Child Welfare: Improved Federal Oversight Could Assist States in Overcoming Key Challenges
Released: 2004-01-28T00:00:00

Letter

Background

ACF is responsible for the administration and oversight of federal funding to states for child welfare services under Titles IV-B and IV-E. HHS headquarters staff are responsible for developing appropriate policies and procedures for states to follow in terms of obtaining and using federal child welfare funds, while staff in HHS’s 10 regional offices and 10 national resource centers provide guidance and technical assistance to improve child welfare services nationwide. HHS compiles state-reported child welfare data in two databases: the Adoption and Foster Care Analysis and Reporting System (AFCARS) and the National Child Abuse and Neglect Data System (NCANDS). HHS relies on the information available in its databases to analyze and track children’s experiences in the child welfare system, to determine states’ performance on federal child welfare outcome measures, and to report to Congress on children’s well being and child welfare experiences. However, the monitoring of children served by state child welfare agencies is the responsibility of the state agencies that provide the services to these children and their families. Child welfare caseworkers at the county or local level are the key personnel responsible for documenting the wide range of services offered to children and families, such as investigations of abuse and neglect; treatment services offered to families to keep them intact and prevent the need for foster care; and arrangements made for permanent or adoptive placements when children must be removed from their homes. Most states and counties provide some child welfare services directly and provide others through contracts with private agencies. National survey data confirm that both state and private child welfare agencies are experiencing similar challenges recruiting and retaining qualified caseworkers. For instance, turnover of child welfare staff has been estimated at between 30 percent and 40 percent annually nationwide, with the average tenure for child welfare workers being less than 2 years.

In 2000, HHS established a new federal review system to monitor state compliance with federal child welfare laws. One component of this system is the CFSR, which assesses state performance in achieving safety and permanency for children, along with well-being for children and families. The CFSR process includes a self-assessment by the state, an analysis of state performance in meeting national standards established by HHS, and an on-site review by a joint team of federal and state officials. Based on the results of this process, HHS determines whether a state achieved substantial conformity with (1) outcomes related to safety, permanency, and well-being, such as keeping children protected from abuse and neglect and achieving permanent and stable living situations for children and (2) key systemic factors, such as having an adequate case review system and an adequate array of services. States are required to develop program improvement plans to address all areas of nonconformity.

Federal Funding of Child Welfare Services and Programs

Two titles of the Social Security Act provide federal funding targeted specifically to foster care and related child welfare services. Title IV-E provides an open-ended individual entitlement for foster care maintenance payments to cover a portion of the food, housing, and incidental expenses for all foster children whose parents meet certain federal eligibility criteria. Title IV-E also provides payments to adoptive parents of eligible foster children with special needs. To qualify for federal IV-E funding for SACWIS, states must prepare and submit an advance planning document (APD) to ACF’s Children’s Bureau, in which they describe the state’s plan for managing the design, development, implementation, and operation of a SACWIS that meets federal requirements and state needs in an efficient, comprehensive, and cost-effective manner. Since the administration and structure of state child welfare agencies vary across the nation, states can design their SACWIS to meet their state needs, as long as states meet certain federal requirements.

Title IV-B of the Social Security Act, established in 1935, authorizes funds to states to provide a wide array of services to prevent the occurrence of abuse, neglect, and foster care placements. In 1993, the Congress created a new program as subpart 2 of Title IV-B (now known as Promoting Safe and Stable Families), which funds similar types of services but is more prescriptive in how states can spend the funds. No federal eligibility criteria apply to the children and families receiving services funded by Title IV-B.

Title IV-B subpart 1 provides grants to states for child welfare services, which are broadly defined. Subpart 1 funds are intended for services that are directed toward the accomplishment of the following purposes: (1) protect and promote the welfare of all children; (2) prevent or remedy problems that may result in the abuse or neglect of children; (3) prevent the unnecessary separation of children from their families by helping families address problems that can lead to out-of-home placements; (4) reunite children with their families; (5) place children in appropriate adoptive homes when reunification is not possible; and (6) ensure adequate care to children away from their homes in cases in which the child cannot be returned home or cannot be placed for adoption.

In 1980, the Congress enacted legislation that limited the total subpart 1 funds states could use for three categories of services: foster care maintenance payments, adoption assistance payments, and child care related to a parent’s employment or training. The total of subpart 1 funds used for these purposes cannot exceed a state’s total 1979 subpart 1 expenditures for all types of services. The intent of this restriction, according to a congressional document, was to encourage states to devote increases in subpart 1 funding as much as possible to supportive services that could prevent the need for out-of-home placements. However, this restriction applies only to the federal portion of subpart 1 expenditures, as the law notes that states may use any or all of their state matching funds for foster care maintenance payments.

