Purpose

To determine whether the Office of Children and Family Services (OCFS) has effective controls in place to ensure that foster homes meet required criteria prior to their certification or approval for the placement of foster children, and to determine whether casework contacts occur as required for these children. Our audit covered the period April 1, 2012 through March 22, 2017.

Background

OCFS regulates and supervises child welfare services, including foster care and adoption, through its Division of Child Welfare and Community Services. Regional Offices oversee the entities that provide child welfare services, including voluntary agencies (VAs) and local Departments of Social Services (counties). These entities administer the foster care program, including placing children in foster care settings, certifying and approving certain foster homes, and providing casework services to children and families. OCFS and these entities use the CONNECTIONS system to document information about service delivery, including assessments and case plans for families and children.

Key Findings

• At each of the ten sites we visited, foster home records lacked evidence that counties or VAs met certain critical foster home certification/approval and recertification requirements, thus increasing the risk of placing children in an unacceptable environment. The problems we identified included missing home visits and no record that background checks for criminal history and/or child abuse history were done for foster home residents.
• Casework records lacked evidence that caseworkers made required contacts with foster children, foster parents, and parents. For example, for 150 children we selected for review, casework records for 33 lacked evidence that caseworkers had two contacts with the child within the first 30 days of placement, as required. For one of the 33 children, it took more than 60 days to make the initial contacts, and 14 were not visited in the foster home within the first 30 days of placement.
• For 30 of 150 children selected for review, we determined that 162 contacts were not entered within OCFS’s 30-day limit. For example, for one child, 23 contacts were entered anywhere from 35 to 244 days after they took place.
• Inconsistencies and errors exist among different sources of foster care data, which may compromise its integrity and usefulness.

Key Recommendations

• Identify and implement strategies to improve county and VA compliance with requirements for the certification and approval of foster homes, promptness and frequency of casework contact services, and timely entry of casework contact progress notes.
• Identify and correct the inconsistencies and errors in foster care population data, and take prompt steps to address those that may compromise its completeness and/or accuracy.

Agency Response

In response to the draft report, OCFS officials stated that they “reject” our findings and characterized our recommendations as “irrelevant” and “nonsensical.” In part, officials argued that it is inappropriate for auditors to gauge performance without specific law or regulation specifying minimum performance standards. However, OCFS officials overlooked their own internal operating standards, which auditors used to assess OCFS’s performance. With specific regard to entering data about casework contacts, which are face-to-face visits done to assess the child’s safety or adjustment to foster care, OCFS officials “would consider entry within 30 days to be a reasonable standard.”

OCFS officials also asserted that supplemental information (records) they accumulated, and provided to us as much as six months after we issued our preliminary findings, disputes at least one error that we cited for half of the children in our tests and one-third of the individual findings overall. However, some of these records indicated that certain requirements were met after and in response to our preliminary audit results. For example, in one case, 427 days elapsed between the July 2015 casework contact and the September 2016 date when information about this visit was finally entered, which was nine days after OSC’s site visit. When records are not contemporaneous with the events in question, they are of limited evidentiary value. Also, OCFS officials did not account for the other half of the sampled children, for whom they did not provide evidence of the required oversight and supervision. Nor did OCFS officials provide evidence for the remaining two-thirds of the individual findings we cited. Consequently, we maintain that this report provides a reasonable basis for its findings and conclusions.

OCFS is responsible for the safety, permanency, and well-being of many of society’s most vulnerable youth. Timely, complete, and accurate management information is needed to ensure compliance with prescribed protocols (including supervisory visits) designed to protect youth placed in OCFS programs. However, OCFS’s defensive and dismissive response is not indicative of an appropriate agency control environment, particularly given the nature of the youth OCFS must protect. Consequently, we urge OCFS officials to reconsider the audit’s findings and recommendations with more open minds, to better enable OCFS to fulfill its vital mission. 

Other Related Audit/Report of Interest

New York City Administration for Children’s Services: Administration of Non-Competitive and Limited-Competition Contracts (2013-N-2)