District of Columbia: Federal Funds for Foster Care Improvements Used to Implement New Programs, but Challenges Remain
Published: 2005-07-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: To help improve foster care in the District of Columbia, the Congress provided $14 million for fiscal year 2004 to the Child and Family Services Agency (CFSA), the Department of Mental Health (DMH), and the Metropolitan Washington Council of Governments (COG). These funds were for programs for early intervention, emergency support, and student loan repayments; computer technology upgrades, mental health services, and respite care (short-term care to provide relief for foster parents). GAO was asked to (1) assess whether the federal funds were being obligated and expended by the District government and COG consistent with provisions in the District of Columbia Appropriations Act, 2004, and the spending plans that were submitted to the Congress; (2) determine whether internal controls were operating effectively over the obligations and disbursements; and (3) assess the extent to which the District government and COG have implemented the foster care improvement programs and initiatives specified in the act and spending plans. GAO received written comments from CFSA, DMH, and COG. The agencies generally agreed with GAO's findings and conclusions.
section_title: What GAO Found
paragraphs: The District and COG have used the federal funds for foster care improvements as intended by the Congress and as described in their respective spending plans. As of March 31, 2005, about $13.2 million of the funds provided had been obligated, about $6.2 million of the obligated funds had been expended, and about $722,524 remained unobligated. The unobligated funds for CFSA and DMH, in the amounts of $588,859 and $30,545 respectively, ceased to be available for new obligations after September 30, 2004, and should revert to the general fund of the U.S. Treasury. However, there is no such fiscal limitation on COG's use of the funds it received; thus, its unobligated $103,120 remains available for its foster care improvement program. Internal controls were generally operating effectively over obligations related to the federal funds at CFSA and DMH. Overall, we found that authorized personnel were processing and approving transactions and transactions were adequately supported. However, we found three instances worth discussion. These involved the need for sufficient documentation, better adherence to operating procedures and greater control over physical assets. CFSA, DMH, and COG have implemented the programs and initiatives specified in the appropriations act and spending plans; however, it is too early to assess the effectiveness of some and challenges remain for others. Although implementation of the early intervention program was delayed, this program helped about 150 families. Also, the emergency support fund helped about 100 kinship families--relatives who provide foster care. However, it will be a challenge for CFSA to reduce the number of unlicensed kinship homes--one program goal. Although most of CFSA's unlicensed homes are not kinship homes, 265 of the 300 unlicensed homes are not in the District and officials from other jurisdictions will play a role in the licensing process. About 70 percent of CFSA's eligible caseworkers participated in the agency's student loan repayment program. This program was intended to help recruit and retain caseworkers, but CFSA's attrition rate increased from about 15 percent in 2003 to about 18 percent in 2004. CFSA developed an information technology plan that indicates the system upgrades will be completed by the end of 2005, and provided laptops to some caseworkers. DMH increased mental health services available to foster care children; however, it faces ongoing challenges in building its capacity to provide assessments and in securing long-term funding for treatment services. COG established a respite program for foster parents, but few families completed the required licensing process, and fewer placements were made than anticipated. It may be a challenge for COG to recruit, train, and license enough respite providers and convince foster parents to participate.

section_title: Letter
paragraphs: In fiscal year 2003, about 3,000 children in the District of Columbia (the  District) were under the care of the city’s Child and Family Services Agency  (CFSA).  Most of these children had been removed from their homes  because of abuse or neglect and were being cared for by foster parents or  relatives, known as kinship families.  These foster children and the families  that care for them need various services and support.  CFSA is the District  government agency with primary responsibility for ensuring the proper  care of these children, and it works with several other District agencies to  provide essential services to the children and their families.  One of these is  the Department of Mental Health (DMH), which provides comprehensive  mental health services to foster children as well as to other children,  teenagers, adults, and families.  Mental health services are considered  critical for children who have suffered abuse or neglect. Organizations  outside the District government also help to support the foster care system.   One such organization is the Metropolitan Washington Council of  Governments (COG), which works across jurisdictions to address issues  facing the metropolitan area, such as an insufficient number of foster  parents.
Because CFSA had a history of mismanagement and failed to protect some  of the children under its care, the Congress enacted laws and provided  funds to help improve the city’s foster care system.  The District of  Columbia Appropriations Act, 2004,  included a federal payment of $14  million for foster care improvements in the District.  Funds were provided  for (1) CFSA to establish an early intervention program to help reduce the  number of children coming into foster care, an emergency support fund to  help reduce the number of unlicensed kinship homes, and a loan  repayment program to help recruit and retain caseworkers, as well as to  upgrade its automated case management system and provide caseworkers  with computer technology to help improve case management and  caseworkers’ productivity; (2) DMH to provide all court-ordered or agency- required mental health screenings, assessments, and treatments to children  in CFSA’s care; and (3) COG to develop a program with the Foster and  Adoptive Parent Advocacy Center (FAPAC) to aid in recruitment of foster  parents and provide them with respite care (short-term care provided by  individuals licensed to care for foster children when the foster family needs  to take a break or attend to other matters).  On March 17, 2004, the District  received the $14 million federal payment, less a 0.59 percent rescission, for  a total of about $13.9 million.
In September 2004, we reported on several CFSA and DMH management  issues related to the District’s foster care system and the District’s and  COG’s plans for and use of the federal foster care improvement funds. We  found that CFSA, DMH, and COG had spending plans that were consistent  with the statutory language providing these federal funds and that only a  small portion of the foster care improvement funds had been obligated or  spent as of June 2004, in part because CFSA, DMH, and COG did not  receive the funds until March 2004.  Most of the expenditures outlined in  the spending plans were for operating costs that would continue  indefinitely once the programs were established.  At that time, it was  uncertain how the District and COG planned to fund some of these  initiatives in the long term.  We also reported that many steps had been  taken to improve the District’s foster care system, but that most of the  programs and initiatives would need sustained attention and ongoing  support to achieve the intended results.
