptive parents. 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. 

Similarly, Florida funded adoption support services for children with 

special needs who are awaiting adoption, including counseling, behavior 

modification, tutoring, and other services to expedite the adoption 

process. In contrast, less than 1 percent of subpart 1 dollars were used to 

provide adoption support and preservation services. 

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. One county we visited in 

California used subpart 2 funds for a shared family care program, in which 

the parent and child are placed together in a mentor home. The mentor 

provides a role model for good parenting behavior and provides hands-on 
Page 19 GAO-03-956 Title IV-B Child Welfare Services 

parenting guidance to keep the family together, while a case manager 

ensures that family members receive services to address problems that 

could lead to the removal of the child, such as substance abuse or 

homelessness. Subpart 1 funds were used much less frequently for family 

reunification services; states reported using 1 percent of subpart 1 funds 

for these services. 

Significant overlap exists among the types of children and families served 

by these subparts, although certain populations are more closely 

associated with a particular subpart. Services funded by each subpart 

predominantly targeted children at risk of abuse or neglect and their 

parents, as well as children in foster care and their parents. States 

responding to our survey reported that services funded by subpart 1 in 

fiscal year 2002 most frequently served children living in foster care and/or 

their parents, while 9 percent of subpart 2 funds are used for services that 

target the same population (see table 3). Similarly, while subpart 2 

services most commonly targeted children at risk of abuse and neglect 

and/or their parents, about 17 percent of subpart 1 funds were also used 

for services aimed at this population. In addition, 9 percent of subpart 1 

funds and 11 percent of subpart 2 funds were used to fund services 

intended for both of these types of families. 

Significant Overlap Exists 

among the Types of 

Children and Families 

Served by Subparts 1 and 2 
Page 20 GAO-03-956 Title IV-B Child Welfare Services 

Table 3: Populations Targeted by Services Funded by Subparts 1 and 2 of Title IV-B in Fiscal Year 2002 

Subpart 1 Subpart 2 

Population served No. of services 

Amount of 

subpart 1 

funding

Percent of 

funding No. of services 

Amount of 

subpart 2 

funding 

Percent of 

funding 

Children in foster care 

and/or their parents 33 $34,732,673 42 46 $15,218,065 9 

Children at risk of child 

abuse and neglect 

and/or their parents 28 13,751,328 17 133 73,996,404 44 

Programs serving 

multiple populations 21 11,949,444 14 43 18,119,756 11 

Children at risk of child 

abuse or neglect and/or 

their parents and 

children living in foster 

care and/or their parents 12 7,077,448 9 39 17,606,172 11 

Programs serving all 

populations 5 7,513,368 9 7 11,028,464 7 

Children waiting for 

adoption, adopted 

children, and adoptive 

parents 9 4,153,271 5 54 27,340,372 16 

Other populations, such 

as delinquent teens and 

foster parents 10 3,492,142 4 16 3,336,070 2 

Totala 118 $82,669,674 100% 338 $166,645,301 100% 

Source: GAO survey. 

Note: This analysis is based on survey responses from 35 states with state-administered child welfare 

systems that provided population data for their subpart 1 services and 39 states with stateadministered child welfare systems that provided population data for their subpart 2 services. 

Therefore, these data can only be generalized to states with state-administered child welfare 

systems. 

a

The dollar totals in this table do not match those in table 2 because we do not have population data 

from states that completed the county-administered survey. Due to the differences in information 

available from states with county-administered child welfare systems, we did not request data in the 

first county-administered survey on the types of children and families who received services funded 

by Title IV-B—these data were to have been obtained on the second survey. In addition, we did not 

collect data on the populations served for the category of staff salaries, and we excluded population 

data for the category of administration and management expenses since these expenses are not 

targeted to a particular population of children and families. 

The overlap in populations observed at the national level can also be seen 

when looking at the children and families targeted by individual states. We 

found that individual states frequently funded programs with each subpart 

that served the same types of children and families. For example, all 
Page 21 GAO-03-956 Title IV-B Child Welfare Services 

20 states that used subpart 1 dollars to fund services for children at risk of 

abuse or neglect and/or their parents also used subpart 2 dollars to fund a 

program serving this same population type (see table 4). Alaska, for 

instance, used subpart 1 dollars to fund a broad family support program, 

which provided services to children at risk of abuse and neglect and their 

parents. The state also used subpart 2 funds to provide another family 

support program, which provides similar services to the same types of 

children and families. In addition, 17 states funded one or more individual 

services with funds from both subparts, so that subparts 1 and 2 were 

serving the same children and families. 

Table 4: Number of States Using Funds from Each Subpart of Title IV-B to Target Specific Populations 

Population type 

Number of states providing 

services for this population 

type with subpart 1 fundsa

Number of states 

providing services 

for this population 

type with subpart 2 

fundsa

Number of states 

providing services for 

this population type 

with both subpart 1 

and subpart 2 funds 

Children in foster care or parents with children 

living in foster care 20 29 15 

Children at risk of child abuse or neglect and 

parents with children at risk of child abuse and 

neglect 20 34 20 

Children waiting for adoption, adopted children, 

and adoptive parents 8 26 5 

Foster parents 5 7 3 

Source: GAO survey. 

Note: This analysis is based on survey responses from 35 states with state-administered child welfare 

systems that provided population data for their subpart 1 services and 39 states with stateadministered child welfare systems that provided population data for their subpart 2 services. 

Therefore, these data can only be generalized to states with state-administered child welfare 

systems. Due to the differences in information available from states with county-administered child 

welfare systems, we did not request data in the first county-administered survey on the types of 

children and families who received services funded by Title IV-B—these data were to have been 

obtained on the second survey. 

a

We did not collect data on the populations served for the category of staff salaries. In addition, we 

excluded population data for the category of administration and management expenses since these 

expenses are not targeted to a particular population of children and families. 

In our second survey, we requested more detailed information about the 

populations served by programs funded by subparts 1 and 2, such as 

demographic and socioeconomic characteristics. However, few of the 

17 states responding to the second survey were able to provide this kind of 

data. When asked about selected subpart 1 services, 10 of the 17 states 

were able to estimate the extent to which the same children and families 
Page 22 GAO-03-956 Title IV-B Child Welfare Services 

receiving the identified service funded by subpart 1 also received services 

funded by subpart 2. Of children and families receiving the identified 

subpart 1 service, 

• four states reported that generally none or almost none of the recipients 

also received a service funded by subpart 2, 

• three states reported that generally less than half of the recipients received 

subpart 2 services, 

• one state reported that all or almost all recipients received subpart 2 

services, and 

• two states provided varying estimates for different subpart 1 services.19

While none of the states we visited were able to provide data about the 

extent to which the same children and families were receiving services 

funded by both subparts 1 and 2, state officials in each of these states 

recognized some overlap among the types of populations participating in 

these services. Officials in California and New Jersey told us that they use 

subpart 1 for services to families that are involved with the child welfare 

agency due to a report of abuse or neglect, while services funded by 

subpart 2 target a broader population, including families who are at risk of 

abusing their children. However, while some of the subpart 2 programs 

these officials described focused on this at risk population, many of them 

were targeted to families who were already involved with the agency. 

