Child Welfare
Enhanced Federal Oversight of Title IV-B Could Provide States Additional Information to Improve Services Gao ID: GAO-03-956 September 12, 2003In 2001, states determined that over 900,000 children were the victims of abuse or neglect. In fiscal year 2003, subparts 1 and 2 of Title IV-B of the Social Security Act provided $697 million in federal funding for services to help families address problems that lead to child abuse and neglect. This report describes (1) the services provided and populations served under subparts 1 and 2; (2) federal oversight of subpart 1; and (3) existing research on the effectiveness of services unique to subpart 1--that is, when states used subpart 1, but not subpart 2, to fund programs in a particular service category. The report focuses primarily on subpart 1 because little research exists on this subpart, while studies have been conducted on subpart 2.
On a national level, GAO's survey showed that the primary emphases of subparts 1 and 2 vary somewhat, but the range of services offered and the types of families served overlap significantly. No single category of service was funded solely by either subpart. In fiscal year 2002, states used subpart 1 funds most frequently for the salaries of child welfare agency staff, administrative and managerial expenses, child protective services, and foster care maintenance payments. Subpart 2 primarily funded family support, family preservation, family reunification, and adoption support services. Programs funded by the two subparts served similar types of populations--predominantly children at risk of being abused or neglected and their parents, as well as children in foster care and their parents. HHS's oversight focuses primarily on states' overall child welfare systems and outcomes, but the agency provides relatively little oversight specific to subpart 1. For example, HHS works with states to establish goals to improve the safety and well-being of children and measure progress toward those goals. However, HHS has limited knowledge about how states spend subpart 1 funds. States submit an annual estimate about how they plan to use their subpart 1 funds in the upcoming year, but provide no data on actual expenditures. HHS reports that it reviews these estimates for relatively limited purposes. We also found that HHS regional offices pay little attention to statutory limits on the use of subpart 1 funds for foster care maintenance and adoption assistance payments. For example, 9 of the 10 HHS regional offices do not monitor states' compliance with these limits. As a result, HHS approved projected 2002 spending plans for 15 states that reported estimated spending amounts that exceeded the limits by over $30 million in total. While GAO's survey data revealed no unique service categories funded by subpart 1 on a national level, 37 states reported unique subpart 1 service categories within their state. Little research is available on the effectiveness of the services in these categories, such as hotlines to report child abuse and emergency shelter services. No states conducted rigorous evaluations of these services, although several states provided some information on outcomes.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-03-956, Child Welfare: Enhanced Federal Oversight of Title IV-B Could Provide States Additional Information to Improve Services
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Report to the Chairman, Subcommittee on Human Resources, Committee on
Ways and Means, House of Representatives:
United States General Accounting Office:
GAO:
September 2003:
Child Welfare:
Enhanced Federal Oversight of Title IV-B Could Provide States
Additional Information to Improve Services:
GAO-03-956:
GAO Highlights:
Highlights of GAO-03-956, a report to the Chairman, Subcommittee on
Human Resources, Committee on Ways and Means, House of
Representatives
Why GAO Did This Study:
In 2001, states determined that over 900,000 children were the victims
of abuse or neglect. In fiscal year 2003, subparts 1 and 2 of Title IV-
B of the Social Security Act provided $697 million in federal funding
for services to help families address problems that lead to child
abuse and neglect. This report describes (1) the services provided and
populations served under subparts 1 and 2; (2) federal oversight of
subpart 1; and (3) existing research on the effectiveness of services
unique to subpart 1”that is, when states used subpart 1, but not
subpart 2, to fund programs in a particular service category. The
report focuses primarily on subpart 1 because little research exists
on this subpart, while studies have been conducted on subpart 2.
What GAO Found:
On a national level, GAO‘s survey showed that the primary emphases of
subparts 1 and 2 vary somewhat, but the range of services offered and
the types of families served overlap significantly. No single category
of service was funded solely by either subpart. In fiscal year 2002,
states used subpart 1 funds most frequently for the salaries of child
welfare agency staff, administrative and managerial expenses, child
protective services, and foster care maintenance payments. Subpart 2
primarily funded family support, family preservation, family
reunification, and adoption support services. Programs funded by the
two subparts served similar types of populations”predominantly
children at risk of being abused or neglected and their parents, as
well as children in foster care and their parents.
HHS‘s oversight focuses primarily on states‘ overall child welfare
systems and outcomes, but the agency provides relatively little
oversight specific to subpart 1. For example, HHS works with states to
establish goals to improve the safety and well-being of children and
measure progress toward those goals. However, HHS has limited
knowledge about how states spend subpart 1 funds. States submit an
annual estimate about how they plan to use their subpart 1 funds in
the upcoming year, but provide no data on actual expenditures. HHS
reports that it reviews these estimates for relatively limited
purposes. We also found that HHS regional offices pay little attention
to statutory limits on the use of subpart 1 funds for foster care
maintenance and adoption assistance payments. For example, 9 of the 10
HHS regional offices do not monitor states‘ compliance with these
limits. As a result, HHS approved projected 2002 spending plans for 15
states that reported estimated spending amounts that exceeded the
limits by over $30 million in total.
While GAO‘s survey data revealed no unique service categories funded
by subpart 1 on a national level, 37 states reported unique subpart 1
service categories within their state. Little research is available on
the effectiveness of the services in these categories, such as
hotlines to report child abuse and emergency shelter services. No
states conducted rigorous evaluations of these services, although
several states provided some information on outcomes.
What GAO Recommends:
GAO recommends that the Secretary of the Department of Health and
Human Services (HHS) (1) provide guidance to ensure that HHS regional
offices provide appropriate oversight of subpart 1; (2) consider the
feasibility of collecting data on states‘ use of these funds to
facilitate program oversight; and (3) use the information gained
through enhanced oversight of subpart 1 in designing its proposed
child welfare option, which would allow states to use other federal
child welfare funds for services allowed under Title IV-B. HHS
generally agreed with GAO‘s findings, but did not fully concur with
these recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-03-956.
To view the full product, including the scope and methodology, click
on the link above. For more information, contact Cornelia Ashby at
(202) 512-8403 or ashbyc@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
The Primary Emphases of These Subparts Vary Somewhat, but the Range of
Services and Types of Families Served Overlap Significantly:
HHS Focuses Oversight on Overall Child Welfare System, but Has Limited
Knowledge about States' Use of Subpart 1 Funds:
Some Unique Subpart 1 Service Categories Exist at the State Level, but
Little Research Exists on the Effectiveness of These Services:
Conclusions:
Recommendations:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Health and Human Services:
Appendix III: GAO Contacts and Acknowledgments:
GAO Contacts:
Acknowledgments:
Related GAO Products:
Tables:
Table 1: Selected Requirements to Obtain Grants under Subparts 1 and 2
of Title IV-B:
Table 2: Fiscal Year 2002 Expenditures for Subparts 1 and 2 Service
Categories:
Table 3: Populations Targeted by Services Funded by Subparts 1 and 2 of
Title IV-B in Fiscal Year 2002:
Table 4: Number of States Using Funds from Each Subpart of Title IV-B
to Target Specific Populations:
Figures:
Figure 1: Percentage of Subpart 1 Funds Used for Staff Salaries
Dedicated to Each Type of Staff Position in Fiscal Year 2002:
Figure 2: Survey Data on States' Preferences between Subparts 1 and 2
of Title IV-B for Different Program Components:
Figure 3: Fifteen States with Approved CFS-101s with Fiscal Year 2002
Subpart 1 Spending Estimates that Exceeded Limits for Foster Care
Maintenance and Adoption Assistance Payments:
Figure 4: Ten States That Reported Fiscal Year 2002 Subpart 1
Expenditures Exceeding Limits for Foster Care Maintenance and Adoption
Assistance Payments:
Abbreviations:
ACF: Administration for Children and Families:
APSR: Annual Progress and Services Report:
CFSR: Child and Family Services Review:
CPS: child protective services:
HHS: Health and Human Services:
HIPPY: Home Instruction for Parents of Preschool Youngsters:
United States General Accounting Office:
Washington, DC 20548:
September 12, 2003:
The Honorable Wally Herger
Chairman
Subcommittee on Human Resources
Committee on Ways and Means
House of Representatives:
Dear Mr. Chairman:
In 2001, child protective services (CPS) staff in state child welfare
agencies determined that over 900,000 children had been the victims of
abuse or neglect by their parents or other caretakers.[Footnote 1]
Title IV-B of the Social Security Act is the primary source of federal
funding for services to help families address problems that lead to
child abuse and neglect and to prevent the unnecessary separation of
children from their families. Title IV-B is divided into two parts.
States can use subpart 1 funds on almost any child welfare activity.
Subpart 2 provides grants to states for similar types of child welfare
services, such as family support services to enhance family stability
and services to help parents reunify with a child in foster care, but
is more restrictive in how the funds can be spent. In fiscal year 2003,
appropriations were $292 million for subpart 1 and $405 million for
subpart 2.[Footnote 2]
Title IV-B represents a small percentage of total federal spending on
child welfare activities. Most federal funding for these activities
comes from Title IV-E of the Social Security Act and is devoted
primarily to paying for the room and board of children in foster care-
-known as foster care maintenance payments. Title IV-B dollars can also
be used for foster care maintenance payments, but are more frequently
used for other types of services. As the Congress has enacted various
pieces of legislation to help move children from foster care into
permanent homes more quickly, it has emphasized the need for states to
use Title IV-B funding to provide supportive services needed to
preserve and reunify families. In 1980, for example, the Congress
increased appropriations for subpart 1, but enacted limits on the use
of these funds for foster care maintenance payments and adoption
assistance payments to encourage states to use the additional funding
for services to families.[Footnote 3] In addition, while states could
already use subpart 1 funds for services targeted in the new subpart 2
program, the creation of subpart 2 was motivated in part by the fact
that few states used a significant share of their subpart 1 funds for
these types of services. The Department of Health and Human Services'
(HHS) Administration for Children and Families is currently developing
a child welfare option that would allow states to use Title IV-E funds
for the same range of services allowed under Title IV-B.
Because of your interest in the services states are providing to meet
the needs of families,[Footnote 4] you asked us to examine the
following: (1) How do the services provided and populations served
under subpart 1 compare with those under subpart 2? (2) What has the
federal government's role been in overseeing the use of Title IV-B
subpart 1 funds? (3) What does the research say about the effectiveness
of services unique to subpart 1?
To answer these questions, we sent two surveys to child welfare
directors to obtain information on how they use Title IV-B funds. To
obtain a breakdown of state spending for subparts 1 and 2, we sent the
first survey to all 50 states and the District of Columbia and received
responses from 47 states[Footnote 5]. We sent the second survey to the
30 states that provided sufficient data on their first survey within
the timeframe that allowed us to conduct the second survey. We received
responses from 17 states, providing detailed information on the 3
services they reported as receiving the most subpart 1 funding and the
3 services they reported as receiving the most subpart 2 funding.
Because the data from these states may not be representative of all
states, we have used data from the second survey to provide examples of
the types of children and families served by Title IV-B. We also
conducted site visits in California, New Jersey, Ohio, and Washington,
where we interviewed state and local officials and service providers to
obtain more in-depth information on the services provided and the types
of children and families served. These states represent both geographic
diversity and diversity in how states used subpart 1 funds. In
addition, these states were identified as using innovative CPS tools or
processes. Further, we reviewed applicable laws and regulations;
interviewed HHS central and regional office officials about their
oversight activities with regard to Title IV-B; reviewed results from
HHS's assessments of state child welfare agencies, known as Child and
Family Services Reviews (CFSR); reviewed the literature assessing the
effectiveness of child welfare services; and interviewed child welfare
experts.
Results in Brief:
On a national level, our survey showed that the primary emphases of
subparts 1 and 2 vary somewhat, but the range of services offered and
the types of families served overlap significantly. Our survey found
that no single category of service was funded solely by subpart 1 or
subpart 2 in fiscal year 2002. In response to our survey, states
reported spending about 28 percent of subpart 1 funds on the salaries
of child welfare agency staff--primarily social work staff who can
provide a variety of services, including CPS investigations, recruiting
foster parents, and referring families for needed services. The next
three largest spending categories--administration and management
expenses, such as rent and utilities; CPS services; and foster care
maintenance payments--accounted for about 43 percent of subpart 1
spending. In comparison, states spent over 80 percent of subpart 2
dollars on the four mandated service categories--family support, family
preservation, family reunification, and adoption promotion and support
services. States reported funding services with subparts 1 and 2 that
serve similar populations--primarily children at risk of abuse and
neglect and their parents, as well as children living in foster care
and their parents. While none of the four states we visited could
provide data on the extent to which the same families participated in
services funded by subparts 1 and 2, officials in three of these states
believed that the two subparts generally served the same types of
children and families. Officials in almost all HHS regional offices
said that they believe that the two subparts offer a good balance in
allowing states some flexibility to address state needs and targeting
some federal funds toward services to keep families together.
HHS's oversight focuses primarily on states' overall child welfare
systems and outcomes, but the agency provides relatively little
oversight specific to subpart 1. For example, HHS regional offices work
with states to establish overall goals to improve the safety,
permanency, and well-being of children and measure progress toward
those goals. Using its CFSR process, HHS also evaluates how well states
are achieving positive outcomes for children and has found that many
states do not have strong outcomes with regard to providing the
services families need. However, HHS has limited knowledge about how
states spend their subpart 1 funds. HHS does not collect data on
subpart 1 expenditures, requiring instead that states submit annual
estimates about how they plan to use their subpart 1 funds in the
upcoming year. HHS regional offices reported that they review these
estimates for relatively limited purposes, such as ensuring that states
provide required matching funds. Several HHS officials noted that they
do not review the spending plans for subpart 1 as closely as subpart 2
because subpart 1 has few restrictions on how funds can be used. We
also found that HHS regional offices pay little attention to statutory
limits on the use of subpart 1 funds for foster care maintenance and
adoption assistance payments.[Footnote 6] For example, 9 of HHS's 10
regional offices do not monitor states' compliance with these limits.
As a result, HHS approved projected 2002 spending plans for 15 states
with planned spending amounts that exceeded these limits. In response
to our survey, 10 states reported a total of over $15 million in actual
2002 subpart 1 expenditures that exceeded the spending limits and were
thus out of compliance with the law.
