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entitled 'Child Welfare: Better Data and Evaluations Could Improve 
Processes and Programs for Adopting Children with Special Needs' which 
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Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

June 2005: 

Child Welfare: 

Better Data and Evaluations Could Improve Processes and Programs for 
Adopting Children with Special Needs: 

GAO-05-292: 

GAO Highlights: 

Highlights of GAO-05-292, a report to congressional requesters: 

Why GAO Did This Study: 

On September 30, 2002, the most recent date for which Department of 
Health and Human Services (HHS) data were available, about 126,000 
foster children were waiting to be adopted. Estimates suggest that a 
significant portion of these children had one or more special needs, 
such as a medical condition or membership in a minority group, that may 
discourage or delay their adoption. Federal support in the form of 
adoption subsidies and incentive payments to states is available to 
promote special needs adoption. This report (1) identifies the major 
challenges to placing and keeping special needs children in adoptive 
homes, (2) examines what states and HHS have done to facilitate special 
needs adoptions, and (3) assesses how well the Adoption Assistance 
Program and the Adoption Incentives Program have worked to facilitate 
special needs adoptions, and determines if changes might be needed. 

What GAO Found: 

According to state child welfare officials, limited resources, court 
processes, and delays in completing interstate placements challenged 
the adoption of children with special needs by hindering recruitment of 
adoptive families and delaying the adoption process. In particular, 
adoptive parents in many states received lower subsidies and fewer 
services than foster parents. In addition, child welfare officials, 
court staff, and judges said that the adoption process can take months 
to complete because hearings to terminate parents’ rights are hard to 
schedule and may involve appeals. Further, officials said that 
interstate placements are often hampered by delays in completing home 
studies of prospective families, although no data exist to assess the 
timeliness of such placements. 

States and HHS have developed and implemented strategies and programs 
to promote special needs adoptions, but few evaluations measure their 
effectiveness. Four of the 5 states we visited sponsored post adoption 
resource centers. However, only 9 of 49 states responding to a relevant 
question in our survey indicated that they had evaluated the 
effectiveness of their services. At the federal level, HHS supported 
and promoted local innovation, provided technical assistance, and 
disseminated information, but the agency has done little to assess the 
effectiveness of the programs it has funded. When HHS has taken steps 
to have states assess funded projects, the agency has not ensured 
sufficient rigor to assess effectiveness. 

The Adoption Assistance and Adoption Incentives Programs have provided 
support for special needs adoptions, but data are lacking to determine 
if changes are needed to better facilitate adoption. The former uses an 
income eligibility threshold that is more restrictive than other cash 
assistance programs’ standards of need and may not include all who 
might otherwise qualify. Since 1998, the Adoption Incentives Program 
has provided financial awards to almost all states for increasing 
adoptions, but does not provide a specific inducement for interstate 
placements. Data to track and credit states for collaborating on 
interstate placements are not available. 

Flowchart of a Typical Adoption Process: 

[See PDF for image]

[End of figure]

What GAO Recommends: 

GAO recommends that HHS improve its data collection and evaluation 
efforts. HHS did not explicitly agree or disagree with the 
recommendations. It said that changes to address the data collection 
recommendations were being considered and that while steps to 
strengthen evaluations have been taken, some project results have 
sometimes been of limited use because of problems adhering to 
evaluation protocols. 

www.gao.gov/cgi-bin/getrpt?GAO-05-292. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Cornelia Ashby at (202) 
512-8403 or ashbyc@gao.gov. 

[End of section]

Contents: 

Letter: 

Results in Brief: 

Background: 

States Reported That Limited Resources, Court-Related Processes, and 
Interstate Placement Delays Impede the Adoption of Special Needs 
Children: 

States and HHS Have Promoted Special Needs Adoption, but Few 
Evaluations Measure Program Effectiveness: 

The Adoption Promotion Programs Have Supported Special Needs Adoption, 
but Data Are Lacking to Determine if Changes Are Needed: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Objectives: 

Scope and Methodology: 

Survey: 

Site Visits: 

Interviews and Discussion Groups: 

Review of States' Reports, Federal Laws, and HHS Regulations: 

Review of Studies and Evaluations: 

Appendix II: Comments from the Department of Health and Human Services: 

Appendix III: GAO Contact and Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Characteristics of Post Adoption Resources Available in Five 
States: 

Figures: 

Figure 1: Flowchart of a Typical Adoption Process: 

Figure 2: Types of Support Provided to Families Caring for Children 
with Special Needs: 

Figure 3: Frequency of States' Attainment of the Adoption Incentive 
Award, 1998-2003: 

Figure 4: Number of States Claiming Award, by Earning Year: 

Figure 5: Illustration of the Difficulty in Claiming an Award under the 
Adoption Incentives Program: 

Abbreviations: 

AFCARS: Adoption and Foster Care Analysis and Reporting System: 
AFDC: Aid to Families with Dependent Children: 
APHSA: American Public Human Services Association:
ASFA: Adoption and Safe Families Act of 1997: 
CFSR: Child and Family Services Review: 
HHS: Department of Health and Human Services: 
ICPC: Interstate Compact on the Placement of Children: 
NCANDS: National Child Abuse and Neglect Data System: 
SSBG: Social Services Block Grant: 
SSI: Supplemental Security Income: 
TANF: Temporary Assistance for Needy Families: 
TPR: Termination of Parental Rights: 

United States Government Accountability Office: 

Washington, DC 20548: 

June 13, 2005: 

The Honorable Charles E. Grassley: 
Chairman: 
Committee on Finance: 
United States Senate: 

The Honorable Hillary R. Clinton: 
United States Senate: 

On September 30, 2002, the most recent date for which these data were 
available, about 126,000 foster children were reported by the 
Department of Health and Human Services (HHS) to be waiting for 
adoption. These children, on average, were 8 years old, had been in 
foster care for nearly half their lives, and 55 percent were living 
with an unrelated foster care provider. According to federal program 
officials, a significant portion of these children had at least one 
special need, such as a medical condition or membership in a minority 
group that might make adoptive placements challenging. Further, in some 
cases, the most appropriate adoptive families reside in one state while 
waiting children reside in another. Therefore, interstate placements, 
which require child welfare agencies in both states to work together, 
are critical to finalizing their adoption. 

In an effort to promote the adoption of children with special needs, 
Congress authorized the Adoption Assistance Program in 1980 under Title 
IV-E of the Social Security Act. Through this program, the federal 
government partially reimburses states for subsidies they provide to 
adoptive parents of eligible special needs children to assist them with 
related caretaking expenses. The act defines children as having special 
needs if the state has determined that the child should not or could 
not be returned to the home of his or her parents, and certain factors, 
such as age; membership in a sibling unit or minority group; or 
emotional, mental, or physical conditions would make finding an 
appropriate adoptive home difficult. 

In order to qualify for the federal subsidy reimbursement, children 
must meet the special needs definition and one of several eligibility 
criteria. These criteria include having been removed from the home 
pursuant to a judicial determination and being eligible for the Aid to 
Families with Dependent Children (AFDC) program, as it existed in 1996. 
In each of the fiscal years 2001 through 2003, the federal adoption 
assistance subsidy reimbursement, including related administrative and 
training expenses, exceeded $1 billion. In fiscal year 2002, the latest 
year for which HHS could provide figures, the federal government 
partially reimbursed states for adoptive families' subsidies for about 
66 percent of foster children adopted. 

In addition to the adoption subsidy reimbursement, the Adoption 
Incentives Program, created by the Adoption and Safe Families Act of 
1997 (ASFA) and amended in 2003, provides rewards for states that 
increase the number of foster care adoptions, special needs adoptions, 
or adoptions of children age 9 and older. Since the program's inception 
through 2003, the most recent year for which data are available, the 
federal government has awarded nearly $178 million to states in 
adoption incentive payments. 

To better understand the issues related to the placement and adoption 
of special needs children, we (1) identified the major challenges to 
placing and keeping special needs children in adoptive homes, (2) 
examined what states and the Department of Health and Human Services 
have done to facilitate special needs adoptions, and (3) assessed how 
well the Adoption Assistance Program and the Adoption Incentives 
Program have worked to facilitate special needs adoptions and what 
changes, if any, might be needed to further facilitate adoptions. 

To conduct our work, we gathered and analyzed data from several 
sources. We developed and conducted a nationwide survey of adoption 
directors in all 50 states, as well as those in Washington, D.C., and 
Puerto Rico, and we received 50 responses.[Footnote 1] We visited 5 
states --Georgia, Massachusetts, Michigan, New Mexico, and Oregon-- 
where we spoke with child welfare agency officials, caseworkers, 
parents, court personnel, and private adoption agency officials to 
better understand states' strategies for placing children with 
appropriate adoptive families.[Footnote 2] We selected these states for 
diversity in the size of their foster care populations, location, and 
program administration, and for the different degree of success they 
have had in finalizing adoptions. In addition, we selected and reviewed 
10 states' Child and Family Services Plans and Annual Progress and 
Services Reports--documents that HHS requires as part of its ongoing 
child welfare oversight--in order to obtain information on how states 
were using the adoption incentive funds. Further, we reviewed federal 
adoption assistance and adoption incentive laws and regulations, as 
well as additional adoption-related research and evaluations conducted 
by HHS, the states, and nongovernmental organizations. We also 
interviewed HHS officials and staff from independent child welfare 
organizations, and we conducted discussion groups with adoptive parents 
and adoption program managers from around the country at two national 
conferences. We conducted our work between May 2004 and April 2005 in 
accordance with generally accepted government auditing standards. A 
more detailed discussion of our scope and methodology appears in 
appendix I. 

Results in Brief: 

According to state officials, limited resources, court processes, and 
delays in completing interstate placements were the major challenges to 
successful special needs adoptions. These challenges hindered efforts 
to recruit families and delayed the adoption process. According to 
state officials in 4 of the 5 states we visited, budget issues in their 
states have caused reductions in or elimination of adoption services. 
In part because of these resource limitations, adoptive parents in many 
states received lower subsidies and fewer services than foster parents. 
Our survey asked states about 13 types of services or support. For 9 of 
the 13 services, fewer states reported providing them to adopted 
children than to foster children. In addition to reporting limited 
resources, child welfare officials, court staff, and judges from our 
site visit states said that the adoption process can take many months 
to complete because hearings to terminate parental rights are hard to 
schedule, and appeals by parents and other relatives may add months to 
the process. Further, although federal law requires states to 
facilitate the timely adoptive placement of children through the 
effective use of cross-jurisdictional resources, interstate placements 
can be delayed, in part, by the slow completion of home studies to 
determine the qualifications of prospective families. HHS officials 
said that there are no data to assess the timeliness of such 
placements. However, they are in the process of updating their central 
data system and informed us that they are considering many revisions to 
improve data collection. 

