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Testimony:

Before the Committee on Government Reform, House of Representatives:

United States General Accounting Office:

GAO:

For Release on Delivery Expected at 10:00 a.m.EDT:

Friday, May 16, 2003:

D.C. child and Family Services:

Key Issues Affecting the Management of its Foster Care Cases:

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

GAO-03-758T:

GAO Highlights:

Highlights of GAO-03-758T, testimony before the Committee on 
Government Reform, House of Representatives

Why GAO Did This Study:

The District of Columbia (D.C.) Child and Family Services Agency 
(CFSA) is responsible for protecting children at risk of abuse and 
neglect and ensuring that critical services are provided for them and 
their families. GAO was asked to discuss the extent to which CFSA has 
(1) met the requirements of the Adoption and Safe Families Act (ASFA) 
of 1997 and other selected performance criteria, (2) adopted and 
implemented child protection and foster care placement policies, and 
(3) enhanced its working relationship with the D.C. Family Court.

To address these questions, GAO analyzed data in the District’s 
automated child welfare information system, known as FACES; reviewed 
laws, regulations, and reports; examined case files; and interviewed
officials.   

What GAO Found:

CFSA’s performance relative to three sets of measures—nine ASFA 
requirements, eight selected performance criteria, and six of the 
agency’s foster care policies—has been mixed. The agency took actions 
to implement six of the nine ASFA requirements related to the safety 
and well-being of foster children, and met or exceeded four of the 
eight selected foster care performance criteria, but its plans do not 
address all unmet requirements and criteria. CSFA has established many 
foster care policies, but caseworkers did not consistently implement 
the six GAO examined. In addition, FACES lacked data on four of these 
six policies for at least 70 percent of its active foster care cases. 
The following table summarizes five selected foster care policies for 
which data were available and the percentage of cases for which the 
data indicated the policy was implemented.

Implementation of Selected CFSA Foster Care Policies, as Documented in 
FACES:

[See PDF for image]

[End of table]

CFSA has enhanced its working relationship with the D.C. Family Court, 
but several factors hindered this relationship. For example, CFSA’s 
top management and Family Court judges talk frequently about foster 
care case issues.  However, differing opinions among CFSA caseworkers 
and judges about their responsibilities have hindered the 
relationships.  CFSA officials and Family Court judges have been 
working together to address these hindrances.     

www.gao.gov/cgi-bin/getrpt?GAO-03-758T.

To view the full testimony, click on the link above.  For more 
information, contact Cornelia M. Ashby, (202) 512-8403, 
ashbyc@gao.gov.

[End of section]

Mr. Chairman and Members of the Committee:

I am pleased to be here today to discuss preliminary findings from our 
study of the District of Columbia's Child and Family Services Agency 
(CFSA) you requested. My testimony will focus on the extent to which 
CFSA has (1) taken actions to address the requirements of the Adoption 
and Safe Families Act (ASFA) of 1997 and met selected performance 
criteria, (2) adopted and implemented child protection and foster care 
placement policies that are comparable to those generally accepted in 
the child welfare community, and (3) enhanced its working relationship 
with the D.C. Family Court.

My comments today are based primarily on our analysis of the 
information in the District's automated child welfare information 
system, known as FACES, which CFSA is to use to manage child welfare 
cases and report child abuse and neglect, foster care, and adoption 
information to the U.S. Department of Health and Human Services (HHS). 
We selected three sets of measures to assess CFSA's performance. We 
assessed CFSA's progress in implementing nine ASFA requirements that 
were related to the safety and well-being of children in foster care, 
the extent to which CFSA met or exceeded eight selected performance 
criteria established during its probationary period, and the extent to 
which caseworkers implemented six foster care policies related to their 
day-to-day responsibilities. We included HHS's evaluation of how CFSA 
implemented ASFA requirements in our assessment of the agency's 
performance. We analyzed foster care cases in FACES that were at least 
6 months old as of November 2002 and verified the accuracy of its data. 
However, CFSA had not entered into FACES detailed information on the 
data elements we needed for our analysis with respect to about two-
thirds of the District's active foster care cases--mostly cases that 
originated prior to FACES going on-line in October 1999. Consequently, 
we also reviewed paper case files for children with different beginning 
dates in the foster care system to supplement FACES information for 
some cases. We also interviewed District officials; CFSA managers, 
judges, and child welfare experts; and we analyzed federal and District 
laws and regulations, related court documents, and child welfare 
policies. Our final report will be issued later this month. We 
conducted our work between September 2002 and May 2003 in accordance 
with generally accepted government auditing standards.

In summary, CFSA has taken actions to implement various ASFA 
requirements and met several selected foster care performance 
criteria,[Footnote 1] established child protection and foster care 
placement policies and procedures, and enhanced its working 
relationship with the D.C. Family Court; however, much remains to be 
done. CFSA took actions to implement two-thirds of the ASFA 
requirements and met or exceeded half of the selected foster care 
performance criteria we used and developed written plans to address two 
of the three ASFA requirements not fully met and three of the four 
unmet foster care performance criteria. In addition, CFSA has adopted 
child protection and foster care placement policies and procedures that 
are comparable to most, but not all, of those recommended by 
organizations that develop standards applicable to child welfare 
programs. However, CFSA has not adopted some key policies and 
procedures for ensuring the safety and permanent placement of children, 
and caseworkers have not consistently implemented or documented some of 
the policies and procedures that have been adopted. While timeframes 
for implementing certain policies, such as initiating investigations 
and completing safety assessments have improved since 2000, caseworkers 
still take considerably longer than the prescribed time limits to 
complete these critical tasks, thereby increasing the potential risks 
posed to the safety and well-being of the District's children. In 
addition, CFSA has developed an automated child welfare data system to 
help manage its caseload, among other initiatives to help improve its 
performance. However, detailed information for the data elements 
related to four of the six policies reviewed had not been entered into 
the system for at least 70 percent of its active foster care cases. 
Further, CFSA has improved its working relationship with the Family 
Court through improved communication and support from top CFSA managers 
and Family Court judges; however, both CFSA and the Family Court still 
need to overcome barriers that continue to hinder this relationship.

