Youth Treatment Center November 1995 EXECUTIVE SUMMARY The state of Wyoming funds a variety of community-based and residential treatment programs for at-risk youth. According to statutes, adolescents in need of services are required to be placed in the least restrictive setting considered appropriate for their individual needs. Young persons generally enter the youth services system through the courts. Multi-disciplinary teams at the community level advise juvenile court judges regarding appropriate placements. The Youth Treatment Center (YTC) is one component of the continuum of services available for at-risk youth in Wyoming. YTC is a long-term residential program providing education, health, and social services to address the multiple problems of high-risk youth. According to YTC's management, treating traumatized children is at the forefront of its service mission, and many of the residents have been emotionally, physically, or sexually abused. Some residents have mental illnesses such as severe depression, while others exhibit behavior disorders. Many of the youth also have a history of abusing substances. For FY 1995, we estimate that it cost an average of $140 per day to provide services for each resident admitted to YTC. Based on a median stay of 8.5 months, an average treatment cost would be more than $35,000. YTC has an average census of 38.7, and in the course of a year, serves 90 to 100 adolescents. Finding 1 Planning and Coordinating Weaknesses Limit YTC's Effectiveness Although YTC's accomplishments are not well documented, knowledgeable individuals we interviewed generally agreed that treatment at the Center can have a positive impact on youth. However, these individuals also recognized a need for improved planning and interagency coordination. The combination of ineffective treatment planning and weak coordination of transitions tends to extend time for treatment and also limit sustainable benefits of therapy. Although YTC has been a part of DFS since reorganization in 1991, DFS has not clearly outlined for YTC its expectations regarding residents' treatment planning and coordination of transitions. This lack of management direction has allowed problems to develop and go unaddressed. Recommendation: DFS should develop and implement a comprehensive strategy to strengthen planning for treatment, transitions, and aftercare. Treatment outcomes for YTC residents can be improved if DFS develops a strategy to address system problems in the areas of treatment, transitioning, and aftercare. The resulting strategy should require DFS and YTC to establish management controls which guarantee that new planning and coordinating procedures are effectively carried out. Finding 2 Human Resources Management Problems Have Resulted in High Staff Turnover Ineffective human resources management at YTC has resulted in an excessive staff turnover rate. YTC's turnover rates for 1994 and 1995 were 36.8 percent and 39.7 percent respectively. These rates were more than triple the turnover rate for all state employees, and more than double the rates at either the Girls' or Boys' Schools. YTC has not effectively identified and addressed the causes of its high staff turnover rates. Current and former employees attributed turnover primarily to management practices, not to pay. Several former employees told us they were so dissatisfied that they resigned without having new employment to go to. Recommendation: DFS should review human resources management practices at YTC and take appropriate actions to resolve problems. Specific steps to improve human resources management could include some of the following: improving internal communications, establishing an ongoing team building training program, reviewing YTC's organization structure to determine if there are an appropriate number of staff at the various levels, developing an employee recognition program for all levels of employees, and developing employee incentives which may include recognition and award features. Finding 3 YTC Has Not Addressed Critical Facility Problems YTC's aging and inappropriately designed facilities limit staff's ability to supervise residents. Consequently, the state cannot be assured that YTC is providing a safe living and treatment environment for youths placed at the Center. The Center has not presented policymakers with a plan to incrementally address the most critical needs in the existing buildings. YTC has identified cottage design as presenting the greatest risks to the residents and the state. Therefore, it has an obligation to continue informing policymakers of those specific risks and to justify funding requests for upgrades. YTC's capital outlay requests have not reflected this focus. Recommendation: DFS should conduct a systematic assessment of YTC's facilities to identify and prioritize its most critical needs. DFS should obtain an independent condition assessment of YTC's facilities to identify critical building needs. Using the assessment as a guide, YTC should develop a five to seven year plan to reduce critical facility deficiencies. Finding 4 YTC Has A Serious Runaway Problem We found that YTC has an ongoing and severe runaway problem, but has not identified the causes or effectively addressed the issue. As a result, YTC has exposed its runaways, the community, and the state to unnecessary risks. YTC does not have a systematic process to review runaways from the Center. It lacks a system to determine the number of youths who run away, to ascertain the causes of runaways, and to strengthen its program and security procedures to reduce the number of runaways. Recommendation: YTC should develop a process to reduce runaways. YTC should develop a system to track the number of residents who run away, to determine the causes of runaways, to provide staff training on prevention, and to strengthen security procedures. These steps should contribute to reduced runaway rates. DFS should require YTC, through rules or written policy, to report all cases of runaways immediately. In addition, YTC should be required to provide follow up reporting on steps taken and the disposition of these cases. Finding 5 Customers Are Dissatisfied With YTC Responsiveness Interviews with judges, caseworkers, county attorneys, multi-disciplinary team members, and families depicted a great deal of dissatisfaction with the timeliness and substance of YTC contact. Many local officials told us they had problems communicating with YTC prior to an admission, during treatment, and at the time of release. Ineffective communication diminishes the ability of local workers and the courts to effectively meet the needs of local youth treated at YTC. As a state facility operating within DFS, YTC has an obligation to work within DFS to meet the needs of youth, and also to serve the needs of local communities. However, due to communication problems with YTC, officials in several counties have refused to work with YTC. They opt instead to place youth with private providers. Recommendation: YTC should improve responsiveness to its broad range of customers. YTC needs to recognize it has many customers, including the local officials who are responsible for youth in treatment. YTC should take steps to identify its diverse clientele, in ways that enhance rather than diminish focus on the residents. YTC should develop rules concerning admission criteria, so placement officials can have more information about the process. It should develop a systematic approach for communicating with, and obtaining feedback from, key groups prior to admission, during treatment, and at release. Finding 6 Quality Control Systems Are Lacking at YTC YTC operates largely without external oversight and internal quality assurance systems which can promote program quality. YTC undergoes no external quality control review by the state or by independent accrediting entities. Also, YTC lacks an internal, formalized quality assurance system to continually assess and improve operations. Without these systems, YTC is isolated from the mainstream of residential treatment for adolescents. Residents and their families, the Legislature, and the public have no independent assurance that treatment provided at YTC is appropriate and safe. Recommendation: DFS should develop and implement a plan for providing effective oversight and internal review at YTC. To protect the interests of its residents and of the state, YTC needs to be made part of a larger framework. As part of the strategic planning process, DFS could establish a goal of developing performance measures related to effective oversight for YTC. All parties stand to benefit from external and internal quality assurance programs at YTC. Because the Management Audit Committee requested a focused study emphasizing YTC, not the larger youth services system, our findings and recommendations are intended to strengthen the Center's operations. However, they necessarily will need to be considered in a broader context. Policy makers need to be working toward resolution of a number of related and over-arching public policy matters. Questions for consideration, some of which have been noted in prior studies of the youth services system, include: What are the state's expectations for court-ordered placements? How can YTC best fit into the state's youth services system? Should the YTC continue to provide services which are also available in the private sector? Which agency should run the state's mental health