Officials at a California child welfare agency told us that all of the services 

provided by subparts 1 and 2 are targeted toward the same high-risk 

communities in which many people are involved with the agency, and they 

considered it likely that families receiving subpart 1 services have also 

received subpart 2 services in the past or will at some time in the future. 

Washington officials noted that children and families involved with the 

child welfare agency may receive multiple services, some of which may be 

funded by subpart 1 and some of which may be funded by subpart 2. 

Finally, although Ohio does not track clients served, one state official 

estimated that the types of children and families served by the programs 

funded by subparts 1 and 2 overlap by 100 percent. 

 19The second survey requested information about the three services receiving the largest 

portions of subpart 1 funding, so states generally only estimated the extent to which 

recipients of these services also received services funded by subpart 2. These data are not 

necessarily representative of other subpart 1 services or other states. 
Page 23 GAO-03-956 Title IV-B Child Welfare Services 

One New Jersey state official described the services funded by subparts 1 

and 2 as part of a continuum of child welfare services, such that some 

population overlap is to be expected. In New Jersey, services funded by 

subpart 1 target families who are experiencing difficulties that may 

jeopardize the safety and well-being of their children. Programs funded by 

subpart 2 may also serve these families. However, they also target families 

who are not currently having difficulties, but who could become involved 

with the child welfare agency in the future. In addition, some subpart 2 

programs serve adopted children, many of whom were previously involved 

with the child welfare agency and received services funded by subpart 1. 

None of the states we visited could provide data on the numbers of 

children and families who participated in services funded by subparts 1 

and 2 dollars. 

Given the overlap observed between the two subparts, we discussed the 

potential advantages and disadvantages of consolidation with HHS 

regional officials and asked states for their perspective on our survey. 

Officials in almost all of HHS’s regional offices said that Title IV-B should 

maintain its current balance between allowing states some flexibility and 

targeting some resources toward prevention. Officials in all regional 

offices told us that they believe states need some flexibility to use Title IVB funds to address state specific child welfare needs as is currently the 

case under subpart 1. One regional office noted that subpart 1 gives states 

the flexibility to address unexpected circumstances affecting the child 

welfare system—for example, by developing substance abuse treatment 

programs to address the needs of parents affected by the cocaine epidemic 

of the 1980s. Similarly, officials in three states we visited felt strongly that 

the flexibility to direct the use of subpart 1 funds for state priorities was 

important and they would not want to lose this flexibility in any 

consolidated program. Our survey results also indicate that the flexibility 

to use subpart 1 to meet the needs of their child welfare systems is 

important to states. For example, when asked about their preference 

between subparts 1 and 2 with regard to different program components, 

24 and 26 states, respectively, reported that they preferred subpart 1 when 

considering (1) spending restrictions on the percentage of funds that can 

be used for specific services and (2) allowable spending categories (see 

fig. 2). When asked about the advantages and disadvantages of Title IV-B’s 

current structure, several states cited the spending restrictions of subpart 

2 as a disadvantage, while a couple of states mentioned the flexibility 

associated with subpart 1 as an advantage. 

HHS Officials Believe Title 

IV-B Offers Flexibility 

While Targeting Prevention 

Activities, and States 

Emphasize the Need for 

Flexibility 
Page 24 GAO-03-956 Title IV-B Child Welfare Services 

Figure 2: Survey Data on States’ Preferences between Subparts 1 and 2 of Title IV-B 

for Different Program Components 

Note: Data on state preferences are based on responses from 46 states, although they did not all 

respond to each item. 

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. One 

state we visited expressed opposition to consolidation for this reason, 

arguing that keeping a separate subpart 2 was important to ensure that 

states fund some prevention services. State and county officials in this 

state noted that subpart 2 represents an important federal investment in 

prevention services and expressed concern that states would use all 

available funds to provide services to families already involved with the 

child welfare agency unless funds were specifically targeted for services to 

support families at risk of abusing or neglecting their children. In addition, 

0

5

10

15

20

25

30

Formula for 

state grant

Allowable 

spending 

categories

Spending

restrictions

Federal

set asides

Reporting

requirements

Formula for 

Indian tribe 

grants

Subpart 1 preferred

Subpart 2 preferred

Equally preferred

Not applicable

Source: GAO survey data.

Number of states expressing a preference
Page 25 GAO-03-956 Title IV-B Child Welfare Services 

on our survey, several states cited the prevention focus of subpart 2 as an 

advantage of Title IV-B’s current structure. 

Officials in 8 of HHS’s regional offices said that they believe that the 

current structure of Title IV-B offers a good balance between flexibility 

and targeting resources toward prevention.20 Officials in the other 

2 regional offices told us that Title IV-B provides a good mix of flexibility 

and a focus on services considered to be federal priorities. One regional 

office noted that a consolidated Title IV-B program could be structured to 

offer this balance. For example, a consolidated program could require 

some minimum spending levels for the current subpart 2 categories, but 

also set aside some funds that states could use for a broader array of child 

welfare services. In addition, most of the regional offices did not believe 

that consolidation would lead to any significant administrative savings. 

For example, several regional offices explained that consolidating the 

subparts would not reduce HHS’s oversight responsibilities, while another 

noted that consolidation would have little impact on HHS regional or state 

offices, which are staffed and organized to manage multiple sources of 

funding. Another regional office noted that the planning and reporting 

requirements for the two subparts are already consolidated in the planning 

documents states submit to HHS. 

State and local child welfare officials in one state, along with officials at 

2 HHS regional offices, commented that increasing the funds available for 

service provision was more critical than consolidating the two subparts. 

They believe 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, rather than paying primarily for foster care maintenance 

payments as it currently does. Since 1994, states have been able to apply 

for demonstration waivers to use federal child welfare funds to test 

innovative foster care and adoption practices without regard to certain 

restrictions in Titles IV-B and IV-E. For example, four states are using 

demonstration waivers to create fixed Title IV-E budgets for counties 

within the state in which funds can be used more flexibly for prevention 

and community-based services not traditionally reimbursed by Title IV-E. 

 20Several officials noted that allowing a little more flexibility with the 20 percent spending 

requirement for subpart 2 could provide some additional flexibility to states without having 

to seek approval from HHS. For example, staff in one regional office suggested that 

requiring states to spend no less than 10 percent and no more than 40 percent of subpart 2 

funds in any service category would offer this additional flexibility. 
Page 26 GAO-03-956 Title IV-B Child Welfare Services 

However, HHS’s authority to approve such waivers is scheduled to expire 

at the end of fiscal year 2003. States may soon have another mechanism to 

use Title IV-E funds to provide preventive services through the child 

welfare option HHS is currently proposing. 

HHS’s oversight focuses primarily on states’ overall child welfare systems 

and outcomes, but the agency provides relatively little oversight specific to 

subpart 1. For example, HHS regional offices work with states to establish 

overall goals to improve the safety, permanency, and well-being of 

children and measure progress toward those goals. However, HHS has 

limited knowledge about how states use their subpart 1 funds. HHS does 

not collect data on subpart 1 expenditures and instead requires states to 

submit annual estimates about how they plan to use their subpart 1 funds 

in the upcoming year. HHS regional offices reported that they review these 

estimates for relatively limited purposes, with several HHS officials noting 

that they do not review the spending plans for subpart 1 as closely as 

subpart 2 because subpart 1 has few restrictions as to how these funds can 

be used. We also found that HHS regional offices pay little attention to 

statutory limits on the use of subpart 1 funds for foster care maintenance 

and adoption assistance payments.21 As a result, HHS approved projected 

2002 spending plans for 15 states that reported planned spending amounts 

that exceeded these spending limits. In response to our survey, 10 states 

reported actual 2002 subpart 1 expenditures that exceeded the spending 

limits by over $15 million in total. 

