Feds Eye New Measures for Child Welfare Reviews

The Department of Health and Human Services is amending its Child and Family Services Review (CSFR) process, including the addition of a few key measurements.

The CFSR process, which began during the Bush administration, includes a litany of metrics and case studies created to gauge the performance and progress of state child welfare agencies. In a nutshell: every state is reviewed over a four-year period, and notified of indicators on which they failed.

States are given a chance to submit program improvement plans aimed at addressing those shortcomings; they face financial penalties for continued failure. The second round of reviews was completed in 2010.

HHS is still taking input from the public on changes. Here’s a look at some of the new data the agency hopes to draw from states:

Re-Report of Maltreatment

Denominator: Number of children with at least one screened-in report of alleged maltreatment in a 12-month period.

Numerator: Number of children in the denominator that had another screened-in report with a disposition within 12 months of their initial report.

Notes: This would be the first time that states will be held accountable for unsubstantiated allegations of abuse or neglect. If the system screens in a report of maltreatment, and then screens in another one within a year, it will be measured and counted against the state in the CFSR.

More Data on Permanency Outcomes

HHS is proposing several new ways to measure a state when it comes to moving foster youths into permanent situations.

“Children’s Bureau is committed to maintaining focus on the key outcome of achieving permanency for all children in foster care and shortening the time to permanency,” the notice said.

The new measures:

Permanency Within 12 Months

Denominator: Number of children who enter foster care in a 12-month period.
Numerator: Number of children in the denominator who discharged to permanency within 12 months of entering foster care.

12-Month Resolution After 2 Years in Care

Denominator: Number of children in foster care on the first day of a 12-month period who had been in foster care (in that episode) for 2 or more years.
Numerator: Number of children in the denominator who discharged to permanency within 12 months of the first day.

Re-Entry to Foster Care

Denominator: Number of children who entered foster care in a 12-month period who discharged within 12 months to reunification, living with a relative, or guardianship.
Numerator: Number of children in the denominator who re-entered foster care within 12 months of their discharge from foster care.

Notes: It is hardly a surprise that HHS wants to know more about the permanency process, because the area of the CFSR where states struggle most is in permanency.  The goal set in the CFSR is for a permanency goal to be established in 90 percent of cases, and for a stable placement to be maintained in 90 percent of cases. One state achieved the former, zero states achieved the latter.

The re-entry measurement is actually a redux of an existing measurement. The proposed change would focus re-entry measurement on an “entry cohort” followed  for outcomes, as opposed to an “exit cohort.”

Limiting Permanency/Stability Metrics to Under 18

This is not a new measurement, but HHS made clear in the proposals that it wants to keep the CFSR process focused on minors. From the notice:

“The Children’s Bureau believes that it is appropriate to limit the permanency statewide data indicators to children under age 18 in this way to maintain consistency as we have in prior rounds.”

Notes: The impetus for this notification is the Fostering Connections to Success and Increasing Adoptions Act, which was signed into law in 2008. The law gave states the option to receive federal funding to provider foster care for young adults between 18 and 21.

This is reasonable; the anticipated experience for over-18 foster youths is notably different than minors.  But one hopes that some amount of federal research will be done on services and outcomes for older foster youth. For one, it would be nice to know how many youths changed placements during those older years.

Foster Care Experience

HHS is proposing two different measures for gauging the foster care experience:

Maltreatment During Foster Care

Denominator: All child days in foster care over a 12-month period.

Numerator: Number of instances of substantiated or indicated maltreatment among children in foster care over that same period.

Foster Care Placement Stability

Denominator: Among children who enter foster care in a 12-month period, the total number of days these children were in foster care as of the end of the 12-month period.

Numerator: Among children in the denominator, the total number of placement moves during the 12-month period.

Notes: The first measure is an addition meant to ensure that states are not removing children from one bad situation and putting them into another one.  The strength of the data is directly connected to a state’s efficacy when it comes to investigating maltreatment in its foster placements.

