October 11, 1999

 

 

 

The Honorable Jim Twiford

Chairman, Management Audit Committee

Legislative Services Office

State Capitol Building

Cheyenne, WY   82002

 

                                                                                    Re:       Child Protective Services Audit

 

                                                                                    Ref:      SRC-99-298

 

Dear Senator Twiford,

 

LEGISLATIVE SERVICE OFFICE (LSO) CHILD PROTECTION REVIEW

 

Chapter 2. Evaluating the Child Protective Services (CPS) Program

 

Recommendation:  DFS should implement an institutional research function to evaluate both program and administrative effectiveness.

 

Partially Agree          

 

Two years ago one consultant position was dedicated one-half time to data collection. Part of the duties for this position includes some analysis of the data that is collected.  In-depth analysis is not possible due to a lack of resources to hire a trained statistician.

 

The federal government has established seven outcomes for child welfare as they relate to safety, permanency, and well-being.  DFS has incorporated these outcomes in our newest strategic plan.  The methodology developed involved determining what data to collect, how to collect that data, and established baselines.  These outcomes were only available in draft form during the time LSO was conducting this review.

 

The Staff Assistance Visit (SAV) review form used for child welfare has been developed through field and state teamwork.  This method corresponds with the federal goals and outcomes. After a year of using this tool, evaluation will be done.  The state office will also use aggregate results from the SAV reviews to assess the information gathered from the reviews.

 

DFS is applying for participation in a federal project focused on management and supervision using data.  If Wyoming is approved for participation, managers and supervisors will be trained and methods and goals will be developed.

 

It should also be noted that after the LSO review, DFS was recognized nationally for almost doubling adoptions.  Wyoming is number two in the nation.  This is certainly one measurement of effectiveness.

 

Chapter 3.  Intake, Investigation, and Ongoing Services

 

Recommendation:  DFS should monitor and evaluate CPS intake, investigation, and ongoing service procedures at the state level.

 

Partially Agree

 

Page 20.          Variation in Rejection Rates.

 

            As described above, DFS will continue to improve the SAV process as resources permit. A comprehensive review should include a larger number of case file reviews to assure validity of the sample.  In addition, quality assurance should be done at the regional level.  Emphasis will be placed on reviewing rejected allegations.  To improve this process, additional staff are needed.  At this time, we have only one full-time position.  We will evaluate and if appropriate initiate an increase in staff.

 

Page 20.          Other Staff Collecting Intake Information.

 

Three years of SAV reviews have not indicated a problem with trained staff completing the intake process.  Basic information may be taken by other staff when a social worker is not available, but a social worker will call the reporter for detailed information.

 

CPS rules prohibit untrained staff providing any CPS service without direct supervision. In CPS core training, this is emphasized.  Current law allows for a centralized intake process which could take advantage of modern technologies.

 

Page 21. Variations in Substantiation Rates.

 

Data analysis is appropriate and the Department will seek ways to complete this step as resources allow.

 

Page 22.          Investigation Requirements, Ongoing Services.

 

            This review done by LSO only looked at electronic data, not at the hard copy files available in the local offices.  SAV reviews look at both the hard copy case files and the computer data.

 

            The need to officially establish regulations around the definition of a case file is readily apparent.  By so doing, reviews could be done using only one source, the computer. Technological consideration would have to be addressed, i.e., scanning equipment in every field office.

 

            Procedures will be developed to specify documentation of those present during an interview.

 

Page 23.          Not Known How Many Receive Ongoing Services

 

            The capability of WYCAPS to provide this information will be developed.  This should also increase confidence that children are being seen and will pinpoint problems in this area.

 

Page 24.          Variation in the Rate of Contract Service Provision.

 

            DFS will analyze this information to determine the relationship between office size, availability of community resources and utilization of those resources.

 

Page 24.          Reasons Services are not Provided.

 

            See comments above regarding official case file.

 

Page 25.          Risk Assessment not used as Policy Requires

 

            Policy will be rewritten to emphasize this requirement in ongoing cases.  WYCAPS forces response time assessment via the intake process.  The Wyoming model is required to be used at substantiation.  The development of Computer-Based Training will enable DFS to provide training and re-training on CPS rules.

 

Page 26.          State Office Leaves Monitoring of CPS to Local Field Offices.

 

State level review of social work decisions is monitored through fair hearings, fatality and major injury review at the local and state level, the SAV process, and by specific request at the state office level.  All results of these monitoring efforts need to be consolidated and analyzed.

 

Chapter 4.  DFS Policies

 

Recommendation:  DFS should develop more specific policies to establish agency CPS practice expectations.

 

Partially Agree

 

            Throughout the years, both nationally and locally, philosophy has shifted from less prescriptive to more prescriptive depending on research and leadership.  A concerted effort was made to reduce the Family Services Manual by 60 to 65 percent.  The points outlined in this review have validity especially with the loss of veteran staff.  Prescriptive policy is necessary with the high worker turnover we are experiencing, giving us an increased percentage of inexperienced workers.  State and local DFS staff are scheduled to rewrite CPS rules, and policy will become more balanced.

