GAO

United States General Accounting Office

Report to the Subcommittee on the

District of Columbia, Committee on

Government Reform, House of

Representatives

December 2000 DISTRICT OF

COLUMBIA CHILD

WELFARE

Long-Term Challenges

to Ensuring Children’s

Well-Being

GAO-01-191

Page 1 GAO-01-191 District of Columbia Child Welfare

Contents

Letter 3

Appendixes Appendix I: Scope and Methodology 44

Appendix II: District of Columbia Child Welfare System Features

the MFO Required, July 2000 46

Appendix III: Child and Family Services Agency Organization,

September 2000 54

Appendix IV: Comments From the Child and Family Services

Agency 55

Related GAO Products 60

Tables Table 1: Modified Final Order and Actual Caseloads, July 2000 14

Table 2: The Percentage of Case Plans Entered in FACES,

September 2000 18

Table 3: Cases Referred to Investigation, October 1999 to July 2000 20

Table 4: Children Placed in Settings Prohibited by the MFO,

July 2000 22

Table 5: The Timeliness of Case Reviews, December 1998 and

July 1999 28

Figure Figure 1: Key Participants in the District of Columbia’s Child

Welfare System 34
Contents

Page 2 GAO-01-191 District of Columbia Child Welfare

’

Abbreviations

AFDC Aid to Families with Dependent Children

ASFA Adoption and Safe Families Act of 1997

CFSA Child and Family Services Agency

CSS Court Social Services

DHS Department of Human Services

HHS Department of Health and Human Services

ICPC Interstate Compact for the Placement of Children

MFO modified final order

MIS Management Information System

MPD Metropolitan Police Department

MSW Master of Social Work

OCC Office of Corporation Counsel

SACWIS Statewide Automated Child Welfare Information System
Page 3 GAO-01-191 District of Columbia Child Welfare

United States General Accounting Office

Washington, D.C. 20548 Letr

December 29, 2000

The Honorable Tom Davis

Chairman

The Honorable Eleanor Holmes Norton

Ranking Minority Member

Subcommittee on the District of Columbia

Committee on Government Reform

House of Representatives

Many children in the District of Columbia, like those in other jurisdictions

across the country, have lived at risk of abuse and neglect. Once in the care

of the District’s child welfare system, many have languished there for

extended periods of time. Years of indifference, managerial shortcomings,

and long-standing organizational divisiveness constrained the system’s

ability to keep children safe. As a result of these prolonged deficiencies, the

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

1991 to improve the performance of the child welfare agency and, lacking

sufficient evidence of program improvement, later removed the agency

from the District’s Department of Human Services (DHS) and placed it in

receivership in 1995.1 Under a modified final order (MFO) established by

that court, the receiver of the Child and Family Services Agency (CFSA)

was directed to comply with more than a hundred policy and procedural

requirements. These requirements include steps for improving protective

services; services to children and families; and the placement, supervision,

and review of children in foster care. On October 23, 2000, the court signed

a consent order that outlines a process to terminate the receivership upon

the satisfaction of certain specified conditions.2

Prompted in part by the death in January 2000 of a toddler who had been in

the care of the child welfare agency, you asked us to assess the progress the

receiver appointed in October 1997 had made in complying with the

requirements of the MFO and other critical elements that are important to

facilitating needed reforms. In May 2000, we testified on our initial

observations of the agency’s efforts to achieve compliance with the MFO

1

The agency was known in 1991 as the Child and Family Services Division of the District of

Columbia’s Department of Human Services. A receivership is an arrangement in which a

court appoints a person to temporarily manage a local agency with broad authority to

ensure full compliance with the court order in an expeditious manner.

2

LaShawn A. v. Anthony Williams, Consent Order, C.A. No. 89-1754, October 23, 2000.
Page 4 GAO-01-191 District of Columbia Child Welfare

and related systemwide issues.3 Subsequently, you asked us to conduct

more in-depth work to examine (1) how financial and operational changes

made by CFSA to comply with the MFO have affected the protection of

children and the provision of services to children and families, (2) the

extent to which critical elements of an effective child welfare system have

been applied in the District, and (3) issues that need to be addressed in

planning for the transfer of CFSA back to local governance.

In conducting this work, we interviewed a variety of key participants in the

District’s child welfare system, including the receiver, CFSA managers and

staff, and other District of Columbia officials, as well as child welfare

experts affiliated with other organizations. We also obtained and analyzed

information from CFSA to document the extent to which it has complied

with key provisions of the MFO. In addition, we reviewed reports and

evaluations that examined CFSA’s performance and key challenges facing

the District’s child welfare system. We conducted our work between March

and October 2000 in accordance with generally accepted government

auditing standards. (A more detailed discussion of our scope and

methodology appears in appendix I.)

Results in Brief The receiver has undertaken financial and operational changes in an effort

to comply with the MFO and improve children’s well-being by addressing

management and programmatic needs. These changes include initiatives to

recruit and train qualified social workers, develop policies and procedures

to guide service delivery to children and families, establish and enhance

organizational components, and develop a new automated information

system. However, the implementation of these management and

programmatic changes has not resulted in significant improvements in the

protection of children and the provision of other child welfare services. For

example, children in the District’s care remain in the system for an average

of 3.7 years, which far exceeds the federally mandated goal of 12 months.

In addition, inadequate efforts to retain staff have contributed to caseloads

that exceed the maximum caseloads allowed by the MFO and have

impaired the ability of social workers to perform critical services, such as

visiting children to ensure their safety and the adequacy of their care and

making referrals to other support services.

3

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

(GAO/T-HEHS-00-109, May 5, 2000).
Page 5 GAO-01-191 District of Columbia Child Welfare

Our previous work has shown that critical elements of an effective child

welfare system include collaborative operations among the agencies that

provide child welfare-related services to children and families and “casespecific” initiatives that aim to bring together children, family members,

social workers, attorneys, and others to help address the needs of a specific

child and family. Although the District has begun efforts to integrate child

welfare services with other support services, its child welfare system still

lacks a fully developed collaborative structure to help foster more efficient

day-to-day operations and improve program accountability. To address

case-specific needs, some entities in the child welfare system have initiated

projects of limited scope. For example, the District of Columbia Superior

Court instituted a mediation pilot that is designed to involve relatives in

making important decisions regarding children’s care, and two

neighborhood collaboratives began family case conferencing practices to

address circumstances that undermine family stability.

Beyond expanding efforts at collaboration, District officials also identified

several other key factors that need to be addressed before CFSA can be

transferred back to local governance. These factors include ensuring

adequate staffing and elevating CFSA to a cabinet-level agency within the

District government to provide for greater independence in setting

priorities and obtaining resources. District officials and child welfare

experts placed high priority on developing a transition plan that

incorporates these issues, because the District’s child welfare system

continues to face significant challenges despite the changes initiated by the

receiver and first steps the District has taken to foster systemwide

collaboration. An emergency reform plan prepared at the request of this

subcommittee on October 4, 2000, and a consent order issued on October

23, 2000, by the U.S. District Court for the District of Columbia will

significantly influence the pending transfer of CFSA to local governance.

Among other priorities, both call for establishing CFSA as a cabinet-level

agency and providing sufficient legal support for children in the agency’s

care. While the court-mandated requirements provide a framework for

addressing longstanding structural and operational challenges, a long-term

commitment from the Mayor and District government will also be

necessary to develop the child welfare system’s capacity to protect

children. In its comments on a draft of this report, CFSA found it to be

balanced, noting clarifications that we have incorporated where

appropriate.
Page 6 GAO-01-191 District of Columbia Child Welfare

Background The appointment of a child welfare receivership began with the filing of a

class action in 1989 on behalf of abused and neglected children in the

District of Columbia. The U.S. District Court trial and subsequent opinions

documented many shortcomings within the child welfare system and led to

a finding of liability on the part of the District. For example, the court found

that as a result of inept management and the indifference of the mayor’s

administration, the District had failed to comply with reasonable

professional standards in almost every area of its child welfare system.

Specifically, the court found that the District had failed to investigate

reports of neglect or abuse in a timely manner, make appropriate

placements for children who entered the child welfare system, monitor

their care, or adequately ensure that they had permanent homes. Court

documents traced these failures to staffing and resource problems—

namely, staff shortages, inconsistent application of policies and

procedures, and an inadequate automated system to track the placement

and status of children in the District’s care. A remedial action plan was

developed jointly by the plaintiffs and the defendants in the class action,

and that plan led to the development of the MFO in January 1994. The MFO

includes more than a hundred policy, procedural, and data requirements

with which the agency must comply. These requirements include steps for

improving protective services; services to children and families; and the

placement, supervision, and review of children in foster care (app. II

provides a summary of selected requirements). In 1995, the court, lacking

sufficient evidence of program improvement, removed the agency from

DHS and placed it in full receivership. Since then, the court has twice

appointed a receiver to manage the child welfare agency’s efforts to

institute the changes outlined in the MFO. The first receiver served from

August 1995 through June 1997. Not finding improvements in the child

welfare program, the court appointed a second receiver in 1997, who

served through November 30, 2000. The court appointed the deputy

receiver for programs to serve as interim receiver effective November 30,

2000.

The receiver appointed in 1997 primarily focused on changes to the

organization’s infrastructure, such as enhancing personnel management

and implementing a new management information system, as we reported

in our previous testimony. Additionally, in February 2000, CFSA

consolidated functions that had been dispersed at seven locations

throughout the city and co-located almost all staff into the same building

(see the CFSA organization chart in app. III). CFSA has also taken steps to

create new organizational roles or units to fulfill specific responsibilities.
Page 7 GAO-01-191 District of Columbia Child Welfare

For example, in 1998, the receiver hired specialists in child care, housing,

education, and substance abuse, who act as “internal consultants” by

sharing their expertise with social workers and interacting with other

District agencies. The substance abuse specialist, for example, identifies

and locates services in the community that meet the needs of the

population of children in CFSA’s care.

CFSA provides a range of child welfare services from the time children

enter the system until they reach permanent stable care arrangements.

Specifically, the Intake Administration oversees the process by which

children enter the system. After intake, children are served by a number of

different programs, depending on the setting in which they are placed once

they are removed from their home, such as traditional foster care, kinship

care, and adoptions. Other program areas provide special services, such as

the Teen Services Division, which focuses on adolescents in care by, for

example, helping to prepare them to live independently as adults, and the

Family Services Division, which addresses the needs of families when a

determination has been made that a child can safely remain at home.

Health Services, through a program called D.C. KIDS that was established

in October 1999, provides for initial physical and mental health screenings

and for continuing medical care.

In recent years, the number of children receiving such services has

increased, while the number of social workers has declined. Although the

agency serves children in a variety of settings, in December 1997, 2 months

after the appointment of the second receiver, there were approximately

2,900 children in foster care; at that time, there were 289 social workers on

board providing a broad array of services in agency programs, such as

kinship care, foster care, and adoptions.4 As of August 31, 2000, there were

about 3,271 children in foster care, and the agency employed 241 social

workers.5 To provide services to children, CFSA had a budget in fiscal year

2000 of $147 million, almost one-third of which was federal child welfare

4

These data do not include social work aides and trainees who can assist social workers in

their duties.

5

These data do not include social work aides and trainees who can assist social workers in

their duties. As of August 31, 2000, CFSA had 677 employees.
Page 8 GAO-01-191 District of Columbia Child Welfare

funding.6 The MFO requires CFSA to maximize its use of several federal

funding sources, including title IV-E and Medicaid, and it has taken steps to

increase the receipt of such funding. CFSA has requested an increase of $37

million for fiscal year 2001, for a total budget of $184 million, which

according to some agency officials is the first budget that will fully support

their efforts to comply with the MFO.

CFSA operates in a complex child welfare system. Although it provided

many services directly, in fiscal year 2000, about 57 percent of all agency

expenditures were spent on contracted services. For example, contracts

provide for placements of children in group homes as well as some foster

homes and other facilities. The agency spends about $6.2 million annually

on eight Healthy Families/Thriving Communities collaboratives, nonprofits

that provide neighborhood-based support services to stabilize families so

that fewer children enter the child welfare system. CFSA also works with a

consortium of 22 private agencies to place children in foster and adoptive

homes.7 In addition, CFSA relies on services provided by other District

government agencies. For example, both the Fire Department and the

Health Department inspect facilities where children are placed; D.C. Public

Schools prepares individual education plans for children in care; and the

D.C. Interstate Compact office in the Department of Human Services has

responsibility for working with CFSA and other states to process the

interstate placement of children.8 To process cases through the court

system, CFSA interacts with 59 D.C. Superior Court judges, each of whom

has responsibility for a share of the child abuse and neglect caseload.