Background:

While CFSA is responsible for protecting children at risk of abuse and 
neglect, many children in CFSA's care languished for extended periods 
of time due to managerial shortcomings and long-standing organizational 
divisiveness in the District of Columbia. As a result of these 
deficiencies, the U.S. District Court for the District of Columbia 
issued a remedial order in 1991 to improve the performance of the 
agency. Under a modified final order established by the court in 1993, 
CFSA was directed to comply with many requirements. In 1995, lacking 
sufficient evidence of program improvement, the agency was removed from 
the District's Department of Human Services and placed in 
receivership.[Footnote 2] Among its efforts to improve agency 
performance, CFSA established an automated system, FACES, to manage its 
caseload. The District Court issued a consent order in 2000 
establishing a process by which the agency's receivership could be 
terminated. The order also established a probationary period, which 
would commence upon termination of the receivership, and identified 
performance standards CFSA had to meet in order to end the probationary 
period. The court-appointed monitor, the Center for the Study of Social 
Policy, was to assess CFSA's performance and had the discretion to 
modify the performance standards. In June 2001, the court removed CFSA 
from receivership. In September 2002, the court-appointed monitor 
reported that a 7-year old child was abused by two children in a group 
home licensed by CFSA. This incident, according to the monitor, 
together with the history of inadequate care and attention given this 
child by CFSA, indicated that its operations and policies, especially 
those regarding foster care cases, may still need improvement.

CFSA operates in a complex child welfare system.[Footnote 3] Several 
federal laws, local laws, and regulations established goals and 
processes under which CFSA must operate. ASFA, with one of its goals to 
place children in permanent homes in a timelier manner, placed new 
responsibilities on all child welfare agencies nationwide. ASFA 
introduced new time periods for moving children toward permanent, 
stable care arrangements and established penalties for noncompliance. 
For example, ASFA requires child welfare agencies to hold a permanency 
planning hearing--during which the court determines the future plans 
for a child, such as whether the state should continue to pursue 
reunification with the child's family or some other permanency goal--
not later than 12 months after the child enters foster care. The 
District of Columbia Family Court Act of 2001 (P.L. 107-114) 
established the District's Family Court and placed several requirements 
on the District's Mayor and various District agencies, including CFSA 
and the Office of Corporation Counsel (OCC).[Footnote 4] The District 
of Columbia Family Court Act of 2001 requires the Mayor, in 
consultation with the Chief Judge of the Superior Court, to ensure that 
CFSA and other D.C. government offices coordinate the provision of 
social services and other related services to individuals served by the 
Family Court.

CFSA relies on services provided by other District government agencies. 
For example, both the Fire Department and the Health Department inspect 
facilities where children are placed, and D.C. Public Schools prepare 
individual education plans for some children in care. CFSA also works 
with agencies in Maryland, Virginia, and other states to arrange for 
placements of District children and also works with private agencies to 
place children in foster and adoptive homes. In addition, CFSA is 
responsible for licensing and monitoring organizations with which it 
contracts, including group homes that house foster care children.

The management of foster care cases involves several critical 
responsibilities required by CFSA policy. Typically, these cases begin 
with an allegation of abuse or neglect reported to CFSA's child abuse 
hot line. CFSA staff are required to investigate the allegations 
through direct contact with the reported victim. If required, the child 
may be removed from his or her home, necessitating various court 
proceedings handled by the District's Family Court. CFSA caseworkers 
are responsible for managing foster care cases by developing case 
plans; visiting the children; participating in administrative review 
hearings, involving CFSA officials, children, parents, attorneys, and 
other officials; attending court hearings, and working with other 
District government agencies. CFSA case workers are also responsible 
for documenting the steps taken and decisions made related to a child's 
safety, well being, and proper foster care placement, as well as those 
related to developing the most appropriate goal for permanency. 
Depending on their circumstances, children leave foster care and 
achieve permanency through reunification with their birth or legal 
parents, adoption, legal guardianship with a relative, or 
independence.[Footnote 5] As of September 2002, a child's length of 
stay in the District's foster care program averaged 2.8 years.

HHS is responsible for setting standards and monitoring the nation's 
child welfare programs. In fiscal year 2001, about $6.2 billion in 
federal funds were appropriated to HHS for foster care and related 
child welfare services. HHS's monitoring efforts include periodic 
reviews of the operations, known as Child and Family Services 
Reviews,[Footnote 6] and of the automated systems, known as Statewide 
Automated Child Welfare Information System (SACWIS) Reviews, in the 
states and the District of Columbia. HHS last reviewed CFSA's child 
welfare information system in 2000 and its overall program in 2001.