Subpart 2 authorizes grants to states to provide four categories of services, which are defined below: Family preservation services: Services designed to help families at risk or in crisis, including services to (1) help reunify children with their families when safe and appropriate; (2) place children in permanent homes through adoption, guardianship, or some other permanent living arrangement; (3) help children at risk of foster care placement remain safely with their families; (4) provide follow-up assistance to families when a child has been returned after a foster care placement; (5) provide temporary respite care; and (6) improve parenting skills.

Family support services: Community-based services to promote the safety and well-being of children and families designed to increase the strength and stability of families, to increase parental competence, to provide children a safe and supportive family environment, to strengthen parental relationships, and to enhance child development. Examples of such services include parenting skills training and home visiting programs for first time parents of newborns.

Time-limited family reunification services: Services provided to a child placed in foster care and to the parents of the child in order to facilitate the safe reunification of the child within 15 months of placement. These services include: counseling, substance abuse treatment services, mental health services, and assistance to address domestic violence.

Adoption promotion and support services: Services designed to encourage more adoptions of children in foster care when adoption is in the best interest of the child, including services to expedite the adoption process and support adoptive families.

States Spend IV-B Funds on A Variety of Services, With Subpart 2 Focusing More on Prevention

In our September 2003 report on Title IV-B, we found that states use these funds to provide a wide variety of services to prevent the occurrence of abuse, neglect, and foster care placements, as well as services to help children in foster care and their parents; however, relatively few subpart 1 dollars are used to provide family support and family preservation services, while the majority of subpart 2 funds are used for these purposes. According to our survey data for fiscal year 2002, states spent subpart 1 funds most frequently on the salaries of child welfare agency staff, administration and management expenses, CPS services, and foster care maintenance payments. In comparison, states spent half of their subpart 2 funds on family support or prevention programs and another 12 percent on family preservation services. CFSR results for the past 2 years, however, indicate that states have not performed strongly in terms of assessing the services families need and providing those services.

States Use Subpart 1 Funds Primarily for Staff Salaries

Relatively few subpart 1 dollars were used for family support or family preservation services; instead, they were most frequently used to fund staff salaries, with almost half of these funds designated for the salaries of CPS social workers. Another 20 percent of these funds were used for the salaries of other social workers. During a site visit to the state of Washington for the Title IV-B report, child welfare officials told us that they used over 50 percent of the state’s subpart 1 funds for salaries of staff providing direct services, including CPS social workers, other types of social workers, social work supervisors, and clerical support staff. Administration and management comprised the second largest category of service, accounting for almost 17 percent of subpart 1 dollars. This category included rent and utilities for office space, travel expenses for agency staff, and staff training.

CPS represents the third largest category of services that states funded with subpart 1. States used about 16 percent of their subpart 1 funds to provide a variety of CPS services, such as telephone hotlines for the public to report instances of child abuse and neglect, emergency shelters for children who needed to be removed from their homes, and investigative services. During our site visit to California, for example, officials reported using about 40 percent of their subpart 1 dollars to fund staff salaries and operating expenses associated with a variety of shelter care services provided by counties, such as emergency shelters and foster homes. A child is placed in one of these shelters when no other placement option is immediately available—for example, when an investigation in the middle of the night determines that the child is at immediate risk of harm. States also used nearly 11 percent of their subpart 1 funds to make recurring payments for the room and board of foster children who are not eligible for reimbursement through Title IV-E. About 10 percent of subpart 1 dollars were used to provide family support and family preservation services.

Subpart 2 Most Frequently Funds Family Support and Family Preservation Services

In contrast to subpart 1, states used over 80 percent of their subpart 2 dollars to fund services in its four mandated service categories—family support, family preservation, family reunification, and adoption promotion and support services (see app. I for additional information on states’ comparative expenditures on subparts 1 and 2). For example, states reported using half of their subpart 2 dollars to fund family support and prevention services. These services included mentoring programs to help pregnant adolescents learn to be self-sufficient; financial assistance to low- income families to help with rent and utility payments; and parenting classes, child care, and support groups provided by a community-based resource center. Washington funded a network of public health nurses and social service agencies to provide support services to families that are the subject of a report of abuse or neglect—these services are provided in lieu of, or following, a formal investigation when the level of risk to the child is not considered high.