Under District of Columbia law, while CFSA has primary responsibility for

6

Federal funding is primarily authorized under title IV-E of the Social Security Act, which

reimburses states for a portion of out-of-home care costs for children under the Aid to

Families with Dependent Children (AFDC) program. Although legislation passed in 1996

eliminated the AFDC program, children who meet the 1996 eligibility criteria for AFDC

continue to be eligible for title IV-E assistance.

7

Consortium members include agencies like Lutheran Social Services, Catholic Charities,

and For Love of Children.

8

The Interstate Compact for the Placement of Children (ICPC) is essentially a uniform law,

enacted in all 50 states, the District of Columbia, and the U.S. Virgin Islands, that governs

the interstate placement of children in foster and adoptive homes. Under ICPC, the state

from which a child is sent retains jurisdiction over the child and his or her placement. Each

state must, however, provide the other with information sufficient to ensure that a

placement is appropriate and in the best interest of the child. Although this report discusses

the District’s role in the ICPC process, we use “interstate placement” to refer to placements

outside District boundaries.
Page 9 GAO-01-191 District of Columbia Child Welfare

investigating neglect cases, the Metropolitan Police Department (MPD) has

primary responsibility for investigating abuse cases. 9 This arrangement,

known as “bifurcation,” is unique among child welfare systems nationwide.

Following MPD investigation, the office of Court Social Services (CSS) of

the District’s Superior Court provides oversight and management of these

abuse cases, which totaled about 600 in July 2000. In abuse cases in which a

child cannot be returned home and no relative can be found, CSS transfers

the case to CFSA.

In addition to complying with the provisions of the MFO and District law,

CFSA must comply with applicable federal laws, including the Adoption

and Safe Families Act of 1997 (ASFA), which placed new responsibilities on

all child welfare agencies nationwide. The act introduces new time periods

for moving children toward permanent stable care arrangements and

penalties for noncompliance. For example, it requires states to hold a

permanency planning hearing no later than 12 months after the child is

considered to have entered foster care.

In an effort to provide for greater accountability among court-appointed

receivers in the District, including the child welfare receiver, the Congress

passed and the President signed in October 2000 the District of Columbia

Receivership Accountability Act of 2000 (Pub. L. No. 106-397). The act

provides for increased oversight and accountability of receivership

performance. The act specifies several approaches for enhancing oversight,

including periodic fiscal, management, and program audits, that are

intended to strengthen the structure of accountability for District

government programs.

Receiver’s Changes

Had Limited Effect on

Children’s Well-being

Since 1997, the receiver introduced management and programmatic

changes intended to meet the requirements of the MFO and to improve

child welfare outcomes in the District. These changes include initiatives to

recruit and train qualified social workers, provide additional funding for

community-based services, establish and enhance organizational

components, and develop a new automated system. The implementation of

these efforts has fallen short of expected results, and these efforts have had

a limited effect on CFSA’s ability to provide needed child welfare services

to enhance children’s well-being and guide their progress toward

9

D.C. Code Ann. 6-2104. The MFO requires CFSA to conduct joint investigations with MPD.
Page 10 GAO-01-191 District of Columbia Child Welfare

permanent stable care arrangements. For example, although many new

staff have been hired, some had not yet been assigned caseloads because of

delays in obtaining professional social work licenses. As a result of such

delays and inadequate efforts to retain staff and maintain adequate staffing

levels, caseloads remain above standards defined in the MFO. This impairs

social workers’ ability to perform critical casework functions, such as

visiting children to ensure their safety and adequacy of care, preparing

court reports, and investigating cases within designated time periods.

Likewise, CFSA issued a policy handbook in 1995 to which it has made

numerous revisions. While a recent effort to include these policies in the

agency’s automated system may improve staff access to them, many staff

told us that they have lacked consistent direction in how to implement

policies during the course of their work. Moreover, the policy handbook

and subsequent revisions do not yet include policies covering all

requirements of the MFO. In addition, CFSA’s new automated system—

FACES—lacks complete case information, and social workers have not

fully used it in conducting their daily case work.10

Changes in Key

Management Requirements

Fall Short of Expected

Results

In response to management-related requirements contained in the MFO,

the receiver undertook changes in areas such as recruitment and retention,

training, social worker caseload reduction, the development of policies and

procedures, and the implementation of a new automated information

system. However, these changes have generally fallen short of expected

results. (See app. II for an assessment of CFSA’s compliance with selected

provisions of the MFO.)

Recruitment, Retention, and

Training Activities

Problems with the recruitment and retention of qualified social workers

preceded the receivership. Recognizing these challenges, the MFO required

CFSA to improve recruitment efforts and hire a sufficient number of social

workers who had obtained Master of Social Work (MSW) degrees.11

10An agencywide contest provided the name for the information system.

11In order to carry cases, social workers with an MSW must also obtain professional social

work licenses. One factor that delayed the immediate deployment of social workers upon

their being hired was a prolonged licensing process. Some newly hired social workers we

spoke to said that they had been on the job for periods ranging from 3 to 5 months before

receiving their licenses. The Deputy Mayor for Children, Youth, and Families announced in

September 2000 that the Mayor had signed an order allowing the District to automatically

recognize licenses granted by other states as one way to expedite licensing for some new

hires.
Page 11 GAO-01-191 District of Columbia Child Welfare

Following recent recruitment efforts, CFSA hired 56 social workers

between March and June 2000, which represented 80 percent of its goal of

70 new hires for that period.12 This hiring activity resulted from recruitment

efforts that included obtaining independent hiring authority in October

1999, developing a recruitment plan in March 2000, conducting several job

fairs, raising salaries, and offering additional recruitment incentives.

The retention of qualified social workers, however, has been a constant

challenge for CFSA. To help the agency maintain a stable workforce, the

MFO required it to develop a retention plan. As of August 2000, CFSA had

created a retention committee that meets periodically and reports to the

receiver, but it has not developed an agencywide retention plan. The

agency continues to experience a fluctuating yet significant loss of social

workers. CFSA staff estimated that in 1997, the first year of the receiver’s

term, the agency lost about 15 social workers per month. While CFSA

officials stated that this rate had declined by June 2000 to about four or five

social workers per month, attrition continues to be a significant issue.13

Overall, according to a CFSA official’s estimate, the agency lost about onethird of its social workers between January 1999 and July 2000.

While attrition is high in many other child welfare agencies across the

country, turnover among social workers in the District is explained in large

part by unmanageable workloads and the availability of better-paying jobs

with other District agencies and the private sector, according to CFSA

officials and staff. Furthermore, according to CFSA’s analysis of interviews

with staff who left the agency, some social workers cited the quality of

supervision as a reason for their decision to resign.14 CFSA officials noted

that the creation of a social worker associate position at the Bachelor’s of

12Before CFSA obtained independent hiring authority in October 1999, it could not conduct

direct recruitment and had to depend on the District’s Office of Personnel to refer

candidates to fill positions. According to CFSA human resources officials, the agency

received only 10 to 15 referrals of job candidates each year from DHS before CFSA obtained

its independent hiring authority. CFSA officials believed the agency would comply with the

MFO with 60 new hires.

13Agency data for June, July, and August 2000 show that CFSA lost between five and nine

social workers each month.

14CFSA officials indicated that two new initiatives—the conversion of all agency

management and supervisory employees from career service to the District government’s

Management and Supervisory Service and the development of a new agency performance

appraisal system—could enhance accountability for management and supervisory

employees.
Page 12 GAO-01-191 District of Columbia Child Welfare

Social Work level could help agency retention efforts by providing more

flexibility in assigning such workers to deliver some MFO-required

services.

High turnover adversely affects CFSA’s capacity to effectively manage the

provision of services to children and families. According to CFSA staff, the

agency is losing many of its more experienced social workers, whereas the

new hires selected to replace these workers and to help CFSA attain more

desirable staffing levels face a significant learning curve. New hires, senior

social workers, and supervisors we spoke with also cited casework

problems associated with high turnover, such as delays that result when

social workers resign and cases previously assigned to them need certain

actions, including transfer to another program area. New hires also stated

that once on the job, they were assigned cases previously handled by

others that lacked sufficient case data, forcing them to spend extra time to

recreate the data and learn the case history. Additionally, high turnover

results in the assignment of a succession of social workers to the case of a

child in CFSA’s care, furthering instability in the lives of these children.

The MFO also required CFSA to establish a full-time training unit and to

provide minimum requirements for training new hires and ongoing training

for more senior workers. While CFSA has met these requirements,

casework priorities often lead to low attendance at training sessions. In

response to these requirements, the agency initially conducted a needs

assessment to plan the development of the training unit. Until the training

unit was established, an administrator and a trainer provided or obtained

training for agency employees. In January 1999, CFSA established the

training unit through a contract with Virginia Commonwealth University to

provide training to agency social workers beginning in February 1999.15 The

university has developed a training course for new hires, which provides

the 80 hours the MFO requires, and a curriculum of about 30 courses, from

which more senior staff can choose classes to meet the continuing

education requirements of the MFO. The training program director

reported that between May and October 2000, 54 of 72 new hires completed

their initial training.16 Additional training has been provided in areas such

as preparing for court appearances and meeting ASFA requirements.

15The contract is supported by subcontracts with Howard University and Catholic University

of America.

16Additionally, the training program director stated that 212 CFSA staff with casework

responsibilities received some form of training between May and October 2000.
Page 13 GAO-01-191 District of Columbia Child Welfare

Staff we interviewed expressed a variety of views on the quality of training.

For example, some new hires who had recently earned their MSWs stated

that they found portions of the new-hire training to be elementary or

insufficiently tailored to their case management duties at CFSA. In

addition, staff at all levels stated that they wanted additional training in

how to assess the risks a child faces at home to determine whether removal

is necessary, as well as additional training in agency policies and

procedures. CFSA officials stated that risk assessment training has been

offered to intake workers several times but cancelled for poor attendance.

CFSA officials and social workers stated that casework priorities often

result in low attendance at classes, which leads to either course

cancellations or rescheduling trainers. CFSA incurs additional training

costs that range from $500 to $800 per day for rescheduled classes.

In addition, the MFO required CFSA to assess whether staff satisfactorily

master the course content. CFSA lacks such methods, although the agency

hired a curriculum specialist in September 2000 to develop methods for

evaluating the extent to which social workers apply training content to the

work they perform.

Caseload Reduction The MFO established caseload limits to help social workers respond to the

service needs of children and families. Although CFSA has achieved these

caseload levels in some program areas, the caseloads CFSA reported for

other areas remain significantly above the maximum caseloads allowed by

the MFO, limiting social workers’ ability to meet the needs of children and

families. For each program area, table 1 identifies staffing levels, caseloads

per staff required by the MFO, and average caseloads carried by CFSA

social workers in teams in each program area as of July 2000. As the table

shows, social workers were carrying actual average caseloads that

exceeded the MFO limits in 6 of 10 CFSA programs. For example, workers

in the traditional foster care program were carrying average caseloads that

ranged from 13 to 55, compared with the MFO limit of 16. Moreover, eight

of the agency’s nine traditional foster care teams had average worker

caseloads that exceeded this limit.
Page 14 GAO-01-191 District of Columbia Child Welfare

Table 1: Modified Final Order and Actual Caseloads, July 2000

Note: The definition of case varies, depending on the service provided. For example, in traditional

foster care and adoptions, each child constitutes a case. In intake, a case is an investigation; in family

services, each family is a case; and in adoption home studies, a case is a prospective adoptive home.

In September 2000, the receiver announced plans to hire 22 additional social workers. As a result,

actual caseloads carried by social workers since then may vary from these data.

a

CFSA reported average caseloads carried per worker by team (or “section”) in each program area. A

team typically consists of five social workers. The data reflect the range of average caseloads carried

by workers in each team. Of the seven case-carrying teams in intake, four exceeded the MFO

caseload limit; seven of ten kinship teams exceeded the limit; all three teen services teams exceeded

the limit, as did the teen life options team; eight of nine traditional foster care teams exceeded the limit;

and five of seven adoptions teams exceeded the limit.

b

Taken together, the kinship and traditional foster care programs account for about two-thirds of the

children in CFSA’s care, according to CFSA officials.

c

Data reflect average caseloads for one team in these areas.

d

In foster care, children are placed with foster families after being removed from the home. CFSA uses

“traditional” to distinguish this form of care from “therapeutic foster care,” a form of foster care for

children who have special needs. Contractors handle CFSA’s therapeutic foster care program.

e

Data reflect two teams, each reporting an average caseload of 25.