Little research is available on the effectiveness of unique services
funded by subpart 1 at the state level because few states have
evaluated these services. While our survey data reveal no unique
categories of services funded by subpart 1 on a national level, 37
states generally reported 1 or 2 categories of services that were
uniquely funded by subpart 1 within their state--that is, they used
subpart 1, but not subpart 2, to fund services in particular
categories. The most common unique categories were CPS, foster care
maintenance payments, and staff salaries. Within the CPS category, for
example, unique services include professional assessments of a
caregiver's parenting skills, telephone hotlines to report child abuse
and neglect, and short-term shelter placement services. We contacted
the states with unique service categories other than administration,
salaries, and foster care maintenance and adoption assistance payments
and none of these states had conducted rigorous evaluations of these
services, although several states provided some outcomes data for the
services included in these categories. Our literature review on the
effectiveness of child welfare practices identified research for some
of these unique service categories, such as certain family preservation
programs, but only two specific services included in a unique subpart 1
category were identified in the research. For example, research on a
service that works with parents to prepare their children for school
and to enhance parent-child interactions has shown mixed results.
We are recommending that the Secretary of HHS (1) provide the necessary
guidance to ensure that HHS regional offices are providing appropriate
oversight of subpart 1, (2) consider the feasibility of collecting
basic data on states' use of these funds to facilitate its oversight of
the program and to provide guidance to help states determine
appropriate services to fund, and (3) use the information gained
through enhanced oversight of subpart 1 to inform its design of the
child welfare option that would allow states to use Title IV-E funds
for the same range of services allowed under Title IV-B. HHS's
Administration for Children and Families (ACF) generally agreed with
our findings, but did not fully concur with our recommendations. While
ACF agreed with our recommendation to provide the necessary guidance to
ensure that its regional offices monitor states' use of Title IV-B
subpart 1 funds, it said that these limits no longer serve a useful
purpose. ACF disagreed with our recommendation to consider collecting
data on subpart 1 expenditures. ACF believes its current level of
oversight is commensurate with the scope and intent of subpart 1,
noting that its oversight efforts are more appropriately focused on the
CFSR process. We believe, however, that assessing the feasibility of
collecting some basic data on states' subpart 1 expenditures could
enhance ACF's overall oversight of states' child welfare operations and
outcomes. ACF did not comment on our recommendation to use such data to
inform the design of its child welfare option.
Background:
Title IV-B of the Social Security Act, established in 1935, authorizes
funds to states to provide a wide array of services to prevent the
occurrence of abuse, neglect, and foster care placements. In 1993, the
Congress created a new program as subpart 2 of Title IV-B (now known as
Promoting Safe and Stable Families), which funds similar types of
services but is more prescriptive in how states can spend the funds. No
federal eligibility criteria apply to the children and families
receiving services funded by Title IV-B. The amount of subpart 1 funds
a state receives is based on its population under the age of 21 and the
state per capita income, while subpart 2 funding is determined by the
percentage of children in a state who receive food stamps.
In fiscal year 2003, the Congress appropriated $292 million for subpart
1 and $405 million for subpart 2. These federal funds cover 75 percent
of states' total Title IV-B expenditures because states must provide an
additional 25 percent using nonfederal dollars. Title IV-B funding is
relatively small compared with the other federal and state funds used
for child welfare services. According to the most recent data
available, states spent an estimated $10.1 billion[Footnote 7] in state
and local funds for child welfare services in state fiscal year 2000,
while federal Title IV-E expenditures in federal fiscal year 2000 were
$5.3 billion. In comparison, Title IV-B appropriations in federal
fiscal year 2000 were $587 million. Title IV-E[Footnote 8] provides an
open-ended individual entitlement for foster care maintenance payments
to cover a portion of the food, housing, and incidental expenses for
all foster children whose parents meet certain federal eligibility
criteria.[Footnote 9] Title IV-E also provides payments to adoptive
parents of eligible foster children with special needs.[Footnote 10]
States may choose to use Title IV-B funds to provide foster care
maintenance or adoption assistance payments for children without regard
to their eligibility for these payments under Title IV-E.[Footnote 11]
The Administration for Children and Families within HHS is responsible
for the administration and oversight of federal funding to states for
child welfare services under Titles IV-B and IV-E. HHS headquarters
staff are responsible for developing appropriate policies and
procedures for states to follow in terms of obtaining and using federal
child welfare funds, while staff in HHS's 10 regional offices are
responsible for providing direct oversight of state child welfare
systems.
In 2000, HHS established a new federal review system to monitor state
compliance with federal child welfare laws. One component of this
system is the CFSR, which assesses state performance in achieving
safety and permanency for children, along with well-being for children
and families. The CFSR process includes a self-assessment by the state,
an analysis of state performance in meeting national standards
established by HHS, and an on-site review by a joint team of federal
and state officials. Based on a review of statewide data, interviews
with community stakeholders and some families engaged in services, and
a review of a sample of cases, HHS determines whether a state achieved
substantial conformity with (1) outcomes related to safety, permanency,
and well-being, such as keeping children protected from abuse and
neglect and achieving permanent and stable living situations for
children and (2) key systemic factors, such as having an adequate case
review system and an adequate array of services. States are required to
develop program improvement plans to address all areas of
nonconformity.
Subpart 1:
Subpart 1 provides grants to states for child welfare services, which
are broadly defined. Subpart 1 funds are intended for services that are
directed toward the accomplishment of the following purposes:
* protect and promote the welfare of all children;
* prevent or remedy problems that may result in the abuse or neglect of
children;
* prevent the unnecessary separation of children from their families by
helping families address problems that can lead to out-of-home
placements;
* reunite children with their families;
* place children in appropriate adoptive homes when reunification is
not possible; and:
* ensure adequate care to children away from their homes in cases in
which the child cannot be returned home or cannot be placed for
adoption.
When the Congress enacted the Adoption Assistance and Child Welfare Act
of 1980, it established a dollar cap on the amount of subpart 1 funds
that states could use for certain services and created Title IV-E of
the Social Security Act. This legislation limited the total subpart 1
funds states could use for three categories of services: foster care
maintenance payments, adoption assistance payments, and child care
related to a parent's employment or training. While appropriations for
subpart 1 increased from $56.5 million in 1979 to $163.6 million in
1981, the law requires that the total of subpart 1 funds used for
foster care maintenance, adoption assistance, and child care payments
cannot exceed a state's total 1979 subpart 1 expenditures for all types
of services. The intent of this restriction, according to a
congressional document, was to encourage states to devote increases in
subpart 1 funding as much as possible to supportive services that could
prevent the need for out-of-home placements.[Footnote 12] However, this
restriction applies only to the federal portion of subpart 1
expenditures, as the law notes that states may use any or all of their
state matching funds for foster care maintenance payments.
Subpart 2:
In 1993, the Congress established the family preservation and family
support program under Title IV-B subpart 2, authorizing grants to
states to provide two categories of services: family preservation and
community-based family support services. The Adoption and Safe Families
Act of 1997 reauthorized the program, renaming it Promoting Safe and
Stable Families and adding two new service categories: adoption
promotion and support services and time-limited family reunification
services. Through fiscal year 2006, the Congress has authorized $305
million in mandatory funding for subpart 2 and up to $200 million
annually in additional discretionary funding. In fiscal year 2002, the
Congress appropriated $70 million in discretionary funding for the
program.[Footnote 13]
The definitions of the four subpart 2 service categories are:
* Family preservation services: Services designed to help families at
risk or in crisis, including services to (1) help reunify children with
their families when safe and appropriate; (2) place children in
permanent homes through adoption, guardianship, or some other permanent
living arrangement; (3) help children at risk of foster care placement
remain safely with their families; (4) provide follow-up assistance to
families when a child has been returned after a foster care placement;
(5) provide temporary respite care; and (6) improve parenting skills.
* Family support services: Community-based services to promote the
safety and well-being of children and families designed to increase the
strength and stability of families, to increase parental competence, to
provide children a safe and supportive family environment, to
strengthen parental relationships, and to enhance child development.
Examples of such services include parenting skills training and home
visiting programs for first time parents of newborns.
* Time-limited family reunification services: Services provided to a
child placed in foster care and to the parents of the child in order to
facilitate the safe reunification of the child within 15 months of
placement. These services include: counseling, substance abuse
treatment services, mental health services, and assistance to address
domestic violence.
* Adoption promotion and support services: Services designed to
encourage more adoptions of children in foster care when adoption is in
the best interest of the child, including services to expedite the
adoption process and support adoptive families.
These services are similar to those allowed under subpart 1, although
the range of services allowed under subpart 2 is more limited in some
cases. For example, time-limited family reunification services can only
be provided during a child's first 15 months in foster care, while no
such restriction is placed on the use of subpart 1 funds. In addition,
states must spend a "significant portion" of their subpart 2 funds on
each of the four service categories. HHS program instructions require
states to spend at least 20 percent of their subpart 2 funds on each of
the four service categories, unless a state has a strong rationale for
some other spending pattern. By statute, states can spend no more than
10 percent of subpart 2 funds on administrative costs. A congressional
document notes that states already had the flexibility to use subpart 1
funds for family support and family preservation services, but that few
states used a significant share of these funds for these
services.[Footnote 14] In creating subpart 2, the Congress did not
revise any components of subpart 1.
State Plan Requirements for Subparts 1 and 2:
To receive Title IV-B funds, states are required to submit a 5-year
child and family services plan to HHS. These plans have a number of
specific reporting and procedural requirements. While several of the
requirements are similar for subparts 1 and 2, states are required to
provide information about more aspects of their child welfare systems
under subpart 1. Some of the major requirements are outlined in table
1.
Table 1: Selected Requirements to Obtain Grants under Subparts 1 and 2
of Title IV-B:
Subpart 1: To receive subpart 1 funding, states must submit to HHS a 5-
year plan outlining the goals of the child welfare agency and annual
reports describing the progress made toward those goals. In this plan,
states must:
Subpart 1: * Specify the goals that will be accomplished by the end of
the 5-year plan, specific and measurable objectives that will be
undertaken to achieve each goal, and describe the methods to be used in
measuring annual progress in meeting these goals;
Subpart 1: * Describe the child welfare services provided and the
geographic areas where they are available;
Subpart 1: * Describe the steps taken to provide child welfare services
and to make progress in developing new services and expanding access to
services;
Subpart 1: * Consult with appropriate public and community-based
organizations in designing programs;
Subpart 1: * Ensure that the state will administer the plan in
accordance with methods determined by HHS to be proper and efficient;
Subpart 1: * Provide reports and participate in evaluations as required
by HHS;
Subpart 1: * Describe activities undertaken for children adopted from
other countries and report certain data on those children who enter
state custody due to the disruption or dissolution of such an
adoption;
Subpart 1: * Ensure that the state will develop plans for the effective
use of cross-jurisdictional resources to facilitate timely adoptions
for children waiting to be adopted;
Subpart 1: * Provide for the diligent recruitment of foster and
adoptive families that reflect the racial and ethnic diversity of
children in the state who need foster or adoptive homes;
Subpart 1: * Describe specific measures taken to comply with the Indian
Child Welfare Act;
Subpart 1: * Ensure that the state has implemented policies and
procedures that allow expeditious decisions about permanent placement
for children who are abandoned at birth;
Subpart 1: * Ensure that the state operates a case review system for
each child in state-supervised foster care;
Subpart 1: * Ensure that the state operates a statewide information
system to provide information about children in foster care;
Subpart 2: * To receive subpart 2 funding, states must
submit to HHS a 5-year plan outlining the goals of the child welfare
agency and annual reports describing the progress made toward those
goals. In this plan, states must:
Subpart 2: * Specify
the goals that will be accomplished by the end of the 5-year plan,
specific and measurable objectives that will be undertaken to achieve
each goal, and describe the methods to be used in measuring annual
progress in meeting these goals.
Subpart 2: * Describe the
child welfare services provided and the geographic areas where they are
available and the populations to be served.
Subpart 2: * Describe how subpart 2 funds will be used to
develop or expand services covered by subpart 2.
Subpart 2: * Consult with
appropriate public and community-based organizations in designing
programs.
Subpart 2: * Ensure that the state will administer the plan in
accordance with methods determined by HHS to be proper and efficient.
Subpart 2: * Provide reports and participate in evaluations as
required by HHS.
Subpart 2: * Ensure that the safety of children will be the
paramount concern in administering and conducting services.
Subpart 2: * Ensure that, at the
end of the 5-year period covered by the state's child welfare plan,
states review with appropriate public and community-based organizations
the progress made toward goals, publish a report on the progress, and
develop new goals for the program.
Subpart 2: *
Ensure that federal funds provided under subpart 2 will not supplant
federal or nonfederal funds for existing services that promote the
purposes of subpart 2.
Subpart 2: * Ensure that no more than 10 percent of
expenditures will be used for administrative costs.
Subpart 2: * Explain how
organizations were selected to provide family support services and how
these organizations meet the requirement that family support services
be community based.
Source: Title IV-B of the Social Security Act and 45 CFR 1357.
Note: Bolded text indicates where subpart 2 requirements differ from
those pertaining to subpart 1.
[End of table]
Alternative Financing Mechanisms for Child Welfare Services:
Federal child welfare funding has long been criticized for entitling
states to reimbursement for foster care placements, while providing
little funding for services to prevent such placements. HHS is
currently developing a legislative proposal to give states more
flexibility in using Title IV-E foster care funds for such preventive
services. Under this new proposal, states could voluntarily choose to
receive a fixed IV-E foster care allocation (based on historic
expenditure rates) over a 5-year period, rather than receiving a per
child allocation. The fixed allocation would be an estimate of how much
a state would have received in Title IV-E foster care maintenance
funds. States could use this allocation for any services provided under
Titles IV-B and IV-E, but would also have to fund any foster care
maintenance payments and associated administrative costs from this
fixed grant or use state funds.
Since 1994, HHS has also been authorized to establish child welfare
demonstrations that waive certain restrictions in Titles IV-B and IV-E
and allow states a broader use of federal funds. States with an
approved waiver must conduct a formal evaluation of the project's
effectiveness and must demonstrate the waiver's cost neutrality--that
is, a state cannot spend more in Title IV-B and IV-E funds than it
would have without the waiver. Projects generally are to last no more
than 5 years. HHS's authority to approve these waivers is scheduled to
expire at the end of fiscal year 2003.