States and HHS have developed and implemented both general and targeted 
strategies to promote special needs adoptions, but few evaluations 
measure their effectiveness. All 5 of the states we visited partner 
with adoption exchanges--information and referral services for adoptive 
families--to operate electronic registries of children awaiting 
adoption, and all 5 states worked with private agencies to promote 
adoption. In addition to these general activities, many states used 
targeted recruitment strategies. For example, states hosted adoption 
promotion events geared toward matching prospective families with 
certain children, such as those who have been waiting the longest for 
placements. Four of the 5 states we visited sponsored formal post 
adoption resource centers. However, only 9 of 49 states responding to a 
relevant question in our survey indicated that they had evaluated the 
effectiveness of their post adoption services. At the federal level, 
HHS has supported and promoted local innovation through its programs, 
provided technical assistance, and disseminated information to increase 
public awareness about the need for adoptive families. However, the 
agency has done little to assess the effectiveness of its programs. 
Moreover, when HHS has taken steps to have participating states assess 
specific projects, few of the evaluations produced reliable data. We 
found that five of the seven evaluations we reviewed lacked sufficient 
rigor to determine whether the projects had met their intended goals. 
HHS officials acknowledged the need for more rigorous evaluation. 
However, they informed us that once they approve the projects, they 
have very little control over how the evaluations are actually 
conducted because states manage the evaluations. 

While the adoption assistance and adoption incentive programs have 
supported special needs adoption, data are lacking to determine if 
changes are needed to better facilitate adoptions. For example, the 
Adoption Assistance Program uses an income threshold or need standard 
from the expired Aid to Families with Dependent Children program, which 
is more restrictive than other cash assistance programs and therefore 
limits eligibility. HHS does not separately collect data on the 
characteristics of children who do not meet IV-E eligibility, so the 
number of children with special needs from low-income families is 
unknown, and we cannot determine the extent to which this population is 
being underserved. With regard to the Adoption Incentives Program, all 
states have received financial awards for adoption achievements at 
least once since 1998. However, the program is not currently designed 
to provide a specific inducement for interstate placements. Data to 
track and give credit to states for collaborating on interstate 
placements are not available. 

Given the challenges states face with respect to special needs 
adoptions, the limited assessments available to determine best 
practices, and the lack of data available to determine if changes to 
federal adoption programs are needed, we recommend that HHS (1) assist 
states in collecting and reporting data related to interstate 
placements and analyze this data to provide a basis for facilitating 
timelier placements, (2) facilitate the evaluation of federal and state 
strategies and programs that promote special needs adoption, and (3) 
gather data on the economic circumstances of special needs children who 
do not currently qualify for the Adoption Assistance Program and assess 
the impact of expanding eligibility on federal cost. 

HHS provided written comments on a draft of this report but did not 
explicitly agree or disagree with the recommendations. In its comments, 
HHS stated that changes to address the recommendations designed to 
improve data collection were being considered in conjunction with 
efforts to revise its central data system. While HHS said that our 
recommendation to improve evaluations was unnecessary because the 
agency has taken steps to strengthen evaluations, it acknowledged that 
projects have sometimes not yielded useful results, because of problems 
adhering to evaluation protocols. Also, HHS stated that it will 
continue to work with states to identify rigorous, administratively 
feasible evaluation strategies. We continue to recommend that HHS 
develop additional guidance to improve evaluations. Such guidance is 
needed to help assess the effectiveness of funded projects. 

Background: 

Most children enter foster care when the state's child welfare agency 
determines that they have been subjected to abuse or neglect and it is 
not in their best interest to immediately return home. On September 30, 
2002--the latest date for which HHS figures were available for our 
review, 532,000 children were in foster care in the United 
States.[Footnote 3] Generally, after investigating the circumstances 
that contributed to the abuse or neglect, state child welfare agency 
staff develop a plan to help the parent make improvements and create a 
safe and stable family environment. ASFA requires that states hold a 
permanency planning hearing at least once every 12 months to determine, 
among other things, when and if reunification with the child's family 
is a safe and practical option. HHS estimated that just over 50 percent 
of the 281,000 children who exited foster care during fiscal year 2002 
were reunified with a parent or principal caretaker. 

If the parent has not followed child welfare agency plans or has failed 
to change behaviors to make reunification safe, the state may identify 
an alternative goal to establish a permanent home for the child. These 
goals include adoption, independence, or legal guardianship. 
Independent living arrangements may be attained once children reach the 
age of 18--or 21 in some jurisdictions--and have not been reunified 
with their families or adopted and for whom federal reimbursement for 
foster care expenditures is no longer available. Legal guardianship is 
a judicially created relationship between a child and a caretaker 
whereby the caretaker is awarded custody and decision-making rights 
with respect to the child. An October 2004 report indicated that 35 
states and the District of Columbia had established subsidized 
guardianship programs to help ensure permanent families for 
children.[Footnote 4] The federal government typically does not 
reimburse states for costs associated with subsidized guardianship. 
However, 7 states have operated or are currently operating federally 
funded guardianship projects through their participation in the Title 
IV-E waiver program. HHS data show that 4 percent of children exited 
foster care through guardianship in fiscal year 2002. 

HHS reports that in fiscal year 2002, 17 percent of children exited 
foster care through adoption. Unless a parent voluntarily relinquishes 
his or her rights, states must petition the court for a termination of 
parental rights (TPR) before a foster child can be adopted. ASFA 
requires, with few exceptions, that states file a TPR petition when a 
child has been in foster care for 15 of the most recent 22 months, but 
ASFA does not address the length of time needed to grant the petition 
to terminate. Before the termination is completed, states can begin to 
recruit for an adoptive family and even place a child in a pre-adoptive 
home with an interested family after this family has been approved. The 
adoptive family approval process generally involves background checks 
and a home study--a detailed examination of a family's circumstances, 
including its employment and finances and family medical history--to 
ensure that the family will provide a safe and suitable placement. The 
key steps in the process for adopting children from state child welfare 
agencies are summarized in figure 1. 

Figure 1: Flowchart of a Typical Adoption Process: 

[See PDF for image]

[End of figure]

In order to be eligible to receive federal funding, ASFA requires that 
states do not delay or deny the placement of a child for adoption when 
an approved family is available outside the jurisdiction that currently 
handles the child's case[Footnote 5] and requires states to facilitate 
the timely adoptive placement of children through the effective use of 
cross jurisdictional resources.[Footnote 6] States govern the placement 
of children across state lines through a compact known as the 
Interstate Compact on the Placement of Children (ICPC). At the time of 
publication, the compact was being rewritten to improve the process of 
placing children across state lines. 

Families who adopt children with special needs can receive monthly 
subsidies. The Adoption Assistance Program, under Title IV-E of the 
Social Security Act, authorizes the federal government to partially 
reimburse the states for the subsidies they provide to families who 
adopt special needs children. Payments to the parents of an eligible 
child with special needs can include both one-time adoption assistance 
for expenses such as attorney fees and ongoing monthly assistance, 
which is used for any identifiable needs of the child. Special needs 
children must meet at least one criterion from the following list: (1) 
the child is a dependent child who would have been eligible for AFDC, 
as it existed in 1996;[Footnote 7] (2) the child is eligible for 
Supplemental Security Income (SSI);[Footnote 8] (3) the child is a 
child of a minor parent who is in foster care already and receiving 
foster care maintenance payments under Title IV-E; or (4) the child 
received adoption assistance previously, but the adoption dissolved or 
the adoptive parents died. If the child does not meet these eligibility 
criteria, but still meets the state's definition of special needs, the 
state can provide a subsidy to the child's adoptive family, but cannot 
claim federal reimbursement. 

The amount of the subsidy is determined through negotiations between 
the adoptive parents and a representative of the state agency based on 
the needs of the child and circumstances of the adoptive family. The 
subsidies are intended to help adoptive families manage the cost of 
caring for their special needs children. Adopted children often have 
difficulties with issues of loss, attachment, and identity formation 
that can lead to behavioral and developmental problems and require 
professional treatment. In addition, special needs children with 
physical and other mental disabilities may require specialized care and 
treatment. Adoption subsidies are available to families until children 
reach age 18 but may be extended to age 21 if a mental or physical 
disability necessitates continuation. 

In addition to reimbursing states for the adoption subsidies, the 
federal government pays adoption incentive funds to qualifying states. 
Under the Adoption Promotion Act of 2003, (Pub. L. No. 108-145), which 
amended the Adoption Incentives Program, a state is eligible for an 
award if the number of adoptions from the foster care system for the 
fiscal year under review exceeds the state's baseline year, the highest 
number of adoptions in any previous year, beginning with fiscal year 
2002. States may also receive an incentive payment based on the 
adoptions of children having special needs or children older than age 
9. Specifically, when a state exceeds its baseline year in each 
category, it will receive an incentive payment of $4,000 for each child 
adopted from foster care, $2,000 for the adoption of each special needs 
child younger than age 9, and $4,000 for the adoption of each child 
aged 9 or older. Thus, the program encourages adoption generally while 
emphasizing the adoption of children with special needs. In fiscal year 
2003, the federal government paid states more than $17 million in 
incentive payments through this program. 

Title IV-E adoption subsidies and adoption incentive awards are not the 
only federal assistance available to support adoption. Funds authorized 
under Title IV-B of the Social Security Act, the Temporary Assistance 
for Needy Families program (TANF), and the Social Services Block Grant 
(SSBG) have also been used to facilitate and sustain 
adoptions.[Footnote 9] We reported that in fiscal year 2002 states used 
more than $5 million in Title IV-B funds on adoption subsidy payments, 
more than $9 million on recruitment and training for foster and 
adoptive parents, and nearly $29 million on adoption support and 
preservation services.[Footnote 10] A recent survey on states' fiscal 
year 2002 allocations of federal funds for child welfare found that 
states reported spending $56 million in TANF funds, $44 million in 
Title IV-B funds, and $22 million in SSBG funds on adoption and support 
services for adopted children.[Footnote 11]

HHS's Children's Bureau administers and oversees federal funding to 
states for child welfare services under Titles IV-B and IV-E of the 
Social Security Act, and states provide these child welfare services, 
either directly or indirectly through contracts with private agencies. 
Among other activities, HHS staff are responsible for developing 
appropriate policies and procedures for states to follow and conducting 
administrative reviews to ensure that states are in compliance with 
established policies. HHS staff from its 10 regional offices provide 
technical assistance to states, review state planning documents, assist 
with state data system reviews, and assess states' use of funds for 
foster care maintenance payments. Between 2001 and 2004, HHS completed 
its first round of Child and Family Services Reviews (CFSR), which 
assessed child welfare outcomes in all 50 states, the District of 
Columbia, and Puerto Rico. These reviews assessed states' progress and 
achievement in many areas and found weaknesses related to adoption. For 
example, HHS reported that at least 27 states experienced challenges 
seeking terminations of parental rights in accordance with ASFA. In 
addition, HHS also reported that 37 of the 52 states failed to meet the 
national standard of finalizing adoptions within 24 months of the 
child's most recent entry into foster care. 