Source: CFSA.

Moreover, average caseloads may understate the caseloads actually carried

by some social workers. Social workers we spoke to consistently described

their caseloads as overwhelming and unmanageable. To illustrate the effect

of high caseloads, a senior social worker, also in traditional foster care, told

us that his caseload included responsibility for 44 children. He described

Number of

social workers

Average

caseload

rangea

MFO caseload

limit

Intake investigations 47 6-26 12

Kinship careb 45 3-33 17

Family services

In-home 40 10-17 17

Intensive family services 10 2-4 4

Permanency and placement

Teen services 13 20-34 16

Teen life options 5 19c 12

Traditional foster careb,d 36 13-55 16

Adoptions 34 10-21 12

Adoption home studies 5 16c 30

Family resources 9 25e 30

Total 244
Page 15 GAO-01-191 District of Columbia Child Welfare

the following duties that he must fulfill to meet the needs of these children

and their families: He must prepare 44 case plans, assess the needs of 44

children and make appropriate referrals, attend the court hearings for

these cases, participate in internal reviews of these cases, and ensure

appropriate placements in 44 different schools, among other activities. In

addition, the social worker is responsible for obtaining a variety of goods

and services, including clothing, transportation, health and mental health

services, and mentoring services.

Caseloads that exceed prescribed limits have several effects. For example,

supervisors reported that they sometimes must carry cases. This practice

not only violates an MFO requirement that supervisors not carry cases; it

also limits their ability to provide effective supervision. Yet, CFSA data as

of June 2000 showed 25 supervisory staff carrying the cases of 129 children.

High caseloads also have a very direct effect on the availability and level of

CFSA oversight of the children in its care. Specifically, social workers

reported that when caseloads are high, certain other activities assume a

lower priority. Among these are providing referrals so that children can

obtain needed services, conducting required visits to assess children’s

progress in their placements, and entering data in the management

information system.

Finally, social workers we spoke to acknowledged that high caseloads also

lengthen the time required to process cases, and they contribute to

difficulties in moving children to permanency without delay. According to a

report prepared for the Deputy Mayor for Children, Youth, and Families,

children still spend an average of 3.7 years in the District’s child welfare

system.17 In this environment, these time periods jeopardize the District’s

ability to comply with ASFA’s requirement that children reach permanency

within 12 months, according to District Superior Court officials.

Policies and Procedures

Development

The MFO required CFSA to develop policies and procedures covering 28

key child welfare program areas, including conducting timely

investigations, providing needed services, developing performance-based

contracting, appropriately placing children and achieving permanency for

17Carolyn N. Graham and Kennedy Khabo, The District of Columbia Safe Passages to

Permanency Initiative (Washington, D.C.: Office of the Deputy Mayor for Children, Youth,

and Families, Oct. 1999).
Page 16 GAO-01-191 District of Columbia Child Welfare

them, and managing social worker caseloads.18 The agency issued policies

in a 1995 handbook. Since then, these policies have been revised by

changes communicated through “circular letters” that provided draft

updates to specific policies and procedures and direction that varied from

supervisor to supervisor. As a result, staff expressed confusion over how to

achieve consistent implementation of agency policies. Moreover, agency

policies do not cover all court-mandated requirements contained in the

MFO. Additionally, until October 2000, CFSA had assigned only one worker

to coordinate the development of draft policies.

Even though policies have been in place, CFSA staff told us they have not

been completely clear or useful in carrying out their work. Uncertainty

over CFSA’s policies constrained supervisors’ ability to communicate

priorities and direct the work of social workers under their supervision,

and in some cases, social workers expressed a reluctance to seek guidance

from their supervisor because they felt their supervisor lacked sufficient

knowledge. Finally, staff we interviewed said that, as a result, CFSA’s ability

to work effectively with other key child welfare partners was constrained.

For example, according to a CFSA official, the lack of clear and consistent

policies created uncertainty regarding how social workers should respond

to directives from the District’s Superior Court regarding the preparation of

court-mandated reports, appearances at court hearings, and other legal

matters. Even though policies are now available through FACES, CFSA

staff indicated that social workers will still need to seek supervisory

guidance to clarify and implement them consistently.

CFSA officials demonstrated the approved policies and procedures manual

feature of the automated information system to GAO in October 2000.19

While the policies and procedures appeared to be at least as

comprehensive as earlier policies, it is too early to say how staff will rely on

this new feature to obtain consistent direction to their work. However,

CFSA officials stated that social workers will receive training on using the

automated policies and can contact CFSA’s Office of Planning, Policy, and

Program Support to obtain clarification on specific policy implementation.

18 App. II lists these policy requirements and identifies the extent to which CFSA has begun

to draft policies corresponding to each mandate.

19The feature is available through the system’s “Help” menu and provides an index and

search capability.
Page 17 GAO-01-191 District of Columbia Child Welfare

New Automated Information

System

The MFO required CFSA to develop an automated information system to

permit the agency to comply with the provisions of the MFO and with

District law. On October 1, 1999, CFSA implemented the FACES system,

adapted from systems previously implemented in Oklahoma and West

Virginia, at a cost of about $20 million.20 While additional modifications or

enhancements could be made, CFSA considers the system fully

implemented and available for staff use. According to the system

administrator, several factors contributed to system design: the

requirements of federal law, compliance with the provisions of the MFO,

and input from a team of 70 “end users” consisting of staff from various

program areas throughout the agency. While CFSA officials believe FACES

will comply with federal requirements, it cannot produce all the reports the

MFO required.21 For example, CFSA reported that FACES could not

produce reports on the timeliness of administrative reviews and could not

generate certain placement data as specified by the MFO.22

CFSA staff also do not fully use the system. Staff across the agency noted

that they continue to use spreadsheets or databases outside of FACES.23

The system administrator expressed concerns about the completeness of

the data in FACES—and, therefore, its validity—noting that incomplete

data entry undermines the purpose for which the system was designed. She

described FACES as a tool that supports case practice and allows social

workers and supervisors to track cases, assess risks to children, control

vendor payments, and assess contractor performance. The system can also

document actions social workers perform during a case’s entire history. To

the extent that timely and complete data entry is not achieved, however,

the agency’s ability to track its entire caseload is compromised. In part, this

low usage stems from the lack of case data entry into the system by social

workers. For example, CFSA officials estimated that as of September 2000,

20Included in this cost is $10 million in federal funding.

21System officials stated that the federal Statewide Automated Child Welfare Information

System (SACWIS) compliance visit took place in June 2000. CFSA officials expected that the

federal Department of Health and Human Services (HHS) would provide a draft of its review

in December 2000.

22Federal law and the MFO require an administrative review every 6 months of the progress

toward permanency and the achievement of case plan goals for all children in foster care.

23For example, staff in administrative review, adoptions, placement, and monitoring said

that they maintain data outside FACES. System staff believe that FACES could

accommodate some of these functions and said that they have begun to discuss with staff in

certain program areas how such data could be included in FACES.
Page 18 GAO-01-191 District of Columbia Child Welfare

across all programs, about half of all case plans had been entered into

FACES; however, Superior Court judges and a court official we spoke to

believe that this estimate may overstate the actual rate of data entry. CFSA

officials also noted that the percentage of data entered in the system varies

by program area, as shown in table 2.

Table 2: The Percentage of Case Plans Entered in FACES, September 2000

Note: Together, kinship and traditional foster care account for about two-thirds of all children in CFSA’s

care, according to CFSA officials.

a

Intake workers are responsible for creating cases in FACES and for entering data that support the

case plan, such as legal information, family demographics, and contact notes. Because a case cannot

be transferred to another program area if these data are left blank, CFSA officials stated that 100

percent of these data are entered as new cases are created. However, CFSA officials estimated that

70 percent of the cases that remain in intake for more than 30 days have been entered in the system.

Source: CFSA.

The system administrator identified several possible reasons why social

workers might not be entering complete data into FACES: a lack of comfort

with learning new technology and a “cultural” preference for paper

documents among child welfare practitioners, a lack of knowledge among

staff about the system’s capabilities, supervisors’ decisions to allow social

workers to continue using paper, and insufficient time to use the system

because of other case priorities. Social workers also said that when

caseloads become difficult to manage, other activities like data entry

assume a lower priority.

Finally, FACES is not yet well linked with systems in other agencies.24

Existing linkages with other agencies are limited and do not include key

participants in the child welfare system, such as MPD, CSS, Office of

Program area Percentage of case plans entered

Intakea 100

Adoptions 70

Family services 65

Teen services 60

Traditional foster care 42

Kinship care 35

24In this context, “linked with” means “able to access” FACES or FACES data from a remote

location.
Page 19 GAO-01-191 District of Columbia Child Welfare

Corporation Counsel (OCC), D.C. Superior Court, and D.C. KIDS.25 Officials

in some of these agencies expressed a desire for access to FACES to track

children in the child welfare system and report more complete case

information in support of District efforts to obtain additional federal funds.

In July 2000, the CFSA System Administrator noted that the agency’s 2001

budget provides for limited linkages with OCC, CSS, and MPD and a full

FACES interface with D.C. KIDS. However, implementation priority to date

has focused on rolling out the system within CFSA.

Changes in Key ProgramRelated Areas Also Fail to

Meet Established Goals

In addition to requirements that address human resources and caseloads,

the MFO imposed program requirements on CFSA in a number of areas,

ranging from intake and assessment to efforts to provide children with

permanent placements. Despite progress in some areas, CFSA still faces

challenges in meeting the terms of the court order. In particular, the agency

has not met certain MFO time periods for initiating and completing

investigations. While the agency has begun to address its need for

additional homes and facilities, it continues to place children in settings

prohibited by the MFO, such as homes without current licenses and homes

with more children in their care than their licenses permit. Additionally,

CFSA has not consistently met MFO requirements regarding the provision

of ongoing support services to children once they are placed, and its

oversight of contractors’ service delivery is limited. Moreover, while the

agency has added staff to process the cases of children placed outside the

District without proper documentation, a large backlog of these cases

remains. Finally, despite MFO requirements to expedite the process by

which children move into permanent, stable care arrangements, children

still spend an average of 3.7 years in the system.

Intake and Assessment The court order mandated certain time periods to expedite the process by

which children enter the child welfare system. For example, it required that

investigations be initiated within 48 hours of the receipt of the abuse or

neglect report and completed within 30 days of the report. District law

exceeds the MFO requirement and requires that the initial investigation be

25CFSA exchanges data with the Income Maintenance Administration and has system

linkages with the Office of Early Childhood Development, some of the Healthy

Families/Thriving Communities collaboratives, and 22 private consortium agencies (a group

that includes Lutheran Social Services, Catholic Charities, For Love of Children, and

others).
Page 20 GAO-01-191 District of Columbia Child Welfare

initiated within 24 hours of the report.26 As shown in table 3, CFSA has had

great difficulty meeting these requirements. For example, roughly one-third

of all cases referred for investigation since October 1999 were not initiated

within 24 hours of the report and CFSA failed to complete investigations

within 30 days on about half of them.

Table 3: Cases Referred to Investigation, October 1999 to July 2000

Note: Investigations include child neglect cases investigated by CFSA and child abuse cases

investigated by MPD. An investigation constitutes cases in which every member of the household

under investigation has been interviewed, according to CFSA officials.

a

These numbers refer to cases undergoing investigation between October 1999 and July 2000.

However, the total number of cases is higher than that for cases initiated within 24 hours because 308

of these investigations were begun before October 1999.

Source: CFSA.

CFSA has made some progress in reducing the backlog of cases for which

investigations had not been completed within 30 days. An intake official

recently reported that the backlog of incomplete neglect investigations had

been significantly reduced and that only 30 incomplete investigations

remained as of August 2000. Beginning in June 2000, CFSA set a unit of

recently hired intake workers to helping the MPD reduce its own backlog

that had not met the 30-day time period from 177 cases to 64 cases.

However, intake officials acknowledged continuing difficulties in meeting

both the 24-hour and the 30-day time periods. Intake officials cited staff

turnover as one explanation. CFSA lost about 26 percent of its intake

workers in 1999. Intake officials believe they will be able to comply with

both time periods if the agency is fully staffed, and they cited the succes

26D.C. Code Ann. 6-2102 and 6-2103.