CFSA Undertook Actions to Implement Most ASFA Requirements Reviewed and 
Met Half of the Selected Performance Criteria for Child Safety and 
Well-Being:

CFSA undertook actions to implement six of the nine ASFA requirements 
we reviewed and met or exceeded four of the eight performance criteria 
we included in our study, but CFSA's plans to improve its performance 
do not include all unmet ASFA requirements or selected performance 
criteria. Table 1 summarizes CFSA's progress in implementing the nine 
ASFA requirements that we reviewed.

Table 1: CFSA's Progress in Implementing Nine ASFA Requirements:

ASFA requirements CFSA has implemented: 1. Include the safety of the 
child in state case planning and in a case review system; ASFA 
requirements CFSA has not fully implemented: 
1. Initiate or join proceedings to terminate parental rights for 
certain children in foster care--such as those who have been in foster 
care for 15 of the most recent 22 months of care.

ASFA requirements CFSA has implemented: 2. Comply with requirements for 
criminal background clearances and have procedures for criminal 
record checks; ASFA requirements CFSA has not fully implemented: 
2. Provide participants a notice of reviews and hearings and an 
opportunity to be heard.

ASFA requirements CFSA has implemented: 3. Develop a case plan 
documenting steps taken to provide permanent living arrangements for a 
child; ASFA requirements CFSA has not fully implemented: 3. Conduct 
mandatory permanency hearings every 12 months for a child in foster 
care.

ASFA requirements CFSA has implemented: 4. Develop plans for the 
effective use of cross-jurisdictional resources to facilitate timely 
adoptive or permanent  placements for waiting children; ASFA 
requirements CFSA has not fully implemented: [Empty].

ASFA requirements CFSA has implemented: 5. Provide for health insurance 
coverage for children with special needs in state plans for foster 
care and adoption assistance; ASFA requirements CFSA has not fully 
implemented: [Empty].

ASFA requirements CFSA has implemented: 6. Incorporate standards to 
ensure quality services for children in foster care in 
state plans; ASFA requirements CFSA has not fully implemented: [Empty].

Source: ASFA and HHS's CSFR and GAO analysis.

Note: Our assessment of CFSA's progress in implementing three 
requirements--include the safety of the child in case planning, develop 
a case plan documenting steps taken to provide permanent living 
arrangements for a child, and provide for health insurance coverage for 
children with special needs--is based on data and information provided 
to us. Our assessment of CFSA's progress in implementing the remaining 
ASFA requirements is based on HHS's review of CFSA.

[End of table]

The HHS review of CFSA found that the agency did not meet three 
requirements. CFSA did not consistently petition the Family Court to 
terminate parental rights when returning the child to his or her family 
had been deemed inappropriate and the child had been in foster care for 
15 of the last 22 months. Based on its review of 50 foster care cases, 
HHS reported that 54 percent of the children who were in care longer 
than 15 months did not have hearings initiated for the termination of 
parental rights, and reasons for not initiating such hearings were not 
documented in the case plan or court order. HHS also found that not all 
cases had hearings to review a child's permanency goal within the 
timeframe prescribed by ASFA. In addition, foster parents, relative 
caretakers, and pre-adoptive parents were not consistently notified of 
reviews or hearings held on behalf of the foster child. HHS found that 
there was a lack of communication in notifying caregivers and 
prospective caregivers of the time and place of a hearing, if such 
notification took place at all.

We also analyzed automated data from FACES related to eight foster care 
performance criteria and found that CFSA met or exceeded four of them. 
For example, one of the criteria requires 60 percent of children in 
foster care to be placed with one or more of their siblings; we found 
that as of November 30, 2002, 63 percent of children were placed with 
one or more siblings. The areas in which CFSA's performance fell short 
included criteria related to (1) caseworker visitation with children in 
foster care, (2) placement of children in foster homes with valid 
licenses, (3) progress toward permanency for children in foster care, 
and (4) parental visits with children in foster care who had a goal of 
returning home. For example, none of the 144 children placed in foster 
care during the 2-month period prior to November 30, 2002, received 
required weekly visits by a CFSA caseworker. Table 2 summarizes our 
analysis of the selected foster care performance criteria.

Table 2: Analysis of Selected Foster Care Performance Criteria:

Foster care performance criteria: 1. Current case plans for foster care
 cases; Forty-five percent of foster care cases have current case 
plans; Analysis: Met; Analysis: As of September 30, 2002, 46 percent 
of foster care cases had current case plans.

Foster care performance criteria: 2. Visitation between children in 
foster care and
 their parents; Thirty-five percent of cases in which children have a 
permanency goal of return home have parental visits at least every 2 
weeks; Analysis: Not met; Analysis: As of November 30, 2002, 1 percent 
of children with a return home goal had parental visits at least every 
2 weeks.

Foster care performance criteria: 3. Social worker visitation with 
children in foster
 care; Twenty-five percent of children in foster care have weekly 
visits with social workers in their first 8 weeks of care; 35 percent 
of all children in foster care have at least monthly visits with a 
social worker; Analysis: Not met; Analysis: As of November 30, 2002, 
no children had weekly visits and at least 98 percent of children did 
not have monthly visits with a caseworker.[A].

Foster care performance criteria: 4. Appropriate legal status for 
children in foster care; No child in emergency care for more than 90 
days; Analysis: Met; Analysis: As of November 30, 2002, no children in 
emergency care more than 90 days.