system? The Legislature faces a fundamental decision regarding YTC: should it continue to operate according to status quo, be changed, closed, or is another policy direction desirable? Regardless of which decision is made, we believe the recommendations in thisreport have implications for the entire youth services system. They speak to the state's obligation to ensure that youth treatment is delivered in an environment and manner which promote high quality treatment, safety for residents, retention of skilled staff, and attainment of desired outcomes. Introduction A. Scope W.S. 28-8-107 (b) authorizes the Legislative Service Office to conduct program evaluations and performance audits. The general purpose of a program evaluation is to provide a base of knowledge from which policy makers can make informed decisions. In February 1995, the Management Audit Committee chose the Youth Treatment Center in Casper, which is a part of the Department of Family Services, as the subject of a review. The Committee requested that research focus on the Center and its operations, but, to the extent possible, that its operations be reviewed in the context of the youth services system. The research in this report centered around the following questions: What is YTC's purpose and how effective is it in carrying out that purpose? Are YTC's facilities appropriate to its mission? How are placement decisions made? How comparable are YTC's treatment strategies to accepted practices? What is known about outcomes for YTC residents? What supervision and oversight does YTC receive from DFS? B. Methodology This evaluation was conducted according to statutory requirements and appropriate program evaluation standards and methods. We conducted our research between June and October 1995. We reviewed relevant Wyoming statutes, rules, YTC policies, annual reports, budget requests, academic literature, agency records, and a variety of other state and federal reports and studies. We contacted the Department of Health, the Department of Education, and several mental health centers for information. We selected a random sample of former residents at YTC and reviewed records pertaining to their placement and release. We interviewed current and former staff at YTC and DFS, as well as former participants in the program and parents. We traveled throughout the state to interview District Court judges and members of multi-disciplinary teams. We toured private residential treatment centers, the Girls' and Boys' Schools, and several community based programs for troubled youth. Finally, we conducted telephone interviews and reviewed documentation from several neighboring and western states, including Alaska, Colorado, and Nebraska. C. Acknowledgements The Legislative Service Office would like to express appreciation to all the individuals who assisted us in our research on this project, and especially to staff at the Youth Treatment Center and the Department of Family Services. Background Description of the Problem of At-Risk Youth Wyoming, like all states, faces difficult challenges in deciding how best to approach the problem of youth whose behavior places them at risk of not becoming self sufficient members of society. The Youth Treatment Center (YTC) is one facet of Wyoming's approach to dealing with at-risk youth. One study has estimated that more than 10 percent of the nation's youth aged 10 to 17 engage in three or more of the four behaviors most commonly associated with this risk: poor performance in school, substance abuse, delinquency, and early unprotected sexual activity. Many of these children come from troubled families and have experienced neglect or physical, sexual, or emotional abuse. They may internalize or act out their problems through behaviors that range from depression to delinquent acts. Two Basic Approaches to the Problem One way to serve high-risk youth is through nonresidential community-based programs. Such programs serve youths at home, at school, or through other community locations. Another way of addressing youths' problems is through out of home placements. Options range from short-term crisis centers to comprehensive, long-term (6 to 18 months) residential programs. YTC is a long-term residential program providing education, health, and social services to address the multiple problems of high-risk youth. Wyoming's Approach to At-Risk Youth The state of Wyoming funds a variety of community-based and residential treatment programs for at risk youth. According to statutes, adolescents in need of services are required to be placed in the least restrictive setting considered appropriate for their individual needs. Young persons generally enter the youth services system through the courts. Juveniles can come under the protection of the courts in cases of neglect or abuse. They can be adjudicated delinquent if they have broken the law or have violated the terms of a court order. Juveniles who are out of parental control, such as habitual truants, chronic runaways, and status offenders can be adjudicated as children in need of supervision (CHINS). The state gains custody of those youth ordered to out of home placements. Local and private options for out of home placements include family members, foster care, specialized foster care, therapeutic foster care, group homes, and private residential treatment facilities (RTFs). There are 13 RTFs in Wyoming providing long-term residential mental health care and special education services. These RTFs have capacities ranging from 14 to 70 beds. The state operates several institutions for youth. DFS is responsible for the Youth Treatment Center -- a treatment facility for adolescents, and two correctional institutions -- the Girls' School and the Boys' School. The Department of Health is responsible for the State Hospital, which has an adolescent psychiatric unit. Three agencies are involved in funding court-ordered placements. Generally, DFS pays for room, board and treatment; the State Department of Education (SDE) pays for educational costs; and the Department of Health (WDH) pays for medical expenses and certain mental health services. As shown below, both the number of court-ordered placements and expenditures for placements have been increasing in recent years. Exhibit 1: Court-Ordered Placements FY91 through FY94 Fiscal Year Placements Expenditures 1991 572 $7,728,838 1992 632 $8,519,865 1993 682 $10,452,141 1994 747 $11,206,008 Source: LSO analysis of data from DFS, WDH, and SDE Placement Decisions are Made Locally According to state statutes, multi-disciplinary teams (MDTs) at the community level advise juvenile court judges regarding appropriate placements. The composition of these teams varies somewhat from community to community, but must consist of at least four members, some specified in statutes. Teams often consist of parents or guardians, the youth's legal counsel, school officials, state or local social service workers, county attorneys, or other professionals. In making recommendations, MDTs typically consider factors such as the availability of appropriate local services, immediate availability of space in preferred facilities, and individual members' impressions of program effectiveness. Although MDT members consider the cost of various placement options, many do not believe this to be their primary consideration. Typically, local DFS offices are responsible for paying for placements, while juvenile court judges have the ultimate placement authority. To initiate the process of making a placement at YTC, a local DFS office generally contacts YTC directly. They discuss the appropriateness of placement and the availability of a bed. Some placements are made immediately, while other youth are put on a waiting list until a bed is available. YTC may advise against placement if, for example, staff believe they cannot serve the treatment needs of the particular youth. Overview of the Youth Treatment Center The Youth Treatment Center is one component of the continuum of services available for at-risk youth in Wyoming. YTC and privately operated RTFs in the state accept youth with similar problems and provide similar treatment and educational services. W.S. 25-7-101 authorizes DFS to operate the YTC for the purpose of providing special care or treatment for children not otherwise adequately served. YTC is a residential treatment facility located near the center of the state in Casper, on a 24-acre open campus. YTC typically serves male and female adolescents 12 to 18 years old who have been adjudicated as delinquent or CHINS. Although statutues allow the placement of delinquents up to age 21, YTC rarely serves individuals over age 18. Many of these adolescents have experienced several other treatment placements prior to coming to YTC. According to YTC's management, treating traumatized children is at the forefront of its service mission, and many of the residents have been emotionally, physically, or sexually abused. Some residents have mental illnesses such as severe depression, while others exhibit behavior disorders. Many of the youth also have a history of abusing substances. The Center provides long-term care with the goal of enabling children to return home or to an alternative living situation, able to manage life in a constructive fashion. YTC's program offers mental health services and special education programs. Each resident participates in group therapy and may also request individual therapy sessions. The