Family preservation services—designed to keep families together and prevent the need to place a child in foster care—represented the second largest service category funded by subpart 2. Washington used subpart 2 funds for its statewide family preservation program, which offers counseling and parent training services for up to 6 months to families with children who are at risk of being placed in foster care.

In addition, states reported using about 11 percent of their subpart 2 funds for adoption support and preservation services. With these funds, states provided services such as counseling for children who are going to be adopted, family preservation services to adoptive families, and respite care for adoptive families. Officials in Ohio reported using almost half of its subpart 2 dollars for adoption services, including post adoption services and services to recruit families for children in need of adoptive homes.

Finally, states spent about 9 percent of their subpart 2 dollars on family reunification services. States funded a diverse array of family reunification programs, such as supervised visitation centers for parents to visit with their children and coordinators for alcohol and drug treatment services for families whose primary barrier to reunification is substance abuse. New Jersey funded a supervised visitation program that offers parenting education, counseling, transportation, and support groups and is located in a private home, allowing families to visit together in a homelike setting and engage in more natural interactions.

CFSRs Find States Are Weak in Assessing Families’ Service Needs

While states are using Title IV-B funds to provide this array of services, CFSR results for the past 2 years indicate that states have not performed strongly in terms of assessing the services families need and providing those services. When HHS reviewed case files it determined that 31of the 32 states that underwent a CFSR in 2001 or 2002 needed improvement in terms of assessing family needs and providing services to meet those needs. While 21 of the 32 states were considered to have an appropriate array of services for families, HHS found that the accessibility of services was a particular weakness in that many services were either not available statewide or had long waiting lists or other barriers to accessibility.

Staff and Data Issues Affect States’ Ability to Protect Children From Abuse and Neglect

Child welfare agencies face a number of issues related to staffing and data management that impair their ability to protect children from abuse and neglect. In particular, low salaries hinder agencies’ ability to attract potential child welfare workers and to retain those already in the profession. Additionally, caseworkers in the four states we visited for the March 2003 child welfare workforce report cited high caseloads and a lack of supervisory support as issues impacting their ability to work effectively. According to these caseworkers, high turnover rates and staffing shortages leave remaining staff with insufficient time to establish relationships with children and families and make the necessary decisions to ensure safe and stable permanent placements. Furthermore, our July 2003 report found that states face challenges developing appropriate information systems needed to track abuse or neglect reports and monitor children in foster care. While 47 states are developing or operating a SACWIS, many states reported that the development of their SACWIS is delayed. Most states responding to our survey faced challenges to SACWIS development, such as obtaining state funding and developing a system that met the child welfare agency’s needs statewide. In addition, several factors affect states’ ability to collect and report reliable adoption, foster care, and child abuse and neglect data, including insufficient caseworker training, inaccurate and incomplete data entry, and technical challenges reporting the data.

Recruitment and Retention Challenges May Hamper Agencies’ Attainment of Federal Child Welfare Outcomes

In our report on the child welfare workforce, we found that public and private child welfare agencies face a number of challenges recruiting and retaining qualified caseworkers and supervisors. Low salaries, in particular, hinder agencies’ ability to attract potential staff and to retain those already in the profession. For example, caseworkers in each of the four states we visited said that many of their former child welfare colleagues pursued positions in the education field where they could not only make more money but also work with children without risking their own safety. For example, the Bureau of Labor Statistics’ national wages survey reports that elementary and middle school teachers earn, on average, about $42,000 annually while social workers earn about $33,000.

Additionally, high caseloads, administrative burdens, limited supervision, and insufficient training reduce the appeal of child welfare work. Caseworkers and supervisors in all four states we visited cited demanding and complex caseloads and related administrative requirements, such as casework documentation, as factors affecting retention. Some of the caseworkers we interviewed handled double the number of cases recommended by advocacy organizations, and one study found that caseloads for individual child welfare workers ranged from 10 to 110 children, with workers handling an average of about 24 to 31 children each. Furthermore, some of the caseworkers we interviewed told us that they spent between 50 and 80 percent of their time completing paperwork, thereby limiting their time to assist children and families.