Foster care performance criteria: 5. Current and valid foster home 
licenses; Seventy-five percent of children are placed in foster home 
with valid licenses; Analysis: Not met; Analysis: As of November 30, 
2002, 47 percent of children were in foster homes with valid licenses.

Foster care performance criteria: 6. Progress toward permanency; No 
more than 10 percent of children in foster care have a permanency goal 
of return home for more than 18 months; Analysis: Not met; Analysis: 
As of November 30, 2002, 30 percent of children had permanency goal of 
return home more than 18 months.

Foster care performance criteria: 7. Foster care placement with 
siblings; Sixty percent of children in foster care are placed with one 
or more of their siblings; Analysis: Met; Analysis: As of November 30, 
2002, 63 percent of children were placed with one or more siblings.

Foster care performance criteria: 8. Placement stability; No more than 
25 percent of children in foster care as of May 31, 2002, have had 
three or more placements; Analysis: Met; Analysis: As of November 30, 
2002, 21 percent of children had three or more placements.

Source: GAO analysis.

[A] For 2 percent of the children, caseworker visits equaled or 
exceeded the number of months in placement. However, CFSA's data for 
the performance measure to this criterion do not allow for the 
determination of whether caseworkers visited children each month they 
were in foster care.

[End of table]

CFSA's Program Improvement Plan, a plan required by HHS to address 
those areas determined not met by HHS, identifies how it will address 
two of the unmet ASFA requirements--(1) to initiate or join proceedings 
to terminate parental rights (TPR) of certain children in foster care 
and (2) to ensure that children in foster care have a permanency 
hearing every 12 months. For example, CFSA has outlined steps to 
improve its filings of TPR petitions with the Family Court. To help 
facilitate this process, CFSA hired additional attorneys to expedite 
the TPR proceedings. The new attorneys have been trained in ASFA 
requirements and in the process for referring these cases to the Family 
Court. CFSA is also developing a methodology for identifying and 
prioritizing cases requiring TPR petitions. While CFSA's updated 
Program Improvement Plan states its intent to provide notification of 
hearings to all participants, this plan does not make it clear whether 
all applicable reviews and hearings will be included.

Another CFSA plan--the Interim Implementation Plan--includes measures 
that were developed to show the agency's plans for meeting the 
requirements of the modified final order issued by the U.S. District 
Court for the District of Columbia.[Footnote 7] This plan includes 
actions to address three of the four performance criteria CFSA did not 
meet--visits between children in foster care and their parents, social 
worker visitation with children in foster care, and placement of 
children in foster homes with current and valid licenses. The plan 
states that, for new contracts, CFSA will require its contactors to 
identify community sites for parental visits to help facilitate visits 
between children in foster care and their parents. The plan also 
indicates that CFSA will concentrate on the recruitment and retention 
of caseworkers. According to CFSA officials, caseworkers would have 
more time for quality casework, including visitation with children, 
parents, and caregivers, once they hire more caseworkers. Additionally, 
the plan established a goal to have 398 unlicensed foster homes in 
Maryland licensed by December 31, 2002. However, CFSA does not have 
written plans that address the performance criterion to reduce the 
number of children in foster care who, for 18 months or more, have had 
a permanency goal to return home. Without complete plans for improving 
performance for all measures, CFSA's ability to comply with the ASFA 
requirements and meet the selected performance criteria may be 
difficult. Furthermore, unless these requirements and criteria are met, 
the time a child spends in foster care may be prolonged, or the best 
decisions regarding a child's future well-being may not be reached.

CFSA officials cited several factors that hindered their ability to 
fully meet the ASFA requirements and the selected performance criteria, 
including court-imposed requirements, staffing shortages, and high 
caseloads. For example, program managers and supervisors said that the 
new court-imposed mediation process intended to address family issues 
without formal court hearings places considerable demands on 
caseworkers' time. The time spent in court for mediation proceedings, 
which can be as much as 1 day, reduces the time available for 
caseworkers to respond to other case management duties, such as 
visiting with children in foster care. Furthermore, managers and 
supervisors reported that staffing shortages have contributed to delays 
in performing critical case management activities, such as identifying 
cases for which attorneys need to file TPR petitions. However, staffing 
shortages are not a unique problem to CFSA. We recently reported that 
caseworkers in other states said that staffing shortages and high 
caseloads had detrimental effects on their abilities to make well-
supported and timely decisions regarding children's safety. [Footnote 
8] We also reported that as a result of these shortages, caseworkers 
have less time to establish relationships with children and their 
families, conduct frequent and meaningful home visits, and make 
thoughtful and well-supported decisions regarding safe and stable 
permanent placements.

CFSA Has Established Many Foster Care Policies but Lacks Others, and 
the Extent of Implementation and Documentation 
Varies:

CSFA has established many foster care policies, but caseworkers did not 
consistently implement the six we selected. These policies covered the 
range of activities involved in a foster care case, but did not 
duplicate those examined in our review of the AFSA requirements or the 
selected foster care performance criteria. In addition, CFSA's 
automated system lacked data on policy implementation for at least 70 
percent of its active foster care cases. Without information on all 
cases, caseworkers do not have a readily available summary of the 
child's history needed to make decisions about a child's care, and 
managers do not have information needed to assess and improve program 
operations.

