NORTH CAROLINA DEPARTMENT OF HEALTH AND HUMAN SERVICES DIVISION OF SOCIAL SERVICES CHILD WELFARE SERVICES Background and Purpose The North Carolina Department of Health and Human Services has the authority under General Statute 108A-74 (http://www.ncleg.net/gascripts/statutes/statutelookup.pl?statute=108a-740) to evaluate and provide technical assistance to county social services agencies to assure child welfare programs are in compliance with statutory requirements. The evaluation entails a review of program protocols and practices, including a review of case records, to determine the agency s level of functioning. A plan for improvement is developed and the North Carolina Department of Health and Human Services through the Division of Social Services (NCDSS) provides technical assistance and oversight to ensure plans are implemented and the expected outcomes are achieved. In the first week of February, 2014, the NCDSS recognized an unusual number of child protective services assessments open with (WCDSS) indicating possible problems with the management of the child protective services (CPS) cases. On February 19, 2014, the NCDSS became aware of a case in which foster children were victimized while in a placement made through the WCDSS. On February 21 and 24, 2014, staff from the NCDSS conducted a preliminary assessment at the WCDSS to determine the program areas that required further in depth review. The NCDSS staff reviewed the entire case record of the foster children noted above. As a result of this assessment, the NCDSS developed a plan to conduct a broader review of child protective services cases and the management of those cases. Program Evaluation During the week of March 3, 2014, five staff from the NCDSS reviewed cases and evaluated child protective services processes. The case review included a sample of: 17 CPS assessments open in excess of 45 days to determine the source of delays in decision making; 3 CPS In Home Services cases that were open in excess of 180 days; and 8 CPS intake reports that the WCDSS determined did not meet the criteria for a CPS assessment. The focus of the evaluation was on the delivery of child protective services provided by the WCDSS. The review included an examination of the records for the intake decisions, initiation of assessments, safety planning, required notices to the reporter, District Attorney and law enforcement, interviews with victim children, parents and collateral contacts, home visits and face to face contacts, supervision and decision making. 1 of 7
Key Observations / Findings and Recommendations This report outlines 6 key areas with observations / findings and recommendations identified during the evaluation. Each key area contains a subset of bulleted details. Key observations / findings IV, V, and VI contain introductory information so as to give context for the area. This information is generally a brief description of state and federal child welfare law, rule, policy or practice guidance. As noted, the evaluation focused on a targeted sample of cases with issues identified as concerns subsequent to the NCDSS reviews conducted in February 2014. As such, the observations / findings are not necessarily a reflection of the WCDSS child welfare program performance. The 6 key areas center on the following themes: I. Agency Structure and Administration II. Case Documentation III. Quality Assurance IV. Child Protective Services Intake V. Child Protective Services Assessments VI. Child Protective Services In Home Services I. Agency Structure and Administration Wilkes County DSS had a 39.29% vacancy rate among child welfare social workers compared to 22.49% for North Carolina. Based on calendar year 2013 data submitted by the WCDSS in late January, 2014, the WCDSS had an average of 219 CPS assessment cases open at the end of the month compared to an average of 62 new cases accepted each month. This indicates a large number of assessments not being resolved in a reasonable time. The large number of open CPS assessment cases open for unreasonably lengthy periods of time is in large part due to the lack of leadership, supervision and timely assessments ending with accurate and well informed case decisions. The WCDSS is out of compliance with supervisor to social worker ratio of 1 supervisor to 5 social workers. Two CPS Supervisors are responsible for supervising 11 and 8 positions, respectively. Two Foster Care Supervisors supervise 6 and 8 positions respectively. Based on interviews with management, Lead Supervisors for CPS and Foster Care areas were designated as a strategy to mitigate the supervision deficiency. However, these designations do not have any apparent significance in daily operations and offer no additional accountability or coordination for program or case outcomes. The 4 child welfare supervisors report to a program administrator who is also responsible for supervising all line supervisors in the agency resulting in a ratio of 1 program administrator to 12 supervisors. There is no clear coordination of activities between the supervisors resulting in diverse decision making and disagreements on the management of cases. The WCDSS has an automated system for tracking cases, but it is not used since information is not kept up to date by social workers or supervisors. This results in incomplete and inaccurate tracking data that is unreliable for decision making. 2 of 7
