D.C. Child and Family Services: Better Policy Implementation and Documentation of Related Activities Would Help Improve Performance
Published: 2003-05-27T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The District of Columbia (D.C.) Child and Family Services Agency (CFSA) is responsible for protecting children at risk of abuse and neglect and ensuring that services are provided for them and their families. GAO was asked to discuss the extent to which CFSA has (1) met requirements of the Adoption and Safe Families Act (ASFA) of 1997 and other selected performance criteria, (2) adopted and implemented child protection and foster care placement policies, and (3) enhanced its working relationship with the D.C. Family Court. To address these questions, GAO analyzed data from CFSA's child welfare information system, known as FACES; reviewed laws, regulations, and reports; examined case files; and interviewed officials.
section_title: What GAO Found
paragraphs: CFSA's performance relative to three sets of measures--nine ASFA requirements, eight selected performance criteria and six of the agency's foster care policies--has been mixed. The agency took actions to implement six of the nine ASFA requirements related to the safety and well-being of foster children and met or exceeded four of the eight selected foster care performance criteria, but its plans did not address all requirements not fully implemented and unmet performance criteria. CSFA has established many foster care policies, but caseworkers did not consistently implement the six GAO examined. In addition, FACES lacked data related to four of the policies reviewed for at least 70 percent of its active foster care cases. CFSA has enhanced its working relationship with the D.C. Family Court, but several factors hindered this relationship. For example, CFSA's top management and Family Court judges talk frequently about foster care case issues. However, differing opinions among CFSA caseworkers and judges about their responsibilities have hindered the relationships. CFSA officials and Family Court judges have been working together to address these hindrances.

section_title: Letter
paragraphs: The District of Columbia’s Child and Family Services Agency (CFSA) is  responsible for protecting foster care children who have been at risk of  abuse and neglect and ensuring that critical services are provided to them  and their families. In 2002, CFSA had about 3,000 children in foster care. As  a result of a history of poor performance, the U.S. District Court for the  District of Columbia placed CFSA in receivership in 1995. To help  improve its performance during receivership, CFSA made several changes,  including establishing an automated case management system, FACES. In  2000, the District Court issued a consent order establishing a process by  which the agency’s receivership could be terminated. The order also  established a probationary period, which would begin when the  receivership ended and identified performance criteria CFSA had to meet  in order to end the probationary period. In April 2001, CFSA became a  cabinet-level agency within the government of the District of Columbia, in  June 2001 the court removed CFSA from receivership, and in October 2001  responsibility for child abuse investigations was transferred from the  District’s Metropolitan Police Department to CFSA.  Additionally, new  legislation established requirements that CFSA had to meet. The Adoption  and Safe Families Act (ASFA) of 1997 mandated that all child welfare  agencies achieve timely placement of children in permanent homes. The  U.S. Department of Health and Human Services (HHS) is responsible for  setting standards and monitoring the nation’s child welfare programs,  including assessing compliance with ASFA requirements through its Child  and Family Services Reviews.  In addition, the District of Columbia Family  Court Act of 2001 required CFSA to work closely with the Family Division  of the D.C. Superior Court and the District’s Office of Corporation Counsel  (OCC). In September 2002, the court-appointed monitor reported that a  child was abused by two children in a group home licensed by CFSA.  According to the monitor, this incident, together with the history of  inadequate care and attention given this child by CFSA, indicated that its  operations and policies, especially those regarding foster care cases, may  still need improvement.
You asked us to address the following questions: (1) To what extent did  CFSA address the requirements of the Adoption and Safe Families Act of  1997 and meet selected foster care performance criteria and what plans  does it have to address unmet requirements and criteria? (2) To what  extent has CFSA adopted and implemented foster care policies that are  comparable to those generally accepted in the child welfare community,  and how has implementation affected foster care children? (3) What has  CFSA done to enhance its working relationship with the D.C. Family Court  and what factors have affected these efforts?
To address these questions, we selected three sets of measures to assess  CFSA’s performance. First, we examined CFSA’s progress in implementing  nine ASFA requirements that were related to the safety and well-being of  foster children. Second, we assessed the extent to which CFSA met or  exceeded eight selected performance criteria established during its  probationary period. Third, we assessed the extent to which caseworkers  implemented six foster care policies related to their day-to-day  responsibilities. We analyzed data in the District’s automated child welfare  information system, known as FACES; reviewed laws, regulations, and  reports; examined case files; and interviewed officials. We obtained and  analyzed automated data from FACES on all foster care cases that were at  least 6 months old as of November 30, 2002. We selected ASFA  requirements and CFSA policies directly related to the safety and well- being of foster children. We selected foster care performance criteria from  among those CFSA had to meet in order to end the probationary period  that, in our judgment, most directly related to the safety and permanent  placement of children in foster care. We reviewed federal and local laws,  regulations, foster care policies recommended by various organizations,  and reports on CFSA’s implementation of the District’s foster care  program and selected CFSA policies that covered several key foster care  management functions. We included HHS’s evaluation of how CFSA  implemented ASFA requirements in our assessment of the agency’s  performance. We independently verified the reliability of data in FACES;  however, CFSA had not entered into FACES detailed information on the  data elements we needed for our analysis with respect to about two-thirds  of the District’s active foster care cases—mostly cases that originated  prior to FACES going on-line in October 1999. To obtain information on  policy implementation, we also examined foster care case files. We  interviewed CFSA executives, managers, and supervisors; Family Court  judges, attorneys from OCC; and officials from organizations that  recommend policies applicable to child welfare programs. We conducted  our work between September 2002 and May 2003 in accordance with  generally accepted government auditing standards.  See appendix I for  additional information on our scope and methodology.