Total number

Not

completed

within time

period

Completed

within time

period

Rate not

completed

within time

period

Investigations

initiated within 24

hours 2,586 954 1,632 37%

Investigations

completed within

30 daysa 2,894 1,495 1,399 52%
Page 21 GAO-01-191 District of Columbia Child Welfare

that new intake workers had in reducing the backlogs in July 2000 as one

example of their ability to comply, given additional staff.

The MFO also required joint investigations of abuse cases by CFSA social

workers and police officers and mandated that CFSA develop policy to

guide such joint activities. While CFSA reported that 562 joint

investigations were conducted in fiscal year 2000, joint investigations are

not yet routine.27 For example, CFSA and MPD officials agree that this

number refers to investigations in which CFSA and MPD staff collaborated

in some way on a case. The number of cases in which CFSA and MPD

jointly visited families to conduct investigations is much lower, and the

officials could not provide a concrete number. While CFSA and MPD

officials developed a protocol for working together in September 2000, the

lack of available staff in both agencies is likely to continue to limit their

ability to conduct joint investigations.

Opportunities for Placing

Children in Foster, Adoptive, and

Group Homes

The MFO addressed the placement of children by requiring that CFSA

prepare a needs assessment and development plan to identify more

placement opportunities in additional foster, adoptive, and group homes

and other facilities. The MFO also prohibited placing children in settings

considered harmful to them, such as placing children younger than 6 in

group homes.28 While CFSA has not developed a resource development

plan per se, the agency’s strategic plan for fiscal year 2000 identified goals

for developing more foster and adoptive homes, for example, and included

time periods and specific steps to be taken. This plan had not yet been

updated by October 2000.

Social workers we spoke to emphasized that the development of additional

capacity in foster and adoptive homes is crucial if children are to be

appropriately placed in a timely manner. CFSA staff also cited a shortage of

group homes, noting that 76 placement slots have been lost because of the

27Overall, MPD investigated more than 2,000 abuse cases each year for the past 3 years. The

Safe Shores D.C. Children’s Advocacy Center, a nonprofit organization in partnership with

District and federal government agencies, coordinates the work of an interagency

multidisciplinary team to investigate allegations of child physical and sexual abuse. The

Center has both a CFSA liaison and MPD officers on site to facilitate joint responses to case

referrals.

28The MFO exempts from this prohibition children who have exceptional needs that cannot

be met by any other type of care.
Page 22 GAO-01-191 District of Columbia Child Welfare

recent closing of several group homes.29 Finally, social workers noted that

the supply shortage is especially acute for emergency care facilities, infant

care facilities, and homes for large sibling groups.

CFSA’s difficulties in securing appropriate placement facilities are

illustrated by the fact that CFSA has placed children in facilities that lack

current licenses, facilities where the number of children exceeds the

number permitted by the license, and inappropriate facilities—all practices

prohibited by the MFO.30 For example, as shown in table 4, in July 2000,

CFSA reported that 62 children younger than 6 were residing in congregate

care or group homes for as long as 3 months to almost 2 years. A national

child welfare expert described such placements as very harmful to young

children.

Table 4: Children Placed in Settings Prohibited by the MFO, July 2000

Source: CFSA.

The lack of placement options has also led to extended stays by children in

CFSA’s on-site “respite center,” which was not designed for overnight care.

CFSA staff confirmed that the respite center has been used to place

children on an emergency basis for several days at a time.

Recognizing the need to develop new placement capacity, CFSA has taken

some recent steps to do so, but the effects of these activities are not yet

known. Moreover, several officials we spoke to agreed on the need for a

comprehensive analysis of needs, matched with an analysis of existing

29As of September 2000, CFSA had slots for 297 children in 17 group homes.

30In October 2000, the receiver said that in most cases homes without current licenses

reflect expired medical information not updated by foster parents. At the time of our review,

CFSA was exploring ways to obtain such information in a more timely manner. Additionally,

the consent order requires licensing functions to be consolidated within CFSA.

Type of setting

Number of

children

Number of

facilities

Homes without current licenses 147 81

Homes with more children than allowed by

license 25 20

Group homes with children younger than 6 62 5
Page 23 GAO-01-191 District of Columbia Child Welfare

system capacity to meet the agency’s long-term needs for placement

opportunities.31

To address its placement needs, CFSA has worked with the Annie E. Casey

Foundation to study ways to recruit additional foster homes, and it

implemented a project with this aim in June 2000. The foundation’s Familyto-Family initiative, for example, uses strategies to recruit, train, and retain

foster families that are community-based and culturally sensitive.

Additionally, CFSA’s adoption program manager identified ways to improve

adoptive home recruitment by, for example, conducting effective follow-up

with persons interested in adopting.32 In September 2000, the receiver

announced emergency plans to pursue contract modifications that would

allow providers who have an immediate capacity to accept additional

children to do so.

Support Services for Foster and

Adoptive Families

CFSA has had difficulties in providing pre-placement and post-placement

support services. For example, the MFO required social workers to visit

children in foster homes not less frequently than once a week for the first 2

months after placement. While CFSA reported that as of June 2000 social

workers had visited most foster children at least once, agency data show

that in most cases the reported visits were less frequent than once a week.

As of June 2000, CFSA reported that 53 children had not been visited at all

since being placed.33

Moreover, foster and adoptive parents may not be fully prepared for the

complexity of children’s needs. CFSA’s Office of Quality Assurance studied

children who had experienced multiple placements and concluded that

many foster parents lacked an understanding and knowledge of how to

cope with the special needs of some children.34 These needs reflect

underlying conditions such as depression, attention deficit hyperactivity

31In September 2000, the need for such an analysis was cited by a Chapin Hall Center for

Children survey of the private organizations providing child welfare services to children and

families in the District. See Fred Wulczyn, Emily Zimmerman, and Jennifer Haight, An

Assessment of Contract Agency Capacity in the Washington, DC Child Welfare System,

Chapin Hall Center for Children at the University of Chicago (Chicago: June 2000).

32Toni Oliver, Issues in Recruitment (College Park, Ga.: J.T. Oliver & Associates, 1993).

33Of 1,030 children needing visits, CFSA reported in June 2000 that 977 had been visited at

least once and 53 had not yet been visited.

34CFSA Office of Quality Assurance, “Children with Four or More Placements,” Spring 2000.
Page 24 GAO-01-191 District of Columbia Child Welfare

disorder, post-traumatic stress disorder, and attachment disorder. In some

cases, CFSA has provided insufficient support to stabilize placements and

prevent disruptions. For example, the report found that, in some cases,

social workers failed to implement recommendations included in

psychological and psychiatric evaluations and that some children who had

been physically or sexually abused were not provided therapy or other

services aimed at addressing the effect of abuse when they entered foster

care.

Similarly, the MFO recognized that services are necessary to preserve

adoptive families and requires that families at risk of disruption receive

appropriate services. A CFSA adoption official acknowledged that many

children also have special needs that present long-term issues that may not

become apparent until some time after the adoption has been finalized.

This situation can appear to be overwhelming to adoptive parents, who

may need ongoing services to ensure family stabilization and prevent

disruption. In response to the needs of adoptive families, CFSA initiated a

new postadoption program, supported by an initial grant from Freddie Mac

in June 1999.35 The new program will coordinate a range of referrals for

adoptive parents, such as medical and mental health advocacy groups,

developmental specialists and therapists, and experts who are

knowledgeable about the needs of adopted children.

Oversight of Contracted Services Although the MFO requires CFSA to use performance-based contracting,

CFSA has made little progress in holding its contractors more accountable

for the services they provide.36 For example, although CFSA has succeeded

in introducing some performance measures to guide oversight of the eight

Healthy Families/Thriving Communities collaboratives, these performancebased contracts represent a small proportion of all contracts. More

generally, CFSA’s capacity for effective oversight of contracts is limited in

several ways. The agency employed six contract monitors to oversee

contract expenditures of about $80 million for fiscal year 2000.37 A CFSA

35The Freddie Mac Foundation provides grants to improve outcomes for children and

families, including initiatives in foster care and adoption. In 1999, the foundation gave about

$1.9 million to foster care and adoption projects nationwide.

36The MFO required that each contract include specific standards by which contractors’

performance can be measured.

37CFSA stated that this amount did not reflect some outstanding payables as of October

2000.
Page 25 GAO-01-191 District of Columbia Child Welfare

contracts official stated that some of these contract monitors lack training

and experience corresponding to this level of responsibility.38

CFSA’s oversight of certain facilities is augmented by group home and

residential treatment center monitors, who are responsible for ensuring

that facility staff and conditions are consistent with the terms of the

contract. Specifically, 4 group home monitors are responsible for

overseeing about 17 homes, and 3 residential treatment center monitors

have oversight of about 30 facilities.39 Generally, contracts with the group

homes require visits by the group home monitors at least once a month,

and visits with each residential treatment center are to be made at least

quarterly. Given the monitors’ oversight responsibilities and staff

resources, they told us they need additional monitoring staff to more

effectively oversee facility performance. Moreover, the monitors stated that

there is currently no oversight of about 200 purchase-of-service

agreements, which are small contracts that usually involve specific

services for one child each. Agency officials stated that CFSA plans to

develop a process to monitor these contracts.

Specialized Organizational Units Although not required to do so by the MFO, CFSA has added staff to

existing organizational units that address relationships with the court and

the processing of interstate placements for children. While both units have

helped the agency address specific problems, the units face ongoing

challenges related in part to high social worker caseloads and the agency’s

difficulties in securing placements for children.

Since 1998, CFSA has added nine positions to its Court Liaison Unit, which

formerly consisted of one person.40 The unit is to track all court reports and

court orders, submit court reports and case plans in timely fashion, and

38CFSA’s FACES system has the ability to aggregate social workers’ detailed ratings of

contractor performance to provide specific feedback at contract renewal. However, to be

effective, this mechanism depends on complete data entry, and social workers were not

consistently using this feature as of October 2000, according to the deputy receiver for

operations.

39The residential treatment centers are located throughout the country. For example, there

are centers serving youth in CFSA’s care in Florida, Massachusetts, New Mexico,

Pennsylvania, South Carolina, and Texas. According to CFSA’s residential treatment

coordinator, there were about 130 youths in these centers as of August 2000.

40Of the current staff assigned to the unit, three social services assistants were assigned as

recently as May 2000.
Page 26 GAO-01-191 District of Columbia Child Welfare

maintain relationships with the judges. Despite these additional resources,

as of July 2000, Superior Court judges said that social workers consistently

fail to submit court reports and case plans in a timely way, which adversely

affects working relationships between CFSA and the court. Social workers

we spoke to acknowledged that when caseloads become difficult

tomanage, they cannot always document case information, compounding

the court’s dissatisfaction with their performance.

Regarding interstate placements, the agency hired four social workers on a

temporary basis in May 2000 to reduce a backlog of several hundred

placements that lacked proper documentation. Numerous clearances (for

example, police clearances and medical reports) are required when

children are placed in foster homes. Because these clearances require lead

time to process, children were placed outside the District before all the

paperwork could be completed. According to CFSA officials and social

workers, CFSA continued making such placements without completing all

the necessary documentation, effectively violating the ICPC requirement to

provide sufficient information to the state where the placement is made.

Agency staff cited several factors that contributed to the growth of the

backlog. For example, some children were required to be placed out of

state by court order, some were placed with relatives, and, for other

children, no alternative placements were available in the District. Some

social workers said that all or most of their cases require interstate

placement and, therefore, completion of the ICPC process. CFSA reported

999 children in its ICPC backlog as of September 2000.41 The interstate

compact coordinator reported that the majority of these backlog cases

needing additional documentation were in Maryland.42 In September 2000,

CFSA, the Deputy Mayor for Children, Youth, and Families, and the state of

Maryland signed a memorandum of understanding regarding the

completion of interstate compact documentation for children already

placed in Maryland and expedited the processing of current and future

interstate compact approvals. The memorandum provides that 10 percent

of Maryland’s emergency placement slots are to be designated for District

placements of up to 30 days. According to the terms of the consent order,

CFSA will assume total responsibility for the ICPC function and will no

41Of the 999, CFSA reported that, as of September 2000, 249 ICPC packets were either being

prepared for submission or had been submitted to the District ICPC office for processing.

42The agency stated in September 2000 that it relies on 754 foster homes in Maryland for

placements; these homes represented 60 percent of all foster homes available to the agency.
Page 27 GAO-01-191 District of Columbia Child Welfare

longer need to forward paperwork to DHS for processing, creating an

opportunity to reduce processing delays.

