Performance audit, Department of Economic Security Division of Children, Youth and Families Child Protective Services relative replacement

              Debra K. Davenport
Auditor General
Performance Audit
Department of
Economic Security—
Division of Children, Youth and Families—Child
Protective Services—Relative Placement
Performance Audit Division
September • 2009
REPORT NO. CPS-0902
A REPORT
TO THE
ARIZONA LEGISLATURE
The is appointed by the Joint Legislative Audit Committee, a bipartisan committee composed of five senators
and five representatives. Her mission is to provide independent and impartial information and specific recommendations to
improve the operations of state and local government entities. To this end, she provides financial audits and accounting services
to the State and political subdivisions, investigates possible misuse of public monies, and conducts performance audits of
school districts, state agencies, and the programs they administer.
The Joint Legislative Audit Committee
Audit Staff
Copies of the Auditor General’s reports are free.
You may request them by contacting us at:
Office of the Auditor General
2910 N. 44th Street, Suite 410 • Phoenix, AZ 85018 • (602) 553-0333
Additionally, many of our reports can be found in electronic format at:
www.azauditor.gov
Senator Thayer Verschoor, Chair Representative Judy Burges, Vice Chair
Senator Pamela Gorman Representative Tom Boone
Senator John Huppenthal Representative Cloves Campbell, Jr.
Senator Richard Miranda Representative Rich Crandall
Senator Rebecca Rios Representative Kyrsten Sinema
Senator Bob Burns (ex efficio) Representative Kirk Adams (ex efficio)
Melanie M. Chesney, Director
Catherine Dahlquist, Manager and Contact Person
Dan Hunt, Team Leader
Emily Chipman
2910 NORTH 44th STREET • SUITE 410 • PHOENIX, ARIZONA 85018 • (602) 553-0333 • FAX (602) 553-0051
WILLIAM THOMSON
DEPUTY AUDITOR GENERAL
DEBRA K. DAVENPORT, CPA
AUDITOR GENERAL
STATE OF ARIZONA
OFFICE OF THE
AUDITOR GENERAL
September 8, 2009
Members of the Arizona Legislature
The Honorable Janice Brewer, Governor
Mr. Neal Young, Director
Department of Economic Security
Transmitted herewith is a report of the Auditor General, a Performance Audit of the
Department of Economic Security, Division of Children, Youth and Families—Child
Protective Services—Relative Placement. This report was prepared pursuant to and under
the authority vested in the Auditor General by Arizona Revised Statutes §41-1966.
As outlined in its response, the Department of Economic Security agrees with the findings
and plans to implement all of the recommendations.
My staff and I will be pleased to discuss or clarify items in the report.
This report will be released to the public on September 9, 2009.
Sincerely,
Debbie Davenport
Auditor General
Attachment
Relative Placement
The Division surpassed
other states’ performance
in placing children in out-of-home
care with relative
caregivers between 2000
and 2006, but a few
changes would improve
staff performance.
Specifically, the Division
should revise two policies
to ensure that staff have
sufficient guidance to arrive
at consistent decisions
when assessing
prospective relative
caregivers’ criminal
backgrounds and the
safety of their homes. In
addition, the Division should
enforce the statutory and
policy requirement that
staff provide written
notification to individuals
who are declined as
relative caregivers that
explains the reason they
were declined and the
process to appeal the
decision, or seek a
statutory change allowing
for verbal notification to the
declined relatives. Finally,
the Division should identify
a central location for
documenting staff’s
ongoing efforts to identify
and place children with
relatives, which would allow
staff to efficiently review
and continue these efforts.
The Department agrees
with the findings and will
implement the
recommendations.
This audit was conducted
under the authority vested
in the Auditor General by
Arizona Revised Statutes
§41-1966.
As required by federal and state law, when the Child Protective Services (CPS)
program within the Department of Economic Security’s (Department) Division of
Children, Youth and Families (Division) must remove a child from his/her home
because of abuse or neglect, it will first look to place the child with a relative.
The process for placing a child with a relative includes several steps such as
identifying a potential relative caregiver, verifying that the caregiver and any
other adults in the home are fit to care for the child, and conducting a home
study to ensure the home environment is safe.
For the past several years, Arizona has surpassed the national median rate for
placing children in out-of-home care with relative caregivers. Studies support
that children placed with relatives experience fewer placement changes, are
less likely to re-enter out-of-home care after returning home, and have fewer
behavioral health problems. In addition, information from the federal
government indicates that placement of children with relatives is encouraged
because this is where children can maintain their family and cultural ties. As of
June 30, 2008, approximately one-third of Arizona’s children in out-of-home
care were living with relatives.