The Primary Emphases of These Subparts Vary Somewhat, but the Range of
Services and Types of Families Served Overlap Significantly:
On a national level, our survey showed that the primary emphases of
subparts 1 and 2 vary somewhat, but the range of services offered and
the types of families served overlap significantly. According to our
survey data for fiscal year 2002, states spent subpart 1 funds most
frequently on the salaries of child welfare agency staff--primarily
social work staff who can provide a variety of services, such as CPS
investigations, recruiting foster parents, and referring families for
needed services. The next three largest categories--administration and
management expenses, CPS services, and foster care maintenance
payments--accounted for about 43 percent of subpart 1 funding. Subpart
2 funds, in comparison, were used primarily to fund programs within its
required service categories--family support, family preservation,
family reunification, and adoption promotion and support services. Some
social work staff whose salaries were funded with subpart 1 may provide
similar services to families as the staff in these programs funded by
subpart 2. On a national basis, however, no service category was solely
funded by either subparts 1 or 2. The programs funded by subpart 1 and
2 dollars served similar types of children and families. States used
the majority of funds from each subpart to provide services to children
at risk of abuse and neglect and their parents, as well as foster
children and their parents. Officials in most HHS regional offices said
that they believe that the current structure of Title IV-B offers a
good balance in allowing states some flexibility to address state needs
and targeting some federal funds toward services to keep families
together and prevent children from entering foster care.
While the Distribution of Funds Differs Somewhat, Some Overlap in
Service Categories Exists:
Although no category of service is funded solely by either subparts 1
or 2 dollars, somewhat different spending patterns emerged with regard
to the distribution of these funds among the categories. The states
responding to our survey reported spending about 28 percent of subpart
1 funds in fiscal year 2002 on the salaries of child welfare agency
staff, with an additional 43 percent used for administration and
management expenses, foster care maintenance payments, and direct CPS
services (see table 2). In comparison, states used over 80 percent of
subpart 2 dollars to fund services in its mandated service categories-
-family support, family preservation, family reunification, and
adoption promotion and support services.[Footnote 15] However, neither
subparts 1 nor 2 funded a unique category of service at the national
level.[Footnote 16] For example, states typically reported using
subpart 1 to fund CPS programs; however, 5 states used subpart 2
dollars to fund programs in this category.
Table 2: Fiscal Year 2002 Expenditures for Subparts 1 and 2 Service
Categories:
Service category: Staff positions; Subpart 1: Number of states: 25;
Subpart 1: Amount of subpart 1 funding[A]: $70,965,578; Subpart 1:
Percentage of subpart 1 funding: 27.6; Subpart 2: Number of
states: 17; Subpart 2: Amount of subpart 2 funding[A]: $6,229,058;
Subpart 2: Percentage of subpart 2 funding[B]: 2.4.
Service category: Administration and management; Subpart 1: Number of
states: 16; Subpart 1: Amount of subpart 1 funding[A]: 43,143,097;
Subpart 1: Percentage of subpart 1 funding: 16.8; Subpart 2:
Number of states: 18; Subpart 2: Amount of subpart 2 funding[A]:
11,614,667; Subpart 2: Percentage of subpart 2 funding[B]: 4.5.
Service category: Child protective services; Subpart 1: Number of
states: 17; Subpart 1: Amount of subpart 1 funding[A]: 40,543,000;
Subpart 1: Percentage of subpart 1 funding: 15.8; Subpart 2:
Number of states: 5; Subpart 2: Amount of subpart 2 funding[A]:
2,248,690; Subpart 2: Percentage of subpart 2 funding[B]: 0.9.
Service category: Foster care maintenance payments; Subpart 1: Number
of states: 17; Subpart 1: Amount of subpart 1 funding[A]: 27,890,783;
Subpart 1: Percentage of subpart 1 funding: 10.8; Subpart 2:
Number of states: 2; Subpart 2: Amount of subpart 2 funding[A]:
647,154; Subpart 2: Percentage of subpart 2 funding[B]: 0.3.
Service category: Multiple responses[C]; Subpart 1: Number of states:
8; Subpart 1: Amount of subpart 1 funding[A]: 25,806,347; Subpart 1:
Percentage of subpart 1 funding: 10.0; Subpart 2: Number of
states: 4; Subpart 2: Amount of subpart 2 funding[A]: 3,503,585;
Subpart 2: Percentage of subpart 2 funding[B]: 1.4.
Service category: Family support/prevention; Subpart 1: Number of
states: 17; Subpart 1: Amount of subpart 1 funding[A]: 19,840,891;
Subpart 1: Percentage of subpart 1 funding: 7.7; Subpart 2:
Number of states: 28; Subpart 2: Amount of subpart 2 funding[A]:
127,430,496; Subpart 2: Percentage of subpart 2 funding[B]: 49.8.
Service category: Counseling and mental health services; Subpart 1:
Number of states: 2; Subpart 1: Amount of subpart 1 funding[A]:
8,350,562; Subpart 1: Percentage of subpart 1 funding: 3.2;
Subpart 2: Number of states: 5; Subpart 2: Amount of subpart 2
funding[A]: 1,354,763; Subpart 2: Percentage of subpart 2 funding[B]:
0.5.
Service category: Family preservation; Subpart 1: Number of states: 7;
Subpart 1: Amount of subpart 1 funding[A]: 5,986,045; Subpart 1:
Percentage of subpart 1 funding: 2.3; Subpart 2: Number of
states: 23; Subpart 2: Amount of subpart 2 funding[A]: 30,308,896;
Subpart 2: Percentage of subpart 2 funding[B]: 11.8.
Service category: Adoption subsidy payments; Subpart 1: Number of
states: 7; Subpart 1: Amount of subpart 1 funding[A]: 4,657,546;
Subpart 1: Percentage of subpart 1 funding: 1.8; Subpart 2:
Number of states: 2; Subpart 2: Amount of subpart 2 funding[A]:
737,412; Subpart 2: Percentage of subpart 2 funding[B]: 0.3.
Service category: Family reunification; Subpart 1: Number of states: 4;
Subpart 1: Amount of subpart 1 funding[A]: 2,446,570; Subpart 1:
Percentage of subpart 1 funding: 1.0; Subpart 2: Number of
states: 26; Subpart 2: Amount of subpart 2 funding[A]: 23,625,973;
Subpart 2: Percentage of subpart 2 funding[B]: 9.2.
Service category: Recruitment and training for foster/adoptive parents;
Subpart 1: Number of states: 9; Subpart 1: Amount of subpart 1
funding[A]: 2,260,061; Subpart 1: Percentage of subpart 1 funding: 0.9;
Subpart 2: Number of states: 16; Subpart 2: Amount of subpart
2 funding[A]: 6,828,885; Subpart 2: Percentage of subpart 2 funding[B]:
2.7.
Service category: Adoption support and preservation services; Subpart
1: Number of states: 2; Subpart 1: Amount of subpart 1 funding[A]:
446,877; Subpart 1: Percentage of subpart 1 funding: 0.2;
Subpart 2: Number of states: 27; Subpart 2: Amount of subpart 2
funding[A]: 28,481,585; Subpart 2: Percentage of subpart 2 funding[B]:
11.1.
Service category: Other; Subpart 1: Number of states: 11; Subpart 1:
Amount of subpart 1 funding[A]: 4,817,180; Subpart 1: Percentage of
subpart 1 funding: 1.9; Subpart 2: Number of states: 15;
Subpart 2: Amount of subpart 2 funding[A]: 12,795,915; Subpart 2:
Percentage of subpart 2 funding[B]: 5.0.
Service category: Total[D]; Subpart 1: Number of states: ; Subpart 1:
Amount of subpart 1 funding[A]: $257,154,537; Subpart 1: Percentage of
subpart 1 funding: 100.0%; Subpart 2: Number of states: ;
Subpart 2: Amount of subpart 2 funding[A]: $255,807,079; Subpart 2:
Percentage of subpart 2 funding[B]: 100.0%.
Source: GAO survey.
Notes: Percentages do not always total to 100 due to rounding.
Data on subpart 1 expenditures are based on survey responses from 46
states and data on subpart 2 expenditures are based on survey responses
from 44 states. While Pennsylvania responded to our survey, it did not
provide expenditure data for subparts 1 or 2.
[A] When providing data for our survey, states were asked to indicate
the single service category that best described the type of program
funded by subparts 1 and 2. Thus, programs that fall into multiple
service categories may not be fully captured. For example, one state
indicated it funded a family support program, which includes some
family preservation and reunification services. In addition, states may
not have been consistent in categorizing services. For example, several
HHS officials told us that the delineation between family support and
family preservation services is not clear, so that two states providing
the same services to the same types of families may report them in
different categories. Inconsistencies such as these could have an
effect on any measured differences among service categories.
[B] States may spend less than 20 percent of their subpart 2 funds on
any of the required service categories if they have a strong rationale.
Some HHS regional officials said that they approve exceptions to the 20
percent requirement if a state is spending a significant amount of
nonfederal funds on a subpart 2 service category.
[C] Although states were asked to indicate the single service category
that best described the type of program funded by subparts 1 and 2,
several states selected multiple program categories when responding to
our survey. For example, Rhode Island reported that it funded a home
visitation program and indicated that this program includes family
support, health, and family reunification services. Thus, the responses
from states that reported multiple categories for a program are
represented by this category.
[D] The aggregate dollars reported in the service categories do not
match the total allocations for subparts 1 and 2 in fiscal year 2002.
States have 2 years to spend their Title IV-B allocations; as a result,
expenditures in fiscal year 2002 may include dollars from a state's
fiscal year 2001 Title IV-B allocation, as well as its fiscal year 2002
Title IV-B allocation. Similarly, some fiscal year 2002 allocations may
not have been spent until fiscal year 2003.
[End of table]
Subpart 1 dollars were most frequently used to fund staff salaries,
with almost half of these funds designated for the salaries of CPS
social workers. Another 20 percent of these funds were used for the
salaries of other social workers (see fig. 1).[Footnote 17] During our
site visit, Washington child welfare officials told us that they used
over 50 percent of the state's subpart 1 funds for salaries of staff
providing direct services, including CPS social workers, social workers
who provide ongoing case management and support services to families
involved with the child welfare agency due to concerns about abuse or
neglect, social work supervisors, and clerical support staff. While
states also reported using subpart 2 funds for staff salaries, only 2
percent of subpart 2 dollars were used for this purpose. This
comparison may underestimate the overlap in services funded by subparts
1 and 2, however, because much of the costs of programs funded by
subpart 2 is likely attributable to staff salaries. Similarly, some
social work staff whose salaries are funded by subpart 1 likely provide
a variety of services, such as family preservation services, recruiting
foster families, and referring families for needed services, some of
which may be similar to services funded by subpart 2.
Figure 1: Percentage of Subpart 1 Funds Used for Staff Salaries
Dedicated to Each Type of Staff Position in Fiscal Year 2002:
[See PDF for image]
Notes: Some states spent subpart 1 funds on salaries, but could not
provide information on the types of staff positions included.
[End of figure]
Percentages do not total to 100 due to rounding.
Administration and management comprised the second largest category of
service, accounting for almost 17 percent of subpart 1 dollars. These
services included rent and utilities for office space, travel expenses
for agency staff, and staff training.[Footnote 18] Ohio, for example,
used most of its subpart 1 dollars to fund state and county child
welfare agency administrative expenses. In contrast, states spent less
than 5 percent of their subpart 2 funds on administration and
management.
CPS represents the third largest category of services that states
funded with subpart 1. States used about 16 percent of their subpart 1
funds to provide a variety of CPS services, such as telephone hotlines
for the public to report instances of child abuse and neglect,
emergency shelters for children who needed to be removed from their
homes, and investigative services. During our site visit to California,
for example, officials reported using about 40 percent of their subpart
1 dollars to fund staff salaries and operating expenses associated with
a variety of shelter care services provided by counties, such as
emergency shelters and foster homes. A child is placed in one of these
shelters when no other placement option is immediately available--for
example, when an investigation in the middle of the night determines
that the child is at immediate risk of harm or when a child runs away
from a foster home. In comparison to states' use of subpart 1 funds,
states reported using less than 1 percent of their subpart 2 dollars to
fund programs within this service category.
States used nearly 11 percent of their subpart 1 funds to make
recurring payments for the room and board of foster children who are
not eligible for reimbursement through Title IV-E. For instance, New
Jersey officials reported spending over 50 percent of the state's
subpart 1 funds on foster care maintenance payments. Seventeen states
spend subpart 1 funds on foster care maintenance payments, while only 2
states reported using subpart 2 funds for this purpose, accounting for
less than 1 percent of total subpart 2 expenditures.
States reported using half of their subpart 2 dollars to fund family
support services. These services included mentoring programs to help
pregnant adolescents learn to be self-sufficient, financial assistance
to low-income families to help with rent and utility payments, and
parenting classes, child care, and support groups provided by a
community-based resource center. One California county we visited used
subpart 2 to fund a network of family support services with the goal of
strengthening communities and keeping families from becoming involved
with the child welfare system. Funds were granted to community groups
to provide support and improve the healthy development of families for
different populations, such as grandparent caregivers and adolescent
mothers. Washington funded a network of public health nurses and social
service agencies to provide support services to families that are the
subject of a report of abuse or neglect--these services are provided in
lieu of, or following, a formal investigation when the level of risk to
the child is not considered high. Over one-third of the states
responding to our survey also reported using subpart 1 funds to provide
family support services similar to those funded by subpart 2, although
family support services only accounted for 8 percent of subpart 1
expenditures. For example, New Jersey transferred about 27 percent of
its subpart 1 funds to local child welfare agencies to provide family
support services, which included parent education classes,
transportation, and mentoring for children.
Family preservation services--designed to keep families together and
prevent the need to place a child in foster care--represented the
second largest service category funded by subpart 2. Washington used
subpart 2 funds for its statewide family preservation program, which
offers counseling and parent training services for up to 6 months to
families with children who are at risk of being placed in foster care.
In some cases, services provided in this category were similar to those
in the family support category, but were intended to help keep families
together. For example, Florida funded several neighborhood resource
centers, which provide child care, parenting classes, adult education
and training opportunities, mental health services, transportation
services, and a food pantry. Although states primarily used subpart 2
dollars to provide these services, states also reported using
approximately 2 percent of subpart 1 funds on family preservation
services.
In addition, states reported using about 11 percent of their subpart 2
funds for adoption support and preservation services. With these funds,
states provided services such as counseling for children who are going
to be adopted, family preservation services to adoptive families, and
respite care for adoptive parents. Officials in Ohio reported using
almost half of its subpart 2 dollars for adoption services, including
post adoption services and services to recruit families for children in
need of adoptive homes. Similarly, Florida funded adoption support
services for children with special needs who are awaiting adoption,
including counseling, behavior modification, tutoring, and other
services to expedite the adoption process. In contrast, less than 1
percent of subpart 1 dollars were used to provide adoption support and
preservation services.