Caseworkers told us that their desire to stay in the child welfare profession was influenced by high-quality supervision and adequate on- the-job training; however, these elements were often lacking. According to supervisors in one city we visited, about half of new trainees left their jobs before completing 1 year, in part, because these newly hired caseworkers were not sufficiently trained to do their jobs. Furthermore, some newly promoted supervisors have requested demotions because they felt unprepared to meet job demands, and the caseworkers they supervised complained of poor management and insufficient support.

There is some evidence to suggest how recruitment and retention challenges affect the safety and permanency of children in care, but the magnitude of this effect is unknown. Caseworkers in the four states that we visited said that high turnover rates and staffing shortages leave remaining staff with insufficient time to conduct the types of home visits necessary to assess children’s safety and to make well-supported decisions to ensure safe and stable permanent placements. For example, when staff change, caseworkers may have to reestablish information to update the case record and families may become hesitant to work with unfamiliar caseworkers, making it difficult to learn the history of the case. Worker turnover also disrupts the continuity of services, particularly when newly assigned caseworkers have to conduct or reevaluate educational, health, and safety assessments due to poor or insufficient information in case files left behind by others. Furthermore, caseworkers explained that high caseloads require them to limit the number and quality of the home visits they conduct, forcing them to focus only on the most serious circumstances of abuse and neglect. One caseworker in Texas noted that when she does make a home visit, the visit is quick and does not enable her to identify subtle or potential risks to the child’s well-being.

Our analysis of federal CFSRs corroborated caseworker accounts, showing that large caseloads and worker turnover delay the timeliness of investigations and limit the frequency of worker visits with children, thereby hampering agencies’ attainment of some key federal safety and permanency goals. Although identifying workforce deficiencies is not an objective of the CFSR process, in all 27 CFSRs we analyzed, HHS explicitly cited workforce deficiencies—high caseloads, training deficiencies, and staffing shortages—that affected the attainment of at least one assessment measure. While the number of affected assessment measures varied by state, we found that HHS cited these factors for an average of nine assessment measures per state, with more than half of the 27 states exceeding this average. For example, in New Mexico’s CFSR, reviewers cited staff turnover and vacancies as impairing workers’ ability to investigate child maltreatment reports, provide appropriate services for families, and establish timely permanency goals. Furthermore, the District of Columbia’s CFSR describes heavy workloads, high staff turnover, and a climate in which supervisors often call new workers out of training to handle ongoing caseload activities.

Delays in SACWIS Completion and Challenges with Data Collection Affect States’ Ability to Ensure Reliable Data on Children’s Experiences

In addition to performing a wide range of services to protect children, child welfare caseworkers are the key personnel who collect and document information on children and families served by children welfare agencies. Case file documentation is generally captured in state computer systems. In our July 2003 report, HHS reported that 47 states are using targeted federal funds to develop or operate their child welfare computer systems—known as SACWIS—but many continue to face challenges completing their systems. In our November 2003 testimony on SACWIS, we reported on the costs associated with developing SACWIS and the associated barriers, such as development delays and difficulties in receiving state funding approval, creating a system that reflects child welfare work processes, and securing contractors knowledgeable about child welfare. Many state officials said that they recognize the benefit their state will achieve by developing SACWIS, such as contributing to the timeliness of child abuse and neglect investigations. In Oklahoma, for example, caseworkers and state officials noted that they believe their children are safer since the implementation of SACWIS simply because the information on the children is easily accessible to the caseworkers and their supervisors. According to our survey results, automated systems provided easier access to data and allowed caseworkers to better monitor children in their care, which may contribute to additional child welfare and administrative benefits, such as decreased incidences of child abuse and neglect, shortened length of time to achieve adoption, timeliness of payments to foster families, and timeliness of payments to foster facilities.

Some of the data captured in case file records are reported to two HHS databases that compile child welfare data—AFCARS and NCANDS. We found that several factors affect states’ ability to collect and report reliable data to HHS on children served by state child welfare agencies. Almost all of the states responding to our survey reported that insufficient caseworker training and inaccurate and incomplete data entry into their information system affect the quality of AFCARS and NCANDS data. Although most states reported these as separate factors, HHS and the states we visited found that insufficient training and inaccurate and incomplete data entry are often linked. Caseworkers, supervisors, and managers in the five states that we visited reported that additional factors, such as difficulties balancing data entry with the time that they spend with the families and children, contributed to inaccurate or incomplete data entry. Supervisors in Iowa explained that since caseworkers are responsible for ensuring that children and their families receive the services they need, the caseworkers tend to initially limit data entry to the information that is necessary to ensure timely payment to foster care providers, and complete all other data elements when the caseworkers have time. In addition, caseworkers in Colorado said that they are between 30 and 60 days behind in their data entry, so the information in the automated system may not accurately reflect the current circumstances of children in care.

