Hathaway Building, 2300 Capitol Avenue, Cheyenne, WY 82002-0490
(307)777-7561
fax (307)777-7747
Internet:ttasse@missc.state.wy.us
October
11, 1999
The
Honorable Jim Twiford
Chairman,
Management Audit Committee
Legislative
Services Office
State
Capitol Building
Cheyenne,
WY 82002
Re: Child Protective Services Audit
Ref: SRC-99-298
Dear
Senator Twiford,
Recommendation: DFS should implement an institutional
research function to evaluate both program and administrative effectiveness.
Partially
Agree
Two years ago one consultant position was dedicated
one-half time to data collection. Part of the duties for this position includes
some analysis of the data that is collected.
In-depth analysis is not possible due to a lack of resources to hire a
trained statistician.
The federal government has established seven
outcomes for child welfare as they relate to safety, permanency, and
well-being. DFS has incorporated these
outcomes in our newest strategic plan.
The methodology developed involved determining what data to collect, how
to collect that data, and established baselines. These outcomes were only available in draft form during the time
LSO was conducting this review.
The Staff Assistance Visit (SAV) review form used
for child welfare has been developed through field and state teamwork. This method corresponds with the federal
goals and outcomes. After a year of using this tool, evaluation will be
done. The state office will also use
aggregate results from the SAV reviews to assess the information gathered from
the reviews.
DFS is applying for participation in a federal project
focused on management and supervision using data. If Wyoming is approved for participation, managers and
supervisors will be trained and methods and goals will be developed.
It should also be noted that after the LSO review,
DFS was recognized nationally for almost doubling adoptions. Wyoming is number two in the nation. This is certainly one measurement of
effectiveness.
Recommendation: DFS should monitor and evaluate CPS intake,
investigation, and ongoing service procedures at the state level.
Partially
Agree
Page 20. Variation in Rejection Rates.
As described above, DFS will
continue to improve the SAV process as resources permit. A comprehensive review
should include a larger number of case file reviews to assure validity of the
sample. In addition, quality assurance
should be done at the regional level.
Emphasis will be placed on reviewing rejected allegations. To improve this process, additional staff
are needed. At this time, we have only
one full-time position. We will
evaluate and if appropriate initiate an increase in staff.
Page 20. Other Staff Collecting Intake
Information.
Three years of SAV reviews have not indicated a
problem with trained staff completing the intake process. Basic information may be taken by other
staff when a social worker is not available, but a social worker will call the
reporter for detailed information.
CPS rules prohibit untrained staff providing any CPS
service without direct supervision. In CPS core training, this is
emphasized. Current law allows for a
centralized intake process which could take advantage of modern technologies.
Page 21. Variations in
Substantiation Rates.
Data
analysis is appropriate and the Department will seek ways to complete this step
as resources allow.
Page 22. Investigation
Requirements, Ongoing Services.
This review done by LSO only looked
at electronic data, not at the hard copy files available in the local
offices. SAV reviews look at both the
hard copy case files and the computer data.
The need to officially establish
regulations around the definition of a case file is readily apparent. By so doing, reviews could be done using
only one source, the computer. Technological consideration would have to be addressed,
i.e., scanning equipment in every field office.
Procedures will be developed to
specify documentation of those present during an interview.
Page 23. Not
Known How Many Receive Ongoing Services
The capability of WYCAPS to provide
this information will be developed.
This should also increase confidence that children are being seen and
will pinpoint problems in this area.
Page 24. Variation
in the Rate of Contract Service Provision.
DFS will analyze this information to
determine the relationship between office size, availability of community
resources and utilization of those resources.
Page 24. Reasons
Services are not Provided.
See comments above regarding
official case file.
Page 25. Risk
Assessment not used as Policy Requires
Policy will be rewritten to
emphasize this requirement in ongoing cases.
WYCAPS forces response time assessment via the intake process. The Wyoming model is required to be used at
substantiation. The development of
Computer-Based Training will enable DFS to provide training and re-training on
CPS rules.
Page 26. State
Office Leaves Monitoring of CPS to Local Field Offices.
State
level review of social work decisions is monitored through fair hearings,
fatality and major injury review at the local and state level, the SAV process,
and by specific request at the state office level. All results of these monitoring efforts need to be consolidated
and analyzed.
Chapter
4. DFS Policies
Recommendation: DFS should develop more specific policies to
establish agency CPS practice expectations.
Partially
Agree
Throughout the years, both
nationally and locally, philosophy has shifted from less prescriptive to more
prescriptive depending on research and leadership. A concerted effort was made to reduce the Family Services Manual
by 60 to 65 percent. The points
outlined in this review have validity especially with the loss of veteran
staff. Prescriptive policy is necessary
with the high worker turnover we are experiencing, giving us an increased
percentage of inexperienced workers.
