Child Protective Services
November 1999
Management
Audit Committee
Senator
Jim Twiford, Chairman
Representative
Eli Bebout, Vice Chairman
Senator
Henry H.R. “Hank” Coe
Senator
Keith Goodenough
Senator
April Brimmer Kunz
Senator
Mike Massie
Representative
Deborah Fleming
Representative
Randall B. Luthi
Representative
Wayne Reese
Representative
Colin M. Simpson
Representative
Bill Stafford
GLOSSARY
List
of Acronyms
AHA American
Humane Association
ASFA Adoption
and Safe Families Act of 1997
CA/N Child
Abuse or Neglect
CPS Child
Protective Services
CPT Child
Protection Team
CWLA Child
Welfare League of America
DFS Department
of Family Services
GAO Governmental
Accounting Office
NCSL National
Conference of State Legislatures
POWER (TANF) Temporary Assistance for Needy Families
SAV Staff
Assistance Visits
WYCAPS Wyoming
Children’s Assistance and Protection System
EXECUTIVE
SUMMARY
Child
Protective Services
CHAPTER 1:
Background
The Legislature has charged the Department of Family Services
(DFS) with administering statutes enacted to investigate allegations of child
abuse and neglect (CA/N), and to provide protective services when
necessary. Child Protective Services
(CPS) within DFS is organized as a state-administered system with field offices
implementing the processes necessary to protect children from abuse and neglect
and provide them with services. When
field offices receive reports of CA/N, caseworkers must verify that the reports
meet legal definitions for investigation, investigate reports meeting statutory
definitions of CA/N, and provide case management and services when abuse or
neglect is substantiated.
We found DFS child protection workers
generally to be hard working, dedicated, and concerned about children. However, DFS could benefit from additional
state-level evaluation of both the CPS program and management issues affecting
the program. Our recommendations will
help DFS ensure that its goals for abused and neglected children can be
accomplished in all cases.
CHAPTER
2: Evaluating the CPS Program
While field offices understand
individual CPS decisions, DFS has not systematically evaluated the cumulative
impact of CPS strategies on program effectiveness. Ad hoc studies and local monitoring have been the main avenues of
evaluation. State-level understanding
of the aggregate impact of local CPS decisions is needed to understand both how
the program works in its entirety and to better apply limited resources. Without this understanding, there can be no
assurance that children are best served under current conditions.
DFS needs to recognize that data
analysis is a critical component in providing effective CPS and develop a plan
for systematically looking at program outcomes and the effects of
administrative processes on those programs.
Data collection and protecting children are not mutually exclusive;
rather, the collection and use of data in decisionmaking should enable the
agency to better protect children.
Recommendation:
DFS should implement an institutional research function to evaluate both
program and administrative effectiveness.
CHAPTER
3: Intake, Investigation, Ongoing
Services Procedures
Our analysis of CPS processes revealed
potential problems with CPS intake, investigation, and ongoing service procedures. Historically, DFS has not systematically
evaluated CPS procedures to identify potential operational shortcomings. Although DFS needs to rely on caseworker
judgment and supervision to monitor the appropriateness of individual
decisions, the state office also needs to assure these procedures are being
carried out as intended, to determine compliance with requirements, and to
examine the quality of services provided.
Overall lack of documentation at
critical points of procedure, and variations among field offices in what is
documented, raise questions about consistency and internal safeguards
associated with how DFS provides child protective services. Since DFS does not regularly monitor and
evaluate these procedures, the state office cannot assess the overall
effectiveness of methods used by local offices. Without monitoring and evaluating intake, investigation, and case
management procedures, DFS cannot make informed decisions about how or when to
modify policies and strategies.
Recommendation: DFS should monitor and evaluate CPS intake,
investigation, and ongoing service procedures at the state level.
CHAPTER
4: DFS Policies
DFS policies for CPS practice vary in
their specificity. For example, DFS has
written little policy regarding how often and under what circumstances
caseworkers should see children who are receiving ongoing services. There are no policy expectations that
caseworkers see children receiving services who remain in their homes, often
with the persons who abused or neglected them.
Agency officials have intentionally
written some DFS policies without specificity to allow flexibility and judgment
to guide caseworkers who provide CPS, and to allow field offices to tailor
practices to fit community standards.
We believe the agency has preserved this flexibility at the expense of
providing adequate guidance to workers or
conveying internal practice expectations for CPS.
Policies are important in the
decision-laden CPS process because they provide structure in the stressful environment
in which caseworkers function, and reduce the probability of making serious
mistakes. Further, well-defined
practice expectations established through policy provide a means to hold
caseworkers accountable for their CPS decisions.
Maintaining broad policies for CPS
practice is particularly a concern because of the conditions DFS faces in
providing CPS throughout the state.
These conditions include high caseworker turnover and caseloads in some
offices, a small percentage of caseworkers with social work backgrounds,
difficulties in providing ongoing training, and the sharing of supervision
among field offices.
Recommendation: DFS should develop more specific policies to
establish agency CPS practice expectations.
CHAPTER
5: Caseworker Turnover
Professionals recognize on-the-job
experience to be a key factor in providing good social work. In FY99, 33 percent of DFS caseworkers left
the agency. Turnover affected two-thirds
of field offices. As of August 1999, 40
percent of DFS field office caseworkers had less than two years experience.
Turnover has a negative effect on
children, on families, on caseworkers, and on the agency. Loss of a caseworker means loss of
continuity in cases, loss of experience necessary for quality outcomes, loss of
good judgment, loss of understanding of community networks and an increased
workload for remaining caseworkers and supervisors. High turnover leads many caseworkers to believe that they are
just doing crisis management rather than providing quality intervention, and
this in turn contributes to burnout and higher turnover. The agency’s efforts
so far have not resulted in a reduction of turnover or in the creation of a
plan to decrease the rate of departure.
Recommendation:
DFS should assess the causes of high turnover and develop a plan of action.
CHAPTER
6: Counting and Measuring Workload
Historically, DFS has reported that
workloads are too high. But we found DFS does not have a meaningful way of
counting or measuring workload. Because workloads are a major factor affecting
the quality of CPS, DFS needs reliable information about workload trends.
In addition, DFS does not have a
standard for or definition of manageable workload. The 25 cases per caseworker set as its standard for reasonable
workload in 1986 was based on a conservative guess at what might be an
attainable workload, not on a staffing study that considered the specific tasks
and responsibilities of caseworkers.
Furthermore, the load and nature of casework has changed significantly
since 1986 when the current workload was established. DFS needs to develop
workload standards using a methodology specific to the tasks and activities
expected of caseworkers.
The CPS function could be strengthened
by accurate reporting of workloads, measured against standards that are
meaningful for the different types of field offices in Wyoming.
Recommendation:
DFS should develop a workload methodology and an updated workload standard.
CHAPTER
7: CPS Supervision
The nature of CPS work demands that
many casework actions and decisions be made in consultation with a
supervisor. While supervision is key to
the CPS process, we noted several factors that strain the ability of DFS’s 19
social work supervisors to perform the function. For example, because smaller field offices share supervisors,
many CPS caseworkers do not have on-site supervision available to them at all
times. In addition, high turnover,
on-the-job training of new workers, the agency’s minimal use of policies, high
caseloads and the need for some supervisors to carry caseloads increase
pressures on supervisors.
Our survey of caseworkers indicated
that supervision may not occur when or as often as the agency expects. For example, just half of the caseworkers
responding to our survey indicated they obtained supervisory review as they
monitor CPS cases. We found that DFS
does not have adequate system assurances that caseworkers obtain adequate
supervision, such as policies that incorporate supervisory responsibilities or
specialized supervisory training. Given
current trends, DFS will likely continue to rely upon its supervisors to train
and supervise caseworkers who have little experience and no formal social work
training.
Recommendation:
DFS should strengthen its supervisory structure.
CHAPTER
8: Training
Ongoing training in the CPS field is
essential to ensure that caseworkers have the specialized skills and knowledge
necessary to provide quality CPS services.
Due to high turnover among caseworkers, DFS has needed to focus most of
its training resources on training new workers. Despite agency efforts to enhance training opportunities beyond
that provided for new workers, more tenured caseworkers do not believe their
needs for ongoing training are being met.
Only 15 percent of caseworkers reported receiving regular training
beyond the core curriculum. DFS has not
instituted advanced training requirements for its caseworkers to maintain CPS
certification.
DFS has hesitated to identify training
funds in field operations budgets, believing the Legislature would target such
funds for cuts. Yet, by doing so, it
may be undermining the agency’s professed emphasis on training. National criteria stressing the importance
of ongoing training for CPS workers combined with the agency’s relatively inexperienced
caseworker staff provide strong justification for the agency enhancing its
training program.
Recommendation: DFS should assess how to enhance ongoing CPS
training.
CHAPTER
9: Conclusion
DFS officials have a strong intuitive
sense that the state’s CPS program is providing safety and support for Wyoming
children and families. Our research
neither proved nor disproved that belief, only that the agency has not
systematically collected and analyzed information to verify its internal
perception. DFS monitoring procedures are inadequate to determine effectiveness
of programs except in case-by-case review.
During our evaluation the agency
stressed its emphasis on keeping caseworkers and resources focused on
protecting children and helping families.
This goal is not at odds with strategic data collection and
analysis. An agency-wide commitment to
rigorous data collection and analysis at the state level would allow DFS to
more strategically focus its CPS efforts and enable DFS to provide the field
with the analytical support and training to make individual caseworkers more
effective.
Scope
and Methodology
A. Scope
W.S. 28-8-107(b) authorizes the
Legislative Service Office to conduct program evaluations, performance audits,
and analyses of policy alternatives.
Generally, the purpose of such research is to provide a base of
knowledge from which policymakers can make informed decisions.
In May 1999, in response to a
legislator’s request, the Management Audit Committee directed staff to
undertake a review of child protective services (CPS) within the Department of
Family Services (DFS). Our research
centered around the following questions:
·
What procedures has DFS established to
receive and screen reports of child abuse and neglect and to investigate them?
·
How does DFS provide services to
victims and their families and what are the outcomes?
·
To what extent does DFS monitor and
supervise child protective services as carried out at the local level?
·
How well is DFS adhering to its own as
well as national standards?
·
What kinds of evaluation does DFS do to
ensure high quality and uniform CPS statewide?
·
What procedures has DFS established to
ensure there are internal safeguards for the CPS system?
·
Are there management issues pertaining
to CPS that affect program quality?
We limited
our evaluation to reviewing these aspects of DFS’ responsibilities for child
protection. Our evaluation did not
include a review of the larger child welfare system, the agency’s
responsibility for prevention of child abuse and neglect, or the effectiveness
of service providers. We did not
include the Wyoming Risk Assessment Model or the Central Registry of Child
Protection Cases in the scope of our study.
We also did not look at the Wind River Indian Reservation, which
provides separate social services, because it is currently undergoing
organizational change.
B. Methodology
This
evaluation was conducted according to statutory requirements and professional
standards and methods for governmental audits. The research was conducted from May through August 1999.
In order to
compile basic information about child protective services, we reviewed relevant
statutes, statutory history, annual reports, budget documents, strategic plans,
rules, policies, training manuals, and other internal documents. We reviewed a considerable body of
professional literature about child protective services.
We visited
seven local field offices; the offices were of all sizes and at least one was
located in each of the four DFS regions.
We conducted extensive interviews with field office managers and CPS
staff, regional managers, state office officials and staff, and other
individuals familiar with CPS.
To gather
information specific to how CPS is carried out in Wyoming, we submitted a data
request to DFS and worked with the agency to analyze and interpret the data
they provided. Using electronic means,
we reviewed a random sample of 100 CPS incidents to gain an understanding of
CPS procedures. However, we did not
review the corresponding hard-copy files for these incidents, nor did we review
the quality of DFS’ decisionmaking. We
mailed surveys to all DFS caseworkers, supervisors, and managers to gain a
broad understanding of their perspectives and to gather certain system data. We received a 78 percent survey response
from caseworkers and an 84 percent response from supervisors and managers.
C. Acknowledgments
The
Legislative Service Office expresses appreciation to those who assisted in this
research, especially to the Department of Family Services and its personnel
throughout the state. We also thank the
many other government and nonprofit sector individuals who contributed their
expertise.
CHAPTER
1: Background
In the United
States, societal awareness of the abuse and neglect of children began to emerge
late in the 19th century. However,
child physical abuse did not receive widespread attention in this country until
a 1962 medical journal article discussed patterns of suspicious injuries in
children. Within four years, all 50
states had passed laws requiring certain professionals to report cases of
suspected child maltreatment. These
laws were intended to protect children because they are a particularly
vulnerable portion of the population.