Changes would help staff better comply with the
relative placement process (see pages 7 through 11)
When comparing Arizona’s performance to other states’ performance between
2000 and 2006, the Division is performing well in placing children with relatives,
but some changes would facilitate CPS staff’s decision making and compliance
with policy. Specifically:
 First, although division policy requires staff to assess the criminal
background of prospective relative caregivers and other adults living in the
relative’s home to determine their fitness to care for children, it provides
limited guidance on criteria CPS staff should use to determine if individuals
clear, or pass, the background check. This situation may lend itself to
inconsistent decision making due to staff’s using varying criteria and/or
thresholds. To ensure greater consistency in staff’s criminal background
assessments and decisions, the Division should revise its policy to include
additional guidance. Specifically, the policy should list offenses that would
automatically preclude someone from clearing the criminal background
check and additional factors that staff should consider if an individual
requests reconsideration of staff’s decision to deny clearance such as the
extent of the individual’s rehabilitation.
Office of the Auditor General
page i
Agency Comments
SUMMARY
Our Conclusion
State of Arizona
 Second, although division policy requires that a prospective relative caregiver’s
home undergo a safety assessment to ensure it is a safe environment prior to
placing a child with the relative, it does not provide sufficient guidance on the
types of safety hazards that should be considered when conducting the
assessment. Similar to what is occurring with criminal background checks, this
situation may lend itself to inconsistent decision making because staff are using
varying criteria. To ensure greater consistency in home safety assessments and
decisions, the Division should revise its policy to include additional guidance.
For example, the policy could include common types of safety hazards that, at
a minimum, should be looked for when performing home safety inspections.
These might include a pool or spa without an adequate barrier, unsecured
weapons, lack of working smoke detectors, and inadequately stored
medications and cleaning supplies.
 Finally, although statute and division policy require staff to provide written
notification to a prospective relative caregiver when it determines that placement
with the relative is not in the child’s best interest, this is not consistently
occurring. Providing this notification is important because it includes the reason
for denying the placement and the process for appealing it. Division
management indicated that this notification is occurring verbally, which may
benefit relatives because it provides them with an opportunity to ask questions.
However, supervisors do not have a mechanism to verify that these verbal
notifications are consistently occurring. Further, if the relative caregiver who was
denied the placement wants to appeal CPS’ decision, the appeals process
requires that he/she send a letter to the responsible juvenile court. Therefore, it
is important that the Division provide the denied relative caregiver the applicable
court address and contact information. Finally, if the individual decides to appeal
the decision, it may be helpful to have the reasons placement was denied in
writing. Therefore, the Division should ensure that staff comply with the statutory
and policy requirement that staff notify in writing individuals who are declined as
relative placements. Alternately, if the Division believes that verbal notification is
more effective, the Division should seek a statutory change to allow the required
information to be communicated verbally, and develop a mechanism that will
allow supervisors to verify staff are providing the required information.
Staff efficiency may be improved by centralizing relative
placement documentation (see pages 13 through 14)
Although division staff document their relative searches and other efforts to place
children with relatives, the documentation is scattered throughout the hard copy and
electronic case files. As a result, reviewing cases to identify relative placement efforts
is time intensive. Because division staff must continually attempt to place children in
page ii
out-of-home care with relatives, having easy access to relative identification and
placement information is important to ensure staff are not duplicating efforts and can
efficiently review relative information and placement actions taken.
Best practice and literature suggest that centralizing relative information avoids
duplicated efforts and provides proof that the agency has made diligent efforts to
contact relatives. It also ensures that a record is available for the courts and for CPS
supervisors and staff. In a system where staff turnover is high, creating a
documentation system is critical to ensure that the effort that goes into the initial and
on-going searches is not lost for future use. Ideally, this ongoing documentation is
incorporated into a child’s electronic case file. Division staff reported that reviewing
and compiling relative placement efforts can take significant amounts of time
because the information is recorded in multiple locations. Therefore, the Division
should centralize information on staff’s ongoing efforts to identify and place children
with relatives, preferably in an electronic format so that it is easily and readily
accessible to CPS supervisors and other staff needing the information. The Division
should also modify its policies to indicate what information staff are required to record
in the centralized location. Finally, the Division should ensure that staff are recording
the required information in this location.
page iii
Office of the Auditor General
State of Arizona
page iv
Relative placement
page 1
When CPS removes a
child from his/her
home because of
abuse or neglect, it
will first look for a
relative to care for the
child. Relative
placements benefit
children in several
ways, including
reducing the likelihood
that the child will re-enter
out-of-home
care after returning
home.
