While CFSA is responsible for protecting thousands of foster care children, many children in CFSA’s care languished for extended periods of time due to managerial shortcomings and long-standing organizational divisiveness in the District of Columbia. As a result of these deficiencies, the U.S. District Court for the District of Columbia issued a remedial order in 1991 to improve the performance of the agency. Under a modified final order established by the court in 1993, CFSA was directed to comply with many requirements. In 1995, lacking sufficient evidence of program improvement, the agency was removed from the District’s Department of Human Services and placed in receivership. Among its efforts to improve agency performance, CFSA established an automated system, FACES, to manage its caseload. The District Court issued a consent order in 2000 establishing a process by which the agency’s receivership could be ended. The order also established a probationary period, which began when the receivership ended, and identified performance standards CFSA had to meet in order to end the probationary period. The court-appointed monitor, the Center for the Study of Social Policy, was to assess CFSA’s performance and had discretion to modify the performance standards. In April 2001, CFSA became a cabinet-level agency within the government of the District of Columbia. In June 2001, the court removed CFSA from the receivership and its probationary period began. In October 2001, responsibility for child abuse investigations was transferred to CFSA from the District’s Metropolitan Police Department. CFSA’s probationary period ended in January 2003. However, in September 2002, the court-appointed monitor reported that a 7-year old boy was abused by two children in a group home that CFSA had licensed to provide care for 9-21 year olds. The report also identified several actions CFSA took or failed to take and concluded that the child was not adequately protected or served by CFSA. For example, contrary to its policies, CFSA did not place the child with his sibling, and there was no evidence that CFSA assessed his social, emotional, or behavioral needs. According to the court-appointed monitor, these events indicated that CFSA’s operations and policies may still need improvement. CFSA operates in a complex child welfare system. Several federal laws, local laws, and regulations established goals and processes under which CFSA must operate. ASFA, with one of its goals to place children in permanent homes in a timelier manner, placed new responsibilities on all child welfare agencies nationwide. ASFA introduced new time periods for moving children toward permanent, stable care arrangements and established penalties for noncompliance. For example, ASFA requires child welfare agencies to hold a permanency planning hearing—during which the court determines the future plans for a child, such as whether the state should continue to pursue reunification with the child’s family or some other permanency goal—not later than 12 months after the child enters foster care. The District of Columbia Family Court Act of 2001 established the District’s Family Court and placed several requirements on the District’s Mayor and various District government agencies, including CFSA and OCC. The District of Columbia Family Court Act requires the Mayor, in consultation with the Chief Judge of the Superior Court, to ensure that CFSA and other District government agencies coordinate the provision of social services and other related services to individuals served by the Family Court. CFSA relies on services provided by other District government agencies. For example, both the Fire Department and the Health Department inspect facilities where children are placed, and D.C. Public Schools prepare individual education plans for some foster care children. CFSA also works with agencies in Maryland, Virginia, and other states to arrange for placements of District children and also works with private agencies to place children in foster and adoptive homes. In addition, CFSA is responsible for licensing and monitoring organizations with which it contracts, including group homes that house foster care children. The management of foster care cases involves several critical steps required by CFSA policy. (See fig. 1.) Typically, these cases begin with an allegation of abuse or neglect reported to the CFSA child abuse hot line. CFSA staff are required to investigate the allegations through direct contact with the reported victim. If required, the child may be removed from his or her home, necessitating various court proceedings handled by the District’s Family Court. CFSA caseworkers are responsible for managing foster care cases by developing case plans; visiting the children; participating in administrative review hearings involving CFSA officials, children, parents, and other officials; attending court hearings; and working with other District government agencies. CFSA caseworkers are also responsible for documenting the steps taken and decisions made related to a child’s safety, well-being, and proper foster care placement, as well as