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Home > Advocacy > Advocacy Archives > The Adoption and Safe Families Act of 1997 (P.L. 105-89)

 
 

CWLA Comments on Section 203 of the Adoption and Safe Families Act

Welfare Outcome Measures

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March 4, 1999

Marianne Rufty
Children's Bureau
U.S. Department of Health and Human Services
330 C Street, SW
Washington, DC 20447

Regarding: CWLA Comments on Section 203 of the Adoption and Safe Families Act, Child Welfare Outcome Measures

Dear Ms. Rufty:

We are pleased to comment on the proposed measures resulting from Section 203 of the Adoption and Safe Families Act (ASFA), PL 105-89, which required the Department of Health and Human Services (DHHS) to develop a set of child welfare outcome measures that can be used to assess the performance of the States in operating child protection and child welfare programs and which were published in the February 2, 1999 issue of the Federal Register.

There are many positive features to the proposed measures. We applaud the Children's Bureau's aggressive approach in their focus on actual outcomes as opposed to process and appreciate the opportunity CWLA was given to participate in the development of the measures. Our primary concern is related to the exclusion of indicators that measure system resources and capacity, i.e., the amount and quality of resources the states allocate on behalf of those children and families who are served by the child welfare system.

We recognize that the current effort represents a work in progress. Although it is disappointing that measures of child well-being were excluded from this iteration because of your wish to limit the measures to data available through the National Child Abuse and Neglect Data System (NCANDS) and the Adoption and Foster Care Analysis and Reporting System (AFCARS), we strongly encourage further development in this area and support the Children's Bureau's plans to focus on education and health in the development of measures of child well-being.

Conceptual Framework

ASFA establishes a conceptual framework of safety, permanency, and child well-being for the outcome measures which we believe to be consistent with both societal values and current laws governing the conduct of the child welfare system. Although some critics of the system may be disappointed that measures of child well-being will be limited to the well-being of children living in out-of-home care, we realize that the current legislative mandate poses limits on what the Children's Bureau can propose at this time.

Child Welfare Outcome Measures

We are going to comment on each of the proposed measures. In some cases CWLA proposes additional measures or changes in the wording of the measures.

Safety Related Outcomes

Although not strictly measures of outcomes, we think a few basic measures derived from NCANDS should be included as an aid in understanding and interpreting the others. These include the number of children reported for child abuse and neglect per 1000 children in the population, the number of children reported for child abuse and neglect and referred for investigation per 1000 children in the population, the number of child victims (children substantiated) per 1000 reported and referred for investigation, the number of child victims removed from the home per 1000 child victims, and the number of children substantiated for child abuse and neglect by foster parents, kinship care providers, and facility staff per 1000 children living in out-of-home care.

1.   Of all children who were victims of substantiated child abuse and neglect, what percentage had another substantiated report within a 12-month period?

CWLA agrees this is a vital measure of child safety and recidivism.

2.   Of all children who were victims of substantiated child abuse and neglect, who were not placed in foster care, and whose families received services from the agency, what percentage had another substantiated report within a 12-month period?

We have no objection to this measure.

3.  Of all children who were victims of substantiated child abuse and neglect, who were not placed in foster care and whose families did not receive services from the agency, what percentage had another substantiated report within a 12-month period?

We have no objection to this measure.

4.  Of all child fatalities resulting from child abuse and neglect, what percentage of child victims had been the subject of a substantiated report of child abuse and neglect within the 12 (24) months prior to the reported fatality?

For counting purposes, anchoring this measure by children substantiated makes sense, but we would also like to know about cases that were reported, not substantiated, and resulted in child deaths.

5.  Of all child protection investigations initiated, what was the mean length of time between the report and initiation of the investigation?

We have no objection to this measure, but it appears to be a quality indicator as opposed to an outcome.

Permanency Related Measures

Like the safety related measures, we think a few basic measures related to permanency and derived from AFCARS, the Voluntary Child Information System (VCIS), or CWLA's National Data Analysis System (NDAS) should be included as an aid in understanding and interpreting the others. These include the number of children in out-of-home care (end of year census) per 1000 children in the population, the number of children entering and exiting out-of-home care per 1000 children in the population, the number of children exiting per 100 entries, and the median length of stay (in months) in out-of-home care for those living in out-of-home care and those who exited.

1.  Of all children who were reunified with their parents or caretakers from foster care placements, what percentage was reunified in less than 12 months from the time of the latest removal from home?

We have no objection this measure.

2.  Of all children who were reunified with their parents or caretakers from foster care placements, what percentage was reunified in 12 to 24 months from the time of the latest removal from home?

We have no objection this measure.