For the past several
years, Arizona has
surpassed the national
median rate for
placing children in out-of-
home care with
relative caregivers. As
of June 30, 2008,
approximately one-third
of Arizona’s
children in out-of-home
care were living
with relatives.
Arizona’s relative care
program serves both
licensed and
unlicensed relative
caregivers.
Arizona facilitates and
supports relative care
through various types
of financial assistance
and services.
BACKGROUND
Office of the Auditor General
When Child Protective Services (CPS) removes a child from his/her home
because of abuse or neglect, federal and state laws require that the child be
placed in the least restrictive, or most family-like, setting possible that can meet
the child’s needs.1 As a condition of receiving federal funding for foster care and
adoption assistance, federal law also requires that states consider giving
placement preference to an adult relative who meets state protection standards
over a nonrelated caregiver.2 Therefore, when looking for a placement for a child,
CPS will first look for relatives.3 If no relatives are available, the child may be
placed with an unrelated licensed foster family or in a group care facility, such as
a group home.
Relative placements benefit children in several ways. Studies support that
children placed with relatives experience fewer placement changes and are less
likely to re-enter out-of-home care after returning home than children who had
been in nonrelative placements or in group care facilities.4 Teachers and
caregivers also rate children placed with relatives as having fewer behavioral
problems than their peers in other out-of-home placement settings.5
Information from the federal government indicates that placing of children with
relatives is encouraged because this is where children can maintain their family
and cultural ties.6 In line with this, the Department of Economic Security
(Department), Division of Children, Youth and Families (Division) also indicated
that children’s sense of cultural identity and positive self-esteem is reinforced by
living with people they know and trust. The children are able to make and sustain
family connections and continue lifelong family traditions and memories. Further,
extended family can support children in preserving healthy family relationships,
1 42 U.S.C. §675 (5)(A), A.R.S. §8-514
2 42 U.S.C. §671(a) (1) and (19)
3 According to division policy, a person with a significant relationship to a child is considered kin and part of the child’s
extended family.
4 Iglehart, A.P. (1994). Kinship foster care: Placement, service and outcome issues [Electronic version]. Children and
Youth Services Review, 16(1-2), 107-122; Chamberlain, P., Price, J.M., Reid, J.B., Landsverk, J., Fisher, P.A., &
Stoolmiller, M. (2006). Who disrupts from placement in foster and kinship care? [Electronic version]. Child Abuse &
Neglect, 30, 409-424; and Leslie, L.K., Landsverk, J., Horton, M.B., Ganger, W., & Newton, R.R. (2000). The
heterogeneity of children and their experiences in kinship care [NIH public access author manuscript]. Child Welfare,
79(3), 315-334.
5 National Survey of Child and Adolescent Well-Being. (2005). CPS sample component wave 1 data analysis report.
Washington, DC: United States Department of Health and Human Services. (ERIC Document Reproduction Service
No. ED501301)
6 Department of Health & Human Services Administration for Children and Families. (2009). Family connection
discretionary grants. Retrieved August 17, 2009, from http://www.acf.hhs.gov/grants/open/HHS-2009-ACF-ACYF-CF-
0078.html
support the child’s need for safety and well-being, and create a sense of belonging
in a child’s life. According to division data, 32 percent, or 3,142, of the 9,965 children
in out-of-home care on June 30, 2008, were living with relatives.
Arizona historically surpasses national median rate for
placing children in out-of-home care with relatives
As shown in Figure 1, Arizona has surpassed the national median rate for placing
children in out-of-home care with relative caregivers. Specifically, between 2000 and
2006, the percentage of Arizona children in out-of-home care living with relatives
ranged from 25 to 32 percent, which was 9 to 15 percent higher than the national
median. Although national comparisons are not yet available for 2007 and 2008,
division data indicates that Arizona’s relative placement rate was 31 percent for 2007
and 33 percent for 2008. Division officials reported that the strengthening of “family-centered
practice” in 2002 contributed to the increase in relative placement rates
beginning in 2003. According to officials, an overriding principle of family-centered
practice is maintaining children within family settings or placing children who cannot
safely remain at home with relatives. Another contributing factor the Division cited
was its developing and implementing a safety and risk assessment process that
includes the importance of placing children who cannot remain safely in their homes
with relatives.
page 2
State of Arizona
0
5
10
15
20
25
30
35
2000 2001 2002 2003 2004 2005 2006
Percent
Arizona National Median
Figure 1: Comparison of Arizona and National Relative Placement Rates
As of September 30, 2000 through 2006
Source: Child Welfare League of America compilation of data obtained from the federal Adoption
and Foster Care Analysis and Reporting System.
page 3
Office of the Auditor General
Arizona’s relative care program
Arizona’s relative care program, also known as the kinship care program, facilitates
and supports relative placements by providing financial assistance and services to
relative caregivers, including persons with a significant relationship to a child.