State and local DFS staff are scheduled to rewrite CPS rules, and policy
will become more balanced.
Chapter
5. Caseworker Turnover
Recommendation: DFS should assess the causes of high
turnover and develop a plan of action.
Partially Agree
Agree, on the whole, with all recommendations with
the exception of the final recommendation that DFS should assess the causes of
high turnover and development of a plan of action. The following comments are directed towards the conclusions
presented by that recommendation.
The Chapter Summary for Chapter 5 alludes to two
things. The first is that the agency's
efforts to reduce turnover for CPS workers has not resulted in a reduction of
turnover nor in the creation of a plan by the DFS to decrease the rate of
departures.
The first statement does acknowledge that the agency
has made efforts to reduce the turnover (departures) of CPS worker, but the
assessment of the effectiveness of the Department's efforts seems
conjectural. The second statement about
a plan is somewhat puzzling since it is the Department's recollection no one
asked the Department whether or not the Department had a plan to reduce CPS
staff turnover.
The Department did in fact develop a plan or
strategy to reduce staff turnover based upon reducing the individual worker's
CPS caseload, increasing workers' compensation, and increasing the number of
workers with social work or closely related degrees.
The reduction in caseload was approached both by
presenting requests for additional CPS worker slots and through reallocation of
existing positions. The closure of the
Wyoming Youth Treatment Center resulted in 11 new probation and CPS worker
positions being assigned to various field office locations. In addition, the Department put in place a
staffing model which has resulted in several more new probation/CPS worker
positions being created from existing positions already assigned to field
offices. This latter process continues
to this day.
The Department has also taken steps to increase
compensation to CPS staff. For
instance, some years back and based upon Fair Labor Standards Act (FLSA)
rulings, the Department re-designated all line CPS staff from exempt to
non-exempt. This change made CPS line
staff eligible for overtime pay beyond forty (40) hours a week. The Department, prior to the recent change
in the state's classification and compensation systems, routinely reclassified
CPS workers in entry level Social Worker I positions with two years of
professional level social work at the Social Worker I level (entry level
classification) to Social Worker II (journey level classification)
positions. The difference in pay grade
minimums between the entry and journey resulted in as much as a 19.4% increase
to some workers. The Department supported
a change by the State Division of Human Resources that moved entry level CPS
workers from a pay grade 6 to a pay grade 7 resulting in a 5.95% increase in
the grade minimum rate for entry-level CPS workers. The Department also planned and implemented a three stage market
pay adjustment plan (including that mandated as a result of the reversion of
general fund dollars to state agencies) and one general pay adjustment increase
for all DFS workers. The general result
has been to substantially increase the compensation of CPS workers over
previous levels. Finally, the
Department's most recent effort to improve CPS worker compensation is to
implement on-call pay compensation for those CPS workers designated to be
available 24 hours a day for call back to work emergency CPS cases.
The Department has put in place a requirement that
in hiring new CPS workers or promoting existing CPS workers, a preference is
given to workers with bachelors or masters degree in social work or a closely
related field. The requirement is
intended to increase timeliness and quality of CPS cases and reduce the
potential liability of ineffective casework decisions to the client and the
Department.
The Department has attempted over the years to
assess why CPS turnover occurred. These
efforts resulted in a conclusion that lower caseloads, consistent increases in
compensation, and career development were issues important to CPS workers. The development of more consistent,
comprehensive, and innovative policies and programs in areas such as
recruitment and retention has been hampered by the lack of available staff time
in the DFS Human Resources Unit.
Available staff time is almost completely directed to carrying out
mandated human resource and pay functions, which are increasingly more complex
and time consuming under newly, implemented systems. For example, the Department estimates it now takes twice as long
to obtain a certificate of eligibles from an existing register (two weeks versus
one week) even though no additional recruitment is required. It is also necessary to divert more and more
staff time to increasingly numerous and complex employee grievance
hearings. Requests have in the past
been made for an additional full time equivalent (FTE) professional staff
position to develop and maintain formal policies for non-mandatory functions
such as recruitment and retention programs but resources could not be made
available.
The time factor is very important since every day a
CPS position is vacant is a day another CPS worker must assume the additional
caseload resulting from a CPS position being vacant. It is also important to try and hire workers with the proper
credentials in order to achieve an end result of more effective workers once
the initial training and orientation period is completed. This is especially true when consideration
is given to the necessary lag time (at least one-year) of training and
orienting new workers.
Retention is important, but the workers retained
must be those with the most appropriate type and level of knowledge and
experience. It is important in this
regard to state that many of the factors necessary to recruit and retain high
quality workers are not under the Department's control. Factors relating to statewide policies and
budgets influence retention and hiring factors such as provision of health and
life insurance benefits. These and
factors relating to increases in individual compensation are more influenced by
the revenue sources available to the state and how the state chooses to allocate
those resources.