subsections: section_title: Background
paragraphs: While CFSA is responsible for protecting thousands of foster care  children, many children in CFSA’s care languished for extended periods of  time due to managerial shortcomings and long-standing organizational  divisiveness in the District of Columbia. As a result of these deficiencies,  the U.S. District Court for the District of Columbia issued a remedial order  in 1991 to improve the performance of the agency. Under a modified final  order established by the court in 1993, CFSA was directed to comply with  many requirements. In 1995, lacking sufficient evidence of program  improvement, the agency was removed from the District’s Department of  Human Services and placed in receivership. Among its efforts to improve  agency performance, CFSA established an automated system, FACES, to  manage its caseload. The District Court issued a consent order in 2000  establishing a process by which the agency’s receivership could be ended.  The order also established a probationary period, which began when the  receivership ended, and identified performance standards CFSA had to  meet in order to end the probationary period. The court-appointed  monitor, the Center for the Study of Social Policy, was to assess CFSA’s  performance and had discretion to modify the performance standards. In  April 2001, CFSA became a cabinet-level agency within the government of  the District of Columbia.   In June 2001, the court removed CFSA from the  receivership and its probationary period began.  In October 2001,  responsibility for child abuse investigations was transferred to CFSA from  the District’s Metropolitan Police Department. CFSA’s probationary period  ended in January 2003.
However, in September 2002, the court-appointed monitor reported that a  7-year old boy was abused by two children in a group home that CFSA had  licensed to provide care for 9-21 year olds. The report also identified  several actions CFSA took or failed to take and concluded that the child  was not adequately protected or served by CFSA. For example, contrary to  its policies, CFSA did not place the child with his sibling, and there was no  evidence that CFSA assessed his social, emotional, or behavioral needs.  According to the court-appointed monitor, these events indicated that  CFSA’s operations and policies may still need improvement.
CFSA operates in a complex child welfare system. Several federal laws,  local laws, and regulations established goals and processes under which  CFSA must operate. ASFA, with one of its goals to place children in  permanent homes in a timelier manner, placed new responsibilities on all  child welfare agencies nationwide. ASFA introduced new time periods for  moving children toward permanent, stable care arrangements and  established penalties for noncompliance. For example, ASFA requires  child welfare agencies to hold a permanency planning hearing—during  which the court determines the future plans for a child, such as whether  the state should continue to pursue reunification with the child’s family or  some other permanency goal—not later than 12 months after the child  enters foster care. The District of Columbia Family Court Act of 2001  established the District’s Family Court and placed several requirements on  the District’s Mayor and various District government agencies, including  CFSA and OCC. The District of Columbia Family Court Act requires the  Mayor, in consultation with the Chief Judge of the Superior Court, to  ensure that CFSA and other District government agencies coordinate the  provision of social services and other related services to individuals  served by the Family Court.
CFSA relies on services provided by other District government agencies.  For example, both the Fire Department and the Health Department inspect  facilities where children are placed, and D.C. Public Schools prepare  individual education plans for some foster care children. CFSA also works  with agencies in Maryland, Virginia, and other states to arrange for  placements of District children and also works with private agencies to  place children in foster and adoptive homes. In addition, CFSA is  responsible for licensing and monitoring organizations with which it  contracts, including group homes that house foster care children.
The management of foster care cases involves several critical steps  required by CFSA policy. (See fig. 1.) Typically, these cases begin with an  allegation of abuse or neglect reported to the CFSA child abuse hot line.  CFSA staff are required to investigate the allegations through direct  contact with the reported victim. If required, the child may be removed  from his or her home, necessitating various court proceedings handled by  the District’s Family Court. CFSA caseworkers are responsible for  managing foster care cases by developing case plans; visiting the children;  participating in administrative review hearings involving CFSA officials,  children, parents, and other officials; attending court hearings; and  working with other District government agencies. CFSA caseworkers are  also responsible for documenting the steps taken and decisions made  related to a child’s safety, well-being, and proper foster care placement, as  well as those related to developing the most appropriate goal for  permanency. Depending on their circumstances, children leave foster care  and achieve permanency through reunification with their birth or legal  parents, adoption, legal guardianship with a relative, or independence. As  of September 2002, a child’s length of stay in the District’s foster care  program averaged 2.8 years.