To evaluate states' performance on child welfare indicators, such as 
timely adoptions, HHS relies, in part, on its Adoption and Foster Care 
Analysis and Reporting System (AFCARS) to capture, report, and analyze 
information collected by the states. In addition, AFCARS is used to 
generate annual reports on foster care and adoption programs 
nationwide, and it is the primary source of data for the Adoption 
Incentives Program. We reported that the AFCARS data were not reliable 
and recommended that HHS make improvements. HHS officials agreed with 
our findings and stated that several data definitions in AFCARS would 
be updated and revised.[Footnote 12] In June 2004, HHS officials stated 
that the regulations related to making these changes were being 
drafted. As of April 2005, the regulations had not been issued, and HHS 
officials said they did not have a specific planned release date. 

States Reported That Limited Resources, Court-Related Processes, and 
Interstate Placement Delays Impede the Adoption of Special Needs 
Children: 

States we visited reported that limited resources, court-related 
processes, and delays in completing interstate placements were the 
major challenges to special needs adoption. The limited resources 
impeded state agencies' efforts to recruit adoptive families. 
Additionally, officials said that difficulties scheduling cases and the 
time involved with other court proceedings delayed finalizing 
adoptions. Officials also reported that delays in completing home 
studies hindered adoptions that involved interstate placements. 

State Adoption Officials Report That Limited Resources Impede 
Adoptions: 

In part because of resource limitations, adoptive parents in many 
states received lower subsidies and fewer services than foster parents. 
Officials in 4 of the 5 states we visited told us that budget issues in 
their states have caused reductions in or eliminations of adoption 
services. States are prohibited by statute from providing monthly 
adoption assistance payments that exceed the foster care maintenance 
payments that would have been paid if the child had been in a foster 
home. Officials in 4 of the states we visited said that most special 
needs children are adopted by their foster parents, and a 2002 report 
found that nearly two-thirds of children adopted from the child welfare 
system are adopted by their foster parents.[Footnote 13] In responding 
to a question in our survey, 31 of 49 states reported that adoption 
assistance payments were lower than foster care maintenance payments in 
those states, and more than half of the 31 states viewed lower adoption 
payments as a moderate to very great hindrance to the adoption of 
special needs children. According to an official in one of the states 
we visited, adoption subsidies are critical to helping families who 
adopt special needs children pay for the care and services these 
children need. Families adopting special needs children may face 
substantial costs for medical care and mental health services, and 
several of the experts we interviewed explained that prospective 
adoptive families may hesitate to adopt special needs children because 
they are concerned about the costs of providing services to meet their 
needs. In addition, services, such as respite care, provided by the 
state for foster children may be provided to a lesser degree or not at 
all to adopted children or to children being cared for by legal 
guardians. Our survey asked states about 13 types of services. For 9 of 
the 13 services, fewer states reported providing the services to 
adopted children than to foster children; for every service, the fewest 
number of states extended these services to children in guardianship 
arrangements. (See fig. 2.) Further, officials in 4 of the 5 states we 
visited confirmed that subsidies and services declined when foster 
parents became adoptive parents. 

Figure 2: Types of Support Provided to Families Caring for Children 
with Special Needs: 

[See PDF for image]

Notes: Data based on survey responses from 47 states, the District of 
Columbia, and Puerto Rico. 

Maintenance payments are payments to foster parents to reimburse them 
for the costs associated with caring for foster children. Analogous 
payments can be made to adoptive parents in the form of adoption 
subsidies. 

Agency caseworker services are ongoing case management services, 
provided by trained agency staff that can include, among other things, 
information and referral services that adoptive or foster families 
might need. 

Medical supplies can include reimbursement for physical therapy or 
medical equipment, such as wheelchairs. 

Residential treatment is a therapeutic intervention process for 
children who cannot or do not function satisfactorily in their own home 
environments. 

Respite service is temporary care for foster or adoptive children so 
that foster or adoptive parents can be relieved of the responsibility 
for the children's daily care for a period of time (several hours or 
several days). 

Crisis intervention is provided on an emergency basis and can include 
mental health treatment or family counseling in response to severe 
emotional or health issues that threaten the stability of a foster care 
or adoptive placement. 

Individual/group therapy and family therapy include psychological and 
emotional counseling for children in the care or their adoptive or 
foster parents. 

Post secondary waivers provide free or reduced tuition for adoptive or 
foster children in state-supported post secondary educational programs. 

[End of figure]

In addition, many states reported that it was difficult to recruit 
families and limited resources affected their efforts. Nearly half of 
the 49 states responding to a relevant question in our survey indicated 
that difficulty recruiting families was a great or very great challenge 
to the adoption of special needs children. In 4 of the 5 states we 
visited, child welfare staff we interviewed told us that high caseloads 
limited the time caseworkers could spend recruiting families and 
placing children. In some cases, tight budgets led officials to make 
personnel decisions that made fewer experienced staff available to 
recruit adoptive parents. In Georgia, officials explained that because 
of budget and staffing constraints, instead of having workers who could 
specialize in various processes, such as recruiting adoptive parents, 
child welfare workers had to handle multiple aspects of each case. 
Further, in Michigan, officials explained that a budget saving plan to 
encourage early retirement led many experienced child welfare staff to 
retire. While the child welfare agency hired new workers, nearly all of 
them were inexperienced and needed both formal and on-the-job training. 
As a result, according to the foster and adoptive parents we 
interviewed in that state, these inexperienced workers were less 
effective than experienced workers at meeting families' needs. 

Additionally, in part because of staffing and resource constraints, 
there are concerns about how long it takes to place children with 
families. Both a home study and a background check are required for 
adoptive families, but according to adoptive and waiting parents in one 
state, high caseloads limited the time caseworkers could spend 
completing these studies, and frequently it was several months from the 
time families indicated interest in adopting until their home studies 
were completed. In addition, states typically provide adoptive families 
with an orientation to the adoption process and relevant training, but 
caseworkers in one of the states we visited told us that because of 
resource constraints, training of prospective adoptive parents is 
limited, particularly in the rural areas. 

After home studies are completed and the families have been approved, 
families often wait for suitable placements. One study found that the 
matching and placement phase involved more uncertainty and 
misunderstanding for prospective adoptive families than any other step 
in the adoption process.[Footnote 14] The same study also found that 
one-quarter of potential adoptive parents felt that they were not given 
an accurate estimate of the time it would take for a placement. Another 
report noted that infrequent contact between caregivers--foster parents 
and guardians--and case managers resulted in caregivers leaving the 
foster care system and not pursuing adoption.[Footnote 15] In 3 of the 
states we visited, foster, adoptive, and pre-adoptive parents told us 
that because of staff shortages, high caseloads, and other duties, 
caseworkers did not give them the attention they needed. As a result, 
some adoptive and pre-adoptive parents who were trained lost interest 
or sought children through other means, such as private placements. In 
New Mexico, almost all of the potential adoptive families we talked 
with in one rural area had been waiting for more than a year to adopt. 
They expressed frustration over the lack of contact from the child 
welfare agency while they knew that there were many children waiting 
for placements. Correspondingly, 20 of 46 states responding to an open- 
ended question in our survey reported that high caseloads or 
insufficient staff were among the three greatest challenges to 
facilitating or finalizing the adoption of special needs children. 

Officials Cited Court Delays as a Challenge to the Adoption of Special 
Needs Children: 

Court-related delays were also cited as a challenge to the adoption of 
special needs children. Twenty-two of the 46 states responding to a 
relevant question in our survey indicated that court-related delays 
were among the three greatest challenges to the adoption of special 
needs children. In 3 of the states we visited, judges told us that it 
was hard to schedule termination of parental rights hearings because 
court dockets were full and because of the many parties involved in 
some hearings. In some cases, the participants include the judge, 
biological parents, foster parents, the caseworker, and multiple 
attorneys--one for each child in a sibling group, one for each 
biological parent, and one for the caseworker or child welfare 
department. Scheduling a hearing date that fits everyone's schedule and 
allows all parties to attend can be difficult. 

In addition to difficulties in scheduling hearings, termination 
proceedings can last months. Many judges want to be sure that the 
biological parents have had sufficient opportunity to remedy the 
problems that led to their children being removed. If a parent seems to 
be making progress, even if the parent is not yet ready to resume 
custody of his or her child, the judge may postpone a decision. Even in 
cases in which the likelihood for reunification is low, attorneys in 3 
of the 5 states we visited told us that some courts hesitate to 
terminate parental rights until adoptive families are found for 
children. According to HHS's analysis of its Child and Family Services 
Reviews, in over half of the states reviewed between 2002 and 2004, 
many judges were reluctant to terminate parental rights either because 
adequate services had not been provided to parents or because an 
adoptive family had not been identified.[Footnote 16] Yet while some 
judges may not want to create a legal orphan before an adoptive 
placement is identified, judges we spoke with in 3 of the 5 states we 
visited said that the identification of prospective adoptive families 
did not play a role in their decision to terminate parental rights. 
Furthermore, the termination process can be delayed if an appeal is 
filed by a biological parent or a relative raises an objection. In 
Michigan, court officials told us that children's relatives may come 
forward to protest when such a decision is imminent. Relatives' 
objections can create delays because the child welfare agency must 
determine whether the relatives can be involved in the children's care, 
and the court may also schedule further hearings concerning the details 
of their objections. 

Delays Completing Home Studies Have Hindered Some Interstate Adoptive 
Placements: 

Delays in completing home studies impeded the interstate placement of 
children and therefore delayed the adoption process. Of the 49 states 
responding to our survey, 26 cited the lengthy process to place 
children across state lines as a moderate to very great hindrance to 
the adoption of special needs children. In the course of seeking an 
adoptive placement, sometimes a child welfare agency in the state where 
the child resides finds a suitable family in another state. The agency 
in the state with the child, known as the sending state, seeks a 
placement in the state where a potential adoptive family lives--the 
receiving state. Generally, caseworkers from the sending state request 
that a receiving state complete a home study of the prospective family. 
However, caseworkers in the receiving state may assign this request a 
low priority because conducting the home study would take time away 
from their own caseloads. According to a survey of state officials 
conducted by the American Public Human Services Association (APHSA), 32 
of the 45 respondents cited staffing and workload issues as the leading 
cause for delay in completing home studies requested by other states. 
Another frequently cited cause of delay was the low priority assigned 
to interstate placements by local workers.[Footnote 17] According to 
current interstate compact guidelines, 6 weeks or 30 working days is 
the recommended processing time from the date the receiving state gets 
notice from the sending state until the placement request is approved 
or denied. However, APHSA notes that sometimes the receiving state does 
not complete home studies for many months. In some cases, therefore, 
children linger in foster care when interstate placements are delayed. 