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. In discussing their oversight of 

subpart 1, several HHS officials at headquarters and in the regional offices 

emphasized the importance of reviewing the overall child welfare system 

and the outcomes achieved, rather than scrutinizing individual programs 

outside of that context. A major component of HHS’s subpart 1 oversight 

is having the regional offices actively work with states to develop 

 21The statutory limit also includes payments for child care services required due to a 

parent’s employment or training needs. However, only two states reported any planned 

subpart 1 spending on this type of child care service for fiscal year 2002. For the purposes 

of this report, 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. 

HHS Focuses 

Oversight on Overall 

Child Welfare System, 

but Has Limited 

Knowledge about 

States’ Use of Subpart 

1 Funds 

HHS Focuses Much of Its 

Oversight on States’ 

Overall Child Welfare 

Systems and Outcomes 
Page 27 GAO-03-956 Title IV-B Child Welfare Services 

appropriate goals for their child welfare systems and ensure that available 

funds, including subpart 1, 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 well-being of children and families. This 5-year plan 

includes a description of services and programs the state will pursue to 

achieve these goals. 

In addition to the 5-year plan, HHS requires states to submit an Annual 

Progress and Services Report (APSR) each year to discuss their progress 

in meeting the goals outlined in their plans and revise the goals as 

necessary. Regional HHS staff review this planning document to ensure 

that they meet all the technical requirements outlined in the annual 

program instructions issued by HHS. For example, states must certify that, 

in administering and conducting services under the 5-year plan, the safety 

of the children to be served shall be of paramount concern. In addition, 

some regional offices reported that they review the state’s objectives and 

goals to determine if they are reasonable, assess the progress the state has 

made in achieving these goals and objectives, and determine whether child 

welfare services are coordinated with the efforts of other agencies serving 

children. Some regional officials noted that states are still struggling to use 

these documents appropriately for planning purposes. These officials told 

us that instead of focusing on outcomes and collecting data to measure 

progress toward those outcomes, frequently states simply describe their 

current programs. 

In addition to reviewing planning documents, all of the regional offices 

consult regularly with states to discuss child welfare issues and provide 

technical assistance.22 For example, the regional office may provide 

guidance on how to comply with specific program regulations or how to 

develop a 5-year plan that will function as a strategic plan for the state’s 

child welfare agency. Two regional offices told us that they also conduct 

site visits to states as part of their oversight. One regional office reported 

visiting states in its region to gain a better understanding of each state’s 

child welfare services. This allows the regional office to share good ideas 

with other states and to ensure that states are working on areas the 

 22In addition, HHS funds eight national resource centers to disseminate information on best 

practices and provide technical assistance to help states implement federal legislation 

intended to ensure the safety, permanent placement, and well-being of children who enter 

the child welfare system. 
Page 28 GAO-03-956 Title IV-B Child Welfare Services 

regional office has identified as in need of improvement. Other regional 

offices reported that they would like to conduct site visits to states under 

their purview, but a lack of travel funds prevented them from doing so. 

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

conform with 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. They consider the CFSR an important 

complement to a state’s planning documents—it gives them 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. 

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

strongly in terms of assessing families to determine what services they 

need and providing those services. While 21 of the 32 states that 

underwent a CFSR in 2001 or 2002 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. When 

HHS reviewed case files, however, it determined that 31 of these states 

needed improvement in terms of assessing family needs and providing 

services to meet those needs. 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. However, the official also pointed out that HHS gives states a 

lot of latitude to determine the most appropriate use of their subpart 1 

funds and that the agency cannot become too involved in state budget 

decisions given the complexities of the budget processes for states. 

HHS has little information about states’ use of subpart 1 funds. Each year, 

HHS requires states to submit a form CFS-101, which includes state 

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). The descriptions provided by 

regional office staff of their review of these estimates indicate that they 

review them for relatively limited purposes. Officials in 4 of the regional 

offices told us that they generally use the CFS-101 data to ensure that 

states request the total amount of subpart 1 funds to which they are 

HHS Has Little Information 

about States’ Use of 

Subpart 1 Funds 
Page 29 GAO-03-956 Title IV-B Child Welfare Services 

entitled and that they comply with the requirement to match 25 percent of 

subpart 1 funds with state funds. Most regional offices indicated that their 

reviews of the CFS-101s focus more on subpart 2 than subpart 1. For 

example, they reported that they review states’ planned subpart 2 

spending more closely to ensure that states are meeting the requirement 

that they spend at least 20 percent of funds on each of the service 

categories and spend no more than 10 percent of funds for administrative 

purposes. Several HHS officials reported that they do not monitor the use 

of subpart 1 funds as closely as other federal child welfare funds due to 

the relatively small funding amount and the lack of detailed requirements 

about how the funds can be used. 

Moreover, the CFS-101 estimates may not provide reliable data as to how 

states are using subpart 1 funds. HHS officials explained that the 

CFS-101 data are estimates and that states’ actual expenditures may vary 

from these estimates, as they address unforeseen circumstances. The 

timing for submitting the CFS-101 also affects how well states can 

estimate their planned subpart 1 spending. HHS requires states to submit 

their initial CFS-101 for the upcoming fiscal year by June 30, which forces 

states to estimate their planned spending before the final spending 

amounts for Title IV-B and other federal funds have been appropriated.23

Some regional officials indicated that they did not know how well states’ 

CFS-101 estimates reflect their actual subpart 1 spending. We did not 

conduct a review of the reasonableness of the data states submit on their 

CFS-101s, but we did identify a few instances that suggested that the data 

are not always accurate. Two states with county-administered child 

welfare systems told us that they do not have reliable data to allow them 

to accurately estimate planned spending.24 A child welfare official in one of 

these states told us that its CFS-101 data represented its “best guess” as to 

how subpart 1 funds will be used, because the state distributes these funds 

to county child welfare agencies and does not collect any data on how the 

 23For example, the CFS-101 for fiscal year 2002 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. 

24While most states administer their child welfare systems at the state level, a handful of 

states delegate administrative responsibility and substantial control to counties or other 

local entities. Several large states, such as California, New York, Ohio, and Pennsylvania, 

are county-administered. 
Page 30 GAO-03-956 Title IV-B Child Welfare Services 

counties use these funds. The other state told us that its current 

CFS-101 data are most likely based on county data from several years 

ago and that counties may now be spending subpart 1 funds on different 

services. 

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

of subpart 1 funds, such as their subpart 1 expenditures for specific 

services.25 As a result, several regional offices noted that they have no way 

of knowing how states actually spend their subpart 1 funds. An official 

from one regional office explained that the only way to determine how a 

state actually uses its Title IV-B funds is to review its financial accounts, 

which HHS does not do. Some regional officials suggested that it would be 

helpful to have actual expenditure data for both Title IV-B subparts, 

especially to determine if states were actually using 20 percent of their 

subpart 2 funds for each of the four required service categories. Three 

regional offices indicated that they have begun asking states to provide 

Title IV-B expenditure data. 

