The Department of Health and Human Services’ (HHS) Children’s Bureau (CB) has announced the third round of the Child and Family Services Reviews (CFSR). The reviews are a detailed assessment of each state’s child welfare system. This first round was conducted in 2001 and this third round is beginning in FY 2015. The CFSRs are a result of a 1994 Congressional mandate that was included as amendments to the Social Security Act (P.L. 103-432). The law required HHS to review state child welfare programs to ensure “substantial conformity” with state plan requirements in Titles IV-B and IV-E of the Social Security Act. State child welfare programs are to be measured or judged in certain areas or standards. Over the next several years, HHS and the states worked to develop the CFSR review process according the dictates of the law.
States are assessed on 14 outcomes with each state measured by 7 child and family outcomes and 7 systemic outcomes. If a state does not “substantially achieve” an outcome, penalties can be imposed, but regardless, states have to implement Program Improvement Plans (PIPs). As was the case in the first two rounds, the reviews will be staggered with all states covered over four years (FY 2015-2018).
In the first round of reviews, no state ‘passed’ (achieved substantial conformity) in their CFSR. Because of this, all states were required to complete a Performance Improvement Plan (PIP). This plan gave states the opportunity to work to improve specific outcome and systemic factors. The PIP is a two year process with an extra year allowed for states to realize negotiated improvements in their outcome data.
In this round the CB is making some revisions in how data from states is collected and reviewed in an attempt to provide a more accurate assessment. Changes are being made in how on-site interviews with stakeholders and case level data is assessed and how statewide data is used to make the determination of whether or not a state is in conformity on safety and permanency outcomes. The statewide data indicators are based on data available in states’ Adoption and Foster Care Analysis and Reporting System (AFCARS) and National Child Abuse and Neglect Data System (NCANDS) systems.
Public feedback has suggested a number of challenges with the statewide data indicators that ranged from methodological issues related to use of exit data, the lack of ease in interpreting composite numbers, and concerns about the comparability of states’ data. The CB indicated they will refine the safety measures to address some challenges raised by the widespread and varied implementation of differential response in state child protective services systems. More detailed information and rationales for the changes in the statewide data indicators and the national standards calculations will be available in the forthcoming Federal Register notice with an opportunity for public comment. The public will have 30 days to provide feedback to the CB about the indicators.