YSI: HHS Interested in Monitoring Differential Response?

Every once in awhile, a statement of real significance is nestled within the many pages of a policy tome. This is perhaps the case with a paragraph included in the recent Department of Health and Human Services’ notice about proposed new measurements on the Child and Family Services Review (CFSR).

Here is the paragraph that caught the eye of Youth Services Insider:

“The Children’s Bureau believes that multiple reports, regardless of whether maltreatment is substantiated or indicated, is a viable measure of the agency’s attempts to prevent maltreatment based on research indicating that families with screened-in but unsubstantiated reports are at a high risk of re-report, in some cases as high as substantiated cases.“

The statement emanates from a description of one proposed new measure that would, for the first time, see HHS hold states accountable on the CFSR for unsubstantiated maltreatment allegations.

The new measure would look at the number of children with at least one screened-in report in a 12-month period, and determine how many of them had “another screened-in report with a disposition” during those 12 months.

Screened-in reports that have a disposition reported are included, “regardless of whether the disposition is that the child is a victim or a non-victim.”

There are two reasons why, in YSI’s opinion, this statement probably deserved better than to be buried in the pages of a federal notice:

1) It is a significant precedent to set that states should answer for families that have not committed abuse or neglect in the eyes of the law. Libertarians might see the proposition that two unsubstantiations add up to a substantiation as a bit “Minority Report” –ish.

At the same time, the measure would put HHS in line with what many believe to be true about child welfare statistics: that substantiating maltreatment is difficult, and the number of substantiated cases of maltreatment represents just a fraction of the real amount.

2) While the term differential response (DR) is never used in the CFSR notice, it seems likely that this new re-report measure is meant to help HHS assess that practice.

DR is an alternative child welfare track in which some parents with substantiated abuse or neglect cases are offered voluntary help and support services. Help is at their disposal, but they do not run the risk of losing their child if they choose to pass on those services.

More than half the states use differential response to some extent now, and several states are using new federal IV-E waivers to try DR out. This new measure might give HHS insight into whether states using DR see a higher volume of parents that are screened in for maltreatment investigations twice in a short time span.

Youth Services Insider is mostly written by Chronicle Editor-in-Chief John Kelly.

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