We also reported in our July 2003 report and November 2003 testimony that many states experienced technical challenges reporting their data to HHS. The problems reported by states are typically a result of challenges associated with data “mapping”—matching state data elements to the federal data elements. For example, 36 states reported in our survey that matching their state-defined data to HHS’s definitions affected the quality of the data reported to NCANDS and AFCARS. In addition to the challenges reported in our survey, HHS reported that transferring data from older data systems into SACWIS affects the quality of the data reported to AFCARS and NCANDS.

Improvements in HHS’S Oversight of Child Welfare Programs Could Help States Overcome Some Challenges

HHS plays a role in helping states implement their child welfare programs, but in some cases, additional federal oversight or technical assistance could help states provide more effective services. In terms of child welfare funding, HHS focuses its programmatic oversight on the overall child welfare system in each state and provides relatively little oversight specific to Title IV-B subpart 1. HHS’s role in assisting states overcome the child welfare workforce challenges is limited to partial federal reimbursement for training expenses and management of discretionary grant programs, such as the Child Welfare Training Program. HHS also monitors SACWIS development and data reporting and provides assistance to states to address some of the associated challenges; however, states reported ongoing challenges, such as the lack of clear and documented guidance on how to report child welfare data, despite the availability of this assistance.

HHS Focuses Oversight on the Overall Child Welfare System, but Has Limited Knowledge about States’ Use of Subpart 1 Funds

HHS focuses much of its programmatic oversight on the overall child welfare system in each state, rather than focusing specifically on subpart 1 or any other federal funding source. A major component of HHS’s subpart 1 oversight is having the regional offices actively work with states to develop appropriate goals for their child welfare systems and ensure that available funds are used to support those goals. To receive Title IV-B funding, HHS requires states to submit a Child and Family Services Plan, which covers a 5-year period and describes the state’s goals and objectives toward improving outcomes related to the safety, permanency, and well- being of children and families, as well as the services and programs the state will pursue to achieve these goals. In addition to the 5-year plan, HHS requires states to submit an update each year to discuss their progress in meeting the goals outlined in their plans. Some regional officials noted that states are still struggling to use these documents appropriately for planning purposes and frequently just describe their current programs, rather than focusing on outcomes and collecting data to measure progress toward those outcomes.

The CFSR process is an additional tool HHS uses to ensure that states conform to federal child welfare requirements and to help states improve their child welfare services. Staff at one regional office described the CFSR as a thorough review of the services funded by different federal programs, such as Title IV-B, providing an opportunity to determine whether states are providing the services they report in their planning documents and whether those services are adequate and appropriate to meet the needs of the state’s children and families. When asked about HHS’s role in guiding states’ use of subpart 1 funds to address weaknesses identified by the CFSRs, an HHS official told us that the agency provides technical assistance to states to help them determine the most effective use of their resources, while giving states much latitude to determine the most appropriate use of their subpart 1 funds.

HHS does not require states to provide any data about their use of subpart 1 funds, such as their subpart 1 expenditures for specific services. As a result, several regional offices noted that they have no way of knowing how states actually spend their subpart 1 funds. Instead, HHS requires states to submit annual estimates of the amount of subpart 1, subpart 2, and other federal funds the state plans to spend in the upcoming year on different categories of services (such as family support or CPS). However, these estimates may not provide reliable data as to how states are using subpart 1 funds. HHS officials explained that states’ actual expenditures may vary from these estimates, as they address unforeseen circumstances.

In addition, HHS requires states to submit their estimates before the final spending amounts have been appropriated.

The descriptions provided by regional office staff of their review of these estimates indicate that they review them for relatively limited purposes. As a result, most HHS regional offices do not review the annual estimates for compliance with the statutory limits. In addition, HHS’s annual program instruction, which details what information states must include in their estimates and serves as the basis for the regional offices’ review of subpart 1 spending, does not mention the subpart 1 limits. Five regional offices were unaware that any limits on the use of subpart 1 funds existed. Four other regional offices were aware of the limits, but did not ensure that states complied with the limits.