residents work through the program on a "level" system, under which they progress toward release at individual speed. According to YTC management, the focus of group therapy and the level system is to empower residents to help each other through the program. Residents are not required to complete the program within a designated time period. Agency officials report that current placement trends involve adolescents requiring more and more acute psychiatric care. They say over 50 percent of the youth served at YTC have previously received acute psychiatric hospital care. Approximately 30 to 40 percent of the residents are on psychotropic medications, which are dispensed through a self-administered program. History of the Institution YTC's facilities date to the 1930s when they served as the State Children's Home for orphans. In 1983, YTC changed its focus from a state orphanage to that of a clinically-focused residential treatment center and special education school. YTC reported to the Board of Charities and Reform until 1991, when it became part of DFS. Budget and Staffing The Center's budget for the 1995-96 biennium is $3.8 million, which is a two percent increase over the previous period. The General Fund is the source of more than 98 percent of the Center's funds, with Federal Funds contributing less than two percent. As shown in Exhibit 2, nearly 86 percent of FY 95 expenditures were for residents' room and board, therapeutic services, and education. Exhibit 2: YTC Expenditures by Category Fiscal Year 1995 Total Expenditures = $1.9 million Source: LSO analysis of YTC data YTC is authorized 58 employees: 56 full-time and 2 part-time. They fill a variety of positions which support a program designed around four residential cottages, staffed 24 hours per day. Many of the staff work rotating shifts. Each cottage has an assigned therapist who manages the cottage and conducts group and individual therapy sessions. Each cottage also has a supervisor who is responsible for day-to-day operations. The Center is authorized 24 full-time and one part-time youth service workers. These staff act in a parental role and are responsible for such tasks as meal preparation and monitoring and supervising residents. Within educational services, YTC employs an education director, five teachers, a Chapter One aide, and a recreation director. YTC also contracts with a psychiatrist and a physician for mental and medical health services. Program Costs and Descriptive Statistics For FY 1995, we estimate that it cost an average of $140 per day to provide services for each resident admitted to YTC. Additionally, for the FY95/96 biennium, the Legislature appropriated $352,000 for capital improvements to the facility. Admissions and releases occur throughout the year, with some youth staying only a short while and others for extended periods. Based on a median stay of 8.5 months, an average treatment cost would be more than $35,000. YTC has an average census of 38.7, and in the course of a year, serves 90 to 100 adolescents. As a state facility, YTC is a resource to youth from all counties, although admissions are more likely to come from some counties than from others. For the four-year period FY 1992 through FY 1995, YTC admitted adolescents from 21 of Wyoming's 23 counties. During that time, 30 or more youths were admitted from two counties, Natrona and Sweetwater. By contrast, only seven admissions came from each of the following counties: Albany, Campbell, and Laramie [see Appendix B]. Placements After Release After successfully completing the fourth and final program "level," residents may progress to a new placement on a 60-day extended pass. During this period, YTC still has legal custody of the youth even though they are no longer in the Center's physical custody. Those youth who are not making progress in the program are transferred out of the facility to someone else's custody. Residents can be released to any of a variety of settings, ranging from less to more restrictive than YTC. Youth may go to group homes, therapeutic foster care, back to their families, to independent living, other residential facilities, psychiatric hospitals, or correctional facilities. Based on our file review, we found that 38 percent of the youth released from YTC returned to their families. Once released, it is widely accepted that youth need provision for aftercare, or ongoing support and service. As one comprehensive Government Accounting Office (GAO) study found, "a number of research efforts have suggested that a youth's environment after discharge is crucial to sustaining the effects of residential treatment." High-risk youth are not necessarily "cured" or "fixed" by residential treatment. In addition, there may be ongoing family problems which require counseling and monitoring. Some examples of aftercare are: continued therapy, substance abuse support groups, home visits by social workers, counseling to help ensure completion of schooling, and assistance in obtaining jobs. Many Earlier Reports Point to System Deficiencies During the past 15 years, Wyoming has studied its youth services system many times, through consultant studies, committee reviews, and task forces. Cumulatively, these efforts have produced at least 13 reports, and many of them contain similar findings about Wyoming's system: There is no early identification of risk or assessment system in place. Community resources are limited and not effectively used. There is no consistent process for evaluation of the need for placement or treatment. There is a lack of clearly defined missions for state agencies and facilities. There needs to be a clearly defined continuum of care to serve each type of child in the system. Because our research was not directed at the youth services system as a whole, we did not attempt to re-verify these findings. Nevertheless, it is fair to state that we found nothing to contradict the findings listed above. In addition, it appears that few of the recommendations made in these reports have been acted on in the intervening years. None of these reports focused exclusively on YTC's role in serving youth. The Management Audit Committee, in an effort to shed light on an as yet unstudied aspect of the system, chose to focus on YTC and its role within the youth services system. Consequently, our findings and recommendations focus on what exists at YTC, with a view to how operations might improve. In this report, we identify several areas in which YTC and DFS can improve: coordination and treatment strategies, staff turnover, deficiencies in the physical plant, the rate of runaways, responsiveness to customer concerns, and oversight and independent scrutiny. Finding 1 Planning and Coordinating Weaknesses Limit YTC's Effectiveness Although YTC's accomplishments are not well documented, knowledgeable individuals we interviewed generally agreed that treatment at the Center can have a positive impact on youth. However, these individuals also recognized a need for improved planning and interagency coordination. The combination of ineffective treatment planning and weak coordination of transitions tends to extend time for treatment and also limit sustainable benefits of therapy. To gain an understanding of YTC's operations, we talked to a broad range of current and former employees and residents, parents, public officials, and professionals in related fields. We questioned them about various aspects of the Center's operations, obtained their views concerning its effectiveness, and asked some of them to compare YTC to standards we found in the literature about residential programs. In addition, we examined a randomly selected sample of 25 cases admitted to YTC between September 1, 1992 and August 31, 1994. None of these cases involved current residents. For this sample, we found: The median length of stay was 255 days, or about 8.5 months. The median time from admission until the completion of a written individual treatment plan was 110 days, or about 3.7 months. There was no evidence that any of these plans, once completed, had been revised during treatment to reflect modified goals. 17 of our sample of 25 residents (68 percent) were released without completing their treatment plans. 