HHS is responsible for setting standards and monitoring the nation’s child  welfare programs. In fiscal year 2001, about $6.2 billion in federal funds  were appropriated to HHS for foster care and related child welfare  services. HHS’s monitoring efforts include periodic reviews of the  operations, known as Child and Family Services Reviews, and of the  automated systems, known as Statewide Automated Child Welfare  Information System (SACWIS) Reviews, in the states and the District of  Columbia. HHS last reviewed CFSA’s child welfare information system in  2000 and its overall program in 2001.
section_title: CFSA Undertook Actions to Implement Most ASFA Requirements Reviewed and Met Half of the Selected Performance Criteria for Child Safety and Well-Being
paragraphs: CFSA undertook actions to implement six of the nine ASFA requirements  we reviewed and met or exceeded four of the eight performance criteria  included in our study, but as of March 2003, its plans to improve its  performance did not include all ASFA requirements not fully implemented  or selected performance criteria. With regard to implementing ASFA  requirements, for example, CFSA signed a border agreement to achieve  more timely placement of District children in Maryland, which addresses  the ASFA requirement to use cross-jurisdictional resources to facilitate  timely adoptive or permanent placements for waiting children.  Table 1  summarizes CFSA’s progress in implementing the nine ASFA requirements  that we reviewed.
HHS’s review of CFSA found that the agency did not meet three  requirements. CFSA did not consistently petition the Family Court to  terminate parental rights when returning the child to his or her family had  been deemed inappropriate and the child had been in foster care for 15 of  the last 22 months. Based on its review of 50 foster care cases, HHS  reported that 54 percent of the children who were in care longer than   15 months did not have hearings initiated for the termination of parental  rights and reasons for not initiating such hearings were not documented in  the case plan or court order. HHS also found that not all cases had  hearings to review a child’s permanency goal within the timeframe  prescribed by ASFA. In addition, foster parents, relative caretakers, and  pre-adoptive parents were not consistently notified of reviews or hearings  held on behalf of the foster child. HHS found that not all caregivers and  prospective caregivers were notified of the time and place of a hearing, if  such notification took place at all.
We also analyzed automated data from FACES related to eight foster care  performance criteria and found that CFSA met or exceeded four of them.  For example, one criterion requires 60 percent of children in foster care to  be placed with one or more of their siblings; we found that as of November  30, 2002, 63 percent of children were placed with one or more siblings. The  areas in which CFSA’s performance fell short were the criteria related to  (1) caseworker visitation with children in foster care, (2) placement of  children in foster homes with valid licenses, (3) progress toward  permanency for children in foster care, and (4) parental visits with  children in foster care who had a goal of returning home. For example,  none of the 144 children placed in foster care during the 2-month period  prior to November 30, 2002, received required weekly visits by a CFSA  caseworker. Table 2 summarizes our analysis of the selected foster care  performance criteria.
CFSA’s Program Improvement Plan, a plan required by HHS to address  those areas determined not met in a CFSR, identifies how it will address  two of the unmet ASFA requirements—(1) to initiate or join proceedings  to terminate parental rights (TPR) of certain children in foster care and   (2) to ensure that children have a permanency hearing every 12 months  after entering foster care. For example, CFSA has outlined steps to  improve its filings of TPR petitions with the Family Court. To help  facilitate this process, CFSA hired additional attorneys to expedite the  TPR proceedings. The new attorneys have been trained in ASFA  requirements and in the process for referring these cases to the Family  Court. CFSA is also developing a methodology for identifying and  prioritizing cases requiring TPR petitions. In another plan, the April 2003  Implementation Plan,  CFSA states that it will redesign its administrative  review process to improve, among other things, notification and  attendance of relevant parties and to provide for a comprehensive review  of case progress, permanency goals, and adequacy of services. However,  this plan does not make it clear whether all applicable hearings and  proceedings will be included, such as permanency hearings.
Another CFSA plan, the Interim Implementation Plan, includes measures  that were developed to show the agency’s plans for meeting the  requirements of the modified final order issued by the U.S. District Court  for the District of Columbia. This plan includes actions to address three of  the four performance criteria the agency did not meet—visits between  children in foster care and their parents, social worker visitation with  children in foster care, and placement of children in foster homes with  current and valid licenses. The plan states that, for new contracts, CFSA  will require its contactors to identify community sites for parental visits to  help facilitate visits between children in foster care and their parents. The  plan also indicates that CFSA will concentrate on the recruitment and  retention of caseworkers. According to CFSA officials, caseworkers would  have more time for quality casework, including visitation with children,  parents, and caregivers, once they hire more caseworkers. Additionally,  the plan established a goal to have 398 unlicensed foster homes in  Maryland licensed by December 31, 2002. According to an agency official,  104 of these foster homes remained unlicensed as of May 14, 2003.  However, CFSA does not have written plans that address the performance  criterion to reduce the number of children in foster care who, for   18 months or more, have had a permanency goal to return home. Without  complete plans for improving performance for all measures, CFSA’s ability  to comply with the ASFA requirements and meet the selected performance  criteria may be difficult. Furthermore, unless these requirements and  criteria are met, the time a child spends in foster care may be prolonged,  or the best decisions regarding a child’s future well-being may not be  reached.