Since the issuance of our September 2004 report, we have, as called for by  the appropriations act, reviewed the obligations and expenditures of the  fiscal year 2004 federal funds provided for foster care improvements. As  you subsequently requested, we have also assessed the status of the  programs supported by the foster care improvement funds.  Specifically,  our objectives were to (1) assess whether the federal funds were being  obligated and expended by the District government and COG in a manner  consistent with the act’s provisions and the spending plans that were  submitted to the Congress, (2) determine whether internal controls are  operating effectively over obligations related to the federal funds for foster  care improvements received by the District and COG, and (3) assess the  extent to which CFSA, DMH, and COG have implemented the foster care  improvement programs and initiatives specified in the act and spending  plans.
To analyze CFSA, DMH, and COG’s use of their fiscal year 2004 federal  funds for foster care improvements, we reviewed the agencies’ spending  plans, budget data, and internal reports of obligations and expenditures for  the period March 2004 through March 2005.  We interviewed financial and  program personnel from all three organizations and from the District  government’s central Office of the Chief Financial Officer to obtain an  understanding of the procedures and controls over the use of the funds.  In  addition, we selected a statistical sample of CFSA and DMH obligation  transactions covering the period March 17, 2004, through September 30,  2004, from total obligations to test whether procedures were properly  implemented to provide internal control over the use of the funds.  We  reviewed COG’s fiscal year 2004 financial statements audit opinion,  conducted walk-throughs of the accounting, payroll, procurement, and  payments processes in place, and analyzed its spending plans, budget, and  financial documents.  To assess the extent to which CFSA, DMH, and COG  had implemented the foster care improvement programs specified in the  appropriations act, we interviewed knowledgeable officials, reviewed  related program policies and protocols, and analyzed program data.  We  took several steps to assess the reliability and reasonableness of the  program data.  Overall, we found the data to be sufficiently reliable for the  purpose of assessing the status of the foster care improvement programs.   We conducted our work from October 2004 through June 2005 in  accordance with U.S. generally accepted government auditing standards.   See appendix I for more details on our scope and methodology.
subsections: section_title: Background
paragraphs: The child welfare system is designed to promote the well-being of children  by ensuring their safety and by strengthening families to enable them to  successfully care for their children.  Generally, families become involved  with the child welfare system after a report of abuse or neglect has been  made and confirmed. When agency officials determine that a child may be  further harmed or mistreated if left in the home, the child is placed in foster  care.
The federal government has allocated about $7 billion each year to  investigate abuse and neglect of children in this country, provide  placements to children outside their homes, and deliver services to help  keep families together.  Part E of title IV of the Social Security Act (title IV- E), as amended, is a major source of federal funding and is primarily used  to pay for the room and board of children in foster care.
Child welfare caseworkers are at the core of the child welfare system.   They are responsible for overseeing individual cases and for performing  many critical tasks such as arranging placements when children must be  removed from their homes, visiting children and foster families,  maintaining records on each case, and coordinating with other agencies to  obtain services for the children and their families. Child welfare agencies  face challenges in recruiting and retaining caseworkers.  We previously  reported that low salaries hinder agencies’ abilities to attract and retain  them.  We also found that high caseloads, administrative burdens, a lack of  supervisory support, and insufficient time for training were issues that  affected caseworkers’ abilities to work effectively and their decisions to  stay in or leave the child welfare profession.
CFSA is responsible for managing the child welfare system for the District  and it relies on services provided by other District government agencies in  order to achieve its mission.  For example, the Fire Department and the  Health Department inspect homes and facilities where foster children are  placed as part of the licensing process to ensure these homes are safe, and  the Department of Mental Health provides mental health services to  children in CFSA’s care. In addition, CFSA works with child welfare  agencies in other states to arrange for placements of the District’s children  in cases where the most appropriate foster or adoptive family lives outside  the District.  CFSA also works with private agencies to place children in  foster and adoptive homes, and with private vendors to obtain needed  services and supplies. CFSA uses an automated case management system,  known as FACES, to track each child’s case, including services rendered or  supplies obtained.  FACES is also used to record and authorize payments  for such services through an interface with the District’s core financial  management system, known as SOAR. CFSA receives title IV-E funding as  well as other federal, local, and private funds to support its programs.
CFSA had a history of managerial deficiencies that led the U.S. District  Court for the District of Columbia to issue a remedial order in 1991 to  improve the performance of the agency, and then in 1995, due to  insufficient evidence of program improvement, the agency was placed in  receivership. After almost 6 years of federal receivership, CFSA was  reorganized as a District cabinet-level agency.  Since that time, it has  worked to improve services and promote the safety and well-being of  children and families.  The U.S. District Court appointed the Center for the  Study of Social Policy (CSSP) to monitor and assess CFSA’s performance.  CSSP and we have reported that the management and operations of CFSA  have improved since the receivership, but also found that matters of  concern remained.
The District’s mental health agency was similarly placed in receivership for  over 5 years, from 1997 to 2002.   As originally established, the District’s  mental health system was not organized or funded to meet the particular  needs of children, youth, and their families.  When DMH took the place of  the Commission on Mental Health Services in 2001, it had too few providers  to accommodate the needs of the District’s foster care children.  Mental  health services—both assessments and treatment—are considered critical  for children who have suffered abuse or neglect; therefore, to better  connect foster care children with such services, CFSA began to contract  directly with mental health providers.