Time Periods to Achieve

Permanent, Stable Care

As embodied in ASFA, an important goal in child welfare is to reduce the

amount of time children spend in the system and move them into

permanent placements as soon as possible. Permanent placements may

take one of several forms, such as family reunification, adoption,

independent living, and placement with a relative or guardian. Although the

number of adoptions has increased, the agency has made little progress in

moving children into other permanent placements. CFSA relies on several

processes to expedite permanency, but each has its shortcomings, and

children still spend about 3.7 years on average in the system. Moreover,

under ASFA, which requires a permanency hearing no later than 12 months

after a child enters foster care and allows the federal government to

withhold funding in the event of noncompliance, the District faces

additional pressures to reduce delays in moving children into permanency.

The MFO included various provisions to expedite processing adoption

cases.43 While the agency has been instrumental in increasing the number

of adoptions, more can be done to expedite the cases of children waiting to

be adopted. In fiscal year 1999, CFSA achieved 250 adoptions that were

made final by the District Superior Court—a record number and an

increase of almost 200 percent from 1995. In fiscal year 2000, 329 adoptions

were made final. The adoption program manager attributes the increase to

efforts that have been made to identify various ways to expedite the

processing of adoption cases, such as moving the cases of abandoned

babies directly from intake to adoptions, using the waiver of parental rights

(which can be more timely than the termination process), and setting

deadlines for paperwork submitted by pre-adoptive parents. However,

CFSA’s adoption program manager estimated that at least 600 children in

CFSA’s care with a goal of adoption are being handled by other programs,

such as traditional foster care and kinship care, and concluded that more

needs to be done to transfer adoption cases to the adoption program in a

timely way.

43For example, within 30 days of establishing a permanency goal of adoption, CFSA social

workers are to develop a plan with attorneys of OCC regarding the termination of parental

rights and, within 5 days of establishing this goal, the case should be transferred from its

original program (for example, foster care or kinship) to the adoption program.
Page 28 GAO-01-191 District of Columbia Child Welfare

Several agency processes aim to expedite moving children into permanent

care: administrative reviews, special staffings, and using new performance

standards in staff appraisals. Regarding administrative review, federal law

and the MFO require every 6 months an administrative review of the

progress toward permanency and the achievement of case plan goals for all

children in foster care.44 The objective of these reviews is to ensure that

children’s physical, social, and emotional needs are being met and that

progress toward permanency is timely. However, as shown in table 5, a

report prepared by the court-appointed monitor shows that as of July 1999,

while CFSA had made some progress in reducing the number of cases with

no review between December 1998 and July 1999, the agency had made no

progress in reducing the number of cases with untimely reviews.45

Moreover, of the cases with untimely reviews in July 1999, about half had

not been reviewed in more than a year. As of October 2000, the agency

could not provide more recent data on cases without reviews and cases

with untimely reviews.46

Table 5: The Timeliness of Case Reviews, December 1998 and July 1999

Source: Center for the Study of Social Policy.

In late 1998, CFSA began a series of special “permanency staffings”

meetings to review children’s progress toward obtaining permanent, stable

care arrangements. The effort focused on the cases of children who had

been in foster care for 15 of the past 22 months.47 CFSA plans to continue to

hold these meetings in order to reduce the backlog of cases in this category.

4442 U.S.C. 675(5)(B).

45Center for the Study of Social Policy, LaShawn A. v. Williams Progress Report as of

December 31, 1999 (Washington, D.C.: Mar. 7, 2000).

46Data on reviews were still being entered into FACES and this data entry was expected to

be complete by the end of the calendar year; once data entry is complete, the system is

expected to be able to generate the data necessary to track the timeliness of reviews.

Cases December 1998 July 1999

No administrative review 490 212

Untimely administrative reviews 362 366

47Newer cases continue to go through the administrative review process.
Page 29 GAO-01-191 District of Columbia Child Welfare

For each case reviewed, the cognizant worker and supervisor review the

case plan and the permanency goal and make suggestions for determining

whether the permanency goal is still appropriate and consistent with the

case plan. In some instances, it may be determined that the child has

reached permanency and that the case is ready to be closed. However, the

meetings do not routinely include legal advice that may be required to

determine whether a case is ready to be closed. In February 2000, a District

Superior Court official reviewed 68 cases that were subject to these special

permanency staffings and found that, for most cases, documents contained

insufficient information to make a determination of case closure and that

legal input to determine whether certain legal standards (for example,

“reasonable efforts”) had been met was lacking.48

Finally, according to CFSA officials, children’s movement toward

permanency will be considered in a new staff appraisal process that

incorporates performance standards developed by the firm of Arthur

Andersen.49 While this step would enhance individual social worker

accountability for progress toward permanency, the performance

standards had not been implemented in September 2000 as planned,

pending resolution of a citywide collective bargaining process.

While CFSA needs to demonstrate more progress in moving children into

permanent placements, the implementation of ASFA, with its specific time

periods and financial penalties, introduces new risks for CFSA’s federal

funding.50 Federal regulations provide for periodic audits of states’

48Established under the Adoption Assistance and Child Welfare Act of 1980 (Pub. L. No. 96-

272), the term “reasonable efforts” is not defined in federal statute or regulations and has

been interpreted in a wide variety of ways by states and the courts. According to HHS,

services offered or provided to the family, such as family counseling, respite care, and

substance abuse treatment, have often been considered to constitute reasonable efforts to

prevent a child from being removed from home or to return a child home.

49Larry A. King, Development of Performance Standards (Washington, D.C.: Arthur

Andersen, June 20, 2000).

50For example, ASFA modified the definition of the case review system to require a

permanency hearing no later than 12 months after a child entered foster care and the filing

of a petition to terminate parental rights when a child has been in foster care for 15 of the

most recent 22 months or a court has determined that a child is abandoned or the parent has

murdered another child (or committed certain other offenses). See 42 U.S.C. 675(5)(C) and

(E). Failure to comply with these and other requirements can jeopardize federal funding for

foster care maintenance payments. See 45 C.F.R. 1356.21(a).
Page 30 GAO-01-191 District of Columbia Child Welfare

substantial compliance with ASFA.51 The audits review outcomes and

timeliness on small samples of about 30 to 50 cases. If CFSA is deemed out

of substantial compliance with ASFA, penalties could be imposed,

jeopardizing a portion of the agency’s federal funding. CFSA officials

expect that HHS will conduct this audit in July 2001.

The District’s Efforts to

Provide More

Collaborative Services

Are Limited in Scope

Our previous work and studies by other organizations have shown that

certain systemwide initiatives are critical to improving child welfare

outcomes. Critical initiatives include collaborative operations among the

agencies that provide child welfare and other support services, as well as

case-specific initiatives aimed at bringing together children, family

members, social workers, attorneys, and others to help address the needs

of children and their families.52 Some participants in the District’s child

welfare system have recently taken initial steps to improve operations. For

example, District agencies have initiated recent efforts to integrate child

welfare services with other family services. However, systemwide

collaboration has not yet been fully developed, leaving the District’s child

welfare system hampered by continued fragmentation. In addition, while

some District families have access through the collaboratives to an

approach called family case conferencing that brings relatives into

decision-making around a child’s well-being, CFSA has not adopted this

approach in its own practice with families.

Collaboration on Two Levels

Is Critical to Effective Child

Welfare Systems

In our earlier testimony, we reported that effective working relationships

among key child welfare system participants who play a role in keeping

children safe are essential to successful reform efforts.53 In order to

function effectively, child welfare agencies need a rich array of services to

meet the needs of abused and neglected children and their families. Rarely,

however, does a single state or local agency have control over acquiring all

the needed services, and many of those services, such as mental health care

and drug treatment, are outside the control of the child welfare agency.

Therefore, strong collaboration among all stakeholders who play a role in

5145 C.F.R. 1355.31-1355.39 (as added Jan. 25, 2000).

52Case-specific initiatives focus on practice at the case level rather than the system or

interagency level.

53Foster Care: Status of the District of Columbia’s Child Welfare System Reform Efforts

(GAO/T-HEHS-00-109, May 5, 2000).
Page 31 GAO-01-191 District of Columbia Child Welfare

helping children and families, such as the courts, private provider agencies,

neighborhood collaboratives, the police department, local government

leaders, substance abuse and mental health agencies, and agency legal

counsel, is essential to obtaining the necessary services.

Collaborative approaches can occur on two levels—some focus on

integrating the key child welfare system participants to develop joint

solutions to cross-cutting problems, and others focus on building

collaboration in making decisions on individual child welfare cases. In our

earlier testimony, we reported that strong collaboration among all

stakeholders who play a role in helping children and families is essential to

obtaining necessary services.54 For example, jurisdictions in five states—

California, Florida, Illinois, North Carolina, and Ohio—have convened

multidisciplinary advisory committees to work on resolving turf battles,

dispel the mistrust among system participants, and develop and implement

reforms. Committees were typically composed of representatives from key

groups such as child welfare agencies, attorneys, judges, court-appointed

special advocates, and other advocates.55

For example, Cook County, Illinois, established a Child Protection

Advocacy Group of 32 individuals representing all offices of the court, the

child welfare agency, private social service agencies, legal service

providers, advocacy groups, and universities. The group’s subcommittees

focus on various issues such as formulating alternatives to court

intervention, making decisions in the best interest of the child, and

terminating parental rights. To help reform the child welfare system and the

court’s role in it, the group was charged with advising the presiding judge

on all matters relating to improving the court’s Child Protection Division.

Participants in these groups noted that working together in this way

provided a unifying force that was invaluable in initiating and

institutionalizing reforms.

In a 1999 report, the National Association of Public Child Welfare

Administrators, an affiliate of the American Public Human Services

Association, also cited the benefits of interagency collaboration. According

to the association, an interagency approach to providing child protection

54GAO/T-HEHS-00-109.

55Court-appointed special advocates, usually volunteers, are trained to assist the court and

oversee a child’s case.
Page 32 GAO-01-191 District of Columbia Child Welfare

and other services can improve agency coordination, identify service gaps,

and advocate for needed resources.56

Other jurisdictions across the country have taken a different approach to

building collaboration by pooling or blending funds from multiple funding

sources to obtain the needed services on a more integrated, systemwide

basis. For example, Boulder County, Colorado, pooled its child welfare

allocation from the state with funding from the mental health agency and

the youth corrections agency to provide joint programming and placement

decision-making for adolescents in need of out-of-home care in group or

residential settings. Similarly, the Wraparound Milwaukee program in

Wisconsin blended Medicaid, child welfare, and federal grant funds into a

single buying pool to purchase individualized, family-based services to help

children placed in residential treatment centers return to their families,

foster homes, or other living arrangements in the community.57

Other collaborative efforts focused on improving decision-making on

individual cases, intervening at key points to gather and share

comprehensive information among participants. For example, Day One

Conferences in North Carolina’s District 20 are held on the first business

day after a child is taken into custody by the child welfare agency. In

attendance are the parents, child welfare caseworkers, guardians ad litem,

public and mental health liaisons, attorneys, public education liaisons,

child support liaisons, and law enforcement officers.58 These meetings

provide a forum to arrange immediate services for the family and provide

an opportunity to reach agreement on many aspects of the case outside the

courtroom, thus reducing the number of times a case is continued in

court.59 Our previous work showed that state and local officials who had

implemented these conferences believe that additional time invested at the

beginning of a case can shorten the length of time it takes to make a

56American Public Human Services Association, Guidelines for a Model System of Protective

Services for Abused and Neglected Services and Their Families, rev. ed. (Washington, D.C.:

1999).

57The county child welfare agency and the state health care financing agency each agreed to

pay a specific monthly rate for services to children. These funds were pooled with a federal

grant to pay the costs of residential treatment, group and foster care, and all other services

except physical health care.

58Guardians ad litem are attorneys or trained volunteers who represent a child in court,

investigate the case, and monitor case progress.

59Judges continue a case by rescheduling it for another day.
Page 33 GAO-01-191 District of Columbia Child Welfare

permanent placement decision.60 The National Council of Juvenile and

Family Court Judges has also provided guidance on how to improve casespecific decision-making in child abuse and neglect cases. The council

reported that the nation’s juvenile and family courts need clear guidance on

how they can best fulfill their responsibilities in child abuse and neglect

cases. According to the council, such guidance should explain the decisionmaking process in these cases and identify the individuals required to

attend applicable proceedings.61

District Agencies Have

Undertaken Initial

Collaborative Efforts

In the District of Columbia, numerous and diverse agencies provide

programmatic and legal services for the many children in CFSA’s custody,

as depicted in figure 1. District officials and child welfare experts familiar

with the District acknowledge that collaboration is key to protecting

children. Toward this end, various District agencies and others have

undertaken initial efforts to work together to improve services for children

and families. However, these efforts have been limited in scope. The

information below highlights such interagency efforts.