Arizona’s program includes two forms of relative care:
 Licensed relative care—A minority of relative caregivers obtain department
licensure to become foster care providers. Licensure requires that the individual
meet specific age, income, and health requirements. In addition, the individual
and any other adults living in the home must pass a criminal background check,
and the home must pass a life and safety inspection. According to the Division’s
2008 Kinship Foster Care Report, licensed relative caregivers were caring for 12
percent, or 365, of the 3,142 children in relative placements on June 30, 2008.
 Unlicensed relative care—The majority of relative caregivers are unlicensed and
therefore must receive court approval to be a relative caregiver.1 Although
unlicensed relative caregivers do not need to meet licensure standards, they still
must undergo CPS and criminal history background checks, home safety
assessments, and meet other requirements such as providing personal
references and participating in personal interviews. According to the Division’s
2008 Kinship Foster Care Report, unlicensed relative caregivers were caring for
88 percent, or 2,777, of the 3,142 children in relative placements on June 30,
2008.
Financial assistance and services available to support
relative placements
To facilitate and support relative placements, various types of financial assistance
and services are available. Specifically:
 Financial assistance—Financial assistance varies depending on whether the
relative caregiver is licensed or unlicensed. Licensed caregivers are eligible to
receive daily foster care maintenance payments for the care of their relative
children. In fiscal year 2008, the Division’s daily foster care maintenance rates
ranged from $25 to $45 per day depending on the age and needs of the child
in care.2 The Division funds the maintenance payments using federal Title IV-E
(Foster Care and Adoption Assistance) monies and State General Fund monies.
1 If CPS places a child with an unlicensed relative caregiver prior to filing a dependency petition, the placement with the
relative is part of the petition, and the juvenile court subsequently may approve the placement. However, if a dependency
petition is filed prior to placing the child with the relative, the juvenile court needs to approve the placement.
2 The Department reduced the daily foster care maintenance rates in response to the State’s fiscal year 2009 budget
reductions. As of March 1, 2009, the rates range from $20 to $38 per day.
page 4
Although unlicensed relative caregivers are not eligible for the daily foster care
maintenance payment, they may apply for federal Temporary Assistance for
Needy Families (TANF) cash assistance. The Division reported that the
households of 37 percent, or 1,151, of the 3,142 children in relative care on June
30, 2008, received TANF, and the average monthly payment for children in
relative care was $265. Reasons provided by relative caregivers for not applying
for TANF included not wanting to accept public assistance and determining that
it was not worth the effort since the child was returning home soon. In addition,
some relatives reported difficulty completing the TANF application, although the
Department has streamlined the application process. For example, the
Department allows applicants to waive the face-to-face interview requirement
and to complete the interview by telephone.
In addition to the maintenance and TANF payments, both licensed and
unlicensed caregivers may receive a combined personal and clothing allowance
for the relative children in their care, ranging from $0.63 to $2.63 per day,
depending on the child’s age. Under certain circumstances, special allowances
for the children’s graduation costs, diapers, and other special needs are also
available.
However, as shown in Table 1 (see page 5), in response to the State’s fiscal year
2009 budget reductions, the Department reduced or suspended some financial
assistance previously available to relative caregivers effective March 1, 2009. For
example, both the daily foster care maintenance payments and TANF payments
were reduced by 20 percent, while several of the allowance amounts were cut
in half.
 Services—Arizona Revised Statute (A.R.S.) §8-514.03 requires the Department
to provide relative caregivers with nonfinancial services that it determines are
necessary to meet the child’s and family’s needs. Nonfinancial services are
provided by department staff or through referral to outside agencies and
organizations, and may include services such as case management, parent
skills training, and transportation. However, in addition to reducing financial
assistance, the Department has also reduced the availability of some services
such as parent skills training and transportation services.