12 of our sample of 25 residents (48 percent) were released to placements that were equally or more restrictive than YTC. Research Shows Key Characteristics of Effective Programs We reviewed pertinent literature and program evaluations from other states to gain an understanding of residential care for at-risk youth. The U.S. General Accounting Office has identified key elements believed to be important for the success of residential treatment programs. A description of these characteristics is shown in Exhibit 3. Exhibit 3: Characteristics of Effective Residential Treatment Programs Developing Individual Treatment Plans. Nearly all residential treatment programs develop individual treatment plans for each youth. Plans, in some cases, are updated at specific intervals, such as monthly. Participation of a Caring Adult. The presence of a caring adult, such as a counselor or other staff member, was considered important in many youths' successful experiences in residential programs. Self-Esteem Building. According to officials from most programs, it is important for residential programs to provide opportunities to build self-esteem so that youths can develop a sense of success. Planning for Post-Program Life. Planning for transitions may begin as soon as youths enter the program. Some programs connect youths to community services and work with families to strengthen relationships and resolve problems such as substance abuse. Teaching Social, Coping, and Living Skills. One important purpose of residential care is to prepare youths for the everyday world. Youths are taught good work habits, handling confrontations, and preparing nutritious meals. Coordination of Services. Program officials viewed coordination of services as important, whether the services were provided by a single caseworker or a team. Involving the Family. Programs acknowledge that youths' behaviors are often related to family problems and dysfunction. Several programs contacted involved families in their formal treatment approach, although this is not always feasible. Positive Peer Culture. Peer influence is used to effect healthy behavior changes in youths. Program staff work with peer groups to foster desirable values and behavior patterns. Enforcing a Strict Code of Discipline. Program officials believe a strict code of discipline for residents was of great importance. Post-Program Support. Research efforts suggest that a youth's environment after discharge is crucial to sustaining the effects of residential treatment. Accordingly, some programs continue services after the youths are discharged from residential care. Providing a Family-Like Atmosphere. Because many at-risk youths have not grown up in constructive family environments, several programs helped youths develop skills and relationships in a healthy family-like setting. Source: U.S. General Accounting Office DFS Has Not Provided YTC With Clear Directions Although YTC has been a part of DFS since reorganization in 1991, DFS has not clearly outlined for YTC its expectations regarding residents' treatment planning and coordination of transitions. This lack of management direction has allowed problems to develop and go unaddressed. Specifically, we found YTC has not developed written policies or management controls necessary to ensure that individual treatment plans are consistently prepared in a timely manner and regularly updated. YTC managers told us they have a goal to complete plans within 30 to 45 days of a resident's admission. They said treatment plans are continuously reviewed and changes noted in the monthly updates sent to courts, parents, and social workers. However, they acknowledged that actual treatment plans are not revised. Without up-to-date treatment plans, we believe staff and residents may not fully understand and be working toward the same specific treatment goals. Opportunities Exist to Improve YTC's Effectiveness Our review showed that many features of YTC's treatment program resemble those of other highly effective residential treatment programs. Several individuals we interviewed commended YTC for its highly qualified staff and, in September 1995, DFS recognized a YTC job training program as exemplary. Despite its strengths, however, we also found that opportunities exist to improve YTC's effectiveness through better planning and interagency coordination. Although it is extremely difficult to prove that planning and coordinating problems have specific effects, we believe there are strong indications that these difficulties tend to increase the cost of care. This occurs because the length of stay at YTC is extended due to delays in developing personalized therapeutic treatment plans. In the 25 cases we reviewed, we found the median time to complete a written treatment plan was 110 days, or about 3.7 months. This delay in establishing formal goals amounted to nearly half of the 8.5 month median length of stay for this group. By contrast, private treatment facilities told us they produce treatment plans in no more than 40 days -- which is 70 days earlier than YTC -- as is required by state standards for RTF licensure. Based on this information, we concluded that YTC takes an unreasonably long amount of time to complete individual treatment plans. The likely effect is to extend treatment periods. Moreover, until plans are completed, residents may not be receiving care sufficiently tailored to meet their individual needs. Our sample analysis also showed that more than two out of three residents left YTC without completing their treatment programs. No objective criteria exist to show the number who should be expected to complete specified treatment plans, and data was not available to determine completion rates for private RTFs. Nevertheless, we believe the large percentage of residents who do not complete the program suggests that YTC's treatment plans may not be sufficiently tailored to individual residents' needs. Finally, almost half of the residents in our sample were transferred to facilities that were equally or more restrictive -- and potentially as expensive. This data also suggests a need for improvement. Recommendation: DFS should develop and implement a comprehensive strategy to strengthen planning for treatment, transitions, and aftercare. Treatment outcomes for YTC residents can be improved if DFS develops a strategy to address system problems in the areas of treatment, transitioning, and aftercare. The resulting strategy should require DFS and YTC to establish management controls which guarantee that new planning and coordinating procedures are effectively carried out. The strategy should require a more timely development of individual treatment plans at YTC than has occurred in the past. Regular reviews and appropriate revisions of plans, based on progress toward treatment goals, should ensure that more residents complete their planned treatment. The strategy should also require DFS social workers and YTC treatment staff to ensure that appropriate post-program support is in place prior to releasing the resident. One approach would be to require that written plans for transitions and aftercare be incorporated into individual residents' treatment plans. Whenever possible, the strategy should provide for appropriate family interventions, especially when family reunification is being considered. Finding 2 Human Resources Management Problems Have Resulted in High Staff Turnover Interviews with current and former YTC employees revealed a widespread sense of disillusionment and job dissatisfaction, resulting in high staff turnover. Although many staff we interviewed expressed a deep-seated pride in the value of their work, they frequently were critical of YTC's human resources management practices. Ineffective human resources management at YTC has resulted in an excessive staff turnover rate. YTC's turnover rates for 1994 and 1995 were 36.8 percent and 39.7 percent respectively. As shown in Exhibit 4, YTC's turnover rate has been two to three times higher than the turnover rate for all state employees and the Boys' and Girls' Schools. Exhibit 4: State Employee Turnover During 1994 and 1995 Organization: Employees Turnover Percent 1994 1995 1994 1995 1994 1995 State Government 7,014 n/a 865 n/a 12.3% n/a Boys' School 88 88 8 11 9.1% 12.5% Girls' School 53 54 10 3 18.9% 5.6% YTC 57 58 21 23 36.8% 39.7% Source: Department of Family Services and Department of Administration and Information. YTC acknowledges that staff turnover rates increase expenditures and decrease productivity. Their estimates place one-time costs for recruitment and training of a new employee at $335. Additionally, YTC estimates its new employees are 20 percent less productive than seasoned staff. Using these assumptions, YTC estimates that during calendar year 1994, its total turnover costs were $362,180. Although it is unrealistic to believe YTC could entirely eliminate turnover and associated costs, it could reduce them. By moderating its turnover rate to a level similar to the overall state employee turnover rate, we estimate YTC could achieve annual budget savings in excess of $200,000. Our review showed there are other less quantifiable effects of staff turnover. Numerous sources indicated that turnover has hampered residents' care. YTC suggests this consequence in a document which states the key to successful treatment programs for these individuals (residents) is consistency and stability in staff. Staff told us they believe turnover is disruptive and prevents residents from bonding with staff. They felt that a lack of continuity among staff results in longer treatment periods and also decreases the effectiveness of treatment. They told us that turnover is especially difficult for residents who are already trying to come to grips with abandonment issues in their own lives. Some residents view turnover as their fault. As one staff member put it, "you lose time and you lose kids." Another stated, "kids fall apart when they hear a staff member is leaving. Common sense says that it's not healthy to have this kind of turnover." Good Management Practices Require Stable Staffing One popular reference volume describes effective human resources management practices. The practices described in this book include: making people feel they are part of a team; encouraging open communication, informing people of new developments and encouraging them to offer suggestions and complaints; reducing the distinctions of rank between the top management and those in entry-level jobs; and expanding the skills of personnel through training programs and reimbursement of tuition for outside courses. DFS itself has recognized the need for effective human