60Juvenile Courts: Reforms Aim to Better Serve Maltreated Children (GAO/HEHS-99-13, Jan.

11, 1999).

61National Council of Juvenile and Family Court Judges, Resource Guidelines: Improving

Court Practice in Child Abuse and Neglect Cases (Reno: 1995).
Page 34 GAO-01-191 District of Columbia Child Welfare

Figure 1: Key Participants in the District of Columbia’s Child Welfare System

a

Leads a remedial project intended to expedite case review for children in foster care 15 of the past 22

months.

b

A nonprofit, nongovernment agency reporting directly to the U.S. District Court.

Source: CFSA data and interviews with system participants.
Page 35 GAO-01-191 District of Columbia Child Welfare

• Children’s Advocacy Center. Created in 1995, the D.C. Children’s

Advocacy Center—“Safe Shores”—operates a nonprofit organization in

partnership with the District and federal government agencies. The

center coordinates the work of an interagency, multidisciplinary team

that investigates allegations of physical and sexual abuse of children.

The interagency team includes law enforcement officers, social service

officials, prosecution attorneys, mental health workers, medical

personnel, and victim advocates. Despite the collaborative efforts

spearheaded by the center, its efforts focus on the population of

physically and sexually abused children and do not reach the population

of neglected children.

• Family Reunification. Recognizing the central role proper housing can

play in helping to reunify children and their families, CFSA and the

District’s Housing Authority have worked together to help families

obtain suitable housing. Funds from the U.S. Department of Housing

and Urban Development support this effort for the benefit of families

with children in CFSA’s custody, among other program participants.

However, the demand for housing in this program exceeds the supply.

• Court Reform Project. The D.C. Superior Court and CFSA have had

difficulty sustaining effective working relationships, as discussed

previously. To address these difficulties, the court, in conjunction with

the National Council of Juvenile and Family Court Judges, has been

selected to participate in a court reform project aimed at applying best

practices to court processes, including practices to improve working

relationships between CFSA and other selected child welfare system

participants.

Another approach to improving collaboration across programs and

systemwide operations is pooling or blending funds. To help facilitate

access to various funding sources, CFSA has budgeted for emergency cash

assistance to help finance such needs as one-time rent deposits, furniture,

and clothing. While such assistance may help social workers and other staff

gain access to funds in support of multiple needs, these budgeted funds do

not cover other service needs, such as mental health services for children

living with their birth parents or kin. The separation of funding streams that

are tied to different programs may also hamper the ability to pool or blend

funds across programs or to target funds appropriately. According to the

Children’s Advocacy Center Executive Director’s testimony in May 2000,

the historical lack of a citywide strategic funding plan for maltreated

children has adversely affected the prevention of child abuse and has

allowed funding from multiple sources to determine programming rather
Page 36 GAO-01-191 District of Columbia Child Welfare

than permitting the needs of the community’s children to drive the system’s

response.62

In addition to collaborative efforts involving specified agencies and funding

sources, several CFSA officials, District officials, and other child welfare

experts we spoke with suggested that systemwide authority is needed to

provide overarching leadership and accountability. The information below

highlights two existing structures to provide interagency oversight and

coordination.

• Deputy Mayor for Children, Youth, and Families. In 1999, the District’s

Mayor appointed a Deputy Mayor for Children, Youth, and Families as a

new cabinet position with responsibility for overseeing initiatives aimed

at addressing the needs of the District’s children, youth, and families. In

this position, the Deputy Mayor oversees DHS, the Department of

Health, Office on Aging, and the Department of Recreation. CFSA

management and District officials we interviewed acknowledged the

Deputy Mayor as a focal point for fostering greater communication or

collaboration among District government agencies on behalf of children

and families.

• Mayor’s Advisory Committee on Child Abuse and Neglect. During an

earlier mayoral administration, the Mayor’s office established the

Mayor’s Advisory Committee on Child Abuse and Neglect to promote

public awareness of child abuse and neglect, assist in improving

services and coordinating interagency activities, and make

recommendations regarding needs assessments and policies, among

other priorities. The committee recommends program improvements to

the Mayor. While the committee includes 27 members, as of September

2000, its membership did not include representatives from the District’s

substance abuse agency, public school system, or public housing

authority. Moreover, the committee has relatively limited funding. It

administers a $50,000 fund held in trust for the District’s children.

Case-specific initiatives can improve efforts to meet the needs of children

and their families as well. For example, District agencies recently initiated

efforts to address circumstances that undermine family stability and case

processing needs. The D.C. Superior Court’s Special Master, among other

62Testimony from Safe Shores, the D.C. Children’s Advocacy Center, before the House of

Representatives Committee on Government Reform, Subcommittee on the District of

Columbia, May 5, 2000.
Page 37 GAO-01-191 District of Columbia Child Welfare

priorities, reviews the status of child welfare cases to facilitate timely

action and reduce case backlogs.63 In addition, the Superior Court has

begun a permanency mediation pilot designed to include birth parents and

relatives in decisions concerning particular permanency goals for children,

such as adoption. Finally, two of the Healthy Families/Thriving

Communities neighborhood collaboratives began family case conferencing

practices aimed at bringing families together, with the support of trained

facilitators, to develop a strategy to support the child’s well-being. CFSA

program managers said that, consistent with a neighborhood-based service

delivery philosophy, the agency has chosen to rely on the collaboratives to

initiate efforts at achieving family case-conferencing and other casespecific collaboration, preferring instead to hold special meetings with

agency personnel, once a child is in its custody. As of September 2000,

CFSA reported that it had referred 17 families to collaborative-sponsored

family case conferencing. The receiver acknowledged that CFSA could

adopt family case conferencing for its own case practice and that such an

approach would benefit children and families. However, she said that this

approach would not be appropriate for all families.

Collaborative Efforts Are

Constrained by LongStanding Organizational

Impediments

While various entities in the child welfare system have begun efforts to

improve collaboration between CFSA and others, these efforts have been

constrained by ineffective working relationships among CFSA and other

key participants. In 1999, the Mayor’s office issued the results of a study

that reviewed the status of interagency operations in the District’s child

welfare system.64 The study found that CFSA lacks functional relationships

with critical executive branch government agencies, such as DHS, the

Department of Health, Fire and Emergency Medical Services, and the

District of Columbia public school system. In addition, CFSA staff and

Superior Court judges said the agency and the court have poor working

relationships. CFSA social workers have not consistently provided court

reports and other hearing documentation when ordered by the court, and

they have not always reported to court to attend hearings. Attorneys from

OCC have responsibility for prosecuting civil abuse and neglect cases on

behalf of the District of Columbia. CFSA attorneys acknowledge this role,

noting that OCC represents not the legal interests of children but the

63A special master is a parajudicial officer appointed to assist the court with a particular

matter or case.

64Graham and Khabo.
Page 38 GAO-01-191 District of Columbia Child Welfare

District as a whole. As a result, the opinions of CFSA social workers and

OCC attorneys are sometimes at odds. In this instance, CFSA social

workers believe that they do not have adequate representation. Moreover,

OCC management acknowledged that it does not have enough attorneys to

cover all cases. Given these resource constraints, they focus on new cases

entering the system and other critical issues.

As specified in its child welfare system emergency reform plan of October

2000, the District plans to provide additional resources to OCC to help

eliminate the backlog of foster care and adoption cases and achieve

compliance with ASFA. Toward this end, the plan requires a workload

analysis of OCC and a survey of other jurisdictions to determine the

staffing and resource levels necessary to help ensure ASFA compliance and

to expedite prosecutions for child abuse and neglect. In addition, the U.S.

District Court’s consent order requires the District to provide CFSA with

adequate legal staff to enable the agency to meet its legal obligations under

the MFO, including the creation of a legal unit within OCC to provide legal

services to CFSA.

Bifurcated responsibilities for child abuse investigations compound the

organizational fragmentation of the District’s child welfare system. Under

this bifurcated approach, the District’s criminal statutes assign MPD lead

responsibility for investigating child abuse cases. The investigatory

practices of MPD are sometimes at odds with those of CFSA social

workers, which can make it more difficult for social workers to respond to

the needs of the child and family based on their own established protocols.

Investigatory responsibilities are further complicated by resource

constraints. While the MFO requires MPD and CFSA to conduct joint

investigations of abuse cases, department and agency officials said that the

inability of both organizations to jointly staff investigations has prolonged

investigatory time periods. MPD and CFSA attributed the lack of joint

investigations to the lack of available police officers and social workers

when an instance of child abuse is first alleged. The bifurcated approach

also splits case administration responsibilities between CSS and CFSA.

According to CSS staff, they administer about 600 child abuse cases that

are not included in CFSA’s automated system. To address the difficulties

posed by having bifurcated investigatory responsibilities between CFSA

and MPD, a District task force has developed joint investigatory protocols

involving child protection workers and law enforcement officials. The U.S.

District Court’s consent order addresses the current bifurcated system and

calls for District government to enact legislation requiring CFSA and MPD

to conduct joint investigations of child abuse allegations.
Page 39 GAO-01-191 District of Columbia Child Welfare

The Structural Issues

Are Important in

Transferring CFSA

Back to the District

Long-standing challenges such as a lack of effective working relationships

in the child welfare system impede the District’s ability to fully apply best

practices to protect children. As it prepares for the transfer of CFSA to

local governance, the District faces many organizational and operational

challenges. To maximize the opportunity for the child welfare system to

improve the well-being of children and their families, District officials and

child welfare experts have acknowledged that a sound transition plan

should be developed to help facilitate this transfer. They believe this plan

should address several factors, such as the organizational context within

which the new child welfare agency would operate, the recruitment and

retention of qualified personnel, and a mechanism for ongoing oversight

and accountability.

Participants in the child welfare system took the first step and developed

an emergency reform plan at the request of the Subcommittee on the

District of Columbia of the House Committee on Government Reform.

Prepared with input from key participants in the District’s child welfare

system and presented to the subcommittee by the Mayor in October 2000,

this plan addresses the roles of OCC, MPD, the D.C. Superior Court, and

others in the District’s child welfare system.65 In October 2000, the U.S.

District Court issued a consent order terminating the receivership upon the

satisfaction of several major conditions, such as the enactment of

legislation ending bifurcated investigations of child abuse and neglect

allegations, the appointment of a child welfare agency administrator by the

District’s mayor, and the development of licensing standards for foster

homes and group homes. The order also provides for a 1-year probationary

period during which CFSA must meet specific performance standards,

such as meeting investigation time periods, complying with social work

visitation requirements, and complying with ASFA time periods, among

others. During this probationary period, the MFO is not enforceable,

allowing the District time to make improvements to the system without the

threat of litigation. At the conclusion of this period, if the court believes the

agency has performed satisfactorily, the MFO will again become fully

enforceable and the monitor will continue to report on the agency’s

compliance with the order.

65District of Columbia Child Welfare System Emergency Reform Plan, submitted to the

House of Representatives, Committee on Government Reform, Subcommittee on the

District of Columbia (Washington, D.C.: Oct. 4, 2000).
Page 40 GAO-01-191 District of Columbia Child Welfare

The plan and subsequent consent order attempt to address a number of the

organizational challenges faced by CFSA and the District’s child welfare

system as a whole. The consent order mandates that CFSA be established

as a cabinet-level agency with independent hiring authority and

independent procurement authority consistent with District law, as a

precondition for terminating the receivership. CFSA officials said that

certain benefits would be associated with separate, cabinet-level status.

These officials believe that cabinet-level status would provide CFSA with

greater independence for setting program priorities and obtaining needed

resources. For example, some officials believed this status would provide

the agency more control over recruiting staff and would allow the agency

to respond more flexibly to the needs of children and families. One official

thought that cabinet-level status would enhance service delivery and

interagency coordination.

The emergency plan and court mandates contained in the consent order

also call for additional responsibilities to be transferred to the agency. For

example, these requirements call for transferring to CFSA responsibility for

(1) implementing the ICPC from DHS; (2) licensing, regulating, and

monitoring foster and group homes from the Department of Health; and (3)

managing the child abuse cases currently handled by CSS. The emergency

reform plan also calls for, among other things, developing a communitybased service delivery system in which services are provided to children

and families in their own neighborhoods and for expanding the Safe Shores

Children’s Advocacy Center into a Children’s Assessment Center—colocating and integrating the work of all agencies involved in the

investigation and prosecution of child abuse and neglect. Accomplishing

many of these initiatives, however, would require developing and

implementing new local legislation and enhancing federal funding.

