State of Arizona
Office
of the
Auditor General
PERFORMANCE AUDIT
Report to the Arizona Legislature
By Douglas R. Norton
Auditor General
DEPARTMENT OF
ECONOMIC
SECURITY,
DIVISION OF
CHILDREN, YOUTH
AND FAMILIES
November 1997
Report Number 97-18
2910 NORTH 44th STREET • SUITE 410 • PHOENIX, ARIZONA 85018 • (602) 553-0333 • FAX (602) 553-0051
DOUGLAS R. NORTON, CPA
AUDITOR GENERAL
DEBRA K. DAVENPORT, CPA
DEPUTY AUDITOR GENERAL
STATE OF ARIZONA
OFFICE OF THE
AUDITOR GENERAL
November 10, 1997
Members of the Arizona Legislature
The Honorable Jane Dee Hull, Governor
Dr. Linda J. Blessing, 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. This report is in response to a May 29, 1995, resolution of the Joint Legislative Audit Committee.
The report addresses several aspects of the Division’s oversight of child protective services, including its ability to: investigate
reports of abuse or neglect, measure and manage its CPS workload, monitor problem group and shelter homes, provide sufficient
out-of-home placements, and provide necessary management information to analyze its services and other needs. The report also
acknowledges several major efforts the Division has undertaken in recent years to improve its ability to provide comprehensive
child protective services. These efforts include the implementation of a statewide child abuse hotline, development of a case
weighting system, and development and implementation of a comprehensive information system.
Regarding the Division’s investigative process, our review found that the Division is unable to investigate all child maltreatment
reports and thus cannot ensure that the children involved are safe. Therefore, to ensure the Division can investigate all its cases,
additional staff will be needed. While the Division is currently in the process of developing staffing estimates, it could not provide
auditors with the historical data needed to independently determine the extent to which additional staff are needed. In addition, a
review of nearly 200 investigative case files in Maricopa County revealed that nearly 40 percent of investigations were not initiated
within the required response time. Furthermore, some investigations were poorly documented, with some cases remaining open
for extended periods when no further investigative activity was needed. Additional problems identified in the file review included
investigative cases not receiving supervisory review and missing case files.
Regarding the Division’s ability to measure its workload and staffing needs, our review found that although the Division recently
implemented a case weighting model to better determine its CPS workload, further improvement of the model is needed.
Specifically, the time study that was conducted to develop the case weighing model collected information from too few cases, did
not consider the differences between types of caseworkers and excluded several important factors that can impact a caseworker’s
ability to manage caseloads. Regarding the Division’s oversight of group and shelter homes, a review of 16 group care agencies that
have exhibited problematic supervision and care of children revealed that the Division did not adequately document or resolve the
problems occurring within those agencies. Regarding the current availability of foster homes, our review found that more children
who are removed from their homes are being placed in temporary shelter care, for longer periods, because it is difficult to find
appropriate placements for them. Specific problems often encountered in attempting to find more permanent placements include
the inability or unwillingness of many homes to accept certain children, difficulty in finding placement for children with special
needs and an overall shortage of foster homes located in the metropolitan areas. Finally, the report addresses the Division’s need to
continue to monitor data integrity after the implementation of its new information system.
As outlined in its response, the Department of Economic Security agrees with all of the findings and 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 November 12, 1997.
Sincerely,
Douglas R. Norton
Auditor General
Enclosure
i
SUMMARY
The Office of the Auditor General has conducted a performance audit of the Arizona Depart-ment
of Economic Security, Division of Children, Youth and Families, pursuant to a May 29,
1995, resolution of the Joint Legislative Audit Committee.
During fiscal year 1997, the Division of Children, Youth and Families (Division) received
55,645 calls regarding suspected child abuse, neglect, or exploitation of Arizona children. Based
on information callers provided, the Division determined that 38,063 of these calls (involving
62,839 children) required a Child Protective Services (CPS) investigation. The Division is
responsible for ensuring these cases are investigated and that the children involved are safe
from imminent danger.
To improve its efficiency and effectiveness in providing child protective services (CPS), the
Division, over the last three years, has undertaken a number of major initiatives. Specifically,
it has successfully implemented a statewide child abuse hotline, and it has developed a case
weighting system for managing its CPS workload. Additionally, Arizona is a lead state in
developing and implementing a comprehensive information system that is intended to capture
information on the entire CPS process. The Division expects to complete implementation of this
system, the Children’s Information Library and Data Source (CHILDS), by the end of 1997.
The Division Is Unable to Investigate
All Child Maltreatment Reports
(See pages 9 through 14)
The Division is required to take calls regarding suspected child abuse and investigate those
it deems appropriate. Such calls are referred to as CPS reports. Although the Division is
mandated to investigate 100 percent of CPS reports, its fiscal year 1997 statewide investi-gation
rate is 84 percent. Without conducting investigations in all cases deemed appropri-ate
for investigation, the Division cannot ensure that the children involved are safe. De-spite
this, the number of uninvestigated reports increased between fiscal year 1996 and
fiscal year 1997. Specifically, during fiscal year 1996, more than 1,500 cases went uninvesti-gated,
and approximately 5,900 cases went uninvestigated during fiscal year 1997.
To ensure the Division can investigate all its cases, additional staff will be needed. Although
the Division is developing staffing estimates, it could not provide auditors with historical
information regarding workload because its workload measurement methods have recently
changed. Although this Office’s audit work does not dispute the need for additional staff,
without this historical data, it was not possible to determine how reasonable the Division’s
estimates are. In addition, other factors may influence the need for additional staff and
ii
resources and should be studied. For example, the Division should analyze whether the
34 percent increase in CPS reports during fiscal year 1997 will continue. Similarly, the
Division should continue to review the process it uses to classify reports, since the Division
received fewer calls regarding suspected child abuse in fiscal year 1997 than in 1996
(55,645 vs. 59,145), but determined that a much higher percentage of these reports required
investigations (70 vs. 49 percent). Another factor the Division should review is the impact
of the recently approved Family Builders Pilot Program, which is expected to provide
services to families whose cases might otherwise remain uninvestigated. The Division
anticipates that, over time, this program will reduce the number of staff it needs, so the
Division will need to continually assess how many cases this program will handle once it
is implemented in January 1998.
The Division’s Investigations Are
Not Always Timely or Thorough
(See pages 15 through 21)
A review of 196 randomly selected District I (Maricopa County) investigative files found that
nearly 40 percent of these investigations were not initiated within the required response time.
In addition, some investigations were poorly documented, some cases were left open for
extended periods when no further investigative activity was needed, and only about 40 percent
of the investigated cases were reviewed by a supervisor in some manner prior to closure.
Moreover, 6 percent of the case files were missing, so it was not possible to determine if any
investigative activities were performed for these files.
The Division=s problems with investigation timeliness and thoroughness are likely to continue
because there were more reports requiring investigations during fiscal year 1997. While the
Division is currently developing plans that would increase the number of investigative staff,
it should make changes now in two other areas. First, the Division should develop additional
training for its investigators covering both the basic investigative tasks required as well as
specific investigative policies and procedures. Second, the Division should increase its over-sight
of investigations by ensuring that supervisors review cases prior to closure, and that
Division management conduct random case file reviews to help assess the quality of its investi-gations.
Workload Measurement
Model Needs Further Improvement
(See pages 23 through 28)
Although the Division has recently implemented a better method for determining its CPS
workload, the Division=s case weighting model needs further improvement. Recognizing that
case counts are not the best measure of workload, in 1994, the Division sought to implement
iii
a more accurate means for assessing workload. The Division hired a consultant to design a
case weighting model that measures workload by considering some of the complexities in-volved
in handling a case, including the number of children and type of case plan established.
However, when conducting the time study necessary to design the model, the Division col-lected
information from too few cases, did not consider the differences between types of
caseworkers, and excluded several important factors that can impact a caseworker’s ability to
manage caseloads, such as cases involving delinquent children or substance abuse, and chil-dren
needing behavioral health services. To improve its case weighting model, the Division
should increase its sample size so that it can gather more information for analysis when it
conducts its next time study, scheduled for 1998.
The Division’s Oversight of Group
and Shelter Homes Is Inadequate
(See pages 29 through 33)
The Division should improve its oversight of group and shelter homes. A review of 16 group
care agencies= licensing files (chosen because they had been the subject of at least 2 child abuse
and neglect reports during 1996) revealed that the Division did not adequately document or
resolve the problems occurring at these agencies. Specifically, the Division did not adequately
document all of these reports in the agencies= licensing files, and did not document whether
it considered them during the agencies’ licensing renewal process. Some agencies were al-lowed
to alternate between regular and provisional licenses without adequately addressing
the problems that originally caused them to receive a provisional license.
To help improve the Division’s oversight of group and shelter homes, the Legislature should
consider providing the Division with the authority to impose civil penalties. In the meantime,
the Division should use its current authority to suspend or revoke the licenses of agencies that
continually fail to adhere to licensing requirements.
Current Foster Homes Unable
to Meet Certain Placement Needs
(See pages 35 through 40)
More children who are removed from their homes are being placed in temporary shelter care,
for longer periods, because it is difficult to find appropriate placements for them. Placement
specialists and caseworkers cited three primary reasons for this problem: the inability or
unwillingness of many homes to accept certain children, such as teenagers or large sibling
groups; difficulty in finding placements for children with special needs; and the overall short-age
of foster homes located in the metropolitan areas. Placement delays are not only costly,
they are not in the child’s best interest.
iv
To ensure there are enough foster homes to meet placement needs, the Division needs to
centralize foster home recruiting oversight and coordination, and expand its efforts to retain
current foster families.
Data Integrity Should Remain a
Continuous Priority for the Division’s
New Information System
(See pages 41 through 44)
The Division should continue to monitor data integrity after the implementation of its new
information system, the Children’s Information Library and Data Source (CHILDS). During
CHILDS’ planning and implementation phases, the Division ensured that the system contained
quality control features that would help address the previous data systems’ problems identi-fied
in two prior Auditor General Reports (Nos. 91-6 and 94-L9). To ensure the Division
remains committed to monitoring data integrity, it should continue with its development and
implementation of a formal, written quality assurance program.