The Department of Family Services
requests support from legislators to increase pay and increase staff, so
caseloads can be reduced.
Chapter
6. Counting and Measuring Workload
Recommendation: DFS should develop a workload methodology
and an updated workload standard.
Agree
We
find the statements made in this chapter are generally true and accurate. The Department has, in fact, used weighted
caseload counts in the distant past. We
have also had adjusted work standards for the differences between larger office
(who can specialize workers in types of cases) and smaller offices (where
workers have the added burden of covering for sick or absent staff in any
unit). Because of the need to implement
the new social services computer system (WYCAPS), the agency has tried to
maintain the current caseload measurement until such time as the new system was
functional. This “shakedown period”
would allow the workload design to be a final product and the agency
standard. The time is right to complete
the process recommended by the LSO study.
We will be considering a “real time study” for the actual hours required
to appropriately perform all mandated social services functions
To effect the suggested process, DFS staff contacted
staff from A.T. Hudson & Co. Inc. during a national conference and
discussed the workload study they are currently conducting for the Denver
County Colorado Social Services Office.
Arrangements are underway to attempt to bring A. T. Hudson & Co. to
Cheyenne to demonstrate the study process being used in Colorado. We hope to determine this study's
appropriateness for a similar Wyoming study.
If this meeting moves to the next stage, we anticipate A.T. Hudson &
Co. and other vendors will evaluate the Wyoming request to project the
anticipated cost of the request for Wyoming and submit bids. Region Managers from the field, and Central
Office staff will prepare the Wyoming Workload Standard request for submission
and bid. LSO staff may be invited to
participate to make certain the process meets their findings and
recommendations as determined by this study.
The outcome of the workload study will become the baseline standard for
all Wyoming projections of staffing needs and workload levels compared to the
national standards quoted in the LSO study.
The fix to this recommendation is legislative
support and funding for additional supervisory positions.
Chapter
7. Supervision
Recommendation: DFS should strengthen its supervisory
structure.
Agree
In response to budget reduction
pressure, the Department of Family Services has reduced management through the
creation of districts. This has
actually increased social work supervision expertise, but it has created a
proximity problem. It has increased
distances between management/supervision and field offices. We would further point out the loss of one
of the supervisory positions in Laramie County. This was due to a legislative cut of a vacant position because of
our inability to attract a well-qualified person in a timely manner.
Chapter
8. CPS Training
Recommendation: DFS should assess how to enhance ongoing CPS
training.
Agree
The state office responded as
follows: DFS has always been aware of
the need for more training but lack of resources have precluded the type of
advanced training that is needed. The development of Computer-Based Training
will certainly improve the system. Each
year, a Social Services Conference is held and national experts are brought in
to train. Not everyone is able to
attend because of the need to be on-call for CPS. Grid trainings have been held much more frequently since the
passage of ASPHA. Refresher CPS core
curriculum needs to be developed.
The field office responded as
follows: There appears to be a need for
clear communication and understanding about the DFS training budget which could
be used for on-going CPS training.
Managers seem to be relying on local budgets for on-going training needs
when they could be utilizing a state training budget which would increase
training opportunities.
Conclusion:
We
appreciate the effort the Legislative Service Office staff made to understand
the system in which our staff works. We
believe the LSO staff made a concerted effort to evaluate the work of our
people as fairly as they could in the brief time span they were given to
produce their report.
It has been long recognized in the Department, there
was a need to improve the data collection systems used by the majority of the
DFS workers. DFS had the request before
the legislature for two sessions before the funding was finally approved for
the development of WYCAPS. We believe
WYCAPS is a good data collections system and we have taken it as far as we
could, given the 18 months of time we have had to work with it and the
information it generates. With the
pressure to reform the welfare system, the need to increase the child support
collections and the continued focus on the juvenile justice system, staff time
has been directed to the most immediate and critical need as required by the
federal or state mandates. We are proud
of the fact our few people have been able to balance all of the numerous
mandates and deliver quality service that competes favorably with every state
in the Union.
Though it is true, we cannot point to one or two
data reports which prove the Department is delivering effective and efficient
child protective services, we maintain we can demonstrate this to the public’s
satisfaction by case documents and our internal reviews. Still, we agree with the LSO assessment of
the need to have simple and appropriate measurements, which meet or exceed
national standards.
We fully intend to implement the vast majority of
the LSO recommendations if we receive legislative support through funding and
case worker position increases. We
respectfully request vacant positions not be arbitrarily cut from the DFS
budget, but rather reviewed first for potential impact.
Wyoming is one of only a very small number of states
not currently under a court mandate to improve child protective services. We do not want to wait until that
requirement forces us to change our procedures. We hope this report is sufficient to begin the process and we
will report on our progress as we complete each recommendation.
Sincerely,
Shirley
R. Carson
Director
SRC/tat
cc: DFS Administrators