As reporting
increased, states developed systems to support their child protection
responsibilities, and a number of federal laws (see Appendix A) were enacted
that have guided the development of states’ child protection systems. The primary responsibility for responding to
cases of child maltreatment rests with state agencies. States must comply with federal child abuse
and neglect guidelines to receive federal funds. However, beyond that, states
have some autonomy in how services are provided to abused and neglected
children and their families.
Wyoming’s
CPS Law and Rules
Wyoming’s
comprehensive Child Protective Services Act was enacted in 1977, and remains
substantively intact in current statute.
The purpose of the child protection statutes, W.S. 14-3-201 through W.S.
14-3-215 (see Appendix B), is generally to protect the best interest of
children, to protect them from abuse or neglect which jeopardizes their health
and welfare, and to provide protective services when necessary. Further, statutes declare the state’s purpose
as stabilizing the home environment and preserving family life when possible.
The
Legislature has charged the state’s child protective agency, the Department of
Family Services (DFS), with administering these statutes. To achieve the goals in law, DFS has
identified child protective services (CPS) as one of its core
responsibilities. However, laws
actually direct DFS field or regional offices to implement the processes
necessary to protect children from abuse and neglect, and provide them with
services (see Appendix C for a description of typical stages in the handling of
CPS cases). Further, Wyoming law
requires all persons who know or have reasonable cause to believe or suspect
that a child has been abused or neglected to report that information to the
child protective agency or local law enforcement.
Receiving
and Investigating Child Abuse and Neglect Reports
Nationally,
the number of cases of suspected maltreatment of children has increased greatly
from 1962 to the present. Experts
attribute this growth to two major factors:
there is greater awareness now of abuse as a social problem than there
was over 30 years ago, and the definitions of maltreatment have been expanded.
In Wyoming,
statistics about suspected maltreatment have been collected by various methodologies over time, and thus are
not always comparable. However, based
on data we compiled from various DFS sources, it appears that between 1986 and
1998, reports of maltreatment of children in Wyoming have increased by about 40
percent.
Intake
Process. When
a DFS field office receives a report of suspected child abuse or neglect
(CA/N), agency personnel must verify whether the report meets the legal
definition of CA/N. The agency process
of screening reports at this stage is known as “intake.”
If the report
meets the statutory definition of CA/N, DFS will accept the report for further
investigation. If the report does not
fall within the scope of CPS, the report is rejected and not investigated. In FY99, DFS received 5,469 reports of
CA/N. After comparing the reports with
criteria for acceptance in statute and rules, DFS accepted two-thirds of the
reports for further investigation.
Investigation
Process.
Reports of CA/N that DFS is required to investigate are defined
generally in statute, but DFS rules further define categories of maltreatment
to be investigated. DFS is mandated to investigate: physical abuse; nutritional deprivation; medical care neglect;
intentional drugging or poisoning; sexual abuse; psychological abuse and neglect;
emotional abuse; lack of supervision; negligent treatment; withholding needed
medical treatment from handicapped infants; and abandonment.
We compiled
information on reports investigated by DFS in FY99 and found the most common
type of abuse investigated was negligent treatment; the next most common was
physical abuse. Allegations can range
from a child reportedly left alone in a car for a few minutes, to a report of
multi-generational physical and sexual abuse in a family. Figure 1 shows the types of maltreatment
investigated by DFS in FY99.
Figure 1: Maltreatment Types Investigated by DFS
FY99
Source: LSO analysis of WYCAPS data.
By law, DFS
field offices must initiate an investigation of every report verified as
meeting the rule definitions of CA/N within 24 hours of notification. CPS rules require even more immediate
investigation for certain types of reports, such as complaints involving
serious physical harm and cases involving young children left alone.
Agency
personnel must conduct thorough investigations to determine if there is
credible evidence that abuse or neglect occurred, and if the child is at
risk. If these two conditions are met,
a caseworker then takes action to protect the child from further abuse or
neglect. However, DFS has no unilateral
authority to remove children from their families. Only a physician or law enforcement officer can take temporary
protective custody of a child.
By rule,
caseworkers have 60 days to investigate a report of CA/N, but are allowed a
30-day extension in certain circumstances, such as when law enforcement
conducts the investigation. Upon
completion of the investigation, DFS staff make a determination as to whether
the child was abused or neglected. This
determination is based on whether or not the information gathered during the
investigation constitutes credible evidence to “substantiate” the report. If the investigation did not reveal that
CA/N occurred, the report is “unsubstantiated.” Unless the family requests services, DFS will close the case and
no longer be involved with the family.
Of the 3,688
reports accepted for investigation in FY99, DFS investigated 4,444 allegations
associated with those reports.1
Of these allegations, DFS substantiated 1,533 of them (33 percent). Substantiated cases are classified as either
low risk, moderate risk, or high risk.
This risk classification relates to DFS’ assessment of likely future danger
to the child.
Information
from substantiated reports where DFS finds there is moderate or high risk of
the maltreatment recurring are placed on the Wyoming Central Registry of Child
Protection Cases and maintained indefinitely.
The Central Registry is a legislatively mandated system used to identify
perpetrators in an effort to better protect children.
Once the
investigation is completed, the case may be closed by DFS unless the family
voluntarily accepts services or if services are ordered by the court. In those cases, DFS provides ongoing
services.
1 Reports of maltreatment may involve more
than one child and/or may involve more than one allegation of
maltreatment. For example, one report
may contain four allegations involving two siblings who are alleged to have
been both physically abused and sexually abused.
Providing
Ongoing CPS Services
After a CPS
investigation, the help DFS can
provide to a family to eliminate child maltreatment is referred to as “ongoing
services.” A DFS caseworker begins to
provide ongoing services by assessing the family’s strengths and weaknesses
and, with client input, formulating a case plan with specific goals and tasks
designed to help the child and family.
Case plans are to have one of five overall goals: family preservation, family reunification,
adoption, independent living, or other permanent living arrangement.
Case
Management Services. Case
management is the primary responsibility of caseworkers, and the mechanism
through which DFS can also offer clients a range of more specific CPS services
to help correct the problems that caused the abuse or neglect. Case management entails the caseworker
developing a case plan, keeping all involved in service provision apprised of
relevant information, filing mandated reports, and calling case conferences.
Direct
and Contracted Services. In
addition to case management, DFS caseworkers can provide other services to
children and families to help correct the problems at the root of child
maltreatment. These services can be
provided directly by DFS or by contracting for services with local providers. Caseworkers determine the mixture of direct
and contracted services based on their own strengths, workload, availability of
services in the community, and availability of funds.
Some examples
of direct services which DFS would typically provide to clients are: parenting classes, home-monitoring visits, transportation, and supervised
parent/child visits. Caseworkers sometimes use the assistance of
40 three-quarter time family assistance workers (FAWs) in providing direct
services to clients.
A caseworker
can also arrange for services, such as mental health counseling or foster care
placement, to be contracted for with local providers. Contract services are paid for through a combination of client
resources, DFS resources, and community or federal funding. However, a full range of contract services
is not always available in every community.
A report on CPS from the National Conference of State Legislatures
(NCSL) says, “There is a general consensus that appropriate, effective,
accessible and affordable services to troubled families are not consistently
available in all communities.” The lack
of community-based services may be a more pressing issue for smaller
communities in rural Wyoming.
Who
Gets Services? Most
allegations of child maltreatment do not result in the provision of ongoing
services to the involved family. In
FY99, 19 percent of allegations investigated by DFS resulted in contract
services being provided, while 81 percent received no contract services. See Appendix D for detail.
There are valid reasons why a family may not receive services. For example, the caseworker may have
concluded the incident was a one-time, low-risk occurrence.
In FY99,
1,302 children received contract services through the CPS program. Of these 1,302 children, 328 remained in the
home and received contract services, and 974 children were in out-of-home
placement. Figure 2 on the next page
gives detail about the children in placement in FY99.
Figure 2: CPS Children By Types of Placement
FY99
ASFA
Requirements. The
Adoption and Safe Families Act of 1997 (ASFA) is a recent federal law requiring
state CPS agencies to initiate termi-nation of parental rights based on a
child’s length of stay in out-of-home placement. Unless there is a compelling reason for an exception, DFS must
seek to terminate parental rights
and establish permanent living situations for children who have been in
placement for 15 of the most recent 22 months.
ASFA is still being phased in and DFS estimates permanency has been
achieved for 280 children since ASFA requirements took effect in 1998.
Case
Closure. During
ongoing services, the caseworker monitors the child and family’s progress
during services and adjusts the case plan to reflect changing
circumstances. DFS can close a case
under a number of circumstances, from safely reunifying the child and family,
to termination of parental rights and finding an adoptive family.
Local
and State-Level Organization
DFS is
organized as a state-administered system which sets rules and policies at the
state level, while allowing some local flexibility in the provision of
services. This structure evolved from
an earlier county-based system under which local boards hired county managers and counties assessed mill levies in
partial support of welfare and social services. Subsequently, these functions were folded into a division of the
Department of Health and Social Services. Still later, with the 1991 reorganization
of state government, it became a separate department.
CPS
Funding.
Since CPS is one of many functions that DFS personnel at the local and
state levels perform, DFS has not budgeted separately for the CPS program. However, agency estimates based on the
FY99-00 biennial budget indicate CPS annual costs are approximately $11.7
million, or 14.5 percent of the total DFS budget. Included are expenditures for the field office personnel who
provide CPS services, the state-level staff who support CPS services, CPS
training, and a proportion of DFS administrative costs, such as financial
services.
A large
portion of CPS costs are contracted services arranged for by the agency as
treatment for victims and perpetrators of CA/N. DFS estimates that during the current biennium, approximately 35 percent
of CPS costs, or $4.1 million annually, will go for contracted services. This
amount covers out-of-home placements
in foster care, residential treatment, and other settings, as well as the costs
of community-based services such as counseling.
State
Office Organization.
At the state level, DFS’ efforts in CPS are centered within the Children
and Family Services Program in the Programs and Policy Division. This division also oversees 28 other welfare programs, including POWER
(TANF), Food Stamps, Medicaid eligibility, and others.
With a staff
of six, the Children and Family Services Program writes policy, interprets
federal guidelines concerning CPS, and provides technical CPS training. Further, the staff is available for
consultation with field office personnel.
The program is also responsible for other child welfare matters such as
adoption and foster care and the Interstate Compact on Placement of
Children. Another division at the state
office, the Field Operations Division, is responsible for program delivery,
working directly with regional managers and the field offices.
Local
Organization. DFS
staff are state employees who work out of 29 field offices (not including the
Wind River Reservation) and small satellite offices (which are not staffed
full-time) throughout the state. DFS
has clustered the field offices into four regions, each with a regional manager
acting as liaison between local offices and the state office. The regions are large; for example, Region 2
includes the towns of Afton and Lovell, which are nearly 300 miles apart.
Because of
the state’s geographic size and dispersed population, DFS staff in many areas
must travel to provide regular services to smaller communities. Each county has at least one DFS office, yet
field office managers, casework supervisors, and caseworkers often have
responsibility for more than one office.
Region 1 has ten office locations but only three field office managers.
One-third of
the DFS offices may be considered very small, as they have only one or two
caseworkers. The two largest DFS
offices, Natrona County and Laramie County, have 18 and 17 caseworkers
respectively. The remaining
“medium-sized” offices range from 3 to 12 caseworkers. In FY99, DFS had 125 caseworker positions
and 19 supervisor positions.
In Natrona
and Laramie Counties, and some of the medium-sized offices, caseworkers and
supervisors specialize in providing CPS.
In the remaining offices, caseworkers do generic social work, carrying
mixed caseloads that include juvenile probation, adult protective services, and
youth and family services. Based on
agency-reported figures, CPS cases grew 14 percent between FY95 and FY 98, and
in FY98, represented 44 percent of all cases handled by DFS caseworkers. See Appendix E for detail.
Because of
differences among offices in staffing size and specialization, it is difficult
to describe a typical DFS field office.
Nevertheless, all DFS caseworkers must handle CPS work during the course
of their work: some are CPS
specialists, some carry a generic caseload that includes CPS, and others must
be prepared to do CPS when performing on-call rotation. However, DFS social service caseworkers are
not involved in providing economic assistance services: a separate group of workers and supervisors
handle those programs.
Conflicting
Pressures on the CPS System
An effective
child protection system does not rely solely on the efforts of one child
protection agency. Rather, many
individuals and agencies, including reporters of maltreatment, teachers, mental
health agencies, county attorneys, the courts, law enforcement agencies, and
providers of support services have a role in ensuring the safety of children.
