CFSA’s Oversight Responses: What can we learn?

Screen Shot 2020-02-26 at 10.08.48 AMEvery year, the DC Council’s Committee on Human Services, currently chaired by Councilwoman Brianne Nadeau, submits a series of detailed oversight questions to the Child and Family Services Agency (CFSA). These questions focus on many aspects of the agency’s operations and policy.  The lengthy responses, available on the DC Council website, are some of the most interesting and detailed information that the agency releases during the year. This post attempts to highlight some of the more revealing  responses, as well as providing some comparisons with the previous year’s oversight responses.

Child Protective Services

Hotline Calls: The number of calls to CFSA’s child abuse and neglect hotline increased from 26,602 in FY 2018 to 28,561 in FY 2019. The highest number of calls (594) concerned educational neglect (usually student absences from school), followed by physical abuse (428), substance abuse (407), inadequate supervision (343), and domestic violence (248). The agency screened out 11,768 of these calls, or 41%, compared to 35% of the slightly smaller number of calls in FY 2018.

Assessments and Investigations: CFSA eliminated its Family Assessment track as of April 1, 2019, so that all screened-in Hotline calls, other than some infant positive toxicology reports , receive an investigation.  The total number of investigations increased from 4193 to 4788, which reflects the elimination of Family Assessment. The total number of investigations substantiated increased slightly from 1127 to 1204–which was a smaller percentage of investigations than in the previous year. The top factors leading to substantiation in 2018 and 2019 were substance abuse (in almost 25 percent of the cases), educational neglect (21 percent), physical abuse (19 percent), inadequate supervision (19 percent), domestic violence (15 percent) and caregiver incapacity due to incarceration., hospitalization, or physical or mental incapacity (11 percent). Substance abuse was the top factor in both years, but the order of the next five factors differed.

Educational Neglect Allegations: Because of the increase in allegations of educational neglect, CFSA is piloting a new approach to these allegations in collaboration with DCPS. A specialized unit has been created and is being piloted at two schools in order to provide early intervention services.

Sex Trafficking: Sex trafficking has been a hot topic in child welfare for the past decade or so after it became known that children in foster care are at particular risk. The Committee asked numerous detailed questions about sex trafficking and CFSA’s response.  Unfortunately it requested only the top ten factors accounting for substantiation of allegations to the hotline–and sex trafficking was not one of the top ten.  In order to know the number of substantiated sex trafficking allegations, the committee could ask for the numbers of substantiated allegations for all categories, not just the top ten. Without knowing how many sex trafficking cases were substantiated, we do know that the number of cases must have been less than the 49 substantiated for general neglect, the lowest number listed out of the top ten factors accounting for substantiation.

Worker Caseloads: The current plan to exit the LaShawn court case  requires that 90 percent of investigators and social workers will have caseloads less than or equal to 12′ no individual investigator shall have a caseload greater than 15 cases, reflecting generally accepted caseload standards. In response to the Committee’s question about the average caseload per worker, CFSA provided the average caseload for each individual investigator rather than the entire investigative workforce.  For a better picture, the Committee could request that the agency provide the average caseload for all investigators. It is encouraging to note, however, that the highest average caseload for any investigator in FY 2019 was 10.21 although there were many “instances” when a worker had a caseload of 13-15 and one “instance” when a worker had a caseload of 16 or more. The concept of “instance” is hard to interpret as it could reflect one minute or a year. The Committee could instead request the median number of days with a higher caseload for all investigators.

Newborns with Positive Toxicology: CFSA changed its policy in 2017 to require that all positive toxicology reports for newborns be screened in to make contact with the family and determine whether an investigation needs to be conducted. The number of hotline calls received regarding newborn positive toxicology in FY 2019 was 233, almost exactly the same number as the previous year but the response appears to have been more extensive. Of these 233 calls, 87 percent resulted in an in-home wellness visit by nursing staff (compared to 56 percent in FY 2019), 69 percent resulted in an investigation (compared to 30 percent in FY 2019) and 12 (five percent) resulted in removal of a child (data not provided for FY 2019).

Child Removals: CFSA removed a total of 360 children from their homes in FY 2018 and 378 in FY 2019. The most common reasons for removal were neglect (unspecified, 84 percent), physical abuse (13 percent), parental drug abuse (nine percent), and “caregiver ill/unable to cope” (7.5 percent).

In-Home Services

Cases Opened: In F’Y 2019, 618 cases were assigned to the In-Home Administration. 1 Of these cases, 69 percent resulted from a finding of abuse, 26 percent from neglect, five percent from sexual abuse, and less than one percent from allegations of sex trafficking (three cases) and child fatality (three cases). A total of 662 in-home cases closed in 2019, slightly more than the number that opened.