CFSA officials cited several factors that hindered their ability to fully  implement the ASFA requirements and meet the selected performance  criteria, including court-imposed requirements, staffing shortages, and  high caseloads. For example, program managers and supervisors said that  the new court-imposed mediation process intended to address family  issues without formal court hearings places considerable demands on  caseworkers’ time. The time spent in court for mediation proceedings,  which can be as much as 1 day, reduces the time available for caseworkers  to respond to other case management duties, such as visiting with children  in foster care. Furthermore, managers and supervisors reported that  staffing shortages have contributed to delays in performing critical case  management activities, such as identifying cases for which attorneys need  to file TPR petitions. However, staffing shortages are not a unique problem  to CFSA. We recently reported that caseworkers in other states said that  staffing shortages and high caseloads had detrimental effects on their  abilities to make well-supported and timely decisions regarding children’s  safety.  We also reported that as a result of these shortages, caseworkers  have less time to establish relationships with children and their families,  conduct frequent and meaningful home visits, and make thoughtful and  well-supported decisions regarding safe and stable permanent placements.
section_title: CFSA Has Established Many Foster Care Policies but Lacks Others, and the Extent of Implementation and Documentation Varies
paragraphs: CSFA has established many foster care policies, but caseworkers did not  consistently implement the six we selected. These policies covered the  range of activities involved in a foster care case, but did not duplicate  those examined in our review of the AFSA requirements or the selected  foster care performance criteria. In addition, CFSA’s automated system  lacked data on four of the six policies we examined for at least 70 percent  of its active foster care cases. Without information on all cases,  caseworkers do not have a readily available summary of the child’s history  needed to make decisions about a child’s care and managers do not have  information needed to assess and improve program operations.
subsections: section_title: CSFA Has Established Many Foster Care Policies, but Caseworkers Did Not Consistently Implement Those We Selected
paragraphs: While we previously reported in 2000 that CFSA lacked some important  child protection and foster care placement policies, CFSA has now  established many such policies and most are comparable to those  recommended by organizations that develop standards applicable to child  welfare programs. For example, CFSA has policies for investigating  allegations of child abuse, developing case plans, and establishing  permanency goals for foster children. In addition, one policy is more  rigorous than suggested standards. Specifically, CFSA’s policy requires an  initial face-to-face meeting with children within 24 hours of reported abuse  or neglect, while the suggested standard is 24 to 48 hours or longer,  depending on the level of risk to the child’s safety and well-being.  However, CFSA does not have some recommended policies, namely those  addressing (1) written time frames for arranging needed services for  children and families (e.g., tutoring for children and drug treatment for  family members); (2) limits on the number of cases assigned to a  caseworker, based on case complexity and worker experience; and   (3) procedures for providing advance notice to each person involved in a  case about the benefits and risks of services planned for a child and  alternatives to those services. CFSA managers said that the agency had not  established these policies because agency executives gave priority to  complying with court-ordered requirements.
CFSA did not consistently implement the policies we examined. We  selected six policies that did not duplicate those examined in our review  of the AFSA requirements or the selected foster care performance criteria  in order to cover most of the case management duties and responsibilities.
CFSA could not provide automated data regarding the implementation of  one policy requiring administrative review hearings every 6 months.  As  for the remaining five policies, data in FACES indicate that caseworkers’  implementation of them varied considerably. Table 3 summarizes these  five policies and the percentage of cases for which the data indicated the  policy was implemented.
The policies related to initiating face-to-face investigations and completing  safety assessments are particularly critical to ensuring children’s safety.  CFSA’s policy requires caseworkers to initiate an investigation of alleged  child abuse or neglect within 24 hours of the call to CFSA’s hot line  through face-to-face contact with the child. Also, caseworkers are required  to complete a safety assessment within 24 hours of the face-to-face  contact with the child. While it took CFSA caseworkers considerably  longer than the time specified in the policy to take these actions in some  cases, CFSA’s performance has improved. CFSA has reduced the average  time it takes to make contacts and complete the assessments. In 2000, it  took caseworkers an average of 18 days to initiate a face-to-face  investigation, whereas in 2002 the average was 2 days. Similarly,  caseworkers took an average of 30 days to complete safety assessments in  2000, whereas the average time declined to 6 days in 2002. Although there  were cases that took much longer than the 24-hour limits, there were  fewer in 2002 than in 2000. CFSA caseworkers took 5 or more days to  initiate a face-to-face investigation for 61 cases in 2000, and for 16 cases in  2002. Table 4 summarizes the number of cases for which caseworkers took  5 or more days to initiate investigations and complete safety assessments  from 2000 through 2002.
We also reviewed case files and examined related data from FACES for   30 foster care cases to assess compliance with policies requiring timely  case planning, periodic administrative review hearings, and arrangements  for needed services. The case files we reviewed were often voluminous,  inconsistently organized, and contained information that was not always  traceable to data entered in FACES. Our review found that case plans  were not routinely completed within 30 days, as required by CFSA policy.  The FACES data provided subsequent to our case file review supported  this assessment.
