The Child Welfare League of America (CWLA) and its members including state child welfare agencies are pleased to respond to the proposed CFSR measures outlined in the Federal Register of January 11, 2008.
CWLA acknowledges the commitment of ACF to improving AFCARS. CWLA notes that there are several positive elements to the proposed AFCARS changes. We are pleased that the proposed rule includes a longitudinal component. This was recommended by CWLA in its response to a Federal Register request for comment about AFCARS in June of 2003. Longitudinal data will allow for a more complete understanding of a child’s experience in care and provide invaluable information for use in decision-making regarding policy and practice in child welfare. We believe this will enhance quality improvement activities and strengthen front-line practice that will maximize positive outcomes for children and families. It is believed that the use of episode based data will provide a clearer picture of stability of children in care and critical elements such as the effectiveness of permanency planning for children in care. This represents a significant improvement over the current point-in-time, child based reporting.
CWLA also supports the removal of the requirement to provide summary data. We believe this information does not contribute meaningful information regarding the child welfare population and service provision.
CWLA believes it is consistent with our mission to seek greater coordination between systems and other agencies that serve child populations. We are also supportive of efforts to collect greater information and detail on the children in the child welfare population. The changes as offered in this proposal represent a significant change in the data content and the manner in which data is collected. As a result it will involve a great investment of time, training and implementation in order for these proposed changes to be carried out in a way that will yield the most useful and accurate data possible. Examined in this light, CWLA has great concerns about certain key aspects of the proposed changes. The major issues center on the way data is restructured, how best to report on children not included in the child welfare population, the rapid expansion of data elements, and potential lack of quality data that may result. Finally we have a concern regarding the use and assessment of penalties. The proposed rule, if implemented incorrectly or by requiring unsound information will not only create significant burdens for states, it will fail to provide the type of information that will improve outcomes for children in the child welfare system.
CWLA is a strong advocate for greater research and information to learn where children are, how long they are in care, the type of care received, the composition of the families, and outcomes achieved in the child welfare system. We urge a special caution: the people most responsible for gathering this data are the same individuals charged with many other duties including managing the case, attempting to reunify and evaluate the child and family, and documenting the case for the courts and other mechanisms of oversight. In recent testimony before Congress we described the challenge in the child welfare workforce. As an example we cited a New York state Workload Study conducted in 2006 that determined that caseworkers were spending between 35 to 90 minutes in face to face contact with children and their families per case per month. Other states have reported similar findings both anecdotally and in formal workload studies. This highlights the often overwhelming demands placed on caseworkers when multiple or conflicting priorities are instituted, sometimes without fully evaluating their impact on workloads and the ability to provide effective services to families. In light of recent federal government mandates requiring face to face visits monthly, something we endorse as a best practice, we feel these proposed changes must also be evaluated for their impact on the workforce.
There are also important questions in regard to an implementation schedule. These changes suggest some very significant modifications to state information systems. Some in the child welfare field have suggested the creation of a workgroup that can help in further developing these proposed changes. CWLA strongly encourages ACF to consider utilizing a workgroup approach such as that used in the formation of the NCANDS data collection process. We believe such a group could be created and could act in an expeditious way so that in the end we do reach the goals for which there seems to be common agreement.
CWLA wishes to express appreciation for the opportunity to provide feedback on this proposed rule regarding the critical task of AFCARS data collection and reporting. CWLA once again commends ACF for its efforts to facilitate a move toward longitudinal data, but as outlined here the proposed regulations offer a number of challenges and we hope that we can work together with the states to resolve these issues.