Over the years, the Congress has enacted laws and provided funds to help  improve the District’s child welfare system.  For example, the District of  Columbia Family Court Act of 2001 established the D.C. Family Court  dedicated solely to matters concerning the District’s children and families.   The D.C. Family Court has jurisdiction over cases involving alleged child  abuse and neglect, juvenile delinquency, domestic violence, child support,  and other family matters. In addition to establishing the Family Court, the  Congress authorized funds to the District in fiscal year 2002 for the  completion of a plan to integrate the District’s computer systems with  those of the D.C. Family Court and for CFSA’s caseworkers to help  implement family court reform.  Also, the District of Columbia  Appropriations Act,  2004, included a fiscal year 2004 federal payment of  $14 million to CFSA, DMH, and COG for improvements to specific foster  care programs. The federal funds were supplemented by private funds for  CFSA’s early intervention program and COG’s respite care and foster parent  recruitment program.  In February 2004, the District and COG submitted  their respective plans to the Congress, outlining how they intended to use  the foster care improvement funds.  Table 1 summarizes the purposes for  the funds as designated in the appropriations act and the planned  expenditures as listed in the spending plans.
section_title: CFSA, DMH, and COG Obligated and Spent Funds for Purposes Consistent with the Appropriations Act and Spending Plans, but Some Funds Were Not Used
paragraphs: We found that CFSA, DMH, and COG obligated and expended the federal  funds provided for foster care improvement for purposes consistent with  the appropriations act and organizations’ spending plans.  The funds were  used for authorized expenses such as repairs for foster homes, student loan  repayments, psychiatric evaluations, staff salaries for the family team  meeting project, and training and education materials.  For a comparison of  agency spending plans to provisions of the appropriations act, see table 1.   Additional information about the programs is provided in later sections of  this report.
On March 17, 2004, the District received the $14 million federal payment,  less a 0.59 percent rescission, for a total of about $13.9 million.  The  District sent COG a payment of $1,093,510, as specified by the  appropriations act.  The availability of the federal payment of funds  received by the District for foster care improvements was limited to fiscal  year 2004.  Any unobligated balances of funds after September 30, 2004,  were no longer available for the District’s use and should revert to the  general fund of the U.S. Treasury.  When the District disbursed funds to  COG for its use, the funds lost their federal payment character; thus there is  no fiscal time limitation on the use of the federal funds provided to COG.
As we previously reported, only a small portion of the federal funds for  foster care improvements had been obligated or spent as of June 30, 2004.   At that time, over $12.4 million of the $13.9 million provided remained  unobligated.  However, as of September 30, 2004, the District agencies and  COG had obligated about $12.6 million of their funds. Since then COG has  obligated an additional $599,000, bringing the total amount of funds  obligated as of March 31, 2005, to $13.2 million.  As of March 31, 2005, about  $6.2 million of the total obligated funds had been expended and about  $722,524 remained unobligated.  The unobligated funds for CFSA and DMH,  in the amounts of $588,859 and $30,545 respectively, ceased to be available  for new obligations after September 30, 2004, and should revert to the  general fund of the U.S. Treasury. COG’s $103,120 in federal funding  remains available for use in the respite program for foster parents of  District children.  Table 2 provides details on the amounts of the  organization’s obligations as of March 31, 2005.
section_title: Internal Controls Are Generally Operating Effectively
paragraphs: In our testing at CFSA and DMH, we concluded that internal controls were  in place over obligations of the funding provided to both District agencies  to ensure that the federal funds were expended appropriately for their  intended purposes.  Consistent with standards for internal control in  government, the agencies’ internal controls comprise a series of  appropriate actions and activities conducted throughout the agencies’  operations on an ongoing basis.   Internal control activities we tested  include (1) adequate segregation of duties so that no one person can  approve as well as execute a transaction, (2) approval of transactions by  appropriate supervisory officials, (3) sufficient documentation of  transactions, and (4) physical control over negotiable assets.  Agency fiscal  officers are charged with providing oversight to ensure that controls are  adequate to provide reasonable assurance that funds obligated and  expended are used effectively and as intended, according to the spending  plans and the appropriations act.
To test specific control activities at CFSA and DMH, we selected a  statistical sample of obligation transactions covering the period March 17,  2004, through September 30, 2004, in the sum of about $11.9 million from  foster care improvement obligations of about $12.2 million.  In addition, we  tested the District’s supporting documentation for the $1.1 million transfer  to COG.  Based on the results of our tests, we concluded that internal  controls are generally operating effectively.  Two key internal control  activities were built into the requisition and purchasing processes by the  Office of the Chief Financial Officer and Office of Contracts and  Procurement.  We found that key duties and responsibilities associated  with the sample transactions were divided (segregated) among different  staff members so that no one person could both approve and fully execute  a transaction.  Moreover, we found that key documents, such as requisition  and purchase orders, were authorized and executed by staff members  acting within the scope of their authority, and that the documents  supported the purpose and amount of the transaction. However, in  conducting our tests, we found three instances worth discussion.  These  involved the need for sufficient documentation, better adherence to  operating procedures, and greater control over physical assets.
The first instance involved documentation that did not fully describe the  transaction and a negotiable asset that was potentially vulnerable to misuse  or fraud.  In the transaction we tested, CFSA had recorded an obligation in  the emergency support fund in the amount of $9,375 for the purchase of gift  cards to be used to purchase clothing for foster children.  The transaction  was part of a requisition that totaled about $99,000 for the purchase of gift  cards from several vendors.  While the approval of the gift card purchase  was adequately documented, it was unclear whether the gift cards were  ever received because the District did not provide us documentation of  their receipt of the cards during the time of our review.  We were also  unable to determine, based on District records, whether the District had  paid for the cards.  District officials told us that the gift cards had been  received, paid for, and had not been activated for use.  However, without an  invoice or receiving document, we could not verify that the gift cards were  received or paid for, or whether the cards had been activated.  In its  comments on a draft of this report, CFSA provided additional  documentation, including the vendor invoice and financial system reports  showing receipt of the gift cards and the payment made.