Case Closures: The the reasons for closure of in-home cases that CFSA provided are confusing, and Chairperson Nadeau asked about these during the hearing. Half of the cases closed because “child welfare services not needed,” a category whose meaning is unclear. Another 126 closed because “services/service plan not completed.” Still another 89 closed because of “completion of treatment plan.” It is hard to understand how that differs from “service plan completed.”  Four cases closed for “client’s failure to co-operate.” Since in-home cases by definition involve high risk to children, this is somewhat disconcerting. The Council might want to ask what happened to the families in these cases. Were the children removed, or simply left in their risky situations without monitoring? Was a risk assessment done before case closure? CFSA and the Court monitor have agreed that court involvement (through community papering) should be considered for noncooperative parents with in-home cases.  It is also significant that 38 of the families moved out of the District. A reasonable conjecture would be that many moved to Maryland. There have been child fatality cases around the country involving families with in-home cases moving between states (or even lying that they were moving out of state) and avoiding further supervision by CPS. The Council could ask CFSA whether they verify such moves and inform the receiving state of these families.

Services to In-home families: Families with in-home cases develop a case plan with their social workers that outlines the services they need to complete in order to close their cases. Among the services most frequently included are mental health services, drug treatment, parenting skills training, and domestic violence interventions. As the Citizen Review Panel pointed out in a recent report, many many parents with in-home cases who need mental health services in order to comply with their case plans, as well as many of their children, struggle to obtain timely quality services in light of long waiting times and high provider turnover. In response to the committee’s question about what the agency is doing to ensure these families get the services they need, CFSA stated that “In-Home families access mental health services through DBH” and that the two agencies work collaboratively to address families’ needs.  It is clear that CFSA understands the deficiencies in DBH services because it has opened an in-house mental health unit to serve children in foster care and plans to expand these services to their families. That leaves the larger group of parents and children with in-home cases out in the cold. Unfortunately, the Family First Act, which was supposed to fund services to prevent children entering foster care, does not allow federal Title IV-E funds to pay for services which can be funded by Medicaid, ruling out most mental health programs in the District for Title IV-E funding..

Family First Act: Under the Family First Act, CFSA can now spend federal Title IV-E funds, formerly confined to foster care, for in-home services that have been included in the federal Title IV-E Prevention Services Clearinghouse. As discussed in the oversight hearing, CFSA expects only $80,000 in revenue from Family First because there was only one program in the clearinghouse at the time CFSA developed its Family First Plan–Parents as Teachers–that CFSA chose to provide and that was not already sufficiently funded using other sources. However, Motivational Interviewing and Healthy Families America have been added to the clearinghouse since CFSA submitted its plan, and CFSA stated that it hopes to draw down federal funding for these programs.

Foster Care

Placement instability: Frequent placement changes continued to be a problem in 2019. About 51 percent of children had one placement episode in FY 2019; another 27 percent experienced two episodes, 16 percent experienced three to four episodes and seven percent had five or more. The percentages were fairly similar in FY 2018, with slightly more experiencing one or more than five episodes. As described by witnesses at the oversight hearing, it is often the children with behavioral problems and disabilities who bounce from placement to placement because foster parents are unable to handle their issues.

Overnight stays at CFSA and emergency placements: As discussed at the oversight hearing, more children stayed overnight at the agency in FY 2019 than in FY 2018.  This number increased from 13 youths in FY 2018 to 31 in FY 2019. According to CFSA’s responses, the factors behind these overnight stays included placement disruptions occurring late at night or early in the morning, lack of psychiatric options such as sub-acute psychiatric programs and partial hospitalization programs, youth brought back to the agency by foster parents, and youths refusing to leave the building for an offered placement. The number of youths staying in an emergency, short-term, or otherwise temporary placement while awaiting a long-term placement also increased from 79 in FY 2019 to 100 in 2020.

Placement Capacity: Placement capacity has increased greatly from 758 beds as of September 30, 2018  to 941 at the time of the oversight responses–presumably January 2020. Not surprisingly, given the decline in the foster care population, the number of vacant beds increased from 66 in January 2019 to 327 in January 2020. This huge increase in vacancies at a time when children are staying overnight in the CFSA building as described below illustrates that the problem in the District is not the number of foster homes but the lack of placements for harder-to-place children.

Expanding Placement Capacity: In order to expand the placement array, CFSA in FY 2019 added two Stabilization Observation Assessment Respite (“SOAR”) professional foster homes with a total of four beds, to serve high-needs children; entered into a contract with Children’s Choice to provide intensive foster care to 36 children, secured six additional congregate care beds for children with Autism Spectrum Disorder, and added six additional behavioral/therapeutic beds in a new group home run by the Children’s GuildThe agency expressed the hopes that these new resources will reduce stays in offices and emergency placements and also hopes to increase placements with kin.