Increasingly, experts are pointing out the importance of the community in
helping government identify and treat child abuse and neglect.
The state has
long acknowledged the importance of community collaboration in CPS. Since 1977, statutes (W.S. 14-3-212) have
provided for the establishment of child protection teams (CPTs) within communities. These teams involve representatives from
county and district attorney offices and school districts, as well as other
relevant professions. DFS field offices
each determine how to use CPTs. By
statute, they may assist and coordinate with DFS, the field offices, and all
local agencies dealing with child welfare.
DFS also has a state-level advisory group that makes policy
recommendations, and develops and monitors a comprehensive agency plan to
protect children.
However,
interjecting varying community standards and expectations into CPS through
formal CPTs or other means, also complicates what is already a complex
undertaking. Balancing government’s
responsibility to protect children with the inherent rights of parents to raise
their children is perhaps the most challenging consideration. Not surprisingly, a recent NCSL publication
on CPS states that child protection is one of the most controversial functions
of state government.
Philosophically,
some maintain that child protection agencies are too intrusive into families’
lives and they destroy parent-child bonds.
Others express outrage that the agencies are not intrusive enough, and
that leaving a child in a home with unfit parents puts the child at further
risk of harm. Similarly, caseworkers face
the inherent conflict of needing to protect children from abuse and neglect,
while often trying to reunite them with the parents who once abused them.
In addition,
CPS work can be complicated, technical, sometimes adversarial, and often high
pressure. Caseworkers need to make
decisions about a child’s safety based on a relatively brief encounter. They
need to have skills to enable them to work with the child alone, with the
child’s parent(s), and the entire family.
As well, they must understand and use a wide array of legal and social
work concepts, and interact with professionals from a variety of fields, such
as law enforcement, the courts, and the medical community.
System
Facing Strains
Because
legislators were interested in finding out more about the child protection
practices of DFS and the outcomes of those practices, this study was
requested. Given the complex nature of
child protection and the challenges Wyoming’s system must balance, such accountability
is critical.
However,
Wyoming’s system may be stretched to its limits. The system lacks safeguards
that ensure children are best-served under current conditions. Its numerous challenges include high
caseworker turnover, high caseloads in some areas, supervisors who must split
their time between offices, and limited ongoing training opportunities for
workers with disparate educational backgrounds.
These
challenges may alarm the public and elected officials who want assurances that
DFS is making appropriate decisions.
However, given historical data collection limitations, DFS has not been
able to systematically track how such challenges impact the agency’s ability to
provide CPS. While the state office has
conducted some ad hoc studies of Wyoming’s CPS system and relies on local
offices for an understanding of individual CPS success and failures, DFS needs
additional assurances that the system is working as intended. Such assurance can come from methodically
tracking and evaluating aggregate data about CPS.
Although we
identified problems with the CPS system, we also found DFS child protection
workers generally to be hard-working, dedicated, and concerned about
children. Our recommendations are
intended to help DFS ensure that its goals for abused and neglected children
can be accomplished in all cases.
CHAPTER
2: Evaluating the CPS Program
Chapter
Summary. Wyoming’s
CPS system makes important decisions about whether and how government should
intervene in families’ lives to protect the interests of children. As
important as these decisions are, most are made with limited public scrutiny,
since DFS tracks and analyzes little aggregate information about the CPS
program. Although field offices
understand individual CPS decisions, this awareness at the local level does not
provide a cumulative understanding of the overall effectiveness of the
program.
DFS needs to
more systematically track and
analyze aggregate information about the CPS program. Although individual
social worker judgment and supervision are critical factors when making decisions in CPS incidents, the agency needs
more information about the cumulative impacts of those individual
decisions. With the implementation of
an electronic case management system in the past year, DFS is now
well-positioned to begin rigorous data collection and analysis. Systematic evaluation of data can lead to
better understanding of what is working well in current CPS provision and where
changes are needed to more fully protect children.
More
Information Needed About Program Impact and Administrative Effectiveness
National
child protection experts and standards stress the importance of evaluating both
CPS program and administrative effectiveness.
According to Child Welfare, a
publication of the Child Welfare League of America (CWLA), “Evaluation research
should have two discrete tracks. The
first would emphasize outcomes, examining effectiveness and efficiency. The second would deal with management and
planning.”
We found that
DFS needs to more systematically analyze both program impact and administrative effectiveness in providing
CPS. While DFS conducts occasional ad
hoc studies and prepares some basic information on the CPS program, primarily
for federal reporting requirements, DFS needs to develop additional information about CPS program activity
and management and collect such information more consistently over time.
As will be discussed in later chapters in this
report, we found several areas where DFS could benefit from additional state-level evaluation of both the CPS
program and management issues affecting the program:
·
Chapter 3 discusses the need for DFS to
track and analyze aggregate information
about CPS: basic program statistics,
variations in the program, compliance with CPS requirements, and program
results.
·
Chapter 4 explains that DFS may wish to
set additional standards of practice
for some areas of CPS, to better evaluate the quality and consistency of
cumulative CPS services in the
state.
·
Chapter 5 recommends that DFS analyze the causes of caseworker
turnover and how caseworker turnover impacts program outcomes.
·
Chapter 6 recommends that DFS develop a
consistent means of measuring workload, tracking variations in workloads, and
evaluating how those variations affect the delivery of CPS.
·
Chapter 7 explains that DFS should
develop more structured ways of
monitoring whether supervision is taking place at the desired levels.
·
Chapter 8 recommends DFS evaluate
current training opportunities to determine where training needs to be enhanced
and if current training enables caseworkers and supervisors to provide CPS
effectively.
Electronic
Case Management.
DFS recently created an electronic case management system that provides
raw data about the CPS work being done in the field, as well as casework for
other social service programs. In June
of 1998, DFS began using this automated system, known as the Wyoming Children’s
Assistance and Protection System (WYCAPS), which has enabled the agency to
begin baseline measurement of CPS activities.
Prior to
WYCAPS, the agency was not able to collect CPS information consistently over
time. Historical data limitations have
allowed little trend analysis because the information that is available is not
comparable year-to-year. Statistics
about CPS were often based on different methodologies that varied according to
reporting needs. Now, WYCAPS positions
the agency to conduct more systematic analysis of CPS.
WYCAPS was
developed in response to federal requirements that certain reports be produced
electronically, and its development was funded by a 75-percent federal
match. The system was designed with both standardized and ad hoc reporting
capability. According to one DFS
official, the standardized reports are “there if anybody wants them.”
Although data
is being collected in WYCAPS, we found indications that it may not be fully
used both at the state office and in the field. DFS needs to explicitly charge specific personnel to routinely
analyze these reports, because officials throughout the agency believe there is
a need for more information about CPS processes and outcomes. As one DFS official said, “Information that
is produced on CPS isn’t produced with any continuity .... We need good baseline statistical
reporting.”
DFS
Cannot Evaluate the Cumulative Impact of its CPS Strategies
DFS needs to
more systematically evaluate its data to better understand how well the CPS
program is functioning and how administrative matters, such as turnover and
caseload, affect the program. Much of
the data we needed to evaluate CPS was not available in report form from DFS, so we compiled information
from raw WYCAPS data for all CPS incidents opened in FY99. For information that could not be downloaded
from WYCAPS, we electronically reviewed 100 randomly selected substantiated CPS
incidents opened in FY99. DFS keeps its
records pertaining to individual cases in hard-copy and electronic form, so
some of the infor-mation we wished to obtain may not have been present in the
electronic files we reviewed. See
Appendix F for methodology about the file review.
When we asked
for agency reaction to the information we prepared about CPS, DFS officials
were often surprised at what we had found.
Several DFS officials were not aware of either aggregate statistics
about the program, such as the number of reports investigated, or the frequency
with which caseworkers were meeting CPS procedures, such as having in-person
contact with the victim during the investigation.
With more comprehensive information about the
CPS program, DFS would be better able to evaluate the impact of CPS strategies,
and could more effectively advocate
for resources to support the program.
While there is a general sense that DFS is helping children, the agency
needs to verify this assumption with data to more fully ensure that the CPS
program operates to protect children in the most effective manner and that
resources have been best deployed.
DFS was able
to provide us with one outcome measure, in the form of a 5-year maltreatment
recurrence rate of 17.5 percent. This
means that for the 5,334 victims of child maltreatment during the period FY93
through FY99, 933 children were known by DFS to have had another instance of
maltreatment. Since this information
can be used to gauge the success of CPS interventions, DFS needs to track it
over time to determine if recurrence is increasing, decreasing, or steady. DFS officials report that they plan to use
this information for baseline statistical analysis.
Data
Analysis is a Critical Component in Providing Effective CPS
Since 1977,
the Legislature has required DFS to develop and analyze statistical information
to regularly evaluate the effectiveness of existing CPS laws and programs. W.S. 14-3-213(b)(iii) requires evaluation
using the information gathered through the central registry. Although it is not clear how this
requirement fits with the agency’s data collection capabilities in WYCAPS, the
Legislature clearly intended DFS to periodically evaluate the effectiveness of
CPS provision in the state.
Professional
standards also advocate the use of data to improve CPS. CWLA, a nationally
recognized organization dedicated to improving practices in child welfare
services, sets standards of excellence to guide social work practice. CWLA standards require an agency to maintain
a management information system that contains information sufficient to allow
an evaluation of program and administrative effectiveness. CWLA standards require information be used
to improve service delivery, evaluate program effectiveness, and to advocate
for sufficient staff and fiscal resources.
Importance
of Documentation.
Documentation of CPS activities is a critical principle in this field,
serving as an essential link in demonstrating the effectiveness of CPS
strategies. The American Humane Association
(AHA), a leading national organization in child protection issues, devotes an
entire chapter in its casework handbook to the importance of documentation,
noting that almost everything known about CPS work being done is based on
information provided by the caseworker.
AHA adds that “information is the key ingredient of an accountable
system.”
Ad
Hoc Studies and Local Monitoring Have Been The Main Avenues of Evaluation
We found that
DFS has not dedicated resources to institutional research to consistently track
and evaluate CPS data. According to
agency officials, DFS employed a statistician at one time, but as resources
were cut, the position was eliminated.
Currently, one consultant in the Programs and Policy Division splits
time between adult protection responsibilities and institutional research. As a result, the agency has had to rely on
occasional studies of elements of the system and on local understanding of
individual CPS cases to provide assurances that the system works as intended.
Although
several DFS officials see a need for an institutional research function for the
agency, they do not believe DFS has the resources to support such a
position. Further, some officials told
us that if additional resources were identified, those resources would be best
directed to funding casework positions in the field.
We also found
some indications that the state office may believe that the combination of ad
hoc evaluation, coupled with local monitoring of individual CPS cases, provides
sufficient understanding of the CPS program. For example, when we asked
how many children were in ongoing services in FY99, one state official said,
“It is more important for local managers to know who is in services than for us
to know.” While we agree that local
offices should have a day-to-day understanding of the children they are
serving, it is important that the state not rely exclusively on local
monitoring to determine whether or not the program is working as intended. A
systemwide understanding is needed.
In 1996, the
DFS director initiated an internal review mechanism, known as Staff Assistance
Visits (SAV), to evaluate field office activities. The SAV process is an
important quality assurance mechanism for the state office, providing a
significant foundation to furnish DFS with information to fully evaluate
CPS. However, SAVs have not been used
to provide a comprehensive evaluation of CPS.
Rather, they briefly touch upon many agency programs operating in the
field. DFS reviews only a limited
number of CPS cases in individual offices.
Further, DFS does not use the
information from the SAVs to assess the cumulative impact of the CPS program
statewide.
Transition
to WYCAPS. Prior
to the development of WYCAPS, the agency did not have a reliable mechanism to
track much of the data necessary to evaluate the CPS program. DFS is not unique in this regard. Professional literature and experts in the
field note that the systematic analysis of CPS data is at a relatively early
stage. With the development of WYCAPS,
DFS is in a position to be a leader in leveraging electronic casework data to
make informed decisions about CPS.
It appears
that to this point, WYCAPS has been used primarily to meet federal reporting
requirements and to manage contracts.
Several officials noted that the agency is now poised to use the
information in the system to evaluate the effectiveness of CPS. However, the ability to use this information
is limited by the extent to which caseworkers are using WYCAPS as their
principal case management system.
Our case file review revealed a great deal of
variation in the extent to which caseworkers documented their work in
WYCAPS. Absent complete documentation
of CPS activities in WYCAPS, we were unable to determine if caseworkers carried
out CPS according to DFS requirements and simply were not documenting their
efforts, or if caseworkers were not meeting CPS requirements.