those related to developing the most appropriate goal for permanency. Depending on their circumstances, children leave foster care and achieve permanency through reunification with their birth or legal parents, adoption, legal guardianship with a relative, or independence. As of September 2002, a child’s length of stay in the District’s foster care program averaged 2.8 years. HHS is responsible for setting standards and monitoring the nation’s child welfare programs. In fiscal year 2001, about $6.2 billion in federal funds were appropriated to HHS for foster care and related child welfare services. HHS’s monitoring efforts include periodic reviews of the operations, known as Child and Family Services Reviews, and of the automated systems, known as Statewide Automated Child Welfare Information System (SACWIS) Reviews, in the states and the District of Columbia. HHS last reviewed CFSA’s child welfare information system in 2000 and its overall program in 2001. CFSA undertook actions to implement six of the nine ASFA requirements we reviewed and met or exceeded four of the eight performance criteria included in our study, but as of March 2003, its plans to improve its performance did not include all ASFA requirements not fully implemented or selected performance criteria. With regard to implementing ASFA requirements, for example, CFSA signed a border agreement to achieve more timely placement of District children in Maryland, which addresses the ASFA requirement to use cross-jurisdictional resources to facilitate timely adoptive or permanent placements for waiting children. Table 1 summarizes CFSA’s progress in implementing the nine ASFA requirements that we reviewed. HHS’s review of CFSA found that the agency did not meet three requirements. CFSA did not consistently petition the Family Court to terminate parental rights when returning the child to his or her family had been deemed inappropriate and the child had been in foster care for 15 of the last 22 months. Based on its review of 50 foster care cases, HHS reported that 54 percent of the children who were in care longer than 15 months did not have hearings initiated for the termination of parental rights and reasons for not initiating such hearings were not documented in the case plan or court order. HHS also found that not all cases had hearings to review a child’s permanency goal within the timeframe prescribed by ASFA. In addition, foster parents, relative caretakers, and pre-adoptive parents were not consistently notified of reviews or hearings held on behalf of the foster child. HHS found that not all caregivers and prospective caregivers were notified of the time and place of a hearing, if such notification took place at all. We also analyzed automated data from FACES related to eight foster care performance criteria and found that CFSA met or exceeded four of them. For example, one criterion requires 60 percent of children in foster care to be placed with one or more of their siblings; we found that as of November 30, 2002, 63 percent of children were placed with one or more siblings. The areas in which CFSA’s performance fell short were the criteria related to (1) caseworker visitation with children in foster care, (2) placement of children in foster homes with valid licenses, (3) progress toward permanency for children in foster care, and (4) parental visits with children in foster care who had a goal of returning home. For example, none of the 144 children placed in foster care during the 2-month period prior to November 30, 2002, received required weekly visits by a CFSA caseworker. Table 2 summarizes our analysis of the selected foster care performance criteria. CFSA’s Program Improvement Plan, a plan required by HHS to address those areas determined not met in a CFSR, identifies how it will address two of the unmet ASFA requirements—(1) to initiate or join proceedings to terminate parental rights (TPR) of certain children in foster care and (2) to ensure that children have a permanency hearing every 12 months after entering foster care. For example, CFSA has outlined steps to improve its filings of TPR petitions with the Family Court. To help facilitate this process, CFSA hired additional attorneys to expedite the TPR proceedings. The new attorneys have been trained in ASFA requirements and in the process for referring these cases to the Family Court. CFSA is also developing a methodology for identifying and prioritizing cases requiring TPR petitions. In another plan, the April 2003 Implementation Plan, CFSA states that it will redesign its administrative review process to improve, among other things, notification and attendance of relevant parties and to provide for a comprehensive review of case progress, permanency goals, and adequacy of services. However, this plan does not make it clear whether all applicable hearings and proceedings will be included, such as permanency hearings. Another CFSA plan, the Interim Implementation Plan, includes measures that were developed to show the agency’s plans for meeting the requirements of the modified final order issued by the U.S. District Court for the District of Columbia.