While gift cards provide the flexibility to respond quickly to emergency  needs, adequate documentation and sufficient physical controls are  essential to provide accountability over their use and to ensure the  propriety of transactions.  Gift cards, similar to cash, can easily be used for  improper purchases—such as purchases excessive in cost, for purposes  other than that stated, or for personal use.  Purchased gift cards need to be  properly inventoried and stored, similar to the cash in an imprest fund.    When the gift cards are distributed, the number and dollar amount of the  cards taken from the inventory should be noted as should the identities of  the employees who received the cards.  Employees should be required to  provide receipts for items purchased with gift cards.  Periodic surprise  audits of the gift card funds would also help to safeguard the gift cards  inventory.  In its comments on a draft of this report, CFSA described its  procedures to track, monitor, and manage the distribution process of the  gift cards, including several actions recently taken and planned actions  designed to improve procedures in this area.
In the second instance, on September 28, 2004, DMH generated and issued  a purchase order for professional consulting services in the amount of  $221,637; however, a detailed contract was not executed until February 2,  2005.  District officials told us that, according to operating procedures,  there should have been an approved purchase order and signed contract  before obligating funds.  However, in order to obligate funds by September  30, 2004, the District told us that they issued a purchase order to which the  consultant agreed and both parties agreed to finalize the contract later.   District officials told us that they believe they had a valid obligation based  on the approved purchase order as agreed to by the vendor, provided the  vendor could meet all the detailed requirements specified in the purchase  order.  They further explained that during the months following the  recording of the obligation, DMH officials negotiated the final detailed  deliverables with the vendor and signed the contract in February 2005.
However, the District did not provide us with evidence that the vendor  agreed to the purchase order.  This type of procurement procedure  increases the risk that the District might lose obligated funds if it were to  later determine that the vendor could not meet the requirements indicated  in the purchase order.  While the purchase order could be later cancelled,  expiration of the funds would prevent their reobligation.  This type of  practice increases the risk to DMH that it may improperly record an  obligation where no binding agreement may exist at the time of recording  the obligation, as required by 31 U.S.C. § 1501(a).  See 34 Comp. Gen. 459  (1955).
Finally, a vendor’s invoice billed the District for 248 laptop computers.   Initial documentation provided to us by CFSA showed a handwritten  notation on the invoice by the head of CFSA’s Information Technology  branch acknowledged receipt of only 247 computers at a cost of $510,796.   District officials could not provide documentation to support the number  of computers received.  Thus, we could not verify the number actually  received.   Additional documentation provided with CFSA’s comments on a  draft of this report show that the agency purchased 247 computers with the  federal funds for foster care improvements and 1 computer with local  funds, for a total of 248 laptop computers. While we did not test the  physical control environment at the District, our Standards of Internal  Control requires agencies to establish physical control to secure and  safeguard vulnerable assets to establish accountability, and to properly  record transactions.
We did not conduct detailed tests of transactions at COG because those  transactions were included in COG’s financial statement audit performed  by an independent public accounting firm who audits COG’s financial  statements annually.  COG received an unqualified, “clean,” opinion for  fiscal years ended June 30, 2004, and June 30, 2003.   In COG’s 2004  financial statements, the Foster Care Improvements federal funding of  $1.1 million was recorded in the supplementary information—Project  Statement of Revenues, Expenditures, and Changes in Net Assets—and  audited as part of the financial audit. Furthermore, the independent auditor  did not identify any internal control weaknesses over financial reporting  and operations or any instances of noncompliance for purposes of the  reports on internal controls and compliance that are required by  Government Auditing Standards.
section_title: New Programs Have Been Implemented to Improve Foster Care, but Challenges Remain
paragraphs: CFSA, DMH, and COG have implemented the programs and initiatives  specified in the appropriations act and spending plans, and some foster  families have received needed services. CFSA began its early intervention  program a few months later than it had planned.  Nonetheless, funds from  this program, as well as the emergency support program funds have  provided needed services to some families. CFSA also established a  student loan repayment program, developed an information technology  plan, and provided laptops to some caseworkers. DMH increased the  mental health services available to foster care children, and COG and  FAPAC worked together to develop a respite program.
However, it is too early to assess the effectiveness of some programs, and  challenges remain for others.  The long-term effectiveness of the early  intervention and student loan programs cannot yet be assessed and the  information technology improvements have not been completed.  Furthermore, challenges remain that could affect the success of CFSA’s  emergency support fund initiative, as well as DMH’s ability to build  capacity to provide needed assessments and to secure long-term funding  for treatment.  Also, the future success of COG’s respite program depends  on some factors beyond the organization’s control.
subsections: section_title: Implementation of the Early Intervention Program Was Delayed, Nevertheless Needed Services Were Provided to Some Families
paragraphs: The early intervention program included two key components—the  Facilitated Family Team Meeting (FFTM) initiative and funds for various  services and supports. According to agency officials, the FFTM initiative is  the core of the program.  These meetings are intended to give families a  voice in decisions about removing a child from the home or changing his or  her placement. CFSA planned to begin holding meetings in the summer of  2004, but implementation was delayed until September. CFSA officials  stated that much of the delay was the result of time needed to train the  parties involved in the program, including caseworkers, judges, and foster  parents.  CFSA operated a pilot program from September to December  2004 for selected high-risk cases. In January 2005, CFSA began conducting  FFTMs for all cases, and as of March 2005, CFSA had held 47 FFTMs for 85  children.  Based on the outcome of the FFTMs, CFSA officials are to assess  the families’ needs and identify services and supports that may enable  children to remain safely in their own homes or with their current foster  families.  Table 3 lists services and supports eligible for program funds.
Program data show that as of April 2005, CFSA provided 207 services and  supports to 151 families and 386 children with the early intervention  program funds.   Most of the services provided were related to housing  needs such as rent, utility payments, and furniture, as shown in figure 1.