CSFA Has Established Many Foster Care Policies, but Caseworkers Did Not 
Consistently Implement Those We Selected:

While we previously reported in 2000[Footnote 9] that CFSA lacked some 
important child protection and foster care placement policies, CFSA has 
now established many such policies and most are comparable to those 
recommended by organizations that develop standards applicable to child 
welfare programs. For example, CFSA has policies for investigating 
allegations of child abuse, developing case plans, and establishing 
permanency goals for foster children. In addition, one policy is more 
rigorous than suggested standards. Specifically, CFSA's policy requires 
an initial face-to-face meeting with children within 24 hours of 
reported abuse or neglect, while the suggested standard is 24 to 48 
hours or longer, depending on the level of risk to the child's safety 
and well-being. However, CFSA does not have some recommended policies, 
namely those addressing (1) written time frames for arranging needed 
services for children and families (e.g., tutoring for children and 
drug treatment for family members); (2) limits on the number of cases 
assigned to a caseworker, based on case complexity and worker 
experience; and (3) procedures for providing advance notice to each 
person involved in a case about the benefits and risks of services 
planned for a child and alternatives to those services. CFSA managers 
said that the agency had not established these policies because agency 
executives gave priority to complying with court-ordered requirements.

CFSA did not consistently implement the policies we examined. We 
selected six policies that covered the range of activities involved in 
a foster care case, but did not duplicate those examined in our review 
of the AFSA requirements or the selected foster care performance 
criteria. CFSA could not provide automated data regarding the 
implementation of one policy requiring administrative review hearings 
every 6 months.[Footnote 10] As for the remaining five policies, data 
in FACES indicate that caseworkers' implementation of them varied 
considerably. Table 3 summarizes these five policies and the percentage 
of cases for which the data indicated the policy was implemented.

Table 3: Implementation of Selected CFSA Foster Care Policies as 
Documented in FACES:

Policy: Initiate face-to-face investigation of alleged child abuse or 
neglect within 24 hours of receiving an allegation on CFSA's child 
abuse hotline; Percent of foster care cases for which the policy was 
implemented[A, B]: 26.

Policy: Complete a safety assessment within 24 hours of face-to-face 
contact with the child; Percent of foster care cases for which the 
policy was implemented[A, B]: 13.

Policy: Complete a risk assessment within 30 days of receiving an 
allegation on the hotline; Percent of foster care cases for which the 
policy was implemented[A, B]: 73.

Policy: Complete an initial case plan within 30 days of a child's entry 
into foster care; Percent of foster care cases for which the policy 
was implemented[A, B]: 9.

Policy: Arrange needed services for foster care children or their 
families; Percent of foster care cases for which the policy was 
implemented[A, B]: 83.

Source: FACES data and GAO analysis.

[A] With the exception of the policy to arrange needed services, the 
analysis is based on 943 foster care cases that were at least 6 months 
old, as of November 30, 2002. These cases were initiated after FACES 
came on-line in October 1999. The analysis of the policy to arrange for 
needed services is based on 1,837 foster care cases and includes cases 
that pre-dated FACES but for which services were provided after FACES 
came on-line. Data show the percentage of cases for which caseworkers 
arranged at least one service.

[B] CFSA counted cases that had missing data as instances of caseworker 
noncompliance with the applicable policy.

[End of table]

The policies related to initiating face-to-face investigations and 
completing safety assessments are particularly critical to ensuring 
children's safety. CFSA's policy requires caseworkers to initiate an 
investigation of alleged child maltreatment within 24 hours of the call 
to CFSA's hot line through face-to-face contact with the child. Also, 
caseworkers are required to complete a safety assessment within 24 
hours of the face-to-face contact with the child. While it took CFSA 
caseworkers considerably longer than the time specified in the policy 
to take these actions in some cases, CFSA's performance has improved. 
CFSA has reduced the average time it takes to make contacts and 
complete the assessments. In 2000, it took caseworkers an average of 18 
days to initiate a face-to-face investigation, whereas in 2002 the 
average was 2 days. Similarly, caseworkers took an average of 30 days 
to complete safety assessments in 2000, whereas the average time 
declined to 6 days in 2002. Although there were cases that took much 
longer than the 24-hour limits, there were fewer in 2002 than in 2000. 
CFSA caseworkers took 5 or more days to initiate a face-to-face 
investigation for 61 cases in 2000, and for 16 cases in 2002. Table 4 
summarizes the number of cases for which caseworkers took 5 or more 
days to initiate investigations and complete safety assessments from 
2000 through 2002.

Table 4: Number of Cases Taking 5 or More Days to Implement Policy 
(2000-2002):

Policy: Initiate face-to-face investigation of alleged child abuse or 
neglect within 24 hours of receiving an allegation; Fiscal Year: 2000: 
61; Fiscal Year: 2001: 66; Fiscal Year: 2002: 16; Fiscal Year: Total: 
143.

Policy: Complete a safety assessment within 24 hours of face-to-face 
contact with child; Fiscal Year: 2000: 101; Fiscal Year: 2001: 122; 
Fiscal Year: 2002: 50; Fiscal Year: Total: 273.

Source: FACES data and GAO analysis.

[End of table]:

We also reviewed case files and examined related data from FACES for 30 
foster care cases to assess compliance with policies requiring timely 
case planning, periodic administrative review hearings, and 
arrangements for needed services. The case files we reviewed were often 
voluminous, inconsistently organized, and contained information that 
was not always traceable to data entered in FACES. Our review found 
that case plans were not routinely completed within 30 days, as 
required by CFSA policy. The FACES data provided subsequent to our case 
file review supported this assessment.