Given that HHS’s subpart 1 oversight focuses primarily on a state’s overall 

child welfare goals and outcomes, the regional offices pay little attention 

to the statutory limits on the use of federal subpart 1 funds for foster care 

maintenance and adoption assistance payments. Most HHS regional 

offices do not review the CFS-101s for compliance with the statutory 

limits. In addition, HHS’s annual program instruction, which details what 

information states must include in their CFS-101 submittals and serves as 

the basis for the regional offices’ review of subpart 1 spending, does not 

mention the subpart 1 limits. 

Only 1 of HHS’s 10 regional offices told us that it compares states’ planned 

subpart 1 spending reported on the CFS-101 with the actual dollar limit for 

each state to ensure that states observe the statutory limits. This office 

used an HHS program instruction for 1979 listing each state’s subpart 1 

allocation to determine the ceiling on foster care maintenance and 

 25States 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. 

HHS Regional Offices Are 

Unaware of Subpart 1 

Spending Limits or Do Not 

Enforce Them 
Page 31 GAO-03-956 Title IV-B Child Welfare Services 

adoption assistance payments.26 In contrast, 5 regional offices were 

unaware that any limits on the use of subpart 1 funds existed, although 

1 of these offices indicated that it generally did not consider it appropriate 

for states to use subpart 1 funds for foster care maintenance payments 

because subpart 1 should be used to fund services for families. 

Nonetheless, this office approved a CFS-101 for 1 state that exceeded the 

statutory limits. Four other regional offices were aware that some 

limitations with regard to foster care maintenance and adoption assistance 

payments existed, but did not ensure that states complied with the limits. 

These 4 regional offices provided several reasons for why they did not 

monitor states’ planned spending for compliance with the subpart 1 limits. 

Two regional offices indicated that HHS had provided no guidance as to 

how such limits should be enforced or that no data were available to 

calculate subpart 1 limits for each state. The third regional office reported 

that it did not have the specific ceiling amounts for each state. However, 

officials in this office said they reviewed planned subpart 1 spending for 

foster care maintenance and adoption assistance payments on the 

CFS-101 to determine if they had increased from the previous year. If the 

amounts had not increased, the regional office assumed that someone had 

checked the amounts previously and that they were within the limits. This 

regional office approved CFS-101s for 2 states in the region that reported 

planned subpart 1 spending for foster care maintenance and adoption 

assistance payments in excess of the limits. The fourth regional office told 

us that, in the past, it had a list of the maximum spending limits for each 

state in its region and that it had previously checked states’ CFS-101s to 

ensure that planned spending did not exceed the limits. However, the 

regional office no longer conducts such reviews; regional officials said that 

they consider the limits to be meaningless because state funds spent on 

child welfare services greatly exceed subpart 1 funds. In other words, any 

attempt to enforce the limits would only lead to changes in how states 

accounted for their funds—if a state was spending $1 million in state funds 

on CPS investigations and $1 million in subpart 1 funds for foster care 

maintenance and adoption assistance payments, the state could simply 

switch state and subpart 1 funding so that state funds paid for the foster 

care maintenance and adoption assistance payments, while subpart 1 

funding paid for CPS investigations. 

 26Each state’s ceiling on the use of subpart 1 funds for foster care maintenance and 

adoption assistance payments is based on its total 1979 subpart 1 expenditures for all types 

of services. 
Page 32 GAO-03-956 Title IV-B Child Welfare Services 

This lack of review led HHS to approve CFS-101s 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 (see fig. 3).27 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 CFS101 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. Moreover, 13 of these 

15 states submitted fiscal year 2003 CFS-101s with planned subpart 1 

spending above the statutory ceiling, which were approved by HHS. 

 27In 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. In addition, we were unable to determine 

whether the planned fiscal year 2002 subpart 1 spending for 5 other states exceeded the 

limits because HHS approved their CFS-101s with flawed data. These 5 states—Iowa, 

Nevada, New Hampshire, New Jersey, and New Mexico—all reported planned subpart 1 

spending for foster care maintenance and adoption assistance payments in excess of the 

statutory limits. However, although states are supposed to separately estimate planned 

spending for the federal portion of their subpart 1 funds on the CFS-101, these 5 states 

included the state match and/or other funds in their estimates. In these cases, we could not 

determine whether the spending plans exceeded the statutory limits for federal subpart 1 

funds. States are allowed to use all of their state matching funds for foster care 

maintenance or adoption assistance payments. 
Page 33 GAO-03-956 Title IV-B Child Welfare Services 

Figure 3: Fifteen States with Approved CFS-101s with Fiscal Year 2002 Subpart 1 Spending Estimates that Exceeded Limits 

for Foster Care Maintenance and Adoption Assistance Payments 

Several regional offices noted that they judge the appropriateness of 

subpart 1 spending on foster care maintenance and adoption assistance 

payments in the context of a state’s overall child welfare system. For 

Ala. Conn. Fla. Ga. Hawaii Kans. Md. Mich. Miss. Nebr. N.Y. Pa. S. Dak. Tenn. Wyo.

Statutory limit on total subpart 1 spending for foster care maintenance and adoption assistance payments

Combined subpart 1 planned spending for foster care maintenance and adoption assistance payments (as

reported on CFS-101)

Source: GAO analysis of HHS data.

Dollars in millions

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000
Page 34 GAO-03-956 Title IV-B Child Welfare Services 

example, these 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 they would, however, ask a state to 

reconsider its funding strategy if the state were performing poorly. 

However, many of the states with approved CFS-101 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 12 of the 

15 states with approved CFS-101s 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 11 of 

the 12 states. In addition, 6 of the 12 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.28

We also compared our survey data on states’ fiscal year 2002 subpart 1 

expenditures for foster care maintenance and adoption assistance 

payments with the statutory limits and found that 10 states reported 

spending subpart 1 funds on these payments that exceeded the legal limits 

(see fig. 4). As with their planned spending estimates, states’ subpart 1 

actual spending for foster care maintenance and adoption assistance 

payments exceeded the statutory limits by varying amounts. Michigan, for 

example, reported on our survey that it spent over $6 million on foster 

care maintenance payments in fiscal year 2002—well over its $2.2 million 

limit for such payments—while New Hampshire’s use of subpart 1 for 

foster care maintenance and adoption assistance payments was only about 

$27,000 above its limit. In total, these 10 states reported subpart 1 

expenditures for foster care maintenance and adoption assistance 

payments that exceeded the statutory limits by over $15 million. Our 

survey results may underestimate the number of states with subpart 1 

spending over the statutory limits, because several states reported on our 

survey that they used subpart 1 for foster care maintenance or adoption 

assistance payments, but were not able to identify the specific dollar 

amount of subpart 1 funds used for these purposes. 

 28Nine of the 12 states were also cited as needing improvement in ensuring that needed 

services are accessible to families in all areas of the state and 8 of the 12 states were 

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

needs of individual families. 
Page 35 GAO-03-956 Title IV-B Child Welfare Services 

Figure 4: Ten States That Reported Fiscal Year 2002 Subpart 1 Expenditures Exceeding Limits for Foster Care Maintenance 

and Adoption Assistance Payments 

Four of these 10 states with subpart 1 expenditures over the statutory 

limits were also part of the 15 states with CFS-101s that indicated planned 

Statutory limit on total subpart 1 spending for foster care maintenance and adoption assistance payments

Combined subpart 1 expenditures for foster care maintenance and adoption assistance payments (as 

reported on GAO’s survey)

Source: Analysis of GAO survey and HHS data.