 

Chapter 5.  Caseworker Turnover

 

Recommendation:  DFS should assess the causes of high turnover and develop a plan of action.

 

Partially Agree

 

Agree, on the whole, with all recommendations with the exception of the final recommendation that DFS should assess the causes of high turnover and development of a plan of action.  The following comments are directed towards the conclusions presented by that recommendation.

 

The Chapter Summary for Chapter 5 alludes to two things.  The first is that the agency's efforts to reduce turnover for CPS workers has not resulted in a reduction of turnover nor in the creation of a plan by the DFS to decrease the rate of departures.

 

The first statement does acknowledge that the agency has made efforts to reduce the turnover (departures) of CPS worker, but the assessment of the effectiveness of the Department's efforts seems conjectural.  The second statement about a plan is somewhat puzzling since it is the Department's recollection no one asked the Department whether or not the Department had a plan to reduce CPS staff turnover.

 

The Department did in fact develop a plan or strategy to reduce staff turnover based upon reducing the individual worker's CPS caseload, increasing workers' compensation, and increasing the number of workers with social work or closely related degrees.

 

The reduction in caseload was approached both by presenting requests for additional CPS worker slots and through reallocation of existing positions.  The closure of the Wyoming Youth Treatment Center resulted in 11 new probation and CPS worker positions being assigned to various field office locations.  In addition, the Department put in place a staffing model which has resulted in several more new probation/CPS worker positions being created from existing positions already assigned to field offices.  This latter process continues to this day.

 

The Department has also taken steps to increase compensation to CPS staff.  For instance, some years back and based upon Fair Labor Standards Act (FLSA) rulings, the Department re-designated all line CPS staff from exempt to non-exempt.  This change made CPS line staff eligible for overtime pay beyond forty (40) hours a week.  The Department, prior to the recent change in the state's classification and compensation systems, routinely reclassified CPS workers in entry level Social Worker I positions with two years of professional level social work at the Social Worker I level (entry level classification) to Social Worker II (journey level classification) positions.  The difference in pay grade minimums between the entry and journey resulted in as much as a 19.4% increase to some workers.  The Department supported a change by the State Division of Human Resources that moved entry level CPS workers from a pay grade 6 to a pay grade 7 resulting in a 5.95% increase in the grade minimum rate for entry-level CPS workers.  The Department also planned and implemented a three stage market pay adjustment plan (including that mandated as a result of the reversion of general fund dollars to state agencies) and one general pay adjustment increase for all DFS workers.  The general result has been to substantially increase the compensation of CPS workers over previous levels.  Finally, the Department's most recent effort to improve CPS worker compensation is to implement on-call pay compensation for those CPS workers designated to be available 24 hours a day for call back to work emergency CPS cases.

 

The Department has put in place a requirement that in hiring new CPS workers or promoting existing CPS workers, a preference is given to workers with bachelors or masters degree in social work or a closely related field.  The requirement is intended to increase timeliness and quality of CPS cases and reduce the potential liability of ineffective casework decisions to the client and the Department.

 

The Department has attempted over the years to assess why CPS turnover occurred.  These efforts resulted in a conclusion that lower caseloads, consistent increases in compensation, and career development were issues important to CPS workers.  The development of more consistent, comprehensive, and innovative policies and programs in areas such as recruitment and retention has been hampered by the lack of available staff time in the DFS Human Resources Unit.  Available staff time is almost completely directed to carrying out mandated human resource and pay functions, which are increasingly more complex and time consuming under newly, implemented systems.  For example, the Department estimates it now takes twice as long to obtain a certificate of eligibles from an existing register (two weeks versus one week) even though no additional recruitment is required.  It is also necessary to divert more and more staff time to increasingly numerous and complex employee grievance hearings.  Requests have in the past been made for an additional full time equivalent (FTE) professional staff position to develop and maintain formal policies for non-mandatory functions such as recruitment and retention programs but resources could not be made available.

 

The time factor is very important since every day a CPS position is vacant is a day another CPS worker must assume the additional caseload resulting from a CPS position being vacant.  It is also important to try and hire workers with the proper credentials in order to achieve an end result of more effective workers once the initial training and orientation period is completed.  This is especially true when consideration is given to the necessary lag time (at least one-year) of training and orienting new workers.

 

Retention is important, but the workers retained must be those with the most appropriate type and level of knowledge and experience.  It is important in this regard to state that many of the factors necessary to recruit and retain high quality workers are not under the Department's control.  Factors relating to statewide policies and budgets influence retention and hiring factors such as provision of health and life insurance benefits.  These and factors relating to increases in individual compensation are more influenced by the revenue sources available to the state and how the state chooses to allocate those resources.