3.  Of all children who were reunified with their parents or caretakers from foster care placements in less than 12 months from the time of removal, what percentage re-entered foster care in less than 12 months from the time of reunification?

Using 12 months as the length of stay in out-of-home care would include almost everyone. We suggest you drop the 12 months criterion. The measure would read, "Of all children who were reunified with their parents or caretakers from foster care placements, what percentage re-entered foster care in less than 12 months from the time of reunification?"

4.  Of all children who were younger than 3 at the time of foster care entry and who exited foster care to finalized adoptions, what percentage exited to finalized adoptions in less than 24 months from entry?

Although adoption is not the appropriate outcome for most children living in out-of-home care, measures should reflect efforts at reducing the number of children living in out-of-home care through adoption. CWLA suggests adding the number of finalized adoptions per 1000 children living in out-of-home care.

5.  Of all children who were age 3 or older at the time of foster care entry and who exited foster care to finalized adoptions, what percentage exited to finalized adoptions in less than 36 months from entry?

Comments are the same as the previous measure.

6.  Of all children entering foster care, what percentage had been previously adopted when they were older than 2 years of age?

We should also measure the number of adoption disruptions per 1000 adoptions.

7.  Of all children who were discharged with a legal guardianship, what percentage was discharged in less than 24 months from the time of removal?

We have no objection to this measure.

8.  For children in non-relative foster care who exited care, what was the median length of time in care for African American children, American Indian/Alaska Native children, Asian and Pacific Islander children, Caucasian children, and Hispanic children?

In order to establish a baseline for all cohorts, we suggest including the median length of stay for all children who leave out-of-home care (for any given year) and the median length of stay for those who remain in out-of-home care.

9.  For children in relative foster care who exited care, what was the median length of time in care for African American children, American Indian/Alaska Native children, Asian and Pacific Islander children, Caucasian children, and Hispanic children?

Comments are the same as the previous measure.

10.  For all children who were identified as disabled and who exited care, what percentage exited to reunification, adoption, or legal guardianship?

The term disabled is problematic. Many states do not uniformly document whether or not a child has a physical or emotional disability. The term special needs is preferred.

11.  For all children who were 12 years of age or older at the time of their most recent entry into care and who exited care, what percentage exited to reunification, adoption, or legal guardianship?

We have no objection to this measure.

12.  For all children exiting care through emancipation, what percentage was younger than 12 years of age at the time of their most recent entry into care?

We have no objection this measure.

13.  For all children who had been in foster care for longer than 3 months, what percentage had not more than 2 placement settings during their most recent episode?

We have no objection to this measure.

14.  For all children who were younger than age 12 when they were placed in their current foster care settings, what percentage had a current placement in a group home? What percentage had a current placement in an institution?

We hope the Children's Bureau is not implying that placement into a group home or residential group care facility is a poor outcome when we know that type of placement should fit the individual needs of children and youth.

15.  For all children who were 12 years of age and older when they were placed in their current foster care settings, what percentage had a current placement in a group home? What percentage had a current placement in an institution?

Comments are the same as the previous measure.

16.  For all children whose current placement settings are group homes or institutions, what percentage is placed out-of-state?

We agree that it should be the goal of every state to serve children and youth as close to their homes and communities as possible.

As was mentioned earlier, we understand postponing the use of child well-being indicators because of the lack of available data, but we strongly recommend for the future including the number of children who receive family preservation or family support services per 1000 children reported and referred for investigation, the number of children receiving independent living services per 1000 children living in out-of-home care eligible to receive independent living services, the number of children living in out-of-home care with completed Early Periodic Screening, Diagnosis and Treatment (EPSDT) evaluations or the equivalent per 1000 children living in out-of-home care, and the number of children who age out of out-of-home care with high school diplomas or the GED per 1000 children who age out of out-of-home care.

Finally, CWLA strongly believes that using outcomes to assess the performance of state systems makes no sense outside the context of the resources brought to bear on those outcomes. CWLA recommends including dollars spent on child welfare per 1000 children in the population, the number of direct service practitioners whose primary responsibility is the investigation of child abuse and neglect per 1000 children reported and referred for investigation, the minimum educational requirement for a direct service practitioner whose primary responsibility is the investigation of child abuse and neglect, the required number of pre-service training hours for a direct service practitioner whose primary responsibility is the investigation of child abuse and neglect, and the annual turnover rate for direct service practitioners whose primary responsibility is the investigation of child abuse and neglect. Note that the measures are anchored by a position description that would be common to most, if not all child welfare systems.

We appreciate your attention to these comments and look forward to working with you to advance the safety, permanency, and well-being of children and families.

Sincerely,
David S. Liederman
Executive Director


For more information on these comments, contact Ada White, Director of Adoption Services, awhite@cwla.org.


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