Interestingly, the proposal notes that this would include maltreatment by “any perpetrator, which may include foster parents, facility staff members, parents or others.” It will be interesting to see if public feedback on this has anything to say about inclusion of abuse by another youth.

The second measure would replace the current placement stability indicator, which tallied the percentage of youths served in a 12-month window who had more than two placements. Instead, HHS would create a number of placements-to-days-in-care ratio within a 12-month time frame.

The rationale is that national data ““indicates that most placement moves occur within a child’s first 12 months of foster care, which is why we plan to focus this indicator on that time period.”

This could shed light on the extent to which youths are placed more than twice in the first year, since that seems to be what HHS believes is happening in many cases.

John Kelly is editor-in-chief of The Chronicle of Social Change.

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About John Kelly, Editor in Chief, The Chronicle of Social Change 1213 Articles
John Kelly is editor-in-chief of The Chronicle of Social Change. Reach him at jkelly@chronicleofsocialchange.org.


  1. Pleased to see some attention given to reviewing the CFSR process. With ALL states experiencing failure, it seems appropriate to review the fundamentals of the evaluation process. Would like to see a series of public forums to discuss key elements of the new process. Practitioners as well as key stakeholders should have the opportunity to offer input.

  2. Kinship Care for Permanency
    Police can check you background before they even ask for your driver’s license and insurance care, but CPS agencies seem to need months. Even with incentives to complete interstate compacts, the process is taking far too long. Also, many agencies incorrectly only accept names of blood relative for placement, rather than people “known to the child” as required.

    Also, the requirement that foster training be taken in order to receive placement is an unnecessary and time consuming tactic that leads to issues of multiple placements.

  3. 12 Month Permanency
    My concern is concerning shortening the time to permanency. Although, for the children, it SOUNDS good, it isn’t possible in most cases.

    When children are removed, the states/counties have up to 90 days to complete the investigation. At that time, there is a hearing and case planning isn’t done until this point. With only 9 months left, parents are put on waiting lists for parenting classes that last 3 months. Psych evals, another element of the standard, cookie cutter case planning, takes up to 6 months from the setting of the appointment to the report being submitted to the court. Usually, at time, 9 months into the case, agencies will use what they have collected and (another cookie) 6 months of counseling. That puts this over the 12 month limit. Now add the reunification phase home. (another useless case plan item)

    Review Criteria
    The number of cases reviewed should be tied to the number of open cases, rather than a set number. This will give a better snapshot of the situation within the state. In “county administered” states, care should be taken that all counties are represented. Also, in these states, there needs to be a check for a state level investigative grievance procedure to be in accordance with SSA.

    This idea simply cannot work due to the poor scheduling skills of caseworkers. There is no reason to wait 90 days for court if investigations are completed prior. There is no reason that every caseplan has the same requirements, whether or not the service applies.

  4. I have concerns with the foster care placement stability measure. As the resolution for children in care measure for 2 years indicates a recognition of the vulnerability of this population in terms of waitng too long for permanency, so should the placement stability measure. In my county, we are historically able to exceed the current standards for our children in care for under 2 years. However, we have historically had to challenge ourselves to meet the standard for children in care for longer than 2 years. Additionally, I do not feel that the incidence ratio is as helpful to stakeholders as the the measures that refer to actual children. This data may prove less beneficial to practicioners and officials who need to make sense of what it all means when appropriating funding, etc. For example, as the round 1, 2 measures indicate, the federal bennchmark for kids in care for 2 or more years is much lower than the one for children in care under 12 mo or under 24 mo. This, in and of itself, is an indicating that this is a more vulnerable population and one whose quality of service must be carefully monitored.

  5. Measuring repeat maltreatment as well as dispositions regarding reports of abuse and neglect is a good way to identify families that are most vulnerable and require interventions. This might also be helpful in identifying gaps in services to specific populations and in individual states.

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