While the Adoption and Safe Families Act includes a provision that 
directs states to develop plans to facilitate the timely adoptive 
placement of children through the effective use of cross-jurisdictional 
resources, there are no national data to assess the timeliness of these 
placements. Data from AFCARS can show whether or not children were 
adopted outside their home state, and they also can be used to track 
the length of time from entry into foster care to termination of 
parental rights and adoption. However the system does not capture which 
states were involved or when placement requests were made or completed. 
Without such specific data, HHS does not know the extent to which 
states are cooperating, which states may need to improve their 
processes, or whether certain states are burdened by high numbers of 
requests for home studies in support of interstate placement. APHSA has 
developed a database for tracking interstate adoptions. Unlike HHS's 
system, this database tracks the total number of children any 
participating state sent out of state or received for adoption and the 
total number of finalized adoptions a state made after receiving 
requests from other states. Participation in the association's database 
is voluntary, and as of November 2004, 16 state agencies had provided 
their information. 

States and HHS Have Promoted Special Needs Adoption, but Few 
Evaluations Measure Program Effectiveness: 

States and HHS have developed strategies and implemented programs to 
promote special needs adoptions, but few evaluations measure their 
effectiveness. States used both general and targeted recruitment 
efforts to help identify adoptive homes for special needs children. 
States have also provided special services and programs to help sustain 
adoptions. To assist states in their adoption efforts, HHS has 
supported many demonstration programs over the years. Although HHS has 
disseminated information and summaries about some of the programs and 
services, little has been done to assess the effectiveness of such 
programs, and as a result, neither HHS nor the states know which 
approaches have been most successful. 

States Used General and Targeted Approaches to Identify Adoptive 
Families and Promote Adoption: 

States have used various methods to recruit adoptive families. They 
have placed ads on billboards; distributed or posted fliers and posters 
at booths during public events or in special locations, such as 
shopping malls, libraries, churches, and businesses; sent caseworkers 
to community fairs and parades; and used special public service 
announcements and media campaigns to generally recruit adoptive 
families. Many states have observed and participated in National 
Adoption Awareness Month each November, and some states have promoted 
adoptions by designating other special days.[Footnote 18] For example, 
officials in Massachusetts told us that they finalized 32 adoptions on 
a single day in May 2004. According to the National Adoption Day 
organization, more than 3,100 adoptions were finalized during National 
Adoption Awareness Month in 2003. 

To help facilitate adoption, states have contracted with private 
adoption agencies to recruit and train prospective families, developed 
Web sites, and partnered with adoption exchanges. Of the 49 states 
responding to our survey, 40 indicated that contracts with private 
agencies were an essential or very important recruitment method. In 
addition, all 5 of our site visit states, as well as others, operated 
Web sites that include photo listings of children awaiting adoption as 
well as information on adoption procedures and resources for 
prospective adoptive families. Also, 4 of the 5 states we visited, as 
well as other states, partnered with adoption exchanges--information 
and referral services for prospective adoptive families--to operate 
electronic registries of waiting children. For example, Michigan's 
adoption resource exchange operates a Web site containing a calendar of 
training opportunities and events, a searchable database of children 
awaiting adoptive families, and general information on the adoption 
process. 

In addition, most states used targeted recruitment strategies that 
focused on a specific group of children. Of the 49 states responding to 
a question in our survey on methods for recruiting adoptive families 
for special needs children, 37 reported that television advertisements 
and stories were essential or very important, 35 states reported that 
advertisements in magazines and other periodicals were essential or 
very important, and 22 responded similarly regarding mass mailings or 
flyer distribution. For example, Kentucky officials noted in our survey 
that they created a special television public service announcement to 
recruit adoptive families for special needs children. The advertisement 
was filmed at the Governor's home and included children with special 
needs. Another state, Georgia, issued a photo listing book, entitled 
"My Turn Now," that includes those children who have been awaiting 
adoption for the longest period of time. 

Many states also hosted adoption promotion events throughout the year 
that targeted certain children, such as minorities or those in sibling 
groups. In Massachusetts, for example, the state agency has partnered 
with a local furniture store to host several adoption parties. The goal 
of the event is to help match prospective families with those children 
in attendance. State officials credit this business partnership with a 
number of successful adoptive matches. Another targeted strategy, known 
as the Heart Gallery, has been under way in New Mexico since 2001 and 
has also been implemented by a number of other states. This event has 
showcased professional photographs of children waiting to be adopted. 
Though the organizers in New Mexico have not collected data to track 
matches resulting from participation in the gallery event, one 
organizing official told us that several children who were showcased at 
the events have been adopted. Further, a Massachusetts official stated 
that within 2 months of implementing the Heart Gallery in that state, 
placements were found for half of the children showcased. In addition, 
some states are working with local community organizations and churches 
to help recruit and place particular children in adoptive homes. 
According to a National Governor's Association report, 30 states and 
the District of Columbia have participated in an adoption program 
called One Church One Child, since 1980. The program seeks to recruit 
one family from each African-American church to adopt an African- 
American child. 

States Provided Some Services and Resources to Help Sustain Adoptions: 

As indicated earlier in figure 2, states are providing some post- 
adoption services and resources, which many experts have said are 
critical to helping families sustain adoptions. Generally, post- 
adoption services are provided with the recognition that parents 
adopting children often face challenges they did not anticipate and for 
which they are not fully prepared, especially when the children have 
special needs. These services are intended to help reduce the number of 
adoptions that are dissolved.[Footnote 19] As previously noted, states 
generally provide fewer services to adoptive families than to foster 
families. However, 4 of the 5 states we visited have established 
centers to assist families after their adoptions were finalized--see 
table 1. 

Table 1: Characteristics of Post Adoption Resources Available in Five 
States: 

Georgia: 

State resource: Georgia Center for Adoption Resources and Support--a 
statewide service center located in Atlanta, Georgia. The center became 
operational in 2002 and is part of Georgia's Office of Adoptions. 
Resource Advisors are located in each of the regions of the Department 
of Human Resources throughout the state; 
Key features of post adoption service: 
* Toll-free number: Connects families with the resource center, lending 
library, and Resource Advisors; 
* Post adoption advisors: Assist families in locating resources; 
* Newsletter: Provides articles of interest to adoptive families; 
* Adoptive Family Network: Matches adoptive families with "buddy" 
families who adopted children with similar needs; 
* Web site: Provides current information on resources and special 
events; 
* Lending library: Contains a collection of books, magazines, and 
videotapes covering a variety of adoption, parenting, and child 
development issues; 
Eligibility regulations: Services provided through the Georgia Center 
for Adoption Resources and Support are available to all adoptive 
families residing in Georgia. 

State resource: Georgia's Office of Adoptions--created to develop, 
promote, and support quality adoptive placements and services; 
Key features of post adoption service: 
* A TEAM mentoring program: Provides mentoring for adopted teens in 
grades 6-12; 
* Intervention team: Provides early intervention to improve the 
family's well being, and to decrease adoption disruption and 
dissolution; 
* Tutorial services: Provides educational support services for children 
who need tutorial intervention; 
* Camp Promise: Provides an opportunity for adopted children to attend 
a summer camp program with other adopted children; 
* Respite care: Provides short-term, time-limited care for adopted 
children; 
Eligibility regulations: With the exception of services provided by the 
Georgia Center for Adoption Resources and Support, services provided by 
the Office of Adoptions are available only to families who have adopted 
children from the state's public child welfare agency. 

Massachusetts: 

State resource: Adoption Journeys (formerly known as Adoption 
Crossroads)--a statewide program founded in 1997. Services are 
administered and coordinated by the Child and Family Services Agency 
for the state, and are provided through a network of five affiliate 
agencies located in different geographic regions of the state; 
Key features of post adoption service: 
* Toll-free number: Connects families and professionals to a 24-hour 
toll-free phone line that offers information, joint problem solving, 
and immediate emotional support; 
* Family support groups: Meet on a weekly basis in all regions of the 
state; 
* Regional response teams: Work with families to address a range of 
problems that could jeopardize the long-term success of the adoption; 
* Advocacy and coordination: Empowers families and enhances their self-
advocacy skills; 
* Training for mental health and social service professionals: Provides 
consultation and training; 
* Respite care: Provides short-term, time-limited care for adopted 
children; 
Eligibility regulations: Services are available to all state residents 
who have adopted children or legalized guardianships, including those 
originating from state, private, or international sources. 

Michigan: 

State resource: Regional Resource Centers for Post Adoption Services-- 
established in 2001. At the time of our site visit, there were seven 
centers serving specific counties in the state; 
Key features of post adoption service: 
* Toll-free number: Connects families to a toll-free line to obtain 
information on free and low-cost services that are available around the 
state; 
* Parent support groups: Allow parents to meet and connect with others 
facing similar situations; 
* Family support events: Allow adoptive families to connect while 
taking the time to relax and enjoy activities; 
* Parent training: Provides training for adoptive parents to become 
educated on issues that affect their families; 
Eligibility regulations: Services are available to families who have 
adopted children from the state's foster care system. The child must be 
under 18 years of age, receive an adoption subsidy, and reside in the 
county in which the center provides services. 

New Mexico: 

State resource: According to state officials, no formal post adoption 
program exists in the state. Families needing assistance can call their 
caseworkers for information and referral and may be linked to training 
and support groups that private agencies provide. 

Oregon: 

State resource: Oregon Post Adoption Resource Center--a statewide 
service founded in 1999. The center, a program of the Oregon Department 
of Human Services, is federally funded; 
Key features of post adoption service: 
* Parent support groups: Provide on-site assistance, training, and 
technical support for adoptive parent support groups; 
* Parent training: Provides formal on-site training twice a year in 
each of the state's four regions; 
* Directory: Lists local, regional, and statewide resources for parents 
in need of therapists, respite care, support groups, camps, public 
school programs, special educational facilities, and other services; 
* Lending library: Includes videos, books, self-study courses, and 
information packets; 
* Respite care: Develops and maintains systems that help families 
connect with respite resources; 
Eligibility regulations: Services are available to families who have 
adopted children from the state's foster care system. 

Source: GAO summary of resources, as described by state resource 
centers. 

[End of table]

However, according to state adoption officials, caseworkers, and 
adoptive parents we met during our site visits, better post adoptive 
mental health services are needed. In addition, several of the experts 
we interviewed expressed the opinion that many mental heath providers 
needed to develop and improve their competencies in adoption-related 
topics such as trust, abandonment, and attachment. Some states have 
established programs to do just this. For example, New Jersey's 
Adoption Certificate Program, in coordination with Rutgers University 
School of Social Work and Continuing Education Department, developed a 
45-hour postgraduate training program leading to an adoption 
certificate for mental health clinicians. The certificate program is 
intended to increase the knowledge of mental health practitioners 
regarding the core issues facing adoptive families, and to expand their 
clinical skills in attachment-based, family-focused therapeutic 
interventions. Oregon's efforts present another example. Portland State 
University, in collaboration with Oregon's Department of Human Services 
and Oregon's Post Adoption Resource Center, has also developed a 
postgraduate training certificate program for mental health providers 
working with adoptive families. The training program includes hands-on 
strategies for coaching and working with adoptive parents to address 
their children's challenging behaviors. According to program officials, 
the program has trained 27 therapists, and 15 more are expected to 
complete the program by June of 2005. The names of these therapists 
have been or will be forwarded to Oregon's adoptions resource center to 
be included in referral information sent to adoptive families in need 
of mental health therapists. 