We also found that for almost half the cases we examined administrative 
review hearings, which are held to ensure that key stakeholders are 
involved in decisions about a child's permanent placement, were 
rescheduled, resulting in their being held less frequently than 
required by CFSA policy. CFSA policy requires that these hearings be 
held every 6 months, and FACES automatically schedules them to occur 6 
months after the most recent hearing. However, CFSA officials are 
unable to track how frequently they are rescheduled or the length of 
time between hearings because the system overrides the dates of prior 
hearings. Long delays between administrative review hearings could mean 
delays in getting children into permanent placement. As for arranging 
needed services, we could not determine from case files or FACES 
whether services recommended by caseworkers were approved by 
supervisors or if all needed services were provided. The FACES data 
indicate that at least one service was provided for 83 percent of the 
cases, but do not include a complete record of all services caseworkers 
determine to be needed, nor do they indicate whether the services were 
provided on a timely basis.

Officials said that several factors affected the implementation of some 
of the policies we reviewed. Caseworkers' supervisors and managers 
explained that, generally, the policies were not always implemented 
because of limited staff and competing demands, and the policies were 
not documented because some caseworkers did not find FACES to be user 
friendly. Agency officials explained that, in part, data on the 
implementation of the initial investigations and safety assessment 
reflected a change in who was responsible for the initial investigation 
of child abuse cases. Until October 2001, the District's Metropolitan 
Police Department had this responsibility, and data on initial 
investigations were not entered into FACES. CFSA now has responsibility 
for both child abuse and neglect investigations. Further, program 
managers and supervisors said that several factors contributed to the 
time frames required to initiate face-to-face investigations, including 
difficulty in finding the child's correct home address, contacting the 
child if the family tries to hide the child from investigators, and 
even obtaining vehicles to get to the location. Regarding 
administrative review hearings, the records indicate that they were 
rescheduled for a variety of reasons, such as the caseworker needing to 
appear at a hearing for another case or the attorney not being able to 
attend the hearing. Managers also said that the data on service 
delivery was not always entered into FACES because caseworkers 
sometimes arranged services by telephone and did not enter the data 
into FACES.

CFSA officials said they recently made changes to help improve the 
implementation of some of the policies we reviewed. They said CFSA has 
focused on reducing the number of cases for which a risk assessment had 
not been completed and has reduced the number of these investigations 
open more than 30 days from 807 in May 2001 to 263 in May 2002. CFSA 
officials also said that they anticipate a reduction in the number of 
administrative review hearings that are rescheduled. They said the 
responsibility for notifying administrative review hearing 
participants about a scheduled hearing was transferred from caseworkers 
to staff in CFSA's administrative review unit, and they intend to 
provide notification well in advance of the hearings. Additionally, 
another official said that CFSA has begun testing a process to ensure 
that all needed services are provided within 45 days.

Such improvements are needed because without consistently implementing 
policies for timely investigations and safety and risk assessments, a 
child may be subject to continued abuse and neglect. Delays in case 
plan preparation and in holding administrative review hearings delay 
efforts to place children in permanent homes or reunite them with their 
families. Further, without knowing whether children or families 
received needed services, CFSA cannot determine whether steps have been 
taken to resolve problems or improve conditions for children in its 
care, which also delays moving children toward their permanency goals.

CFSA Has Established Policies and Goals for Group Homes:

In addition to its policies for managing cases, CFSA has policies for 
licensing and monitoring group homes, plans for training staff in group 
homes, and a goal to reduce the number of young children in group 
homes. CFSA's policies for group homes are based primarily on District 
regulations that went into effect July 1, 2002. For example, the 
regulations prohibited CFSA from placing children in an unlicensed 
group home as of January 1, 2003. According to CFSA officials, as of 
March 2003, all CFSA group homes were licensed, except one, and CFSA 
was in the process of removing children from that home. CFSA plans to 
monitor group homes by assessing their compliance with contractual 
provisions and licensing requirements. CFSA also plans to provide 
training to group home staff to make it clear that, as District 
regulations require, any staff member who observes or receives 
information indicating that a child in the group home has been abused 
must report it. Further, CFSA has a goal to reduce the number of 
children under 13 who are placed in group homes. According to agency 
officials, CFSA has reduced the number of children under 13 in group 
homes from 128 in August 2002 to 70 as of February 2003 and has plans 
to reduce that number even further by requiring providers of group home 
care to link with agencies that seek foster care and adoptive families.

CFSA's Automated System Lacked Data on Many Foster Care Cases:

In our efforts to assess CFSA's implementation of the six selected 
foster care policies related to the safety and well-being of children 
as shown in table 2, we determined that FACES lacked data on many 
active foster care cases. In December 2000, we reported that FACES 
lacked complete case information and caseworkers had not fully used it 
in conducting their daily casework.[Footnote 11] During our most recent 
review, we determined that FACES lacked data on four of six foster care 
policies for at least 70 percent of its active foster care cases. Of 
the 2,510 foster care cases at least 6 months old as of November 30, 
2002, data were not available for 1,763 of them. CFSA officials 
explained that all of these cases predated FACES, and the previous 
system was used primarily to capture information for accounting and 
payroll purposes, not for case management. Top agency managers said 
that CFSA does not plan to make it an agency priority to transfer 
information kept in paper files for cases that predated FACES into the 
system. Additionally, FACES reports show that data were not available 
on many of the cases that entered the foster care system after FACES 
came on line. For example, complete data on the initiation of 
investigations and completion of safety assessments were not available 
for about half of the 943 cases that entered the foster care system 
after FACES came on line. CFSA officials explained that they intend to 
focus on improving a few data elements at a time for current and future 
events.