resources management. Its draft strategic plan for 1996 includes an objective to attract, develop, and retain highly professional employees. This draft plan suggests that to retain highly professional employees, DFS divisions and institutions should reduce staff turnover, develop an employee recognition and awards program, increase the percentage of staff receiving training, and increase employee satisfaction through non-monetary recognition of above average effort and efficiency in job performance. DFS' draft plan would also establish staff turnover as a department outcome measure. The GAO study of residential care found that the presence of a caring adult, such as a counselor or other staff member, was important in many youths' successful experiences in residential treatment programs. GAO stated that behavioral change can only take place in the context of a caring relationship -- youth will listen and learn only from adults they believe care about them. Excessive staff turnover at YTC makes it less likely that residents will form these kinds of relationships. Management Has Not Addressed the Causes of Turnover YTC has not effectively identified and addressed the causes of its high staff turnover rates. Current and former employees attributed turnover primarily to management practices, not to pay. Several former employees told us they were so dissatisfied that they resigned without having new employment to go to. In addition, YTC has not established formal feedback channels, such as performance measures, which are necessary to improve its human resources management program. Specific causes of employee dissatisfaction cited in staff interviews included the following: Limited communication between administrators and staff members. After reorganization, DFS conducted a survey of staff at all the youth institutions, to ascertain the root causes of some morale problems. At YTC, this study found a large degree of separation between various work groups, strong staff dissatisfaction with the administration at YTC, and communication problems. More recent statistics show that YTC's turnover during 1994 and 1995 occurred among non-administrators. This is a likely indication that a communication breakdown continues and is most critical at the staff level, as was also indicated in our interviews. Lack of recognition and respect for staff problems, thoughts, and suggestions. Many staff felt administrators have a singular focus that does not always include their concerns. Current and former staff told us they believe their opinions do not count and they are considered expendable resources. One told us, "we're told what, when, and how. We're punished for disagreements. When we ask why, we're told, just because." A DFS official stated, "there is a huge gap between administrators and workers, involving such matters as trust and teamwork." Lack of management support for staff decisions. Staff we talked to were frustrated because they believed that YTC's management consistently did not support their decisions. As one said, "We try to help each other out and stick together. It's important that we do this because we aren't supported by management." Another said, "Management subverts, demeans, and belittles staff by arbitrarily making changes that render (our) work ineffective." Generally, our interviews showed that many staff are discouraged because they are addressing the same issues over and over, with no results. YTC management has identified staff turnover as a problem in its strategic plan and other documents. They attribute turnover to several factors including too few staff for the number of residents, rotating shift work, and an improved local economy which provides better paying career alternatives. While these may be valid contributing factors, staff we interviewed said they are not the most important reasons. Overwhelmingly, current and former employees cited negative management attitudes toward them and a perceived lack of respect for the value of their contributions to the Center. Other similar state institutions, such as the Girls' and Boys' Schools, do not have turnover rates as high as YTC's. Regardless of the causes, we believe YTC's turnover rate is excessively high and it is affecting the Center's ability to do its job well. The evidence points to a need to address this problem decisively. Recommendation: DFS should review human resources management practices at YTC and take appropriate actions to resolve problems. Specific steps to improve human resources management could include some of the following: improving internal communications, establishing an ongoing team building training program, reviewing YTC's organization structure to determine if there are an appropriate number of staff at the various levels, developing an employee recognition program for all levels of employees, and developing employee incentives which may include recognition and award features. Additionally, so that decision makers can monitor this situation over time, YTC should establish staff turnover rates as a performance measure for strategic planning purposes, and report this information biennially to the Legislature. Finding 3 YTC Has Not Addressed Critical Facility Problems YTC's aging and inappropriately designed facilities limit staff's ability to supervise residents. Consequently, the state cannot be assured that YTC is providing a safe living and treatment environment for youths placed at the Center. YTC operates in a facility which originally housed the state orphanage. The administration and school building dates back to 1935, while the four residential cottages were built over a 30-year period: one in 1952, one in the late 1960s, another about 10 years later, and the latest in 1982. Inadequate Cottage Designs Numerous risks are associated with inadequate supervision of residents. Residents are at risk of harming themselves by engaging in dangerous activities such as drug use and suicide attempts. Residents are also at risk of harm from other residents, through fights and sexually aggressive behavior. Additionally, the state is at risk because it is responsible for protecting the youths in its custody. The floor plans of two of the four cottages make it difficult for staff to maintain visual contact with residents. The two cottages have several right- angled hallways which block the view. It is not possible for staff to observe each bedroom entrance, the living room, and the kitchen from a central location. As a result, it is difficult to adequately monitor, protect, and supervise residents. YTC Has Not Prioritized Critical Needs YTC has not conducted a systematic evaluation of its facilities in order to identify and prioritize its most critical needs. In 1988, the Legislature funded a feasibility study to compare the costs and benefits of either remodeling or replacing YTC's facility. Without presenting a detailed analysis of individual building deficiencies, the study concluded: The Center's most critical deficiencies were with the four residential cottages. Two needed substantial remodeling. The other two needed to be demolished and rebuilt. The administration building was adequate, although the heating, ventilation and air conditioning systems needed updating. The school was acceptable, but a new gym, locker area, and recreation room were needed. The study recommended that YTC not continue to operate in the facilities as they existed. To mitigate the facility risks, it suggested the state should either renovate, build a new facility, or place youths with other providers. In 1991, a bill sponsored by individual legislators to fund construction of a new YTC facility was defeated. YTC did not present a capital outlay request to the Governor for the 1993/1994 biennium. Recently, YTC was able to use federal funds to improve one of the cottages. However, this construction was not undertaken as part of a systematic plan designed to address the Center's critical facility needs. The Center has not presented policymakers with a plan to incrementally address the most critical needs in the existing buildings. For example, in the 1995/1996 capital outlay request, DFS proposed three options for YTC: $8 million to build a new facility. $5 million to completely renovate the facility. $352,000 to remove and repair the curbs, gutters, and paving; to remove and replace soffits on the administration/school building; to construct two therapist offices; and to construct four time-out rooms. In justifying the first two options, YTC did not articulate the specific risks associated with cottage design. The Governor recommended and the Legislature approved the smallest request. As a result, YTC is currently working on road projects, rather than on projects intended to reduce risks to residents. YTC has identified cottage design as presenting the greatest risks to the residents and the state. Therefore, it has an obligation to continue informing policymakers of those specific risks and to justify funding requests for upgrades. YTC's capital outlay requests have not reflected this focus. Recommendation: DFS should conduct a systematic assessment of YTC's facilities to identify and prioritize its most critical needs. DFS should obtain an independent condition assessment of YTC's facilities to identify critical building needs. The study should include a point by point enumeration of building and facility deficiencies, including: The appropriateness of the buildings for current use. Any