It is not
clear that there is a high-level commitment to mandating WYCAPS as the primary
case management system for CPS, given the level of documentation by some
caseworkers using WYCAPS. We believe
this is due at least in part to the recent
transition to WYCAPS, and a desire on the part of DFS administrators not to
overwhelm caseworkers with the additional data entry burden WYCAPS entails.
Recommendation: DFS should implement an institutional
research function to evaluate both program and administrative effectiveness.
DFS should
implement an institutional research function to evaluate the effectiveness of
the CPS program. Research is needed
both to evaluate outcomes of the CPS program, and to review how administrative
processes affect program delivery. An
institutional research function could use both WYCAPS data, provided casework
is documented in the system by caseworkers, as well as the SAV process, to
ensure CPS strategies are appropriate.
We believe
the resources currently dedicated to providing CPS can be better leveraged
through consistent and rigorous analysis of DFS data to inform
decisionmaking. Data collection and
protecting children are not mutually exclusive; rather, the collection and use
of data in decisionmaking should enable the agency to better protect children. DFS
should make institutional research a higher priority and should reallocate resources
internally to fund such a function in order to demonstrate program performance
and advocate for needed resources to the Legislature. Data analysis can also be
used at the state level to modify CPS strategies at the local level.
CHAPTER
3: Intake, Investigation, and Ongoing
Services Procedures
Chapter
Summary. We
found some of the agency’s procedures for CPS intake, investigation, and
ongoing services may not be working as DFS intends, but DFS has not
systematically evaluated CPS at the
state level to identify potential operational shortcomings. The ability to evaluate systemwide how
caseworkers are carrying out intakes, investigations, and service delivery
could help DFS change course when necessary, and provide internal assurances
that children are being protected.
The findings
in this chapter raise questions about consistency and internal safeguards
associated with how DFS provides child protective services. However, the questions we present should not
be construed to be a criticism of current CPS provision. Rather, such questions highlight the need to
better understand both how the agency provides CPS overall and whether changes
are needed to current processes. Although
DFS needs to rely on caseworker judgment and supervision to monitor the
appropriateness of individual decisions made at these three stages, the agency
also should be analyzing the cumulative impacts of individual intake,
investigation, and service decisions.
Concerns
About CPS Highlight the Need to Analyze Procedures
As noted in
Chapter 2, DFS has not historically tracked much of the data we needed to
independently evaluate CPS. So, we used a variety of methods to look
at the continuum of CPS services in order to determine both compliance with
requirements and also aspects of the quality of services provided, including
aggregate information from WYCAPS and the selected information from the WYCAPS
file review. We compared this data to
information we developed on workload and other office characteristics to
identify trends. In addition, we asked questions about
the CPS process in our survey to caseworkers and supervisors.
Analysis of
these varied sources of information gave us concerns about intake,
investigation, case management, and risk assessment procedures; affirming the
need for state-level evaluation of CPS processes. Potential shortcomings we identified are discussed below.
Concerns
About Intake Procedures
At the state
level, DFS does not routinely track and analyze information about how CPS
intake is carried out locally. We
identified some areas where intake procedures may not be working as DFS
intends.
Variation
in Rejection Rates. We
found that small and medium-sized offices and offices with lower caseloads were
more likely to accept reports for investigation than were large offices and
offices with higher caseloads. In FY99,
large offices investigated a little over
one-half of the reports they
received, while small and medium
offices investigated more than two-thirds
of all reports received. See Appendix G
for detail. Further, offices with higher caseloads investigated 61
percent of the total reports received, while offices with lower caseloads
investigated 74 percent of all reports received. See Appendix H for detail.
In and of
itself, variation does not indicate problems with local field office rejection
procedures. However, these trends
should be analyzed to ensure that reports are appropriately rejected throughout
the state.
Reasons
for Rejected Reports. We found that one-third of CA/N
reports received were rejected at intake
in FY99. Because DFS has only limited data available
about reports rejected at intake, a cumulative understanding of this population
has not emerged. DFS state officials said they believe the
reasons reports are rejected can be understood at the local level.
Analysis at
the state level of the reasons
reports are rejected could be a critical feedback component in providing
CPS. The intake process is an
especially sensitive phase of CPS because when a report of CA/N is rejected,
the child receives no protection from the state.
Other
Staff Collecting Intake Information. In our surveys, we asked if staff other than
caseworkers collect intake information for CPS. Forty-two percent of managers, supervisors, and caseworkers said
yes, and many of them said this occurs occasionally to regularly. They reported that supervisors,
administrative staff, economic assistance workers, and others are conducting
intakes.
Respondents
may have been indicating that other staff sometimes collect basic information
and then pass that information on to a caseworker who conducts the actual
intake interview. Nevertheless, the responses highlight the need for
the DFS state office to more thoroughly track and analyze local intake
procedures to ensure they are carried out as intended.
Compliance
and Concerns With Investigation Procedures
We found that
DFS does not monitor field office compliance with some of its investigation
requirements and does not evaluate local
investigation procedures systemwide.
We found that the agency is meeting mandated investigation timelines,
but we also identified some potential shortcomings in other DFS investigation
procedures.
Offices
Meeting Timelines. DFS
does track the average time to initiate and complete investigations for federal
reporting requirements. We found that local offices are meeting the mandated
timelines for intake and investigation.
DFS caseworkers in FY99 initiated investigations within the 24-hour
statutory requirement, averaging less than nine hours per incident to initiate.
We found that
the agency is also meeting its timelines to conduct investigations. Local offices are, on average, completing
investigations well within the 60-day investigation timeline established in
rule. In FY99, the office average to
complete an investigation for a substantiated finding was 29 days, while for an
unsubstantiated finding, the average was 25 days.
Variation
in Substantiation Rates. We
found that small offices were slightly more
likely to substantiate reports after investigation than were large
offices. In small offices, about 44
percent of investigated allegations were substantiated, while only 30 percent
were substantiated in large offices.
See Appendix I for detail.
Again, this
variation may be coincidental, but the agency should track and analyze
variation rates among offices to ensure that investigation decisions have been
appropriately made.
Reasons
Reports are not Substantiated. We found that of the 4,444 allegations
investigated, more than half were not substanti-ated after investigation in
FY99. However, DFS does not evaluate
the reasons that these reports are unsubstantiated. Evaluation could help determine if there are any shortcomings in
investigation procedures that contribute to the high proportion of
unsubstantiated reports.
Compliance
With Investigation Requirements. DFS does not track and monitor compliance
with all mandated investigation requirements.
So, as part of our WYCAPS file review, we looked for evidence of
compliance with investigation requirements.
Although a review of only 100 files is not comprehensive, it appears caseworkers either are not
always documenting that they have met investigation requirements, or they are
not always complying with some investigation requirements.
DFS rules
require either agency personnel or law enforcement to have direct in-person
contact with the alleged victim and perpetrator within seven calendar days
after the investigation starts.
However, in 20 of the files we reviewed in WYCAPS, we found no
indication that either the child or the perpetrator had been seen in person by
DFS. Law enforcement assisted in 7 of
these investigations, so it is possible law enforcement personnel made contact
with the child and the perpetrator in lieu of DFS.
In another 10
files, we found indications that the perpetrator was seen in person by DFS
during the investigation, but there was no documentation that the child was
seen in person. Law enforcement
assisted DFS in 6 of these investigations, but it is unknown if they made
contact with the child.
In 60 of the
incidents we reviewed, caseworkers
documented that both the child and the perpetrator were seen in person during
the course of the investigation. DFS
rules state that investigations normally should start by making in-person
contact with the child alleged to have been abused or neglected. Further, rules say the perpetrator should
not be present during the initial interview.
However, we were unable to determine whether or not the child was seen before
the perpetrator in about half (27) of these incidents because the time of the
interview was not documented in WYCAPS.
One DFS state
official emphasized the importance of direct contact with the victim during the
investigation, stating, “You never don’t see that child ... I would
consider it not a good investigation if the caseworker had not seen the
child.”
Concerns
About Case Management Procedures During Ongoing Services
DFS does not
evaluate at the state level how case management services are provided and how
effective the outcomes are. Our review
raised concerns about the comprehensiveness of WYCAPS data, how frequently
caseworkers have contact with children, and the rate of service provision in
different-sized field offices.
Not
Known How Many Receive Ongoing Services.
The count of children and families
receiving only direct services from DFS is unknown. This is because direct services (where DFS is not paying outside providers such as counselors or
foster parents) are paid for through the administrative funding in each DFS
field office, and are not specifically tracked in WYCAPS.
Children
receiving direct services are included in WYCAPS, but DFS cannot identify them
as a group for aggregate data analysis purposes. While local offices likely have a working knowledge of these
children, systemwide, DFS does not have a complete picture of the children and
families to whom they provide direct ongoing services. Furthermore, DFS officials reported that
WYCAPS could not produce a tally of children who are in DFS legal custody but
placed in the home, since caseworkers are not required to put the information
into the system.
In addition,
caseworkers do not appear to be consistently indicating in WYCAPS that they
have established a case plan. Without
this information, the WYCAPS system does not provide complete information about
the children in ongoing services. For
example, WYCAPS had a total of 492 case plans indicated in the system for FY99;
however, 1,302 children were receiving contract services and still others were
receiving only direct services. At a
minimum, this would indicate an average of 2.6 children addressed on every case
plan. This does not seem likely
because, according to census figures, there is an average of 1.1 children per
Wyoming family.
Caseworker
Contact with Child. It
is important for caseworkers to see the child during ongoing services in order
to make professional judgments about the safety of the child and the
effectiveness of the service intervention.
Our survey of supervisors, and managers revealed 21 percent of
respondents have low confidence that caseworkers are making an adequate number
of contacts with children during ongoing services.
Our file
review also raised doubts that children are being seen by caseworkers during
ongoing services. Because caseworker
contacts with children could not be aggregated from WYCAPS, we looked for this
information during our case file review. Of the 100 substantiated incidents we
reviewed, documentation in WYCAPS showed
services were delivered in 32 incidents.
It would be
incorrect to develop conclusions about the entire population from a sample of
32 incidents. However, what we learned
may point to a larger problem. In 17 of the 32 incidents, it was not
documented in WYCAPS that the caseworker saw the child. Eleven of the 17 children not seen were
living at home and six were in out-of-home placement.
Variation
in the Rate of Contract Service Provision. We found the proportion of investigated
allegations that receive contract services varies by size of field office. Small and medium offices provided contract
services to 20 and 21 percent of investigated allegations, respectively in
FY99. Large offices provided contract
services to 15 percent of investigated allegations. Refer to Appendix D for detail on all field offices. While variation in the rate of contract
service provision does not necessarily indicate a problem, it is something DFS officials
may wish to analyze more thoroughly.
Reasons
Services are not Provided. We found that 72 percent of substantiated
allegations did not receive contract services
in FY99. Some state office personnel we contacted were unaware that nearly
three-quarters of substantiated allegations do not result in contract service provision.
DFS has not
systematically examined the reasons so many substantiated allegations do not
receive services. So, we used our case
file review to analyze reasons services are not provided. No services
were provided in 65 of the 100 files we reviewed. The family declined services in 17 cases; in 27 cases, the child
was determined to be safe; and in the other 21 cases, no reason was documented
in WYCAPS.
Evaluating
the reasons why services are not provided would help DFS to understand this
population and what changes in procedures may be needed. For example, as noted above, a large number
of substantiated incidents received no services because the family refused DFS’
offer of services. As explained in
Chapter 1, DFS has no enforcement authority to mandate families accept
services. If a family refuses services,
DFS must decide whether to refer the case to the judicial system. An evaluation of the number of families
who refuse services may indicate a greater need for DFS to engage the judicial
system in mandating that families accept services.
Risk
Assessment Not Used As Policy Requires
DFS has
developed the Wyoming Risk Assessment Model for caseworkers to be used to make
determinations about the risk factors facing a child. Risk assessment is important because it is a structured way for
caseworkers to analyze the safety of a child and if service interventions are
working. DFS policy requires a risk
assessment be conducted throughout the life of the case, including
substantiation and case closure.
It appears
caseworkers record the risk assessment in WYCAPS more at substantiation than at
case closure. A risk assessment had
been documented at substantiation in 76 of the 100 incidents we reviewed, while
in 24, it had not. Of the 100
incidents, 66 were closed at the time of our review, yet only 16 of those had
documented that a risk assessment had been conducted at substantiation and closure, as policy requires.
Further, caseworkers do not appear to be using
the risk assessment at other points in the life of an incident, as policy
requires. In 86 of the 100 incidents,
there was no evidence in WYCAPS that any
risk assessment was conducted at points other than substantiation or
closure. However, policy allows a model
other than the Wyoming Model to be used at other points, so caseworkers may not
be documenting the use of other models in WYCAPS.