This lack of review led HHS to approve spending plans for 15 states that reported fiscal year 2002 planned subpart 1 expenditures for foster care maintenance and adoption assistance payments that exceeded the statutory limits. The dollar amounts by which the subpart 1 spending estimates surpassed the limits were small in some cases, but large in others. For example, Georgia reported that it planned to spend $1,497,000 of subpart 1 funds for these purposes in 2002, which would exceed its statutory limit by $1,558. At the other extreme, Florida’s estimate indicated that it planned to spend over $9 million, which was more than $7 million over the maximum allowable spending of $1.9 million. In total, these 15 states submitted planned subpart 1 spending estimates for foster care maintenance and adoption assistance payments that would exceed the statutory limits by over $30 million.

Several regional offices said that they are not concerned about a state planning to spend significant proportions of its subpart 1 funds on foster care maintenance and adoption assistance payments if they believed the state had a strong child welfare system with an appropriate array of services. Regional office staff said that they would, however, ask a state to reconsider its funding strategy if the state were performing poorly. However, many of the states with approved subpart 1 estimates above the statutory ceilings did not achieve strong outcomes on their CFSR evaluations with regard to providing needed services and having an appropriate array of services. HHS has conducted CFSRs on 13 of the 15 states with approved annual estimates over the subpart 1 spending limits and determined that appropriately assessing family needs and providing services to address those needs was an area needing improvement in 12 of the 13 states. In addition, 7 of the 13 states were also determined to need improvement in terms of having an appropriate array of services to meet the needs of families in the state.

In discussing the current structure of Title IV-B, officials in all of HHS’s regional offices told us that they believe states need some flexibility to use Title IV-B funds to address state-specific child welfare needs as is currently the case under subpart 1. At the same time, officials in 8 of HHS’s 10 regional offices also stressed the importance of subpart 2 to ensure that states use some funds on family support services and prevention activities to help preserve families and keep children from entering foster care. Several regional offices expressed concern that, in the absence of the minimum spending requirements outlined in subpart 2, states would neglect preventive services, while using Title IV-B funds for more urgent services, such as CPS or foster care. State and local child welfare officials in one state we visited, along with officials at 2 HHS regional offices, said that states need more federal funds to provide services to prevent foster care placements, such as an increase in funds available under Title IV-B or more flexibility to use Title IV-E funds to provide services. HHS is currently developing a legislative proposal to give states more flexibility in using Title IV-E foster care funds for such preventive services.

HHS’s Involvement with States’ Child Welfare Workforce Is Limited

HHS’s primary connection to the child welfare workforce has been through partial federal reimbursement—75 percent—of states’ training funds to implement educational programs for current child welfare staff and to enhance the child welfare curriculum of undergraduate and graduate social work programs to better educate and prepare potential caseworkers. This funding may also be used for curriculum development, materials and books, support for current workers to obtain a social work degree, and incentives to induce entry to the child welfare field. During fiscal year 2002, 49 states received $286 million in title IV-E training reimbursements. These reimbursements ranged from a low of approximately $10,400 in Alaska to a high of more than $79 million in California, with the median reimbursement approximating $2.7 million.

In addition, ACF’s Children’s Bureau manages six discretionary grant programs through which it funds various activities related to improvements in the child welfare system. One of these programs—the Child Welfare Training Program, authorized by Section 426 of Title IV of the Social Security Act—awards grants to public and private nonprofit institutions of higher learning to develop and improve the education, training, and resources available for child welfare service providers. This is the only program of the six with a specific emphasis on staff training; however, in fiscal year 2003, it received the second smallest share—8 percent—of the Children’s Bureau’s total discretionary funds.

According to HHS officials, HHS has no authority to require states to address caseload issues in their CFSR-related program improvement plans or to enforce any caseload standards. Furthermore, HHS officials said that states have made few requests of HHS’s national resource centers for assistance with child welfare staff recruitment and retention. Although HHS officials told us that they plan to examine the CFSRs to better understand the relationship between recruitment and retention and safety and permanency outcomes across the states, the agency is still conducting these reviews and is not expected to complete them until March 2004.