Finally, states spent about 9 percent of their subpart 2 dollars on
family reunification services. States funded a diverse array of family
reunification programs, such as supervised visitation centers for
parents to visit with their children and coordinators for alcohol and
drug treatment services for families whose primary barrier to
reunification is substance abuse. New Jersey funded a supervised
visitation program that offers parenting education, counseling,
transportation, and support groups and is located in a private home,
allowing families to visit together in a homelike setting and engage in
more natural interactions. One county we visited in California used
subpart 2 funds for a shared family care program, in which the parent
and child are placed together in a mentor home. The mentor provides a
role model for good parenting behavior and provides hands-on parenting
guidance to keep the family together, while a case manager ensures that
family members receive services to address problems that could lead to
the removal of the child, such as substance abuse or homelessness.
Subpart 1 funds were used much less frequently for family reunification
services; states reported using 1 percent of subpart 1 funds for these
services.
Significant Overlap Exists among the Types of Children and Families
Served by Subparts 1 and 2:
Significant overlap exists among the types of children and families
served by these subparts, although certain populations are more closely
associated with a particular subpart. Services funded by each subpart
predominantly targeted children at risk of abuse or neglect and their
parents, as well as children in foster care and their parents. States
responding to our survey reported that services funded by subpart 1 in
fiscal year 2002 most frequently served children living in foster care
and/or their parents, while 9 percent of subpart 2 funds are used for
services that target the same population (see table 3). Similarly,
while subpart 2 services most commonly targeted children at risk of
abuse and neglect and/or their parents, about 17 percent of subpart 1
funds were also used for services aimed at this population. In
addition, 9 percent of subpart 1 funds and 11 percent of subpart 2
funds were used to fund services intended for both of these types of
families.
Table 3: Populations Targeted by Services Funded by Subparts 1 and 2 of
Title IV-B in Fiscal Year 2002:
Population served: Children in foster care and/or their parents;
Subpart 1: No. of services: 33; Subpart 1: Amount of subpart 1 funding:
$34,732,673; Subpart 1: Percent of funding: 42; Subpart 2: No.
of services: 46; Subpart 2: Amount of subpart 2 funding: $15,218,065;
Subpart 2: Percent of funding: 9.
Population served: Children at risk of child abuse and neglect and/or
their parents; Subpart 1: No. of services: 28; Subpart 1: Amount of
subpart 1 funding: 13,751,328; Subpart 1: Percent of funding: 17;
Subpart 2: No. of services: 133; Subpart 2: Amount of subpart
2 funding: 73,996,404; Subpart 2: Percent of funding: 44.
Population served: Programs serving multiple populations; Subpart 1:
No. of services: 21; Subpart 1: Amount of subpart 1 funding:
11,949,444; Subpart 1: Percent of funding: 14; Subpart 2: No.
of services: 43; Subpart 2: Amount of subpart 2 funding: 18,119,756;
Subpart 2: Percent of funding: 11.
Population served: Children at risk of child abuse or neglect and/or
their parents and children living in foster care and/or their parents;
Subpart 1: No. of services: 12; Subpart 1: Amount of subpart 1 funding:
7,077,448; Subpart 1: Percent of funding: 9; Subpart 2: No. of
services: 39; Subpart 2: Amount of subpart 2 funding: 17,606,172;
Subpart 2: Percent of funding: 11.
Population served: Programs serving all populations; Subpart 1: No. of
services: 5; Subpart 1: Amount of subpart 1 funding: 7,513,368; Subpart
1: Percent of funding: 9; Subpart 2: No. of services: 7;
Subpart 2: Amount of subpart 2 funding: 11,028,464; Subpart 2: Percent
of funding: 7.
Population served: Children waiting for adoption, adopted children, and
adoptive parents; Subpart 1: No. of services: 9; Subpart 1: Amount of
subpart 1 funding: 4,153,271; Subpart 1: Percent of funding: 5;
Subpart 2: No. of services: 54; Subpart 2: Amount of subpart 2
funding: 27,340,372; Subpart 2: Percent of funding: 16.
Population served: Other populations, such as delinquent teens and
foster parents; Subpart 1: No. of services: 10; Subpart 1: Amount of
subpart 1 funding: 3,492,142; Subpart 1: Percent of funding: 4;
Subpart 2: No. of services: 16; Subpart 2: Amount of subpart 2
funding: 3,336,070; Subpart 2: Percent of funding: 2.
Population served: Total[A]; Subpart 1: No. of services: 118; Subpart
1: Amount of subpart 1 funding: $82,669,674; Subpart 1: Percent of
funding: 100%; Subpart 2: No. of services: 338; Subpart 2:
Amount of subpart 2 funding: $166,645,301; Subpart 2: Percent of
funding: 100%.
Source: GAO survey.
Note: This analysis is based on survey responses from 35 states with
state-administered child welfare systems that provided population data
for their subpart 1 services and 39 states with state-administered
child welfare systems that provided population data for their subpart 2
services. Therefore, these data can only be generalized to states with
state-administered child welfare systems.
[A] The dollar totals in this table do not match those in table 2
because we do not have population data from states that completed the
county-administered survey. Due to the differences in information
available from states with county-administered child welfare systems,
we did not request data in the first county-administered survey on the
types of children and families who received services funded by Title
IV-B--these data were to have been obtained on the second survey. In
addition, we did not collect data on the populations served for the
category of staff salaries, and we excluded population data for the
category of administration and management expenses since these expenses
are not targeted to a particular population of children and families.
[End of table]
The overlap in populations observed at the national level can also be
seen when looking at the children and families targeted by individual
states. We found that individual states frequently funded programs with
each subpart that served the same types of children and families. For
example, all 20 states that used subpart 1 dollars to fund services for
children at risk of abuse or neglect and/or their parents also used
subpart 2 dollars to fund a program serving this same population type
(see table 4). Alaska, for instance, used subpart 1 dollars to fund a
broad family support program, which provided services to children at
risk of abuse and neglect and their parents. The state also used
subpart 2 funds to provide another family support program, which
provides similar services to the same types of children and families.
In addition, 17 states funded one or more individual services with
funds from both subparts, so that subparts 1 and 2 were serving the
same children and families.
Table 4: Number of States Using Funds from Each Subpart of Title IV-B
to Target Specific Populations:
Population type: Children in foster care or parents with children
living in foster care; Number of states providing services for this
population type with subpart 1 funds[A]: 20; Number of states providing
services for this population type with subpart 2 funds[A]: 29; Number
of states providing services for this population type with both subpart
1 and subpart 2 funds: 15.
Population type: Children at risk of child abuse or neglect and parents
with children at risk of child abuse and neglect; Number of states
providing services for this population type with subpart 1 funds[A]:
20; Number of states providing services for this population type with
subpart 2 funds[A]: 34; Number of states providing services for this
population type with both subpart 1 and subpart 2 funds: 20.
Population type: Children waiting for adoption, adopted children, and
adoptive parents; Number of states providing services for this
population type with subpart 1 funds[A]: 8; Number of states providing
services for this population type with subpart 2 funds[A]: 26; Number
of states providing services for this population type with both subpart
1 and subpart 2 funds: 5.
Population type: Foster parents; Number of states providing services
for this population type with subpart 1 funds[A]: 5; Number of states
providing services for this population type with subpart 2 funds[A]: 7;
Number of states providing services for this population type with both
subpart 1 and subpart 2 funds: 3.
Source: GAO survey.
Note: This analysis is based on survey responses from 35 states with
state-administered child welfare systems that provided population data
for their subpart 1 services and 39 states with state-administered
child welfare systems that provided population data for their subpart 2
services. Therefore, these data can only be generalized to states with
state-administered child welfare systems. Due to the differences in
information available from states with county-administered child
welfare systems, we did not request data in the first county-
administered survey on the types of children and families who received
services funded by Title IV-B--these data were to have been obtained on
the second survey.
[A] We did not collect data on the populations served for the category
of staff salaries. In addition, we excluded population data for the
category of administration and management expenses since these expenses
are not targeted to a particular population of children and families.
[End of table]
In our second survey, we requested more detailed information about the
populations served by programs funded by subparts 1 and 2, such as
demographic and socioeconomic characteristics. However, few of the 17
states responding to the second survey were able to provide this kind
of data. When asked about selected subpart 1 services, 10 of the 17
states were able to estimate the extent to which the same children and
families receiving the identified service funded by subpart 1 also
received services funded by subpart 2. Of children and families
receiving the identified subpart 1 service,
* four states reported that generally none or almost none of the
recipients also received a service funded by subpart 2,
* three states reported that generally less than half of the recipients
received subpart 2 services,
* one state reported that all or almost all recipients received subpart
2 services, and:
* two states provided varying estimates for different subpart 1
services.[Footnote 19]
While none of the states we visited were able to provide data about the
extent to which the same children and families were receiving services
funded by both subparts 1 and 2, state officials in each of these
states recognized some overlap among the types of populations
participating in these services. Officials in California and New Jersey
told us that they use subpart 1 for services to families that are
involved with the child welfare agency due to a report of abuse or
neglect, while services funded by subpart 2 target a broader
population, including families who are at risk of abusing their
children. However, while some of the subpart 2 programs these officials
described focused on this at risk population, many of them were
targeted to families who were already involved with the agency.
Officials at a California child welfare agency told us that all of the
services provided by subparts 1 and 2 are targeted toward the same
high-risk communities in which many people are involved with the
agency, and they considered it likely that families receiving subpart 1
services have also received subpart 2 services in the past or will at
some time in the future. Washington officials noted that children and
families involved with the child welfare agency may receive multiple
services, some of which may be funded by subpart 1 and some of which
may be funded by subpart 2. Finally, although Ohio does not track
clients served, one state official estimated that the types of children
and families served by the programs funded by subparts 1 and 2 overlap
by 100 percent.
One New Jersey state official described the services funded by subparts
1 and 2 as part of a continuum of child welfare services, such that
some population overlap is to be expected. In New Jersey, services
funded by subpart 1 target families who are experiencing difficulties
that may jeopardize the safety and well-being of their children.
Programs funded by subpart 2 may also serve these families. However,
they also target families who are not currently having difficulties,
but who could become involved with the child welfare agency in the
future. In addition, some subpart 2 programs serve adopted children,
many of whom were previously involved with the child welfare agency and
received services funded by subpart 1. None of the states we visited
could provide data on the numbers of children and families who
participated in services funded by subparts 1 and 2 dollars.
HHS Officials Believe Title IV-B Offers Flexibility While Targeting
Prevention Activities, and States Emphasize the Need for Flexibility:
Given the overlap observed between the two subparts, we discussed the
potential advantages and disadvantages of consolidation with HHS
regional officials and asked states for their perspective on our
survey. Officials in almost all of HHS's regional offices said that
Title IV-B should maintain its current balance between allowing states
some flexibility and targeting some resources toward prevention.
Officials in all regional offices told us that they believe states need
some flexibility to use Title IV-B funds to address state specific
child welfare needs as is currently the case under subpart 1. One
regional office noted that subpart 1 gives states the flexibility to
address unexpected circumstances affecting the child welfare system--
for example, by developing substance abuse treatment programs to
address the needs of parents affected by the cocaine epidemic of the
1980s. Similarly, officials in three states we visited felt strongly
that the flexibility to direct the use of subpart 1 funds for state
priorities was important and they would not want to lose this
flexibility in any consolidated program. Our survey results also
indicate that the flexibility to use subpart 1 to meet the needs of
their child welfare systems is important to states. For example, when
asked about their preference between subparts 1 and 2 with regard to
different program components, 24 and 26 states, respectively, reported
that they preferred subpart 1 when considering (1) spending
restrictions on the percentage of funds that can be used for specific
services and (2) allowable spending categories (see fig. 2). When asked
about the advantages and disadvantages of Title IV-B's current
structure, several states cited the spending restrictions of subpart 2
as a disadvantage, while a couple of states mentioned the flexibility
associated with subpart 1 as an advantage.
Figure 2: Survey Data on States' Preferences between Subparts 1 and 2
of Title IV-B for Different Program Components:
[See PDF for image]
Note: Data on state preferences are based on responses from 46 states,
although they did not all respond to each item.
[End of figure]
At the same time, officials in 8 of HHS's 10 regional offices also
stressed the importance of subpart 2 to ensure that states use some
funds on family support services and prevention activities to help
preserve families and keep children from entering foster care. Several
regional offices expressed concern that, in the absence of the minimum
spending requirements outlined in subpart 2, states would neglect
preventive services, while using Title IV-B funds for more urgent
services, such as CPS or foster care. One state we visited expressed
opposition to consolidation for this reason, arguing that keeping a
separate subpart 2 was important to ensure that states fund some
prevention services. State and county officials in this state noted
that subpart 2 represents an important federal investment in prevention
services and expressed concern that states would use all available
funds to provide services to families already involved with the child
welfare agency unless funds were specifically targeted for services to
support families at risk of abusing or neglecting their children. In
addition, on our survey, several states cited the prevention focus of
subpart 2 as an advantage of Title IV-B's current structure.
Officials in 8 of HHS's regional offices said that they believe that
the current structure of Title IV-B offers a good balance between
flexibility and targeting resources toward prevention.[Footnote 20]
Officials in the other 2 regional offices told us that Title IV-B
provides a good mix of flexibility and a focus on services considered
to be federal priorities. One regional office noted that a consolidated
Title IV-B program could be structured to offer this balance. For
example, a consolidated program could require some minimum spending
levels for the current subpart 2 categories, but also set aside some
funds that states could use for a broader array of child welfare
services. In addition, most of the regional offices did not believe
that consolidation would lead to any significant administrative
savings. For example, several regional offices explained that
consolidating the subparts would not reduce HHS's oversight
responsibilities, while another noted that consolidation would have
little impact on HHS regional or state offices, which are staffed and
organized to manage multiple sources of funding. Another regional
office noted that the planning and reporting requirements for the two
subparts are already consolidated in the planning documents states
submit to HHS.
State and local child welfare officials in one state, along with
officials at 2 HHS regional offices, commented that increasing the
funds available for service provision was more critical than
consolidating the two subparts. They believe that states need more
federal funds to provide services to prevent foster care placements,
such as an increase in funds available under Title IV-B or more
flexibility to use Title IV-E funds to provide services, rather than
paying primarily for foster care maintenance payments as it currently
does. Since 1994, states have been able to apply for demonstration
waivers to use federal child welfare funds to test innovative foster
care and adoption practices without regard to certain restrictions in
Titles IV-B and IV-E. For example, four states are using demonstration
waivers to create fixed Title IV-E budgets for counties within the
state in which funds can be used more flexibly for prevention and
community-based services not traditionally reimbursed by Title IV-E.