specific inadequacies. Risks associated with any inadequacies. The study should also prioritize those risks from most to least critical. Using the assessment as a guide, YTC should develop a five to seven year plan to reduce critical facility deficiencies. Initial capital outlay requests should focus on the most serious health and safety issues. Once these projects have been funded and completed, YTC should incrementally and systematically request funding for other facility needs. Finding 4 YTC Has A Serious Runaway Problem We found that YTC has an ongoing and severe runaway problem, but has not identified the causes or effectively addressed the issue. As a result, YTC has exposed its runaways, the community, and the state to unnecessary risks. Runaway Rates Our review of 25 randomly selected resident files revealed: 52 percent, or 13 of the 25, ran away from YTC at least once. 6 of the 13 who ran away did so more than once: 4 ran away twice and 2 ran away three times. For the purposes of this evaluation, we refer to a "runaway" as an unauthorized departure from the Center, accompanied with the intent not to return. We are not referring to cases where residents fail to get permission to leave the Center, yet intend to return. In numerous interviews around the state, we heard that runaways continue to occur at YTC. In late August 1995, three youths ran away from YTC. As of this writing, only two of them had been located and returned to YTC; one remains unaccounted for. Expected Runaway Rates We did not find a standard for what would be considered an acceptable or reasonable runaway rate at RTFs. However, runaway rates are generally expected to be higher at less secure facilities. Since YTC is a non-secure facility and is located near downtown Casper, it is relatively easy for residents to walk away. Thus, YTC must rely on programs and staff, not locks and fences, to maintain residents at the Center. DFS does not require reporting from RTFs on the number of runaways. Thus, we were unable to determine runaway rates for other non-secure RTFs in Wyoming. However, many judges, county attorneys, and MDT members told us that other non-secure RTFs in Wyoming also have a high number of runaways. In our sample of 25 from YTC, 52 percent had run away. We found that similar non-secure facilities in Tennessee reported runaway rates ranging from 1 to 21 percent, with an average of 18 percent. Risks Created by Runaways Residents who run away from YTC create risks for themselves, the community, the state, and YTC. Although some runaways may only be gone for a few minutes, others are gone much longer, and some may never be located. In most of the cases we reviewed, youths were located and returned to YTC. However, in our sample, two of the 13 who ran away were never located. These youths represent a vulnerable population. Away from YTC supervision and protection, they are at risk of becoming victims of crime or engaging in dangerous behaviors. Also, they are not receiving needed treatment. Runaways create risks to the community when they carry out criminal activities. In our sample of 25, two of the 13 runaways stole vehicles. MDT members and others told us of numerous similar cases in which runaways had stolen vehicles or had been caught breaking and entering. The state is liable for the damages caused by youths who run away from YTC. When a court orders a young person into treatment at YTC, the state becomes the custodian of the youth; consequently, the state is legally responsible for protecting the youth in its custody. Finally, high runaway rates have the potential of eroding confidence in YTC's ability to manage, protect, and treat the youth in its custody. Very few of the individuals we interviewed were aware of YTC's runaway rate. However, they were hesitant to place youths with some private providers who are believed to have high runaway rates. No Process to Reduce Runaways YTC does not have a systematic process to review runaways from the Center. It lacks a system to determine the number of youths who run away, to ascertain the causes of runaways, and to strengthen its program and security procedures to reduce the number of runaways. Our file review indicated that 56 percent of the youth, or 14 of the 25, had run away prior to being placed at YTC. Thus, youths placed at YTC are known to be high runaway risks. Nevertheless, it does not appear that YTC has adjusted its program or security procedures to accommodate this population. YTC officials attribute runaway problems to deficiencies in their facility. Specifically, they point out that YTC is a non-secure facility and thus, a certain number of runaways are to be expected. Also, they note that the design of the facility impairs staff's ability to monitor the residents. These arguments have some merit, in that they relate to areas beyond YTC's immediate control. However, YTC is directly responsible for program content and delivery and also for creating an effective security system. We believe YTC could reduce the number of runaways if it had a process to strengthen its programs and security procedures. Recommendation: YTC should develop a process to reduce runaways. Since YTC serves a high-risk youth population in a non-secure facility, it is unreasonable to expect staff to prevent all runaways. Nevertheless, YTC can take steps to moderate risks associated with this problem. YTC should develop a system to track the number of residents who run away, to determine the causes of runaways, to provide staff training on prevention, and to strengthen security procedures. These steps should contribute to reduced runaway rates. DFS recently requested informally that YTC report runaway cases to the Juvenile Services Division administrator. However, because YTC has not been routinely notifying DFS when residents run away, we believe DFS may not be fully aware of the extent of YTC's problem. Due to the size and seriousness of the problem, we believe more stringent measures are called for. DFS should require YTC, through rules or written policy, to report all cases of runaways immediately. In addition, YTC should be required to provide follow up reporting on steps taken and the disposition of these cases. Finding 5 Customers Are Dissatisfied With YTC Responsiveness Interviews with judges, caseworkers, county attorneys, MDT members, and families depicted a great deal of dissatisfaction with the timeliness and substance of YTC contact. Many local officials told us they had problems communicating with YTC prior to an admission, during treatment, and at the time of release. Ineffective communication diminishes the ability of local workers and the courts to effectively meet the needs of local youth treated at YTC. Many Counties Refuse to Work With YTC As a state facility operating within DFS, YTC has an obligation to work within DFS to meet the needs of youth, and also to serve the needs of local communities. However, due to communication problems with YTC, officials in several counties have refused to work with YTC. They opt instead to place youth with private providers. Some told us they simply grew tired of trying to place youth at YTC, only to be refused every time. YTC has not promulgated rules or developed policies for admission criteria, and placement officials said YTC does not provide a clear explanation when they deny an admission. Others stopped contacting YTC because they were not receiving feedback about a youth's treatment, or were not consulted about developing plans for release. Of the 31 local officials and parents we interviewed, 94 percent were dissatisfied with YTC's responsiveness. Eight of the officials either refuse to work with YTC, or rarely recommend placements there. One DFS worker said, "We don't call YTC anymore. We gave up on them." YTC's Unresponsiveness Directly Affects Local Officials Local officials are responsible for intervening in the lives of troubled youth, and the immediacy of these youths' needs are apparent at the local level. YTC's unresponsiveness impacts judges, county attorneys, MDT members, and DFS social workers in several ways. Initially, MDTs and the courts are under pressure to find placements for troubled youth, and often need a quick and definitive response to placement inquiries. During the course of an individual's treatment, local officials need to assess the effectiveness of treatment and make changes in placement, if necessary. Their ability to do this is limited without feedback from YTC. Finally, it is difficult to coordinate aftercare services for the youth without effective communication processes. Aftercare Should Be Adequately Planned Because admissions to YTC come from all over the state, YTC's ability to directly provide post-program support services is limited. Thus, an exchange of information between YTC and communities is essential to ensure that appropriate aftercare services are developed. Without aftercare, residents still return to the community, but the state has no assurance that the money spent in treatment will have lasting effects. YTC's annual operating budget is approximately $1.9 million. Based on an average length of stay, we estimate it costs more than $35,000 to treat an adolescent at YTC. The time and expense invested in youth during treatment need to be capitalized on when they return to the community. Establishing communication channels between local authorities and YTC is critical to this outcome. There is a lack of scientific data