Rent (52 of 207)
Furniture (51 of 207)
The early intervention program has been operating for several months, but  officials said that the effectiveness of the program cannot yet be  determined. Agency officials said that CFSA has developed a tracking  system to follow the progress of FFTM participants and will have data to  determine whether the program has reduced the number of children  coming into CFSA’s care or the number of times a child’s placement is  changed.
section_title: Emergency Support Fund Provided Critical Services, but the Number of Unlicensed Homes Remained the Same
paragraphs: One goal of the emergency support fund is to help facilitate the licensing of  family members who are willing to provide kinship homes to care for  children who would otherwise go into traditional foster homes or  congregate care.  According to CFSA officials, the funds could be used to  help homes meet established standards by paying for expenses such as lead  abatement, home repairs, and renovation.  In addition, the funds could be  used to purchase services and items such as child care services or clothing,  as well as to provide housing assistance in the form of monthly rent (not  more than three months) or one-time security deposits.
Although efforts to advertise the funds were limited, several families  learned about and received services from this program. Kinship families  learned about the availability of funds through information provided by  caseworkers, word of mouth from other parents, and announcements in  FAPAC’s newsletters for foster parents.  As of April 2005, 99 families and  189 children had been helped by the emergency support fund and 152  services had been provided.  Furniture, rent, and utility assistance were  most often provided; however, families received other services as shown in  figure 2.  FAPAC officials said that the program has been helpful and  beneficial in helping kinship foster families become and remain licensed  foster families.
Utility (22 of 152)
Rent (30 of 152)
Furniture (34 of 152)
While the emergency support fund has assisted some families, the number  of unlicensed homes has not changed in the last year. We previously  reported that CFSA had taken a number of steps to ensure that children  are placed in licensed homes, but as of May 2004, 495 children, or 22  percent of the children in CFSA’s care, were in 308 unlicensed homes. At  that time, CFSA officials told us that the majority of unlicensed homes  entered the foster care program before new licensing standards were  issued, many were kinship homes, and many homes were located in  Maryland. Agency officials also said that CFSA was working to correct this  situation by examining these homes on a case-by-case basis to identify the  specific barrier each home faced in becoming licensed and, if possible, to  resolve the issue. As of April 30, 2005, CFSA had children in 309 unlicensed  homes.  CFSA officials explained that most of the unlicensed homes were  not kinship homes and therefore federal funds were not available to  facilitate licensing of these homes. Further, according to CFSA officials,  most of the unlicensed homes were in other jurisdictions—232 in Maryland  and 33 in other states.  CFSA, like child welfare agencies in other  jurisdictions, is faced with challenges when trying to ensure the quality of  homes outside their respective jurisdiction.  When children are placed in  homes in other jurisdictions, the home study process is complicated  because the two states’ laws and policies must be taken into consideration  and there must be coordination between the jurisdictions. The Interstate  Compact on the Placement of Children is the bridge that facilitates this  process by providing a legal and administrative framework for placing  children across state lines for foster care or adoption.  However, concerns  have been raised by state child welfare officials about the timeliness of  home studies and the quality of background checks done by staff in other  jurisdictions.
section_title: Most Eligible Caseworkers Participated in the Student Loan Repayment Program, but More Could Have Been Supported
paragraphs: About 70 percent of CFSA’s eligible caseworkers participated in the student  loan repayment program and most were approved for payments of more  than $10,000.  CFSA determined that only those caseworkers who managed  cases were eligible to apply for the program.  As of August 2004, CFSA had  310 caseworkers, and according to agency officials, 190 of them managed  cases.  CFSA officials reported that 138 of its 190 caseworkers and nine of  its contractors signed student loan repayment agreements. Most program  participants, 99, had fewer than 3 years of service and 48 had 3 years or  more of service.  The repayment amounts ranged from about $3,000 to  about $18,000 with the average at about $15,000.  According to CFSA  documents, the first payment will be made in July 2005 for those who have  met the service requirements. Figure 3 summarizes the distribution of  these loans.
Although 138 of 190 caseworkers were approved for loan repayments,  more could have been supported with the funds available. At the end of the  fiscal year, CFSA had about $408,000 remaining of the $3 million designated  for the program.  CFSA could have entered into agreements with more than  40 caseworkers with bachelor’s degrees in social work (BSW) or more than  20 with master’s degrees in social work (MSW) or some combination of  both. According to agency officials, the agency took several steps to make  certain that all eligible caseworkers were aware of the program, and they  modified the program in an effort to maximize participation.  CFSA  launched the program in June 2004. CFSA advertised the program through  weekly e-mail messages to all caseworkers, distributed flyers, printed  notifications in an agencywide newsletter, posted fact sheets on the  District government’s intranet, and placed notices in local newspapers,  including the Washington Post.  CFSA extended the application deadline  by a month and increased the maximum amount of the loan repayment  from $5,000 to $10,000 for caseworkers with BSWs and from $10,000 to  $18,000 for those with MSWs.  As the program is structured, if a caseworker  who was approved to receive a loan repayment leaves CFSA before the end  of his or her commitment, the agency will have to return the funds to the  U.S. Treasury.  Agency officials said that one reason more caseworkers did  not participate in the program was their hesitance to commit to working for  CFSA on a long-term basis.  In commenting on a draft of the report, agency  officials also said that all of the funds for the student loan repayments were  not used because the agency could neither advertise the program nor enroll  participants until after March 2004 when the funds were made available,  which was after the height of its spring recruitment season at colleges and  universities.
Even with this program, attrition rates at CFSA increased. Like other child  welfare agencies, CFSA has faced ongoing challenges in efforts to retain  caseworkers.  In fiscal year 2003, CFSA’s attrition rate for caseworkers was  about 15 percent.  In fiscal year 2004, the rate had increased to about 18  percent.  In our September 2004 report, we found a consensus among the  caseworkers we interviewed that deficiencies in CFSA’s management  practices hindered their performance and lowered their morale.  In that  report, we recommended changes to CFSA management practices. CFSA  generally agreed with our recommendations and developed a work plan  that included strategies to help retain qualified caseworkers.  We have not  assessed whether the agency has begun to implement the  recommendations.  Although the attrition rate has increased, it is too soon  to tell whether the student loan repayment program will be effective in the  long-term, particularly since all participants had to remain at CFSA at least  until July 2005.
section_title: Implementation of CFSA’s Information Technology Plan Is Not Yet Completed
paragraphs: CFSA developed an information technology plan to upgrade its child  welfare information system, known as FACES, to a Web-based system.    The information technology plan indicates that the FACES software  upgrade component is scheduled to be completed in December 2005.   In  addition, the contractor may provide maintenance and support services for  the new system through September 29, 2008.  Table 4 summarizes the key  steps in the plan and the related time frames.
