The Department of Health and Human Services is taking suggestions on how to redesign the Child and Family Services Review, the main instrument by which the federal government measures the performance of state child welfare systems.
The public has until May 20 – to submit comments on the CFSR, which was first developed in 2000 and requires states to report on aspects of their child welfare systems that receive federal funding through the Title IV-B and Title IV-E programs. The changes would apply to the third round of reviews, which will begin in 2012.
The current review process combines an on-site inspection of 50 cases with data reported from the Adoption and Foster Care Analysis and Reporting System (AFCARS), such as the number of children who were adopted within 24 months of entering foster care and the number of children who are reunited with their families within 12 months. There are seven measures related to youth outcomes and seven related to system standards; states must be in substantial conformity with all 14 to pass the CFSR.
If a state fails its review, it must submit a program improvement plan (PIP) and then meet the goals in that plan within two years or face penalties from the federal government. Every state failed its first CFSR between 2002 and 2007, and nine were penalized for failing to meet their PIP goals. Ultimately, HHS rescinded the penalties for five states.
The second round of CFSR reviews and improvement plans, which began in 2007, is now complete. Four states have met the PIP goals. The rest have yet to fulfill the goals, and five are already past the stated “last date to complete the PIP.”
The Children’s Bureau, in a notice posted in the April 5 Federal Register, indicated it wanted to provide a way to take into account the fact that a major piece of child welfare legislation has been signed into law since the first iteration of the CFSR was designed.
The Fostering Connections to Success and Increasing Adoptions Act, signed in 2008 by President George W. Bush, requires states to assure educational opportunities for youth involved in the child welfare system, and offers federal funds for states to establish guardianship programs and extend foster care until age 21.
“Following two rounds of CFSRs in every state and the passage of several amendments to federal child welfare laws since the CFSRs began, we believe it is time to reassess how CB reviews title IV–B and IV–E programs through the CFSR and identify enhancements and system improvements we could make,” the notice for comments stated.
The notice poses questions to the public about how much AFCARS data should be relied upon, what other federal review processes the bureau should study, and whether other penalties or incentives should be added to the end of the review process.
The Children’s Bureau is part of the Administration for Children, Youth and Families, a division of HHS. Bryan Samuels, the top political appointee over the Children’s Bureau, voiced a several concerns about the CFSR in an interview with Youth Today, which will be posted on the website later this week.
One major concern, he said, is the equal weight the current CFSR places on all indicators.
“In the current construct, the CFSR combines a whole bunch of different pieces of information, and it’s not clear to me they’re all equally important,” Samuels said. “But as a result of the way it’s designed, they get treated as if they’re all equally important. There is probably a smaller set that ought to be given more attention.”
There are three ways to offer comments on the process to the Children’s Bureau:
Visit the Federal eRulemaking Portal at http://www.regulations.gov. Follow the instructions for submitting comments.
E-mail: CBComments@acf.hhs.gov. Please include ‘‘Comments on CFSR Federal Register Notice’’ in the subject line of the message.
Mail: Jan Rothstein, Division of Policy, Children’s Bureau, Administration on Children, Youth and Families, Administration for Children and Families, 1250 Maryland Ave. SW., 8th Floor, Washington, DC 20024.