DFS
Can Do More to Ensure CPS Procedures are the Most Effective
Based on the
data we compiled about how CPS is being provided, we have some concerns about
current CPS procedures. Since DFS does
not monitor and evaluate these procedures, the state office cannot assess the
overall effectiveness of the methods used by local offices. One agency official
summarized the consequence of not evaluating CPS, stating, “We don’t provide
the quality of services that we have the ability to provide, or perhaps we are
misdirecting our resources.”
DFS should
more systematically evaluate how it
provides CPS, to provide an additional safeguard
for internal operations. Although the judgment
of individual social workers and supervisors is essential to assure the quality
and effectiveness of CPS provision for each child, the public needs more
assurances that the system fully protects children overall through the
cumulative evaluation of individual decisions.
State
Office Leaves Monitoring of CPS to Local Field Offices
As noted in
the previous chapter, DFS relies on individual offices to ensure that CPS is
conducted appropriately in each incident, but there is a need for the agency to
more fully monitor the cumulative impact of individual decisions.
We found that
the state has relied on case-by-case decisions made at the local field office
level, to ensure that intake, investigation, and service decisions have been
made appropriately. While local offices
should evaluate the effectiveness of CPS for each family, the state office
needs to provide more direction to
the field by more fully analyzing
aggregate outcomes for the state as a whole.
Both types of analysis are critical in providing effective CPS. A state-level understanding of the aggregate
impact of local CPS decisions is needed to understand both how the program
works in its entirety and to better apply limited resources.
Recommendation:
DFS should monitor and evaluate CPS intake, investigation, and ongoing service
procedures at the state level.
Based on our
initial analysis of the state’s CPS system, we believe the program would be
strengthened by more ongoing
evaluation. Ideally, DFS should monitor and evaluate intake, investigation,
and case management procedures and results at the state level and modify
policies and strategies accordingly.
While working toward this, the agency could strategically target some
areas of concern for state-level evaluation.
The goal is for the agency to have the necessary analysis to make informed decisions about needed
changes in these areas. The Legislature also needs to have an understanding of
the program-level impact of local CPS decisions to draw informed conclusions
about how well CPS is provided.
CHAPTER
4: DFS Policies
CPS
Policies Need More Specificity
The agency’s
minimal and general policies are more of a concern in some aspects of the CPS
process than others. We identified the
following two areas as needing additional policy guidance.
More
Policy for Ongoing Services Needed. Policies for providing services to children
who are the victims of substantiated CA/N, and who are receiving ongoing
services in placement or at home, are very general. Current policies tell caseworkers only to follow, monitor,
adjust, and evaluate the case plan when providing services, with no further
explanation. DFS does not define these
terms, leaving individual supervisors and managers the discretion to provide
more specificity for the caseworkers they supervise. If they elect not to provide more definition, caseworker judgment
alone prevails.
DFS has
written little policy regarding how often and under what circumstances
caseworkers should see children who are receiving ongoing services. What policy exists is somewhat more specific
for children placed out of their homes than for those left in their homes. The policy regarding monitoring children in
placement requires “minimum monthly contact in person when possible (emphasis added).”
For children in their homes, however, there is no explicit expectation
set in policy (or rules or statute) that caseworkers should see them, or how
frequently.
The absence
of specific policy directing caseworkers to see children who are receiving
services, or directing how frequently to see them, did not seem appropriate to
us. When children are in placement, DFS
seemingly has more certainty that they are safe than when they remain with the
persons who abused or neglected them.
Without policy directing case-workers to see children when they live at
home, and how often, DFS lacks an important practice expectation to ensure
children’s safety. Also, it has no
assurances that children and families are being monitored adequately statewide.
Standard
Intake Procedures Needed. Although DFS rules include specific
requirements for the intake process, there is little policy guiding caseworkers
on how to conduct CPS intakes. DFS has
not developed standardized intake procedures for use in the field offices. This stage of the CPS process is critical
because it generates the information necessary for DFS caseworkers to determine
whether or not to intervene to protect children.
Workers
around the state are not given a standardized list of questions to ask during
the intake interview to ensure all of the necessary information is obtained
from the reporter. Absent an
agency-approved list, many offices have developed their own checklists. The lack of a standardized intake process is
a concern because our survey indicated that persons other than CPS-trained
caseworkers are collecting basic intake information. Further, we were told that caseworkers with a variety of skill
levels conduct CPS intake interviews.
Without a list of standardized questions to cue workers to obtain specific
information, the state lacks assurances that caseworkers in all locales are
gathering the necessary information to accept or reject reports of
maltreatment.
CWLA says
that child protection agencies should develop policies that make legal and
regulatory requirements operational, while still recognizing the need for
professional judgment and flexibility.
Policies should reflect good social work practice and assist staff in
the delivery of services and decisionmaking.
Further, policies should be based on desired outcomes for families and
children, and reflect the realities of the resources available to the agency
and the community. AHA notes that
agencies should develop policies to ensure effective, uniform implementation of
state child protection laws.
Accountability Depends Upon Policies
By leaving
policies broad and general, DFS is relinquishing an opportunity to set
professional practice expectations for its caseworkers. Well-defined expectations would set a
standard for practice and would also be a means for holding caseworkers accountable. Policies provide staff with a clear statement of their roles and
responsibilities. The agency avoids
accountability for its workers and itself by leaving caseworkers to do what
they or their managers consider best according to the circumstances they face.
Further,
broad policies enable local field offices to develop their own standards of
practice, either formally or informally.
This means that children and families stand to receive different
services from DFS caseworkers, depending upon where they live. We learned that many offices do this. For example, a manager in one office
requires caseworkers to travel each month to personally observe children in
out-of-town placements within 100 miles, while others allow telephone contact
to suffice in similar cases. DFS policy officials are aware of these
more specific policies, but are hesitant to prescribe similar ones for every
county.
Recommendation: DFS should develop more specific policies to
establish agency CPS practice expectations.
CHAPTER
5: Caseworker Turnover
Chapter
Summary. A
sudden jump in already high rates of turnover for DFS caseworkers occurred in
FY99, when fully one-third of them left the agency. High turnover is having negative effects on the children and
families served, as well as on DFS workers individually and the agency as a
whole. However, the agency’s efforts so
far have not resulted in a reduction of turnover or in the creation of a plan
to decrease the rate of departures.
Already
High Turnover Spiked in FY99
For several
years, there has been higher turnover among caseworkers than in state
government as a whole: 21 percent for
caseworkers, compared to about 14 percent for state government and about 16
percent for DFS as a whole. Because of
this outflow, the agency has had to place extra emphasis on recruiting and
training new workers.
In FY99,
caseworkers left DFS at an even higher rate than before, 33 percent. Turnover occurred in two-thirds of the field
offices and in offices of all sizes.
Furthermore, very high rates of turnover, 50 percent or more, occurred
in half of the small and one-third of the medium-sized agencies. In some areas of the state, notably the
greater Jackson area and a number of rural sites around the state, DFS says it
has been difficult to get caseworkers to stay even a year or two.
Experience
Is Critically Important for CPS Caseworkers
From our
interviews with managers, supervisors, and caseworkers around the state, we
learned that on-the-job experience is a key factor in helping workers make good
judgment calls. We were told that new
workers may come to the job with some academic training, but that college coursework
alone does not prepare a person for complex tasks such as assessing the risk to
an abused child.
Experience
also builds confidence and prepares a caseworker to take on more difficult
cases. As one supervisor explained,
“You have to substantiate based on facts, but the level of risk to the child is
all perception. You need good clinical
skills and good judgment.”
Many we
interviewed said that understanding rules and policies plus developing good
social worker judgment depends upon the individual, but that it probably takes
a minimum of one to two years on the job.
However, we found that as of August 1999, fully 40 percent of DFS field
office caseworkers had less than two years experience.
The
importance of maintaining a skilled staff to perform CPS work is widely
acknowledged by such organizations as the CWLA and the American Public Human
Services Association. As well, GAO has
stated, “In CPS, where staff are sometimes dealing with life-and-death issues,
the knowledge of and consistent application of appropriate policies and procedures
are critical.”
Turnover
Has Negative Effects on Children, Families, and the Agency
Although hard
to quantify, the consequences of a constantly shifting CPS workforce are
serious. DFS supervisors and officials
assured us that children are not put in danger since caseworkers and
supervisors put in overtime to get CPS work done. However, we believe this is an untenable solution for the problem
long-term, and is likely contributing to even more stress and burnout in the
agency.
Effects
on Children and Families. In
our interviews with DFS staff around the state, we were told repeatedly that
when caseworkers leave, there are problems with continuity in the cases. A child who has been abused or neglected
may, as a result of the abuse, have problems bonding with others. Caseworkers see their link with the child
and the family as being critical to improved outcomes for the child. When that link is disrupted by the disappearance
of a familiar worker, the child has to start over with another caseworker and
may lose trust.
Many in the
field believe a caseworker’s experience level is related to the quality of
outcomes for children and families. One
manager said, “When you watch a skilled worker engage a hard family and work it
through to find a solid solution, that’s where you see experience and training
wrapped up in what we want.
Inexperienced workers will not get the kind of outcomes we want; veteran
workers make it look easy, but it is not.”
We did not
attempt to measure the effects of high turnover on the quality of casework
being conducted. Nevertheless, we
concur with managers and supervisors who told us it is imperative that a worker
has good judgment, since the safety of a child could depend on it. That good judgment is at least in part a
product of real-life, on-the-job experience, which is difficult to develop in a
workforce that is constantly churning.
Effects
on the Agency. The
negative effects of turnover on the agency itself are numerous. Caseworkers and supervisors told us when
turnover is high in their office, they divide up a departing worker’s cases to
ensure there is no gap in services.
This creates an immediate impact on their own responsibilities. Then, when a new worker is hired,
caseworkers and supervisors are often jointly responsible for helping train and
mentor the new person.
Workers also
told us that with turnover, history and understanding of community dynamics are
lost. Several said it takes time for a
new worker to understand and develop the community networks necessary to carry
out CPS effectively. Because it also
takes consistency in personnel to build those relationships, much is lost with
each caseworker’s departure.
Caseworkers
told us they felt as though they were just putting out fires, rather than doing
a deeper level of social work where quality intervention would be
possible. They described some offices
as always being in a crisis mode, such that workers cannot develop a depth of
understanding of the cases. One
supervisor added that it is impossible for workers to believe they are doing a
good job if they are carrying heavy caseloads, and this contributes to morale
problems, burnout, and more turnover.
DFS
Needs to Address Causes of High Turnover
Wyoming is
not unique in experiencing high caseworker turnover. NCSL, which has found turnover to be a problem nationwide,
suggests it is linked to such factors as heavy caseloads, inadequate
compensation, lack of training, and the need to deal on a daily basis with
clients’ hostility. DFS officials agree
there may be a variety of reasons for the FY99 jump in turnover. They particularly single out low pay and benefits that have not
kept pace with other employers of social workers such as school districts,
hospitals, and non-profit organizations.
To address
the problem, the director said the
agency has been able to reallocate some funds and, through position
reclassifications and several rounds of adjustments, give pay raises to those
who were most under-paid. Further, DFS has surveyed former
employees to learn the reasons for their departures. Nevertheless, the director
said, caseworkers continue to leave the agency.
Research
conducted by the CWLA indicates that staff turnover tends to be greater in
states in which workers do not have academic social work preparation for CPS,
and lower in states that require an MSW.
Our survey showed that most caseworkers and supervisors in Wyoming have
neither an MSW nor a BSW, but rather, have a four-year degree in a closely
related field such as psychology or education.
Our survey
also asked current workers what factors are they believe are causing or influencing high
turnover. Managers and supervisors
overwhelmingly (88 percent) replied that low salaries are a factor; nearly 60
percent of caseworkers said the same.
For both groups, job stress was the second most often cited factor. DFS officials add that social work is a
particularly demanding and stressful profession, and that turnover is
natural. One official speculated that
caseworkers may be lacking in professional self esteem, since they get little
recognition from the agency, the public, or the Legislature for their work.
Recommendation: DFS should assess the causes of high
turnover and develop a plan of action.
Retaining a
professional and competent CPS staff is one of the most important
responsibilities DFS has. Left
unchecked, the current rate of caseworker departures is likely to further
stress the personnel who remain and must continue to pick up the load. Not only will workers, supervisors, and
managers continue to be overburdened, but also the quality of their responses
to children and families may well decline.
DFS needs to
systematically review the causes of worker dissatisfaction and the reasons for
terminations, and create a strategy to change the trend. If the agency finds it has exhausted all
remedies available to it using internal resources, it should bring the
Legislature a request for any additional resources needed to bring turnover
down to a less harmful level.