Most states have not conducted evaluations of their post adoption 
services. In responding to our survey, 9 states indicated that they 
have completed evaluations of post adoption services; 8 states said 
that they had evaluations under way, and 30 informed us that they had 
not conducted any evaluations prior to their completion of our survey. 
Evaluations play an important role in improving program operations. 
They can identify which services are most important to families, as 
well as help managers determine whether the services are achieving 
desired goals and if they can be provided more efficiently. Evaluation 
results can help individual states improve their programs and, if 
shared, can provide other states with valuable information to help 
avoid costly mistakes. 

HHS Has Administered Many Programs to Help States' Adoption Efforts: 

Various HHS activities have helped states' adoption efforts. Over the 
years, HHS has administered programs, sponsored campaigns, funded a 
resource center, and taken steps to disseminate information about 
adoptions. According to HHS officials, special needs children 
constitute the majority of children waiting for adoptive homes, and as 
such, they are the beneficiaries of the agency's efforts to support 
adoption. 

HHS has promoted innovation for many years through the Adoption 
Opportunities Program and the Title IV-E Child Welfare Demonstration 
Program. The Adoption Opportunities Program, authorized by the Child 
Abuse Prevention and Treatment and Adoption Reform Act of 1978, as 
amended, generally provides 3-to 5-year grants and contracts to public 
and private adoption agencies. These grants and contracts have been 
used to support states' efforts, such as increasing placement of 
minority children, recruiting minority adoptive families, and providing 
post adoption services for families with special needs children. Since 
the program's inception, Congress has obligated more than $300 million 
for the Adoption Opportunities Program. In 2003, HHS administered about 
$7.3 million in first-year funding for 20 projects and in 2004 awarded 
$4.4 million in first-year funding for 13 projects. Also, to promote 
innovation, HHS has administered the Title IV-E Child Welfare 
Demonstration Program since 1994. Among other things, this program 
allows states to waive certain restrictions on the use of Title IV-E 
funds that heretofore have prevented states from providing support to 
guardians. Since 1996, 7 states have operated or are currently 
operating waiver projects that have provided monthly payments to 
relatives and other caregivers who agree to become a child's legal 
guardian. The objective is to test whether providing monthly support to 
guardians, which is generally less than payments made to foster 
parents, can help reduce a state's overall foster care costs and 
improve permanency outcomes for children. 

Since 2002, HHS has supported local efforts to recruit and support 
adoptive families and increase public awareness about adoption by 
sponsoring AdoptUSKids--a national initiative promoting adoption that 
is operated by a coalition under contract with HHS. AdoptUSKids has 
partnered with the Ad Council--a provider of public service 
announcements to raise awareness about social issues--to develop a 
national campaign to recruit adoptive families, and HHS has contributed 
more than $4.1 million to the effort. The campaign is expected to run 
for 3 years and feature a variety of public service announcements on 
television and radio, and in print media. Of this amount, AdoptUSKids 
has allocated $2 million to support state recruitment response teams to 
handle the anticipated interest the campaign is designed to generate. 
Members of these state-based teams are expected to respond to calls and 
e-mails from prospective parents, link them with the appropriate state 
agencies, keep prospective parents engaged in the adoption process by 
providing a point of contact, and help parents overcome the barriers 
they may face in pursuing adoption. Response teams are also expected to 
encourage local media stations to run AdoptUSKids ads and to network 
with local politicians and community leaders. 

The AdoptUSKids initiative also helps fund adoptive parent 
organizations around the country to recruit prospective adoptive 
families and support existing ones. As of October 2004, AdoptUSKids had 
awarded a total of $420,000 to 105 parent groups in 44 states. To 
recruit prospective adoptive parents, AdoptUSKids operates a national 
database of children waiting to be adopted and has established a Web 
site that includes photos; demographic profiles; and brief descriptions 
of interests, special needs, and the types of adoptive families that 
would be the most appropriate for the children. The site is available 
to the public, although prospective adoptive families can inquire about 
specific children only after their state has approved them for 
adoption. According to AdoptUSKids, as of April 2005, about 41 percent 
of the children featured on the Web site had been placed with families 
in pre-adoptive homes. 

Further, HHS has also dedicated the resources of one of its seven 
federally funded national resource centers to specifically address 
special needs adoption.[Footnote 20] Based in Michigan, the National 
Child Welfare Resource Center for Adoption provides training and 
technical assistance to states to help them achieve timely adoptions 
and develop program improvement plans to correct weaknesses identified 
through federal reviews. HHS has provided about $1 million annually to 
support this resource center. 

HHS also has acknowledged the work of others to promote adoption and 
has disseminated adoption-related information. HHS established the 
Adoption Excellence Awards in 1997 and since then has presented the 
award to public and private organizations, courts, and individuals. In 
2004, HHS acknowledged the efforts of 17 groups and individuals who had 
a role in increasing the number of foster children placed in permanent 
homes. According to agency officials, the nonmonetary awards aim to 
raise awareness about adoption and publicly acknowledge best practices. 
To disseminate information about its programs and other activities 
concerning adoption, HHS has sponsored conferences devoted to adoption 
issues and sends a monthly electronic newsletter, the Children's Bureau 
Express, to more than 9,700 readers. This newsletter highlights new 
developments in the adoption field, as well as provides readers 
information on conferences and funding opportunities. The agency also 
maintains an e-mail distribution list of states' adoption and foster 
care program managers to help disseminate information on policies, 
procedures, and practices to the states and also maintains a Web site, 
operated by the National Adoption Information Clearinghouse, which 
collects and disseminates information concerning all aspects of 
adoption. 

HHS Has Done Little to Assess the Effectiveness of Its Programs: 

Although HHS has administered demonstration programs for many years, 
the agency has done little to evaluate the projects funded through 
these programs and therefore does not know which ones have been most 
successful. For example, the Adoption Opportunities Program has been 
under way since the late 1970s, but HHS did not require evaluations 
from the grantees until 2002. In the absence of evaluations, the agency 
has published summaries of grantees' final reports. For example, a 
document provided by HHS staff in 2002 and disseminated by the 
Clearinghouse synthesized the findings from 8 of 19 projects funded 
under this program. The document contains some information on the 
projects' challenges, lessons learned, and accomplishments, as well as 
recommendations from the grantees. However, HHS has prefaced this 
material with a disclaimer, noting that it does not represent the 
official views of the agency. Although evaluations have been required 
for the last several years, HHS's program staff told us they were still 
in the early stages of identifying criteria to help ensure that future 
evaluations from grantees will be done with sufficient rigor to help 
assess effectiveness. 

HHS has also required evaluations from Title IV-E waiver recipients, 
but little is known about the effectiveness of these projects, even 
though HHS has provided staff and technical assistance to help state 
grantees design, implement, and evaluate their projects. Rigorous 
design is an essential component to incorporate when evaluations are 
intended to develop conclusions about the effectiveness of a project. 
Such design could include random assignment or controlled quasi- 
experimental design.[Footnote 21] Of the seven state evaluations 
submitted between 2002 and 2004 that addressed guardianship, two were 
designed in a manner that allowed for comparisons between experimental 
and control groups. For example, the evaluation in selected regions of 
Illinois was the most methodologically rigorous of the seven, and its 
design incorporated random assignment, which allowed for reliable 
comparison between the control and experimental groups. The Illinois 
evaluation's findings suggest that children for whom subsidized 
guardianship was an option experienced a 6 percent higher permanency 
rate than those in the control group and guardianship was also 
comparable with adoption in terms of safety and ensuring a child's well 
being. The evaluations from the other 5 states were less rigorous in 
their design or implementation. For example, comparison groups used to 
evaluate guardianships in Oregon and New Mexico were not necessarily 
comparable in composition or makeup with the guardianship population 
supported by the project. Consequently, the difference in outcomes for 
those in guardianships could be due to internal differences or 
characteristics, rather than to the treatment (i.e., guardianship) 
itself. Other project evaluations were limited by reliance on group 
numbers too small for generalization and by poor response rates to 
assessment surveys and interviews. While the size of the project and 
the costs associated with measuring outcomes and collecting data should 
be considered in conducting evaluations, HHS officials acknowledged the 
weaknesses of the current work conducted by grantees and said they have 
learned more about the need for greater rigor as evaluations have been 
submitted. They also indicated that evaluations are managed by the 
states and HHS has very little control over how they are completed. 
Meanwhile, HHS has posted summaries of projects undertaken through the 
waiver program, and according to agency officials, they have drafted a 
synthesis of findings reported by grantees. 

The Adoption Promotion Programs Have Supported Special Needs Adoption, 
but Data Are Lacking to Determine if Changes Are Needed: 

The adoption assistance and adoption incentive programs have supported 
the adoption of special needs children, but data are lacking to 
determine if changes are needed to better facilitate adoption. The 
Title IV-E Adoption Assistance Program uses an income threshold for 
eligibility that is outdated and more restrictive than other cash 
assistance programs' standards of needs and therefore limits 
eligibility. With regard to adoption incentives, all states have 
increased their annual number of adoptions enough to receive financial 
awards for doing so at least once but data are lacking to assess 
interstate placement challenges and credit states for collaborating. 

Adoption Assistance Income Criteria Are Outdated, and Eligibility 
Determinations Are Difficult to Make: 

The Title IV-E Adoption Assistance Program was designed to help support 
the adoption of economically disadvantaged children with special needs. 
However, the income measure used to assess the standards of need in the 
AFDC program, as it existed in 1996, is outdated and in many states 
more restrictive than other programs' standards of need, such as the 
measure used for TANF cash assistance eligibility.[Footnote 22] For 
example, in Massachusetts, a family of three could earn up to $633 per 
month and qualify for TANF, but this family would not qualify for AFDC 
unless the earnings were no more than $579--a difference of $54 per 
month. According to an HHS official, eligibility for AFDC and TANF is 
governed by complex rules, which therefore complicate comparison. 
Nonetheless, more than one-third of the 39 states responding to an open-
ended question in our survey, as well as officials in 4 of the 5 states 
we visited, expressed the view that Title IV-E income eligibility 
criteria--based on AFDC eligibility--should be less restrictive. 