We also found that for almost half of the cases we examined  administrative review hearings, which are held to ensure that key  stakeholders are involved in decisions about a child’s permanent  placement, were rescheduled, resulting in their being held less frequently  than required by CFSA policy. CFSA policy requires that these hearings be  held every 6 months, and FACES automatically schedules them to occur   6 months after the most recent hearing. However, CFSA officials are  unable to track how frequently they are rescheduled or the length of time  between hearings because the system overrides the dates of prior  hearings. Agency officials explained that changes have been made to  FACES to enable them to track how many times an administrative review  is re-scheduled. Long delays between administrative review hearings could  mean delays in getting children into permanent placement. As for  arranging needed services, we could not determine from case files or  FACES whether services recommended by caseworkers were approved by  supervisors or if all needed services were provided. The FACES data  indicate that at least one service was provided for 83 percent of the cases,  but do not include a complete record of all services caseworkers  determine to be needed, nor do they indicate whether the services were  provided on a timely basis.
Officials said that several factors affected the implementation of some of  the policies we reviewed. Caseworkers’ supervisors and managers  explained that, generally, the policies were not always implemented  because of limited staff and competing demands, and the policies were not  documented because some caseworkers did not find FACES to be user  friendly. Agency officials explained that, in part, the data on the  implementation of the initial investigations and safety assessment  reflected a change in who was responsible for the initial investigation of  child abuse cases. Until October 2001, the District’s Metropolitan Police  Department had this responsibility and data on initial investigations were  not entered into FACES. CFSA now has responsibility for both child abuse  and neglect investigations. Further, program managers and supervisors  said that several factors contributed to the time frames required to initiate  face-to-face investigations, including difficulty in finding the child’s correct  home address, contacting the child if the family tries to hide the child from  investigators, and even obtaining vehicles to get to the location. Regarding  administrative review hearings, the records indicate that they were  rescheduled for a variety of reasons, such as the caseworker needing to  appear at a hearing for another case or the attorney not being able to  attend the hearing. Managers also said that the data on service delivery  was not always entered into FACES because caseworkers sometimes  arranged services by telephone and did not enter the data into FACES.
CFSA officials said that they recently made changes to help improve the  implementation of some of the policies we reviewed. They said that CFSA  has focused on reducing the number of cases for which a risk assessment  had not been completed and has reduced the number of these  investigations open more than 30 days from 807 in May 2001 to 263 in May  2002. CFSA officials said that they also anticipate a reduction in the  number of administrative review hearings that are rescheduled. They said  the responsibility for notifying administrative review hearing participants  about a scheduled hearing was transferred from caseworkers to staff in  CFSA’s administrative review unit, and they intend to provide notification  well in advance of the hearings. Additionally, another official said that  CFSA has begun testing a process to ensure that all needed services are  provided within 45 days.
Such improvements are needed because without consistently  implementing policies for timely investigations and safety and risk  assessments, a child may be subject to continued abuse and neglect.  Delays in case plan preparation and in holding administrative review  hearings delay efforts to place children in permanent homes or reunite  them with their families. Further, without knowing whether children or  families received needed services, CFSA cannot determine whether steps  have been taken to resolve problems or improve conditions for children in  its care, which also delays moving children toward their permanency  goals.
section_title: CFSA Has Established Policies and Goals for Group Homes
paragraphs: In addition to its policies for managing cases, CFSA has policies for  licensing and monitoring group homes, plans for training staff in group  homes, and a goal to reduce the number of young children in group homes.  CFSA’s policies for group homes are based primarily on District  regulations that went into effect July 1, 2002. For example, the regulations  prohibited CFSA from placing children in an unlicensed group home as of  January 1, 2003. According to CFSA officials, as of March 2003, all CFSA  group homes were licensed, except one, and CFSA was in the process of  removing children from that home. CFSA plans to monitor group homes  by assessing their compliance with contractual provisions and licensing  requirements. CFSA also plans to provide training to group home staff to  make it clear that, as District regulations require, any staff member who  observes or receives information indicating that a child in the group home  has been abused must report it. Further, CFSA has a goal to reduce the  number of children under 13 who are placed in group homes. According to  agency officials, CFSA has reduced the number of children under 13 in  group homes from 128 in August 2002 to 70 as of February 2003 and has  plans to reduce that number even further by requiring providers of group  home care to link with agencies that seek foster care and adoptive  families.