Also, CFSA’s information technology plan includes the purchase of laptops  for its caseworkers.  These laptops are intended to help improve  caseworkers’ productivity and effectiveness because caseworkers can  enter case information data when away from the office.  According to the  spending plan, CFSA would initially purchase laptops for 75 percent of its  caseworkers and in phase two, laptops would be purchased for the  remaining 25 percent who had less critical need for field access. However,  it is not clear when all caseworkers will receive laptops because the date  for beginning of phase two is not listed in either the spending plan or the  information technology plan and CFSA officials could not provide a date  for this phase.
CFSA purchased and received the initial order of laptops as planned, but  the distribution process has taken months.  The final contract, signed on  September 29, 2004, allowed for CFSA to purchase laptops and related  services at a cost of about $2,000 per laptop.  On January 27, 2005,  documents showed that 247 laptops had been purchased with federal  funds—9 for FFTM caseworkers that manage the early intervention  program and the remaining 238 to be distributed among CFSA’s 310  caseworkers.  According to CFSA officials, as of May 2005, 119 laptops had  been issued to caseworkers and they expected that all laptops would be  distributed by June 2005. CFSA explained that distribution was delayed  because initially the laptops did not meet the requested memory  specifications.  CFSA further explained that after the contractor replaced  the memory modules, the agency had to load the software before the  laptops were distributed.
section_title: Mental Health Assessments and Treatments Were Provided, but DMH Faces Ongoing Challenges
paragraphs: DMH provides assessments for children referred to the agency by CFSA  and the Family Court.  From August 2004 through February 2005, DMH  reported completing 351 assessments of foster care children referred by  CFSA. During the same period, CFSA increased the number of cases  referred to DMH for assessment from 15 in August 2004 to 68 in February  2005, for a total of 292 referrals over the 7-month period.  According to  DMH officials, this sharp increase in referrals has raised the average  number of days to complete an assessment—beginning with the  appointment request and ending with the delivery of a report to the Family  Court—above the statutory time frame of 23 days as indicated in the  appropriations act.  DMH reviewed 82 cases completed from August 2004  through February 2005 and found that their evaluators took an average of  33.5 days—approximately 10 days longer than the statutory time frame—to  complete assessments.  According to DMH officials, some cases increased  the average time frame for completion.  For example, one case took 192  days. However, officials also acknowledged that the remaining  assessments, while sometimes taking as little as 1 day to complete, were,  on average, not being completed within the statutory time frame.
Since our September 2004 report, DMH has continued to build its capacity  to provide treatment to foster care children referred by CFSA.  DMH has  increased the number of outside providers it has certified to deliver  treatment to foster care children from 13 in September 2004 to 20 in  February 2005.  From August 2004 through February 2005, CFSA referred  430 cases to providers in the DMH network. In January 2005, DMH  providers began delivering three new types of treatment to foster care  children, (1) multisystemic therapy, (2) intensive home- and community- based services, and (3) mobile response and stabilization services.  DMH  previously anticipated that 300 to 500 children would receive these three  types of treatment within 1 year of the date of the signed agreements with  providers.  Agreements for these treatment services were signed in late  September 2004.  As of April 2005, 3 months into implementation of the  new types of treatment, 31 children had received multisystemic therapy, 37  had received intensive home- and community-based services, and 24 had  received some type of mobile mental health services (see table 5).   According to a DMH official, the department expects 300 children to  receive services by January 2006.
In addition to adding providers and new types of treatment, DMH began its  initiative to train providers in trauma treatment in March 2005.  The first  phase of this initiative included a baseline assessment of whether providers  use treatment practices that reflect current research.  In the second phase,  DMH began offering training sessions on those treatment practices for  DMH’s certified providers.
DMH faces ongoing challenges in building the mental health system’s  capacity to provide timely assessments and in securing long-term funding  for treatment services for foster care children.  As of April 2005, DMH  officials reported that it did not have the capacity to respond to the growing  number of referrals for assessments from CFSA.  To address this issue,  DMH officials stated that the agency was expanding its current contracts  with providers and recruiting new providers.  However, according to DMH’s  director, meeting the demand for assessments will remain an ongoing  concern.  With regard to treatment, DMH is in the process of securing long- term financing for the new services implemented with the federal funds.   DMH officials stated that the agency can obtain funds for mobile response  and stabilization through the District’s Medicaid program.  Officials also  expect that, upon approval of a requested change to the Medicaid program,  DMH will be able to obtain reimbursements for intensive home- and  community-based services and mobile response and stabilization services.   The director said that, even with the federal funds available through  Medicaid, local funds may not be sufficient to meet the treatment needs of  foster care children.
section_title: COG’s Respite Program Was More Challenging to Implement Than Expected
paragraphs: COG, in conjunction with CFSA and FAPAC, developed a respite program  for foster parents of the District’s children. Under this program, known as  “Work of Heart,” COG recruited and trained families from the District and  other surrounding jurisdictions to provide volunteer respite care.  The  program was designed to include overnight respite care provided by  licensed foster parents, as well as daytime respite programs on Saturdays  and Sundays provided by licensed organizations.