Further, making the income determinations has presented problems for 
some states. We asked officials in each of our 5 site visit states to 
comment on the administrative burden associated with the income 
eligibility criteria. Officials in 4 states said that determining 
whether children met the income requirements, by virtue of the parents' 
income, was time-consuming and challenging, particularly if their 
incomes were not readily available through a state-maintained database. 
Between fiscal years 2000 and 2004, HHS found that nearly all states 
had made errors in applying the income criteria and determining the 
income eligibility for foster care maintenance determinations. Since 
states must also base adoption assistance income eligibility on 
parents' income, similar mistakes are likely. HHS fined 50 of the 52 
states it reviewed between 2000 and 2004 more than $14 million for 
claiming foster care maintenance payments for ineligible cases, and one 
of the most frequent reasons for fines, according to HHS officials, was 
the inappropriate application of the AFDC income criteria.[Footnote 23]

Data Are Lacking to Estimate the Cost of Changing or Eliminating the 
Income Requirement: 

While members of Congress, the Administration, and others have proposed 
changing or eliminating income requirements, HHS lacks data to assess 
the likely cost to the federal government of doing so. Nevertheless, 
state officials and adoption subsidy managers from 4 of the 5 states we 
visited recommended that Title IV-E not be tied to criteria once used 
for the old AFDC program. The Pew Commission on Children in Foster 
Care--a national nonpartisan group formed in 2003 and composed of 
legislators, judges, child welfare administrators, and others--has 
estimated that eliminating the AFDC criteria from the foster care and 
adoption programs would cost the federal government $1.6 billion 
annually. The commission based its figure on fiscal year 2002 
expenditure data as well as estimated projections of the percentage of 
children who qualify under current regulations. A more reliable 
estimate cannot be made because HHS does not maintain critical data on 
those children and their families who are not eligible. Specifically, 
for those children deemed ineligible, HHS does not maintain family 
income data or data on the presence or absence of special needs. As a 
result, no one can determine how many families just missed the 
eligibility criteria and how many of these children had special needs. 
According to an HHS official, the agency has not done a formal cost 
estimate of expanding Title IV-E eligibility criteria, but it has been 
developing an approach in support of proposals that the administration 
has made since 2004. According to one agency official, these proposals 
would eliminate income eligibility determinations for foster care. 
However, without critical data and a cost estimate, the extent to which 
expanding eligibility for the Adoption Assistance Program would 
contribute to the nation's growing fiscal imbalance is unknown. 

All States Have Claimed Adoption Incentive Funds at Least Once: 

With regard to the Adoption Incentives Program, as figure 3 indicates, 
all states have been able to increase their annual number of adoptions 
enough to receive financial awards at least once since 1998. 

Figure 3: Frequency of States' Attainment of the Adoption Incentive 
Award, 1998-2003: 

[See PDF for image]

[End of figure]

From 1998 to 2003, only South Dakota and Texas claimed the award each 
year, and 42 states earned it at least three times. The number of 
states receiving the award has fluctuated from year to year, however, 
as figure 4 illustrates. In 1999, 44 states earned the award--a 
reflection, perhaps, of states' implementation of ASFA and their 
pursuit of permanency through adoption. By 2001, though, the number of 
states receiving the award dropped to 24, which may have been due to 
states' inability to sustain high levels of adoptions. Since 2001, the 
number of states receiving the award has been on the rise. However, 
fewer states received the award in 2003 than in 1998, when the program 
began. 

Figure 4: Number of States Claiming Award, by Earning Year: 

[See PDF for image]

[End of figure]

Adoption incentive award amounts have varied, and states have used the 
funds to support an array of activities. For example, award amounts 
Texas earned ranged from $68,000 to nearly $3 million. States 
participating in a 2000 study reported using these awards to fund a 
variety of onetime activities, such as investing in post adoption 
services and making performance-based awards to local offices or 
counties.[Footnote 24] Our review of Child and Family Services Plans 
and Annual Progress and Services Reports from 5 states that received 
the award in 2002, found that these states used the funds to develop ad 
campaigns to recruit adoptive families, provide free legal services for 
adoption, and support child care for adoptive families. 

The Adoption Incentives Program rewards states for exceeding baselines. 
Some states reported that they focused on adoption prior to the 
implementation of the program but have since seen declines in the rate 
at which children enter foster care, and thus have been unable to 
finalize enough adoptions to claim the reward. According to officials 
from Massachusetts, while the state has continued to focus on adoption, 
it does not perceive the program to be an appropriate incentive because 
it simply rewards states for exceeding baselines rather than for other 
improvements such as placing children who have been in care the 
longest. As figure 5 indicates, a state theoretically could increase 
adoptions in the years subsequent to the establishment of its baseline 
and still not be in a position to claim the reward, especially if its 
baseline had been calibrated at a level it might not reach again. 

Figure 5: Illustration of the Difficulty in Claiming an Award under the 
Adoption Incentives Program: 

[See PDF for image]

[End of figure]

According to our survey, respondents had mixed opinions about the 
extent to which the program served as an incentive to promote special 
needs adoption. Twenty-two of the 49 states responding to a relevant 
survey question said the program was a great or very great incentive, 
while 24 responded that the program was a moderate or weak motivator. 
In addition, several of these respondents suggested that HHS further 
modify its baseline calculations. For example, states suggested adding 
a category to reward states for the adoption of children who have been 
in foster care for long periods of time, or altering the baseline to 
reflect increases year-to-year rather than rewarding states for 
exceeding historic baselines. 

Data Are Lacking to Assess Interstate Placement Challenges and Credit 
States for Collaborating: 

In addition, the program does not provide a specific inducement for 
interstate placements. Under the program's authorizing statute, the 
sending state can count the finalized adoption in its totals, but the 
receiving state does not get any credit for facilitating a placement, 
even though the receiving state must conduct the home study--a critical 
step in the adoption process. We do not have estimates of the costs 
incurred by states for conducting a home study, but officials in 1 
state told us that prospective adoptive families who adopt through 
private agencies may pay as much as $3,000 to complete home studies. 
HHS officials noted that it would be difficult to track which states 
should be receiving the credit for facilitating interstate placements, 
given the limitations in the data collected in AFCARS. Furthermore, 
officials informed us that they do not have the authority to split the 
incentive award. Nevertheless, they acknowledged the challenges states 
face with regard to interstate placement and expressed the view that 
changes that would provide an incentive to facilitate interstate 
adoptions could help. 

Conclusions: 

While many states have increased the adoption of children with special 
needs, data and evaluations are lacking to assess the degree to which 
federal and state programs have promoted special needs adoptions. 
Interstate placements have delayed adoptions, but data to assess the 
timeliness of these placements are not available. Without such data, 
HHS cannot identify those states that may need to improve their 
processes or those burdened by requests for assistance. As a result, 
delays associated with interstate placements will likely persist, and 
some special needs children may linger in foster care. Although states 
and HHS have developed strategies and innovative programs to promote 
and support special needs adoptions, HHS has done little to assess the 
effectiveness of its programs and funded projects. As a consequence, 
HHS does not know which projects have been most successful and cannot 
be assured that federal funds used to support state projects have been 
used wisely. While Title IV-E Adoption Assistance has supported special 
needs adoption, it is unclear how many more children would qualify for 
the program if income standards were adjusted to today's income 
standards of need. Further, without critical data and a cost estimate 
of expanding eligibility, the extent to which increasing the number of 
qualified children would contribute to the nation's growing fiscal 
imbalance is unclear. As for the Adoption Incentives Program, it does 
not encourage states to collaborate on interstate placements, therefore 
failing to support an area that already presents barriers. 

Recommendations for Executive Action: 

We are making three recommendations to further improve the process and 
programs related to special needs adoption. 

* To better understand delays associated with interstate placements, 
the Secretary of HHS should assist states in collecting and reporting 
data related to the interstate placement processes, especially the time 
needed to complete home studies and the sending and receiving state for 
each child placed across state lines. Such assistance could include 
modifying HHS's central data system, AFCARS, in conjunction with the 
agency's ongoing efforts to update and revise this system. HHS should 
analyze the data to assess the extent to which home studies cause 
delays or impede interstate adoptions and to identify which states are 
facilitating timely interstate placements. If supported by its 
findings, HHS should consider proposing legislation to amend existing 
law so that both sending and receiving states could claim an interstate 
adoption for purposes of determining award eligibility. 

* To improve HHS's ability to assess the effectiveness of its funded 
projects, the Secretary of HHS should develop guidance to ensure that 
rigorous design elements are incorporated into projects and related 
evaluations. Such guidance could consider the nature and structure of 
the projects and include measures to control costs. 

* To assess the extent to which Title IV-E adoption assistance 
eligibility criteria exclude some economically disadvantaged children 
with special needs, the Secretary of HHS should (1) gather data on the 
economic circumstances of special needs children who do not currently 
qualify for IV-E and (2) develop a model to estimate the federal cost 
of expanding eligibility. 

Agency Comments: 

We received written comments on a draft of this report from HHS. These 
comments are reproduced in appendix II. HHS also provided technical 
comments, which we incorporated when appropriate. : 

HHS did not explicitly agree or disagree with the recommendations, but 
stated that two of our recommendations were being considered as part of 
a process to determine what, if any, revisions would be made to the 
agency's central data system, AFCARS. Specifically, HHS stated that the 
recommendation to collect data related to interstate placements and the 
recommendation to gather data on disadvantaged children with special 
needs would be considered as part of its AFCARS review. 

With regard to our recommendation that HHS develop guidance to improve 
project evaluations and help assess the effectiveness of funded 
projects, HHS stated that such actions were unnecessary and noted that 
it had taken steps to strengthen evaluation requirements and provided 
technical assistance. Nevertheless, HHS acknowledged that a number of 
demonstration projects have sometimes yielded results of limited 
utility because of problems adhering to negotiated evaluation 
protocols. Also, HHS stated that it is committed to continuing to 
improve the quality of information generated by funded projects and it 
will continue to work with states to identify rigorous, 
administratively feasible evaluation strategies. We continue to 
recommend that HHS develop additional guidance to improve evaluations. 
Such guidance is needed to improve the quality of the results from 
funded projects which will enable managers to assess their 
effectiveness. 

HHS also commented on our findings related to the evaluations conducted 
under the Title IV-E waiver program. HHS stated that our summary of 
these evaluations was somewhat misleading. It noted that several states 
in which guardianship is a focus of the demonstration have used 
experimental design. Also HHS said that the Oregon demonstration was 
focused primarily on testing the use of flexible funding, and therefore 
the evaluation of the guardianship components used other methods and 
focused on descriptive data. We modified the report to clarify the 
aspects of rigorous design. However, we did not change our description 
of the Oregon evaluation because it accurately portrayed the 
evaluation, which included information on the impact and effectiveness 
of the guardianship component of the project. 

We also provided a copy of our draft report to child welfare officials 
in the 5 states we visited and received technical comments from 
Georgia, Massachusetts, Michigan, and Oregon. We incorporated these 
comments when appropriate. 

As arranged with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
from its issue date. At that time we will send copies of this report to 
the Secretary of Health and Human Services, state child welfare 
directors, and other interested parties. In addition, we will make 
copies available to others on request. Also, this 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 me 
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 who made major contributions to this 
report are listed in appendix III. 