However, HHS's authority to approve such waivers is scheduled to expire
at the end of fiscal year 2003. States may soon have another mechanism
to use Title IV-E funds to provide preventive services through the
child welfare option HHS is currently proposing.
HHS Focuses Oversight on Overall Child Welfare System, but Has Limited
Knowledge about States' Use of Subpart 1 Funds:
HHS's oversight focuses primarily on states' overall child welfare
systems and outcomes, but the agency provides relatively little
oversight specific to subpart 1. For example, HHS regional offices work
with states to establish overall goals to improve the safety,
permanency, and well-being of children and measure progress toward
those goals. However, HHS has limited knowledge about how states use
their subpart 1 funds. HHS does not collect data on subpart 1
expenditures and instead requires states to submit annual estimates
about how they plan to use their subpart 1 funds in the upcoming year.
HHS regional offices reported that they review these estimates for
relatively limited purposes, with several HHS officials noting that
they do not review the spending plans for subpart 1 as closely as
subpart 2 because subpart 1 has few restrictions as to how these funds
can be used. We also found that HHS regional offices pay little
attention to statutory limits on the use of subpart 1 funds for foster
care maintenance and adoption assistance payments.[Footnote 21] As a
result, HHS approved projected 2002 spending plans for 15 states that
reported planned spending amounts that exceeded these spending limits.
In response to our survey, 10 states reported actual 2002 subpart 1
expenditures that exceeded the spending limits by over $15 million in
total.
HHS Focuses Much of Its Oversight on States' Overall Child Welfare
Systems and Outcomes:
HHS focuses much of its programmatic oversight on the overall child
welfare system in each state, rather than focusing specifically on
subpart 1 or any other federal funding source. In discussing their
oversight of subpart 1, several HHS officials at headquarters and in
the regional offices emphasized the importance of reviewing the overall
child welfare system and the outcomes achieved, rather than
scrutinizing individual programs outside of that context. A major
component of HHS's subpart 1 oversight is having the regional offices
actively work with states to develop appropriate goals for their child
welfare systems and ensure that available funds, including subpart 1,
are used to support those goals. To receive Title IV-B funding, HHS
requires states to submit a Child and Family Services Plan, which
covers a 5-year period and describes the state's goals and objectives
toward improving outcomes related to the safety, permanency, and well-
being of children and families. This 5-year plan includes a description
of services and programs the state will pursue to achieve these goals.
In addition to the 5-year plan, HHS requires states to submit an Annual
Progress and Services Report (APSR) each year to discuss their progress
in meeting the goals outlined in their plans and revise the goals as
necessary. Regional HHS staff review this planning document to ensure
that they meet all the technical requirements outlined in the annual
program instructions issued by HHS. For example, states must certify
that, in administering and conducting services under the 5-year plan,
the safety of the children to be served shall be of paramount concern.
In addition, some regional offices reported that they review the
state's objectives and goals to determine if they are reasonable,
assess the progress the state has made in achieving these goals and
objectives, and determine whether child welfare services are
coordinated with the efforts of other agencies serving children. Some
regional officials noted that states are still struggling to use these
documents appropriately for planning purposes. These officials told us
that instead of focusing on outcomes and collecting data to measure
progress toward those outcomes, frequently states simply describe their
current programs.
In addition to reviewing planning documents, all of the regional
offices consult regularly with states to discuss child welfare issues
and provide technical assistance.[Footnote 22] For example, the
regional office may provide guidance on how to comply with specific
program regulations or how to develop a 5-year plan that will function
as a strategic plan for the state's child welfare agency. Two regional
offices told us that they also conduct site visits to states as part of
their oversight. One regional office reported visiting states in its
region to gain a better understanding of each state's child welfare
services. This allows the regional office to share good ideas with
other states and to ensure that states are working on areas the
regional office has identified as in need of improvement. Other
regional offices reported that they would like to conduct site visits
to states under their purview, but a lack of travel funds prevented
them from doing so.
The CFSR process is an additional tool HHS uses to ensure that states
conform with federal child welfare requirements and to help states
improve their child welfare services. Staff at one regional office
described the CFSR as a thorough review of the services funded by
different federal programs, such as Title IV-B. They consider the CFSR
an important complement to a state's planning documents--it gives them
an opportunity to determine whether states are providing the services
they report in their planning documents and whether those services are
adequate and appropriate to meet the needs of the state's children and
families.
CFSR results for the past 2 years indicate that states have not
performed strongly in terms of assessing families to determine what
services they need and providing those services. While 21 of the 32
states that underwent a CFSR in 2001 or 2002 were considered to have an
appropriate array of services for families, HHS found that the
accessibility of services was a particular weakness in that many
services were either not available statewide or had long waiting lists
or other barriers to accessibility. When HHS reviewed case files,
however, it determined that 31 of these states needed improvement in
terms of assessing family needs and providing services to meet those
needs. When asked about HHS's role in guiding states' use of subpart 1
funds to address weaknesses identified by the CFSRs, an HHS official
told us that the agency provides technical assistance to states to help
them determine the most effective use of their resources. However, the
official also pointed out that HHS gives states a lot of latitude to
determine the most appropriate use of their subpart 1 funds and that
the agency cannot become too involved in state budget decisions given
the complexities of the budget processes for states.
HHS Has Little Information about States' Use of Subpart 1 Funds:
HHS has little information about states' use of subpart 1 funds. Each
year, HHS requires states to submit a form CFS-101, which includes
state estimates of the amount of subpart 1, subpart 2, and other
federal funds the state plans to spend in the upcoming year on
different categories of services (such as family support or CPS). The
descriptions provided by regional office staff of their review of these
estimates indicate that they review them for relatively limited
purposes. Officials in 4 of the regional offices told us that they
generally use the CFS-101 data to ensure that states request the total
amount of subpart 1 funds to which they are entitled and that they
comply with the requirement to match 25 percent of subpart 1 funds with
state funds. Most regional offices indicated that their reviews of the
CFS-101s focus more on subpart 2 than subpart 1. For example, they
reported that they review states' planned subpart 2 spending more
closely to ensure that states are meeting the requirement that they
spend at least 20 percent of funds on each of the service categories
and spend no more than 10 percent of funds for administrative purposes.
Several HHS officials reported that they do not monitor the use of
subpart 1 funds as closely as other federal child welfare funds due to
the relatively small funding amount and the lack of detailed
requirements about how the funds can be used.
Moreover, the CFS-101 estimates may not provide reliable data as to how
states are using subpart 1 funds. HHS officials explained that the CFS-
101 data are estimates and that states' actual expenditures may vary
from these estimates, as they address unforeseen circumstances. The
timing for submitting the CFS-101 also affects how well states can
estimate their planned subpart 1 spending. HHS requires states to
submit their initial CFS-101 for the upcoming fiscal year by June 30,
which forces states to estimate their planned spending before the final
spending amounts for Title IV-B and other federal funds have been
appropriated.[Footnote 23] Some regional officials indicated that they
did not know how well states' CFS-101 estimates reflect their actual
subpart 1 spending. We did not conduct a review of the reasonableness
of the data states submit on their CFS-101s, but we did identify a few
instances that suggested that the data are not always accurate. Two
states with county-administered child welfare systems told us that they
do not have reliable data to allow them to accurately estimate planned
spending.[Footnote 24] A child welfare official in one of these states
told us that its CFS-101 data represented its "best guess" as to how
subpart 1 funds will be used, because the state distributes these funds
to county child welfare agencies and does not collect any data on how
the counties use these funds. The other state told us that its current
CFS-101 data are most likely based on county data from several years
ago and that counties may now be spending subpart 1 funds on different
services.
HHS does not require states to provide any additional data about their
use of subpart 1 funds, such as their subpart 1 expenditures for
specific services.[Footnote 25] As a result, several regional offices
noted that they have no way of knowing how states actually spend their
subpart 1 funds. An official from one regional office explained that
the only way to determine how a state actually uses its Title IV-B
funds is to review its financial accounts, which HHS does not do. Some
regional officials suggested that it would be helpful to have actual
expenditure data for both Title IV-B subparts, especially to determine
if states were actually using 20 percent of their subpart 2 funds for
each of the four required service categories. Three regional offices
indicated that they have begun asking states to provide Title IV-B
expenditure data.
HHS Regional Offices Are Unaware of Subpart 1 Spending Limits or Do Not
Enforce Them:
Given that HHS's subpart 1 oversight focuses primarily on a state's
overall child welfare goals and outcomes, the regional offices pay
little attention to the statutory limits on the use of federal subpart
1 funds for foster care maintenance and adoption assistance payments.
Most HHS regional offices do not review the CFS-101s for compliance
with the statutory limits. In addition, HHS's annual program
instruction, which details what information states must include in
their CFS-101 submittals and serves as the basis for the regional
offices' review of subpart 1 spending, does not mention the subpart 1
limits.
Only 1 of HHS's 10 regional offices told us that it compares states'
planned subpart 1 spending reported on the CFS-101 with the actual
dollar limit for each state to ensure that states observe the statutory
limits. This office used an HHS program instruction for 1979 listing
each state's subpart 1 allocation to determine the ceiling on foster
care maintenance and adoption assistance payments.[Footnote 26] In
contrast, 5 regional offices were unaware that any limits on the use of
subpart 1 funds existed, although 1 of these offices indicated that it
generally did not consider it appropriate for states to use subpart 1
funds for foster care maintenance payments because subpart 1 should be
used to fund services for families. Nonetheless, this office approved a
CFS-101 for 1 state that exceeded the statutory limits. Four other
regional offices were aware that some limitations with regard to foster
care maintenance and adoption assistance payments existed, but did not
ensure that states complied with the limits.
These 4 regional offices provided several reasons for why they did not
monitor states' planned spending for compliance with the subpart 1
limits. Two regional offices indicated that HHS had provided no
guidance as to how such limits should be enforced or that no data were
available to calculate subpart 1 limits for each state. The third
regional office reported that it did not have the specific ceiling
amounts for each state. However, officials in this office said they
reviewed planned subpart 1 spending for foster care maintenance and
adoption assistance payments on the CFS-101 to determine if they had
increased from the previous year. If the amounts had not increased, the
regional office assumed that someone had checked the amounts previously
and that they were within the limits. This regional office approved
CFS-101s for 2 states in the region that reported planned subpart 1
spending for foster care maintenance and adoption assistance payments
in excess of the limits. The fourth regional office told us that, in
the past, it had a list of the maximum spending limits for each state
in its region and that it had previously checked states' CFS-101s to
ensure that planned spending did not exceed the limits. However, the
regional office no longer conducts such reviews; regional officials
said that they consider the limits to be meaningless because state
funds spent on child welfare services greatly exceed subpart 1 funds.
In other words, any attempt to enforce the limits would only lead to
changes in how states accounted for their funds--if a state was
spending $1 million in state funds on CPS investigations and $1 million
in subpart 1 funds for foster care maintenance and adoption assistance
payments, the state could simply switch state and subpart 1 funding so
that state funds paid for the foster care maintenance and adoption
assistance payments, while subpart 1 funding paid for CPS
investigations.
This lack of review led HHS to approve CFS-101s for 15 states that
reported fiscal year 2002 planned subpart 1 expenditures for foster
care maintenance and adoption assistance payments that exceeded the
statutory limits (see fig. 3).[Footnote 27] The dollar amounts by which
the subpart 1 spending estimates surpassed the limits were small in
some cases, but large in others. For example, Georgia reported that it
planned to spend $1,497,000 of subpart 1 funds for these purposes in
2002, which would exceed its statutory limit by $1,558. At the other
extreme, Florida's CFS-101 indicated that it planned to spend over $9
million, which was more than $7 million over the maximum allowable
spending of $1.9 million. In total, these 15 states submitted planned
subpart 1 spending estimates for foster care maintenance and adoption
assistance payments that would exceed the statutory limits by over $30
million. Moreover, 13 of these 15 states submitted fiscal year 2003
CFS-101s with planned subpart 1 spending above the statutory ceiling,
which were approved by HHS.
Figure 3: Fifteen States with Approved CFS-101s with Fiscal Year 2002
Subpart 1 Spending Estimates that Exceeded Limits for Foster Care
Maintenance and Adoption Assistance Payments:
[See PDF for image]
[End of figure]
Several regional offices noted that they judge the appropriateness of
subpart 1 spending on foster care maintenance and adoption assistance
payments in the context of a state's overall child welfare system. For
example, these regional offices said that they are not concerned about
a state planning to spend significant proportions of its subpart 1
funds on foster care maintenance and adoption assistance payments if
they believed the state had a strong child welfare system with an
appropriate array of services. Regional office staff said they would,
however, ask a state to reconsider its funding strategy if the state
were performing poorly. However, many of the states with approved CFS-
101 subpart 1 estimates above the statutory ceilings did not achieve
strong outcomes on their CFSR evaluations with regard to providing
needed services and having an appropriate array of services. HHS has
conducted CFSRs on 12 of the 15 states with approved CFS-101s over the
subpart 1 spending limits and determined that appropriately assessing
family needs and providing services to address those needs was an area
needing improvement in 11 of the 12 states. In addition, 6 of the 12
states were also determined to need improvement in terms of having an
appropriate array of services to meet the needs of families in the
state.[Footnote 28]
We also compared our survey data on states' fiscal year 2002 subpart 1
expenditures for foster care maintenance and adoption assistance
payments with the statutory limits and found that 10 states reported
spending subpart 1 funds on these payments that exceeded the legal
limits (see fig. 4). As with their planned spending estimates, states'
subpart 1 actual spending for foster care maintenance and adoption
assistance payments exceeded the statutory limits by varying amounts.
Michigan, for example, reported on our survey that it spent over $6
million on foster care maintenance payments in fiscal year 2002--well
over its $2.2 million limit for such payments--while New Hampshire's
use of subpart 1 for foster care maintenance and adoption assistance
payments was only about $27,000 above its limit. In total, these 10
states reported subpart 1 expenditures for foster care maintenance and
adoption assistance payments that exceeded the statutory limits by over
$15 million. Our survey results may underestimate the number of states
with subpart 1 spending over the statutory limits, because several
states reported on our survey that they used subpart 1 for foster care
maintenance or adoption assistance payments, but were not able to
identify the specific dollar amount of subpart 1 funds used for these
purposes.