regarding the effectiveness and long-term outcomes of residential treatment for youth. Nevertheless, without service coordination between YTC and local authorities, it is clear that some youth may be "lost in the shuffle" when they are released from YTC. YTC Has Not Defined All of Its Clientele YTC has not recognized or defined all of its clientele. According to the superintendent, YTC operates under a Total Quality Management (TQM) philosophy. According to TQM principles, an organization should have a customer focus and should recognize that it may serve many customers, including members of the same organization. Establishing adequate feedback mechanisms for the customer is another important TQM principle. In its strategic plan, DFS identified the need to strengthen communication with internal and external customers. However, YTC views residents as its primary customers. While the youth they serve are certainly key clients, YTC has not fully acknowledged other clientele within the system. Consequently, YTC does not have a process in place to communicate with, or obtain feedback from, its diverse customer base at the following stages: Communication Prior to Admission. Eighty percent of the local officials we interviewed said that YTC's mission and admission criteria were unclear to them. One county attorney said, "We can call YTC with a number of kids with a variety of problems, and they tell us that none of our kids are appropriate for their program. It really makes us wonder who they do take." Several local officials also stated that it often took a week or two for YTC to decide to accept an adolescent. By comparison, they said private providers usually responded on the same day the request was made. Even after YTC accepted a youth, there were often waiting lists to get into the facility. One judge related that a youth had to wait six weeks to start the program. A delayed admission is of concern to local officials because it increases the time the youth goes without treatment. One said, "The amount of time it takes them to decide whether to accept a kid is a problem. We're trying to coordinate court dates, prepare social summaries, and we need their decision so the MDTs can make recommendations. If we can't get a kid in, we need to find somewhere else." Communication During Treatment. Many local officials who have placed youth at YTC believe the staff did not include them as an integral part of the youth's treatment. Most said they were not informed about the youth's progress during treatment. Others said they made repeated attempts to obtain feedback on the progress of youth at YTC, and would often not get a response for months. One judge stated, "We don't use YTC a lot. Kids get lost in their system. We had one kid there for six months, without hearing a word. We requested information, and didn't receive any. Ten months later we found out he'd been sent to the Boys' School, and we weren't even consulted." In our file review, we found that YTC initiated a median of only three written contacts with local officials during a resident's stay at the Center. YTC recently revised its written communication procedures and now sends monthly progress checklists to judges, DFS, and parents. However, our interviews indicate there is little support for the new format. We were told that, while the new procedure provides for more frequent feedback, the reports do not have much substance. Many parents perceived they were not welcome at YTC, and felt that YTC staff did not encourage them to participate in the treatment program. While some parents may not desire contact, or contact may be detrimental to the youth's treatment, other parents are invested in their child's life. One family related that for five months, they were given almost no information about their daughter's diagnosis, treatment, or prognosis, even though they showed a great deal of interest. Other parents had concerns because YTC staff did not consult them about the course of their child's treatment. Specifically, several parents raised concerns about the use of psychotropic medicines to treat their children. One mother said YTC staff did not notify her when her daughter was placed on several psychotropic medications, to discuss with her the need for medications and the potential side effects. She stated, "I wanted more input, but felt left out of the process." Communication at Release. YTC does not have effective procedures for notifying local authorities of residents' impending release. Local DFS social workers are responsible for arranging appropriate placements and aftercare for youths released from YTC. W.S. 14-6-303(b) states that no youth shall be granted a home leave until the institution makes a reasonable effort to notify the Department of Family Services' office nearest the site of the home leave. However, judges and social workers alike told us they frequently do not receive enough advance notice of a resident's impending release. As a result, they reported being rushed to consider new arrangements. One judge said he was shocked to see a former YTC resident on the streets of his community before receiving any notice of the resident's release. Similarly, DFS workers told us of instances where YTC residents were returned to their communities with little or no advance notice to them. Local authorities need adequate advance notice to ensure that appropriate placements are made and transition and aftercare services are in place. YTC Has Few Monetary Incentives to Please Their Customers Private providers must be responsive to placement officials if they wish to stay in business. They receive payment for each youth they are serving from funds allocated to local DFS offices; thus, their income is based on the number of residents served. YTC's funding, on the other hand, is determined by the Legislature two years in advance and is guaranteed, regardless of the number of youth served. Since DFS pays directly for private RTF placements, but considers placements at YTC to be "free," YTC is an attractive option. However, the result is also that YTC has no need to actively recruit residents for the program, and little incentive to maintain contact with placing officials once a youth is in treatment. One such official said, "If DFS had to pay for YTC slots, the Center wouldn't be full. This is due to their marketing process and administrative procedures." Recommendation: YTC should improve responsiveness to its broad range of customers. YTC needs to recognize it has many customers, including the local officials who are responsible for youth in treatment. YTC should take steps to identify its diverse clientele, in ways that enhance rather than diminish focus on the residents. YTC should develop rules concerning admission criteria, so placement officials can have more information about the process. It should develop a systematic approach for communicating with, and obtaining feedback from, key groups prior to admission, during treatment, and at release. YTC should also track customer satisfaction over time, and report their efforts as part of the strategic planning process. YTC should consider developing the following as part of a customer-focused process: Surveys. YTC could periodically survey customers regarding their satisfaction with YTC operations and to identify areas for improvement. Follow-up. YTC could routinely poll customers to see whether service changes actually yield desired results. Councils or Focus Groups. YTC could create a permanently established council, or convene focus groups, representing many levels of customers to work toward service improvements. Employee Training. YTC could offer customer service training to all levels of employees, delineating their responsibilities to the Center's broad range of customers. Complaint Tracking Systems. YTC could develop complaint tracking systems, one for residents and another for external customers, to ensure access to an impartial source for complaint resolution. YTC can achieve a more customer-oriented focus under the current funding structure. However, if administrative measures do not produce this change, DFS may wish to examine other options. It could consider alternative funding mechanisms which would hold YTC more accountable for services and outcomes. Some alternative funding mechanisms include: Contracting for a specific number of beds. DFS could contract for a certain number of beds at YTC, and provide a block grant for those services. YTC would compete with private providers to fill the remaining slots. Funding treatment on a per diem basis. DFS could divide YTC's budget among regional DFS offices. YTC would then need to compete for admissions with private providers and, like them, would receive funding on a per diem basis. This mechanism would eliminate "free" placements at YTC. Finding 6 Quality Control Systems Are Lacking at YTC YTC operates largely without external oversight and internal quality assurance systems which can promote program quality. YTC undergoes no external quality control review by the state or by independent accrediting entities. Also, YTC lacks an internal, formalized quality assurance system to continually assess and improve operations. Without these systems, YTC is isolated from the mainstream of residential treatment for adolescents. Residents and their families, the Legislature, and the public have no independent assurance that treatment provided at YTC is appropriate and safe. Protections Are