Kinship Care;  Twenty-eight percent of children in out-of-home care were  in kinship homes on the last day of FY 2019  (up from 26% in FY 2018), as compared to a national average of 32 percent. To explain this difference, CFSA cited the stricter licensing requirements in Maryland, where many relatives live, as well as the lack of affordable housing in the District. More use of  kinship diversion to place children with relatives outside of the foster care system could account for a jurisdiction’s lower-than-average percentage of foster parents who are kin. However, neither CFSA nor most other jurisdictions collect the data that would allow comparison of the frequency of the practice.

Assistance to relative caregivers outside foster care: In FY 2019, 521 families with 822 children were served by the Grandparent Caregiver program, up from 513 families with 798 children in FY 2018. The average benefit received in FY 2019 was $1,145 per month. The Close Relative Caregiver program was established in FY 2019 and currently serves 12 caregivers and 22 children, who are expected to receive an average of $553 per child per month. CFSA started its Kinship Navigator Program in the last quarter of FY 2019 and includes a helpline, enrichment events for families, flex funds for one-time or short-term needs, and educational groups, which are slated to begin later in FY 2020.

Group Homes: The number of group home beds decreased from 71 as of January 15, 2019 to 67 as of January 15, 2020 despite CFSA’s opening two new group homes for children with special needs. There were 17 vacant group home beds, as compared to 14 the previous year. In an email responding to my questions, CFSA’s Intergovernmental Affairs Liaison Yolanda McKinley explained that the decrease stemmed from the decline in foster care caseloads and the continuing move away from congregate care as a placement option for most youths.

Mental Health Services: The new in-house mental health unit appears to have reduced the time it takes for children newly placed in foster care to access needed mental health services. Children receiving services from the Department of Behavioral Health (DBH) waited an average of 75 days between mental health screening at CFSA and intake and the actual receipt of services. Children served by the in-house mental health unit waited an average of 35 days. Seventy-three children were served by the unit in FY 2019. Unfortunately, CFSA answered the question about length of service, type of service, and transition to an external provider with a table that provides a separate row for each of the 73 children receiving services. The Committee might want to request aggregate data about length of service to get a better overall picture. For those children who completed services, the average length of service ranged from seven to 399 days.  Six children, all of whom received at least 259 days of services at CFSA, transitioned to another provider after completing service at CFSA.

Psychiatric hospitalization: A total of 118 children in foster care had an episode of psychiatric hospitalization in FY 2019, compared to 122 in 201,  according to Director Brenda Donald, who corrected in her oral testimony an error in the oversight answers for FY 2018.

Educational Performance: The abysmal educational performance of DC youths in foster care is no surprise and not different from that other jurisdictions around the country. Only five percent of third through eighth graders and two percent of those in grades nine through twelve met or exceeded expectations for their grade in mathematics. In reading, the percentage meeting or exceeding expectations was 12 percent  for grades 3-8 and five percent for grades 9-12. In its oversight responses, CFSA rightly points out that there are many factors behind this abysmal school performance, most of which predated children’s placement in foster care. These include cognitive or other disabilities, periods of missed schooling, mental health concerns, and trauma histories. But while all foster youth should receive intensive supports to help reduce the deficits they bring into foster care, my experience as a foster care social worker and mentor has revealed that the system often instead imposes new disadvantages. These can include foster parents who take little interest in the child’s education (especially Maryland foster parents when the child attends a DC school), long commutes to keep children in their original school (which may result in a child missing a whole day of school for a doctor’s appointment), and system-induced absences for court hearings, meetings, and medical appointments scheduled during school hours for the convenience of staff who must take them to these appointments.

The number of students receiving tutoring went down from 285 in 2018 to 209 in 2019. CFSA’s Yolanda McKinley explained in her email that the agency conducted a comprehensive review of service utilization and terminated tutoring services for students with a “poor history of utilization,” those who had completed their educational goals, and those who had exited foster care.

The number of youths receiving mentoring services declined from 172 to 118 during Fiscal Year 2019. In her email, McKinley explained that CFSA has changed its referral guidelines so that youth who are nearing reunification with their families are not referred to contracted mentoring services through BEST Kids. They also removed from the mentorship rolls young people who were not actually participating in mentoring services. According to McKinley’s email, “[T]he lower FY19 number accurately represents youth who are actively engaged in mentoring services.”

