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

Letter

Background

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.

CFSA, DMH, and COG Obligated and Spent Funds for Purposes Consistent with the Appropriations Act and Spending Plans, but Some Funds Were Not Used

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.

Internal Controls Are Generally Operating Effectively

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.

New Programs Have Been Implemented to Improve Foster Care, but Challenges Remain

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.

Implementation of the Early Intervention Program Was Delayed, Nevertheless Needed Services Were Provided to Some Families

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.

Emergency Support Fund Provided Critical Services, but the Number of Unlicensed Homes Remained the Same

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.

Most Eligible Caseworkers Participated in the Student Loan Repayment Program, but More Could Have Been Supported

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.

Implementation of CFSA’s Information Technology Plan Is Not Yet Completed

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.

Mental Health Assessments and Treatments Were Provided, but DMH Faces Ongoing Challenges

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.

COG’s Respite Program Was More Challenging to Implement Than Expected

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.

Concluding Observation

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.

Agency Comments and Our Evaluation

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.

Scope and Methodology

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.

Comments from the District’s Child and Family Services Agency

Comments from the District’s Department of Mental Health

Comments from the Metropolitan Washington Council of Governments

GAO Contacts and Staff Acknowledgments

GAO Contacts

Staff Acknowledgments

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.