Dollars in millions

$0

Colo. Fla. Kans. Mich. Nev. N.H. N.J. N. Mex. Okla. S. Dak.

$1,000,000

$2,000,000

$3,000,000

$4,000,000

$5,000,000

$6,000,000

$7,000,000
Page 36 GAO-03-956 Title IV-B Child Welfare Services 

spending above the limits.29 The remaining 6 states did not report 

estimated subpart 1 spending over these limits.30 For example, Colorado 

did not report any planned subpart 1 spending for foster care maintenance 

or adoption assistance payments. On our survey, however, the state 

reported using over $3 million in subpart 1 funds for these purposes, well 

over its $700,000 limit. 

Little research is available on the effectiveness of unique services funded 

by subpart 1 because few states have evaluated these services. While our 

survey data revealed no unique categories of services funded by subpart 1 

on a national level, 37 states reported categories of services that were 

uniquely funded by subpart 1—that is, the individual state used subpart 1, 

but not subpart 2, to fund services in a particular category. For example, 

Delaware funded two CPS programs with subpart 1—assessments of a 

caregiver’s parenting ability and legal services to represent the child 

welfare agency in court cases—but did not use any subpart 2 funds for this 

service category. We contacted the states with unique service categories in 

their states (other than administration, staff salaries, adoption assistance 

payments, or foster care maintenance payments) and none of these states 

had conducted rigorous evaluations of these services, although several 

states provided some data on the effectiveness of services included in 

these categories. Our literature review on the effectiveness of child 

welfare practices identified research for some of these unique service 

categories, such as certain types of family preservation programs. With 

two exceptions, however, it did not identify any evaluations of the specific 

services included in these categories. 

The most common service categories for which individual states used only 

subpart 1 funds were CPS, foster care maintenance payments, and staff 

salaries. The 37 states generally reported 1 or 2 unique categories, with 

14 states reporting 1 unique category and 1 state reporting a high of 

 29Of the 15 states with planned spending above the limits, 8 reported subpart 1 

expenditures within the statutory limits, 4 reported subpart 1 expenditures above the 

limits, and 3 did not separately identify foster care maintenance and adoption assistance 

payments on their surveys. 

30Four of the 6 states included state matching funds in their CFS-101 estimates, so we could 

not determine whether the spending plans for those states exceeded the statutory limits. 

Some Unique Subpart 

1 Service Categories 

Exist at the State 

Level, but Little 

Research Exists on 

the Effectiveness of 

These Services 
Page 37 GAO-03-956 Title IV-B Child Welfare Services 

6 categories.31 Examples of unique subpart 1 services in the CPS category 

include specialized investigations of reports of child abuse or neglect, 

telephone hotlines to report incidents of child abuse or neglect, and 

temporary shelter services for children removed from their homes at times 

when no other placement option is available, such as evenings and 

weekends. States also provided other types of services that were funded 

uniquely by subpart 1. For example, Minnesota provided intensive in-home 

services to prevent children from being placed in foster care, North 

Carolina contracted for legal services with the state’s Attorney General’s 

office, and Maine helped adopted youth pay for post-secondary education 

costs. 

Our review of child welfare literature and Internet sites that identified 

promising child welfare practices found few studies that evaluated the 

effectiveness of the specific services that states funded uniquely with 

subpart 1 funds. Based on the information provided on our survey, we 

identified evaluation research on two of these services. Texas used 

subpart 1 to fund its Home Instruction For Parents of Preschool 

Youngsters (HIPPY) Program. The goal of HIPPY is to prevent academic 

underachievement of children when they enter school. HIPPY works with 

parents in their homes or in parent group meetings to increase the degree 

and variety of literacy experiences in the home. The program also seeks to 

prevent child abuse by enhancing parent-child interactions and focuses on 

economically disadvantaged parents who may not be involved in parenting 

programs. While Texas has not formally evaluated this program, the model 

has been evaluated in other states. Strengthening America’s Families, a 

Web site about effective family programs to prevent juvenile delinquency 

funded by the Office of Juvenile Justice and Delinquency Prevention, cites 

HIPPY as a model program for which evaluations have shown positive 

effects on children’s measured competence and classroom behavior at the 

end of second grade for children who participated in HIPPY compared 

with children with no formal preschool experience.32 In addition, a 

1999 article summarizing research on the HIPPY program found mixed 

results. For example, an evaluation in New York found that children 

whose parents participated in HIPPY in 1990 outperformed control group 

 31Virginia did not provide any data on its subpart 2 spending, so we were not able to 

determine whether the state uniquely funded any service categories with subpart 1. 

New York does not receive any subpart 2 funds, so we considered all services funded by 

subpart 1 to be unique. 

32See http://www.strengtheningfamilies.org/html/programs_1999/22_HIPPY.html. 
Page 38 GAO-03-956 Title IV-B Child Welfare Services 

children on measures of classroom adaptation and reading scores 1 year 

later, but children whose parents participated in HIPPY in 1991 had similar 

outcomes as children in the control group. The article suggested that 

variability in how the program is implemented and in parental 

commitment to the program may explain the mixed results.33

Missouri funded an alternative response system with subpart 1 funds, 

which offers assessment services (rather than an investigation) for 

families that are the subject of a report of abuse or neglect when the risk 

to the child is not considered high to determine if the family needs 

services to reduce the risk of harm to the child. By responding to low risk 

reports of abuse or neglect in a nonaccusatory manner, the goal is to 

encourage families to collaborate in identifying their needs and cooperate 

with supportive services. A 1998 evaluation of Missouri counties testing 

the state’s alternative response system found that the safety of children 

was not compromised by the lack of an investigation and that, compared 

to counties that were not using the alternative response system, needed 

services were delivered more quickly, subsequent reports of abuse or 

neglect decreased, and the cooperation of families improved. An 

evaluation of Minnesota’s alternative response systems has also shown 

promising results. For example, initial results from the randomized 

experimental evaluation showed an increase in the use of community 

services with no increase in subsequent reports of abuse or neglect. 

Of the 37 states that reported unique subpart 1 service categories, we 

asked the 22 states with unique subpart 1 service categories other than 

foster care maintenance payments, adoption assistance payments, staff 

salaries, or administration, whether they had evaluated the effectiveness 

of the programs included in their unique categories. None of these states 

had conducted rigorous evaluations of the effectiveness of these services 

using randomly selected control groups.34 One official explained that few 

states can afford to divert resources from providing direct services to 

 33The Future of Children, “The Home Instruction Program for Preschool Youngsters 

(HIPPY)” (Los Altos, CA: Spring/Summer 1999). 

34While few states had evaluated their unique subpart 1 services, 4 of the 17 states 

responding to our second survey indicated that they had evaluated other subpart 1 services 

that were not unique. 
Page 39 GAO-03-956 Title IV-B Child Welfare Services 

conducting formal evaluations of programs, given the tremendous service 

needs of families involved with the child welfare system.35

However, 5 states provided some information on the outcomes of the 

services they funded uniquely with subpart 1. North Dakota used subpart 1 

dollars to uniquely fund a component of its family preservation program—

family focused services—which the state characterized as a family 

reunification service. The state provided us with a draft evaluation report 

of its family preservation program, which includes this specific service. 