HHS Offers Assistance to Help States Develop SACWIS and Improve Their Data, but States Report Ongoing Challenges with Some of HHS’s Efforts

In response to some of the challenges states face in developing SACWIS and collecting and reporting child welfare data, HHS has conducted on-site reviews of information systems and provided technical assistance from a variety of sources. For example, at the time of our review, HHS had conducted on-site reviews in 26 states with operational SACWIS to ensure that the systems met all federal requirements and to offer assistance to states that faced challenges completing the development of their SACWIS. Few systems have been determined complete after an on-site review because of unresolved issues, such as not being able to build links to other state information systems or not implementing certain eligibility determination functions. To help states address some of these development challenges, the SACWIS review team provides the state with recommendations for complying with SACWIS requirements and schedules a conference call with the state officials to walk through the system’s deficiencies and offer guidance on how the state can move forward. In addition, in an attempt to help states comply with the reporting standards and address some of the factors that contribute to data quality problems, HHS performs comprehensive reviews of state information systems’ ability to capture AFCARS data to identify problems associated with data collection and reporting and to ensure that the information in the automated system correctly reflects children’s experiences in care.

Other technical assistance is available to states in a variety of formats. HHS facilitates the sharing of information between states developing SACWIS through an automated system users’ group that allows state and federal officials to exchange information, ideas, and concerns. In addition to the users’ group, HHS officials sponsor a Listserv—an electronic mailing list—that allows state officials to exchange information, a monthly conference call with state information technology directors, an annual technical assistance meeting, and an NCANDS state advisory group. The National Resource Center for Information Technology in Child Welfare, which opened in 1999, also provides assistance to states on SACWIS development and data issues.

HHS has also made available to states the software it uses to examine states’ AFCARS and NCANDS submissions for inconsistencies and invalid data. Officials in all the states that we visited said that they regularly use this software, and an HHS official said that nearly every state has used the software at least once. HHS officials reported that these tests help them to identify some data quality errors, such as missing data, and said that they believe that, in general, data have improved in recent years. However, the officials indicated that the tests cannot pinpoint the underlying problems contributing to these errors. Furthermore, one official reported that no specific efforts have been conducted to track the individual data elements and, therefore, HHS cannot report on how data quality has changed over time.

Although the states we visited appreciated some of HHS’s efforts to assist with improving state data quality, they and most states responding to our survey agreed that the assistance is not always consistent or easily accessible. The primary concerns reported by the states we visited were delays in receiving clear written guidance on defining and reporting certain data elements and the lack of state input in suggesting changes to AFCARS. Despite the written guidance available to states in the form of regulations and an online policy manual, states reported that the variation in state policies and practices makes it difficult to interpret how to apply the general guidance. As a result, states consult with HHS to ensure they are applying the regulations appropriately. However, in commenting on a draft of the July 2003 report, officials in Oklahoma told us that a common concern among the states is the lack of timely response from HHS when seeking guidance on how to report data. In commenting on a draft of the same report, HHS explained that it first refers states to its Web site for information and believes that the available guidance addresses states’ concerns in most instances. In addition, the states that have had an AFCARS review experienced delays in obtaining guidance on how to proceed following the on-site review. An HHS official told us that since the review process is relatively new, the agency is still developing a process to respond to the states and recognizes that it has not been responsive to the states already reviewed. In addition, HHS is taking steps to gather feedback from states and other users of AFCARS data to determine how to improve the system to make the data more accurate and usable. As a part of these efforts, HHS has published a Federal Register notice soliciting comments and held focus group meetings at national conferences. The difficulties states face in receiving federal guidance and assistance, as well as the other challenges they face in reporting data, may negatively affect the reliability of the data available in AFCARS and NCANDS.

Concluding Observations

Despite its relatively small funding level compared to other funding sources for child welfare services, Title IV-B represents an important federal commitment to states’ efforts to protect children from abuse and neglect. However, HHS does not provide in-depth oversight specific to Title IV-B subpart 1. Two key issues further compound states’ ability to prevent abuse and neglect. For example, given the difficulties that public and private child welfare agencies are experiencing in hiring, training, and retaining their workforces, these agencies’ ability to provide services to children is threatened. In addition, states face challenges in completing their SACWIS systems and in ensuring that caseworkers input complete and accurate case data in a timely manner.

We recommended in our September 2003 report on Title IV-B that the Secretary of HHS provide the necessary guidance to ensure that HHS regional offices monitor states’ use of Title IV-B subpart 1 funds for compliance with statutory restrictions on the use of these funds. We also recommended that the Secretary consider the feasibility of collecting basic data on states’ use of these funds to facilitate its oversight of the program and to provide guidance to help states determine appropriate services to fund. In commenting on a draft of that report, HHS agreed with our first recommendation but noted that the statutory limitations on Title IV-B funds no longer serve a useful purpose and are incompatible with its current proposal to offer states much more flexibility in using other federal child welfare dollars. HHS disagreed with our second recommendation, stating that it believes that its level of oversight is commensurate with the scope and intent of the program and minimizes states’ reporting requirements.