State of Arizona
Office of the Auditor General
page 5
Fiscal Year 2009 Assistance Level
Funding Beginning of Year Year-End
Maximum emergency clothing allowance $300 annually $150 annually
Annual extra emergency clothing
allowance $200 one time $100 one time
Maximum educational allowance for
books, supplies, course fees, student
service, and physical education
fees/equipment for school-age children $165 annually $82.50 annually
Maximum special needs allowance for
expenses such as holidays, birthdays, and
special occasions $45 annually $22.50 annually
Maximum allowance for diapers for
children requiring additional funding for
this purpose $125 monthly $62.50 monthly
Maximum allowance for summer day camp
and overnight residential stays (requires
division approval) $550 annually Suspended
Maximum allowance for high school
graduation cap, gown, ring, yearbook, and
other graduation-related fees $220 one time $220 one time
Maximum for summer school $165 per session $165 per session
Foster care maintenance payment
(licensed caregivers only) $910 monthly average $728 monthly average
Temporary Assistance to Needy Families
(unlicensed relatives only) $263 monthly average $210 monthly average
Table 1: Impact of Fiscal Year 2009 Department Budget Reductions on
Funding Available to Relative Caregivers
Source: Auditor General staff summary of information provided by the Division’s Finance and Business Office
Administration. The changes in assistance level were effective March 1, 2009.
page 6
State of Arizona
page 7
Changes would help staff better comply with
relative placement process
Relative placement process is multi-step
The Department of Economic Security (Department), Division of Children, Youth
and Families’ (Division), process for placing children with relatives involves
several steps. When Child Protective Services (CPS) staff first remove a child
from his/her home, the staff person will ask the parents, children, or other adults
present if there are any relatives who would be willing to care for the child.1 If a
relative is identified, CPS staff will contact the individual to verify his/her
willingness to care for the child. CPS staff will then initiate criminal and child
abuse background checks on all the adults living in the relative’s household and
conduct or arrange for one or more home visits to assess safety and other
factors, such as how the relative disciplines children and his/her financial
circumstances.2 If the Division believes that the relative cannot adequately meet
the child’s health and safety needs, it is statutorily required to inform the relative
in writing that he/she has been declined as a caregiver, the reasons why, and the
process to appeal the decision.
If no relative is immediately identified, CPS staff will place the child with a
nonrelated licensed foster family or in a group care facility, such as a shelter or
group home, and continue to search for relatives. For example, CPS staff may
request relative information from other sources with knowledge of the family,
such as a school. In addition, the Division has dedicated staff and contractors
available to conduct more intensive searches to identify or locate relatives using
various public and private sources such as motor vehicle records. As long as the
child remains in out-of-home care, the Division is required to conduct frequent
searches for a relative placement, but no less than every 6 months.
The Division’s process
for placing a child with
relatives includes
several steps. Staff
need to identify a
potential relative
caregiver, verify that
the caregiver and any
other adults in the
home are fit to care
for the child, and
conduct a home study
to ensure the home
environment is safe.
The Division
surpassed other
states’ performance in
placing children with
relative caregivers
between 2000 and
2006. However, the
Division should make
two policy changes to
facilitate consistent
staff decision making
and ensure staff
comply with a
statutory and policy
requirement.
Specifically, the
Division should
provide greater
guidance to staff on
how to assess
prospective
caregivers’ criminal
backgrounds and
home safety. Further, it
should ensure staff
follow existing statute
and policy that require
written notification to
individuals who are
declined as relative
caregivers, or seek a
statutory change to
allow these
notifications to be
done verbally.
Office of the Auditor General
FINDING 1
1 Division policy defines a relative as a great grandparent, grandparent, brother or sister, aunt or uncle, or cousin.
Additionally, an adult with a significant relationship to the child is considered kin and part of the child’s extended
family.
2 If a relative is immediately available when CPS removes a child from his/her home, the child may be placed with
the relative pending successful completion and review of a fingerprint-based criminal history check conducted by
the Arizona Department of Public Safety and a formal home study. However, before leaving the child with the
relative, CPS staff will obtain and review Arizona criminal record information obtained through a name-based check
and CPS report information for each adult living in the relative’s home to determine their fitness to care for the child.
In addition, CPS staff will do a preliminary home visit to ensure there are no obvious safety concerns.
1 Effective on June 29, 2009, Laws 2009, Ch. 8, §20, establishes new criteria for a fingerprint clearance card.
page 8
Division performing well in placing children with relative
caregivers, but should make two policy changes
When comparing Arizona’s performance to other states’ performance between 2000
and 2006, the Division has surpassed other states in its placement of children who
have been removed from their homes because of abuse or neglect with relative
caregivers (see page 2), However, the Division can make two policy changes to
facilitate consistent CPS staff decision making. Specifically:
 Assessing criminal backgrounds—-Although division policy requires staff to
assess the criminal background of prospective relative caregivers and other
adults living in their home to determine their fitness to care for children, it
provides limited guidance on criteria CPS staff should use to determine if the
individuals clear, or pass, the background check. Specifically, division policy
directs staff to review the criminal history records for all the adults in the
household, taking into consideration the nature of the offenses and when they
occurred, to determine if any of the adults has a criminal history that would place
the child at risk of harm if placed in the home. If an individual is denied
clearance, he/she can request to meet with CPS staff, including a representative
of CPS management, to present additional information to correct or clarify
his/her criminal history record.