Signed by: 

Cornelia M. Ashby, Director: 
Education, Workforce, and Income Security Issues: 

[End of section]

Appendix I: Objectives, Scope, and Methodology: 

Objectives: 

The objectives of our study were to (1) identify the major challenges 
to placing and keeping special needs children in adoptive homes, (2) 
examine what states and the Department of Health and Human Services 
(HHS) have done to facilitate special needs adoptions, and (3) assess 
how well the Adoption Assistance Program and the Adoption Incentives 
Program have worked to facilitate special needs adoptions and what 
changes, if any might be needed to further facilitate adoptions. 

Scope and Methodology: 

To gather information about these objectives, we utilized multiple 
methodologies: (1) a Web-based survey to state child welfare agencies; 
(2) site visits to 5 states; (3) interviews with HHS officials, staff 
from key National Resource Centers, and child welfare researchers and 
practitioners, as well as discussion groups with adoptive parents and 
state adoption program managers; (4) a review of 10 selected states' 5- 
year reports and 5-year plans that HHS requires as part of its ongoing 
child welfare oversight, as well as a review of federal adoption 
assistance and promotion laws and HHS regulations; and (5) a review of 
adoption-related studies and evaluations conducted by HHS, the states, 
and nongovernmental organizations. We conducted our work between May 
2004 and April 2005 in accordance with generally accepted government 
auditing standards. 

Survey: 

To gather information about states' experiences with special needs 
adoption, we distributed a Web-based survey to the adoption program 
managers in all 50 states, the District of Columbia, and Puerto Rico on 
September 17, 2004. The survey contained a number of both closed-and 
open-ended questions. To determine whether the survey questions were 
clear, unbiased, and used appropriate language, we pretested the survey 
instrument with officials in Delaware, Pennsylvania, Maryland, New 
York, Virginia, Ohio, and the District of Columbia prior to 
distribution. After an appropriate period of time had passed after 
initial survey distribution, we conducted an extensive follow-up 
process that included e-mails and phone calls to states that had not 
yet completed the survey. At the culmination of this process, we 
received and analyzed responses from 50 states.[Footnote 25]

Because this was not a sample survey, there are no sampling errors. 
However, the practical difficulties of conducting any survey may 
introduce errors, commonly referred to as nonsampling errors. For 
example, difficulties in how a particular question is interpreted, in 
the sources of information that are available to respondents, or in how 
the data are entered into a database or were analyzed can introduce 
unwanted variability into the survey results. We took steps in the 
development of the questionnaire, the data collection, and the data 
analysis to minimize these nonsampling errors. For example, social 
science survey specialists designed the questionnaire in collaboration 
with GAO staff with subject matter expertise. Then, the draft 
questionnaire was pretested with a number of state officials to ensure 
that the questions were relevant, clearly stated, and easy to 
comprehend. When the data were analyzed, a second, independent analyst 
checked all computer programs. Since this was a Web-based survey, 
respondents entered their answers directly into the electronic 
questionnaire. This eliminated the need to have the data keyed into a 
database, thus removing an additional source of error. 

We took several steps to assess the reliability of the data obtained 
through our survey. During our pretests, we asked state officials 
questions to determine the reliability of the data they could provide, 
such as how accurate their data entry systems were and how confident 
they would be estimating the data we requested. On the basis of these 
responses, we decided to include an open-ended question in the survey 
instrument that would give states an opportunity to discuss any 
limitations in the data they sent us. After receiving final surveys 
from 50 states, we examined the responses to that particular open-ended 
question, along with all the closed-ended data questions, and made 
decisions about which to report on. We then examined the output to test 
for inconsistencies, took steps to resolve these inconsistencies with 
the relevant states, and determined that the data were sufficient and 
reliable for the purposes of our report. 

Site Visits: 

To gather more detailed information about the challenges states face 
promoting and sustaining adoption, as well as some of the practices 
they've implemented to overcome challenges, we selected 5 states to 
visit--Georgia, Massachusetts, Michigan, New Mexico, and Oregon--based 
on differences in their success achieving adoption incentive awards, 
along with their differences in location, size of child welfare 
population, degree of privatization of services, and whether they had 
state or locally administered systems. In preparation for the visits 
and to understand the unique circumstances in each state, we talked 
with HHS's regional office staff and field experts and obtained and 
reviewed relevant literature from each of the 5 states, such as studies 
of adoption efforts and promising practices. During our visits to each 
state, we talked with officials from the state child welfare agency, 
along with officials and staff from at least one local agency office. 
Specifically, in each state we spoke with the adoption program manager; 
caseworkers and supervisors; foster and adoptive parents; judges, 
attorneys, and other court personnel, such as guardians and advocates; 
and private agency officials under contract with the state. 

Interviews and Discussion Groups: 

To gather information about HHS's role in promoting special needs 
adoption and generating related research and evaluation, we interviewed 
HHS officials from Central Office and all the Regional Offices. We also 
spoke with staff from National Resource Centers involved in special 
needs adoption and permanency issues and interviewed nearly 20 child 
welfare experts and researchers to learn additional information about 
challenges confronting states' promotion and maintenance of special 
needs adoption. 

We also conducted separate discussion groups with adoptive parents and 
state adoption program managers. We conducted a discussion with 11 
adoptive parents from 8 states who were attending the annual conference 
of the North American Council on Adoptable Children to learn their 
perspectives on the adoption process, subsidy rates, and post-adoption 
services. We also held a discussion group with adoption program 
managers from 18 states during the annual meeting of the National 
Association of State Adoption Programs. During this discussion, we 
learned more about the federal role in promoting and sustaining 
adoption and obtained managers' perspectives on Title IV-E funding and 
the provision of subsidies to adoptive parents. 

Review of States' Reports, Federal Laws, and HHS Regulations: 

To learn more about how states were spending the adoption incentives 
funds they had received and what their plans were to recruit and retain 
adoptive families using federal funds, we reviewed 10 states' 2005-2009 
Child and Family Services Plans and 2004 Annual Progress and Services 
Reports--documents required by HHS as part of federal funding 
participation. We selected 10 states--half of which received an 
adoption incentive award in 2002--the latest date for which figures 
were available at the time of our selection and analysis--and half of 
which did not. Since we wanted to include documents from our 5 site 
visit states in the sample, we collected the plans and reports from 
another 5 states, selected randomly based on their receipt or 
nonreceipt of the award. Among the 10 states whose documents we 
reviewed, Georgia, Kentucky, New Hampshire, Oregon, and Pennsylvania 
received an award in 2002, and Alaska, Massachusetts, Michigan, 
Mississippi, and New Mexico did not. We summarized the plans and 
reports that HHS's regional offices provided to us for these states, 
including excerpts from unapproved plans, and included this information 
where appropriate. We also reviewed relevant laws and regulations 
describing the Adoption Assistance and Adoption Incentives Programs. 

Review of Studies and Evaluations: 

During the course of the work, we reviewed more than 20 adoption 
studies that had been conducted by states, university professors, and 
independent child welfare researchers. We also reviewed 14 evaluations, 
including those required under the federal Title IV-E waiver program, 
that were designed to assess the effectiveness of adoption, permanency, 
and post adoption projects. For each of the selected studies that are 
used in this report, we determined whether the study's findings were 
generally reliable. To do so, two GAO social science analysts evaluated 
the methodological soundness of the studies using common social science 
and statistical practices. For example, they examined each study's 
methodology, including its limitations, data sources, analyses, and 
conclusions. 

[End of section]

Appendix II: Comments from the Department of Health and Human Services: 

DEPARTMENT OF HEALTH & HUMAN SERVICES: 
Office of Inspector General: 
Washington, D.C. 20201: 

MAY 18 2005: 

Ms. Cornelia M. Ashby: 
Director, Education, Workforce, and Income Security Issues:
U.S. Government Accountability Office:
Washington, DC 20548: 

Dear Ms. Ashby: 

Enclosed are the Department's comments on the U.S. Government 
Accountability Office's (GAO's) draft report entitled, "CHILD WELFARE - 
Better Data and Evaluations Could Improve Processes and Programs for 
Adopting Children with Special Needs" (GAO-05-292). The comments 
represent the tentative position of the Department and are subject to 
reevaluation when the final version of this report is received. 

The Department provided several technical comments directly to your 
staff. 

The Department appreciates the opportunity to comment on this draft 
report before its publication. 

Sincerely,

Signed by: 

Daniel R. Levinson: 
Acting Inspector General: 

Enclosure: 

The Office of Inspector General (OIG) is transmitting the Department's 
response to this draft report in our capacity as the Department's 
designated focal point and coordinator for U.S. Government 
Accountability Office reports. OIG has not conducted an independent 
assessment of these comments and therefore expresses no opinion on 
them. 

COMMENTS OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES ON THE U.S. 
GOVERNMENT ACCOUNTABILITY OFFICE'S DRAFT REPORT ENTITLED, "CHILD 
WELFARE--BETTER DATA AND EVALUATIONS COULD IMPROVE PROCESSES AND 
PROGRAMS FOR ADOPTING CHILDREN WITH SPECIAL NEEDS" (GAO-O5-292): 

The Department of Health and H Human Services (H INS) appreciates the 
opportunity to comment on the U.S. Government Accountability Office's 
(GAO's) draft report. 

GAO Recommendation: 

We are making three recommendations to further improve the processes 
and programs related to special needs adoption. 

To better understand delays associated with interstate placements, the 
Secretary of the Department of Health and Human Services (TINS) should 
assist States in collecting and reporting data related to the 
interstate placement processes, especially the time needed to complete 
home studies and the sending and receiving State for each child placed 
across State lines. Search assistance could include modifying HHS's 
reporting system (Adoption and Foster Care AnalysIs (and Report System) 
(AFCARS) in conjunction with the agency's ongoing efforts to update and 
revise this system. HHS should analyze the data to assess the extent to 
which home studies cause delays or impede interstate adoptions and to 
identify which States are facilitating timely interstate placements. If 
supported by its findings, HHS should consider proposing legislation to 
amend existing law so that both sending and receiving States could 
claim an interstate adoption for purposes of determining award 
eligibility. 

* To improve HHS's ability to assess the effectiveness of its funded 
projects, the Secretary of HHS should develop guidance to ensure that 
rigorous design elements are incorporated into projects and related 
evaluations. Such guidance could consider the nature and structure of 
the projects and include measures to control costs. 

* To assess the extent to which Title IV-E adoption assistance 
eligibility criteria exclude some economically disadvantaged children 
with special needs, the Secretary of HHS should (I) gather data on 
economic circumstances of special needs children who do not currently 
qualify for IV-E and (2) develop a model to estimate the federal cost 
of expanding eligibility. 