CHAPTER
6: Counting and Measuring Workload
Chapter
Summary.
Historically, DFS has reported to the Legislature that workloads are too
high. Workloads are a major factor
affecting the quality of CPS, yet DFS was unable to provide us with reliable
information about workload trends. DFS
does not compile or report annual workload figures, other than summary figures
reported in biennial budget requests.
We asked for the data supporting those summary figures, but DFS provided
figures that do not match what has been reported.
DFS needs to
analyze workload trends and identify the factors impacting workloads in order
to more effectively advocate for resources.
We believe the agency needs to develop a workload methodology to track
and report annual trends. Additionally,
DFS needs to conduct a staffing study to develop a meaningful standard against
which actual workloads can be compared.
DFS
Needs More Information About Workload Trends
DFS has set
25 cases per caseworker as its standard for reasonable workloads. DFS
has reported to policymakers that caseloads are above the standard, and some
officials in the state office told us in interviews that workloads are too
high. One state official told us, “We
are carrying way, way too many cases per social worker.”
However, most
regional managers were not in agreement.
Three of the four regional managers reported to us that workloads in
their regions overall, while not ideal, were presently manageable. These regional managers did indicate that
isolated areas within their regions have workloads above what they would like
to see.
When we
requested annual workload figures, DFS provided incomplete historical data that
did not match the figures reported in budget requests. Figure 3 compares the workload figures
reported in budget requests and those supplied for this evaluation. DFS was unable to explain the discrepancies
in these numbers and could not
provide this information at the field office level. Thus, from the numbers DFS provided, we could not determine which
offices have had the heaviest and lightest workloads, or where there have been
large increases.
Figure 3: Variations in DFS-Reported Workload
Statistics
|
|
|
FY95 Cases |
FY96 Cases |
FY97 Cases |
FY98 Cases |
FY99 Incidents |
|
|
Reported
in Budget (actual staff) |
33 |
34 |
34.2
(partial) |
-- |
-- |
|
|
Reported
to LSO (actual staff) |
43.3 |
42.7 |
36.8 |
37.6 |
33.8 |
|
|
Reported
to LSO (if fully staffed) |
41.6 |
39.4 |
35.5 |
34.6 |
30.81 |
Source: DFS budget requests and LSO information
request to DFS.
1 For FY99, DFS reported annual average
monthly incidents at full staffing was 30.8, but LSO found it to be 27. This may be because DFS counted a
case/incident according to the number of days in a month it was open when
providing LSO raw WYCAPS data.
Turnover
Seriously Impacts Workload
Although DFS
reported workloads to be high, our own analysis shows that if the agency had
been fully staffed in FY99, the statewide average caseload would have met the
standard in rule. Our analysis suggests
that, in keeping workloads at a reasonable level, turnover and the number of
vacant positions are key factors.
Keeping workloads manageable appears, at present, to be dependent on
keeping the current number of authorized positions filled. Absent reliable information, DFS is not able
to determine what is influencing its workload, such as turnover, and respond
effectively.
Because of
discrepancies in DFS workload data, we prepared our own analysis. We used raw data from WYCAPS on workloads
and combined it with full staffing data to compute workload figures for
FY99. DFS used “case” as the unit of
analysis for workload until FY99 when, in keeping with federal reporting needs,
it switched to “incident.” We did our
analysis in terms of both. The agency
is still transitioning, and at the time of this evaluation did not have
official definitions for either incident or case. Figure 4 summarizes our
findings; Appendix J has detail by field office.
This analysis
does not mean the standard was actually met in all offices at all times, as we
found some offices and regions were above 25 on average for the year. In fact, the standard would have been met
for the state, on average, if the
agency had maintained full staffing.
However, turnover for the agency is quite high, and vacant positions
have added to the workloads of remaining workers.
|
|
Figure 4: FY99 Workload Analysis |
|||||
|
|
|
|
Average
Workload per Worker/Month |
|
||
|
|
|
Region |
All
Incidents |
CPS
Incidents |
All Cases |
|
|
|
|
Region 1 |
26 |
13 |
25 |
|
|
|
|
Region 2 |
29 |
13 |
27 |
|
|
|
|
Region 3 |
32 |
10 |
30 |
|
|
|
|
Region 4 |
20 |
9 |
20 |
|
|
|
|
State |
27 |
11 |
25 |
|
Source:
LSO analysis of reported WYCAPS and personnel data.
2 Assumes full staffing of 125 caseworkers.
Additionally,
until DFS has reliable facts about workload trends at the field office level,
it will be unable to analyze the factors impacting workloads or how workloads
are affecting CPS outcomes. Higher
workloads result in less time for caseworkers to spend with each family. If workloads are too high, it can be assumed
that outcomes for families would not be as favorable. For example, it is possible that the offices with lower workloads
are providing ongoing services to a higher percentage of allegations. There may be corresponding benefits to
providing more services, but without facts about workload, DFS cannot correlate
workloads with CPS actions or outcomes.
Meaningful
Workload Methodology and Standard Are Needed
Counting
Workload. DFS
does not employ a methodology on which to base conclusions about workload
trends. The state office tracks only
monthly workload figures which are not useful in showing trends and, because
they include duplication, cannot be added to produce annual figures. These monthly reports are based on an overly
simplified method that counts every case/incident equally regardless of its
complexity or the number of days it is open.
Furthermore, the annual figures that have been produced lack the detail
to show where changes in workload are occurring.
Personnel in
field offices may be aware of workloads in their offices, since WYCAPS has an
automated staffing report that managers may use. However, we believe the lack of definitions for case and incident
could seriously affect the uniformity of counting workload at the field level. Therefore, each office or region could be
tracking cases or incidents somewhat differently.
Managers have
some ability to reallocate staff
within their office or region, and appear to have done so on occasion. Field office and regional managers use an
agency staffing model to analyze the workload in an office at a
point-in-time. However, we do not
believe this staffing model produces the annual workload data that would give
DFS a comprehensive understanding of workload trends.
We recognize
that methodologies for counting or quantifying social work are imperfect
generalizations. The amount of work
involved in two different cases could vary considerably, yet the cases would
count equally in the workload figures.
Some states use a weighting mechanism to take case complexity into
account, but Wyoming does not. Also,
case or incident, which are common units of analysis, exclude much of the work
caseworkers do, such as intakes that they reject for investigation. Nevertheless, it is important to attempt to
quantify the work done by caseworkers in order to develop accurate and complete
information for use in making management and policy decisions.
Measuring
When Workload Is Too High. DFS’
workload standard of 25 cases was established to indicate when workload levels
grew too high. It does not appear that
this standard, against which the actual workload is judged, is meaningful to
the agency. According to DFS rules,
field office managers should report to regional managers when local workloads
exceed the standard. However, we found
managers do not carry out this reporting.
One DFS official said, “This type of reporting really does not happen
because the agency cannot follow through on it.”
The standard,
which is case based, is of questionable value at present and needs to be
updated. According to a state-level DFS
official, when the standard was set
in 1986, it was based on a conservative guess, not on a staffing study that
considered the specific tasks and responsibilities of caseworkers. The standard was reportedly developed when
the first CPS rules were written, and has not been changed since. We noted the standard in rule is written
specifically for CPS cases, but the agency uses the standard for cases of all
programs. The standard will become further obsolete as the agency
continues its transition to incident-based reporting.
In addition,
since 1986, the work of a caseworker has changed significantly. For example, in 1991, the responsibility for
juvenile probation casework was transferred from the Department of Corrections
to DFS. Also, caseworkers now need to
be proficient at using WYCAPS as a case management system, which adds data
entry to their daily responsibilities.
Furthermore, federal requirements such as ASFA have changed the nature of
their work.
CPS
Agencies Should Establish Standards
CWLA
guidelines for CPS workloads say the agency charged with responsibility for CPS
should develop workload standards specific to the tasks and activities expected
of caseworkers. CWLA has established
national CPS standards to be used until an agency determines its own
standard. CWLA intends these standards
for agencies that exclusively focus on CPS.
The national standard is well below DFS’ standard: 12 investigations per month or 17 ongoing
services cases per month.
Further, CWLA
says that if caseworkers handle both investigations and ongoing services cases
(as do many caseworkers in Wyoming), the standard is 4 investigations per month
and 10 ongoing services cases. Given
the different-sized field offices in Wyoming and the mixed caseloads many
workers carry, the state’s structure and standards for CPS work may be
unique. DFS needs to base workload
standards on an updated analysis of the work caseworkers do in the different
settings around the state.
Recommendation: DFS should develop a workload methodology
and an updated workload standard.
The CPS
function could be strengthened by accurate reporting of workloads, measured
against standards that are meaningful for the different types of field offices
in Wyoming. DFS should develop and
document an official methodology for the state office to use in tracking
workload trends by field office, region, and the state as a whole. This information should be reported to
agency managers and to the Legislature on a regular basis. In addition, DFS should conduct a staffing
study and use it as the basis for establishing a meaningful standard for
workloads in the different-sized field offices.
As these are
both technically challenging endeavors, we recommend DFS seek expertise and
assistance from outside sources. We are
aware of one group, the National Resource Center on Child Maltreatment in New
Mexico, which offers a limited amount of free technical assistance to state CPS
agencies. The agency may also need
additional resources, beyond what can be obtained without cost, to implement
this recommendation.
CHAPTER
7: CPS Supervision
The Extent of CPS Caseworker
Supervision Varies
Supervisors
Are Key To CPS, But Are Stressed By Other Factors
Given the
critical nature of CPS decisions, many casework actions and decisions need to
be made in consultation between the supervisor and caseworker. We surveyed caseworkers to determine when
they obtained supervisory review.
Caseworkers responded as follows:
·
91 percent obtain supervisory review at
intake
·
88 percent at investigation
·
61 percent at case planning
·
50 percent while monitoring a case
·
65 percent when terminating a case
Supervision
Critical to Quality CPS Services
All the
sources to which we looked for standards on how CPS should be delivered
stressed the importance of supervision.
CWLA summarizes the prevailing opinion, stating that supervision by
qualified and competent staff is critical to assure that caseworkers provide
quality services, engage families from a helping perspective, and follow agency
policies and procedures. Supervisors
must have the competencies needed to provide case consultation and guidance to
workers in decisionmaking, and to teach new skills to caseworkers.
More
System Assurances Are Needed That Caseworkers Obtain Adequate Supervision
Although
professional standards recommend incorporating supervisory responsibilities in
agency policy manuals, we found little direction in DFS policy telling
caseworkers when supervisors should be involved in CPS decisionmaking. DFS officials told us that the tenets of
good social work practice prompt caseworkers to obtain their supervisors’
advice at critical decision points, even if policy does not specifically tell
them to do so. However, since most DFS
caseworkers and supervisors do not have social work backgrounds, we believe DFS
should not rely so heavily on common understanding of standard social work practices.
Further, the
agency does not have a way to assess whether caseworkers in all field offices
are receiving adequate supervision. As
noted, WYCAPS does not capture supervisory review so that it can be assessed,
or alert workers when it should be obtained.
Officials said that SAVs, the agency’s internal quality assurance review
process, evaluate the adequacy of supervision.
However, these reviews occur only every two years in each office, and
focus upon a limited number of CPS incidents.
Recommendation: DFS should strengthen its supervisory
structure.
Supervision
is a key component of any CPS system, but perhaps even more critical in Wyoming
because of high caseworker turnover and the added supervisor responsibilities
that turnover creates. If current
trends persist, the agency will continue to rely upon a cadre of tenured and
experienced supervisors to supervise caseworkers with increasingly less
experience and without social work backgrounds.
DFS needs to
strengthen this critical element of CPS by outlining supervisory expectations
in policy. It also needs to broaden its
internal quality review process to evaluate whether supervision occurs in the
field offices as specified. Further,
DFS should incorporate documentation of supervisory review into WYCAPS so that
it can determine if there is a correlation between supervision and positive or
negative CPS outcomes.
CHAPTER
8: CPS Training
DFS Requires Training and Certification
of CPS Caseworkers
More
Ongoing CPS Training Desired
DFS Does Not Require Ongoing Training
Most
Agency Training Efforts Focus on New Caseworkers
Recommendation: DFS should assess how to enhance ongoing CPS
training.
DFS should
determine how to enhance its current ongoing training. Since caseworkers
indicated a preference for training that does not require travel, we thought
the agency’s current CBT and grid approaches made sense. But, judging from the comments we received,
these alone may not be sufficient.