Having systems that provide complete and accurate data is an important 
aspect of effective child welfare programs. HHS requires all states and 
the District of Columbia to have an automated child welfare information 
system. These systems, known as SACWIS, must be able to record data 
related to key child welfare functions, such as intake management, case 
management, and resource management. However, in its review of FACES, 
HHS found CFSA's system was not in full compliance with several 
requirements, including the need to prepare and document service/case 
plans and to conduct and record the results of case reviews.[Footnote 
12]

In addition to the standards and requirements established by HHS for 
all child welfare systems, the modified final order requirements 
established by the U.S. District Court for the District of Columbia 
direct CFSA to produce management data and many reports on their 
operations. For example, the modified final order requires that CFSA be 
able to produce a variety of data such as, the number of children (1) 
for whom a case plan was not developed within 30 days, (2) with a 
permanency goal of returning home for 12 months or more, and (3) placed 
in a foster home or facility who have been visited at specified 
intervals.

Complete, accurate, and timely case management data enables caseworkers 
to quickly learn about new cases, supervisors to know the extent that 
caseworkers are completing their tasks, and managers to know whether 
any aspects of the agency's operations are in need of improvement. 
Child welfare automated systems need to have complete case data to help 
ensure effective management of child welfare programs. A child welfare 
expert said that there is a great need to transfer information from old 
case records to new automated systems. For example, the expert said 
that records of older teens have been lost, and, with them, valuable 
information such as the identity of the child's father. Without data in 
FACES, CFSA's caseworkers will have to look for paper records in the 
case files, some of which are voluminous. This file review effort is 
much more time-consuming than reviewing an automated report and as a 
result, when cases are transferred to new caseworkers, it requires more 
time for them to become familiar with cases.

CFSA Has Enhanced Its Working Relationship with the D.C. Family Court 
by Working Collaboratively, but Hindrances Remain:

CFSA has enhanced its working relationship with the D.C. Family Court 
by working more collaboratively, but several factors have hindered 
these relationships. By participating in committees and training 
sessions, collocating OCC attorneys with caseworkers, and communicating 
frequently, CFSA has enhanced its working relationship with the Family 
Court. CFSA participates in various planning committees with the Family 
Court, such as the Implementation Planning Committee, a committee to 
help implement the District of Columbia Family Court Act of 2001. CFSA 
caseworkers have participated in training sessions that include OCC 
attorneys and Family Court judges. These sessions provide all parties 
with information about case management responsibilities and various 
court proceedings, with the intent of improving and enhancing the 
mutual understanding about key issues. Additionally, CFSA assigned two 
caseworkers who assist in arranging court-ordered services for children 
and their families at the Family Court. Also, since 2002, OCC attorneys 
have been located at CFSA and work closely with caseworkers. This 
arrangement has improved the working relationship between CFSA and the 
Family Court because the caseworkers and the attorneys are better 
prepared for court appearances. Furthermore, senior managers at CFSA 
and the Family Court communicated frequently about day-to-day 
operations as well as long-range plans involving foster care case 
management and related court priorities, and on several occasions 
expressed their commitment to improving working relationships.

However, CFSA officials and Family Court judges also noted several 
hindrances that constrain their working relationship. These hindrances 
include the need for caseworkers to balance court appearances with 
other case management duties, an insufficient number of caseworkers, 
caseworkers who are unfamiliar with cases that have been transferred to 
them, and differing opinions about the responsibilities of CFSA 
caseworkers and judges. For example, although CFSA caseworkers are 
responsible for identifying and arranging services needed for children 
and their families, some Family Court judges overruled service 
recommendations made by caseworkers. Family Court judges told us that 
they sometimes made decisions about services for children because 
caseworkers did not always recommend appropriate ones or provide the 
court with timely and complete information on the facts and 
circumstances of the case. Caseworkers and judges agreed that 
appropriate and timely decisions about services for children and their 
families are important ones that can affect a child's length of stay in 
foster care.

CFSA officials and Family Court judges have been working together to 
address some of the hindrances that constrain their working 
relationship. CFSA managers said that scheduling of court hearings has 
improved. According to agency officials, in March 2003, CFSA began 
receiving daily schedules from the Family Court with upcoming hearing 
dates. This information allows caseworkers to plan their case 
management duties such that they do not conflict with court 
appearances. Also, as of March 2003, Family Court orders were scanned 
into FACES to help ensure that caseworkers and others involved with a 
case have more complete and accurate information. To help resolve 
conflicts about ordering services, CFSA caseworkers and Family Court 
judges have participated in sessions during which they share 
information about their respective concerns, priorities, and 
responsibilities in meeting the needs of the District's foster care 
children and their families.