Although the emergency plan provides time periods for implementing the

initiatives, it does not discuss some of the details regarding

implementation, such as the need for new staff to handle the increased

responsibilities. A member of the Mayor’s staff indicated that the District

will develop an implementation plan as part of its legislative package

outlining how the District will carry out the requirements of the consent

order.

With respect to personnel issues, particularly those in higher-level

management positions, it remains unclear whether the CFSA staff hired as

employees under the receivership would be converted to District

government positions. About one-third of CFSA’s current workforce was

hired by the former receiver. CFSA officials added that the agency will need
Page 41 GAO-01-191 District of Columbia Child Welfare

to plan for how it will address the future employment status of these

employees upon transfer of the agency to the District. The emergency

reform plan was silent on how these personnel issues will be handled. The

consent order, however, requires the named parties to develop a plan for

addressing the status of employees hired under the receivership.

With regard to the continued need for agency oversight, District officials

outside CFSA have pointed to the need for a mechanism to ensure the

agency’s accountability in the future. Upon transfer of CFSA to the District,

the court-appointed monitor will retain responsibility for assessing the

extent to which CFSA meets the performance standards contained in the

consent order. The development of a baseline by which to measure CFSA’s

performance is a critical step in carrying out the consent order. The order

provides the monitor with the authority to establish the baselines for

compliance by conducting a case record review and by relying on CFSA

data that the monitor determines are reliable and appropriate. The monitor

will also have authority to modify the standards if the defendant or

plaintiffs believe they are unreasonable in relation to the baseline.

Conclusions CFSA faces many of the same challenges it faced more than a decade ago

when it became the subject of a class action suit filed on behalf of the

District’s abused and neglected children. Since then the agency has

continued to confront long-term managerial shortcomings, and the lack of

integration in its child welfare system has contributed significantly to the

lack of success in preventing children from entering the system and

reducing their length of stay while in the District’s care. After 5 years of

operating under receivership, CFSA has shown limited progress in meeting

the requirements of the MFO. Compounding these agency challenges, the

child welfare system—of which CFSA is a part—continues to operate

without a fully developed collaborative structure and the effective working

relationships it needs to provide integrated services to children and their

families. Moreover, the agency has not fully applied best practices to

enhance collaboration, such as family case conferencing, that could

enhance outcomes for children and families. While the goals outlined in the

emergency reform plan and consent order are a necessary first step, longterm structural and operational challenges must be considered in

transferring the agency back to local governance and to foster improved

outcomes. It will take a fully collaborative system to help ensure progress

toward improving program outcomes and sustained commitment from the

Mayor and District government to make achieving the goals a priority.

Without such collaboration and leadership, the District will continue to
Page 42 GAO-01-191 District of Columbia Child Welfare

lack the operational framework necessary to protect and meet the needs of

children and ultimately to ensure accountability for these goals.

Agency Comments and

Our Evaluation

We received written comments on a draft of this report from CFSA and one

oral comment from the District of Columbia. CFSA found the report to be

balanced in its findings but believed that clarification was needed on

several points (see app. IV). CFSA also provided a number of technical

comments that we incorporated where appropriate. One of the agency’s

comments addressed the issue of social worker caseloads. CFSA

commented that it is somewhat misleading to report caseload averages for

a team of social workers rather than an average caseload per worker in the

various program areas. When we asked CFSA for caseload data during the

course of our review, the agency provided the range of average caseloads

by team. These data do, however, reflect average caseloads carried by

workers assigned to teams in each program area. Both CFSA and the

Deputy Mayor for Children, Youth, and Families commented on the status

of the agency’s policies, indicating that policies had existed to a greater

extent than portrayed in the draft report. CFSA said it has relied on a 1995

policy handbook and subsequent policy revisions to guide the work of the

agency. CFSA further stated that it had been developing an on-line version

during the course of our review. We have reviewed the 1995 policy

handbook and we have noted the extent to which these policies address

court-mandated requirements in appendix II. However, despite the

existence of the 1995 handbook, staff we spoke to throughout the course of

our review expressed confusion over which policies and procedures to

follow and, in some cases, which policies had been approved.

As we agreed with your offices, unless you publicly announce the report’s

contents earlier, we plan no further distribution of it until 4 days from the

date of this letter. We will then send copies to the Honorable Anthony A.

Williams, Mayor of the District of Columbia, the interim receiver, and other

District officials. We will also send copies to others who are interested on

request.
Page 43 GAO-01-191 District of Columbia Child Welfare

If you or your staffs have any questions about this report, please contact

Diana M. Pietrowiak, Assistant Director, at (202) 512-6239. Other major

contributors were Christopher D. Morehouse, Elizabeth O’Toole, and Mark

E. Ward.

Diana Eisenstat

Director, Education, Workforce, and

Income Security Issues
Page 44 GAO-01-191 District of Columbia Child Welfare

Appendix I

Scope and Methodology ApApenednxidexiIs

Using primary and secondary source material, we designed our

methodology to validate the status of progress the Child and Family

Services Agency (CFSA) has made toward meeting requirements of the

modified final order (MFO). We asked CFSA to provide copies of written

policies and procedures and management information system (MIS)

reports so that we could assess its status in complying with the courtmandated requirements. We did not independently verify the accuracy of

the data in the MIS reports that CFSA provided. In addition, we reviewed

our earlier reports and studies by the American Public Human Services

Association, Child Welfare League of America, and other organizations to

identify generally accepted best practices of child welfare systems and we

assessed the extent to which the District had applied these principles in

implementing systemwide child welfare changes. In conducting our work,

we relied on a broad array of testimonial, documentary, and analytical

evidence in responding to the three research questions.

To identify the financial and operational changes that the receiver

appointed in 1997 made to comply with the MFO requirements, we

analyzed policies, procedures, and information system reports generated

by the receiver and reports from other agencies. Based, in part, on findings

contained in our testimony entitled Foster Care: Status of the District of

Columbia’s Child Welfare Reform Efforts (GAO/T-HEHS-00-109, May 5,

2000), our work focused on requirements directly related to agency

resources, services for children and families, working relationships with

other key stakeholders, and program results. These MFO requirements

direct CFSA to address staffing and caseloads, financial management,

management information systems, resource development, out-of-home

care, and family services. We also obtained and analyzed child welfare

agency policies, regulations, memorandums, and other information on

agency procedures in order to document financial and operational changes

undertaken in efforts to attain MFO compliance. To obtain a broad range of

perspectives from staff across CFSA’s program areas and with different

levels of experience, we interviewed CFSA managers, supervisors, senior

social workers, new hires, and other officials knowledgeable about the

level of agency compliance. For group interviews with agency staff, we

asked CFSA to invite employees with diverse levels of experience to meet

with us.

Regarding the efforts to initiate improvements in the District’s child welfare

system, such as interagency collaboration and the pooling or blending of

funds, we examined the extent to which such practices have been included

in the day-to-day operations of the District’s system and the challenges the
Appendix I

Scope and Methodology

Page 45 GAO-01-191 District of Columbia Child Welfare

system faces in adopting such initiatives. To make this assessment, we

identified initiatives other organizations cited as efforts intended to

improve the operations and program results of child welfare systems in

other jurisdictions. These organizations include the Annie E. Casey

Foundation, the Casey Family Program, the Child Welfare League of

America, the Edna McConnell Clark Foundation, and the National Council

of Juvenile and Family Court Judges.

To identify additional changes required to return the District’s child welfare

agency to local governance, we focused our analysis on areas that affect

the interaction of child welfare agencies with other organizations. We

obtained perspectives on these issues from CFSA staff, program officials in

other District of Columbia government agencies, and other organizations.

In addition, we analyzed transfer-related documentation developed by the

Mayor’s office and other organizations to examine proposed scenarios and

operational issues the District identified in the context of transferring

CFSA back to local governance.
Page 46 GAO-01-191 District of Columbia Child Welfare

Appendix II

District of Columbia Child Welfare System

Features the MFO Required, July 2000 ApendxiI

Featurea Developed

Under

development

No efforts

initiatedb

Protective services (intake and assessment)

Written policies and procedures for cooperative screening and

investigation with the Metropolitan Police Department (MPD) of

alleged child abuse complaints.

X

Written policies and procedures for screening complaints of

abuse and neglect to determine whether they are within the

definitions of District law.

X

Written policies and procedures for prioritizing response times to

each report of abuse and neglect.

X

Written policies and procedures for conducting risk assessments

and ensuring that the child protective services investigations and

decisions are based on a full and systematic analysis of a

family’s situation and the factors placing a child at risk and for

guiding decision-making.

X

An assessment form. X

Written policies and procedures for determining which children

(who are the subject of abuse or neglect reports or other

children in the household) should receive a complete medical,

psychological, or psychiatric evaluation.

X

Ability to produce data showing, for the children who need

medical reports, how many received them within 48 hours after

the report of neglect or abuse was supported.

X

Written policies and procedures for the reporting, investigation,

and determination of reports of neglect or abuse (including

specifications of what information must be included), in a final

determination of whether abuse or neglect has occurred.

X

A standardized form for recording final determination. X

Written policies and procedures for ensuring that workers

receive immediate access to police protection.

X

Services to children and families

Written policies and procedures for determining and ensuring

that families are referred to and receive the intensity and level of

services necessary to preserve family relationships, to prevent

additional abuse and neglect, to promote better parental care,

and to ensure good care for the child.

X

Written policies and procedures for specifying criteria for the

provision of family services and for referring families to private

agencies the agency contracts with for such services.

X

Ability to produce management data showing the actual

caseloads by worker, for workers in home-based services units.

X
Appendix II

District of Columbia Child Welfare System

Features the MFO Required, July 2000

Page 47 GAO-01-191 District of Columbia Child Welfare

Placement of children

Written policies and procedures for governing the placement

process to ensure that children are placed in the least restrictive,

most family-like setting that meets their individual needs and that

they are placed in or in close proximity to the homes and

communities in which they resided before entering the agency’s

custody.

X

Written policies and procedures for ensuring the prompt and

appropriate placement—including return home, where

appropriate—of infants who are residing in hospitals in the

District of Columbia but who are, or are soon to be, medically

ready for discharge.

Xc

Ability to produce management data showing, for children

needing medical screening on entering the agency’s custody,

those who receive screening within 24 hours.

X

Ability to produce management data showing, for children

placed in substitute care facilities and needing a thorough,

professional evaluation of their needs, those who receive

evaluation within 30 days.

X

Written policies and procedures for providing regulations to

govern all foster-care facilities it places children in.

X

Permanency planning

Written policies and procedures that establish a planning

process that initially will seek to work intensively with the child’s

parents and other appropriate family members to allow the child

to remain at home, if appropriate; in instances in which removal

is necessary, will work intensively with the child’s parents and

other appropriate family members collaboratively to return the

child home under appropriate circumstances consistent with

reasonable professional standards; and if, after all reasonable

efforts have been made but have not succeeded in returning the

child home, will assure the child an alternative, appropriate,

permanent placement as quickly as possible.

X

Written policies and procedures for ensuring that in all instances

in which a report of abuse or neglect is supported, the case is

transferred to a foster-care worker within 5 working days of the

finding.

X

Ability to produce management data showing, of all cases in

which a report of abuse or neglect is supported, those that were

transferred to a foster-care worker within 5 working days of the

finding.

X

Ability to produce management data showing, of all cases in

which a report of abuse or neglect is substantiated, those in

which a worker met with parents within 7 calendar days of the

substantiation, those in which a meeting was held after 7 days

and those in which no meeting was held.

X

(Continued From Previous Page)

Featurea Developed

Under

development

No efforts

initiatedb
Appendix II

District of Columbia Child Welfare System

Features the MFO Required, July 2000

Page 48 GAO-01-191 District of Columbia Child Welfare

Ability to produce management data showing children for whom

a case plan was not developed within 30 days.

X

Ability to produce management data showing the number of

children with a permanency goal of returning home for 12

months or more.

X

A standardized form for 90-day reviews. X

Ability to produce management data showing the number of

children with a current, valid 90-day review; number of children

without such a review.

X

Adoption

Written policies and procedures for governing the process of

freeing children for adoption and matching children with adoptive

homes.

X

Ability to produce management data showing, of the children

with a permanency goal of adoption, the number referred to the

adoption branch within 5 days of their permanency goal

becoming adoption.

X

Ability to produce management data showing the number of

children legally free for adoption and awaiting placement for

more than 6 months.