section_title: CFSA’s Automated System Lacked Data on Many Foster Care Cases
paragraphs: In our efforts to assess CFSA’s implementation of the selected foster care  policies related to the safety and well-being of children as shown in table  3, we determined that FACES lacked data on many active foster care  cases. In December 2000, we reported that FACES lacked complete case  information, and caseworkers had not fully used it in conducting their  daily casework. During our most recent review, we determined that  FACES lacked data on four of six foster care policies for at least   70 percent of its active foster care cases. Of the 2,510 foster care cases at  least 6 months old as of November 30, 2002, data were not available for  1,763. CFSA officials explained that all of these cases predated FACES,  and the previous system was used primarily to capture information for  accounting and payroll purposes, not for case management. Top agency  managers said that CFSA does not plan to make it an agency priority to  transfer information kept in paper files for cases that predated FACES into  the system. Additionally, FACES reports show that data were not available  on many of the cases that entered the foster care system after FACES  came on line. For example, complete data on the initiation of  investigations and completion of safety assessments were not available for  about half of the 943 cases that entered the foster care system after  FACES came on line. CFSA officials explained that they intend to focus on  improving a few data elements at a time for current and future events.
Having systems that provide complete and accurate data is an important  aspect of effective child welfare programs. HHS requires all states and  D.C. to have an automated child welfare information system. These  systems, known as SACWIS, must be able to record data related to key  child welfare functions, such as intake management, case management,  and resource management. In its review of FACES, HHS found CFSA’s  system was in compliance with most of the requirements and identified  several that needed improvement, including the requirements to prepare  and document service/case plans and to conduct and record the results of  case reviews. According to a CFSA official, D.C. responded to the HHS  report and made changes to address most of the findings.  He said that the  changes included redesigning the FACES screens documenting  service/case plans and the results of case reviews.  These changes were  made in collaboration with caseworkers to help improve usability.
In addition to the standards and requirements established by HHS for all  child welfare systems, the modified final order requirements established  by the U.S. District Court for the District of Columbia direct CFSA to  produce management data and many reports on their operations. For  example, the modified final order requires that CFSA be able to produce a  variety of data such as, the number of children (1) for whom a case plan  was not developed within 30 days, (2) with a permanency goal of returning  home for 12 months or more, and (3) placed in a foster home or facility  who have been visited at specified intervals.
Complete, accurate, and timely case management data enables  caseworkers to quickly learn about new cases, supervisors to know the  extent that caseworkers are completing their tasks, and managers to know  whether any aspects of the agency’s operations are in need of  improvement. Child welfare automated systems need to have complete  case data to help ensure effective management of child welfare programs.  A child welfare expert said that there is a great need to transfer  information from old case records to new automated systems. For  example, the expert said that records of older teens have been lost, and,  with them, valuable information such as the identity of the children’s  father. Without data in FACES, CFSA’s caseworkers will have to look for  paper records in the case files, some of which are voluminous. This file  review effort is much more time-consuming than reviewing an automated  report and as a result, when cases are transferred to new caseworkers, it  requires more time for them to become familiar with cases.
section_title: CFSA Has Enhanced Its Working Relationship with the D.C. Family Court by Working Collaboratively, but Hindrances Remain
paragraphs: CFSA has enhanced its working relationship with the D.C. Family Court by  working more collaboratively, but several factors have hindered these  relationships. By participating in committees and training sessions,  collocating OCC attorneys with caseworkers, and communicating  frequently, CFSA has enhanced its working relationship with the Family  Court. CFSA participates in various planning committees with the Family  Court, such as the Implementation Planning Committee, a committee to  help implement the District of Columbia Family Court Act of 2001. CFSA  caseworkers have participated in training sessions that include OCC  attorneys and Family Court judges. These sessions provide all parties with  information about case management responsibilities and various court  proceedings, with the intent of improving and enhancing the mutual  understanding about key issues.  Additionally, CFSA assigned a liaison  representative to the Family Court who is responsible for working with  other District agency liaison representatives to assist social workers and  case managers in identifying and accessing court-order services for  children and their families at the Family Court. Also, since 2002, OCC  attorneys have been located at CFSA and work closely with caseworkers.  This arrangement has improved the working relationship between CFSA  and the Family Court because the caseworkers and the attorneys are  better prepared for court appearances. Furthermore, senior managers at  CFSA and the Family Court communicated frequently about day-to-day  operations as well as long-range plans involving foster care case  management and related court priorities, and on several occasions  expressed their commitment to improving working relationships.
However, CFSA officials and Family Court judges also noted several  hindrances that constrain their working relationship. These hindrances  include the need for caseworkers to balance court appearances with other  case management duties, an insufficient number of caseworkers,  caseworkers who are unfamiliar with cases that have been transferred to  them, and differing opinions about the responsibilities of CFSA  caseworkers and judges. For example, although CFSA caseworkers are  responsible for identifying and arranging services needed for children and  their families, some caseworkers said that some Family Court judges  overruled their service recommendations.  Family Court judges told us  that they sometimes made decisions about services for children because  they believe caseworkers did not always recommend appropriate ones or  provide the court with timely and complete information on the facts and  circumstances of the case. Furthermore, the Presiding Judge of the Family  court explained that it was the judges’ role to listen to all parties and then  make the best decisions by taking into account all points of view.  Caseworkers and judges agreed that appropriate and timely decisions  about services for children and their families are important ones that can  affect a child’s length of stay in foster care.