Recommendations: The WCDSS must move to fill the long vacant CPS Supervisor position. In order to be in compliance with supervisor to staff ratio policy, the WCDSS will also need to establish a new child welfare supervisor position. The WCDSS must create a plan for establishing increased accountability of supervisors and social workers. The plan should also include identifying leadership, including the director, to track process and outcome data to assure compliance with law, rule, policy, and best practices. The WCDSS management and supervisors shall evaluate the use of the county automated case tracking system to remain informed on case management activities and workloads. This includes developing a means to hold social workers and supervisors accountable to timely entry of information. The NCDSS will provide technical assistance and support to establish processes and protocols for supervision and the management of cases. This can include: o regular data reviews with supervisors and management, including use of the county automated case tracking system and other tools; o the development and implementation of a case staffing process to produce timely accurate case decisions; o coaching on the use of supervision tools to assure case activity that establishes safety for the child and respect for families. II. Case Documentation The WCDSS does have a written, file organization protocol to which no one is held accountable for using. This was evidenced by the inconsistency in record organization among records reviewed and the wide range of styles in documentation among social workers. The NCDSS reviewers had difficulty finding critical information in records due, in part, to illegible handwritten notes. There was insufficient documentation in most records to determine if decisions regarding child safety and well being were accurate. Required documentation tools, most conspicuously the Structured Decision Making Tool required at the conclusion of CPS assessments, were absent among case documentation. Recommendations: The WCDSS must develop and implement a plan for holding social workers and supervisors accountable for maintaining accurate and timely documentation in case records. This plan must begin with supervisors ceasing to sign off on incomplete records. The WCDSS supervisors must immediately cease approving closure of assessments when the Structured Decision making tools are not completed. o coach supervisors in identifying and reviewing the basic documentation social workers must provide; o identify efficiencies with case documentation so as to maximize staff time in light of current resource capacity concerns; o provide guidance and consultation on establishing documentation expectations. 3 of 7
III. Quality Assurance The WCDSS does not have a systematic means for reviewing records, data, or outcomes by supervisors or management. The lack of any visible review of case records has resulted in many poorly documented cases and cases without any activity for periods of time. Recommendations: The WCDSS must develop, implement, and document a regular system of quality assurance reviews to ensure adherence to federal and state law, rule, and policy which will lead to positive outcomes for children and families. o develop and monitor a plan for maintenance of documentation and records; o develop a model for conducting quality assurance case reviews; o provide guidance on assuring that appropriate feedback loops are implemented for staff and management on the outcomes of the reviews; o train and orient staff on the quality assurance tools when implementing the model; o assist staff to respond to feedback as a means of continuous quality improvement; o develop a sustainability plan to assure continuation of the process. IV. Child Protective Services Intake North Carolina requires the use of the Structured Child Protective Services Intake Report (DSS-1402) as the tool for interviewing and documenting information when a call from someone who suspects child abuse or neglect is received by a county social services agency. The structured tool prompts intake social workers to ask specific questions and document responses to ensure all information known by the reporter is available to make the decision to accept the report for assessment based on maltreatment defined under General Statute 7B-101. When screening the child protective service reports, the Structured Decision-Making model outlined in state policy is used to guide the intake staff through the process of determining if a report meets statutory criteria for an assessment based on the information gathered on the Structured CPS Intake Report. While the Structured CPS Intake Report was found in all records, it was not complete. Thus, the reviewer was unable to determine if screening decisions were accurate. For those reports in which the reporter was known, notices were sent timely. Recommendations The WCDSS social workers who receive and screen CPS intake reports must be held accountable for using and completing the Structured CPS Intake Report to document the interviews. The WCDSS supervisors reviewing CPS intake reports as part of the 2 party review must not sign off on reports until the Structured CPS Intake Report is thoroughly completed, including calling the reporter if necessary to secure additional information. The WCDSS will include in its larger quality assurance system a means by which intake documentation and decisions are systematically reviewed by management. This should include a 4 of 7
means by which any results from quality assurance reviews a systematically reviewed by management, supervisors, and social workers. o provide coaching and guidance in completing the CPS Structured Intake Report and utilizing the Structured Decision-making model to reach intake decisions consistent with law, rule, and policy; o provide consultation and guidance in screening decisions; o develop and implement the means for systematic review of CPS reports to assure accuracy in decision making; o train supervisors and social workers to utilize quality assurance tools to assure CPS reports are thorough; V. Child Protective Services Assessments When reports of suspected child abuse, neglect or dependency are received, the Director of a county social services agency is charged with conducting a prompt and thorough assessment of the allegations in accordance with General Statute 7B-302. The NCDSS outlines required actions and best practices in Chapter VIII of the Family Services Manual. Although the General Statutes do not prescribe a time frame in which to complete assessments, the NCDSS does provide guidance on time frames in which assessments should be completed, and decisions must only be made when all relevant information is gathered and processed to make an informed decision. These decisions must be documented on the Structured Documentation Instrument for CPS Assessments (DSS-5010). When selecting a case sample for review, the NCDSS selected CPS assessment cases that exceeded policy guidelines to determine the source of delays in decision making. Of the 17 CPS assessments reviewed: 7 assessments were still open ranging from 62 to 450 days; 5 assessments were closed within the last 6 months that were open for 34 to 334 days and were determined to