Figure 4: Ten States That Reported Fiscal Year 2002 Subpart 1
Expenditures Exceeding Limits for Foster Care Maintenance and Adoption
Assistance Payments:
[See PDF for image]
[End of figure]
Four of these 10 states with subpart 1 expenditures over the statutory
limits were also part of the 15 states with CFS-101s that indicated
planned spending above the limits.[Footnote 29] The remaining 6 states
did not report estimated subpart 1 spending over these limits.[Footnote
30] For example, Colorado did not report any planned subpart 1 spending
for foster care maintenance or adoption assistance payments. On our
survey, however, the state reported using over $3 million in subpart 1
funds for these purposes, well over its $700,000 limit.
Some Unique Subpart 1 Service Categories Exist at the State Level, but
Little Research Exists on the Effectiveness of These Services:
Little research is available on the effectiveness of unique services
funded by subpart 1 because few states have evaluated these services.
While our survey data revealed no unique categories of services funded
by subpart 1 on a national level, 37 states reported categories of
services that were uniquely funded by subpart 1--that is, the
individual state used subpart 1, but not subpart 2, to fund services in
a particular category. For example, Delaware funded two CPS programs
with subpart 1--assessments of a caregiver's parenting ability and
legal services to represent the child welfare agency in court cases--
but did not use any subpart 2 funds for this service category. We
contacted the states with unique service categories in their states
(other than administration, staff salaries, adoption assistance
payments, or foster care maintenance payments) and none of these states
had conducted rigorous evaluations of these services, although several
states provided some data on the effectiveness of services included in
these categories. Our literature review on the effectiveness of child
welfare practices identified research for some of these unique service
categories, such as certain types of family preservation programs. With
two exceptions, however, it did not identify any evaluations of the
specific services included in these categories.
The most common service categories for which individual states used
only subpart 1 funds were CPS, foster care maintenance payments, and
staff salaries. The 37 states generally reported 1 or 2 unique
categories, with 14 states reporting 1 unique category and 1 state
reporting a high of 6 categories.[Footnote 31] Examples of unique
subpart 1 services in the CPS category include specialized
investigations of reports of child abuse or neglect, telephone hotlines
to report incidents of child abuse or neglect, and temporary shelter
services for children removed from their homes at times when no other
placement option is available, such as evenings and weekends. States
also provided other types of services that were funded uniquely by
subpart 1. For example, Minnesota provided intensive in-home services
to prevent children from being placed in foster care, North Carolina
contracted for legal services with the state's Attorney General's
office, and Maine helped adopted youth pay for post-secondary education
costs.
Our review of child welfare literature and Internet sites that
identified promising child welfare practices found few studies that
evaluated the effectiveness of the specific services that states funded
uniquely with subpart 1 funds. Based on the information provided on our
survey, we identified evaluation research on two of these services.
Texas used subpart 1 to fund its Home Instruction For Parents of
Preschool Youngsters (HIPPY) Program. The goal of HIPPY is to prevent
academic underachievement of children when they enter school. HIPPY
works with parents in their homes or in parent group meetings to
increase the degree and variety of literacy experiences in the home.
The program also seeks to prevent child abuse by enhancing parent-child
interactions and focuses on economically disadvantaged parents who may
not be involved in parenting programs. While Texas has not formally
evaluated this program, the model has been evaluated in other states.
Strengthening America's Families, a Web site about effective family
programs to prevent juvenile delinquency funded by the Office of
Juvenile Justice and Delinquency Prevention, cites HIPPY as a model
program for which evaluations have shown positive effects on children's
measured competence and classroom behavior at the end of second grade
for children who participated in HIPPY compared with children with no
formal preschool experience.[Footnote 32] In addition, a 1999 article
summarizing research on the HIPPY program found mixed results. For
example, an evaluation in New York found that children whose parents
participated in HIPPY in 1990 outperformed control group children on
measures of classroom adaptation and reading scores 1 year later, but
children whose parents participated in HIPPY in 1991 had similar
outcomes as children in the control group. The article suggested that
variability in how the program is implemented and in parental
commitment to the program may explain the mixed results.[Footnote 33]
Missouri funded an alternative response system with subpart 1 funds,
which offers assessment services (rather than an investigation) for
families that are the subject of a report of abuse or neglect when the
risk to the child is not considered high to determine if the family
needs services to reduce the risk of harm to the child. By responding
to low risk reports of abuse or neglect in a nonaccusatory manner, the
goal is to encourage families to collaborate in identifying their needs
and cooperate with supportive services. A 1998 evaluation of Missouri
counties testing the state's alternative response system found that the
safety of children was not compromised by the lack of an investigation
and that, compared to counties that were not using the alternative
response system, needed services were delivered more quickly,
subsequent reports of abuse or neglect decreased, and the cooperation
of families improved. An evaluation of Minnesota's alternative response
systems has also shown promising results. For example, initial results
from the randomized experimental evaluation showed an increase in the
use of community services with no increase in subsequent reports of
abuse or neglect.
Of the 37 states that reported unique subpart 1 service categories, we
asked the 22 states with unique subpart 1 service categories other than
foster care maintenance payments, adoption assistance payments, staff
salaries, or administration, whether they had evaluated the
effectiveness of the programs included in their unique categories. None
of these states had conducted rigorous evaluations of the effectiveness
of these services using randomly selected control groups.[Footnote 34]
One official explained that few states can afford to divert resources
from providing direct services to conducting formal evaluations of
programs, given the tremendous service needs of families involved with
the child welfare system.[Footnote 35]
However, 5 states provided some information on the outcomes of the
services they funded uniquely with subpart 1. North Dakota used subpart
1 dollars to uniquely fund a component of its family preservation
program--family focused services--which the state characterized as a
family reunification service. The state provided us with a draft
evaluation report of its family preservation program, which includes
this specific service. The family preservation program is intended for
families with children at risk of being placed in foster care and
offers a range of services, including parent aides who provide hands-on
parenting education and therapists who are available 24 hours a day to
work with the family in the home to address the issues that may result
in the children being removed from the home. The evaluation of its
total family preservation program found that families receiving
services and the social worker involved with the families both reported
improved family functioning upon completion of the services compared to
their functioning prior to the services. The study also found that
fewer children were at risk of being placed in foster care upon
completion of services. However, the evaluation did not include any
control group to determine if these results would have been achieved if
families had not received these services.[Footnote 36]
Massachusetts used some of its subpart 1 funds to pay for a contractor
to operate a telephone service for reports of child abuse or neglect
that are received in the evenings and on weekends. Officials from
Massachusetts provided an internal study conducted in February 2000
that discussed problems with this telephone service, most notably
limited staff and resources to handle an increasing volume of calls.
The report recommended several actions to improve the operation of the
telephone service, including an increase in staff to field telephone
calls, upgrading the telephone system so that fewer people receive a
busy signal, and increasing the number of beds available for emergency
placements in the evenings and on weekends. Arizona also funded its
child abuse telephone hotline uniquely with subpart 1 funds and
provided the following statistics. In fiscal year 2003, 69 percent of
calls to the hotline were answered without any wait. Of the calls that
were not answered directly, the average wait time was 3.5 minutes and
about 13 percent of calls were abandoned. In addition, quality
assurance staff reviewed over 17,000 calls for which it was determined
that the report did not meet the state's criteria for a CPS report
requiring investigation and changed only 15 of these to a CPS report.
Missouri funded several CPS services with subpart 1 funds, including
intensive in-home services for children at imminent risk of removal
from the home-and family-centered services for families for whom an
investigation determined services are needed to eliminate the risk of
harm to the child. Missouri provided two annual reports for fiscal year
2002 that provide some data on the outcomes of these services. Consumer
surveys indicated that many families found the intensive in-home
services useful, and the annual report on the intensive in-home
services indicated that 88 percent of at-risk children were still with
their families when services ended after approximately 6 weeks. In
addition, 79 percent of children who exited the program in 2001 were
still at home 1 year after services ended. With regard to family
centered services, the annual report indicated that over 70 percent of
families had achieved their goals at the time their case was closed.
Wisconsin used subpart 1 to fund a Youth Aids Program, in which the
state provides grants to counties to provide services to prevent the
placement of children in correctional facilities and other out-of-home
care. The state has not evaluated services provided by the counties,
but a 1995 report notes that in the first several years of operation,
this program produced major reductions in institutional placements and
helped encourage the development of community-based
resources.[Footnote 37] Over time, however, an increase in youth crime
has led to large increases in institutional and out-of-home care, so
that much of Youth Aids funding at the time was reported to be used for
out-of-home placements.
Conclusions:
Despite its relatively small funding level compared to other funding
sources for child welfare services, Title IV-B represents an important
federal commitment to providing supportive services to help preserve
and reunify families. The primary emphases of the two subparts vary
somewhat, but the range of services offered and the types of families
served overlap significantly. In part because of the relatively small
funding involved and the flexible nature of the funding, HHS does not
provide in-depth oversight specific to Title IV-B subpart 1. Instead,
HHS focuses much of its oversight efforts on states' progress toward
the overall goals of their child welfare systems and the outcomes
achieved by these systems. While this type of oversight is appropriate,
HHS could provide valuable assistance to states by obtaining more
concrete data about states' use of these funds and synthesizing these
data with CFSR data on states' outcomes with respect to properly
identifying the service needs of children and families and providing
needed services. Such analyses could allow HHS to develop information
on how investments in certain types of services correlate to improved
outcomes for children, which could be shared with states to help them
more effectively target their spending.
HHS could also use this enhanced knowledge of Title IV-B to help
develop an appropriate accountability strategy for its newly proposed
child welfare option. If enacted, the additional spending flexibility
proposed--given the size of the Title IV-E allocations that would
become available for spending on a variety of child welfare services--
could have a significant impact on a state's child welfare system.
Given the limited information available about the services funded with
subpart 1 and the effectiveness of these services, as well as HHS's
findings about the ability of states' to meet families' needs, ensuring
that states use this flexibility to provide effective services will be
critical to the success of this option. Opportunities also exist for
HHS to continue to encourage states to conduct evaluations of the
programs the states implement.
Recommendations:
We recommend that the Secretary of HHS provide the necessary guidance
to ensure that HHS regional offices monitor states' use of Title IV-B
subpart 1 funds for compliance with statutory restrictions on the use
of these funds. In addition, we recommend that the Secretary consider
the feasibility of collecting basic data on states' use of these funds
to facilitate its oversight of the program and to provide guidance to
help states determine appropriate services to fund. For example, an
analysis of how states' spending patterns correlate to outcomes--both
positive and negative--from the CFSRs could yield useful information
for this purpose.
Given that HHS is currently developing the new child welfare option
that would allow states to use Title IV-E dollars for services similar
to those provided under Title IV-B subpart 1, we further recommend that
the Secretary use the information gained through enhanced oversight of
subpart 1--as well as information it may have on states' use of subpart
2 funds--to inform its design of this option. For example, HHS could
use this information to help states determine the most appropriate
services to provide under this option.
Agency Comments:
We provided a draft of this report to HHS for comment. The Department's
Administration for Children and Families provided comments. These
comments are reproduced in appendix II. ACF also provided technical
clarifications, which we incorporated when appropriate.
ACF agreed with our recommendation that the Secretary of HHS provide
the necessary guidance to ensure that HHS regional offices monitor
states' use of Title IV-B subpart 1 funds for compliance with statutory
restrictions on the use of these funds. ACF agreed to provide guidance
to the regional offices to enable them to enforce the statutory limits
on subpart 1 funds. However, ACF also noted that this limitation no
longer serves a useful purpose and is incompatible with the current
proposal to offer states much more flexibility in using other federal
child welfare dollars. ACF said that it plans to explore ways to
provide states flexibility with respect to the subpart 1 limits.
ACF disagreed with our recommendation to consider the feasibility of
collecting basic data on states' use of subpart 1 funds. ACF said that
it believes that its level of oversight is commensurate with the scope
and intent of the program and minimizes states' reporting requirements.
Rather than using information on Title IV-B expenditures to help states
most effectively use their resources, ACF believes that its oversight
is more appropriately focused on the CFSR process, which requires
states to develop actions in response to weaknesses identified by the
CFSR and which measures the impact of these actions on actual outcomes.
In ACF's opinion, analyzing how states' spending patterns correlate to
CFSR results is not useful, given the lack of a direct relationship
between the relatively small Title IV-B funding levels and the broad
outcome areas of safety, permanency, and well-being. In addition, ACF
noted that any data collected on subpart 1 expenditures would be
outdated because states have 2 years to spend Title IV-B expenditures
and are not required to report final expenditures until 90 days after
the 2-year period has ended.
We believe, however, that assessing the feasibility of collecting some
basic data on states' subpart 1 expenditures could enhance ACF's
overall oversight of states' child welfare operations and outcomes.
While the impact of states' program improvement efforts under the CFSR
process is unknown because states are just getting these efforts
underway, the service deficiencies identified by the CFSRs suggest that
states could benefit from some guidance on the services that are
associated with positive CFSR outcomes. An analysis of how states'
spending patterns correlate to CFSR outcomes need not be limited to
subpart 1 spending; such an analysis could help to identify effective
services (regardless of funding source) that are associated with
positive CFSR outcomes and help states target their subpart 1 and other
funding sources more effectively. Furthermore, we do not believe that
2-year old data on subpart 1 expenditures are necessarily outdated;
rather, we believe such data would provide better information on
states' use of subpart 1 funds than states' current estimates of
planned spending. In addition, ACF could request expenditure data for a
shorter period, such as a year or a quarter or whatever time period
best fits states' other reporting requirements.
ACF did not comment on our recommendation that it use the information
gained through enhanced oversight to inform its design of its child
welfare option. However, we believe that guidance on services
associated with positive CFSR outcomes could also help states that
choose to participate in the proposed child welfare option to manage
their fixed Title IV-E funding. ACF also commented on our finding that
the services provided and families served under subparts 1 and 2
overlap to some extent. Specifically, ACF noted that by not permitting
the funds, services, and families to overlap, ACF would significantly
impede the functionality of the continuum of child welfare services
funded by Title IV-B and other federal funding streams and possibly
lead to families not receiving needed services. While we described the
overlap in services provided and families served, we did not state or
imply that such overlap was inappropriate or unnecessary.
We also provided a draft of this report to child welfare officials in
the 4 states we visited (California, New Jersey, Ohio, and Washington).