Because guidance is limited, staff may use varying criteria when assessing
criminal history, which can result in inconsistent decisions. For example, one
staff person indicated that she would decline criminal background clearance to
an individual if he/she had a history of DUI (driving under the influence)
convictions, even if the most recent was 5 years ago, because she feels that it
is just a matter of time until the individual will be arrested for another DUI.
However, the staff person stated that other staff might clear this individual,
concluding that the person has been rehabilitated since he/she has not had a
DUI in the past 5 years. Of 20 CPS staff interviewed by auditors, 12 reported that
the guidance is inadequate or may require supplemental clarification from
others such as their supervisors, coworkers, or Attorney General staff.
In contrast to the limited guidance provided to CPS staff for assessing criminal
background, statute provides explicit criteria for the Arizona Department of
Public Safety (DPS) and the Arizona Board of Fingerprinting (Board) to use when
assessing the criminal backgrounds of adults in households seeking foster care
licensure. DPS may not clear an individual if he/she has been convicted of
committing or is awaiting trial for any of 101 offenses listed in Arizona Revised
Statutes (A.R.S.) §41-1758.03(B) and (C).1 For some of these offenses, the
State of Arizona
page 9
individual may petition the Board for a good cause exception.1 As part of its
deliberation, the Board is statutorily required to consider various factors such as
the extent of a person’s rehabilitation (see textbox for the complete list of
factors).
To ensure greater consistency in CPS staff’s criminal
background assessments and decisions, the Division should
revise its policy to include additional guidance similar in
concept to that which DPS and the Board use in assessing the
criminal histories of adults in households seeking foster care
licensure. Specifically, the additional guidance should include
a listing of offenses that would automatically preclude
someone from clearing the background check and additional
factors that staff should consider if the individual requested that
CPS staff reconsider the decision to deny clearance
 Conducting home safety assessments—Although division policy requires that a
prospective relative caregiver’s home undergo a safety assessment to ensure it
is a safe environment prior to placing a child with the relative, it does not provide
sufficient guidance on the types of safety hazards that should be considered
when conducting the assessment. This situation may lend itself to inconsistent
decision making because staff are using varying criteria. Auditors interviewed 20
CPS staff and found considerable variation in the typical types of safety hazards
they reported assessing. For example, one CPS staff person indicated that she
looks for dents in walls, potential criminal “vibe,” condition of the home, and how
the family members interact, while another CPS staff person indicated that he
looks for exposed wires, holes in the floors, and uncovered electrical outlets.
Although the majority of the CPS staff auditors interviewed felt they were able to
make these assessments relying on their on-the-job training, common sense,
experience as a parent, college education, and guidance from their supervisor,
25 percent of staff interviewed indicated that more detailed guidance would be
helpful. In addition, detailed guidance could result in more consistent decisions.
To ensure greater consistency in the home safety assessments and decisions
made by staff and others who the Department contracts with to perform this
task, the Division should revise its policy to include additional guidance such as
common types of safety hazards that, at a minimum, should be looked for when
performing home safety assessments. For example, one contractor has its staff
routinely look for common hazards such as a pool or spa without an adequate
barrier, unsecured weapons, lack of working smoke detectors, and inadequately
stored medications and cleaning supplies.
Office of the Auditor General
1 Under A.R.S. §41-619.55(E), the Board may grant a good cause exception at a hearing if the person shows to the Board’s
satisfaction that the person is not awaiting trial on or has not been convicted of committing any of the offenses listed in
A.R.S. §41-1758.03(B). The Board can also grant an exception if it finds that the person has been successfully
rehabilitated and is not a repeat offender.