School stability transportation: CFSA paid a total of $1,310,966 , or $99 per youth per day, to transport 199 foster youth living in Maryland to their original schools in the District. In addition to the high costs, these transportation arrangements may require children to spend two to three hours on the road daily and deprive them of the opportunity to participate in extracurricular activities. There is no debate that it would be  better to place children in foster homes that are near their schools. CFSA is already investing heavily in foster parent recruitment in the District but perhaps future efforts could be targeted around the schools and neighborhoods that send the largest number of children to foster care. Trying to recruit families and teachers from schools and churches close to these schools might be a good approach. In view of the large numerical surplus of foster homes, CFSA might want to consider closing some Maryland foster homes in order to increase the ratio of DC to Maryland homes.

High School Performance and Graduation: CFSA had access to grade point average information for only 84 of the 186 youths enrolled in high school during the 2018-2019 school year. These GPA’s ranged from a low of 0 to a high of 4.42, with a median of 1.61. The high school graduation rate for the last academic year was 73 percent, which was calculated by dividing the number of youth who graduated from the 12th grade or earned a GED by the end of the school year by the number of foster youth who were in the 12th grade or a GED program 2 at the beginning of the year.

College: Thirty-six young people were enrolled at a four-year college in Fall 2019, and 11 were enrolled in a two-year college. These figures are similar to those from the previous year. Eight young people received a Bachelor’s degree in the 2018-2019 school year and no youths achieved an associate’s degree in that year. CFSA reports that 19 youths dropped out of college in FY 2019.

Older Youth Issues

Program changes: YV LifeSet is a new grant-funded program that has replaced Career Pathways. There were 49 youths involved in YVLifeset as of January 2020, compared to 113 in Career Pathways in 2019. Eighteen youths were enrolled in vocational programs in FY 2019, compared to 35 in 2018. It is possible that the reduction is due to the end of the Career Pathways program.

Independent Living: In January 2019, there were 10 beds in Independent Living Programs (ILP’s) in CFSA’s system, of which 5 were vacant. By January 2020, all of these beds had been eliminated. In its oversight responses, CFSA explained that it no longer offers ILP’s due to “underutilization.” Last year’s oversight responses clarify the meaning of this term. In its 2018 responses, CFSA described its conclusion that youths placed in ILP’s who have not demonstrated their maturity have struggled after aging out. In 2018, CFSA revised its policy by requiring youths to demonstrated readiness by having a high school diploma, being engaged in employment, education or training and having a savings account in order to move into an ILP. In tandem with this policy change, CFSA reduced the number of ILP slots from 20 to 10 by eliminating one of the two ILP programs. CFSA reported that only three young people moved into an ILP after the new policy and there were only five youths total in the one ILP at the end of the fiscal year.  This appears to be the “underutilization” that resulted in closure of the remaining program in FY 2019.

Aging Out: CFSA answered that 45 out of 49 youths had stable housing at the time they aged out of foster care in FY 2019. However, a witness from the Children’s Law Center stated at the oversight hearing that “the agency improperly defines transitional housing, college dorms, staying with friends, and DDS placements as ‘stable living arrangements.”’ If those arrangements are considered unstable, 32 out of the 49 youths who aged out were in unstable housing.

Permanency

The number of adoptions finalized remained nearly the same–98 in FY 2019 and 101 in FY 2019. There was an average of 14 months between filing of the adoption petition and finalization of the adoption, up from 10 months in FY 2018. The number of guardianships finalized declined from 64 to 40 with an average of 19 months between placement in a home and finalization of the guardianship, down from 39 months in FY 2018. The Committee did not ask similar questions about reunification.

Fatal Incidents

CFSA reported that eight children and youth died while in CFSA care in FY 2019. Four children were in foster care, three had open In-Home Cases and one had an open Family assessment or investigation at the time of death. I view these numbers as very distressing and I hope that the Council requests further information about them. It could be that some of these children were medically fragile and that their deaths were not due to maltreatment of any type. Such basic information as the cause of death is necessary for the Committee to make sense of this information.

Conclusion: CFSA’s answers to the oversight questions of the DC Council’s Human Services Committee provide a trove of useful information. A continued reduction in the number of children in foster care, an increase in stays in agency offices and emergency placement, a large surplus of foster care beds along with continued need for more placements for hard-to-place youth, expansion of the placement array in response to this problem, successful implementation of a mental health unit to serve foster youth, the elimination of independent living programs, and high number of fatalities among system-involved children are among the  results that stand out.  Child Welfare Monitor DC was able to obtain corrections for some responses from CFSA that did not appear to make sense. Nevertheless, some responses were unclear or delivered in a format that is difficult to use. The Council might want to seek clarification in these cases and modify its questions next year in order to obtain information that is more useful in its effort to oversee and support CFSA’s important work.


  1. There are no comparable data for FY 2018 because of a change in the data collected. 
  2. This number was incorrectly reported as 32 instead of 26 in the oversight responses, according to the clarifying email by CFSA. 

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