Report 2015-502 Recommendation 5 Responses

Report 2015-502: Follow-Up—California Department of Social Services: Although Making Progress, It Could Do More to Ensure the Protection and Appropriate Placement of Foster Children (Release Date: July 2015)

Recommendation #5 To: Social Services, Department of

To ensure that counties' use of foster family agency placements is justified, Social Services should take action to implement the recommendation we previously made in our 2011 audit. Specifically, Social Services should require counties to prepare a detailed justification for any child placed with a foster family agency.

Annual Follow-Up Agency Response From November 2020

Will Not implement, and recommend closure of the issue for the reasons stated below.

The previous response still applies. Counties will determine if a placement with a resource home is appropriate based on a number of factors and assigning a higher priority to place with a FFA versus a foster home is not one of those factors. The paradigm shift and systems change brought about as a result of the Continuum of Care Reform (CCR, AB 403 and subsequent legislation) eliminated the need to make a distinction between FFAs or county homes for placement. The licensing standards, and rates paid to resource families are now the same and will not differ because a child is placed with a FFA. Under CCR, individual services are tailored to the child's needs.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

We are disappointed that Social Services continues to not take steps to address this recommendation to ensure that counties' use of foster family placements is justified.

Annual Follow-Up Agency Response From November 2019

Will not implement.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

Annual Follow-Up Agency Response From November 2018

CDSS will not implement.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

This recommendation has been outstanding since the release of the original audit in October 2011. We are disappointed that Social Services has chosen not take our recommendation seriously and use it to improve its oversight of counties' placements of foster children.

Annual Follow-Up Agency Response From November 2016

Assembly Bill 403 represents a significant shift in the scope of services provided by foster family agencies (FFAs). County Foster Homes and FFA-certified homes will be required to meet the same standards. Effective January 2017, all foster and certified homes, and relatives will be licensed as a Resource Family (RF).

All County Letter (ACL) 16-58 (see link below) outlines the standards which includes how an RF is entered into Child Welfare Services/Case Management System (CWS/CMS). The need for preference to place in an FFA as a priority will no longer be applicable given the shift in direction of how foster homes, certified homes and relatives will be approved.

http://www.dss.cahwnet.gov/lettersnotices/EntRes/getinfo/acl/2016/16-58.pdf

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

1-Year Agency Response

Assembly Bill (AB) 403 requires Foster Family agencies (FFAs) to meet new program standards which include providing services to relative caregivers and county licensed homes, upon request by the county, and making available core services to children/youth. FFAs will also be required to become accredited by a nationally recognized accreditation agency. Since the authorization of AB 403, CDSS has released a revised rates structure with the May Revision budget on May 13, 2016 (Attachment 3). The revised rate structure creates a new basic rate which is applicable to all foster families including county licensed foster homes and relatives. Rates will be paid based on an assessment of the level of need. The rates structure was developed in accordance with the following framework:

- Rates will be a prospective pre-determined amount.

- Reasonable methods will be used for quantifying the costs of changes to the system.

- The rate structure is based on the needs of the youth and level of care.

- CDSS is committed to collecting cost data to quantify anticipated costs of the program changes, but budget realities may also impact the final rate setting revisions.

There are a considerable number of pre-implementation activities yet to be completed between now and January 1, 2017. CDSS will be issuing guidance to the providers and counties by July 2016, announcing the rates structure and rate amounts, revising costs reports in order to capture costs and revenue at a more detailed level and providing technical assistance to assist agencies with the transition. CDSS will continue to work with providers, stakeholders and counties.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

6-Month Agency Response

Assembly Bill (AB) 403 was passed in October 2015 and modifies the program expectations of foster family agencies as part of the continuum of home-based family settings. The revised rate system for Foster Family Agencies (FFAs) is being structured to support the new program changes outlined in AB 403. Pursuant to AB 403, a core set of services will be made available to all children placed in home-based family settings, without regard to the placement type (i.e. FFAs certified homes, county licensed homes and relatives). Placement decisions and services will be based on the needs of a child or youth and not prioritized by placement type. CDSS held six FFA/Continuum of Care Reform rates workgroup meetings from April 2015 through August 2015. The input obtained from these meetings provided valuable information for CDSS's consideration in developing the rate methodology, and offered suggested methods for reasonable documentation to justify the various components of the FFA rate, such as making revisions to the cost reports, exploring the value of provider time studies, and making modifications to FFAs program statements. CDSS will continue to work with stakeholders, counties, and foster care providers to implement a relevant and comprehensive rate system that meets the intent of the Continuum of Care/AB 403 and addresses the concerns identified in the 2011 audit.

California State Auditor's Assessment of 6-Month Status: Partially Implemented

60-Day Agency Response

See response to Recommendation 3.

California State Auditor's Assessment of 60-Day Status: Partially Implemented

All Recommendations in 2015-502

Agency responses received are posted verbatim.