Inclusion of this MOE as part of this option may well have the effect of discouraging states from taking advantage of much-needed flexibility. We urge you to revise this requirement. With respect to the provision requiring national evaluation as it relates to the two sets of flexible funding demonstrations, we are concerned that the encouragement of the use of random assignment will have the effect of limiting states' ability to pursue these demonstrations statewide and will constrain full implementation across a state's caseload. The requirement for random assignment in the current waiver program has been significantly limiting, and, in fact, you seek to mitigate this in the Title II Waiver Modifications provisions. We urge you not to create the same problem in these new demonstrations as you simultaneously address that problem in the current waiver program.
Many states have innovative ideas they are ready to pursue in child welfare and system reform.
However, they will not be able achieve significant reform if they are not allowed the flexibility to make these programs reality. Significant restructuring of federal child welfare financing is crucial for providing the child welfare system with the capacity it needs to be accountable in terms of the outcomes of safety and permanency that are now required by law, and flexibility in federal financing would support the strides states are making toward improving the system. But, increased flexibility alone will not be enough for states to reach desired outcomes for children. In addition to making investments through better spending of existing resources, I am convinced that states also need additional federal investments in child welfare services. Both reinvestment and new investment are needed if we want to meet the increased demands, expectations and capacity needs these systems are facing.