COG used various avenues to recruit parents to serve as respite providers  and made several efforts to inform foster parents about the respite  program.  According to agency officials, to recruit respite providers COG  staff attended 10 community fairs, made 11 presentations at churches and  businesses, hosted bimonthly informational meetings, and explained the  program to CFSA caseworkers.  In addition, COG distributed more than  50,000 recruitment brochures and flyers and advertised through local radio,  local journals, and newspapers to recruit respite providers.  COG also  conducted outreach efforts to inform current foster families about the  availability of respite services. They sent four mailings to all of CFSA’s  foster families and instituted an application and approval process. Current  foster parents had to complete the application and be approved in order to  receive respite services.  Furthermore, FAPAC officials coordinated the  identification and approval of four licensed organizations to provide the  daytime respite programs.
Some respite services have been provided; however, COG’s initial goal was  not met. We reported in September 2004 that COG had set as its goal to  provide 700 respite care placements by March 2005, but officials did not  know how many parents would need to be licensed to reach that goal or  how many children would need care. As of June 2005, 62 respite foster  parents had been trained, and 7 had completed the licensing process. Also  as of June 2005, 44 foster families and 86 foster children—their ages ranged  from 6 months to 17 years of age—had been approved to receive respite.   According to COG officials, six Saturday respite programs were held and  106 children participated.  For overnight respite, 26 placements were  requested and 9 were completed as of June 2005.  COG officials said that  the other requests were cancelled by the foster parents for various reasons.
COG’s initial plan did not adequately consider several factors that hindered  the program’s implementation.  For example, COG officials stated that the  initial program goal was overly optimistic because it was based on a long- running program operating in another state but did not account for  differences between the District’s needs and demographics and those of  that state.  The COG officials also said that the District’s training  requirements were longer than projected and some parents who were  interested in serving as respite volunteers were hesitant to complete the  lengthy application and licensing process. Furthermore, COG officials  stated that a major barrier to the program was the 3 to 4 month waiting  period for FBI clearances, part of the licensing process.  A COG official  explained that they were working with the Washington FBI field office and  the Metropolitan Washington Police Department to finalize a memorandum  of understanding that could reduce the time for clearances to 4 to 5 weeks.   While this step may help improve the process, the future success of the  program depends on some factors beyond COG’s control such as the  number of qualified people who volunteer to serve as respite providers and  the number of foster parents who will participate.
section_title: Concluding Observation
paragraphs: CFSA, DMH, and COG have obligated federal funds for purposes intended  by the Congress to address long-standing problems in the District’s foster  care system. The agencies and COG appear to have exercised effective  internal controls over the use of those federal funds. All programs called  for in the legislation have been implemented to some degree, and services  have been provided to some foster children and families in the District. As  in child welfare systems across the country, the agencies and organizations  working for the welfare of children in foster care face a complex set of  challenges.  Whether these programs are effective and help improve foster  care in the District may not be known for several years.
section_title: Agency Comments and Our Evaluation
paragraphs: We received written comments on a draft of this report from CFSA, DMH,  and COG. These comments are reprinted in appendixes II, III, and IV,  respectively. CFSA and FAPAC also provided technical comments, which  we incorporated where appropriate.
In commenting on a draft of this report, CFSA agreed in general with our  findings and provided a number of comments and additional information.   In response, we made several changes to the report.  We revised the report  to reflect the additional documentation provided by CFSA showing (1)  receipt of the gift cards and the payment made and (2) the purchase of one  additional laptop computer.  CFSA also described its procedures to track,  monitor, and manage the distribution of the gift cards, which we noted in  the report.  Also, we added a statement in the report explaining how the  timing of the receipt of funding impacted CFSA’s ability to use all of the  funds for the student loan repayment program and revised the information  technology section of the report after receiving and reviewing an updated  plan from CFSA.  In addition, CFSA’s comments addressed the goals of the  emergency support program and its unlicensed homes.  CFSA stated that,  while the emergency support funds were used to facilitate licensing of  kinship homes, the primary goal of the emergency support program goal  was to facilitate placement of children with kin.  We did not revise the  statement about the program goal, because the appropriations act and the  related conference report state that the fund would be used to purchase  items necessary to allow children to remain in the care of an approved  licensed family member.  With regard to its unlicensed homes, we revised  the report to reflect some of the information provided by CFSA.
We also received written comments on a draft of this report from DMH that  addressed information on delays in assessments and the department’s  capacity to deliver treatment services. DMH generally agreed with our  findings on the provision of assessments, but provided additional  information on increases in referrals, delayed assessments, and initiatives  to decrease the wait time for assessments. DMH also expressed the view  that it has the capacity to utilize Medicaid funding for treatment services.    We modified the report to reflect that DMH is in the process of securing  long-term funding for treatment services.
In its comments, COG said that recruiting the families to provide respite  has not been a challenge.  COG also said that the challenge has been  keeping volunteers’ level of enthusiasm through the arduous and lengthy  licensing process.  We modified the report to clarify that our conclusion  included all aspects of the process associated with licensing respite  providers.
We will send copies of this report to the Director of CFSA, the Director of  DMH, the Executive Director of COG, and the Chief Financial Officer of the  District of Columbia.  We are also sending copies to the Honorable Senator  Michael DeWine, who was the Chairman of the Subcommittee on the  District of Columbia Senate Committee on Appropriations when the act  was passed that provided the federal funds; to appropriate congressional  committees; and other interested parties.  We will also make copies of this  report available to others on request.  In addition, the report will be  available at no charge on GAO’s Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  Jeanette Franzel, Director, Financial Management and Assurance, at (202)  512- 9471 or FranzelJ@gao.gov,  or Cornelia M. Ashby, Director, Education,  Workforce, and Income Security Issues, at (202) 512-8403 or  AshbyC@gao.gov.  Contact points for our Offices of Congressional  Relations and Public Affairs may be found on the last page of this report.