be other than substantiated or in need of services; 3 assessments that resulted in opening a CPS In Home services due to a substantiated or in need of services finding; 2 assessments on already open CPS assessments or CPS In Home cases. Assessment cases were open for long periods of time with no contacts and no documentation of the reason for no contact. There was little documentation of supervisory oversight other then a signature at time of closure. In some cases when there was documentation of supervisory direction, it was not followed by the social worker and the supervisor had no means to know the task was not completed. The most significant contributor to unreasonable delays in case decisions identified by the reviewers appeared to be a lack of supervisor time and oversight. In 13 of the 17 assessments reviewed, WCDSS did not initiate the assessment within the response time set at the time the report was screened in for assessment. These delays in initiation were not supported in documentation. Ongoing visits and contacts with families to assure safety of the children throughout the assessment process was sufficient in only 11.8% of the assessments. All adults living in the child s household were seen and interviewed in 35.3% of the assessments. Criminal checks on all adults in the home were completed in 35.3% of the assessments; All allegations in the original report were discussed with families in 52.9% of the assessments. 5 of 7
Structured Documentation Instrument for CPS Assessments required by policy were not utilized. In 58% of the closed assessments, it could not be determined whether the decision was accurate due to insufficient information in case documentation. Two of the 12 closed cases were not approved by a supervisor. Collateral contacts that could have critical information were not contacted in over half the cases. Central Registry checks were not completed on all cases as required. Recommendations: The WCDSS supervisors must immediately cease approving closure of assessments when the Structured Documentation Instrument for CPS Assessments are not completed; The WCDSS should develop and implement use of a case tracking log that includes all the documented tasks for the assessments with the date of completion to be maintained by social workers and reviewed by supervisors. The WCDSS should implement the use of a supervisory review tool for use in staffing cases with social workers. The WCDSS should implement a process for conducting case decision staffings when all required tasks for a thorough assessment are completed. The NCDSS will provide technical assistance to o select and implement the use of a case tracking model to assure all necessary case activities are completed; o coach supervisors on the use of the case tracking tool in reviewing case records and evaluating the quality of the case activities; o establish a case staffing system to assure agency decisions, rather than individual social worker decisions, are made at the conclusion of CPS assessments. VI. Child Protective Services In Home Services CPS In Home Services are provided when a child is found to be at risk of abuse or neglect at the conclusion of the CPS assessment. The case management services, guided by a case plan developed with the family, are efforts made to prevent any further maltreatment and prevent foster care placement. These services are designed to be intense and time limited. Cases in which the conditions leading to the risk of maltreatment have not been significantly reduced or ameliorated within 90 days should be reviewed for possible court intervention. Three CPS In Home Services cases were reviewed. Two cases selected were still open after 10 to 14 months. The third case was closed within 6 weeks of the start of CPS In Home Services due to the WCDSS assuming custody of the child. There was a significant lack of documentation or organization in the records. There was no documentation of services to the family. There were no current case plans as required by state and federal policy. There was no documented engagement of the family in the case planning and development process. The lack of case plans to clearly chart case activities and goals resulted in social workers spending more time reacting to crises rather than successfully resolving risks to children and preventing foster care placements. 6 of 7
There was a significant lack of face to face contacts with families or anyone else connected with the families to assure the child s safety for many months at a time. Child and Family Team meetings, the forum through which case plans are developed with the family and their support system according to state policy, were not utilized. If a safety resource placement was used for a child, social workers did not see or screen all adults where the children were staying. There was no indication of supervisory or management oversight in the cases. Recommendations The WCDSS must: o immediately review the status of all open CPS In Home cases to determine the risk to the children in those cases; o establish regular meeting times between social workers and supervisors to provide oversight on the cases and the recommendations/activities; o develop a plan for regular case staffing on any CPS In Home cases open for 90 days of more, preferably with a child welfare attorney, to consider whether court oversight is required for case progress; o develop and implement use of a case tracking tool to assure regular contacts that supervisors would review weekly; o utilize a quality assurance system to ensure social worker and supervisor accountability in management of CPS In Home cases, including a feedback loop to management and supervisors on review outcomes. o provide guidance and consultation in the review of CPS In Home cases; o develop the case tracking tool; o develop and implement a plan for regular supervisory conferences with CPS In Home Service workers and provide support to maintain the conferences; o provide consultation and support in staffing cases open more than 90 days. Next Steps The WCDSS must develop a plan to address the issues identified. Once the plan is developed, the NCDSS will provide oversight, technical assistance and training as described above. A follow up review will occur within 6 months to determine progress toward resolution of these findings. 7 of 7