Officials from California and Washington provided a few technical
clarifications that we incorporated, while New Jersey and Ohio did not
have any comments. In addition, Washington expressed concern that our
recommendations for HHS to (1) ensure that the regional offices monitor
states' use of subpart 1 funds for compliance with the statutory limits
and (2) consider collecting data on states' use of these funds will add
to the reporting burden of states without providing additional funds to
offset that burden. We recommended that HHS consider the feasibility of
collecting such data and would expect HHS to take into account the
burden placed on states in making this decision.
We are sending copies of this report to the Secretary of HHS,
appropriate congressional committees, state child welfare directors,
selected county child welfare directors, and other interested parties.
We will also make copies available to others upon request. In addition,
the report will be available at no charge on GAO's Web site at http://
www.gao.gov.
If you have any questions, or wish to discuss this report further,
please call me at (202) 512-8403 or Diana Pietrowiak at (202) 512-6239.
Key contributors to this report are listed in appendix III.
Sincerely yours,
Cornelia M. Ashby
Director, Education, Workforce, and Income Security Issues:
Signed by Cornelia M. Ashby:
[End of section]
Appendix I: Scope and Methodology:
To determine how the services provided and populations served under
subpart 1 compare with those under subpart 2, we surveyed child welfare
directors in all 50 states and the District of Columbia. We sent a
survey to all states to obtain information on how they use Title IV-B
funds. We also sent a second survey to certain states that responded to
the first survey. We pretested both survey instruments in New
Hampshire, Rhode Island, and Wisconsin and obtained input from several
other states and from a Department of Health and Human Services (HHS)
official. In January 2003, we mailed a copy of the first survey to the
states, asking for specific data on state spending and populations
served for subparts 1 and 2, as well as their opinions about the
current structure of Title IV-B. To address differences in the
administrative structure and reporting systems of state child welfare
agencies, a different version of this survey was sent to states with
county-administered child welfare systems.[Footnote 38] We received
responses from 47 states, although some states were unable to provide
complete information.[Footnote 39] To encourage as many states as
possible to complete the survey, we conducted follow-up telephone calls
to states that did not respond to our survey by the initial deadline.
After a state responded to the first survey, we mailed the second
survey, requesting more detailed information on the three services
receiving the largest portions of subpart 1 funding and the three
services receiving the largest portions of subpart 2 funding. The
second survey also asked for copies of any existing evaluations of the
effectiveness of these services. We sent the second survey to the 30
states that provided sufficient data on their first survey by mid-April
2003 and received responses from 17 states.[Footnote 40]
We did not independently verify the information obtained through either
survey. The responses of the 47 states to the first survey can be used
to explain how the 50 states and the District of Columbia in general
used Title IV-B funds. Since we received responses from only 17 states
for our second survey, they may not be representative of all states.
Consequently, we have used these data only as examples or for
illustrative purposes. As a result, we based our analyses of the
populations of children and families served on data from our first
survey. However, states that completed the county-administered version
of the survey did not provide data on the types of children and
families who received services funded by Title IV-B and were not
included in these analyses. As a result, the data on populations served
by subparts 1 and 2 cannot be generalized to states with county-
administered child welfare systems.
Data from both surveys were double-keyed to ensure data entry accuracy,
and the information was analyzed using statistical software. On the
first survey, we asked states to describe the nature of each service
and select one service category that best characterized each program
funded by Title IV-B, using the following choices: child protective
services (CPS), family support/prevention programs, parent training
programs, health programs, educational programs, substance abuse
programs, counseling and mental health services, domestic violence
programs, formal family preservation programs, family reunification
programs, recruitment and training for foster/adoptive parents,
adoption preservation services, administration and management, foster
care maintenance payments, adoption subsidy payments, and other.
The data were analyzed using states' self-identified categories except
in the following situations: (1) if a state clearly described a program
as funding salaries for staff at the child welfare agency, we included
these data under the staff category; (2) if a state used the "other"
category for a service that clearly fell into one of the existing
categories (writing in "foster care maintenance payments," for
example), we revised the survey response to reflect the actual
category; (3) if it appeared that a state mistakenly checked the wrong
box; for example, we changed the category from CPS to family
reunification if the program was described as a family reunification
service; (4) if a state checked multiple categories, we reported these
programs separately under "multiple responses;" (5) if a state did not
check any categories, we selected a service category that best fit the
description of the program and used "other" if the description did not
clearly fall into one of our categories; and finally (6) if a state
clearly described the use of Title IV-B funds as administrative, but
categorized it in another category, we revised the survey to indicate
that the funds were used for administration and management. Some states
explained that Title IV-B funds were used to cover administrative
expenses for a particular program and characterized the use of these
funds based on the nature of the program. For example, a state might
have selected family preservation program when Title IV-B funds were
used for administrative expenses for that program.
As noted earlier in the report, we recognize that some states may not
have separately identified administration or management expenses
associated with a program and may have included these expenses in the
program costs. For reporting purposes, we combined several service
categories for which states reported spending small percentages of
Title IV-B funds, such as parent training and substance abuse services,
and reported these dollars in the "other" category.
We recognize that the service categories used are not necessarily
mutually exclusive. For example, several HHS officials told us that the
delineation between family support and family preservation services is
not clear, so that 2 states providing the same services to the same
types of children and families may report them in different categories.
In addition, because the survey for states with state-administered
child welfare systems asked them to choose one service category for
each program, the reported service categories may not fully capture all
relevant programs that fall into more than one service category.
Inconsistencies in how states categorized services could have an effect
on any measured differences between service categories.
To obtain more in-depth information on the services provided and the
types of children and families served under Title IV-B, we conducted
site visits in California, New Jersey, Ohio, and Washington. We
selected these states to represent a range of geographic locations and
subpart 1 spending patterns. In addition, because preliminary data
indicated that significant subpart 1 funds were devoted to CPS, we
selected states that used innovative CPS tools or processes. However,
the experiences of these states are not necessarily representative of
the experiences of any other state. During these site visits, we
interviewed state and local child welfare officials and service
providers and reviewed relevant documentation.
To learn about the federal government's role in overseeing subpart 1,
we reviewed applicable laws and regulations and interviewed HHS central
office officials. We also conducted interviews with HHS officials in
all 10 HHS regional offices to discuss their oversight activities and
reviewed results from HHS's CFSR reports. In addition, we reviewed
states' CFS-101s for fiscal year 2002 and compared states' planned
subpart 1 spending for foster care maintenance, adoption assistance,
and child care payments with states' final subpart 1 allocations for
fiscal year 1979 as reported on an HHS program instruction from that
year. States are required to submit the CFS-101 by June 30 of the
preceding year--June 30, 2001, for fiscal year 2002. At that time,
federal appropriations for Title IV-B and other federal child welfare
funds often are not yet finalized, so states base their estimates on
the previous year's allocation. States must submit a revised CFS-101 by
June 30, 2002, to request any additional fiscal year 2002 Title IV-B
funds that might be available to them once appropriations are
finalized. In addition, states can request additional Title IV-B funds
if other states do not use the total funds to which they are entitled.
In most cases, we reviewed the final revised CFS-101s approved by HHS.
For one state, we used the initial CFS-101 approved by HHS because it
included planned subpart 1 expenditures that exceeded the limits for
foster care maintenance and adoption assistance payments, but the
revised CFS-101 did not. Although the revised CFS-101 did not show the
state planned to exceed the limit, we used the initial CFS-101 to show
that HHS had previously approved a spending plan that did not comply
with the statutory limits.
We used our survey results to identify services unique to subpart 1--
that is, categories of services funded by subpart 1 that are not funded
by subpart 2. While no category of service was unique to subpart 1 at
the national level, some states funded unique categories of services
within their state with subpart 1. In our second survey, we asked
states to provide a copy of any evaluations they had conducted of the
three largest services funded by subpart 1. If we did not have survey
data for one of the identified services, either because we did not send
a second survey to the state or because the second survey did not ask
for data on the particular service, we contacted the state directly to
ask if any evaluation had been conducted.
In addition, to identify other evaluations on the effectiveness of the
services in these unique categories, we conducted a literature review
and interviewed child welfare research experts. The reports and
Internet sites we reviewed included the following:
* Strengthening America's Families: Effective Family Programs for the
Prevention of Delinquency (http://www.strengtheningfamilies.org/html/
programs_1999/programs_list_1999.html).
* Child Welfare League of America's Research to Practice Initiative
(http://www.cwla.org/programs/r2p/).
* Casey Family Programs: Promising Approaches to Working with Youth and
Families (http://www.casey.org/whatworks/).
* Promising Practices Network on Children, Families, and Communities
(http://www.promisingpractices.net/).
* U. S. Department of Health and Human Services, "Emerging Practices In
the Prevention of Child Abuse and Neglect" (Washington, D.C.: n.d.).
We conducted our work between August 2002 and July 2003 in accordance
with generally accepted government auditing standards.
[End of section]
Appendix II: Comments from the Department of Health and Human
Services:
DEPARTMENT OF HEALTH & HUMAN SERVICES:
ADMINISTRATION FOR CHILDREN AND FAMILIES Office of the Assistant
Secretary, Suite 600:
370 L'Enfant Promenade, S.W. Washington, D.C. 20447:
DATE: AUG 21 2003
TO: Cornelia M. Ashby:
Director, Education, Workforce, and Income Security Issues General
Accounting Office:
FROM:
Wade F. Horn, Ph.D. Assistant Secretary for Children and Families:
SUBJECT: Comments on the GAO Draft Report, "Child Welfare: Enhanced
Federal Oversight of Title IV-B Could Provide States Additional
Information to Improve Services," (GAO-03-956):
Attached are the Administration for Children and Families' comments on
the GAO Draft Report, "Child Welfare: Enhanced Federal Oversight of
Title IV-B Could Provide States Additional Information to Improve
Services,"( GAO-03-956).
Should you have questions regarding our comments, please contact Susan
Orr, Associate Commissioner of the Children's Bureau, Administration on
Children, Youth and Families, at (202) 205-8618.
Attachment:
COMMENTS OF THE ADMINISTRATION FOR CHILDREN AND FAMILIES (ACF) ON THE
GENERAL ACCOUNTING OFFICE'S DRAFT REPORT, "CHILD WELFARE: ENHANCED
FEDERAL OVERSIGHT OF TITLE IV-B COULD PROVIDE STATES ADDITIONAL
INFORMATION TO IMPROVE SERVICES," GAO-03-956:
The Administration for Children and Families (ACF) appreciates the
opportunity to comment on the General Accounting Office's (GAO) draft
report.
GAO Recommendations:
GAO recommends that HHS provide the necessary guidance to ensure that
HHS regional offices monitor states' use of Title IV-B subpart 1 funds
for compliance with statutory restrictions on the use of these funds.
In addition, GAO recommends that HHS consider the feasibility of
collecting basic data on states' use of these funds to facilitate its
oversight of the program and to provide guidance to help states
determine appropriate services to fund. For example, an analysis of how
states' spending patterns correlate to outcomes - both positive and
negative - from the Child and Family Services Reviews (CFSRs) could
yield useful information for this purpose.
Given that HHS is currently developing a new child welfare option that
would allow states to use Title IV-E dollars for services similar to
those provided under Title IV-B subpart 1, GAO further recommends that
HHS use the information gained through enhanced oversight of subpart 1
- as well as information it may have on states' use of subpart 2 funds
- to inform its design of this option. For example, HHS could use this
information to help states determine the most appropriate services to
provide under this option.
ACF Comments:
In response to the GAO recommendation that HHS (1) provide the
necessary guidance to ensure that HHS regional offices are providing
appropriate oversight of subpart 1, ACF agrees to provide guidance to
the regional offices to enable them to enforce the statutory
limitations on Title IV-B funds. However, as GAO notes in its report,
this Administration has proposed a legislative change to provide
unprecedented flexibility in the use of Title IV-E foster care dollars.
Furthermore, when Congress restricted the amount of Title IV-B funds
that could be spent on foster care maintenance and adoption assistance
payments, it did so at the 1979 appropriation level of $56.5 million.
The FY 2003 appropriation of slightly over $290 million represents a
five-fold increase in funds since 1979, thereby
reducing to approximately 20 percent the amount of these funds that
states may spend on foster care maintenance payments, adoption
assistance payments and for child care under Title IV-B, subpart 1.
(This does not take into account the impact of inflation on the
statutory limit of $56.5 million over the past 24 years or on states'
foster care rates.) ACF questions whether this outdated limitation
serves a state's need for flexibility in funding Child Welfare Services
and does not believe that currently there is a useful purpose for this
restriction. ACF intends, therefore, to explore avenues to provide
states flexibility with respect to this provision.
Our level of oversight for the use of Title IV-B funds is commensurate
with the scope and intent of the program. ACF disagrees with the
recommendation that we collect data on subpart 1 to help states
determine appropriate services to fund.
In response to the GAO recommendation that HHS (2) consider the
feasibility of collecting basic data on states' use of these funds to
facilitate program oversight and to provide guidance to help states
determine appropriate services to fund, when ACF developed the
regulations and guidance to implement Title IV-B, ACF considered the
feasibility of asking states to provide us with actual expenditures
rather than estimates. ACF decided to ask for estimates to reduce state
information collection requirements. In addition, there is a two-year
expenditure period under Title IV-B, which means states would not have
to report final expenditures until 90 days after the two-year period
had ended, at which point the information is too outdated to be useful.
ACF sees no reason to mandate states to report information that is not
required in statute.
The GAO recommendations are based on the premise that states need help
in determining how to best use their Title IV-B funds, and that there
are ample funds for all services needed in the State. The report seems
to conclude that Federal help will resolve the issues raised in the
CFSRs as they relate to the lack of family assessments and services.
Our attention to outcomes in the CFSRs is the appropriate mechanism for
meeting our stewardship responsibilities for Title IV-B programs. ACF
implements this approach through the Program Improvement Plan (PIP)
process, which requires states to identify actions they will take to
remedy weaknesses identified as a result of the CFSR. This process is
already in place and includes the regulatory requirement at 45 CFR
1355.35(f) to integrate the PIP with the State's Child and Family
Services Plan. Use of funds and resources committed to achieving the
identified outcomes are factored into the PIP process. Overall, we do
not see how actual expenditure information or additional data will help
improve the outcomes in the CFSRs since we already collect ample
information through that process.
The recommendation that "an analysis of how states' spending patterns
correlate to outcomes from the CFSRs" is unrealistic given the lack of
direct relationship of Title IV-B funding to the broad outcome areas of
safety, permanency and well-being that are influenced by the unique
blend of services funded by a variety of sources that states use to
meet the needs of families. The CFSR does review many of the major
requirements of Title IV-B subparts 1 and 2 from a systemic view;
however it does not necessarily review case level outcome information
based on services allocated to these programs.