The family preservation program is intended for families with children at 

risk of being placed in foster care and offers a range of services, including 

parent aides who provide hands-on parenting education and therapists 

who are available 24 hours a day to work with the family in the home to 

address the issues that may result in the children being removed from the 

home. The evaluation of its total family preservation program found that 

families receiving services and the social worker involved with the families 

both reported improved family functioning upon completion of the 

services compared to their functioning prior to the services. The study also 

found that fewer children were at risk of being placed in foster care upon 

completion of services. However, the evaluation did not include any 

control group to determine if these results would have been achieved if 

families had not received these services.36

Massachusetts used some of its subpart 1 funds to pay for a contractor to 

operate a telephone service for reports of child abuse or neglect that are 

received in the evenings and on weekends. Officials from Massachusetts 

provided an internal study conducted in February 2000 that discussed 

problems with this telephone service, most notably limited staff and 

resources to handle an increasing volume of calls. The report 

recommended several actions to improve the operation of the telephone 

service, including an increase in staff to field telephone calls, upgrading 

 35Some national research exists for some of the unique service categories at the state level; 

however, the extent to which the research is applicable to the specific services in the 

unique subpart 1 categories is difficult to determine. For example, in some cases, the 

service in a unique subpart 1 category was not based on the same model that was evaluated 

or states did not provide sufficient information on our survey to determine whether the 

program was based on this particular model. Therefore, we do not discuss this research in 

our report. 

36A number of evaluations of similar types of family preservation programs have found that 

children in control groups also had low rates of out-of-home placement, raising questions 

about the effectiveness of these services. 
Page 40 GAO-03-956 Title IV-B Child Welfare Services 

the telephone system so that fewer people receive a busy signal, and 

increasing the number of beds available for emergency placements in the 

evenings and on weekends. Arizona also funded its child abuse telephone 

hotline uniquely with subpart 1 funds and provided the following statistics. 

In fiscal year 2003, 69 percent of calls to the hotline were answered 

without any wait. Of the calls that were not answered directly, the average 

wait time was 3.5 minutes and about 13 percent of calls were abandoned. 

In addition, quality assurance staff reviewed over 17,000 calls for which it 

was determined that the report did not meet the state’s criteria for a CPS 

report requiring investigation and changed only 15 of these to a CPS 

report. 

Missouri funded several CPS services with subpart 1 funds, including 

intensive in-home services for children at imminent risk of removal from 

the home- and family-centered services for families for whom an 

investigation determined services are needed to eliminate the risk of harm 

to the child. Missouri provided two annual reports for fiscal year 2002 that 

provide some data on the outcomes of these services. Consumer surveys 

indicated that many families found the intensive in-home services useful, 

and the annual report on the intensive in-home services indicated that 

88 percent of at-risk children were still with their families when services 

ended after approximately 6 weeks. In addition, 79 percent of children 

who exited the program in 2001 were still at home 1 year after services 

ended. With regard to family centered services, the annual report indicated 

that over 70 percent of families had achieved their goals at the time their 

case was closed. Wisconsin used subpart 1 to fund a Youth Aids Program, 

in which the state provides grants to counties to provide services to 

prevent the placement of children in correctional facilities and other outof-home care. The state has not evaluated services provided by the 

counties, but a 1995 report notes that in the first several years of 

operation, this program produced major reductions in institutional 

placements and helped encourage the development of community-based 

resources.37 Over time, however, an increase in youth crime has led to 

large increases in institutional and out-of-home care, so that much of 

Youth Aids funding at the time was reported to be used for out-of-home 

placements. 

 37Ira M. Cutler, Alexandra Tan, and Laura Downs, State Investments in Education and 

Other Children’s Services: Case Studies of State Innovations (n.p.: September 1995), 

http://www.financeprojectinfo.org/Publications/studies.html (downloaded Jul. 8, 2003). 
Page 41 GAO-03-956 Title IV-B Child Welfare Services 

Despite its relatively small funding level compared to other funding 

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

federal commitment to providing supportive services to help preserve and 

reunify families. The primary emphases of the two subparts vary 

somewhat, but the range of services offered and the types of families 

served overlap significantly. In part because of the relatively small funding 

involved and the flexible nature of the funding, HHS does not provide indepth oversight specific to Title IV-B subpart 1. Instead, HHS focuses 

much of its oversight efforts on states’ progress toward the overall goals of 

their child welfare systems and the outcomes achieved by these systems. 

While this type of oversight is appropriate, HHS could provide valuable 

assistance to states by obtaining more concrete data about states’ use of 

these funds and synthesizing these data with CFSR data on states’ 

outcomes with respect to properly identifying the service needs of 

children and families and providing needed services. Such analyses could 

allow HHS to develop information on how investments in certain types of 

services correlate to improved outcomes for children, which could be 

shared with states to help them more effectively target their spending. 

HHS could also use this enhanced knowledge of Title IV-B to help develop 

an appropriate accountability strategy for its newly proposed child welfare 

option. If enacted, the additional spending flexibility proposed—given the 

size of the Title IV-E allocations that would become available for spending 

on a variety of child welfare services—could have a significant impact on a 

state’s child welfare system. Given the limited information available about 

the services funded with subpart 1 and the effectiveness of these services, 

as well as HHS’s findings about the ability of states’ to meet families’ 

needs, ensuring that states use this flexibility to provide effective services 

will be critical to the success of this option. Opportunities also exist for 

HHS to continue to encourage states to conduct evaluations of the 

programs the states implement. 

We recommend 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. In addition, we recommend 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. For example, an analysis of how 

states’ spending patterns correlate to outcomes—both positive and 

negative—from the CFSRs could yield useful information for this purpose. 

Conclusions 

Recommendations 
Page 42 GAO-03-956 Title IV-B Child Welfare Services 

Given that HHS is currently developing the new child welfare option that 

would allow states to use Title IV-E dollars for services similar to those 

provided under Title IV-B subpart 1, we further recommend that the 

Secretary use the information gained through enhanced oversight of 

subpart 1—as well as information it may have on states’ use of subpart 2 

funds—to inform its design of this option. For example, HHS could use 

this information to help states determine the most appropriate services to 

provide under this option. 

We provided a draft of this report to HHS for comment. The Department’s 

Administration for Children and Families provided comments. These 

comments are reproduced in appendix II. ACF also provided technical 

clarifications, which we incorporated when appropriate. 

ACF agreed with our recommendation 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. ACF agreed to provide guidance to the regional 

offices to enable them to enforce the statutory limits on subpart 1 funds. 

However, ACF also noted that this limitation no longer serves a useful 

purpose and is incompatible with the current proposal to offer states 

much more flexibility in using other federal child welfare dollars. ACF said 

that it plans to explore ways to provide states flexibility with respect to 

the subpart 1 limits. 

ACF disagreed with our recommendation to consider the feasibility of 

collecting basic data on states’ use of subpart 1 funds. ACF said that it 

believes that its level of oversight is commensurate with the scope and 

intent of the program and minimizes states’ reporting requirements. 