Conclusions:

CFSA has taken steps to implement several ASFA requirements, met 
several performance criteria, developed essential policies, and 
enhanced its working relationship with the Family Court. In addition, 
CFSA has implemented new group home policies, improved the average time 
caseworkers took to implement certain policies and undertaken 
initiatives, in conjunction with the Family Court, to improve the 
scheduling of court hearings. However, CFSA needs to make further 
improvements in order to ensure the protection and proper and timely 
placement of all of the District's foster care children. By 
implementing all ASFA requirements, meeting the performance criteria 
and effectively implementing all policies, CFSA will improve a child's 
stay in the foster care system and reduce the time required to attain 
permanent living arrangements. Furthermore, complete, accurate, and 
timely case management data will enable caseworkers to quickly learn 
about new cases and the needs of children and their families, 
supervisors to know the extent to which caseworkers are completing all 
required tasks in the most timely way, and managers to know whether any 
critical aspects of the agency's operations are in need of improvement. 
Without automated information on all cases, caseworkers do not have a 
readily available summary of the child's history, which may be critical 
to know when making plans about the child's safety, care, and well-
being.

Mr. Chairman, this concludes my prepared statement. I will be happy to 
respond to any questions that you or other Subcommittee members may 
have.

GAO Contact and Acknowledgments:

For further contacts regarding this testimony, please call Cornelia M. 
Ashby at 202-512-8403. Individuals making key contributions to this 
testimony included Carolyn M. Taylor, Mark E. Ward, Sheila Nicholson, 
Vernette Shaw, Joel Grossman, and James Rebbe.

[End of section]

GAO Related Products:

District of Columbia: Issues Associated with the Child and Family 
Services Agency's Performance and Policies. GAO-03-611T. Washington, 
D.C.: April 2, 2003.

Child Welfare: HHS Could Play a Greater Role in Helping Child Welfare 
Agencies Recruit and Retain Staff. GAO-03-357. Washington, D.C.: March 
31, 2003.

District of Columbia: More Details Needed on Plans to Integrate 
Computer Systems with the Family Court and Use Federal Funds. GAO-02-
948. Washington, D.C.: August 7, 2002.

Foster Care: Recent Legislation Helps States Focus on Finding Permanent 
Homes for Children, but Long-Standing Barriers Remain. GAO-02-585. 
Washington, D.C.: June 28, 2002.

D.C. Family Court: Progress Made Toward Planned Transition and 
Interagency Coordination, but Some Challenges Remain. GAO-02-797T. 
Washington, D.C.: June 5, 2002.

D.C. Family Court: Additional Actions Should Be Taken to Fully 
Implement Its Transition. GAO-02-584. Washington, D.C.: May 6, 2002.

D.C. Family Court: Progress Made Toward Planned Transition, but Some 
Challenges Remain. GAO-02-660T. Washington, D.C.: April 24, 2002.

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

Foster Care: Status of the District of Columbia's Child Welfare System 
Reform Efforts. GAO/T-HEHS-00-109. Washington, D.C.: May 5, 2000.

FOOTNOTES

[1] These performance criteria were among those included in the 
performance standards that CFSA had to meet in order to end the 
probationary period following the general receivership. We selected 
those performance criteria that in our judgment most directly relate to 
the safety and permanent placement of children.

[2] The receivership was an arrangement in which the court appointed a 
person to temporarily manage the agency with broad authority to ensure 
full compliance with the court order in an expeditious manner.

[3] We issued several reports that addressed CFSA operations and 
program plans. For more information see related GAO products. 

[4] Among other responsibilities, OCC provides legal support to CFSA in 
its handling of foster care cases.

[5] Independent living arrangements may be attained once a child, who 
has not been reunified with his family or adopted, reaches the age of 
18 or, in some jurisdictions, 21 and is no longer eligible to receive 
federal reimbursement for foster care expenditures.

[6] Child and Family Services Reviews, conducted by HHS, cover a range 
of child and family service programs funded by the federal government, 
including child protective services, foster care, adoption, independent 
living, and family support and preservation services. The 2001 review 
evaluated seven specific safety, permanency, and well-being outcomes 
for services delivered to children and families served by CFSA.

[7] In April 2003, the court-appointed monitor submitted a final 
implementation plan containing additional performance measures to the 
U.S. District Court for the District of Columbia for its approval. Once 
approved, this plan will establish goals CFSA must meet by 2006.

[8] U.S. General Accounting Office, Child Welfare: HHS Could Play a 
Greater Role in Helping Child Welfare Agencies Recruit and Retain 
Staff, GAO-03-357 (Washington, D.C.: Mar. 31, 2003).

[9] U.S. General Accounting Office, District of Columbia Child Welfare: 
Long-Term Challenges in Ensuring Children's Well-Being, GAO-01-191 
(Washington, D.C.: Dec. 29, 2000) and Foster Care: Status of the 
District of Columbia's Child Welfare System Reform Efforts, GAO/
T-HEHS-00-109 (Washington, D.C.: May 5, 2000). 

[10] Administrative review hearings are held to make decisions about a 
child's permanent placement. They generally involve foster care 
children, family members, CFSA caseworkers, attorneys, and others with 
a role in the future well-being of the child.

[11] U.S. General Accounting Office, District of Columbia Child 
Welfare: Long-Term Challenges to Ensuring Children's Well-Being, 
GAO-01-191 (Washington, D.C.: Dec. 29, 2000).

[12] HHS completed its SACWIS assessment review of FACES in June 2000. 
The purpose of this review is to assess whether the child welfare 
information system performs functions that are important to meeting the 
minimal requirements.