X

Supervision of children in placement

Ability to produce management data showing, of the children

placed in a DHS foster home, the number whom an agency

worker has visited at specified intervals.

X

Ability to produce management data showing, of the children

placed in a private-agency foster home, the number whom a

private agency worker has visited at specified intervals.

X

Ability to produce management data showing, of the children

placed in a foster family or facility, the number who have been

visited at specified intervals.

X

Case review

Written policies and procedures for ensuring that all children

receive administrative reviews.

X

A quality assurance report. X

Written policies and procedures by which the quality assurance

unit will conduct quality assurance reviews.

X

A standardized form used in the quality assurance process. X

Caseloads

Ability to produce management data showing the caseload

figures by worker for all workers conducting investigations of

reports of abuse or neglect.

X

(Continued From Previous Page)

Featurea Developed

Under

development

No efforts

initiatedb
Appendix II

District of Columbia Child Welfare System

Features the MFO Required, July 2000

Page 49 GAO-01-191 District of Columbia Child Welfare

Ability to produce management data showing the caseload

figures by worker for all workers providing services to families in

which the children are living in their home.

X

Ability to produce management data showing the caseload

figures by worker for all workers providing services to children in

placement, broken out by children with special needs and all

other children.

X

Ability to produce management data showing the caseload

figures by worker for all workers with responsibility for children

(including situations in which the private agency has

responsibility for both the child and the family) in placement with

a private agency.

X

Ability to produce management data showing the caseload

figures by worker for all workers with responsibility for children in

the adoption branch.

X

Written policies and procedures for using a caseload weighing

formula to ensure that workers who have caseloads that fall into

more than one category (mixed caseloads) have caseloads that

conform with the equivalent of the maximum limits.

X

Ability to produce management data showing the caseload

figures by worker for all workers with mixed caseloads.

X

Ability to produce management data showing the caseload

figures by supervisor for all supervisors.

X

A workload study. X

Ability to produce management data showing the number of

children assigned to a worker within 3 hours of the agency’s

assuming custody of the child.

X

Staffing

Ability to produce management data showing the formal

identification and assessment of District of Columbia practices

and procedures that affect the recruitment and retention of social

workers.

X

A recruitment plan for professional staff. X

Worker qualifications

Ability to produce management data showing the number of

supervisors with MSWs and the number without.

X

Ability to produce management data showing the number of

supervisors with at least 3 years of social work experience in

child welfare.

X

(Continued From Previous Page)

Featurea Developed

Under

development

No efforts

initiatedb
Appendix II

District of Columbia Child Welfare System

Features the MFO Required, July 2000

Page 50 GAO-01-191 District of Columbia Child Welfare

Training

Written policies and procedures for providing a comprehensive

child-welfare training program that will ensure that all persons

charged with responsibilities for children in the plaintiff class will

receive sufficient training to permit them to comply with the

relevant mandates of agency policy, District of Columbia law,

and all MFO provisions.

X

An assessment of staff training needs. X

Assessments of training effectiveness. X

Ability to produce management data showing the number of new

hires with 80 hours of instructional training.

X

Ability to produce management data showing the number of new

hires with 80 hours of field training.

X

Ability to produce management data showing the number of

workers with 40 hours of in-service training each calendar year.

X

Ability to produce management data showing the number of

senior workers with casework responsibility who have 24 hours

of training.

X

Ability to produce management data showing the number of

supervisors meeting within 3 months of promotion to supervisor

the requirement for 40 hours of training that is directed to

supervising child welfare social workers.

X

Ability to produce management data showing the number of

supervisors with 24 hours of in-service training each calendar

year.

X

Ability to produce management data showing the number of

foster parents completing 15 hours of training.

X

Ability to produce management data showing the number of

prospective adoptive parents completing 30 hours of training.

X

Ability to produce management data showing the number of

judges trained to date in judicial training program.

X

Ability to produce management data showing the number of

professional staff demonstrating satisfactory mastery of the

curriculum for the following training: new hire 80-hour instruction,

new hire 80-hour field, workers 40-hour in-service, senior

workers 24-hour additional, supervisors 40-hour within 3

months, and supervisors 24-hour in-service.

X

Resource development

Resource needs assessments. X

Resource development plan. X

Reports projecting the number of emergency placements, fosterhomes, group homes, therapeutic foster homes, and institutional

placements that children in the agency’s custody will require

during the next 12 months.

X

(Continued From Previous Page)

Featurea Developed

Under

development

No efforts

initiatedb
Appendix II

District of Columbia Child Welfare System

Features the MFO Required, July 2000

Page 51 GAO-01-191 District of Columbia Child Welfare

A placement implementation plan. X

Written policies and procedures for ensuring that decisions are

made promptly concerning the issuance of a license for any

foster-care facility in which a member of the plaintiff class may

be placed, including foster homes, group homes, residential

treatment centers, and other child-care facilities.

X

Written policies and procedures for monitoring all facilities and

foster homes in which children in the agency’s physical or legal

custody are placed.

X

Ability to produce management data showing the number of

foster homes and group facilities the monitoring unit visits at

least once a year.

X

Ability to produce management data showing by worker the

caseload figures for all workers monitoring foster homes.

X

Ability to produce management data showing by worker the

caseload figures for all workers monitoring group homes and

institutions.

X

Written policies and procedures for licensing relatives as foster

parents.

Xc

Contract review

Written policies and procedures for specific contract

performance and a contract performance review process for

each category of services.

X

Ability to produce information systems reports showing, for each

worker with direct responsibility for any children in the agency’s

physical or legal custody, the number of children for whom that

worker is responsible.

X

Ability to produce information systems reports showing, for each

worker with direct responsibility for any children in the agency’s

physical or legal custody, the number of children for whom that

worker is responsible for whom any of the following events either

are late or are due in the 60 days following the report: expiration

of allowed emergency care status, case plan review,

administrative review, judicial review, or dispositional hearing.

X

Ability to produce information systems reports showing, for each

supervisor who has principal responsibility for any child in the

agency’s physical or legal custody, the number of children for

whom that supervisor is responsible.

X

Ability to produce information systems reports showing all

facilities—foster homes, group homes, institutions, consortium

or other contract homes, or any other facility for which any

vacancies exist—including the name of the facility, the type of

facility, and the number of vacancies.

X

(Continued From Previous Page)

Featurea Developed

Under

development

No efforts

initiatedb
Appendix II

District of Columbia Child Welfare System

Features the MFO Required, July 2000

Page 52 GAO-01-191 District of Columbia Child Welfare

Ability to produce information systems reports showing the

number of children, by unit, who are placed in facilities—foster

homes, group homes, institutions, consortium or other contract

homes, or any other facility—that do not have current valid

permits or licenses.

X

Ability to produce information systems reports showing the

number of children, by unit, who are placed in facilities—foster

homes, group homes, institutions, consortium or other contract

homes, or any other facility—in which there are more children

than is permitted by the facility’s license or permit.

X

Ability to produce information systems reports showing each

facility—foster homes, group homes, institutions, consortium or

other contract homes, or any other facility—in which there are

more children than is permitted by the facility’s license or permit.

X

Ability to produce information systems reports showing all social

workers, by unit, who have caseloads exceeding the caseload

limits established in the MFO, including the name and

identification of the worker, the worker’s supervisor, and the size

of the worker’s caseload.

X

Ability to produce information systems reports showing all cases

in which an investigation has not been initiated within 48 hours

of the receipt of the report.

X

Ability to produce information systems reports showing all cases

in which an investigation has not been completed within 30 days

of the receipt of the report of abuse or neglect.

X

Ability to produce information systems reports showing all cases

in which a child does not have a written case plan within 30 days

of entering the department’s custody.

X

Ability to produce information systems reports showing all cases

in which a child has not received an administrative review during

the preceding 9 months.

X

Ability to produce information systems reports showing all cases

in which a child has not received a dispositional hearing within

21 months of entering the department’s custody.

X

Ability to produce information systems reports showing all cases

in which a child younger than 6 has been placed in a

congregate-care facility.

X

Ability to produce information systems reports showing all cases

in which a child has had a plan of adoption and who has not

been referred to the adoption program within 30 days of the

establishment of the permanency goal.

X

Ability to produce information systems reports showing all cases

in which a child younger than 12 has been assigned a

permanency goal of continued care.

X

(Continued From Previous Page)

Featurea Developed

Under

development

No efforts

initiatedb
Appendix II

District of Columbia Child Welfare System

Features the MFO Required, July 2000

Page 53 GAO-01-191 District of Columbia Child Welfare

Note: We selected MFO requirements for examination that we identified as key to operating child

welfare programs, such as delivering services to children and families and placing children in foster

homes and other facilities.

a

We assessed CFSA’s ability to produce written policies and procedures, management data, and

information system reports as evidence of the extent to which it had developed practices required by

the MFO.

b

A checkmark in this column indicates that unless otherwise specified, CFSA could not provide any

policy or data in response to our request.

c

In commenting on a draft of this report, CFSA reported that these written policies, procedures, or

forms had been developed or were under development. However, at the time of our review, the agency

had not provided documentation to support this development.

Source: CFSA.

Ability to produce information systems reports showing all cases

in which a child younger than 16 has been assigned a

permanency goal of independent living.

X

Written policies and procedures for maximizing funds available

to the agency through titles IV-B and IV-E of the Adoption

Assistance and Child Welfare Act of 1980, the Medicaid Act, and

Supplemental Security Income.

X

(Continued From Previous Page)

Featurea Developed

Under

development

No efforts

initiatedb
Page 54 GAO-01-191 District of Columbia Child Welfare

Appendix III

Child and Family Services Agency

Organization, September 2000 ApendxiI
Page 55 GAO-01-191 District of Columbia Child Welfare

Appendix IV

Comments From the Child and Family

Services Agency ApendxiIV

Now on page 7.

Now on page 7.

Now on page 8.
Appendix IV

Comments From the Child and Family

Services Agency

Page 56 GAO-01-191 District of Columbia Child Welfare

Now on pages 10, 15, and

16.

Now on page 11.
Appendix IV

Comments From the Child and Family

Services Agency

Page 57 GAO-01-191 District of Columbia Child Welfare

Now on page 12.

Now on page 13.

Now on page 14.

Now on page 20.

Now on page 22.
Appendix IV

Comments From the Child and Family

Services Agency

Page 58 GAO-01-191 District of Columbia Child Welfare

Now on pages 22-23.

Now on pages 24-25.

Now on page 29.

Now on page 33.

Now on page 39.

Now on pages 44-51.

Now on page 25.
Appendix IV

Comments From the Child and Family

Services Agency

Page 59 GAO-01-191 District of Columbia Child Welfare
Page 60 GAO-01-191 District of Columbia Child Welfare

Related GAO Products

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

Effects Unknown (GAO/T-HEHS-00-158, July 20, 2000).

Foster Care: HHS Should Ensure That Juvenile Justice Placements Are

Reviewed (GAO/HEHS-00-42, June 9, 2000).

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

Reform Efforts (GAO/T-HEHS-00-109, May 5, 2000).

Foster Care: States’ Early Experiences Implementing the Adoption and

Safe Families Act (GAO/HEHS-00-1, Dec. 22, 1999).

Foster Care: Effectiveness of Independent Living Services Unknown

(GAO/HEHS-00-13, Nov. 5, 1999).

Foster Care: HHS Could Better Facilitate the Interjurisdictional Adoption

Process (GAO/HEHS-00-12, Nov. 19, 1999).

Management Reform: Elements of Successful Improvement Initiatives

(GAO/T-GGD-00-26, Oct. 15, 1999).

Foster Care: Kinship Care Quality and Permanency Issues (GAO/HEHS-99-

32, May 6, 1999).

Foster Care: Increases in Adoption Rates (GAO/HEHS-99-114R, Apr. 20,

1999).

Juvenile Courts: Reforms Aim to Better Serve Maltreated Children

(GAO/HEHS-99-13, Jan. 11, 1999).

Child Welfare: Early Experiences Implementing a Managed Care Approach

(GAO/HEHS-99-8, Oct. 21, 1998).

Foster Care: Agencies Face Challenges Securing Stable Homes for Children

of Substance Abusers (GAO/HEHS-98-182, Sept. 30, 1998).

Child Protective Services: Complex Challenges Require New Strategies

(GAO/HEHS-97-115, July 21, 1997).

Child Welfare: States’ Progress in Implementing Family Preservation and

Support Services (GAO/HEHS-97-34, Feb. 18, 1997).

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