Rather than using information on Title IV-B expenditures to help states 

most effectively use their resources, ACF believes that its oversight is 

more appropriately focused on the CFSR process, which requires states to 

develop actions in response to weaknesses identified by the CFSR and 

which measures the impact of these actions on actual outcomes. In ACF’s 

opinion, analyzing how states’ spending patterns correlate to CFSR results 

is not useful, given the lack of a direct relationship between the relatively 

small Title IV-B funding levels and the broad outcome areas of safety, 

permanency, and well-being. In addition, ACF noted that any data 

collected on subpart 1 expenditures would be outdated because states 

have 2 years to spend Title IV-B expenditures and are not required to 

report final expenditures until 90 days after the 2-year period has ended. 

Agency Comments 
Page 43 GAO-03-956 Title IV-B Child Welfare Services 

We believe, however, that assessing the feasibility of collecting some basic 

data on states’ subpart 1 expenditures could enhance ACF’s overall 

oversight of states’ child welfare operations and outcomes. While the 

impact of states’ program improvement efforts under the CFSR process is 

unknown because states are just getting these efforts underway, the 

service deficiencies identified by the CFSRs suggest that states could 

benefit from some guidance on the services that are associated with 

positive CFSR outcomes. An analysis of how states’ spending patterns 

correlate to CFSR outcomes need not be limited to subpart 1 spending; 

such an analysis could help to identify effective services (regardless of 

funding source) that are associated with positive CFSR outcomes and help 

states target their subpart 1 and other funding sources more effectively. 

Furthermore, we do not believe that 2-year old data on subpart 1 

expenditures are necessarily outdated; rather, we believe such data would 

provide better information on states’ use of subpart 1 funds than states’ 

current estimates of planned spending. In addition, ACF could request 

expenditure data for a shorter period, such as a year or a quarter or 

whatever time period best fits states’ other reporting requirements. 

ACF did not comment on our recommendation that it use the information 

gained through enhanced oversight to inform its design of its child welfare 

option. However, we believe that guidance on services associated with 

positive CFSR outcomes could also help states that choose to participate 

in the proposed child welfare option to manage their fixed Title IV-E 

funding. ACF also commented on our finding that the services provided 

and families served under subparts 1 and 2 overlap to some extent. 

Specifically, ACF noted that by not permitting the funds, services, and 

families to overlap, ACF would significantly impede the functionality of 

the continuum of child welfare services funded by Title IV-B and other 

federal funding streams and possibly lead to families not receiving needed 

services. While we described the overlap in services provided and families 

served, we did not state or imply that such overlap was inappropriate or 

unnecessary. 

We also provided a draft of this report to child welfare officials in the 

4 states we visited (California, New Jersey, Ohio, and Washington). 

Officials from California and Washington provided a few technical 

clarifications that we incorporated, while New Jersey and Ohio did not 

have any comments. In addition, Washington expressed concern that our 

recommendations for HHS to (1) ensure that the regional offices monitor 

states’ use of subpart 1 funds for compliance with the statutory limits and 

(2) consider collecting data on states’ use of these funds will add to the 

reporting burden of states without providing additional funds to offset that 
Page 44 GAO-03-956 Title IV-B Child Welfare Services 

burden. We recommended that HHS consider the feasibility of collecting 

such data and would expect HHS to take into account the burden placed 

on states in making this decision. 

We are sending copies of this report to the Secretary of HHS, appropriate 

congressional committees, state child welfare directors, selected county 

child welfare directors, and other interested parties. We will also make 

copies available to others upon 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, or wish to discuss this report further, please call 

me at (202) 512-8403 or Diana Pietrowiak at (202) 512-6239. Key 

contributors to this report are listed in appendix III. 

Sincerely yours, 

Cornelia M. Ashby 

Director, Education, Workforce, 

 and Income Security Issues 
Appendix I: Scope and Methodology 

Page 45 GAO-03-956 Title IV-B Child Welfare Services 

To determine how the services provided and populations served under 

subpart 1 compare with those under subpart 2, we surveyed child welfare 

directors in all 50 states and the District of Columbia. We sent a survey to 

all states to obtain information on how they use Title IV-B funds. We also 

sent a second survey to certain states that responded to the first survey. 

We pretested both survey instruments in New Hampshire, Rhode Island, 

and Wisconsin and obtained input from several other states and from a 

Department of Health and Human Services (HHS) official. In January 

2003, we mailed a copy of the first survey to the states, asking for specific 

data on state spending and populations served for subparts 1 and 2, as well 

as their opinions about the current structure of Title IV-B. To address 

differences in the administrative structure and reporting systems of state 

child welfare agencies, a different version of this survey was sent to states 

with county-administered child welfare systems.1

 We received responses 

from 47 states, although some states were unable to provide complete 

information.2

 To encourage as many states as possible to complete the 

survey, we conducted follow-up telephone calls to states that did not 

respond to our survey by the initial deadline. After a state responded to 

the first survey, we mailed the second survey, requesting more detailed 

information on the three services receiving the largest portions of subpart 

1 funding and the three services receiving the largest portions of subpart 2 

funding. The second survey also asked for copies of any existing 

evaluations of the effectiveness of these services. We sent the second 

survey to the 30 states that provided sufficient data on their first survey by 

mid-April 2003 and received responses from 17 states.3

We did not independently verify the information obtained through either 

survey. The responses of the 47 states to the first survey can be used to 

explain how the 50 states and the District of Columbia in general used 

Title IV-B funds. Since we received responses from only 17 states for our 

second survey, they may not be representative of all states. Consequently, 

we have used these data only as examples or for illustrative purposes. As a 

result, we based our analyses of the populations of children and families 

 1

The following 7 states completed the county-administered survey version: Colorado, 

Georgia, Maryland, Minnesota, New York, Pennsylvania, and Wisconsin. 

2

We did not receive responses from the District of Columbia, Indiana, Kentucky, or 

Montana. 

3

The 17 states that responded to the second survey were Arkansas, Delaware, Florida, 

Hawaii, Illinois, Kansas, Louisiana, Massachusetts, New Mexico, North Dakota, Oklahoma, 

South Dakota, Texas, Utah, Vermont, Washington, and Wyoming. 

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

Page 46 GAO-03-956 Title IV-B Child Welfare Services 

served on data from our first survey. However, states that completed the 

county-administered version of the survey did not provide data on the 

types of children and families who received services funded by Title IV-B 

and were not included in these analyses. As a result, the data on 

populations served by subparts 1 and 2 cannot be generalized to states 

with county-administered child welfare systems. 

Data from both surveys were double-keyed to ensure data entry accuracy, 

and the information was analyzed using statistical software. On the first 

survey, we asked states to describe the nature of each service and select 

one service category that best characterized each program funded by Title 

IV-B, using the following choices: child protective services (CPS), family 

support/prevention programs, parent training programs, health programs, 

educational programs, substance abuse programs, counseling and mental 

health services, domestic violence programs, formal family preservation 

programs, family reunification programs, recruitment and training for 

foster/adoptive parents, adoption preservation services, administration 

and management, foster care maintenance payments, adoption subsidy 

payments, and other. 