Factors the Arizona Board of
Fingerprinting Considers in Making
Good Cause Exceptions
• Extent of person’s criminal record
• Elapsed time since offense committed
• Nature of offense
• Degree person participated in offense
• Extent of person’s rehabilitation
• Mitigating circumstances
Source: A.R.S. §41-619.55(E).
page 10
Division should ensure existing policy is followed
Although statute and division policy require CPS staff to provide written notification to
a prospective relative caregiver when they determine that placement with the relative
is not in the child’s best interest, this is not consistently occurring. According to
division management, prior to staff’s issuing a formal recommendation to decline an
individual as a relative caregiver, the individual can meet with the staff person and
his/her supervisor to provide additional information or clarification regarding identified
concerns. When CPS staff make their final decision, statute and policy require this
notification to be in writing. Providing this notification is important because it includes
the reason for denying the placement and the process for appealing it. However,
division staff and management reported that the practice in at least two of the
Division’s six districts is to provide the information verbally rather than in writing.
Management indicated that this practice is acceptable as long as staff ensure that
they include information on the process to appeal the decision with the juvenile court,
and suggested that verbally communicating the information may benefit the relative
because it provides him/her with an opportunity to ask questions. However,
supervisors do not have a mechanism to verify that these verbal notifications are
consistently occurring. Further, if the relative caregiver who was denied the
placement wants to appeal CPS’ decision, the appeals process requires that he/she
send a letter to the responsible juvenile court. Therefore, it is important that the
Division provide the denied relative caregiver the applicable court address and
contact information. Finally, if the individual decides to appeal the decision, it may be
helpful to have the reasons placement was denied in writing.
Therefore, the Division should enforce the statutory and policy requirement that the
individual be notified in writing when CPS staff make their final decision to decline the
individual as a relative placement. The notification is required to include the decision,
reason(s) for it, and appeals process information. Alternately, if the Division believes
that verbal notification is more effective, it should seek a statutory change to allow the
required information to be communicated verbally, revise its policy to reflect the
statutory change, and develop a mechanism that will allow supervisors to verify that
staff are providing the required information.
Recommendations:
1.1. The Division should revise its policy to include additional guidance for staff to
consider when determining whether the adults in a prospective relative
caregiver’s household clear their criminal background check. Specifically, the
policy should include a listing of offenses that would automatically preclude
someone from clearing the criminal background check and additional factors
that staff should consider if an individual requested that CPS staff reconsider its
decision to deny clearance.
State of Arizona
page 11
1.2. The Division should revise its assessment guidance to include common types of
safety hazards that should be looked for when performing home safety
assessments.
1.3. The Division should enforce the statutory and policy requirement that the
individual be notified in writing when CPS staff make their final decision to decline
the individual as a relative placement. The notification is required to include the
decision, reason(s) for it, and appeals process information. Alternately, if the
Division believes that verbal notification is more effective, it should seek a
statutory change to allow the required information to be communicated verbally,
revise its policy to reflect the statutory change, and develop a mechanism that
will allow supervisors to verify that staff are providing the required information.
Office of the Auditor General
page 12
State of Arizona
page 13
Staff efficiency may be improved by centralizing
relative placement documentation
Federal and state laws
identify relatives or
other individuals with a
significant relationship
to the child as a
placement preference
when CPS removes
the child from his/her
home and places
him/her in out-of-home
care. In support
of the laws, division
policy requires that
staff conduct
extensive and
documented searches
for relatives and other
significant persons as
placements for
children in out-of-home
care and
continue these
searches while the
children remain in
nonrelative, out-of-home
care.
Although best practice
and literature suggest
that relative
placement
documentation be
centralized, division
staff document their
efforts to place
children with relatives
in varied places such
as the hard copy and
electronic case files.
As a result, reviewing
cases to identify
relative placement
efforts and required
continual relative
searches is time
consuming. Therefore,
the Division should
centralize ongoing
relative placement
efforts to help ensure
staff can efficiently
review and continue
efforts to identify and
place children with
relatives.
FINDING 2
Division must document relative placement efforts
Federal and state laws require the Division to identify relatives or other individuals
with a significant relationship to the child as a placement preference when CPS
needs to remove the child from his/her home and place him/her in out-of-home
care. The order of placement preference is with a parent; grandparent; another
member of the child’s extended family, including a person who has a significant
relationship with the child; in licensed foster care; in a group home; or in a
residential treatment facility.
In support of federal and state law, division policy requires that staff conduct an
extensive and documented search for absent parents, guardians, custodians,
relatives, and other significant persons as placement resources for children in out-of-
home care. When a child is not placed with a relative, or is placed with a relative
who is unable or unwilling to provide a permanent home for the child, division staff
are required to initiate searches for other relatives or other significant persons at
least every 6 months while the child remains in out-of-home care. The Division is
required to report the outcomes of these efforts in periodic reports to the juvenile
court overseeing the child’s case. Further, the federal Fostering Connections to
Success and Increasing Adoptions Act of 2008 requires agencies to use due
diligence to provide notice to all adult grandparents and other adult relatives when
a child has been removed from his/her parents’ custody. It also requires the
Division to provide information on the options a relative has to participate in the
child’s care and placement.