 

            The Department of Family Services requests support from legislators to increase pay and increase staff, so caseloads can be reduced.

 

Chapter 6.  Counting and Measuring Workload

 

Recommendation:  DFS should develop a workload methodology and an updated workload standard.

 

Agree

 

We find the statements made in this chapter are generally true and accurate.  The Department has, in fact, used weighted caseload counts in the distant past.  We have also had adjusted work standards for the differences between larger office (who can specialize workers in types of cases) and smaller offices (where workers have the added burden of covering for sick or absent staff in any unit).  Because of the need to implement the new social services computer system (WYCAPS), the agency has tried to maintain the current caseload measurement until such time as the new system was functional.  This “shakedown period” would allow the workload design to be a final product and the agency standard.  The time is right to complete the process recommended by the LSO study.  We will be considering a “real time study” for the actual hours required to appropriately perform all mandated social services functions 

 

To effect the suggested process, DFS staff contacted staff from A.T. Hudson & Co. Inc. during a national conference and discussed the workload study they are currently conducting for the Denver County Colorado Social Services Office.  Arrangements are underway to attempt to bring A. T. Hudson & Co. to Cheyenne to demonstrate the study process being used in Colorado.  We hope to determine this study's appropriateness for a similar Wyoming study.  If this meeting moves to the next stage, we anticipate A.T. Hudson & Co. and other vendors will evaluate the Wyoming request to project the anticipated cost of the request for Wyoming and submit bids.  Region Managers from the field, and Central Office staff will prepare the Wyoming Workload Standard request for submission and bid.  LSO staff may be invited to participate to make certain the process meets their findings and recommendations as determined by this study.  The outcome of the workload study will become the baseline standard for all Wyoming projections of staffing needs and workload levels compared to the national standards quoted in the LSO study.

 

The fix to this recommendation is legislative support and funding for additional supervisory positions.

 

Chapter 7.  Supervision

 

Recommendation:  DFS should strengthen its supervisory structure.

 

Agree

 

            In response to budget reduction pressure, the Department of Family Services has reduced management through the creation of districts.  This has actually increased social work supervision expertise, but it has created a proximity problem.  It has increased distances between management/supervision and field offices.  We would further point out the loss of one of the supervisory positions in Laramie County.  This was due to a legislative cut of a vacant position because of our inability to attract a well-qualified person in a timely manner.

 

Chapter 8.  CPS Training

 

Recommendation:  DFS should assess how to enhance ongoing CPS training.

 

Agree

 

            The state office responded as follows:  DFS has always been aware of the need for more training but lack of resources have precluded the type of advanced training that is needed. The development of Computer-Based Training will certainly improve the system.  Each year, a Social Services Conference is held and national experts are brought in to train.  Not everyone is able to attend because of the need to be on-call for CPS.  Grid trainings have been held much more frequently since the passage of ASPHA.  Refresher CPS core curriculum needs to be developed.

 

            The field office responded as follows:  There appears to be a need for clear communication and understanding about the DFS training budget which could be used for on-going CPS training.  Managers seem to be relying on local budgets for on-going training needs when they could be utilizing a state training budget which would increase training opportunities. 

 

Conclusion:

 

We appreciate the effort the Legislative Service Office staff made to understand the system in which our staff works.  We believe the LSO staff made a concerted effort to evaluate the work of our people as fairly as they could in the brief time span they were given to produce their report.

 

It has been long recognized in the Department, there was a need to improve the data collection systems used by the majority of the DFS workers.  DFS had the request before the legislature for two sessions before the funding was finally approved for the development of WYCAPS.  We believe WYCAPS is a good data collections system and we have taken it as far as we could, given the 18 months of time we have had to work with it and the information it generates.  With the pressure to reform the welfare system, the need to increase the child support collections and the continued focus on the juvenile justice system, staff time has been directed to the most immediate and critical need as required by the federal or state mandates.  We are proud of the fact our few people have been able to balance all of the numerous mandates and deliver quality service that competes favorably with every state in the Union.

 

Though it is true, we cannot point to one or two data reports which prove the Department is delivering effective and efficient child protective services, we maintain we can demonstrate this to the public’s satisfaction by case documents and our internal reviews.  Still, we agree with the LSO assessment of the need to have simple and appropriate measurements, which meet or exceed national standards. 

 

We fully intend to implement the vast majority of the LSO recommendations if we receive legislative support through funding and case worker position increases.  We respectfully request vacant positions not be arbitrarily cut from the DFS budget, but rather reviewed first for potential impact.

 

Wyoming is one of only a very small number of states not currently under a court mandate to improve child protective services.  We do not want to wait until that requirement forces us to change our procedures.  We hope this report is sufficient to begin the process and we will report on our progress as we complete each recommendation.

 

                                                                                    Sincerely,

 

 

 

                                                                                    Shirley R. Carson

                                                                                    Director

SRC/tat

cc:        DFS Administrators