CFSA officials and Family Court judges have been working together to  address some of the hindrances that constrain their working relationship.  CFSA managers said that scheduling of court hearings has improved.  According to agency officials, in March 2003, CFSA began receiving daily  schedules from the Family Court with upcoming hearing dates. This  information allows caseworkers to plan their case management duties  such that they do not conflict with court appearances. Also, as of March  2003, court orders were scanned into FACES to help ensure that  caseworkers and others involved with a case have more complete and  accurate information. To help resolve conflicts about ordering services,  CFSA caseworkers and Family Court judges have participated in sessions  during which they share information about their respective concerns,  priorities, and responsibilities in meeting the needs of the District’s foster  care children and their families.
section_title: Conclusions
paragraphs: CFSA has taken steps to implement several ASFA requirements, met  several performance criteria, developed essential policies, and enhanced  its working relationship with the Family Court. In addition, CFSA has  implemented new group home policies, improved the average time  caseworkers took to implement certain policies and undertaken initiatives,  in conjunction with the Family Court, to improve the scheduling of court  hearings. However, CFSA needs to make further improvements in order to  ensure the protection and proper and timely placement of all of the  District’s foster care children. By implementing all ASFA requirements,  meeting the performance criteria and effectively implementing all policies,  CFSA will improve a child’s stay in the foster care system and reduce the  time required to attain permanent living arrangements. Furthermore,  complete, accurate, and timely case management data will enable  caseworkers to quickly learn about new cases and the needs of children  and their families, supervisors to know the extent to which caseworkers  are completing all required tasks, and managers to know whether any  critical aspects of the agency’s operations are in need of improvement.  Without automated information on all cases, caseworkers do not have a  readily available summary of the child’s history, which may be critical to  know when making plans about the child’s safety, care, and well-being.
section_title: Recommendations
paragraphs: To improve CFSA’s performance and outcomes for foster care children in  the District of Columbia, we recommend that the Mayor require the  Director of CFSA to (1) develop plans to fully implement all ASFA  requirements; (2) establish procedures to ensure that caseworkers  consistently implement foster care policies; and (3) document in FACES  all activities related to active foster care cases, including information from  paper case files related to the history of each active foster care case.
section_title: Agency Comments and Our Evaluation
paragraphs: We received written comments from the Director of the District of  Columbia’s Child and Family Services Agency who provided them on  behalf of the Deputy Mayor for Children, Youth, Families, and Elders.   These comments are reprinted in appendix II.  The Director generally  agreed with our findings related to the extent to which CFSA implemented  ASFA requirements, developed policies, and improved its relationship with  the D.C. Family Court.  Although the CFSA Director did not directly  address the recommendations, she generally agreed with the areas we  identified for continued improvement and said that CFSA is deeply  committed to continuing improvements in the FACES information system.
Additionally the Director provided overall comments concerning the   (1) implementation plan, (2) establishment of CFSA, and (3) timeframes of  the receivership. CFSA suggested that we modify the report to reflect  strategies listed in the April 2003 Implementation Plan regarding timely  notification and reducing the number of children in foster care for   18 months or more with a permanency goal of returning home.  We  changed the report to reflect the notification strategy but did not make  changes regarding children and their progress towards permanency  because the April 2003 plan did not include a relevant strategy. CFSA also  suggested that we include the date the agency was established as a single  cabinet-level District agency and the date the agency gained responsibility  for abuse cases from the Metropolitan Police Department. We made these  changes. Additionally, CFSA recommended that we discuss the policy  implementation trends earlier in the report, and asked that we note the  time period for the cases included in the HHS review, which we did.  CFSA  also asked that we explain that the data we collected and analyzed  generally covered the October 1999 to mid-2002 period.  We did not make  this change.  As explained in the scope and methodology section of the  report, we reviewed and analyzed a variety of data related to all active  foster care cases.  Some of the data was as of November 2002, and some  analyses were based on active cases that began prior to October 1999.
The CFSA Director also made several detailed comments.   As she  suggested, we added language to clarify the requirement for a permanency  hearing, included information on changes made to FACES regarding  rescheduling administrative reviews and corrected the number of CFSA  staff assigned to the Family Court.  We did not include the March 2003  data listed in the comments because we could not verify the accuracy of  the data.
Although the CFSA director did not directly address the  recommendations, we continue to think that in order for CFSA to further  improve its performance, the agency should develop plans to fully  implement all ASFA requirements, establish procedures to ensure that  caseworkers consistently implement all foster care policies, and document  in FACES all activities related to active foster care cases.
As agreed with your office, unless you publicly release its contents earlier,  we will make no further distribution of this report until 30 days after its  issue date. At that time, we will send copies of this report to the Mayor of  the District of Columbia; the Deputy Mayor for Children, Youth, Families,  and Elders; the Director of the District of Columbia Child and Family  Services Agency; and the Chief Judge of the District of Columbia Superior  Court.  We will also make copies of this report available to others on  request.  In addition, the report will be available at no charge on GAO’s  Web site at http://www.gao.gov.