CHAPTER
9: Conclusion
Referring to
child protective systems in general, a former head of the U.S. Advisory Board
of Child Abuse and Neglect has said that the country has an episodic system
that keeps no records of its successes or failures. Since no outcome data is collected, public accountability is
impossible and there can be no culture of learning from mistakes.
In Wyoming,
based on many years of collective experience, DFS officials have a strong
intuitive sense that the state’s CPS program is providing safety and support
for Wyoming children and families, and that abused and neglected children are
better off because of the agency’s efforts.
Our research neither proved nor disproved that belief. Simply put, we found the agency has not
systematically collected and analyzed information to verify its internal
perception.
While not
discounting the confidence DFS officials and managers place in the agency’s CPS
efforts, we believe perceptions do not suffice to convince external audiences
of a program’s value. One important
audience for performance information is the Legislature, which makes critical
policy and funding decisions that affect CPS.
During our
evaluation, the agency stressed its emphasis on keeping caseworkers and
resources focused on protecting children and helping families. We do not believe this goal is at odds with
strategic data collection and analysis.
Rather, an agency-wide commitment to rigorous data collection and
analysis at the state level would allow DFS to more strategically focus its CPS
efforts.
What is
needed is a broader understanding of how Wyoming’s CPS system is working
overall. Our recommendations encourage
the agency to protect children and help families by going on to develop an
information system that includes longitudinal evaluation. We believe DFS is uniquely positioned to
make strategic use of its year-old WYCAPS system in this manner.
Rather than
viewing such a focus as directing limited resources away from the vulnerable
population it seeks to protect, DFS should consider the value that structured
introspection and data analysis add to the CPS process. This knowledge could
inform internal administrative and policy decisions by cultivating a deeper
understanding of trends over time. It
could also provide a context in which to discuss with the Legislature the
successes and challenges DFS faces
in providing CPS.
APPENDIX
A
Federal Legislation
Impacting CPS
¨
Child Welfare Services
Program, Title IV-B of the Social Security Act (1935)
provides grants to states to support preventative and protective services to
vulnerable children and their families.
Initially, most funds went to foster care payments; since 1980, federal
law has encouraged prevention of out-of-home placement.
¨
Foster care payments
under the Aid to Dependent Children program, Title IV-A of the Social Security
Act (1961) provide federal funds to help states
make maintenance payments for children who are eligible for cash assistance and
who live in foster care. Such payments
go to foster parents to cover the costs of children’s food, shelter, clothing,
supervision, travel home for visits, and the like. In 1980, this program was transferred to a new Title IV-E of the
Social Security Act.
¨
The Child Abuse
Prevention and Treatment Act (CAPTA), Public Law 93-247 (1974)
provides limited funding to states to prevent, identify, and treat child abuse
and neglect. It created the National
Center on Child Abuse and Neglect, developed standards for receiving and
responding to reports of child maltreatment, and established a clearinghouse on
the prevention and treatment of abuse and neglect. Changes in 1996 reinforced the act’s emphasis on child safety.
¨
The Social Services Block
Grant Title XX of the Social Security
Act (1975) provides funds the states can use for
social services to low-income individuals.
A significant but unknown portion of these funds pays for services
related to child protection, including prevention, treatment programs, and
foster care and adoption services.
¨
The Indian Child Welfare
Act, Public Law 95-608 (1978) strengthens
the role played by tribal governments in determining the custody of Indian
children, and specifies that preference should be given to placements with
extended family, then to Indian foster homes.
Grants allow tribes and Indian organizations to deliver preventive
services were authorized, but have not been funded.
¨
The Adoption Assistance
and Child Welfare Act, Public Law 96-272 (1980)
requires states that seek to maximize federal funding to establish programs and
make procedural reforms to serve children in their own homes, prevent
out-of-home placement, and facilitate family reunification following
placement. This act also transferred
federal foster care funding to a new Title IV-E of the Social Security Act, and
it provides funds to help states pay adoption expenses for children whose
special needs make adoptions difficult.
¨
The Family Preservation
and Support Initiative, Public Law 103-66 (1993)
gives funds to the states for family preservation and support planning and
services. The aim is to help
communities build a system of family support services to assist vulnerable
children and families prior to maltreatment, and family preservation services
to help families suffering crises that may lead to the placement of their
children in foster care.
¨
The Adoption and Safe
Families Act, Public Law 105-89 (1997)
reauthorizes and increases funding for the Family Preservation and Support
program, while changing its name to “Promoting Safe and Stable Families.” This law also requires states to move
children in foster care more rapidly into permanent homes, by terminating
parental rights more quickly and by encouraging adoptions.
Source: The Future of Children,
Vol. 8, No. 1 - Spring 1998. Published
by the Center for the Future of Children, The David and Lucile Packard
Foundation.
APPENDIX
B
Selected
Wyoming Statutes
ARTICLE 2
CHILD PROTECTIVE SERVICES
14-3-201. Purpose.
The purpose of W.S. 14-3-201 through
14-3-215 is to protect the best interest of the child or a disabled adult, to
further offer protective services when necessary in order to prevent any harm
to the child or any other children living in the home or to a disabled adult,
to protect children or disabled adults from abuse or neglect which jeopardize
their health or welfare, to stabilize the home environment and to preserve
family life whenever possible.
14-3-202. Definitions.
(a) As used in W.S. 14-3-201 through 14-3-215:
(i) "A person responsible for a child's
welfare" includes the child's parent, noncustodial parent, guardian,
custodian, stepparent, foster parent or other person, institution or agency
having the physical custody or control of the child;
(ii) "Abuse" with respect to a disabled
adult means as defined under W.S. 35-20-102(a)(ii). "Abuse" with respect to a child means inflicting or
causing physical or mental injury, harm or imminent danger to the physical or
mental health or welfare of a child other than by accidental means, including
abandonment, excessive or unreasonable corporal punishment, malnutrition or
substantial risk thereof by reason of intentional or unintentional neglect, and
the commission or allowing the commission of a sexual offense against a child
as defined by law:
(A) "Mental injury" means an injury to
the psychological capacity or emotional stability of a child as evidenced by an
observable or substantial impairment in his ability to function within a normal
range of performance and behavior with due regard to his culture;
(B) "Physical injury" means death or
any harm to a child including but not limited to disfigurement, impairment of
any bodily organ, skin bruising, bleeding, burns, fracture of any bone,
subdural hematoma or substantial malnutrition;
(C)
"Substantial risk" means a
strong possibility as contrasted with a remote or insignificant possibility;
(D) "Imminent danger" includes
threatened harm and means a statement, overt act, condition or status which
represents an immediate and substantial risk of sexual abuse or physical or
mental injury.
(iii) "Child" means any person under the
age of eighteen (18);
(iv) "Child protective agency" means
the field or regional offices of the department of family services;
(v) "Court proceedings" means child
protective proceedings which have as their purpose the protection of a child
through an adjudication of whether the child is abused or neglected, and the
making of an appropriate order of disposition;
(vi) "Institutional child abuse and
neglect" means situations of child abuse or neglect where a foster home or
other public or private residential home, institution or agency is responsible
for the child's welfare;
(vii) "Neglect" with respect to a
disabled adult means as defined under W.S. 35-20-102(a)(xi). "Neglect" with respect to a child
means a failure or refusal by those responsible for the child's welfare to
provide adequate care, maintenance, supervision, education or medical, surgical
or any other care necessary for the child's well being. Treatment given in good
faith by spiritual means alone, through prayer, by a duly accredited
practitioner in accordance with the tenets and practices of a recognized church
or religious denomination is not child neglect for that reason alone;
(viii) "State agency" means the state
department of family services;
(ix) "Subject of the report" means any
child reported under W.S. 14-3-201 through 14-3-215 or the child's parent,
guardian or other person responsible for the child's welfare, or any disabled
adult reported under W.S. 35-20-101 through 35-20-109 or the disabled adult's
caretaker;
(x) "Unfounded report" means any
report made pursuant to W.S. 14-3-201 through 14-3-215 or 35-20-101 through
35-20-109 that is not supported by credible evidence;
(xi) "Substantiated report" means any
report of child abuse or neglect pursuant to W.S. 14-3-201 through 14-3-215, or
any report of abuse, neglect, exploitation or abandonment of a disabled adult
under W.S. 35-20-101 through 35-20-109, that is determined upon investigation
that credible evidence of the alleged abuse, neglect, exploitation or
abandonment exists;
(xii) "Abandonment" with respect to a
disabled adult means as defined under W.S. 35-20-102(a)(i);
(xiii) "Disabled adult" means any person
defined under W.S. 35-20-102(a)(vi);
(xiv) "Exploitation" with respect to a
disabled adult means as defined under W.S. 35-20-102(a)(ix).
14-3-203. Duties of state agency; on-call services.
(a) The state agency shall:
(i) Administer W.S. 14-3-201 through 14-3-215;
(ii) Be responsible for strengthening and
improving state and community efforts toward the prevention, identification and
treatment of child abuse and neglect in the state;
(iii) Refer any person or family seeking
assistance in meeting child care responsibilities, whether or not the problem
presented by the person or family is child abuse or neglect, to appropriate
community resources, agencies, services or facilities; and
(iv) Assist with the diagnosis and referral for
treatment of osteogenesis imperfecta and hemophilia.
(b) The state agency may contract for assistance
in providing on-call services. The
assistance may include screening protection calls, making appropriate referrals
to law enforcement and the agency, and maintaining a record of calls and
referrals. Contractors shall have
training in child protection services.
14-3-204. Duties of local child protective agency.
(a) The local child protective agency shall:
(i) Prepare a plan for child protective services
under guidelines prepared by the state agency, and provide services under the
plan to prevent further child abuse or neglect. The plan shall be reviewed
annually by both agencies;
(ii) Receive, investigate or arrange for
investigation and coordinate investigation of all reports of known or suspected
child abuse or neglect;
(iii) Within twenty-four (24) hours after
notification of a suspected case of child abuse or neglect, initiate an
investigation and verification of every report. A thorough investigation and
report of child abuse or neglect shall be made in the manner and time
prescribed by the state agency. If the child protective agency is denied
reasonable access to a child by a parent or other persons and the agency deems
that the best interest of the child so requires, it shall seek an appropriate
court order by ex parte proceedings or other appropriate proceedings to see the
child;
(iv) If the investigation discloses that abuse or
neglect is present, initiate services with the family of the abused or
neglected child to assist in resolving problems that lead to or caused the
child abuse or neglect;
(v) Make reasonable efforts to contact the
noncustodial parent of the child and inform the parent of substantiated abuse
or neglect in high risk or moderate risk cases as determined pursuant to rules
and regulations of the state agency and inform the parent of any proposed
action to be taken;
(vi) Cooperate, coordinate and assist with the
prosecution and law enforcement agencies; and
(vii) When the best interest of the child requires
court action, contact the county and prosecuting attorney to initiate legal
proceedings and assist the county and prosecuting attorney during the
proceedings. If the county attorney elects not to bring court action the local
child protective agency may petition the court for appointment of a guardian ad
litem who shall act in the best interest of the child and who may petition the
court to direct the county attorney to show cause why an action should not be
commenced under W.S. 14-3-401 through 14-3-439.
14-3-205. Child abuse or neglect; persons required to
report.
(a) Any person who knows or has reasonable cause
to believe or suspect that a child has been abused or neglected or who observes
any child being subjected to conditions or circumstances that would reasonably
result in abuse or neglect, shall immediately report it to the child protective
agency or local law enforcement agency or cause a report to be made.
(b) If a person reporting child abuse or neglect
is a member of the staff of a medical or other public or private institution,
school, facility or agency, he shall notify the person in charge or his
designated agent as soon as possible, who is thereupon also responsible to make
the report or cause the report to be made. Nothing in this subsection is
intended to relieve individuals of their obligation to report on their own
behalf unless a report has already been made or will be made.
14-3-206. Child abuse or neglect; written report;
statewide reporting center; documentation; costs and admissibility thereof.
(a) Reports of child abuse or neglect or of
suspected child abuse or neglect made to the local child protective agency or
local law enforcement agency shall be followed by a written report confirming
or not confirming the facts reported. A written report may be dispensed with
for good cause shown.
(b) The state agency may establish and maintain
a statewide reporting center to receive reports of child abuse or neglect on a
twenty-four (24) hour, seven (7) day week, toll free telephone number. Upon
establishment of the service, all reports of child abuse or neglect may be made
to the center which shall transfer the reports to the appropriate local child
protective agency.