v
Table of Contents
Page
Introduction and Background............................................................... 1
Finding I: The Division Is Unable to
Investigate All Child Maltreatment
Reports ............................................................................................... 9
Investigations Needed to
Assess Children’s Safety............................................................................................. 9
The Division Needs to Address
Several Factors Impacting
Investigation Rates....................................................................................................... 11
Recommendations........................................................................................................ 14
Finding II: The Division’s Investigations
Are Not Always Timely or Thorough............................................... 15
Timely and Thorough
Investigations Are Important ..................................................................................... 15
Review Identifies Concerns
Regarding Quality of Investigations......................................................................... 16
Increasing Number of
Reports May Also Impact
Quality of Investigations............................................................................................. 19
Division Should Develop Specialized
Training and Improve Its Oversight ......................................................................... 19
Recommendations........................................................................................................ 21
vi
Table of Contents (cont’d)
Page
Finding III: Workload Measurement
Model Needs Further Improvement ................................................ 23
Case Weighting Model
Established to Improve
Workload Management .............................................................................................. 23
Weaknesses in Current
Case Weighting Model................................................................................................ 23
Case Weighting Model Needs
Further Refinement...................................................................................................... 26
Recommendations........................................................................................................ 28
Finding IV: The Division’s Oversight of
Group and Shelter Homes Is Inadequate....................................... 29
Division Responsible
for Licensing Group
and Shelter Homes....................................................................................................... 29
Group and Shelter Homes
Inadequately Monitored............................................................................................. 30
Division Should Improve
Oversight of Group and
Shelter Homes............................................................................................................... 31
Recommendations........................................................................................................ 33
Finding V: Current Foster Homes Unable
to Meet Certain Placement Needs................................................... 35
Background................................................................................................................... 35
vii
Table of Contents (cont’d)
Page
Finding V: (cont’d)
Shortage in Availability of
Certain Types of Foster Homes.................................................................................. 35
Division Must Strengthen
Recruiting and Retention Efforts ............................................................................... 38
Recommendations........................................................................................................ 40
Finding VI: Data Integrity Should Remain a
Continuous Priority for the Division’s
New Information System.................................................................. 41
History of Division’s
Computer Systems....................................................................................................... 41
Data Problems Limited
Usefulness of Systems ................................................................................................. 42
Division Efforts to Ensure
Data Integrity Should Continue................................................................................. 42
Recommendation......................................................................................................... 44
Agency Response
Appendix A....................................................................................... a-i
Appendix B....................................................................................... b-i
Appendix C....................................................................................... c-i
viii
Table of Contents (concl’d)
Page
Figure
Figure 1: Location of ACYF Districts ....................................................... 4
Tables
Table 1: Arizona Department of Economic Security
Division of Children, Youth and Families
Statement of Revenues and Expenditures
Years Ended June 30, 1995 through 1997
(Unaudited) ................................................................................... 6
Table 2: Arizona Department of Economic Security
Division of Children, Youth and Families
Number of Reports Requiring Investigation
and Percentage Actually Assigned for Investigation
Years Ended June 30, 1996 and 1997.......................................... 10
Table 3: Arizona Department of Economic Security
Division of Children, Youth and Families
Disposition of Child Abuse Calls
Years Ended June 30, 1996 and 1997.......................................... 13
Table 4: Arizona Department of Economic Security
Division of Children, Youth and Families
Delayed Response Times for District I Sample
of CPS Investigations by Priority Category
Year Ended June 30, 1996 ............................................................ 17
Table 5: Arizona Department of Economic Security
Division of Children, Youth and Families
Quarterly Comparison of Average Number of Children
in Shelter or Receiving Home
Years Ended June 30, 1996 and 1997.......................................... 37
1
INTRODUCTION AND BACKGROUND
The Office of the Auditor General has conducted a performance audit of the Arizona Depart-ment
of Economic Security, Division of Children, Youth and Families, pursuant to a May 29,
1995, resolution of the Joint Legislative Audit Committee.
Division=s Mission Is to Protect
Child Abuse Victims
The Division=s mission is “to protect children, to ensure their on-going safety, and to provide
children in need and their families with an array of services that are accessible, appropriate,
and which promote independence and self-sufficiency.” During calendar year 1995, 43,762
children in Arizona required the Division=s intervention. According to the National Center on
Child Abuse and Neglect, in that year, the rate of children alleged to be victims of maltreat-ment
in the U.S. by state ranged from 8 to 108 per 1,000 children younger than 18. Arizona
ranked 33rd out of 49 states reporting, with a rate of 37 children per 1,000 being the subject of
child abuse and neglect reports. Since 1995, the number of Arizona children involved in sus-pected
maltreatment cases has grown. During fiscal year 1996, the Division received 28,445
child abuse and neglect reports involving approximately 47,000 children. In fiscal year 1997,
the Division received 38,063 reports appropriate for investigation that involved 62,839 Arizona
children.
Children are referred to the Division through its statewide toll-free child abuse hotline. Al-though
any person can report suspected abuse, about half of the calls are made by teachers,
doctors, and other health care professionals who are mandated by law to report such incidents.
The hotline worker who responds to the call determines whether the situation warrants an
investigation. During fiscal year 1997, the hotline received 55,645 calls, and about 70 percent
of these met the Division=s investigation criteria. In addition to determining which calls require
a CPS investigation, the hotline worker also determines how quickly an investigation must be
started. The Division uses four categories to prioritize investigations, and the standard re-sponse
time for these investigations ranges from two hours for Priority 1 reports to seven days
for Priority 4 reports (see Appendix A, pages a-i through a-iv, for more specific information
about the priority classification system).
When an investigation is necessary, the Division must assess the child’s safety, the validity
of the allegations, and the risk of future harm to the child. Depending on the investigation
results, the Division’s involvement in any case can range from:
n Investigation only—When the Division concludes that there are no risk factors severe
enough to warrant continued involvement, a case may be closed after investigation without
2
the Division providing further services. Alternatively, a case may be closed if a family re-fuses
Division services and the risks to the child’s safety are not severe enough to warrant
legal action. Although the Division has no legal authority to compel families to cooperate
or receive services, in every case closed after investigation, the Division still refers families
to community resources that could provide assistance.1 The Division estimates that the
majority of cases are closed after investigation; however, it currently lacks a means for de-termining
precisely how many cases fall into this category.
n Investigation and short-term services—When the Division determines that a child is at
risk of maltreatment, it may offer families services such as counseling and parenting skills
classes that could allow the child to live safely at home. Families participate in these serv-ices
voluntarily. Voluntary services aimed at strengthening and stabilizing families last
from several weeks to several months. As with the previous category, the Division lacks a
mechanism for determining the number of families receiving short-term services, and
whether these services improved the families’ situations.
n Investigation, state custody, and ongoing services—When the Division believes a child
is in imminent danger of abuse or neglect, the child may be removed from the home and
placed in temporary protective custody. When this happens, the Division must file a de-pendency
petition with the local Juvenile Court within 48 hours. If the Court determines
the child to be dependent, it awards custody to the State. An ongoing caseworker must de-velop
a case plan and monitor the family’s progress with the case plan objectives while ar-ranging
for services such as medical and dental care, counseling, parenting skill classes,
and transportation to and from services. Additionally, the caseworker must visit the child
and family at least once a month and review and revise case plans every six months. The
Division estimates that approximately 10 percent of the cases it investigates will fall into
this category.
Overview of the Division=s
Organization and Budget
To carry out its mission, the Division employs 1,312 full-time staff, and is organized into four
sections:
1. Administration for Children, Youth and Families (ACYF)—ACYF is the Division=s
primary unit, and is responsible for providing child protective services, including investi-gations
and ongoing case management. It also offers in-home services, family preservation
1 Per A.R.S. §8-546.02, the Division has no legal authority to compel families to cooperate with the investigation,
nor to receive services. However, it can proceed with the investigation, and if necessary, take temporary custody
of the child and/or file a dependency petition.
3
services, and foster home recruitment, training, and licensing services. To serve the entire
State, ACYF=s programs are provided through more than 98 local Child Protective Services
(CPS) units located in 6 geographic districts, as follows (see Figure 1, page 4):
District I: Maricopa County District II: Pima County
District III: Apache, Coconino,
Navajo, and Yavapai
Counties
District IV: LaPaz, Mohave, and
Yuma Counties
District V: Gila and Pinal Counties District VI: Cochise, Graham,
Greenlee, and
Santa Cruz Counties
The ACYF section contains 1,156 of the Division=s 1,312 employees. The majority of these
employees are located in the districts and local offices and perform direct case management
activities. For example, approximately 600 employees are dedicated to providing investiga-tive
and ongoing case management services. Other employees perform administrative
functions, such as the District Program Managers, or offer support services to the direct
caseworkers, such as teaching parenting and household management classes, providing
transportation, and supervising child/parent visitations.
2. Financial and Business Operations—This section contains various units that provide
budget and financial information and technical assistance, including Information Systems
Management, Evaluation and Statistics, Licensing, Personnel, Contracts, and Adoption
Subsidy and Eligibility determination.
3. Comprehensive Medical and Dental Program (CMDP)—This program provides compre-hensive
medical and dental care to court-adjudicated children placed in out-of-home care
under the custody of the Department of Economic Security, the Department of Juvenile
Corrections, or the Administrative Office of the Courts/Juvenile Probation Offices. CMDP
serves approximately 7,500 children annually and provides a full scope of services ranging
from immunizations and prescriptions to surgery and medically necessary orthodontia.
4. Legal Services—This section comprises Assistant Attorneys General, housed at the Attor-ney
General’s Office, who provide the Division with legal representation for dependencies,
severances, etc.
The Division receives its funding in virtually equal proportions from both the federal and state
governments. As illustrated in Table 1 (see page 6), in fiscal year 1997, the Division received
an estimated $246 million in federal and state monies to operate its programs and provide
services
4
Figure 1
Location of ACYF Districts
5
to children and families. The State supported 46 percent ($114 million) of the Division=s opera-tions
and services, while federal monies made up the remaining 54 percent ($132 million).
Approximately 23 percent of this money (nearly $56 million) was used to administer the
Division=s programs, with the remaining 77 percent (nearly $190 million) used to pay for direct
services such as contracted services, foster care maintenance payments, and adoption subsidy
payments.
Major Initiatives
Implemented in
Recent Years
The Division has undertaken a number of initiatives in recent years to address major opera-tional
issues. For example, the Division has successfully implemented a centralized report
intake process with its statewide child abuse hotline. The hotline, which has been in effect since
November 1994, receives all calls alleging child abuse and neglect and identifies which calls
warrant an investigation. A set of specific cue questions was developed to ensure that hotline
operators ask the same questions during every call received. This most recent review found the
hotline was operating as intended and that Division staff were regularly monitoring its opera-tion
to ensure continued consistency in report screening and prioritization.
The Division has also taken steps to address workload management by developing a case
weighting system to use in allocating staff. In fact, few states have devoted the time and re-sources
necessary to design a comprehensive time study needed to provide information on
workload and caseload complexity. While the Division=s case weighting model is a step in the
right direction, this review found that the model needs further refinement in order for the
Division to use it as an effective workload management tool. (See Finding III, pages 23 through
28, for further information on the Division=s case weighting model.)
Finally, the Division continues its efforts to provide statewide automated information about
its child welfare activities. The Division is nearing the completion of its Children’s Information
Library and Data Source (CHILDS), which is intended to capture information on the entire CPS
process. Similar to its efforts to develop a case weighting system, the Division is ahead of many
other states in its development of a statewide automated system. However, to ensure the
accuracy and reliability of information maintained on the new system, the Division needs to
continue with its plans to establish a quality assurance program that will provide regular data
monitoring and identify system-training needs. (See Finding VI, pages 41 through 44, for
further information on the status of current management information systems.)
6
Table 1
Arizona Department of Economic Security
Division of Children, Youth and Families
Statement of Revenues and Expenditures
Years Ended June 30, 1995 through 1997
(Unaudited)
1995
(Actual)
1996
(Actual)
1997
(Estimated)2
Revenues
General Fund appropriations $106,942,300 $109,958,500 $114,284,100
Federal grants and
reimbursements 97,359,200 115,623,700 131,592,300
Total revenues $204,301,500 $225,582,200 $245,876,400
Expenditures
Operating expenditures:
Personal services $ 33,937,600 $ 36,073,700 $ 37,862,300
Employee related 7,848,500 8,549,000 8,342,100
Other operating 8,389,500 7,473,800 9,743,100
Total operating expenditures 50,175,600 52,096,500 55,947,500
Program expenditures:
Children’s services 65,719,800 75,916,800 87,185,800
Childcare programs 55,652,800 60,443,900 61,206,300
Adoption services 15,699,800 18,163,600 21,062,200
Comprehensive medical and
dental care program for
foster children 7,702,300 8,611,300 9,468,900
Other 6,390,900 8,988,000 11,005,700
Total program expenditures 151,165,600 172,123,600 189,928,900
Total expenditures $201,341,200 $224,220,100 $245,876,400
Revenues over expenditures 1 $ 2,960,300 $ 1,362,100 $ 0
1 Any revenues in excess of expenditures consist of unexpended legislative appropriations that are subject to
reversion to the state general fund.
2 Amounts are based on legislative appropriations and estimates for nonappropriated monies.
Source: The Arizona Department of Economic Security Legislative Report II (BG35A) for the years ended June 30,
1995 through 1997.
7
Audit Scope
and Limitations
This audit focused on the Division’s ability to investigate all CPS reports of abuse or neglect,
conduct investigations in a timely and thorough manner, measure and manage its CPS work-load,
monitor problem group and shelter homes, provide sufficient out-of-home placements
for dependent children, and provide necessary management information to analyze its services
and other needs.
However, the auditors’ ability to comprehensively review two areas was impeded by a lack
of data and/or inaccurate data. First, the audit initially set out to determine the extent to which
services for children and their families were available and how adequately the Division met
the identified needs. This audit objective could not be completed because the Division lacked
data regarding children’s and families’ needs. Specifically, auditors were unable to compile
complete information on service needs and services actually provided. Further, while some
districts maintained or collected information manually, others did not. Therefore, auditors
were unable to identify or determine the extent of problems with service provision, such as
lags between the time a service was requested and the time it was actually provided.
Second, comprehensive compilation and analysis of the Division’s management information
for the purpose of assessing compliance and effectiveness was not possible because of various
data problems within the Division’s two primary data systems. As discussed in Finding VI (see
pages 41 through 44), both systems suffered from incomplete, inaccurate, and untimely data
inputs. As a result, it was difficult to determine how well the Division complies with statutory
requirements, as well as its own policies, such as the requirement to meet with clients on a
monthly basis.
Methodology
Some of the major methodologies used to conduct this audit included:
n Reviewing a judgmental sample of 16 agencies’ licensing files chosen because they had
been the subject of at least 2 child abuse neglect reports in 1996;
n Conducting a random sample of 196 CPS case files from District I involving investigations
that were initiated in fiscal year 1996 to assess the timeliness and thoroughness of investi-gations;
n Observing both the investigative and ongoing case management processes through 62
hours of ride-alongs with caseworkers in Districts I and III;
n Conducting a total of 4 small group discussions with: (1) six CPS unit supervisors and 14
8
caseworkers to identify factors affecting their ability to manage CPS caseloads, and (2) eight
children’s services providers and child advocates to obtain their input on current service
needs, barriers, and strategies for improving service delivery;
n Interviewing various other parties involved in the dependency process, including several
Foster Care Review Board members, Court Appointed Special Advocates, Attorney Gen-eral
representatives, and Court personnel;
n Attending numerous meetings of the Ad Hoc Committee on CPS Issues and legislative
hearings, in addition to reviewing the Division’s proposed and passed legislation;
n Surveying seven other states to obtain comparative information on investigations,
caseloads, licensing, and training and services; and
n Reviewing multiple reports and standards from national organizations such as the Child
Welfare League of America and the National Center on Child Abuse and Neglect.
This report presents findings and recommendations in six areas, addressing the Division’s
need to:
n Investigate all reports of abuse and neglect deemed appropriate for investigation;
n Improve investigation timeliness and thoroughness;
n Improve oversight of group and shelter homes;
n Increase the availability of family foster homes;
n Enhance the current case weighting model in order to more effectively measure and moni-tor
workload; and
n Continue with its plans to implement a quality assurance program to monitor data integrity
on its new computer system.
This audit was conducted in accordance with government auditing standards.
The Auditor General and staff express appreciation to the Director of the Department of Eco-nomic
Security as well as the Division of Children, Youth and Families’ management and staff
for their cooperation and assistance throughout the audit.
9
FINDING I
THE DIVISION IS UNABLE TO INVESTIGATE
ALL CHILD MALTREATMENT REPORTS
The Division is unable to investigate all reports of child maltreatment even though statutorily
required to do so. Without conducting an investigation in every case, the Division cannot assess
a child’s safety. To ensure the Division can investigate all its cases, additional staff will be
needed. However, the Division should also consider how other factors, such as the recent
increase in reports, the recent Family Builders legislation, and its report classification system,
have or will impact its need for additional staff and resources.
Investigations Needed to
Assess Children’s Safety
Statute requires Child Protective Services (CPS) to take calls regarding suspected child mal-treatment
and investigate those it deems appropriate. However, the Division currently does
not investigate all of those calls that it determines should be investigated (referred to as CPS
reports). During fiscal year 1996, the Division never assigned an investigator to more than 1,500
cases that its centralized intake process determined should have been investigated.1 Specifi-cally,
the Division assigned investigators to only 26,930 of 28,445 reports (or 94.67 percent)
deemed appropriate for investigation. As illustrated in Table 2 (see page 10), none of the six
districts were able to investigate 100 percent of the cases referred during fiscal year 1996, and
District I (Maricopa County) had the lowest investigation rate.
Further, as shown in Table 2, most districts experienced a decrease in investigation rates during
fiscal year 1997, with 5,899 cases being uninvestigated (see Appendix B, page b-i, for more
specific details on the uninvestigated cases).2 The largest decrease in investigation rates oc-curred
in District I in its Priority 4 cases. However, statewide, 151 high-to-moderate risk cases
(Priority 1 and 2) were not investigated. While most of the uninvestigated cases were of lower
priorities, and theoretically involved children considered to be at low risk for immediate harm,
even lower priority cases may contain instances of serious harm to children that should be
1 The number of uninvestigated cases does not include pending cases (i.e. those cases that the Division had not yet
determined whether or not to assign an investigator to). There were 31 cases pending in the fiscal year 1996 data
analyzed for this report.
2 The number of uninvestigated cases does not include 57 cases that were pending in the fiscal year 1997 data
analyzed for this report.
10
Table 2
Arizona Department of Economic Security
Division of Children, Youth and Families
Number of Reports Requiring Investigation
and Percentage Actually Assigned for Investigation a
Years Ended June 30, 1996 and 1997
Priority 1 Priority 2 Priority 3 Priority 4 b
High risk Moderate risk Low risk Potential risk
2-hour response 48-hour response 72-hour response 7-day response Total
District I
1996 2,078 99.42% 2,862 98.92% 7,402 88.58% 3,496 84.78% 15,838 91.03%
1997 3,021 99.77 3,740 97.46 10,072 70.64 4,432 59.27 21,265 77.13
District II
1996 654 99.69 809 99.51 2,493 98.68 1,171 97.52 5,127 98.67
1997 873 98.85 1,102 96.37 3,685 86.05 1,665 79.04 7,325 87.54
District III
1996 353 99.72 348 100.00 1,044 99.52 607 99.51 2,352 99.62
1997 506 98.22 403 98.76 1,464 98.36 716 98.88 3,089 98.51
District IV
1996 322 99.69 310 100.00 896 99.55 477 99.16 2,005 99.55
1997 377 99.73 421 99.05 1,241 97.66 576 83.33 2,615 95.03
District V
1996 229 99.56 259 99.23 734 99.73 411 99.16 1,633 99.57
1997 326 100.00 357 100.00 921 99.89 420 100.00 2,024 99.95
District VI
1996 248 100.00 200 99.50 669 100.00 373 99.73 1,490 99.87
1997 291 100.00 255 100.00 810 99.75 389 100.00 1,745 99.89
Statewide
1996 3,884 99.56 4,788 99.21 13,238 93.28 6,535 91.26 28,445 94.67
1997 5,394 99.50 6,278 97.71 18,193 80.61 8,198 72.46 38,063 84.35
a Does not include any cases pending final disposition.
b The Priority 4 category also includes cases for which a priority code was not recorded.
Source: Auditor General staff analysis of Child Protective Services Central Registry data.
11
investigated. Moreover, the Division is statutorily required to investigate all cases it deems
appropriate for investigation regardless of the risk. Without conducting an investigation, the
Division cannot assess the safety of the children involved.
The Division Needs to Address
Several Factors Impacting
Investigation Rates
The Division should take the necessary steps to ensure it investigates all appropriate child
abuse reports. In addition to providing the Division with additional staff, other factors that
may affect investigation rates should be studied.
Additional staff—Information obtained during the course of the review suggests that the
Division needs additional staff to improve its investigation rates. Department and Division
officials contend that the underlying cause of the increased number of uninvestigated reports
is inadequate resources. Specifically, the Division maintains that it has not received sufficient
funding to investigate 100 percent of its cases. Additionally, group discussions held with
supervisors, investigative staff, and service providers confirm that inadequate resources have
negatively affected investigation rates. Finally, the number of reports requiring investigations
rose 34 percent during fiscal year 1997 from 28,445 reports (fiscal year 1996) to 38,063 reports.
To address this increase in reports, the Division is currently pursuing various staffing plans
that would enable it to increase its investigation rates to 100 percent, as well as provide the
necessary ongoing case management and support services. The Division’s plans seek to in-crease
staff and also expand the use of a new program established by the Legislature during
1997. This program, known as Family Builders, will focus on families with children who have
low or potential risk for abuse and neglect. Therefore, when the Division’s supervisors deter-mine
that a Priority 3 or 4 case will go uninvestigated, under certain circumstances, they may
transfer that case to a local service agency. Within 48 hours of report receipt, the families and
children who wish to participate will receive an assessment (instead of an investigation). In
addition, within 30 days, the local service agency will design a service plan to meet the family’s
needs. The Division plans to implement this pilot program during January 1998, in at least two
locations in the State. Further, under the Division’s proposed staffing plans, this program
would be implemented and expanded over a three-year period, and would serve approxi-mately
1,100 children, or about 475 families, during the first 6 months of operation. During the
second year, the program will reach about 1,800 families, and finally, during the third year, the
program is expected to serve about 4,300 families.
Although the Division anticipates that over time the Family Builders Program can reduce the
number of caseworkers needed, the Division is seeking additional staff for the remainder of
fiscal year 1998 and for fiscal year 1999. The estimated number of additional staff needed
ranges from 21 to 75 each year, depending on whether or not a 5 percent caseload growth is
assumed. However, because the Division is still in the process of developing these plans, it has
12
not yet settled on a specific estimate. While the results of audit work do not dispute the need
for additional staff, it was difficult to establish a sound estimate. The Division recently changed
the methods it uses to measure workload (see Finding III, pages 23 through 28) and could not
provide auditors with any historical workload data. Therefore, without adequate historical
data, auditors could not reach conclusions about how reasonable the Division’s estimates are.
Several other factors may influence the need for additional staff—Although the Division needs
additional staff to help improve its investigation rates, it should also study several other factors
that may affect its investigation rates, including:
n The recent increase in number of cases requiring an investigation—As mentioned
previously, the number of reports requiring investigations during fiscal year 1997 increased
34 percent. While the Division attempted to keep pace with this increase by investigating
more cases in 1997 (32,107 vs. 26,930), its investigation rates were negatively affected be-cause
it was unable to match the 34 percent increase in reports. However, because the
number of child abuse reports was fairly stable over fiscal years 1994 through 1996 at about
28,500, it is not clear whether the Division can expect this type of increase to continue,
whether the number of reports will stabilize at current levels, or whether the number of re-ports
will be reduced to previous levels. Nevertheless, the Division’s current staffing plans
are based on the number of reports determined appropriate for investigation in 1997, which
is 34 percent higher than the previous year. Therefore, the Division will need to continue
to assess the number of reports requiring investigations to determine whether this dramatic
increase in reports will continue, and adjust its staffing plans accordingly.
n The Family Builders Program—This Division will also need to continue to assess the
impact of the Family Builders Program. As previously mentioned, this Program is slated
to begin in January 1998. Therefore, as the Program progresses, the Division will need to
carefully monitor this program’s ability to handle the number of cases the Division is cur-rently
projecting, and adjust its staffing alternatives accordingly.
n The report classification system—The Division should also review the process it uses
to determine which reports require an investigation so that only those reports needing an
investigation are assigned to an investigative caseworker. Although the Division regularly
reviews this system, several items discovered during the audit suggest further review is
warranted. First, the total number of calls concerning suspected child abuse received by the
Division’s Child Abuse Hotline has gone down, but the number of reports referred to local
offices for an investigation has increased. Specifically, as noted in Table 3 (see page 13), the
hotline received a total of 59,145 calls during 1996, and 55,645 during 1997. While workers
determined that only 49 percent of the calls needed an investigation in 1996, the percentage
of calls requiring an investigation in 1997 increased to 70 percent. Second, CPS supervisors
(in a group discussion held during the audit) suggested that the Division review and con-sider
revising the report screening processes because, in their opinion, some reports that
did not require investigations were being assigned. Finally, although the Division contends
that it appropriately screens hotline calls because its validation rates (i.e., the number of re-
13
ports that are found valid upon investigation) have remained stable, it has not had a sound
means for historically determining these rates. Specifically, in June 1997, the Division re-vised
its validation rates previously reported for fiscal year 1996, after auditors pointed to
the lack of data in the Child Protective Services Central Registry (CPSCR) regarding inves-tigation
findings. Based on its efforts to input the findings for more than 2,500 cases investi-gated
over a year ago, the Division has shown a 13 percent increase in the number of valid
reports compared to the figure previously reported in its annual report. However, since the
Division does not have sufficient CPSCR data to compare validation rates for previous
years, it is not clear that the validation rates have remained stable over time.
Since the Division regularly reviews its report classification system, with the next re-view
scheduled for the end of 1997, it should consider these factors and modify its
screening tool if necessary.
Table 3
Arizona Department of Economic Security
Division of Children, Youth and Families
Disposition of Child Abuse Calls
Years Ended June 30, 1996 and 1997
1996 1997
Number of calls received concerning
suspected child abuse
59,145 55,645
Number of calls referred to local offices 1 29,070 38,699
Percentage of calls referred to local offices 49.2 69.5
1 This number is higher than the number of reports requiring investigation in Table 2 (see page 10), because after
a call is referred to a local office, it may be determined that it is not within the Division’s jurisdiction or that it is
a duplicate report.
Source: Auditor General staff analysis of Central Intake Monthly Report data from July 1, 1995 to June 30, 1997.
n Characteristics of reports not investigated—Similar to analyzing the report classification
process, the Division should analyze the characteristics of uninvestigated reports. Although
all reports referred to the local offices have been deemed appropriate for investigation and
are required to be investigated per A.R.S. §8-546.01, the Division has a policy that allows
supervisors the discretion to not assign a case for investigation under certain circumstances.
Specifically, Priority 2 through Priority 4 cases can remain uninvestigated as long as the re-port
does not involve a child in CPS custody, a family member involved in an open CPS
case, or a facility licensed by either the Division or the Department of Health Services.1 In
1 Priority 2 cases must be approved for noninvestigation by the District Program Manager.
14
addition, interviews with supervisors revealed that other case-specific characteristics, such
as age of the child, could impact the order in which they assign cases, regardless of priority.
While the Division assumes that cases are not investigated only due to a lack of resources,
supervisors may not be assigning cases to investigators for other reasons, such as the in-ability
to locate the child involved. However, because the Division’s policy does not require
supervisors to document the reason why a case is not assigned for investigation, it is unable
to track which factors lead supervisors to not assign cases for investigation.
Because this policy is in direct conflict with the Division’s statutory mandate to investi-gate
all reports it deems appropriate for investigation, the Division should eliminate
or revise this policy. Recognizing that there may be legitimate reasons why a case goes
uninvestigated, such as the inability to locate the child or family involved, if the Divi-sion
maintains this policy, it should be revised to require supervisors to document the
reasons why cases are not investigated. This information will help the Division deter-mine
what actions should be taken when investigation rates fall below 100 percent.
Recommendations
1. The Legislature should consider providing the Division with additional staff so that it can
investigate all child abuse reports as required per A.R.S. §8-546.01.
2. The Division should assess the recent increase in the number of reports requiring investiga-tions
to determine whether it is likely to continue, and revise its request for additional staff
and resources accordingly.
3. The Division should continue to assess the impact of the Family Builders Pilot Program and
the number of families it will be able to serve.
4. The Division should continue to review and refine its report classification system to ensure
its child abuse hotline more thoroughly screens calls.
5. The Division should eliminate its investigative policy that is in direct conflict with statute,
or revise the policy to require supervisors to document the reason why a case is not as-signed
to an investigator.
15
FINDING II
THE DIVISION’S INVESTIGATIONS ARE
NOT ALWAYS TIMELY OR THOROUGH
In addition to striving to investigate all child maltreatment reports, the Division should ensure
that its investigations are timely and thorough. A review of the Child Protective Services (CPS)
investigation process raised concerns about the timeliness and adequacy of some investiga-tions.
Because the Division is faced with an increasing number of child abuse reports, it needs
to take steps now to improve the quality of its investigations. Therefore, the Division should
provide specialized investigative training and improve its oversight of the investigation proc-ess.
Timely and Thorough
Investigations Are Important
The lack of timely and thorough investigations can actually increase families’ risk of abusive
or neglectful behavior. According to a 1990 U.S. Advisory Board on Child Abuse and Neglect
report, Child Abuse and Neglect: Critical First Steps in Response to a National Emergency, being the
subject of an unresolved investigation creates and sustains uncertainty about the future. This
uncertainty causes anxiety within families, and may stall children’s development. Further,
mandated reporters (i.e., teachers, doctors, etc.) may begin to doubt the system and fail to
continue to report suspected cases of abuse, thus placing children at greater risk of continued
abuse or neglect. The risk is even greater for families who are not offered or do not accept
services following an investigation.
Because CPS investigations are so important in the child welfare process, a file review was
conducted to assess the quality of investigations the Division performed. Auditors’ examina-tion
of the CPS investigation area included a review of a statistically valid random sample of
196 child maltreatment reports referred for investigation in District I during fiscal year 1996.
Files were chosen specifically from District I because it receives more child maltreatment
reports than any other district, and it has the lowest investigation rate statewide. (See Appen-dix
C, page c-i, for further details on the methodology applied in this case file review.)
16
Review Identifies Concerns
Regarding Quality of Investigations
The review of District I investigative files identified several areas of concern regarding investi-gation
timeliness and thoroughness. First, not all investigations were conducted within the
time frames established by the Division. Second, some investigation files were missing, while
others lacked documentation, raising doubts about the thoroughness of investigations. Finally,
not all files were closed in a timely manner, nor were the results of those investigations re-corded
timely.
CPS does not always begin investigations promptly—Although A.R.S. §8-546.01(C)(3) requires
the Division to conduct a “prompt” investigation, the file review and computer data identified
several timeliness problems. First, the Division does not always conduct investigations within
the time frames established by policy. While the required response times vary by report cate-gory,
the Division must investigate even the lowest priority case within 7 days of its receipt.
However, the Division did not respond timely in over 40 percent of the investigated cases
auditors reviewed. As shown in Table 4 (see page 17), 71 of the 167 cases that were assigned
for investigation began after the required response time.1 While 4 of the investigations began
within 1 hour after the response time had passed, 25 others did not start until more than 1
week afterward, often without explanation of the delay. For example, 1 case had no docu-mented
investigative activity until 47 days after receipt of the report, 2 additional cases did not
begin until after the receipt of subsequent reports weeks later, and in 2 other instances, investi-gators
left for vacation before investigating cases, delaying response times by as long as 30
days.
The file review also revealed that the Division does not always accurately record response
times, which raises concerns about the reliability of investigation data recorded on the
Division’s computer. In fact, discrepancies between computer data and caseworker notes
regarding response times occurred in 63 (or 38 percent) of the 167 investigated cases
reviewed. In some instances, the times were recorded incorrectly in the computer. How-ever,
more than a quarter of these cases were recorded as timely even though file docu-mentation
shows the investigation did not meet the Division=s time frames for response.
For example:
A Priority 3 report alleged a mother’s boyfriend had sexually abused her seven-year-old child in
the past. Although the computer indicates CPS responded within two days, implying a timely
response, file documentation shows no case activity took place until five days after report receipt,
when an investigator scheduled a visit with the family. Therefore, computer records indicate a
1 Of the 196 child maltreatment case files chosen for the sample, 182 were recorded as being investigated. How-ever,
only 167 files were reviewed. The District could not locate 11 of the 182 files, and 4 files were eliminated
for other reasons.
17
timely response, when in fact, no one began working on the case until two days after the response
time frame.
Table 4
Arizona Department of Economic Security
Division of Children, Youth and Families
Delayed Response Times for District I Sample of
CPS Investigations by Priority Category
Year Ended June 30, 1996
Priority 1
(2 hours)
Priority 2
(48 hours)
Priority 3
(72 hours)
Priority 4
(7 days) Total
Number of reports assigned for CPS
investigation 16 32 83 36 167
Number of delayed investigations 5 16 41 9 71
Range of delayed response times 1 to
24 hours
5 hours to
47 days
1 hour to
44 days
1 to
6 days
Source: Auditor General staff analysis of a random sample of Child Protective Services fiscal year 1996 investiga-tion
files from District I.
Lack of documentation raises concerns about thoroughness—In addition to concerns regarding
investigation timeliness, missing file documentation raised concerns about investigation
thoroughness. A.R.S. §8-546.01(C)(3) requires CPS to conduct a “thorough” investigation of
every report. Accordingly, for every investigation, Division policy requires investigators to
document their actions and decisions regarding families, as well as the information they collect.
However, for 11 of the cases reportedly investigated in the sample, the Division could not
provide case files to document that an investigation took place. In another instance, the Divi-sion
recreated a case file from an investigator’s memory more than one year after the investiga-tion
took place. Overall, missing and recreated files constituted 6 percent of the statistically
valid file sample.
While most of the 167 investigation files reviewed clearly outlined the steps taken during an
investigation and sufficiently documented the outcome, nearly all lacked documentation
regarding why investigators did not follow policy for some aspect of the investigation. Specifi-cally,
files lacked documentation for:
n Why the investigation deviated from protocol—More than 20 of the 167 investigative
18
files (13 percent) lacked documentation explaining why the investigation was not con-ducted
according to Division standards. For example, although investigation protocol calls
for investigators to interview the victim first, in at least a dozen instances, it appeared chil-dren
were not interviewed until after the case manager had discussed the report with their
parents. In 9 other cases, it could not be established from the file documentation whether
the child was interviewed at any point during the investigation.
n The importance of prior investigations on the current case—Although the Division
requires caseworkers to review prior contacts with CPS as part of every investigation, little
documentation was found to indicate the extent to which prior investigations are reviewed.
According to the 1992 manual Child Protective Services, A Guide For Caseworkers, developed
by the National Center on Child Abuse and Neglect, the existence of previous reports is one
factor that aggravates the risk of imminent harm to children. In fact, approximately one-half
of the families involved in the cases reviewed had at least 1 prior contact with CPS, while
3 had 30 or more. However, in only 1 instance did an investigator summarize the outcome
of previously conducted investigations.
n The findings of the investigation—Due to a lack of documentation, it was unclear
whether all the allegations of abuse or neglect were validated in 13 (or 8 percent) of 167
cases assigned for investigation. Additionally, in 2 instances, the investigator’s written
notes differed from the case outcome recorded in the Division=s computer, thereby affecting
the accuracy of the information retained on these families.
n The number and type of services offered to families—In 15 (or 9 percent) of 167 investi-gated
case files, it was difficult to ascertain what services had been offered to families who
came into contact with CPS. For example, while the caseworker indicated a referral to
community services for the family, the caseworker did not specifically list the services rec-ommended,
nor the problems the services were intended to address.
n Notification of families regarding the investigation outcome—Fewer than 30 files
contained documentation that families had received written notification regarding the in-vestigation
findings and services offered.
Thorough and accurate documentation of CPS investigations is important for at least two
reasons. First, other entities involved in the child welfare process, such as the juvenile
court and the Foster Care Review Board, depend on the caseworker’s documentation of
events to help make important decisions about children involved in the child welfare
process. Accordingly, incomplete or inaccurate information regarding a family can impact
the decisions other individuals involved must make. In addition, recent legislation allows
parents to appeal investigative findings, thereby increasing the importance of complete
and accurate documentation of investigators’ actions and findings.
Cases not always closed promptly after investigation—While case closure is also an important
aspect of the investigative process, some cases were not closed out promptly or recorded on
19
the computer in a timely manner. For example, 1 investigation lasted only 3 days, yet the case
was not closed until 83 days after the investigation. In another instance, an investigation lasted
only 1 day, but was not closed until 63 days after the investigation. Likewise, the investigation
findings (i.e., whether the allegations were validated) are not always entered in a timely
manner. Statutes require the Division to enter investigation findings into the Child Protective
Services Central Registry (CPSCR) within 21 days of report receipt. Moreover, Division policy
requires cases to be resolved within 30 days of report receipt. However, a review of CPSCR
data indicates that more than 2,600 cases received between July 1995 and April 1997 were still
missing information regarding the investigation findings as of June 1997.
In addition to statutory compliance issues, closing investigations in a timely manner is impor-tant
for several reasons. First, as mentioned earlier, unresolved investigations increase the risk
of abusive and neglectful behavior within the families involved. Second, unresolved investi-gations
can potentially impact workload assignments within investigation units. Specifically,
supervisors may not be able to differentiate between completed cases and those actively being
investigated. As a result, workloads may appear higher than they actually are, which may
discourage supervisors from assigning more reports for investigation.
Increasing Number of
Reports May Also Impact
Quality of Investigations
While it is uncertain how workload factors impacted the quality of investigations conducted
in District I during fiscal year 1996, the increased number of child abuse reports during fiscal
year 1997 could negatively impact future investigations. Specifically, the number of child abuse
reports requiring investigations remained fairly stable over fiscal years 1994 through 1996 at
about 28,500. However, as noted in Finding I (see pages 9 through 14) reports increased by 34
percent during 1997, from 28,445 to 38,063. This increase in reports will likely impact investi-gators’
ability to handle all assigned cases in a timely and thorough manner. Discussion groups
held with investigators and supervisors in District I revealed that the number of reports they
receive impacts their ability both to begin investigations on time and to methodically investi-gate
all cases. Some staff also worried that increased pressure regarding investigation rates
could lead to less-thorough investigations.
To ensure that the Division can improve both investigation rates and investigation quality,
additional staff will be needed. Although the Division is developing various staffing plans
to increase the number of caseworkers, as mentioned in Finding I (see pages 9 through 14),
the Division also needs to continue to analyze how several other factors, such as its report
classification system and the characteristics of uninvestigated reports, influence the need
for additional staff.
Division Should Develop Specialized
20
Training and Improve Its Oversight
In addition to assessing its investigative staffing needs, the Division should make changes in
two other areas. First, the Division will need to develop additional specialized training for its
investigators. Second, the Division will need to improve its oversight of the investigation
process to ensure investigations are conducted promptly and appropriately.
Specialized training for investigators needed—The Division should develop specialized
training for its investigators. In discussions with investigators and supervisors, several com-mented
that the core training curriculum was deficient in teaching investigative policies and
procedures. Since 1993, the Division has used a national training model requiring all case
managers to receive 22 days of core training. Although the training model is endorsed by the
Child Welfare League of America and is used by 29 other states, it includes only one day of
material regarding investigations, and does not cover the Division’s specific investigation
policies and procedures. According to the training guide, the investigation training is intended
only as an introduction to the CPS investigation process, requiring investigators to obtain
additional individual training with their supervisors. However, staff agreed that little time is
devoted to developing new investigators, due to the growing number of reports.
Therefore, to help improve the quality of investigations, the Division should develop a spe-cialized
investigative training curriculum. In auditors’ discussions with investigators and
supervisors, several topic items were suggested. First, investigative staff indicated a need for
basic training on how to conduct an investigation, such as how to interview a child and what
indicators of abuse to look for when investigating certain types of cases. Second, investigators
identified a need for policy-oriented training to help them better comply with statutory and
policy requirements.
Investigation oversight needs to be improved—In addition to providing specialized investiga-tive
training, the Division will need to improve its oversight of the investigation process.
Although the Division’s Uniform Case Practice Record used on each investigation since June
1, 1996, requires supervisors to review all investigations, auditors’ file review indicates that
many supervisors were not reviewing cases in a timely manner or ensuring that investigations
were thoroughly conducted. Only 70 of the 167 investigated files (or 42 percent) had been
reviewed in some manner by a supervisor prior to closure by the investigator. Among the
remaining 97 files, approximately one-third were not reviewed for 1 month or more after
closure, while 8 cases contained no documentation indicating a supervisor had ever reviewed
the case. Therefore, in line with national CPS standards, the Division should require supervi-sors
to review all cases prior to closure and in a timely manner. To help ensure this takes place,
the Division should establish a policy that will provide guidance to supervisors on how quickly
they should review cases. Because the Division is statutorily required to enter investigative
findings into CPSCR within 21 days of report receipt, the policy should require supervisors to
review cases close to that time frame.
Additionally, according to the National Center on Child Abuse and Neglect, in their 1994
manual, Supervising Child Protective Services Caseworkers, supervisors should monitor investiga-
21
tion outcomes on a case-by-case basis. In particular, the Center recommends that supervisors
monitor critical casework activities and their outcomes, such as whether investigators conduct
interviews in the proper order, gather complete and accurate information, thoroughly analyze
the information collected, and correctly resolve the case. Therefore, the Division may want to
expand its case review guidelines to incorporate similar factors. The Division should also
require supervisors to document investigative activities that do not meet Division protocol and
the corrective actions taken to rectify those discrepancies.
Finally, as it has done in the past, the Division should routinely conduct random case file
reviews to assess investigation thoroughness and the accuracy of information entered on the
CPSCR. The Division should also consider collecting additional information to better monitor
the investigation process, including:
n Length of time to initiate investigations;
n Length of time cases remain open in investigation; and
n Reason for case closure.
Recommendations
1. To improve the timeliness and thoroughness of investigations, the Division should develop
a specialized investigation curriculum that includes training on investigative techniques,
as well as Division policies and procedures.
2. The Division should require supervisors to review all cases prior to closure and in a timely
manner. To do so, the Division should consider establishing a policy that requires supervi-sors
to review cases within a time frame close to when investigative findings are required
to be entered (i.e., within 21 days).
3. The Division should also consider revising its file review guidelines to include additional
critical casework activities and their outcomes as suggested by the National Center on
Child Abuse and Neglect.
4. The Division should require supervisors to document in the file any investigative activities
that do not meet the Division’s standards and how they will be resolved.
5. The Division should routinely conduct random case file reviews to assess investigation
thoroughness and the accuracy of information entered into its information systems.
6. The Division should collect additional information to better monitor the investigation
process, including length of time to initiate investigations, length of time cases remain open
in investigations, and reasons for case closure.
22
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23
FINDING III
WORKLOAD MEASUREMENT MODEL
NEEDS FURTHER IMPROVEMENT
The Division should improve the system it uses to measure its child protective services work-load.
In an attempt to devise a better method of determining caseworker workloads, the
Division recently implemented a case weighting model that accounts for the level of difficulty
involved in handling the various types of cases rather than just counting the number of as-signed
cases. Although a step in the right direction, the model contains several problems that
hinder its ability to adequately portray the amount of work caseworkers perform. Therefore,
the Division should continue with its plants to refine its case weighting system.
Case Weighting Model
Established to Improve
Workload Management
In 1994, the Division developed a case weighting model to better measure and manage its child
protective services workload. Prior to case weighting, the Division, like many other child
welfare agencies, used case counts (the number of cases each caseworker handles) as a means
of measuring workload and determining staffing needs. However, case counts are not the best
measure of actual workload due to the differences between types of cases and their complexity.
For example, a caseworker handling a case with only one child will likely be able to complete
case management tasks more quickly than a caseworker handling a case with more than one
child. Similarly, a long-term foster care case plan will likely require less intensive oversight
than a case plan of return home or adoption. Recognizing this, the Division sought to imple-ment
a more accurate means of assessing workload and hired a consultant to design a case
weighting model. The concept behind case weighting is to measure the effort workers expend
when managing cases and assign “weights” to cases based on those measurements.
Weaknesses in Current
Case Weighting Model
Although the Division=s case weighting model can provide some valuable information, its
ability to serve as an effective workload management tool is limited for several reasons. First,
the underlying methodology used to design the model contains many flaws, including an
inadequate number of cases by which to establish standards, wide variation in information
caseworkers reported, and no consideration of the differences between types of caseworkers.
24
Additionally, the Division excluded several important factors that impact a caseworker’s
ability to manage his or her caseload.
Case weighting model based on time studies—In designing the case weighting model, the
Division=s consultant conducted two time studies. The purpose of conducting the time studies
was twofold: 1) to create a mechanism for more equitable case assignments, and 2) to deter-mine
the number of caseworkers needed to manage the current workload. These studies were
an essential step in capturing the amount of time workers spend conducting actual casework.
In conducting the time studies, caseworkers from across the State were asked to record, in 15-
minute intervals, the specific tasks they were performing. This information was then compiled
to determine a time estimate to adequately complete tasks for the various case types. Although
both time studies used the same basic methodology, there were some significant differences
between them:
n 1994 study —The Division=s first attempt to design a case weighting model involved a
sample of 200 workers over a one-week period. The study categorized CPS’ cases into 6
types: investigation, in-home care, substitute care, purchased care, adoption, and family re-source
development. Substitute care cases, requiring an average of 5.8 hours per month of
caseworker time, was the category chosen to represent the standard by which all other case
types were compared and was given a case weight of 1. Case categories that took longer
would be given a higher weight, while case types that took a lesser amount of time were
given a lower weight. The Division determined that, based on the amount of time available
in a month, caseworkers could handle a caseload weight of 19.
n 1996 study—This study was conducted to incorporate the effects of casework practice
changes, such as the addition of a computer-based case recording form. This study also
sampled approximately 200 caseworkers, but was conducted over a 1-month period. In ad-dition,
to better capture the variation in case work, the consultant expanded the case type
categories from 6 to 16.1 Because of the expanded case type categories, the 1996 time study
identified licensed foster home cases, a form of substitute care, as the most common case
type. While substitute care cases (the standard to which other cases were compared in 1994)
took an average of 5.8 hours per month, licensed foster home cases required an average of
8.9 hours per month. However, because the Division wanted to maintain a caseload weight
standard of 19, to determine the new weight of 1, the Division took the total number of
hours available for casework in one month (i.e., 121 hours) and divided it by 19. This re-sulted
in increasing the value of a caseweight of 1 from 5.8 to 6.37.
1 The 16 categories used in the 1996 time study were basic investigation, investigation with placement, court-ordered/
private investigation, in-home services (non-court related), in-home services with dependency, shelter
care, unlicensed relative care, licensed foster home, unlicensed non-relative care, group home/residential, inde-pendent
living, Title XIX out-of-home care, adoption, family resource development, interstate compact, and run-away.
25
Time studies suffered from methodological problems—Both time studies contained methodo-logical
flaws that hinder the usefulness of the case weighting model. An analysis of the meth-ods
used to construct the studies revealed the following problems that ultimately impact the
Division=s ability to rely on the case weighting model as an accurate measure of workload:
n Too few cases used to establish standards—The primary methodological problem was
that the number of cases included in the study was not sufficient. The sampling method did
not produce enough workers from the rural districts and did not produce enough cases to
accurately set standards for many of the 16 case type categories. Case weights for 9 catego-ries
were developed using data from 20 or fewer cases, with 3 categories using as few as
10 to 12 cases.
n Too much variation in data resulted in nonrepresentative standards—Because there
were wide variations in data collected between districts, the consolidation of the data into
averages may have resulted in some nonrepresentative standards. For example, the average
time recorded by caseworkers to handle “investigation with placement” cases was 14.3
hours per month, but actual times ranged from 6 hours to almost 24 hours per month.
n Differences between types of workers not reflected—Although the time study estab-lished
separate case categories to capture investigative work, a separate analysis was not
conducted between investigators and ongoing caseworkers. However, duties vary suffi-ciently
between the two, with investigative workers conducting more tasks per each case
in a shorter period of time. Because of this, the Director of Standards from the Child Wel-fare
League of America suggests that investigative workers should handle fewer cases than
ongoing workers. Thus, case weights for investigative workers should be analyzed sepa-rately.
Several factors not considered—After completing the time study and developing the case
weights, the Division overlooked several factors that can significantly impact caseload com-plexity.
Discussions with investigative and ongoing caseworkers across the State revealed the
following factors that currently impact the amount of time required to handle certain cases:
n Increased number of delinquency cases—In addition to being assigned court-ordered
dependency cases, more and more juvenile court judges are placing children determined
to be dually adjudicated (i.e., dependent and delinquent) under the Division=s protection.
According to caseworkers, these children have a tendency to run away and/or present be-havioral
problems that can require an extensive amount of their time.
n Cases involving substance abuse—Many of the children in foster care have been re-moved
from their homes due to their parents’ substance abuse problems. Because the Divi-sion
must make efforts to reunite families, caseworkers must try to find treatment for the
parents.
26
n Children needing behavioral health services—According to caseworkers, many cases
involve children with behavioral health problems. As with delinquent children, these chil-dren
are often difficult to place and need services that are difficult to obtain in a timely
manner, if at all. Therefore, caseworkers can spend a significant amount of time trying to
identify services and find appropriate placements for these children.
n Cases involving multiple children—In cases with multiple children, siblings are often
located in separate placements, requiring caseworkers to coordinate multiple visits with
each child as well as allowing visits among the siblings and their parents. Currently, the
Division allows for an additional case weight for cases with multiple children. However,
a case with three or more children receives the same weight as a case with only two chil-dren.
n Travel time—Caseworkers also report that a great deal of time is spent on travel related
to their caseloads. For example, the best placement for a child may not be close to the
worker’s office or the parents’ home. Therefore, the worker may have to drive across town
or even out of the county to visit a child.
When one or more of these factors are present, case complexity increases, yet it is not reflected
in the case weight. The following example illustrates the inequity that can result in case
weights when certain case complexity factors are not considered:
n This case involves four children suffering from the effects of neglect. One child, with severe
medical and behavioral problems, was hospitalized for an extended period. Meanwhile,
his three siblings were placed in two separate foster homes on the opposite end of town
from the caseworker’s office. Further, both parents were substance abusers who failed to
stop using drugs while the caseworker was making efforts to reunite the family. To manage
this case, the caseworker had to attend weekly meetings for the hospitalized child, search
for a placement for him upon discharge, and drive across town to conduct home visits with
his siblings. Meanwhile, the caseworker also had to arrange various services for the family
to ensure that diligent efforts were made to reunite them. However, this case received a
case weight only slightly higher than a case with two children in a stable foster care home
with no complexity factors present.
Case Weighting Model Needs
Further Refinement
The Division needs to continue to refine its case weighting model to ensure that it can effec-tively
manage its workload. When the Division conducts its planned updated time study, it
needs to overcome methodological problems and consider other case complexity factors for
analysis. Additionally, the Division should consider reinstituting the use of case counts to
27
provide additional insight into workload.
Updated time study can improve utility of case weighting model— Because the Division’s case
weighting model was initially developed as, and can still be an effective workload manage-ment
tool, the Division should follow through with its plans to conduct a revised time study.
The Division, recognizing the need to periodically review and update its case weighting
model, plans to conduct another time study in 1998 to reflect the changes resulting from im-plementation
of its new automated case management system. Therefore, when conducting its
next time study, the Division should take into consideration the methodological concerns
identified during this audit. First, the Division should increase the number of caseworkers
sampled and the corresponding number of cases reviewed. This improvement alone will
provide the Division with the information it needs to analyze the differences between rural and
urban districts as well as between caseworker types. To ensure an adequate number of cases
are reviewed, the Division should attempt to have at least 25 cases, and ideally 50 or more
cases, in each of the 16 case type categories. Additionally, the Division should ensure that its
sample includes sufficient representation from both investigative and ongoing caseworkers.
Moreover, the Division should seek to analyze why any wide variations in data occur, and
consider using a statistic other than an average (such as the median or mode), as a basis for case
weights if the wide variation cannot be explained.
Although increasing the sample size alone will offer a significant improvement over the exist-ing
case weighting model, the Division should also consider analyzing other factors that may
increase case complexity. As mentioned earlier, several factors, such as the increased number
of delinquency cases, cases involving substance abuse, and children needing behavioral health
services, may affect caseload complexity. If the Division incorporates such factors into the time
study, it can analyze how these factors affect workload. If the time study proves these factors
increase case complexity, the Division should consider (as it has done with the number of
children in a case) providing additional allowances to its case weights.
Case counts can aid in analyzing workload—The Division should resume case counts for use
in conjunction with case weights. In August 1996, Division officials decided to stop collecting
case count information since they believed case weights were a sufficient measure of workload.
However, case count data can give the Division a clearer picture of its workload by providing
the actual number and type of cases currently in the system. Further, the Division can use case
counts to determine whether changes in case weights are due to an increased number of cases
or increased case complexity. Additionally, combining case counts with case weight informa-tion
when reporting to outside groups may provide a more meaningful description of case-workers’
workload.
28
Recommendations
1. To ensure that its case weighting model more accurately portrays caseworker workload,
the Division should fulfill its plans to conduct another time study.
2. When conducting its next time study, the Division should select a large enough sample to
allow it to analyze differences that may occur due to geographic location or caseworker
type. If wide data variation continues to exist in each case type category, the Division
should also consider using a statistic other than the average when calculating case weights.
3. The Division should also consider incorporating into its next time study additional factors
affecting case complexity, such as those dealing with delinquent children, substance abuse
and behavioral health issues, multiple children, and travel time.
4. The Division should consider using case counts in conjunction with case weight informa-tion
to further enhance its workload analysis and reporting abilities.
29
FINDING IV
THE DIVISION’S OVERSIGHT OF GROUP
AND SHELTER HOMES IS INADEQUATE
Despite its responsibility to license group and shelter homes, the Division currently does not
provide adequate oversight of these facilities. A review of licensing files revealed that the
Division allows some homes with licensing violations to continue operating, which may
ultimately impact the safety of children placed in those facilities. Therefore, to ensure group
and shelter homes correct licensing violations, the Legislature should consider granting the
Division the authority to impose civil penalties. However, the Division should also use its
current authority to suspend or revoke the licenses of agencies who are unable or unwilling
to correct serious problems. In addition, the Division will need to develop policies and proce-dures
and redirect its licensing staff activities to ensure that it provides adequate oversight.
Division Responsible
for Licensing Group
and Shelter Homes
As mandated by A.R.S. §8-505, the Division is responsible for licensing child welfare agencies
that provide supervised care for children adjudicated as dependent or delinquent.1 These
agencies= facilities (often referred to as group and shelter homes) house not only children in
CPS custody but also children under the custody of other entities, including the Department
of Juvenile Corrections, the Supreme Court’s Administrative Office of the Courts, or other
states. Before issuing a license, the Division is required to investigate an agency’s activities and
standards of care, its financial stability, the character and training of its staff, and the agency’s
ability to safely care for children. If the agency meets licensing standards, the Division issues
a regular license for a period of one year. The Division may also issue a provisional license for
a period of six months to any agency whose services are needed but which is temporarily
unable to conform to the established standards of care. The Division can also suspend, revoke,
or deny a license if an agency fails to meet or maintain the established licensing standards.
As of April 30, 1997, the Division licensed approximately 64 agencies with a total of 183 facili-ties
and approximately 2,935 beds available for child placement. These facilities provide shelter
1 As of July 1995, the Department of Health Services assumed the responsibility for licensing those institutions that
provide supervised mental health treatment to adults and children, including children who have been adjudi-cated
as delinquent or dependent.
30
for approximately 1,000 children within the Division=s custody as well as for additional chil-dren
referred from other entities.
Group and Shelter Homes
Inadequately Monitored
While many children are regularly placed in group and shelter care facilities, the Division=s
oversight of such facilities is inadequate and may ultimately impact the safety of those chil-dren.
To assess the adequacy of the Division=s oversight, a judgmental sample (that is, these
agencies were not selected randomly, but were chosen because of concerns about their ability
to care for children) of 16 agencies that had been the subject of at least 2 child abuse and neglect
reports during calendar year 1996 was reviewed.1 According to Child Protective Services
Central Registry (CPSCR) records, combined, these agencies accounted for a total of 74 child
abuse reports during 1996. Most of these reports involved allegations of neglect or physical
injury due to children being inadequately supervised. Moreover, according to CPSCR data, 19
of these reports were found to be valid. The Division=s oversight of these 16 facilities was
inadequate for the following reasons:
CPS reports were not adequately documented—The Division did not adequately document
concerns raised about the agencies= ability to safely care for children. Specifically, the Division
did not adequately document in the licensing files all the child abuse reports received or the
results of the CPS investigations conducted to assess the allegations of these child abuse re-ports.
2 Further, the 16 agencies’ licensing files did not always contain documentation on how
agencies should correct any safety issues that were identified in investigative reports, such as
inadequate supervision or improper restraint techniques. Although memos to agencies noting
a need for a corrective action plan were placed in some files, these corrective action plans were
not routinely maintained in the files and it is unclear if the plans were ever established and
monitored. Additionally, the Division did not document whether it considered these child
abuse reports during the licensing renewal process. For example, none of the agencies= licens-ing
renewal packages documented concerns about these CPS reports or investigations. While
it may be appropriate to disregard reports that were determined to be invalid, it is unclear why
valid reports are not considered when determining whether licenses should be renewed.
Provisional licenses issued inappropriately—The file review also revealed that, in some
instances, the Division issued provisional licenses inappropriately. A.R.S. §8-505 indicates a
provisional license may be issued to any agency whose services are needed but which is
temporarily unable to conform to the established standards of care. However, the deficiency
must be minor, correctable, and not potentially injurious to children in the agency’s care. In
1 As mentioned earlier, an agency may have several facilities. These 16 agencies had a total of 58 facilities.
2 Reports of agency child abuse and neglect statewide are investigated by two CPS investigators located in District
I (Maricopa County).
31
addition, the provisional license may be issued only for a period of six months and may not
be renewed. Nonetheless, the Division allowed two agencies to alternate between regular and
provisional licenses without adequately addressing the problems that originally indicated a
provisional license was necessary. In addition, some of the problems were potentially injurious
to children. For example, two agencies= personnel files lacked documentation regarding staff
medical examination results, reference checks, or fingerprinting and criminal records clearance.
One of these agencies in particular seemed to be deficient in many areas, yet as demonstrated
below, continued to maintain licensure:
n Agency A was placed on provisional status three times over a three-year period (between
April 1994 and April 1997) for a variety of reasons, including lack of an annual financial
audit and fire inspection, personnel and children’s files lacking required documentation,
and a facility in need of extensive repair. At the end of each of these provisional periods,
the agency returned to regular status. However, little documentation appears in the
agency’s licensing file regarding what corrective actions, if any, were actually taken to ad-dress
the violations that resulted in it being placed on provisional status. In addition,
throughout this three-year period, several concerns were raised about the agency’s ability
to safely care for children. For example, during 1996, this agency was the subject of four
child abuse reports ranging from a lack of supervision to physical abuse. Three of these re-ports
were validated upon investigation. In addition, in 1995 a caseworker filed complaints
with the licensing unit alleging that the agency kept a child without authorization, lacked
supervision and structure, and allowed children to climb on the facility’s roof.
Ultimately, the safety and welfare of children placed in these facilities is compromised when
the Division allows problem homes to continue operating without addressing potential safety
issues.
Division Should Improve
Oversight of Group and
Shelter Homes
The Division needs to improve its oversight of group and shelter homes. To help the Division
in this matter, the Legislature should consider strengthening the Division’s current enforce-ment
authority by providing it with the authority to impose civil penalties. However, the
Division may need to use its current authority to suspend or revoke some agencies= licenses.
In addition, the Division should develop policies and procedures to help guide its monitoring
activities, and should redirect the licensing staff’s activities to ensure monitoring activities are
performed.
Additional legislative authority may be needed—To ensure agencies comply with licensing
standards, the Legislature should consider granting the Division additional authority under
A.R.S. §8-506 to impose civil penalties against agencies that fail to address licensing problems.
32
The Division currently has the authority to issue provisional licenses for a period of six months
when an agency is needed but is unable to conform to the established standards of care. How-ever,
as previously mentioned, in some instances, these provisional licenses have been issued
inappropriately. In addition, it does not appear that placing an agency on provisional status
provides it with adequate incentive to comply with licensing standards.
Therefore, to give agencies additional incentive to comply with licensing standards, the Divi-sion
may need the authority to impose civil penalties similar to that provided to the Depart-ment
of Health Services (DHS). As a part of DHS= responsibility to license health care institu-tions
and child day care programs, it has the authority to impose civil penalties. For example,
A.R.S. §36-891 provides DHS the authority to impose a fine of up to $100 per day for each day
it documents a licensing violation has occurred at a childcare facility.
Some licenses may need to be suspended or revoked—Because the Division has a responsibility
to reasonably ensure the safety of children in its care, it may need to suspend or revoke some
agencies= licenses. While a licensing specialist indicated that the preferred method is to work
with agencies to correct violations, some agencies may not fully resolve the licensing deficien-cies.
Therefore, the Division should use its licensing authority to suspend or revoke the licenses
of those agencies that do not promptly correct violations that may endanger the safety of
children in their care. For example, the Division should have suspended or revoked the license
of one agency that displayed serious ongoing concerns from the time it was initially licensed
in August 1994. Specifically, this agency was the subject of 14 child abuse reports and more
than 50 incident reports during 1996 alone.1 Although the agency had responded with some
corrective action plans, it was never able to fully comply with the Division=s licensing require-ments.
Due to the seriousness of the violations, the Division finally removed the CPS children
from this facility and canceled its child placement contract with this agency. However, the
Division never suspended or revoked this agency’s license, so other entities, such as the De-partment
of Juvenile Corrections or other states, may have continued to place children in the
facility.
Policies and procedures needed—To further guide its oversight of shelter and group homes,
the Division should develop policies and procedures. Although the Division has both statutes
and administrative rules regarding the licensing process, neither provide specific guidance on
how to conduct monitoring or how to follow up on licensing violations. Therefore, by estab-lishing
policies and procedures, the Division can better ensure its licensing staff provide
adequate oversight. Specifically, these policies should address when provisional licenses can
be issued and whether it is appropriate in any instance to place an agency on provisional status
more than once. In addition, policies should provide specific guidelines regarding the type of
licensing violations that warrant a suspension or revocation, what type of oversight the Divi-sion
should provide, how and when monitoring activities should occur, and the level of docu-
1 An incident report must be prepared by the agency when a child is injured or runs away.
33
mentation needed to demonstrate adequate oversight. These policies should also address how
the licensing unit should handle reports of child abuse it receives concerning licensed agencies.
Division should ensure licensing unit’s activities include monitoring—Ultimately, to ensure
homes are adequately monitored, the Division should require that the licensing staff dedicate
a sufficient amount of time to monitoring activities. This unit, consisting of a manager and 6
staff, is responsible for annually licensing the 64 agencies with their 183 facilities, as well as
reviewing new applications, conducting on-site visits, and maintaining licensing files. While
auditors did not evaluate the effectiveness and efficiency with which licensing staff perform
their tasks, it appears that these 6 staff should be able to adequately monitor the 64 agencies.
At a minimum, staff could focus their monitoring efforts on those agencies that continue to
exhibit problems. For example, the Division=s oversight could focus on agencies that have been
the subject of one or more valid child abuse reports. With regular monitoring, the Division
could assist agencies in correcting deficiencies more promptly, or revoke agencies’ licenses
more swiftly.
Recommendations
1. To strengthen the Division=s enforcement authority, and to provide agencies with a further
incentive to comply with licensing standards, the Legislature should consider granting the
Division the authority to impose civil penalties under A.R.S. §8-506.
2. The Division should develop policies and procedures regarding monitoring, including
those which:
n Address when provisional licenses can be used and whether it is appropriate in any in-stance
to place an agency on provisional status more than once;
n Provide guidelines regarding the type of licensing violations that warrant a suspension
or revocation; what type of oversight the Division should provide; how and when
monitoring activities should occur; and the level of documentation needed to demon-strate
adequate oversight; and
n Address the steps needed when it receives reports that a group care home or shelter has
abused or neglected children.
3. The Division should ensure that its licensing staff adequately monitor group and shelter
homes by incorporating regular monitoring activities into their work schedules.
34
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35
FINDING V
CURRENT FOSTER HOMES UNABLE
TO MEET CERTAIN PLACEMENT NEEDS
The Division needs to improve its efforts to recruit and retain foster family homes to ensure
children are quickly moved from temporary placements into more permanent foster care
settings. Currently, caseworkers have difficulty finding appropriate placements in certain areas
of the State as well as for children with special needs. As a result, children are remaining in
temporary shelters for longer periods, which is both expensive and potentially unsafe. To
rectify these problems, the Division will need to establish mechanisms for assessing overall
foster home demands and for helping local offices recruit and retain foster parents.
Background
Pursuant to A.R.S. §8-223, CPS is required to take temporary emergency custody of a child if
the child is “suffering or will imminently suffer abuse or neglect.” Upon initial removal, a child
is typically placed in a temporary emergency placement, which is generally a shelter care
facility or receiving home. Within 48 hours of a child’s removal, CPS reviews the case to deter-mine
if continued out-of-home placement is necessary. If so, once a juvenile court judge orders
a dependency action, the child’s caseworker is responsible for assessing the child’s needs and
attempting to provide a placement in the “least restrictive” setting available. The child typically
remains in the initial temporary emergency placement until the caseworker can locate a more
appropriate placement.
The number of children requiring placements is increasing. As of June 30, 1997, 6,686 children
statewide resided in out-of-home care. This represents an 11 percent increase over the 6,014
children in out-of-home care on June 30, 1996, and a 19 percent increase over the 5,624 children
recorded on June 30, 1995.
Shortage in Availability of
Certain Types of Foster Homes
Although the Division may initially appear to have a sufficient number of homes to meet its
placement needs, these homes often do not match the needs of children ready for placement.
As a result, children are delayed from moving into less costly and more permanent placements
that can better meet their individual needs.
The number of vacant spaces is deceiving—Although the number of licensed foster homes is
36
increasing and there are vacant spaces available, many children cannot be placed in those
homes. During 1996, the total number of foster homes increased by 118, with 467 homes be-coming
newly licensed and 349 homes leaving the program. Similarly, the Division again
increased the number of licensed homes by 47 between January and March 1997. However,
despite the net increase in the number of licensed foster homes, the Division was unable to use
many of these spaces to help meet its placement needs. For example, as of March 31, 1997, there
were 1,902 licensed foster homes with more than 1,200 spaces vacant. Placement specialists and
caseworkers noted three primary reasons why it is difficult to match children with available
homes:
n Many homes will not accept certain children—A match between available spaces and
children is not always possible due to the types of children foster families may be willing
to accept. For example, many foster families are unwilling to accept teenagers and large
sibling groups.
n Difficulty finding placements for children with special needs—Similarly, many foster
families may be unable to adequately care for children with special medical or behavioral
needs, which require the foster parent to have special training or skills. According to dis-trict
placement specialists, placements for children with special medical and behavioral
needs are needed the most, yet are the most difficult to find.
n Too few homes where the demand is greatest—Some communities do not have enough
homes to meet the Division=s placement needs. For example, foster home shortages are par-ticularly
acute in the State=s two metropolitan areas. Specifically, as of December 31, 1996,
81 percent of out-of-home placements were within Maricopa and Pima Counties, while
only 56 percent of the available spaces were located within these two districts.
Movement from shelter care to foster family home care often slow—Because the Division is
not always able to match children with appropriate foster homes, the number of children in
more restrictive temporary settings is increasing. As illustrated in Table 5 (see page 37), the
average number of children in shelters or receiving homes during April to June 1997 was 50
percent higher than the year before. Moreover, children are remaining in these temporary
shelter placements for longer periods of time, despite a statutory requirement that children
cannot remain in these facilities more than 21 days without a juvenile court order.1 For exam-ple,
52 percent of the children placed in shelter care facilities during the third quarter of fiscal
year 1997 had been there more than 21 consecutive days. In many instances, these delays are
not attributable to any special needs of the children. For instance, 36 percent of these children
had no identified special placement needs. CPS placement specialists, child advocates, and
Division service providers have noted that this trend is increasing.
1 Any juvenile court orders extending placements beyond the 21 days must be reviewed weekly, beginning one
week from the date of the order.
37
Table 5
Arizona Department of Economic Security
Division of Children, Youth and Families
Quarterly Comparison of Average Number of Children
in a Shelter or Receiving Home
Years Ended June 30, 1996 and 1997
Quarter 1996 1997
Percentage
Increase
July 1-September 30 375 433 15%
October 1-December 31 395 491 24
January 1-March 31 356 492 38
April 1-June 30 383 574 50
Source: Foster Care Program Activity Report for years ended June 30, 1996 and 1997.
Delays in permanent placement have several consequences—In addition to the rising number
of children remaining in shelter care, several other consequences can result when appropriate
placements are not available in a timely manner. First, the Division incurs a significant cost
when it must continue to place children in temporary shelter care. The Division pays an aver-age
of $17 per day per child for family foster home placements, compared to an average cost
of $80 to $90 per day for group home or shelter care. Children also remain in inappropriate
settings for longer periods. Caseworkers indicate that shelter or group home placements are
more limited in the type of care provided and their ability to meet some children’s special
needs.
Finally, placing an increasing number of children in temporary settings can be potentially
unsafe. Division personnel have indicated that these settings are often the only locations
available to take children with behavioral problems or children who have been adjudicated as
both delinquent and dependent. Consequently, dependent children remain in the same settings
with individuals who may be dangerous. However, with the constant turnover of children in
shelters and group homes, staff may not always be aware of potentially violent youth placed
with younger dependent children. For example, a review of group care agencies’ licensing files
revealed an incident in which three children threw a blanket over three other children, hitting
and kicking them. The victims received substantial injuries to the arms, back, chest, ribs, and
head. Moreover, within months, this same shelter experienced a serious fire that was started
by a child with a long history of arson. In both cases, the perpetrators were children who were
dually adjudicated delinquent and dependent.
38
Division Must Strengthen
Recruiting and Retention Efforts
To ensure children are moved promptly into appropriate permanent foster care settings, the
Division will need to enhance its ability to recruit additional foster homes, assess and coordi-nate
placement needs, and retain existing foster homes.
Better coordination of foster home recruitment efforts needed—The Division can do more to
coordinate foster home recruiting efforts throughout the State. Currently, new foster home
recruitment is centered largely on efforts at the district level with each individual district (or
a contractor hired by the district) being responsible for recruiting homes to meet their place-ment
needs. However, districts receive minimal support from the Division=s central office.
Without centralized recruitment oversight, districts lack knowledge about which recruitment
efforts work best. For example, districts run advertisements using newspapers, billboards, and
tee shirts, and they make presentations to groups, forums, and community fairs. Yet, the
Division has not given anyone the responsibility for monitoring these approaches and deter-mining
which strategies are the most effective. Moreover, statewide recruitment efforts have
been limited. Although the Division recently initiated a statewide recruiting effort, known as
the “Clouds Campaign,” implementation of the campaign was conducted at the district level
rather than by the central office. As a result, the campaign has not been run in all districts and
awareness of the campaign varies by district.
Due to the variations in how foster home recruitment is currently being conducted, the Divi-sion
should gain a better understanding of overall recruitment needs. Both district and con-tracted
recruitment personnel indicated a need for a centralized mechanism for exchanging
information between districts concerning successful recruiting efforts. Because the Division is
currently establishing a central office position to coordinate foster home recruiting, it should
consider using this position for:
n Building stronger recruitment programs—Professionals believe that successful foster
parent recruiting programs educate communities about foster care and involve the com-munities
in supporting foster parents and recognizing the service they provide. Using fos-ter
parents as recruiters and supporting foster parent associations contributes to successful
foster parent recruiting. Additionally, professionals emphasize a need to use positive re-cruiting
themes that realistically portray the difficulties of foster parenting. Although the
Division currently uses foster parents to provide some orientation and training classes, it
can further increase foster parents’ involvement by including them in Division foster care
recruitment efforts.
n Drawing upon additional sources of foster parents—The National Foster Parent Asso-ciation
suggests two potential sources sometimes overlooked in recruiting effortsCsenior
citizens and former foster children.1 In addition, retired medical personnel could be par-
1 U.S. General Accounting Office: Foster Parents, Recruiting and Preservice Training Practices Need Evaluation, August
39
ticularly helpful for foster children with special medical needs.
n Sharing information about what works—The Division should formalize and facilitate
interaction between district recruiters. Additionally, the Division should monitor innova-tive
efforts used by districts and should communicate the results of such efforts throughout
the State.
Better tracking of foster home availability and needs—The Division should also do more to
collect and analyze information about the needs of children entering the CPS system and the
supply of foster homes available. The Division=s current automated information systems do not
contain information on the number of spaces available in each foster care home or facility, the
services each provider offers, or the ages of children providers will accept. Moreover, other
important information maintained on the systems is often incomplete. Although the Division
is developing a new computer system that should be able to capture this type of information,
the Division will need to ensure the data entered into the system is complete and accurate. (See
Finding VI, pages 41 through 44.)
Once the Division can accurately compare the demand for placements to the supply available,
it can use this information to focus recruitment efforts. For example, the Division could use this
information to develop specific statewide recruitment goals, or the districts could use this
information to target their recruitment efforts. The Division may be able to help in recruiting
for these needs by establishing a 1-800 foster care inquiry line, or by paying for statewide
media campaigns and public service announcements. This would then allow districts to focus
on initiatives to recruit for special needs within their own areas.
Increased efforts to retain existing foster homes—A final step toward meeting placement needs
is through expanded efforts to retain current foster families. Although districts collect informa-tion
on the reasons why foster families leave the system, it does not appear that the Division
uses this information to increase foster home retention. For example, during fiscal year 1996,
the Division determined that adoption of the foster child(ren) was the primary reason Arizona
foster families left the system. Although it is not clear why this is the case, it may be that, after
adopting a child, families may feel they are unable to care for additional children. However,
a national study found that many adoptive parents were still eager to take foster children into
their homes.1 In addition to adoptions, the president of the state Foster Parent Association
1989.
1 U.S. Department of Health and Human Services, The National Survey of Current and Former Foster Parents, August
1993.
40
indicates that many foster parents become frustrated with the lack of training and poor rela-tionships
with case managers and ultimately leave the system. Therefore, following the rec-ommendations
of the Child Welfare League of America, contained in their 1995 Standards of
Excellence for Family Foster Care Services, the Division should seek to learn more from and about
the families who are leaving the system, and use this information to establish retention goals
and track actual retention rates.
Recommendations
1. The Division should do more to coordinate foster home recruitment efforts throughout the
State by dedicating a central office staff person to help build a stronger recruitment pro-gram,
draw upon additional sources of foster parents, and share information with the dis-tricts
on what types of recruitment strategies work best.
2. The Division should also do more to collect and analyze information about the needs of
children entering the CPS system and the supply of foster homes available, and use this in-formation
to develop specific statewide recruitment goals.
3. The Division should also increase its efforts to retain existing foster homes, including
establishing annual retention goals and tracking actual retention rates.
41
FINDING VI
DATA INTEGRITY SHOULD REMAIN A
CONTINUOUS PRIORITY FOR THE DIVISION’S
NEW INFORMATION SYSTEM
As the Division continues with its implementation of a new comprehensive management
information system, it should remain committed to ensuring the accuracy and reliability of the
system’s information. The Division’s two previous systems suffered from numerous problems,
including inaccurate entries, untimely inputs, and incomplete data, that limited their ability
to provide reliable and complete management information. Therefore, to ensure the Division’s
new data system does not encounter similar problems, the Division should continue its efforts
to monitor data integrity and identify system-training needs.
History of Division’s
Computer Systems
The Division has relied on two primary computer systems to record information about its child
protective services program. Its first system, the Child Protective Services Central Registry
(CPSCR), was brought on-line in 1985 to register all reports of child abuse and neglect. Infor-mation
recorded for each report includes initial allegation(s), disposition (i.e., whether the
report was investigated), and the result of the investigation (i.e., whether the child abuse report
was found to be valid). In 1991, the Division established a new computer system, the Arizona
Social Services Information and Statistical Tracking System (ASSISTS), to provide better man-agement
information about its child protective services function. Although this system includes
some information on CPS children, such as age, sex, and case plan goal (e.g., return to family,
adoption, etc.), it is primarily used as a payment processing system. Therefore, the system
primarily records information on the services authorized and paid for by the Division for
children and families with ongoing CPS cases.
The Division is currently implementing a new information system, the Children’s Information
Library and Data Source (CHILDS). This system is intended to capture information on the
entire CPS process by incorporating the functions handled by CPSCR and ASSISTS. Addition-ally,
this information system will capture data typically contained only in the caseworkers’
files, such as case notes and the number and types of services offered to families. The Division
anticipates it will complete system implementation by the end of 1997.
42
Data Problems Limited
Usefulness of Systems
Numerous data problems have historically jeopardized the reliability and accuracy of the
information contained on the Division’s two primary data systems—CPSCR and ASSISTS.
Specifically, a 1991 Auditor General study (Report No. 91-6) found that CPSCR data was
improperly classified in some instances, and improperly coded in others. The report also
cautioned the Division that similar data problems might affect the usefulness of its new infor-mation
system—ASSISTS. In fact, a 1994 Auditor General review (Report No. 94-L9) found that
many of the data problems identified in 1991 continued to exist, and also noted that the accu-racy
of the data contained on ASSISTS was suspect because workers were not required to input
information into all data fields. Both systems continued to suffer from inaccurate coding,
untimely inputs, and incomplete data at the time of the Auditor General’s review. Although
the Division acknowledged these problems, it may have chosen not to expend significant
resources to rectify them due to its planned implementation of CHILDS.
However, the Division's ability to obtain important information has been affected because it
did not resolve these problems. For example, the Division was recently interested in the num-ber
of children adjudicated both delinquent and dependent because these children may present
needs the Division is unable to fulfill, and because these children can pose a threat to others
(e.g., dependent children, foster families, and staff). Although ASSISTS has a data field to
capture this information, caseworkers do not consistently complete it. Therefore, in its attempt
to identify the number of dually adjudicated children, the Division had to obtain manual
counts from each district. Additionally, the Division is currently unable to determine what
services it has offered to families and whether these services have prevented further abusive
situations.
Division Efforts to Ensure
Data Integrity Should Continue
As the Division completes CHILDS’ implementation, it should ensure that it continues to
monitor data integrity. During implementation of CHILDS, the Division took several steps to
address the problems encountered by CPSCR and ASSISTS. However, to ensure the Division
continues to monitor data integrity following implementation, it should continue with its plans
to develop and formalize a quality assurance program.
Division took steps to address previous causes of data problems—In designing the new
system, the Division ensured that it contained several quality control features to help address
the problems previously identified. One significant type of quality control is the use of on-line
edits. For example, the system contains mandatory fields that require caseworkers to enter
specific information before the case file can be saved, and validation checks that require case-workers
to enter only specified values or codes. These system edits will help prevent inaccurate
43
or incomplete data entries from occurring. In addition to on-line edits, the system also contains
several security features that will limit individuals’ access to the system and prevent data from
being modified unless approved by a supervisor. Finally, the Division took several steps to
ensure that the data entered into the system was accurate. During the data conversion process,
caseworkers were asked to review all the case file data that would be entered into CHILDS.
While conversion workers were entering the data into the system, caseworkers received three
days of training on how to use CHILDS. After training, caseworkers were required to re-verify
the case file data and only then was the data fully transferred onto CHILDS.
As of October 1997, the Division had converted approximately 55 percent of the statewide CPS
offices to CHILDS. Although the Division plans to complete conversion by December 1997,
ASSISTS is still handling provider payments. The Division is delaying conversion of the
ASSISTS’ payroll component in order to conduct additional data integrity testing. However,
even when CHILDS is fully implemented, the Division will need to maintain both CPSCR and
ASSISTS in “read-only” format for several years so historical information is available, as
required by law.
The Division needs to follow through with its plans—The Division recently announced its
plans to continue monitoring the integrity of the data entered and maintained on CHILDS.
However, at this time the plan appears to be in the very early stages of development. The
Division could not provide us with sufficient documentation outlining the specific monitoring
activities it would conduct, or how frequently it would conduct these activities. Moreover,
although the Division has indicated that its Evaluation and Statistics Unit would be involved
in monitoring data integrity, the amount of time this unit will devote to this activity is not clear.
The Evaluation and Statistics Unit was originally established as a quality assurance unit;
however, this audit revealed that the unit had not regularly performed quality assurance tasks.
Therefore, to ensure quality assurance becomes an institutionalized process within the Divi-sion,
the Division should develop a written formalized plan, and follow through with its plans
to establish a quality assurance program. In the process of developing the plan, the Division
should identify what activities will take place, how often the activities will occur, and who will
conduct the activities. The Division should ensure that the quality assurance program will:
n Monitor data integrity—Regular monitoring is necessary to ensure that data entry
problems are identified and rectified quickly. CHILDS has some built-in quality control
features including built-in logic checks and drop-down menus that should help reduce
data entry errors and incomplete entries. However, data reliability and validity will ul-timately
depend on those individuals responsible for entering the data into the system
(e.g., caseworkers and central intake personnel). As such, the potential for data error
still exists.
44
n Identify system-training needs—To ensure caseworkers and administrators appropri-ately
use the system, periodic training should be offered. Although the Division has
developed a comprehensive training program to meet the needs of new CHILDS users,
continued monitoring of the system’s data may assist the Division in identifying addi-tional
or subsequent training needs.
n Identify necessary system changes—Regular monitoring of the system’s data would
also ensure needed updates are identified and performed quickly. For example, the Di-vision
may need to update existing data fields and codes to adequately reflect changes
in CPS clients, programs, and services.
Recommendation
The Division should continue the development and implementation of a formal, written
quality assurance program to ensure CHILDS consistently contains accurate, reliable, and
timely management information. Specifically, this program should:
n Provide regular monitoring to quickly identify and rectify data integrity problems;
n Help the Division identify additional training needs; and,
n Identify necessary system changes, such as data field and code updates.
45
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Agency Response
__________________ ARIZONA DEPARTMENT OF ECONOMIC SECURITY ___________________
1717 W. Jefferson - P.O. Box 6123 - Phoenix, AZ 85005
Jane Dee Hull Dr. Linda J. Blessing
Governor Director
Mr. Douglas R. Norton, CPA
Office of the Auditor General
2910 North 44th Street, Suite 410
Phoenix, Arizona 85005
Dear Mr. Norton:
Thank