If you have any questions about this report, please contact me on (202)  512-8403.  Other contacts and staff acknowledgments are listed in  appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: To provide a comprehensive assessment of the Child and Family Services  Agency’s (CFSA) performance relative to Adoption and Safe Families Act  of 1997 (ASFA) requirements and selected foster care performance  criteria, we relied on several sources of information and analyses. We  reviewed the U. S. Department of Health and Human Services’ (HHS) Child  and Family Services Review (February 2002) and obtained and analyzed  data to assess CFSA’s implementation of ASFA’s requirements. Our  analysis of CFSA’s implementation of ASFA identified whether the agency  had implemented procedures in accordance with the ASFA requirements  and did not assess the extent to which or how well it had implemented the  requirement across all applicable foster care cases.
To perform our assessment of CFSA’s performance with regard to the  selected performance criteria established during its probationary period,  we obtained and analyzed relevant automated data from FACES on all  active foster care cases as of November 30, 2002, the last complete month  for which data were available at the time of our work.  We analyzed these  data for six of the eight criteria.  For the other two criteria, we analyzed  data on all foster homes as of November 30, 2002, and data on case plans  as of September 30, 2002.  Additionally, we obtained and analyzed  automated FACES data for 943 foster care cases that were at least 6  months old as of November 30, 2002, to assess how CFSA caseworkers  implemented foster care policies that covered several key functions from  investigations through the delivery of services to foster children and their  families. Many of the active foster care cases began prior to October 1999.
We also obtained and analyzed reports by the court-appointed monitor to  assess CFSA’s performance relative to the specified requirements and  criteria. In addition, we reviewed and included relevant information from  several of our prior reports on CFSA and the District’s Family Court. In  addition, we independently verified the reliability of automated data by  reviewing related reports on the data maintained in FACES and by  assessing the degree to which FACES contained erroneous or illogical  data entries. To obtain additional information on policy implementation  and documentation, we reviewed case files for children who entered the  foster care system at different times. Our case file review included  analyses of data contained in FACES and in paper case files for selected  foster care cases. We pretested our data collection instrument for  collecting case file information and received training in the content and  use of FACES. In addition, while FACES did not contain all data on the  implementation of the policies we selected, we analyzed information on  CFSA’s most recent performance to provide a comprehensive assessment  of various agency initiatives intended to improve implementation of foster  care policies. We also reviewed federal and local laws, regulations, and  selected CFSA policies. Using interview protocols, we interviewed CFSA  executives, managers, and supervisors; OCC officials; the Office of the  Deputy Mayor for Children, Youth, Families, and Elders; Family Court  judges and other court officials; and child welfare experts in organizations  that recommend policies applicable to child welfare programs.
section_title: Appendix II: Comments from the Director of the Child and Family Services Agency
section_title: Appendix III: GAO Contacts and Acknowledgments
subsections: section_title: GAO Contacts
section_title: Acknowledgments
paragraphs: The following individuals also made important contributions to this report:  Sheila Nicholson, Vernette Shaw, Joel Grossman, and James Rebbe.
section_title: Related GAO Products
paragraphs: D.C. Child and Family Services: Key Issues Affecting the Management of  Its Foster Care. GAO-03-758T. Washington, D.C.: May 16, 2003.
Foster Care: States Focus on Finding Permanent Homes for Children,  but Long-Standing Barriers Remain. GAO-03-626T. Washington, D.C.:  April 8, 2003.
District of Columbia: Issues Associated with the Child and Family  Services Agency’s Performance and Policies. GAO-03-611T. Washington,  D.C.: April 2, 2003.
Child Welfare: HHS Could Play a Greater Role in Helping Child Welfare  Agencies Recruit and Retain Staff. GAO-03-357. Washington, D.C.: March  31, 2003.
District of Columbia: More Details Needed on Plans to Integrate  Computer Systems With the Family Court and Use Federal Funds. GAO- 02-948. Washington, D.C.: August 7, 2002.
Foster Care: Recent Legislation Helps States Focus on Finding  Permanent Homes for Children, but Long-Standing Barriers Remain.  GAO-02-585. Washington, D.C.: June 28, 2002.
D.C. Family Court: Progress Made Toward Planned Transition and  Interagency Coordination, but Some Challenges Remain. GAO-02-797T.  Washington, D.C.: June 5, 2002.
D.C. Family Court: Additional Actions Should Be Taken to Fully  Implement Its Transition. GAO-02-584. Washington, D.C.: May 6, 2002.
D.C. Family Court: Progress Made Toward Planned Transition, but  Some Challenges Remain. GAO-02-660T. Washington, D.C.: April 24, 2002.
District of Columbia Child Welfare: Long-Term Challenges to Ensuring  Children’s Well-Being. GAO-01-191. Washington, D.C.: December 29, 2000.
Foster Care: Status of the District of Columbia’s Child Welfare System  Reform Efforts. GAO/T-HEHS-00-109. Washington, D.C.: May 5, 2000.