We recommended in our March 2003 report on child welfare worker recruitment and retention that, because of the reported impact staffing shortages and high caseloads have on the attainment of federal outcome measures, that the Secretary of HHS take actions that may help child welfare agencies address the recruitment and retention challenges they face. In commenting on a draft of that report, HHS generally agreed with our findings and concurred with our recommendation, saying that it has begun to explore the effectiveness of child welfare training programs, with an emphasis on lessons learned and best practices. However, HHS stressed that it has no authority to require states to address caseload issues in their CFSR program improvement plans or to enforce any caseload standard.

To improve the reliability of state-reported child welfare data, we recommended in our July 2003 SACWIS report that the Secretary of HHS consider, in addition to HHS’s recent efforts to improve AFCARS data, ways to enhance the guidance and assistance offered to states to help them overcome the key challenges in collecting and reporting child welfare data. HHS generally agreed with our findings and, in response to our recommendation, noted that the data definitions need to be updated and revised and said it is currently in the process of revising the AFCARS regulations to further standardize the information states are to report. More recently, HHS said that it would be creating policy guidance that will delineate what will happen if a state fails to complete its SACWIS within a reasonable time frame.

Mr. Chairman, this concludes my prepared statement. I would be pleased to respond to any questions that you or other members of the Subcommittee may have.

GAO Contact and Acknowledgments

For further information regarding this testimony, please call Cornelia M. Ashby at (202) 512-8403. Individuals making key contributions to this testimony include Diana Pietrowiak, Joy Gambino, Sara Schibanoff, and Michelle St. Pierre.

Related GAO Products

D.C. Family Court: Progress Has Been Made in Implementing Its Transition. GAO-04-234. Washington, D.C.: January 6, 2004.

Child Welfare: States Face Challenges in Developing Information Systems and Reporting Reliable Child Welfare Data. GAO-04-267T. Washington, D.C.: November 19, 2003.

Child Welfare: Enhanced Federal Oversight of Title IV-B Could Provide States Additional Information to Improve Services. GAO-03-956. Washington, D.C.: September 12, 2003.

Child Welfare: Most StatesAre Developing Statewide Information Systems, but the Reliability of Child Welfare Data Could be Improved. GAO-03-809. Washington, D.C.: July 31, 2003.

D.C. Child and Family Services: Key Issues Affecting the Management of Its Foster Care Cases. GAO-03-758T. Washington, D.C.: May 16, 2003.

Child Welfare and Juvenile Justice: Federal Agencies Could Play a Stronger Role in Helping States Reduce the Number of Children Placed Solely to Obtain Mental Health Services. GAO-03-397. Washington, D.C.: April 21, 2003.

Foster Care: States Focusing on Finding Permanent Homes for Children, but Long-Standing Barriers Remain. GAO-03-626T. Washington, D.C.: April 8, 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.

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.

District of Columbia Child Welfare: Long-Term Challenges to Ensuring Children’s Well-Being. GAO-01-191. Washington, D.C.: December 29, 2000.

Child Welfare: New Financing and Service Strategies Hold Promise, but Effects Unknown. GAO/T-HEHS-00-158. Washington, D.C.: July 20, 2000.

Foster Care: States’ Early Experiences Implementing the Adoption and Safe Families Act. GAO/HEHS-00-1. Washington, D.C.: December 22, 1999.

Foster Care: HHS Could Better Facilitate the Interjurisdictional Adoption Process. GAO/HEHS-00-12. Washington, D.C.: November 19, 1999.

Foster Care: Effectiveness of Independent Living Services Unknown. GAO/HEHS-00-13. Washington, D.C.: November 5, 1999.

Foster Care: Kinship Care Quality and Permanency Issues. GAO/HEHS- 99-32. Washington, D.C.: May 6, 1999.

Juvenile Courts: Reforms Aim to Better Serve Maltreated Children. GAO/HEHS-99-13. Washington, D.C.: January 11, 1999.

Child Welfare: Early Experiences Implementing a Managed Care Approach. GAO/HEHS-99-8. Washington, D.C.: October 21, 1998.

Foster Care: Agencies Face Challenges Securing Stable Homes for Children of Substance Abusers. GAO/HEHS-98-182. Washington, D.C.: September 30, 1998.

This is a work of the U.S. government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately.