Follow-up study of the Auditor General's 1991 workload study of Child Protective Services

              AUDITOR GENERAL
LElTER REPORT DOUGLAS R. NORTON, CPA
AUDITOR GENERAL
November 1994 Letter Report No. 94- L9
Members of the Arizona Legislature
The Honorable Fife Symington, Governor
Dr. Linda J. Blessing, Director
Department of Economic Security
SUBJECT: Follow- up Study of the Auditor General's
1991 Workload Study of Child Protective Services
Pursuant to a May 5, 1993, resolution of the Joint Legislative Audit Committee ( JLAC),
our Office was directed to conduct a review of the Department of Economic Security,
Division of Children and Family Services. However, since the date of the JLAC
resolution, DES has initiated several extensive reviews withn the Division. In addition,
the Joint Legislative Committee on Children and Family Services has been studying
issues in the area. To avoid duplicating this work, we reviewed the DES initiatives and
met with the members of the Joint Legislative Committee on Children and Family
Services. We then met with the Chairman of JLAC to review the information we had
gathered and discuss audit scope. Based on that discussion, we were directed to
postpone a full audit of the Division at this time and instead: 1) conduct a follow- up
study on our 1991 report on Child Protective Services ( Auditor General Report Number
91- 6); and, 2) document the current status of the Division for comparative purposes
when we conduct a comprehensive audit to be conducted following completion of the
DES studies.
In 1991, we identified significant limitations in the Division's ability to determine Child
Protective Service's staffing needs. Problems included a lack of accurate and reliable
workload data and the need for a management information system. Although many
problems from the previous audit have not yet been resolved, DES currently is
undertaking several initiatives which, if successful, should address many of our
previous concerns.
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29 10 NORTH 44TH STREET SUITE 410 PHOENIX, ARIZONA 8501 8 ( 602) 553- 0333
Background
The Division of Children and Family Services is comprised of three programs:
Administration for Children, Youth and Families ( ACYF), Child Care Administration,
and Comprehensive Medical and Dental Plan. ACYF employs the majority of the
Division's approximately 1,270 employees. This report focuses on ACYF, the major
functions of which include: Child Protective Services ( CPS), In- Home Services ( parent
skills training, intensive family preservation, counseling, etc.), permanency planning,
adoption subsidy services, and foster home recruitment, training, and licensing. A
majority of ACYF's employees ( 685 out of 1,040), provide child protective services for
over 4,000 children currently in out- of- home placement.
Previous Report Found
Significant Problems
In 1990, the Auditor General was requested to conduct an audit of CPS staff caseload
size due to concerns about the lack of information concerning the number of staff and
funding needed to investigate 100 percent of CPS reports deemed appropriate for
investigation. The audit, ' Workload Study - Child Protective Services," issued in June
1991, examined the number and type of CPS reports received, caseload size and mix,
and staffing ratios. However, several significant limitations were noted that impacted
the audit team's ability to estimate long- term staffing needs for investigating all
appropriate reports:
Inconsistencies in how supervisors categorized reports as " appropriate for
investigation but not investigated or as " information only" made it difficult to
assess the potential CPS caseload.
ACYF lacked precise information about the amount of staff time actually spent
providing child protective services.
The lack of widely accepted staffing criteria made it difficult to determine an
optimum staffing level.
The study recommended that ACYF continue its efforts to develop a management
information system that provides accurate, reliable data on child protective service
activities and use that system to develop and analyze options for staffing CPS
functions. In addition, it was recommended that the Legislature consider establishng
appropriate staffing standards based on the information provided by ACYF.
Problems Identified In
Previous Audit Continue
Many of the problems identified previously have still not been resolved. ACYF
continues to lack a comprehensive management information system that addresses all
aspects of child welfare services. As such, ACYF has been unable to gather the essential
data necessary to continually assess staffing patterns and needs.
Automation - ACYF's current automated systems lack comprehensive management
information system capabilities. ACYF has two primary systems: the Child Protective
Services Central Registry ( CPSCR), brought on- line in 1985 to register all reports of
child abuse and neglect; and the Arizona Social Services Information and Statistical
Tracking System ( ASSISTS), introduced in 1991, whch was intended to provide better
management information about child protective services. However, a recent consultant
review found that ACYF lacked automated support for the majority of its critical
business processes ( child intake, service provision, adoption, and provider
management). Significant shortcomings identified by the consultants include redundant
data entry, increased paperwork, and lack of on- demand and ad hoc reporting
capabilities.
During our review, we found that many of the information system problems identified
in the last audit still exist. For example, CPSCR cannot combine duplicate reports about
the same incident, does not track information pertaining to a case after the initial
investigation, and suffers from data inaccuracy due to classification problems and
inconsistent coding.
In addition, ASSISTS currently operates as a " skeleton," lacking many of its originally
intended modules. For instance, ACYF cannot determine its true client population
because information on children in the homes of relatives or those receiving in- home
services is not maintained on ASSISTS. In addition, because not all data fields are
mandated for data input, the accuracy of information maintained on ASSISTS is
suspect.
Several DES staff attribute the incomplete implementation of ASSISTS to a lack of
funding. ACYF received a special appropriation of approximately $ 1 million for
ASSISTS in fiscal year 1991 for staff, hardware, and other operating expenses.
Approximately two- thirds of that funding was staffing related ( ACYF requested 30
Information Processing Specialists to facilitate data input and four programmers).
However, according to a DES budget official, due to a hiring freeze at the time, ACYF
was unable to hire many of the Information Processing Specialists it had requested.
Thus, ASSISTS funding was identified as surplus and was reverted back to the State
in response to a budget reduction measure. Therefore, only $ 215,300 was expended for
system development. While DES did make a subsequent funding request in fiscal year
1992 ($ 500,100 for additional system modification), it was not funded.
However, other DES staff also attribute ASSISTS current status to low priority given
it by previous administrations. With lack of constancy in leadership and other pressing
needs, ASSISTS never received the administrative support necessary for complete
implementation.
Staffing - ACYF is unable to determine its staffing patterns and needs because it does
not have the information to accurately assess its workload.
When an incident of child abuse or neglect is reported, CPS staff screen the report to
determine if it is within their jurisdiction. If the reporting source provides two basic
pieces of information - they believe somethng has happened to a child and they have
information on how to find the child - a report is taken. CPS staff then categorize the
report as " information only" ( a report that can be handled without CPS involvement
or a case lacking sufficient information for CPS to investigate), or " appropriate for
investigation." A report determined " appropriate for investigation1' is ranked based on
its potential seriousness. Currently, ACYF uses four priority categories, ranging from
" life- threatening or emergency situation" to " substandard care that could be damaging."
In order for ACYF to identify its staffing needs, it requires accurate data on its
workload and the complexity of its cases, as well as a staffing model:
Workload - Workload is based on the number of reports deemed appropriate for
investigation. Currently, each district receives and categorizes its own CPS reports;
however, there are inconsistencies between districts in how reports are categorized.
For example, an internal evaluation of the CPS intake process conducted in 1993
found that of the 824 reports reviewed, 14 percent did not meet the requirements
of a CPS report.(') Moreover, some reports containing no allegations of
maltreatment were assigned for investigation. Other reports were improperly
labeled as " information only" reports ( some were actually " appropriate for
investigation," while others should not have been taken as reports).
A second report on the intake process, completed in March 1994, cited problems
with inconsistent screening and prioritization of reports and frequent misuse of the
" information only" disposition. Consequently, current report counts and
investigation rates may be misleading. For example, the Department reports that
it investigates approximately 92 percent of all reports deemed " appropriate for
investigation." However, this figure does not reflect reports which should be
investigated, but are not, because they are misclassified as " information only."
Caseload Complexity - To determine maximum caseload size, ACYF must
establish workload standards that incorporate factors impacting caseload
complexity. Until recently, ACYF had not taken steps to assess the relative amount
of time each caseworker's caseload requires. As noted in our previous report,
( I) This review consisted of an evaluation of 824 CPS reports made statewide in October 1991.
several factors may contribute to making one case more difficult to manage than
another. For example, one case may consist of only one chld, while another may
consist of several children. Furthermore, cases involving the courts reportedly
require more time because of mandatory court appearances, coordination with
parties, and necessary paperwork. Finally, case plans, such as return home,
adoption, and long- term foster care require varying amounts of time to handle.
Therefore, two caseworkers with the same caseload size may have a considerably
different workload.
Caseload/ Workload Model - Lacking its own caseload standards, ACYF has relied
on standards developed by the Child Welfare League of America ( CWLA) as a
basis for staffing requests.(') CWLA standards are based upon a consensus of what
constitutes best practice and are presented withn the context of other
recommended standards for staff qualifications and training, supervision,
management support, etc. While CWLA standards provide some general guidance
for determining staffing needs, ACYF has never adjusted these standards to reflect
the factors impacting its own caseworkers.
Without accurate and reliable caseload and workload information, it is difficult to
determine what impact the additional 118 positions appropriated since fiscal year 1991
have had on ACYF's ability to investigate 100 percent of " appropriate for investigation"
reports.
Current Initiatives, If Successful,
Should Address Problems
Recently, ACYF has undertaken a " comprehensive network of projects that will result
in an overhaul of all areas of the Division." These projects include information systems
improvement, a review of programmatic issues ranging from casework practices to
policies and procedures, strengthening administrative practices, an internal evaluation
of the CPS intake process, and a plan to obtain more federal revenue and contain the
costs of state- funded programs. These initiatives, if successful, should address many of
the concerns raised in our previous audit:
Comprehensive Statewide Automated Child Welfare Information System - The
goal of this project is to develop a system which encompasses all aspects of child
welfare activities, such as intake management, eligibility determination, case
management, resource management, court processing, financial management,
' The CWLA suggests that caseworkers conducting intake investigations carry no more than 12 cases
and that ongoing caseworkers carry no more than 17 cases per month.
administration, and system interfaces. This system will increase ACYF's ability to
respond effectively to questions regarding the operation and outcome
measurements of its programs.
DES is currently in the planning phase of this three year project. System
implementation is scheduled to begin in May 1996 and completed by October 1997.
The overall cost of the project is estimated at $ 13.8 million. DES will receive federal
enhanced funding at a rate of 75 percent until September 30, 1996. However, the
project is slightly behind schedule, which could impact DES' ability to cover project
costs with the enhanced federal funding. Beginning October 1,1996, federal funding
reverts back to the regular rate of 50 percent for automation projects.
Programmatic Review - Commonly referred to as " Program Redesign", this
initiative is expected to improve the outcomes achieved for children and families
served by ACYF through a systematic and comprehensive analysis of program
operations including children and families served; legal proceedings; services and
budget analysis; results and outcomes; personnel and training; and policies and
procedures. As part of Program Redesign, a comprehensive time study was
conducted to provide information on workload and caseload complexity and the
results of the study will be used by ACYF to develop a case weighting system for
the allocation of staff.
The review and analysis phase of this project is nearing completion. The
implementation phase will begin in January 1995 and is expected to be completed
by January 1996. DES contracted with the National Child Welfare Resource Center
to conduct tlus study at a cost not to exceed $ 971,522.
Effective Quality Unified Intake Process Team, or EQUIPT - A detailed analysis
of the CPS intake process was completed in March, 1994. It resulted in a total of
eight recommendations including eliminating manual tracking of CPS reports,
improving interfaces with the Attorney General's Office, consolidating and
streamlining CPS investigation forms, improving the case closure process, and
eliminating the duplication of services already provided with federal funding. The
most significant recommendation suggests a centralized intake process, which
should address consistency in report screening and prioritization. ACYF has
developed a new statewide priority system for categorizing reports of abuse and
neglect and cue questions for intake workers that, according to DES
administrators, will guarantee the same questions are asked on every call received
statewide.
DES has begun a phased- in implementation of the centralized intake
recommendation in two of the six districts. Statewide implementation is expected
by December 1995. The remaining recommendations are in various stages of
implementation, scheduled to be completed by May 1995.
Much of this project was conducted in- house with some facilitation and technical
assistance from the Office for Excellence in Government. In addition, DES received
consulting assistance from Ernst & Young at a cost of $ 93,000.
Management Control Review - This project was undertaken to strengthen
administrative processes such as current operating practices and controls, including
budgeting, service procurement, claims processing, and accounting; management
policies, procedures and practices; district oversight, reporting and accountability
processes; quality assurance; and, organizational design and capacity.
DES expects completion of this review by March 1995. DES contracted with Deloitte
& Touche to conduct tlus study at a cost not to exceed $ 1,119,044.
Revenue Maximization - This initiative is designed to identify areas and
programs within DES where it can increase its entitlement to additional revenues
from federal funding sources. The initial phase of the project has been limited to
Title IV- E and the Emergency Assistance program within Title W- A. DES projects
that it will receive an additional $ 5 to $ 8 million in federal revenues from ths
project in fiscal year 1995, increasing to $ 8 to $ 12 million in fiscal year 1996.
Projected additional revenues are expected to increase up to $ 20 million annually
by fiscal year 1998.
This project is expected to be completed in February 1996, however, there is a
provision in the contract to renew through February 1998. The consultant on the
project, MAXIMUS, is contracted to receive 6.9 percent of additional federal funds
received over and above current projections.
Review and Improvements in Adoption Subsidy Program - DES utilized both
its internal audit unit and a consultant to conduct reviews of the Adoption Subsidy
program to identify ways to contain costs within the program. As a result, DES
expects to save the Adoption Subsidy Program $ 2 to $ 3 million annually through
greater use of Title XIX funding.
The consultant, Deloitte & Touche, received $ 479,119 for its work.
In addition to the projects underway, a comprehensive review of 4,152 child records
conducted by the National Child Welfare Resource Center ( NCWRC) was completed
in June 1994, assessing the safety of children in ACYF care. The review found that " the
vast majority of children in ACYF custody are safe." However, the consultants also
expressed concerns about the extent to which the agency is finding permanent homes
for children in a timely manner. Moreover, ACYF lacks consistency in compliance with
policies and procedures relating to caseworker contacts with children and their foster
parents.
Other Issues
During our follow- up review of CPS, we also identified several other issues that
directly impact ACYF's ability to provide effective and efficient child protective services.
For instance, while additional positions have been appropriated to address caseload
growth, caseworkers are not provided with the skills and resources needed to perform
their jobs.(') In addition, caseworkers expressed their frustration with the process for
obtaining behavioral health services for foster children. Further, a shortage of foster
homes has resulted in sometimes lengthy and inappropriate out- of- home placements.
Finally, leadership turnover may have impacted ACYF's lack of progress in the past
and could influence the direction of current initiatives.
Caseworker co- ncems - During our review, we accompanied caseworkers from six
separate offices on their daily activities to better understand their responsibilities and
to identify any factors impeding their ability to do their job. Overall, we found the case
workers to be very dedicated, competent, and extremely hardworking. However,
several common concerns arose regarding lack of resources, training, excessive
overtime, and personal safety. We conducted follow- up calls with 20 additional CPS
workers across the state and found they faced similar problems.
A hck of resources impedes the caseworkers' ability to efficiently and effectively
perform their job. Many caseworkers are frustrated with the lack of adequate
vehicles, office space and equipment. For example, in one of the offices we visited,
there are approximately 60 workers involved in case management, but only 2 state
vehicles were available for their use. In addition, the lack of an automated case
management system increases the amount of time spent completing paperwork
and, as a result, impacts case documentation. For example, one- half of caseworkers
we surveyed indicated that they cannot consistently document their cases in a
timely manner. Moreover, most caseworkers do not have direct access to a
computer, which further impacts timely information gathering.
A recent internal survey of DES employees statewide identified similar concerns.
DES task teams have developed workplans to recommend solutions to these and
other concerns and to ensure implementation.
Timing and content of training was also a concern for some caseworkers.
Currently, new caseworkers attend 22 days of core training over a 5- to 6- month
period. Usually, they are not enrolled in training until they have spent some time
in the field. A survey of 15 caseworkers who recently attended training revealed
that they had worked 2 to 8 months before beginning training. According to an
ACYF official, caseworkers are waiting longer for training due to a shortage of
(') In addition to increased positions, ACYF continues to utilize contracted positions. As of December
1993, there were 157 such positions, most located in the rural districts. The majority of contracted
positions are dedicated to ongoing case management.
training staff. In addition, NCWRC found, in its contacts with district staff, that
while some field experience prior to training is acceptable, the delay in receiving
training lessens its usefulness.
In addition, several caseworkers commented about the content of core training.
Some found it was too theoretical and did not provide sufficient guidance in
handling day- to- day activities or situations.
Many of the caseworkers we spoke with expressed great concern about their own
personal safety when performing their job. Some caseworkers often travel to
remote locations and most deal with potentially hostile clients. Yet, very few have
cellular phones or other methods of personal protection should an emergency
situation arise. To compensate, some caseworkers use a " buddy system" or call
local law enforcement to help respond to a report. However, such techruques are
not always available or timely.
Excessive paperwork, frequent travel, and heavy caseloads often result in
unreported overtime for a majority of the caseworkers we surveyed. Many
caseworkers ( 16 of 20 surveyed) indicated that they consistently bring paperwork
home on nights and weekends in an effort to keep file information current. DES
policy requires advance approval prior to working overtime ( except in emergency
situations) and states that employees will either receive payment or compensatory
time. However, while caseworkers are aware that they can receive compensatory
time, they find it difficult to take the time off as it would put them further behind
in their caseload. According to one caseworker, "( they) can't put in for overtime
more than occasionally because workers believe management will fault them as
being ' deficient' for not being able to complete caseload work within the 40 hours."
Behavioral Health Services - Caseworkers expressed their frustration with the current
process for obtaining behavioral health services for foster children. Prior to 1992, DES
obtained behavioral health services for children within its custody by contracting
directly with service providers. However, that process was changed when federal Title
XIX funding was made available for children's behavioral health. As a result, DES
caseworkers are required to request services from Regional Behavioral Health
Authorities ( RBHA's) under contract with the Department of Health Services, Division
of Behavioral Health Services. According to some of the caseworkers we spoke with,
this process is time consuming and cumbersome. Furthermore, they are concerned that
all chldren do not receive services appropriate to their needs.
Due to the complexity of this issue and the limited scope of our review we did not
fully document the extent of the problem or what factors have contributed to the
current situation. However, DES is actively pursuing solutions to this problem with the
Department of Health Services which has primary responsibility for this area.
Foster care crisis - A shortage of foster homes has resulted in children being placed
in temporary shelters or other group facilities for extended periods of time. As of June
1994, there were over 250 children awaiting placement into foster homes. Many of these
children were placed in shelter facilities for temporary placement while a foster home
was being located; however, a stay that should have been only a few days extended
to weeks or months. For example, on July 1,1994, the Crisis Nursery in Phoenix housed
14 infants that had an average stay of 50 days and 11 preschool cluldren with an
average stay of 60 days.(') In addition, as shelter facilities are intended to be temporary
placements, children may be transferred to group homes to allow room in the shelters
for other children entering the system. Not only is the foster shortage impacting
placements, it is also more costly; daily shelter costs range from $ 80 to $ 100, while
foster homes receive approximately $ 8 to $ 23 per day.
Some attribute this current crisis to several factors. First, children in the foster care
system have more medical and behavioral problems, making it difficult to find foster
families willing to take on such complex cases. NCWRC found in its visits with district
staff that the children in foster care have been dramatically affected because of
increased substance abuse and violence in our population. Second, an increased number
of cluldren are spending long periods in foster care, further clogging up the system for
other children awaiting out- of- home placement. For example, according to the recent
NCWRC case review, almost one- half of foster children in December 1993 had been in
foster homes for over two years. Moreover, 22 percent of these cluldren had been in
foster care over 4 years. While the national average for children with " long term foster
care" as a permanent case plan was 12 percent, 24 percent of Arizona children in
foster care had such a case plan goal. Other factors impacting foster care placement
include age ( older cluldren tend to be harder to place), sibling groups ( DES prefers to
keep siblings together), and foster families " dropping out" as they become frustrated
in obtaining services for the children or disenchanted with the system.
Some steps have been taken to alleviate this problem. First, DES recently obtained an
exclusive contract for 50 beds at a group shelter facility. In addition, it may convert
some group shelters into group homes to provide a more stable, permanent placement.
Finally, a recent foster home recruitment effort in Maricopa County resulted in over 100
applications for foster home licenses.
Leadership turnover - Turnover in division leadership may have impacted ACYF's
ability to promote changes in its program. A new division Assistant Director and ACYF
Program Administrator were recently hired. This means that the ACYF Program
Administrator position has been filled by five individuals since May 1993. Moreover,
three individuals have served in the Assistant Director position since 1990. One outside
Crisis Nursery has 36 licensed beds for chlldren from ages 0 to 8. DES contracts for 16 of these
beds, with an agreement to utilize additional beds, if necessary. According to a Crisis Nursery
official, 23 to 24 of its beds are consistently filled by children in DES custody.
consultant noted that inconsistency in leadershp has forced management staff in the
districts to make what are effectively policy decisions based on their experience at the
district level.
The Auditor General and staff express appreciation to the Director and staff of the
Department of Economic Security for their cooperation and assistance during the
review. A copy of the Department's response to this report is included as Attachment
1.
My staff and I will be pleased to discuss or clarify items in this report.
Sincerely,
~ o u ~ hRd. lN orton
Auditor General
Attachment 1
Agency Response
ARIZONA DEPARTMENT OF ECONOMIC SECURITY
171 7 W. Jefferson - P. O. Box 61 23 - Phoenix, AZ 85005
Fife Symington Linda J. Blessing, DPA
Governor Director
November 15, 1994
Mr. Douglas R. Norton
Auditor General
Office of the Auditor General
2910 North 44th Street, Suite 410
Phoenix, Arizona 85018
Dear Mr. Norton:
Thank you for the opportunity to respond to the study of the
Department of Economic Security, Division of Children and
Family Services ( DCFS).
We are pleased that the report summarizes the most important
features of the comprehensive and aggressive plan that has
been initiated to fully address the current challenges
confronting DCFS. These include:
the design, development and implementation of a
statewide automated child welfare information system. Well
into its planning phase, this project promises to be one of
the most comprehensive systems of its kind, encompassing all
aspects of child welfare services.
the complete redesign of current program operations
including children and families services, legal proceedings,
service analysis, results and outcome measurements,
personnel and training, and policies and procedures. The
review and analysis stage of this project is nearing its
conclusion. The implementation phase is scheduled for
completion by January 1996;
a uniform overhaul of the Child Protective Services
( CPS) intake process. A centralized intake process, the
most significant recommendation of the Effective Quality
Unified Intake Process Team ( EQUIPT), has been implemented
in Districts I and VI. Early feedback supports the EQUIPT
vision of treating all incoming reports consistently and
equitably. Five other EQUIPT recommendations, including the
streamlining of intake and related case management forms,
improving interfaces with the Attorney General's Office,
improving the case closure process, eliminating duplicative
services, and eliminating manual reporting processes, are in
various stages of implementation. These process
improvements recommended by EQUIPT have received national
recognition by the Child Welfare League of America.
Mr. Douglas R. Norton
Page Two
Additionally, resource issues related to staffing,
workloads, caseload complexity, training, overtime, and
personal safety are being addressed by the Program Redesign
and internal quality initiatives. The recommendations,
including implementation plans, will be presented in 1995.
The Behavioral Health issues are being addressed through the
Children's Behavioral Health Plan developed by a consortium
comprised of the Departments of Economic Security, Health
Services, ducati ion, Youth Treatment and Rehabilitation, the
Administrative Office of the Courts, Regional Behavioral
Health Authorities, and community behavioral health
advocates. Work group recommendations are scheduled for
delivery throughout 1995.
The shortage of foster care homes is being addressed by a
task force comprised of both internal and external entities.
Recommendations from this work group will be implemented
during 1995.
The Department did not fully implement the 1991 workload
study findings, however, as soon as I was appointed
Director, I made the reform of Arizona's child welfare
services the Department ' s number one priority.
Consequently, we will not settle for anything less than
complete success in this vitally important area.
Finally, I wish to express this Department's appreciation to
you and your staff for the courtesy consistently displayed
by your staff during the course of their study. If you have
any questions or need additional information, please contact
me.
Sincerely,
* j-$. " V
Linda J. B ssing
c: Michael Koppelman 014A
Eric Bost 060A
Phil Bayne 750A
Mary Ault 750A