The data were analyzed using states’ self-identified categories except in 

the following situations: (1) if a state clearly described a program as 

funding salaries for staff at the child welfare agency, we included these 

data under the staff category; (2) if a state used the “other” category for a 

service that clearly fell into one of the existing categories (writing in 

“foster care maintenance payments,” for example), we revised the survey 

response to reflect the actual category; (3) if it appeared that a state 

mistakenly checked the wrong box; for example, we changed the category 

from CPS to family reunification if the program was described as a family 

reunification service; (4) if a state checked multiple categories, we 

reported these programs separately under “multiple responses;” (5) if a 

state did not check any categories, we selected a service category that best 

fit the description of the program and used “other” if the description did 

not clearly fall into one of our categories; and finally (6) if a state clearly 

described the use of Title IV-B funds as administrative, but categorized it 

in another category, we revised the survey to indicate that the funds were 

used for administration and management. Some states explained that Title 

IV-B funds were used to cover administrative expenses for a particular 

program and characterized the use of these funds based on the nature of 

the program. For example, a state might have selected family preservation 

program when Title IV-B funds were used for administrative expenses for 

that program. 
Appendix I: Scope and Methodology 

Page 47 GAO-03-956 Title IV-B Child Welfare Services 

As noted earlier in the report, we recognize that some states may not have 

separately identified administration or management expenses associated 

with a program and may have included these expenses in the program 

costs. For reporting purposes, we combined several service categories for 

which states reported spending small percentages of Title IV-B funds, such 

as parent training and substance abuse services, and reported these 

dollars in the “other” category. 

We recognize that the service categories used are not necessarily mutually 

exclusive. For example, several HHS officials told us that the delineation 

between family support and family preservation services is not clear, so 

that 2 states providing the same services to the same types of children and 

families may report them in different categories. In addition, because the 

survey for states with state-administered child welfare systems asked 

them to choose one service category for each program, the reported 

service categories may not fully capture all relevant programs that fall into 

more than one service category. Inconsistencies in how states categorized 

services could have an effect on any measured differences between 

service categories. 

To obtain more in-depth information on the services provided and the 

types of children and families served under Title IV-B, we conducted site 

visits in California, New Jersey, Ohio, and Washington. We selected these 

states to represent a range of geographic locations and subpart 1 spending 

patterns. In addition, because preliminary data indicated that significant 

subpart 1 funds were devoted to CPS, we selected states that used 

innovative CPS tools or processes. However, the experiences of these 

states are not necessarily representative of the experiences of any other 

state. During these site visits, we interviewed state and local child welfare 

officials and service providers and reviewed relevant documentation. 

To learn about the federal government’s role in overseeing subpart 1, we 

reviewed applicable laws and regulations and interviewed HHS central 

office officials. We also conducted interviews with HHS officials in all 

10 HHS regional offices to discuss their oversight activities and reviewed 

results from HHS’s CFSR reports. In addition, we reviewed states’ CFS101s for fiscal year 2002 and compared states’ planned subpart 1 spending 

for foster care maintenance, adoption assistance, and child care payments 

with states’ final subpart 1 allocations for fiscal year 1979 as reported on 

an HHS program instruction from that year. States are required to submit 

the CFS-101 by June 30 of the preceding year—June 30, 2001, for fiscal 

year 2002. At that time, federal appropriations for Title IV-B and other 

federal child welfare funds often are not yet finalized, so states base their 
Appendix I: Scope and Methodology 

Page 48 GAO-03-956 Title IV-B Child Welfare Services 

estimates on the previous year’s allocation. 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. In most cases, 

we reviewed the final revised CFS-101s approved by HHS. For one state, 

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

subpart 1 expenditures that exceeded the limits for foster care 

maintenance and adoption assistance payments, but the revised 

CFS-101 did not. Although the revised CFS-101 did not show 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. 

We used our survey results to identify services unique to subpart 1—that 

is, categories of services funded by subpart 1 that are not funded by 

subpart 2. While no category of service was unique to subpart 1 at the 

national level, some states funded unique categories of services within 

their state with subpart 1. In our second survey, we asked states to provide 

a copy of any evaluations they had conducted of the three largest services 

funded by subpart 1. If we did not have survey data for one of the 

identified services, either because we did not send a second survey to the 

state or because the second survey did not ask for data on the particular 

service, we contacted the state directly to ask if any evaluation had been 

conducted. 

In addition, to identify other evaluations on the effectiveness of the 

services in these unique categories, we conducted a literature review and 

interviewed child welfare research experts. The reports and Internet sites 

we reviewed included the following: 

• Strengthening America’s Families: Effective Family Programs for the 

Prevention of Delinquency 

(http://www.strengtheningfamilies.org/html/programs_1999/programs_list_

1999.html). 

• Child Welfare League of America’s Research to Practice Initiative 

(http://www.cwla.org/programs/r2p/). 

• Casey Family Programs: Promising Approaches to Working with Youth 

and Families (http://www.casey.org/whatworks/). 
Appendix I: Scope and Methodology 

Page 49 GAO-03-956 Title IV-B Child Welfare Services 

• Promising Practices Network on Children, Families, and Communities 

(http://www.promisingpractices.net/). 

• U. S. Department of Health and Human Services, “Emerging Practices In 

the Prevention of Child Abuse and Neglect” (Washington, D.C.: n.d.). 

We conducted our work between August 2002 and July 2003 in accordance 

with generally accepted government auditing standards. 
Appendix II: Comments from the Department of Health and Human Services 

Page 50 GAO-03-956 Title IV-B Child Welfare Services 

Appendix II: Comments from the Department 

of Health and Human Services 
Appendix II: Comments from the Department of Health and Human Services 

Page 51 GAO-03-956 Title IV-B Child Welfare Services 
Appendix II: Comments from the Department of Health and Human Services 

Page 52 GAO-03-956 Title IV-B Child Welfare Services 
Appendix II: Comments from the Department of Health and Human Services 

Page 53 GAO-03-956 Title IV-B Child Welfare Services 
Appendix III: GAO Contacts and 

Acknowledgments 

Page 54 GAO-03-956 Title IV-B Child Welfare Services 

Diana Pietrowiak (202) 512-6239 

Michelle St. Pierre (617) 788-0558 

In addition to those named above, Melissa Mink and J. Bryan Rasmussen 

made key contributions to the report. Anne Rhodes-Kline, Alison Martin, 

Luann Moy, and George Quinn, Jr., provided key technical assistance. 

Appendix III: GAO Contacts and 

Acknowledgments 

GAO Contacts 

Acknowledgments 
Related GAO Products 

Page 55 GAO-03-956 Title IV-B Child Welfare Services 

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. 

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. 

Foster Care: HHS Should Ensure That Juvenile Justice Placements Are 

Reviewed. GAO/HEHS-00-42. Washington, D.C.: June 9, 2000. 

Juvenile Courts: Reforms Aim to Better Serve Maltreated Children. 

GAO/HEHS-99-13. Washington, D.C.: January 11, 2000. 

Foster Care: States’ Early Experiences Implementing the Adoption and 

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

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. 

Related GAO Products 
Related GAO Products 

Page 56 GAO-03-956 Title IV-B Child Welfare Services 

Child Welfare: States’ Progress in Implementing Family Preservation 

and Support Services. GAO/HEHS-97-34. Washington, D.C.: February 18, 

1997. 

Child Welfare: Opportunities to Further Enhance Family Preservation 

and Support Activities. GAO/HEHS-95-112. Washington, D.C.: June 15, 

1995. 

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