Centralizing information could improve staff efficiency
Since division staff must continually attempt to place children in out-of-home care
with relatives, having easy access to relative identification and placement
information is important to ensure staff can efficiently review previously identified
relatives and prior relative placement actions so they do not duplicate efforts. Best
practice and literature suggest that centralizing relative information can avoid
duplication of efforts and can provide proof that the Division has made diligent
efforts to contact relatives. It also ensures that records are available for the court
and others who may be new to the case, especially if caseworker turnover is high.
Further, it can ensure that the effort that goes into initial and on-going searches is
not lost for future use. Ideally this information should be incorporated into an
electronic file.1
Office of the Auditor General
1 Office of the Inspector General. (2003). Social Security Administration: Best practices in federal papers management
(A-04-03-13030). Washington, D.C.: Author; Government of South Australia. (2008). Australian standard AS ISO 15489
—Records management. Retrieved June 3, 2009, from http://www.archives.org.il/UserFiles/File/119894256812.pdf,
Child Focus. (2007). Making “relative search” happen: A guide to finding and involving relatives at every stage of the
child welfare process. Retrieved June 3, 2009, from http://www.childfocuspartners.com/images/RelativeSearchGuide
10-15.pdf
page 14
Division staff reported that reviewing a case to identify relative placement efforts is
time intensive because CPS staff document their relative placement efforts in several
places within the hard copy case files and the Division’s automated CPS case
management system—CHILDS (Children’s Information Library and Data Source). As
a result, supervisory review of cases for evidence of efforts taken to identify relative
placements can be time intensive, and it may not be clear what steps staff took to
work with relatives or the reasons for staff’s decisions. For example, with the
assistance of a CPS supervisor, it took auditors approximately 4 hours to review one
case that had been open less than 6 months to determine what actions had been
taken to identify and then place the child with a relative. Further, auditors needed
additional explanation from staff about the actions taken to identify relatives because
there were gaps in the record due to missing or unrecorded information.
Documenting information on staff’s efforts to identify and place children with relatives
in a consistent location could reduce the amount of time supervisors and other staff
need to locate this information. Additionally, staff could more efficiently review and
continue relative identification and placement efforts. According to division
management, the Division may be able to modify CHILDS for this purpose, which
would allow staff and supervisors to more easily access the information. Types of
relative placement information currently collected and documented in various
locations that should be recorded in a central location include staff efforts to identify
and locate relatives, identified relatives’ personal and contact information, relatives’
relationship and history with the child, and relatives’ willingness to assist in caring for
the child.
Therefore, the Division should centralize information on staff’s efforts to identify and
place children with relatives, preferably in an electronic format so that it is easily and
readily accessible to CPS supervisors and other staff needing the information. The
Division should also modify its policies to indicate what information staff are required
to record in the centralized location. Finally, the Division should ensure that staff are
recording the required information in this location.
Recommendations:
2.1. The Division should centralize ongoing information on staff’s efforts to identify
and place children with relatives, including:
a. Identifying or developing a centralized location, preferably electronic;
b. Modifying its policies to indicate what information staff are required to
record in the centralized location; and
c. Ensuring staff record the required information in the centralized location.
State of Arizona
AGENCY RESPONSE
AGENCY RESPONSE
Office of the Auditor General
AGENCY RESPONSE
AGENCY RESPONSE
AGENCY RESPONSE
CPS Reports Issued
-0 CHILDS Data
Integrity Process
-0 Timeliness and
Thoroughness of
Investigations
-0 On-the-Job Training and
Continuing Education
-0 Prevention Programs
-0 Complaint Management
Process
-0 Congregate Care
-0 DES’ Federal Title IV-E
Waiver Demonstration
Project Proposal
-0 Family Foster Homes
and Placements
-0 Revenue Maximization
-0 In-Home Services
Program
-0 Federal Deficit Reduction
Act of 2005
-0 Federal Grant Monies
-0 Child Removal Process
-0 Client Characteristics
Future CPS Reports
-0 Substance-Exposed
Newborns
-0 Child Abuse Hotline
-0 Confidentiality of CPS
Information
-0 Licensed Family Foster
Homes
-0 Child and Family
Advocacy Centers
-0 Processes for Evaluating
and Addressing CPS
Employee Performance
and Behavior
In-Home Services Program
Adoption Program