The issues attributed to findings from the CFSRs such as lack of
services available statewide, long waiting lists and improvement needed
in assessing needs and providing services to meet those needs would
generally have very little direct relationship to Title IV-B funding.
Because Title IV-B funding represents such a small percentage of
potential funding available to states compared to Medicaid and other
Federal, state, and local funding streams, it would be a leap to
associate the CFSR findings to Title IV-B oversight issues. The PIP
process is a far more comprehensive process to address issues such as
those outlined above because it involves and commits stakeholders to
activities that directly impact the outcomes rather than simply one
agency and funding stream.
The GAO report points out the overlap with respect to services provided
and families served, as the statutory purposes of both programs are
very similar and are meant for the same type of children and families.
Also, as noted, because of overlapping categories for services (i.e.,
some family preservation services could also be considered family
support services, or many time-limited reunification services may also
be claimed as family preservation or support services) and the
different categorical program definitions by different states, ACF
cannot know specifically how much of one service versus another is
being provided. However, both subparts under Title IV-B, along with the
Child Abuse Prevention and Treatment Act, Title IV-E, and Title XX,
fund a continuum of care in child welfare. By not permitting the funds,
services, and families to overlap, we would significantly impede the
functionality of the continuum, thereby creating potential situations
where families would not receive the necessary services.
[End of section]
Appendix III: GAO Contacts and Acknowledgments:
GAO Contacts:
Diana Pietrowiak (202) 512-6239 Michelle St. Pierre (617) 788-0558:
Acknowledgments:
In addition to those named above, Melissa Mink and J. Bryan Rasmussen
made key contributions to the report. Anne Rhodes-Kline, Alison Martin,
Luann Moy, and George Quinn, Jr., provided key technical assistance.
[End of section]
Related GAO Products:
Child Welfare: Most States Are Developing Statewide Information
Systems, but the Reliability of Child Welfare Data Could be Improved.
GAO-03-809. Washington, D.C.: July 31, 2003.
D.C. Child and Family Services: Key Issues Affecting the Management of
Its Foster Care Cases. GAO-03-758T. Washington, D.C.: May 16, 2003.
Child Welfare and Juvenile Justice: Federal Agencies Could Play a
Stronger Role in Helping States Reduce the Number of Children Placed
Solely to Obtain Mental Health Services. GAO-03-397. Washington, D.C.:
April 21, 2003.
Foster Care: States Focusing on Finding Permanent Homes for Children,
but Long-Standing Barriers Remain. GAO-03-626T. Washington, D.C.: April
8, 2003.
Child Welfare: HHS Could Play a Greater Role in Helping Child Welfare
Agencies Recruit and Retain Staff. GAO-03-357. Washington, D.C.: March
31, 2003.
Foster Care: Recent Legislation Helps States Focus on Finding Permanent
Homes for Children, but Long-Standing Barriers Remain. GAO-02-585.
Washington, D.C.: June 28, 2002.
District of Columbia Child Welfare: Long-Term Challenges to Ensuring
Children's Well-Being. GAO-01-191. Washington, D.C.: December 29, 2000.
Foster Care: HHS Should Ensure That Juvenile Justice Placements Are
Reviewed. GAO/HEHS-00-42. Washington, D.C.: June 9, 2000.
Juvenile Courts: Reforms Aim to Better Serve Maltreated Children. GAO/
HEHS-99-13. Washington, D.C.: January 11, 2000.
Foster Care: States' Early Experiences Implementing the Adoption and
Safe Families Act. GAO/HEHS-00-1. Washington, D.C.: December 22, 1999.
Foster Care: HHS Could Better Facilitate the Interjurisdictional
Adoption Process. GAO/HEHS-00-12. Washington, D.C.: November 19, 1999.
Foster Care: Effectiveness of Independent Living Services Unknown. GAO/
HEHS-00-13. Washington, D.C.: November 5, 1999.
Child Welfare: States' Progress in Implementing Family Preservation and
Support Services. GAO/HEHS-97-34. Washington, D.C.: February 18, 1997.
Child Welfare: Opportunities to Further Enhance Family Preservation and
Support Activities. GAO/HEHS-95-112. Washington, D.C.: June 15, 1995.
FOOTNOTES
[1] Child protective services activities typically include reviewing
reports of alleged child abuse and neglect, investigating those that
meet the state's criteria as a potential incident of abuse or neglect
to determine if the alleged incident occurred, and, in some cases,
referring families to needed services and removing the child from the
home, if necessary.
[2] States are required to provide matching funds in order to receive
federal Title IV-B dollars.
[3] Adoption assistance payments are provided to parents adopting a
child with special needs, such as a physical or mental disability, to
assist with the costs of services required to meet the child's needs.
The subpart 1 limits also apply to child care services to support a
parent's employment or training.
[4] This report focuses primarily on subpart 1 because little, if any,
research has been conducted on how subpart 1 funds have been spent on
child welfare services. In contrast, a number of studies have been
conducted on the services provided under subpart 2.
[5] We did not receive responses from the District of Columbia,
Indiana, Kentucky, or Montana.
[6] The statutory limit also includes payments for child care services
required due to a parent's employment or training needs. However, only
2 states reported any planned subpart 1 spending on this type of child
care service for fiscal year 2002. For this report, we mention only
foster care maintenance and adoption assistance payments when referring
to subpart 1 limits, although we did include planned spending on child
care in our analyses of states' planned subpart 1 spending.
[7] Urban Institute, The Cost of Protecting Vulnerable Children III:
What Factors Affect States' Fiscal Decisions? (Washington, D.C.: n.d.).
[8] In fiscal year 2002, total Title IV-E spending was approximately
$6.1 billion. The state matching rate for these payments is based on a
state's per capita income and ranges from 50 percent to 83 percent.
[9] States are entitled to Title IV-E reimbursement on behalf of
children who would have been eligible for Aid to Families with
Dependent Children (AFDC) (as AFCD existed on July 16, 1996), but for
the fact that they were removed from the home of certain specified
relatives. While the AFDC program was replaced by the Temporary
Assistance for Needy Families program in 1996, eligibility for Title
IV-E payments remains tied to the income eligibility requirements of
the now defunct AFDC program. In addition, certain judicial findings
must be present for the child, and all other requirements included in
section 472 (a) and (b) of the Social Security Act must be met, in
order for the child to be eligible for Title IV-E foster care
maintenance payments.
[10] Special needs are characteristics that can make it difficult for a
child to be adopted and may include emotional, physical, or mental
disabilities, emotional disturbance, age, or being a member of a
minority race. To qualify for an adoption subsidy under Title IV-E, a
state must determine that the child cannot or should not return home; a
state must make a reasonable, but unsuccessful effort to place the
child without the subsidy; and a specific factor or condition must
exist that makes it difficult to place the child without a subsidy.
[11] Foster care maintenance payments funded by Title IV-B would
require 25 percent in matching state funds.
[12] Staff of the House Committee on Ways and Means, 106th Congress,
Background Material and Data on Programs Within the Jurisdiction of the
Committee on Ways and Means (Comm. Print 2000).
[13] Some subpart 2 funds are reserved for specific activities. For
example, $10 million in mandatory funds and 3.3 percent of
discretionary funds in each fiscal year are reserved for grants to
state courts to improve child welfare proceedings. In addition, 1
percent of mandatory funds and 2 percent of discretionary funds are
reserved for grants to Indian tribes.
[14] Staff of the House Committee on Ways and Means, 106th Congress,
Background Material and Data on Programs Within the Jurisdiction of the
Committee on Ways and Means (Comm. Print 2000).
[15] The adoption promotion and support services category includes the
recruitment and training of foster and adoptive parents, adoption
support services, and adoption preservation services.
[16] Although no unique service categories are funded exclusively by
either subpart at the national level, states did report individual
service categories that were funded by subpart 1, but not subpart 2.
However, no national trend emerged among the types of services that
were funded uniquely by subpart 1.
[17] The survey data reported in this category reflect the salaries of
staff affiliated with the child welfare agency. These figures do not
include the salaries of child welfare agency staff dedicated to a
specific program, which may be embedded within some of the other direct
service categories, such as family support and family preservation. In
addition, a state may use Title IV-B funds to contract with an
organization to provide a particular program, which may include salary
expenses as well as direct service expenditures.
[18] This amount may be underestimated, since some states may not have
separately reported administrative expenses associated with a specific
program. For example, officials in one state reported that the total
spending for a family support program included salaries for agency
staff, overhead expenses, and related staff travel.
[19] The second survey requested information about the three services
receiving the largest portions of subpart 1 funding, so states
generally only estimated the extent to which recipients of these
services also received services funded by subpart 2. These data are not
necessarily representative of other subpart 1 services or other states.
[20] Several officials noted that allowing a little more flexibility
with the 20 percent spending requirement for subpart 2 could provide
some additional flexibility to states without having to seek approval
from HHS. For example, staff in one regional office suggested that
requiring states to spend no less than 10 percent and no more than 40
percent of subpart 2 funds in any service category would offer this
additional flexibility.
[21] The statutory limit also includes payments for child care services
required due to a parent's employment or training needs. However, only
two states reported any planned subpart 1 spending on this type of
child care service for fiscal year 2002. For the purposes of this
report, we mention only foster care maintenance and adoption assistance
payments when referring to subpart 1 limits, although we did include
planned spending on child care in our analyses of states' planned
subpart 1 spending.
[22] In addition, HHS funds eight national resource centers to
disseminate information on best practices and provide technical
assistance to help states implement federal legislation intended to
ensure the safety, permanent placement, and well-being of children who
enter the child welfare system.
[23] For example, the CFS-101 for fiscal year 2002 was due by June 30,
2001. Because they are submitted before final appropriations have been
enacted, a state might not request the full amount of funds to which it
is entitled, if the final appropriation is greater than the state's
initial estimate. States must submit a revised CFS-101 by June 30,
2002, to request any additional fiscal year 2002 Title IV-B funds that
might be available to them once appropriations are finalized. In
addition, states can request additional Title IV-B funds if other
states do not use the total funds to which they are entitled.
[24] While most states administer their child welfare systems at the
state level, a handful of states delegate administrative responsibility
and substantial control to counties or other local entities. Several
large states, such as California, New York, Ohio, and Pennsylvania, are
county-administered.
[25] States are required to submit general reports on their total
subpart 1 expenditures, but these provide no data on how the funds are
actually used. Per instructions from the Office of Management and
Budget, agencies must require states receiving federal grants to
complete a financial status report (SF 269), providing general
information on state expenditures. For example, the form might indicate
that a state spent $10 million in subpart 1 funds in a specific fiscal
quarter, but it provides no details on how the $10 million was used.
[26] Each state's ceiling on the use of subpart 1 funds for foster care
maintenance and adoption assistance payments is based on its total 1979
subpart 1 expenditures for all types of services.
[27] In most cases, we reviewed the final revised CFS-101 approved by
HHS. For 1 state, however, we used the initial CFS-101 approved by HHS
because it included planned subpart 1 expenditures that exceeded the
limits for foster care and adoption assistance payments. Although the
revised CFS-101 did not show that the state planned to exceed the
limit, we used the initial CFS-101 to show that HHS had previously
approved a spending plan that did not comply with the statutory limits.
In addition, we were unable to determine whether the planned fiscal
year 2002 subpart 1 spending for 5 other states exceeded the limits
because HHS approved their CFS-101s with flawed data. These 5 states--
Iowa, Nevada, New Hampshire, New Jersey, and New Mexico--all reported
planned subpart 1 spending for foster care maintenance and adoption
assistance payments in excess of the statutory limits. However,
although states are supposed to separately estimate planned spending
for the federal portion of their subpart 1 funds on the CFS-101, these
5 states included the state match and/or other funds in their
estimates. In these cases, we could not determine whether the spending
plans exceeded the statutory limits for federal subpart 1 funds. States
are allowed to use all of their state matching funds for foster care
maintenance or adoption assistance payments.
[28] Nine of the 12 states were also cited as needing improvement in
ensuring that needed services are accessible to families in all areas
of the state and 8 of the 12 states were categorized as needing
improvement in terms of individualizing services to meet the unique
needs of individual families.
[29] Of the 15 states with planned spending above the limits, 8
reported subpart 1 expenditures within the statutory limits, 4 reported
subpart 1 expenditures above the limits, and 3 did not separately
identify foster care maintenance and adoption assistance payments on
their surveys.
[30] Four of the 6 states included state matching funds in their CFS-
101 estimates, so we could not determine whether the spending plans for
those states exceeded the statutory limits.
[31] Virginia did not provide any data on its subpart 2 spending, so we
were not able to determine whether the state uniquely funded any
service categories with subpart 1. New York does not receive any
subpart 2 funds, so we considered all services funded by subpart 1 to
be unique.
[32] See http://www.strengtheningfamilies.org/html/programs_1999/
22_HIPPY.html.
[33] The Future of Children, "The Home Instruction Program for
Preschool Youngsters (HIPPY)" (Los Altos, CA: Spring/Summer 1999).
[34] While few states had evaluated their unique subpart 1 services, 4
of the 17 states responding to our second survey indicated that they
had evaluated other subpart 1 services that were not unique.
[35] Some national research exists for some of the unique service
categories at the state level; however, the extent to which the
research is applicable to the specific services in the unique subpart 1
categories is difficult to determine. For example, in some cases, the
service in a unique subpart 1 category was not based on the same model
that was evaluated or states did not provide sufficient information on
our survey to determine whether the program was based on this
particular model. Therefore, we do not discuss this research in our
report.
[36] A number of evaluations of similar types of family preservation
programs have found that children in control groups also had low rates
of out-of-home placement, raising questions about the effectiveness of
these services.
[37] Ira M. Cutler, Alexandra Tan, and Laura Downs, State Investments
in Education and Other Children's Services: Case Studies of State
Innovations (n.p.: September 1995), http://www.financeprojectinfo.org/
Publications/studies.html (downloaded Jul. 8, 2003).
[38] The following 7 states completed the county-administered survey
version: Colorado, Georgia, Maryland, Minnesota, New York,
Pennsylvania, and Wisconsin.
[39] We did not receive responses from the District of Columbia,
Indiana, Kentucky, or Montana.
[40] The 17 states that responded to the second survey were Arkansas,
Delaware, Florida, Hawaii, Illinois, Kansas, Louisiana, Massachusetts,
New Mexico, North Dakota, Oklahoma, South Dakota, Texas, Utah, Vermont,
Washington, and Wyoming.
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