Lacking YTC residents lack the protections afforded by quality control systems. Institutionalized individuals are commonly recognized as being at risk in numerous ways. They might receive substandard or unnecessary treatment, be harmed by inappropriate treatment, be subjected to abuse or neglect, or not be helped by expensive and extended placement in an institution. YTC appears to have a number of informal protections for residents in place. For example, it has a core of caring, committed staff, it generally hires licensed therapists, and it provides staff training. As important as these protections are, however, YTC should also have a formal system of quality control in place. Without such assurance, the state may not be properly discharging its duty to provide appropriate care. Also, it may be spending money on unnecessary or inadequate treatment. Negative Perceptions About YTC's Treatment Program We asked former residents, parents, judges, MDT members, and staff about YTC's treatment program. They acknowledged YTC staff for their dedication to helping young people, and while the program received both praise and criticism, the criticisms tended to be of a very serious nature. For example, we heard allegations about residents abusing substances while on campus, engaging in inappropriate sexual contacts, and being too heavily medicated. It was not our task to investigate such remarks in order to substantiate or disprove them. Instead, we note these negative perceptions as an area needing DFS attention. If true, the comments indicate a need for program improvement. If not, they need to be dispelled with facts, because unchallenged, they will erode YTC's credibility. As an unregulated, uninspected residential treatment facility, YTC is very susceptible to criticism and needs to safeguard its reputation. The lack of external oversight mechanisms and internal controls has created an "island atmosphere" at YTC. Because YTC does not actively solicit feedback, administration and staff at the Center may not even be aware that such concerns exist. Sources for External Review To protect vulnerable individuals in institutional settings, facilities often adhere to externally developed standards for services and treatment. Some sources for external quality review are: independent accrediting entities, insurance reimbursement programs such as Medicaid, and peer reviews. Although YTC has requested funds in the past to explore independent accreditation, the requests were denied. YTC does not currently participate in these programs and therefore cannot benefit from the rigorous reviews and requirements for improvement they impose. W.S. 14-4-101(a)(vi)(O) exempts YTC from state inspection and licensure requirements for residential treatment facilities. These requirements include a brief inspection, a review of certain records, and a check for minimum health and safety standards. Program oversight is not a part of the process. Private RTFs must be licensed by the state, but YTC is not required to meet even these minimal standards. Internal Review Process is Weak YTC has not developed its own rigorous program of quality assurance. YTC uses a loose process based on TQM principles. YTC administrators identify problems and areas needing improvement, and then appoint teams to study and make recommendations. This approach is not as likely to generate the same results as would a formal, systematic internal assessment process. Without a thorough and ongoing self-assessment process, YTC cannot assure that its program provides quality treatment. Furthermore, many staff members told us they had worked hard on these teams, but were discouraged by the lack of administrative follow through. DFS Exercises Insufficient Management Authority Since reorganization, DFS has offered YTC what might best be characterized as benign neglect: no structured oversight, and no plan to fit YTC into an identified role in the state's continuum of youth services. DFS has allowed YTC to continue operating largely as it did before reorganization, as an independent institution and self-contained operating entity. DFS officials told us they maintain regular contact with YTC, but provide supervision only on an as-needed basis. As one DFS official stated, the agency desired to "evolve them into our organization instead of forcing them...." Numerous DFS employees told us that YTC has not been enthusiastic about its inclusion in DFS. They see YTC as a rather unwilling partner. DFS administration has not ensured a consistent agency-wide approach to transitioning residents out of YTC. DFS and YTC appear to have incongruent philosophies regarding placement for residents who are about to complete the program. YTC focuses almost exclusively on the child's needs and preferences, and these may not center around returning home. DFS strongly advocates family reunification as the primary mechanism for meeting youths' needs. Many of the DFS workers we interviewed spoke of the difficulty of reconciling these two points of view when residents leave YTC. Finally, DFS does not require YTC to report serious incidents involving residents and staff to the director or a designee. Thus, serious incidents such as suicide attempts, runaways, and medical emergencies could go unreported or could be misrepresented to DFS. If such circumstances were to occur, DFS would not have the opportunity to exercise its management discretion and intervene, and residents could be at risk. We believe this is an important enough aspect of management oversight to merit written rules. Recommendation: DFS should develop and implement a plan for providing effective oversight and internal review at YTC. Prior to reorganization of state government and the repeal of the Board of Charities and Reform, the five elected officials visited state institutions annually. BCR's successor organization, DFS, has not carried on this "inspection" custom, nor has it developed alternative means of supervising YTC. Consequently, YTC operates without the state oversight and independent scrutiny that would help ensure quality of care. At this time, the Center appears to be respected for its caring staff and commitment to youth. However, continuing to operate as an independent, isolated entity could seriously undermine the program's effectiveness. To protect the interests of its residents and of the state, YTC needs to be made a part of a larger framework. As part of the strategic planning process, DFS could establish a goal of developing performance measures related to effective oversight for YTC. All parties stand to benefit from external and internal quality assurance programs at YTC. Conclusion Because the Management Audit Committee requested a focused study emphasizing YTC, not the larger youth services system, our findings and recommendations are intended to strengthen the Center's operations. However, they necessarily will need to be considered in a broader context. We identified a number of specific operating problems which DFS and YTC can address now. At the same time, policy makers also need to be working toward resolution of a number of related and over-arching public policy matters. Questions for consideration, some of which have been noted in prior studies of the youth services system, include: What are the state's expectations for court-ordered placements? How can YTC best fit into the state's youth services system? Should the YTC continue to provide services which are also available in the private sector? Which agency should run the state's mental health system? The state's youth services system, with its various components, has evolved over a period of many years to meet specific local needs. However, those needs are changing and new stresses to this system appear to be driving a demand for change. One significant factor is sharply rising expenditures for court-ordered placements. Another is the increasing number of youth entering the system, as well as the severity of their problems. In 1995, the Legislature appointed a Select Committee on Court-Ordered Placements to explore these and other issues. For several years, the Wyoming Department of Health has been discussing whether to close the adolescent treatment unit at the State Hospital. This debate brings to the forefront the question of how the state will diagnose and treat psychiatrically needy children and adolescents in a secure setting. As of this writing, a comprehensive proposal has not emerged, but certainly one possibility would involve redefining YTC's mission and upgrading its facilities in order to accommodate this population. Another would be to explore the benefits and costs of privatizing these services. The Legislature faces a fundamental decision regarding YTC: should it continue to operate according to status quo, be changed, closed, or is another policy direction desirable? Regardless of which decision is made, we believe the recommendations in this report have implications for the entire youth services system. They speak to the state's obligation to ensure that youth treatment is delivered in an environment and manner which promote high quality treatment, safety for residents, retention of skilled staff, and attainment of desired outcomes. These are some of the fundamental principles on which the Legislature and DFS must base any system of managing inpatient treatment for at-risk youth. Whether that will include a YTC as we know it today remains for the Legislature to determine.