NS Response: 

Given that AUCARS is a decade old, the Administration for Children and 
Families (ACF) is evaluating AFCARS to ascertain what revisions, if 
any, are in order. The recommendations identified in the first and 
third bullets above are being considered as part of that process. This 
comprehensive review of AFCARS began in 2003. Input from the field was 
obtained through notice and comment published in the Federal Register 
and a series of focus groups. Input from comments received as a result 
of the Federal Register notice, focus groups, recommendations from GAO 
and the Office of Inspector General-as well as new legislative 
requirements, have been consolidated into an internal working document. 
The document will be used to set forth recommendations and further 
steps. 

111 HS views the second bullet above as unnecessary. As the report 
notes. ACF has already taken steps to strengthen evaluation 
requirements in discretionary grants. Discretionary funding 
announcements require applicants to describe an evaluation plan as part 
of their program approach, to provide foe-an independent project 
evaluation, and to utilize a specific percentage of grant funds to be 
devoted to evaluation. Review criteria for funding applications direct 
review panels to evaluate the strength of applicants' evaluation plans. 
Once discretionary grants have been funded, the Children's Bureau 
provides technical assistance on evaluations to individual grant 
programs. At the conclusion of the demonstration projects, ACF reviews 
evaluations and, in recent years, has begun producing a synthesis of 
evaluation findings from specific grant clusters or topic areas. In 
addition, ACF continues to take the steps necessary. to improve the 
quality of evaluations through contractor support. 

The report's depiction of evaluations conducted under the Title IV-E; 
waiver demonstrations is somewhat misleading. A key requirement of the 
waiver demonstrations is that they be evaluated by an independent 
evaluator, using a rigorous methodology. Since the inception of these 
projects, ACF has encouraged States to conduct demonstrations employing 
a true experimental design using random assignment of cases to 
experimental and control groups. In fact, every applicant For a waiver 
demonstration receives a technical assistance kit that explains the 
reasons for using random assignment and answers questions about this 
approach. 

Since 1996, 17 States have implemented 25 child welfare waiver 
demonstration project components through ?() Title IV-E waiver 
agreements. Only five of the 17 States that have been approved to 
conduct waiver demonstrations were approved to use quasi-experimental 
methodologies for one or more of their project components. The most 
frequent reason for employing, an alternative design (such as the use 
of comparison counties) has been to assess the impact of flexible 
funding demonstrations in which a capped amount of Title TV-F funds is 
provided to localities to use for a range of purposes. In these 
instances, random assignment of cases is not generally feasible. 

With respect to the demonstrations testing subsidized guardianship, all 
four States in which guardianship is the primary focus of the 
demonstration have used experimental designs. (This includes the State 
custody guardianship component of the New Mexico guardianship waiver 
demonstration mentioned in the report, although the Tribal components 
of that waiver demonstration are being evaluated using quasi- 
experimental methods.) In two States, including the State of Oregon 
referenced in the GAO report, guardianship was a strategy included in 
the context of a demonstration focused primarily on testing the use of 
flexible funding. Therefore, the evaluation of the guardianship 
component used other methods and focused primarily on descriptive data. 

While rigorous evaluation methodologies have been required, ACF 
acknowledges that a number of demonstration projects have yielded 
results of limited utility due to problems in the implementation of 
programmatic elements of the demonstrations and sometimes problems in 
adhering to negotiated evaluation protocols. Ultimately, as noted in 
the report, it is the responsibility of the State to implement the 
project as designed and to oversee the conduct of the evaluation. 
However, ACF does provide technical assistance to both State officials 
and their independent evaluators and is committed to continuing to 
improve the quality of information generated by the projects. 

Moving forward, ACF will continue to work with States to identify 
rigorous, administratively feasible and ethical evaluation strategies. 
For instance, in fiscal year 2004, HHS approved two new waiver projects 
(including a new guardianship demonstration) both of which will employ 
random assignment. ACF is also working with States to better coordinate 
collection of consistent data elements across States conducting similar 
demonstrations to facilitate future cross-site comparisons. Finally, as 
referenced in the report, ACF will be issuing several papers 
synthesizing the findings generated by demonstration projects begun 
during the 1990's and will disseminate these findings broadly. 

[End of section]

Appendix III: GAO Contact and Acknowledgments: 

GAO Contact: 

Cornelia M. Ashby (202) 512-8403: 

Staff Acknowledgments: 

In addition to those named above, Joy Gambino, Joah Iannotta, Kopp 
Michelotti, Vernette Shaw, and Carolyn M. Taylor made key contributions 
to this report. Susan Bernstein, Karen Burke, Michele Fejfar, Catherine 
Hurley, Kevin Jackson, Stuart Kaufman, Jason Kelly, Luann Moy, and Jay 
Smale also provided key technical assistance. 

[End of section]

Related GAO Products: 

Indian Child Welfare Act: Existing Information on Implementation Issues 
Could Be Used to Target Guidance and Assistance to States. GAO-05-290. 
Washington, D.C.: April 4, 2005. 

Foster Youth: HHS Actions Could Improve Coordination of Services and 
Monitoring of States' Independent Living Programs. GAO-05-25. 
Washington, D.C.: November 18, 2004. 

D.C. Child and Family Services Agency: More Focus Needed on Human 
Capital Management Issues for Caseworkers and Foster Parent Recruitment 
and Retention. GAO-04-1017. Washington, D.C.: September 24, 2004. 

Child and Family Services Reviews: States and HHS Face Challenges in 
Assessing and Improving State Performance. GAO-04-781T. Washington, 
D.C.: May 13, 2004. 

Child and Family Services Reviews: Better Use of Data and Improved 
Guidance Could Enhance HHS's Oversight of State Performance. GAO-04- 
333. Washington, D.C.: April 20, 2004. 

D.C. Family Court: Operations and Case Management Have Improved, but 
Critical Issues Remain. GAO-04-685T. Washington, D.C.: April 23, 2004. 

Child Welfare: Improved Federal Oversight Could Assist States in 
Overcoming Key Challenges. GAO-04-418T. Washington, D.C.: January 28, 
2004. 

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 States Are 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: Better Policy Implementation and 
Documentation of Related Activities Would Help Improve Performance. GAO-
03-646. Washington, D.C.: May 27, 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: Kinship Care Quality and Permanency Issues. GAO/HEHS-99- 
32. Washington, D.C.: May 6, 1999. 

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

FOOTNOTES

[1] We did not receive responses from Alabama and Nevada. 

[2] This report uses the word "states" to refer to the 50 states, the 
District of Columbia, and Puerto Rico. 

[3] Data were preliminary fiscal year 2002 estimates as of August 2004. 

[4] Children's Defense Fund. "States' Subsidized Guardianship Laws at a 
Glance." Washington, D.C., October 2004. 

[5] 42 U.S.C. §671(a)(23)(A). 

[6] 42 U.S.C. §622(b)(12). 

[7] To be eligible for AFDC, a child (defined as a dependent child 
under the AFDC statute) has to be a needy child who (1) has been 
deprived of parental support due to the death or absence, or physical 
or mental incapacity, of a parent; or (2) has been deprived of parental 
support due to the unemployment of the parent who is the principal 
earner; and (3) is living with one of a number of specified relatives; 
and (4) is generally under the age of 18. 

[8] To be eligible for SSI benefits, a child must be either blind or 
have other impairments. An individual is eligible if he or she has a 
medically determinable physical or mental impairment, which results in 
marked and severe functional limitations and can be expected to result 
in death, or has lasted or can be expected to last for a continuous 
period of not less than 12 months. In addition, the child or his or her 
family must have limited income and resources. 

[9] Title IV-B of the Social Security Act, consisting of two subparts, 
is the primary source of federal funding for services to help families 
address problems that lead to child abuse and neglect and to prevent 
the unnecessary separation of children from their families. TANF was 
created by the Personal Responsibility and Work Opportunity 
Reconciliation Act of 1996 to provide assistance and work opportunities 
for a limited time to individuals and families. SSBG is authorized 
under Title XX of the Social Security Act as a block grant to states 
for the provision of social services for adults and children. 

[10] See GAO, 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). 

[11] The Urban Institute received survey responses from 50 states, 
including the District of Columbia, but some states were unable to 
provide all of the information requested so spending amounts may 
underestimate true spending. The Urban Institute. The Cost of 
Protecting Vulnerable Children, IV. December 2004. 

[12] See GAO, Child Welfare: Most States Are Developing Statewide 
Information Systems, but the Reliability of Child Welfare Data Could Be 
Improved, GAO-03-809. (Washington, D.C.: July 31, 2003). 

[13] American Public Human Services Association. "Understanding Delays 
in the Interstate Home Study Process." September 2002. 

[14] Geen, Rob, Karin Malm, and Jeff Katz, "A Study to Inform the 
Recruitment and Retention of General Applicant Adoptive Parents." 
Adoption Quarterly, 7 (4). 

[15] Lutz, Lorrie, "Achieving Permanency for Children in the Child 
Welfare System: Pioneering Possibilities Amidst Daunting Challenges." 
National Resource Center for Foster Care and Permanency Planning. New 
York. November 2003. 

[16] U.S. Department of Health and Human Services. "General Findings 
from the Federal Child and Family Services Review." No date. 

[17] American Public Human Services Association. Understanding Delays 
in the Interstate Home Study Process. September 2002 

[18] November was proclaimed National Adoption Month in 1990. Its 
purpose is to promote adoption, support adoptive families, and increase 
the awareness of children in foster care nationwide who need permanent 
families. 

[19] Dissolutions occur when a child is returned to foster care after 
the adoption has been finalized. 

[20] HHS's other resource centers also provide some technical 
assistance to states regarding adoption matters, but they primarily 
focus on other topics, such as organizational improvement and data and 
technology. 

[21] Experimental evaluations involve random assignment of participants 
to one group or the other in order to increase the likelihood that the 
two groups are roughly equivalent on all characteristics that could 
affect outcomes. In a quasi-experimental design, a comparison group is 
composed of individuals who share characteristics with program 
participants but who have not been randomly assigned. With this design, 
statistical controls are needed to isolate the program from other 
factors that could influence outcomes. 

[22] Under the AFDC program, states set eligibility criteria within 
federal guidelines and the federal government and states shared the 
costs of providing benefits to eligible families. Under TANF, the 
federal government provides states a fixed amount of funds each year-- 
through a block grant--and the states have much more flexibility in 
determining eligibility criteria and services provided. With this 
increased flexibility and in keeping with the TANF program goals of 
promoting work, many states have increased the amount of earnings a 
parent may make while still receiving cash benefits. However, states 
also have the flexibility to impose a less generous standard of need 
for TANF. 

[23] Other reasons were complications associated with obtaining 
required judicial determinations, lapsed foster family licenses, and 
limited resources to adequately monitor and relicense families whose 
licenses had expired. 

[24] Cornerstone Consulting Group, Inc. A Carrot among the Sticks: The 
Adoption Incentive Bonus. 2001. 

[25] We did not receive responses from Alabama and Nevada. 

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