(c) Any person investigating, examining or
treating suspected child abuse or neglect may document child abuse or neglect
by having photographs taken or causing x-rays to be made of the areas of trauma
visible on a child who is the subject of the report or who is subject to a
report. The reasonable cost of the photographs or x-rays shall be reimbursed by
the appropriate local child protective agency. All photographs, x-rays or
copies thereof shall be sent to the local child protective agency, admissible
as evidence in any civil proceeding relating to child abuse or neglect, and
shall state:
(i) The name of the subject;
(ii) The name, address and telephone number of
the person taking the photographs or x-rays; and
(iii) The date and place they were taken.
14-3-207. Abuse or neglect as suspected cause of
death; coroner's investigation.
Any person who knows or has reasonable
cause to suspect that a child has died as a result of child abuse or neglect
shall report to the appropriate coroner. The coroner shall investigate the
report and submit his findings in writing to the law enforcement agency, the
appropriate district attorney and the local child protective agency.
14-3-208. Temporary protective custody; order; time
limitation; remedial health care.
(a) When a physician treating a child or a
medical staff member of a hospital in which a child is being treated has
reasonable cause to believe there exists an imminent danger to the child's life
or safety unless the child is taken into protective custody and there is not
time to apply for a court order, the child may be taken into temporary
protective custody without a warrant or court order and without the consent of
the parents, guardians or others exercising temporary or permanent control over
the child. Any person taking a child into temporary protective custody shall as
soon as possible notify the appropriate local child protective agency. Upon
notification, the local child protective agency shall initiate an investigation
of the notification and make every reasonable effort to inform the parent or
other person responsible for the child's welfare that the child has been taken
into temporary protective custody.
(b) Any district court judge, district court
commissioner or justice of the peace may issue a temporary protective custody
order upon finding that a child's life or safety is in danger. That order may
be requested by the state agency, the local child protective agency, a local
law enforcement officer, an administrator of a hospital in which a child
reasonably believed to have been abused or neglected is being treated or any
physician who reasonably believes a child has been abused or neglected, whether
or not additional medical treatment is required, and that the child, by
continuing in his place of residence or in the care and custody of the person
responsible for his welfare, would be in imminent danger of his life or health.
The local child protective agency shall be notified of the order.
(c) Temporary protective custody shall not
exceed seventy-two (72) hours.
(d) When necessary for the best interest or
welfare of a child, a court may order medical or nonmedical remedial health
care notwithstanding the absence of a prior finding of child abuse or neglect.
14-3-209. Immunity from liability.
Any person, official, institution or
agency participating in good faith in any act required or permitted by W.S.
14-3-201 through 14-3-215 is immune from any civil or criminal liability that
might otherwise result by reason of the action. For the purpose of any civil or
criminal proceeding, the good faith of any person, official or institution
participating in any act permitted or required by W.S. 14-3-201 through
14-3-215 shall be presumed.
14-3-210. Admissibility of evidence constituting
privileged communications.
(a) Evidence regarding a child in any judicial
proceeding resulting from a report made pursuant to W.S. 14-3-201 through
14-3-215 shall not be excluded on the ground it constitutes a privileged
communication:
(i) Between husband and wife;
(ii) Claimed under any provision of law other
than W.S. 1-12-101(a)(i) and (ii); or
(iii) Claimed pursuant to W.S. 1-12-116.
14-3-211. Appointment of counsel for child and other
parties.
(a) The court shall appoint counsel to represent
any child in a court proceeding in which the child is alleged to be abused or
neglected. Any attorney representing a child under this section shall also
serve as the child's guardian ad litem unless a guardian ad litem has been
appointed by the court. The attorney or guardian ad litem shall be charged with
representation of the child's best interest.
(b) The court may appoint counsel for any party
when necessary in the interest of justice.
14-3-212. Child protection teams; creation;
composition; duties; records confidential.
(a) The state agency and the local child
protective agency shall encourage and assist in the creation of
multi-disciplinary child protection teams within the communities in the state.
(b) The local child protection team shall be
composed of:
(i) A member of the district attorney's office;
(ii) A designated representative from the school
district or districts within the area served by the team;
(iii) Representatives from other relevant
professions; and
(iv) Temporary members selected for the needs of
a particular case as determined by the team.
(c) The local child protection team may:
(i) Assist and coordinate with the state agency,
the local child protective agency and all available agencies and organizations
dealing with children;
(ii) Facilitate diagnosis and prognosis; and
(iii) Provide an adequate treatment plan for the
abused and neglected child and his family.
(d) All records and proceedings of the child
protection teams are subject to W.S. 14-3-214.
14-3-213. Central registry of child and disabled adult
protection cases; establishment; operation; amendment, expungement or removal
of records; classification and expungement of reports; statement of person
accused.
(a) The state agency shall establish and
maintain within the statewide child protection center a central registry of
child protection cases in accordance with W.S. 42-2-111 and of disabled adult
protection cases under W.S. 35-20-101 through 35-20-109.
(b) Through the recording of reports, the
central registry shall be operated to enable the center to:
(i) Immediately identify and locate prior
reports of cases of child abuse or neglect and of abuse, neglect, exploitation
or abandonment of a disabled adult to assist in the diagnosis of suspicious
circumstances and the assessment of the needs of the child and his family or of
the disabled adult and his caretaker as defined under W.S. 35-20-102(a)(iv);
(ii) Continuously monitor the current status of
all pending child protection cases and disabled adult protection cases; and
(iii) Regularly evaluate the effectiveness of
existing laws and programs through the development and analysis of statistical
and other information.
(c) With the approval of the local child protective
agency in the case of child protection cases, or the local police department or
the sheriff's department in the case of disabled adult protection cases, upon
good cause shown and upon notice to the subject of the report, the state agency
may amend, expunge or remove any record from the central registry.
(d) All reports of child abuse or neglect
contained within the central registry shall be classified in one (1) of the
following categories:
(i) "Under investigation";
(ii) "Founded"; or
(iii) "Closed."
(e) Within six (6) months any report classified
as "under investigation" shall be reclassified as "founded"
or "closed" depending upon the results of the investigation.
Unfounded reports shall be expunged from the central registry.
(f) Any person named as a perpetrator of child
abuse or neglect or of abuse, neglect, exploitation or abandonment of any
disabled adult in any report maintained in the central registry which is
classified as a substantiated report as defined in W.S. 14-3-202(a)(xi) shall
have the right to have included in the report his statement concerning the
incident giving rise to the report. Any person seeking to include a statement
pursuant to this subsection shall provide the state agency with the statement.
From and after July 1, 1994 for cases involving a child, and from and after
July 1, 1995 for cases involving a disabled adult, the state agency shall
provide notice to any person identified as a perpetrator of his right to submit
his statement in any report maintained in the central registry.
14-3-214. Confidentiality of records; penalties;
access to information; attendance of school officials at interviews; access to
central registry records pertaining to child and disabled adult protection
cases.
(a) All records concerning reports and
investigations of child abuse or neglect are confidential except as provided by
W.S. 14-3-201 through 14-3-215. Any person who willfully violates this
subsection is guilty of a misdemeanor and upon conviction shall be fined not
more than five hundred dollars ($500.00) or imprisoned in the county jail not
more than six (6) months, or both.
(b) Applications for access to records
concerning child abuse or neglect contained in the state agency or local child
protective agency shall be made in the manner and form prescribed by the state
agency. Upon appropriate application, the state agency shall give access to any
of the following persons or agencies for purposes directly related with the
administration of W.S. 14-3-201 through 14-3-215:
(i) A local child protective agency;
(ii) A law enforcement agency, guardian ad litem,
child protection team or the attorney representing the subject of the report;
(iii) A physician or surgeon who is treating an
abused or neglected child, the child's family or a child he reasonably suspects
may have been abused or neglected;
(iv) A person legally authorized to place a child
in protective temporary custody when information in the report or record is
required to determine whether to place the child in temporary protective
custody;
(v) A person responsible for the welfare of the
child;
(vi) A court or grand jury upon a showing that
access to the records is necessary for the determination of an issue, in which
case access shall be limited to in camera inspection unless the court finds
public disclosure is necessary; and
(vii) Court personnel who are investigating
reported incidents of child abuse or neglect.
(c) A physician or person in charge of an
institution, school, facility or agency making the report shall receive, upon
written application to the state agency, a summary of the records concerning
the subject of the report.
(d) Any person, agency or institution given
access to information concerning the subject of the report shall not divulge or
make public any information except as required for court proceedings.
(e) Nothing in W.S. 14-3-201 through 14-3-215
prohibits the attendance of any one (1) of the following at an interview
conducted on school property by law enforcement or child protective agency
personnel of a child suspected to be abused or neglected provided the person is
not a subject of the allegation:
(i) The principal of the child's school or his
designee; or
(ii) A child's teacher or, counselor, or
specialist employed by the school or school district and assigned the duties of
monitoring, reviewing or assisting in the child's welfare in cases of suspected
child abuse or neglect.
(f) Upon appropriate application, the state
agency shall provide to any chapter of a nationally recognized youth
organization, child caring facility certified under W.S. 14-4-101 et seq.,
public or private school or state institution for employee or volunteer
screening purposes a summary of records maintained under department of family
services rules since December 31, 1986, concerning child abuse involving a
named individual or confirm that no records exist. Upon appropriate application
and for employee or volunteer screening purposes, the state agency shall
provide to any individual, nursing home, adult care facility, service provider
of adult workshop programs or home health care provider, residential programs
or any service provider of programs in an institution or community-based
program, or to any state institution, a record summary concerning abuse,
neglect, exploitation or abandonment of a disabled adult involving a named
individual or shall confirm that no record exists. The applicant shall submit a fee of five dollars ($5.00) and
proof satisfactory to the state agency that the prospective or current employee
or volunteer whose records are being checked consents to the release of the
information to the applicant. Central registry screening shall be limited to
substantiated reports of child abuse and neglect or substantiated reports of
abuse, neglect, exploitation or abandonment of a disabled adult, in which all
opportunities for due process have been exhausted under the Wyoming Administrative
Procedure Act including any appeal to the district court level. The applicant
shall use the information received only for purposes of screening prospective
employees and volunteers who may, through their employment or volunteer
services, have unsupervised access to minors or disabled adults. Applicants,
their employees or other agents shall not otherwise divulge or make public any
information received under this section.
The state agency shall notify any applicant receiving a report under
this section that a prospective employee is under investigation, of the final
disposition of that investigation or any appeal pending. The state agency shall notify any applicant
receiving information under this subsection of any subsequent reclassification
of the information pursuant to W.S. 14-3-213(e). The state agency shall screen
all prospective agency employees in conformity with the procedure provided
under this subsection.
(g) There is created a program administration
account within the earmarked revenue fund to be known as the "child and
disabled adult abuse registry account".
All fees collected under subsection (f) of this section shall be
credited to this account.
14-3-215. Other laws not superseded.
No
laws of this state are superseded by the provisions of W.S. 14-3-201 through
14-3-215.
APPENDIX
C
Stages
of CPS Decision Making and Casework
Intake
¨ Receive
the report
¨ Explore
appropriateness of the referral
¨ Decide
whether to investigate
¨ Determine
the urgency of response
¨ Assign the report to an investigator
Initial
Assessment/Investigation
¨ Make
contact with the child, family
¨ Assess
the harm to the child and other children in the home
¨ Assess
the risk for future harm
¨ Determine
the evidence of abuse/neglect
¨ Provide
emergency services
¨ Identify
resources that could be tapped to protect the child while at home
¨ Decide
on removal of the child
¨ Find
an appropriate placement
¨ Involve
law enforcement and courts, as indicated
¨ Decide
whether to keep case open for continuing protective services or to refer to other services
¨ Provide
feedback to parents and other relevant individuals
¨ Provide results of the assessment/ investigation to the state child welfare information system
Service
Planning
¨ Specify
changes needed to assure the child’s safety
¨ If a child is in placement, decide on permanency goal and develop resources
¨ Explore the family’s strengths and needs
¨ Identify
the outcomes anticipated through services
¨ Determine
what will be provided by whom, for how
long, and with what frequency
¨ Establish
dates for review
¨ Continue to review safety of child
Service
Provision
¨ Contract
for or coordinate services provided by other agencies
¨ Clearly
communicate service goals
¨ Deliver
selected services directly
¨ Prepare
for court hearing, as needed
¨ Continue to review safety of child
Evaluating
Progress
¨ Review
progress with all service providers and court, if involved
¨ Obtain
client perceptions of progress
¨ Determine
which services in the plan
are still needed, new referrals
needed
¨ Continue to review safety of child
Case
Closure
¨ With
family, evaluate progress
¨ Assess
continuing risks to the child
¨ Identify
steps to be taken if protective issues
re-emerge
¨ Decide
whether to close the case
¨ Communicate
decisions to all relevant agencies and persons
¨ Document rationale for closure
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