GAO staff that made major contributions to this report are listed in  appendix V.
section_title: Scope and Methodology
paragraphs: To assess whether the federal funds were being obligated and expended by  the Child and Family Service Agency (CFSA), Department of Mental Health  (DMH) and the Metropolitan Washington Council of Governments (COG)  consistent with the provisions in the District of Columbia Appropriations  Act, 2004, and the spending plans that were submitted to the Congress, we  interviewed District and COG officials responsible for overseeing,  monitoring, and tracking the federal funds received for foster care  improvements.  We reviewed and analyzed the District and COG spending  plans and budgets, and internal reports of obligations and expenditures.
To determine whether internal controls are operating effectively, we  interviewed financial and program personnel from CFSA, DMH, COG, and  from the District government’s central Office of the Chief Financial Officer.   We reviewed operating procedures and flowcharts to understand the  procedures and controls over the use of the funds.  To further understand  the District’s processes for obligating and disbursing funds, we conducted  walk-throughs of the procedures with CFSA and DMH financial officials.
We assessed the reliability of the District’s foster care obligations data by  (1) reviewing existing documentation related to the data sources,  (2) testing the data to identify obvious problems with completeness or  accuracy, and (3) interviewing knowledgeable agency officials about the  data.  We determined that the data were sufficiently reliable for the  purposes of this report.
We selected a dollar-unit sample at a 95 percent confidence level of CFSA  and DMH obligation transactions covering the period March 17, 2004,  through September 30, 2004, totaling about $11.9 million from obligations  of about $12.2 million to test specific control activities, such as segregation  of duties, evidence of approving official review and approval, and adequacy  of supporting documentation.
We also reviewed contract files to validate that the responsible designated  officials within the agency provided the appropriate budget authorizations  to purchase and receive goods and services consistent with the  appropriations act and whether the goods or services rendered were  properly obtained and the quantity and quality of services were verified.
We did not conduct detailed tests of transactions for COG.  An independent  public accounting firm audits the financial statements of COG annually and  the federal funds provided to COG were included in its fiscal year 2004  audit.  COG received an unqualified, “clean,” opinion for fiscal years ended  June 30, 2004, and June 30, 2003. COG’s fiscal year 2004 foster care  improvements funds were recorded in the supplementary information to its  fiscal year 2004 financial statements, specifically its Project Statement of  Revenues, Expenditures, and Changes in Net Assets—and audited as part  of the financial audit. Furthermore, the independent auditor did not  identify any internal control weaknesses over financial reporting and  operations or any instances of noncompliance for purposes of the reports  on internal controls and compliance that are required by Government  Auditing Standards.  We did conduct walk-throughs of COG’s accounting,  payroll, procurement, and payment processes.  In addition, we obtained  and analyzed the COG spending plans, and budget and financial documents  related to their portion of the federal funds.
To assess the extent to which CFSA, DMH, and COG have implemented the  foster care improvement programs and initiatives specified in the  appropriations act and spending plans, we gathered and analyzed data from  various sources. We interviewed agency officials from CFSA, DMH, COG,  and Foster and Adoptive Parents Advocacy Center (FAPAC) that were  responsible for each of the programs and initiatives. Several of these  officials also responded via e-mail to several questions regarding the  program. In addition, officials from CFSA, DMH, and FAPAC prepared  written statements for congressional hearings that addressed these  programs, and we obtained and analyzed these statements. We reviewed  program policies, protocols, and plans as well as the legislation and the  spending plans. Generally, the legislation or the plans identified CFSA’s  goals and desired outcomes for the programs. Data on the number of  participants in the student loan repayment program was as of September  2004, which was the deadline for the program. We obtained program  information on the status of the other programs as of April 2005 or June  2005.  This information included budget documents, expenditure reports,  and data on services provided to children and families.  We compared this  information to the programs’ plans and goals in order to assess the extent  to which the programs and initiatives were implemented, achieved  established goals, or led to other outcomes.
We took several steps to assess the reliability and reasonableness of  program data and found the program data to be reasonable and sufficiently  reliable for the purposes of providing information on the status of the  programs and initiatives supported by the federal foster care improvement  funds provided in fiscal year 2004.  To assess the data on the services  provided by the early intervention program and emergency support fund,  we interviewed officials responsible for compiling the data and compared it  to relevant financial transaction records.  We did not contact individual  families to determine whether they received the services or products, but  we asked officials from FAPAC about the foster and adoptive parents’  views about the programs in general and the services provided.  To  evaluate the student loan repayment data, we interviewed program officials  and compared the data to the numbers previously reported by CFSA and  determined that the various subcategories—such as the number of  participants by loan repayment amounts and by years of service—equaled  the total. We also compared the totals to the financial obligations but could  not compare the data to individual payments because CFSA had not made  any payments to caseworkers as of the date of our review. To corroborate  the data on mental health services provided to foster care children reported  by DMH, we interviewed the officials from the department who were  responsible for compiling the data.  In addition, we checked the reported  data against information provided in DMH testimony before the Senate  Committee on Appropriations, reports submitted to the U.S. District Court  for the District of Columbia by the monitor of the District’s mental health  system, DMH grant agreements, and data provided by CFSA.  Finally, we  interviewed Family Court officials to corroborate assessment time frames  reported by DMH.  Data on the respite program were generally provided by  COG and corroborated by officials from FAPAC.  Upon completion of these  steps, we determined that the above-mentioned data were sufficiently  reliable for the purposes of this report.
We conducted our work from October 2004 to June 2005 in accordance  with U.S. generally accepted government auditing standards.
section_title: Comments from the District’s Child and Family Services Agency
section_title: Comments from the District’s Department of Mental Health
section_title: Comments from the Metropolitan Washington Council of Governments
section_title: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: The following individuals also made important contributions to this report:  Norma Samuel, Carolyn Taylor, Carolyn Yocom, Susan Barnidge, Sharon  Byrd, Jacquelyn Hamilton, Maxine Hattery, Deborah Peay, Vernette Shaw,  and Sandra Silzer.