Report 2021-112 Recommendation 12 Responses

Report 2021-112: The Child Abuse Central Index: The Unreliability of This Database Puts Children at Risk and May Violate Individuals' Rights (Release Date: May 2022)

Recommendation #12 To: Social Services, Department of

Until the Legislature amends state law and DOJ develops processes to use CWS/CMS, Social Services should by November 2022, ensure that all counties develop policies and procedures to review the monthly reports produced by Social Services and ensure that they have sent all appropriate reports to DOJ.

Annual Follow-Up Agency Response From December 2024

In addition to ACL No. 23-66, mentioned in the CDSS response to recommendation 10, CDSS is in the process of developing a subsequent ACL which will provide further guidance to encourage counties to develop policies and procedures consistent with the audit recommendations and the processes outlined in

ACL No. 23-66.

The CDSS is continuing to engage in ongoing discussion with the County Welfare Directors Association and county child welfare agencies to explore:

- How existing data and automation may be leveraged to support ongoing reconciliation and monitoring of submission of eligible reports to the CACI, including the development of monthly reports.

- The determination of additional data points and automation solutions that may be needed to improve ongoing efforts to strengthen the accuracy and completeness of CACI reports, for new and amended BCIA 8583 forms. The CDSS will continue to work with counties and DOJ to ensure the process for completion of these forms is intuitive to complete and will support counties in the reconciliation of their data.

The draft of the subsequent ACL is now expected to be completed by Spring 2025. The CDSS and DOJ are working collaboratively to identify specific data exchange requirements and elements to be collected by DOJ. These data elements will then be matched against child welfare case management system data for all eligible records cross-reported to DOJ for the purpose of listing the perpetrator on the CACI and ensuring incomplete or rejected BCIA 8583 forms are sent to the correct county contact for review, correction, and resubmission to DOJ, as necessary.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Per Social Services' response, it has not fully implemented this recommendation.

Annual Follow-Up Agency Response From October 2023

In addition to the ACL mentioned in Response 1, CDSS is developing a subsequent ACL which will provide further guidance from the state about the review and reconciliation procedures established for CACI reports, including guidance for how county child welfare agencies will establish policies and procedures for tracking and monitoring CACI reports and for correcting and resubmitting reports when necessary. The draft of the subsequent ACL is now expected to be completed by January 1, 2024. CDSS and DOJ are working together to identify specific data elements that can be collected by DOJ and matched against child welfare case management system data for all eligible records cross-reported to the DOJ for the purpose of listing the perpetrator on the CACI.

An ongoing monitoring process of CACI eligible reports will not be able to begin until there is a way to compare DOJ data reports with the child welfare case management data reports from CDSS.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Per Social Services' response, it has not fully implemented this recommendation.

1-Year Agency Response

In addition to the ACL mentioned in Response #1, the CDSS will be developing a subsequent ACL which will provide further guidance from the state about the review and reconciliation procedures established for CACI reports, including guidance for how county child welfare agencies will establish policies and procedures for tracking and monitoring CACI reports and for correcting and resubmitting reports when necessary. Currently, CDSS' efforts have continued to be focused on developing and implementing the reconciliation process through an ACL for the 27,000 reports and exploring processes for ongoing reconciliation in partnership with the DOJ. The draft of the subsequent ACL is now expected to be completed by January 1, 2024.

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

Per Social Services' response, it has not fully implemented this recommendation.

6-Month Agency Response

The CDSS has drafted an All County Welfare Director's Letter (ACWDL) which includes guidance for how counties will complete the reconciliation of the 27,000 reports and shared it with the workgroup noted above and plans to disseminate the letter once all workgroup feedback has been resolved. The CDSS had originally planned to complete an All County Letter (ACL) by October 31, 2022, providing state guidance on the review and reconciliation procedures established for CACI reports, including guidance for how county child welfare agencies will establish policies and procedures for tracking and monitoring CACI reports and for correcting and resubmitting reports when necessary. CDSS' efforts have been focused on developing the reconciliation process and ACWDL for the 27,000 reports and entering into a data use agreement with the DOJ, and the draft of this ACL is now expected to be completed by January 31, 2023. Once the draft ACL has been completed, CDSS will follow protocols for stakeholder review, final approval and posting to the CDSS website.

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

Per Social Services' response, it will not fully implement this recommendation until January 2023.

60-Day Agency Response

CDSS has partially implemented this recommendation and is currently engaged in ongoing discussions with counties and the County Welfare Directors Association to explore how existing data and automation may be most effectively leveraged to support ongoing reconciliation and monitoring of submissions of eligible reports to the CACI, including the development of monthly reports, and where additional data points and automation solutions may be needed to further ongoing efforts to strengthen the accuracy and completeness of CACI reports. As part of these discussions, CDSS is committed to working with counties to develop necessary policies and procedures to support ongoing reconciliation efforts, including providing state guidance, technical assistance, and support for ongoing CACI report reconciliation efforts established in collaboration with counties and DOJ. This includes ongoing collaboration to develop and issue state guidance on any review and reconciliation procedures established for CACI reports, including procedures for county child welfare agencies to receive any data reports, how to reconcile potential discrepancies identified by the reports, and how to ensure reports are submitted correctly or identified as inappropriate for submittal. Estimated Time of Completion for issuing state guidance in the form of an All County Letter is expected to be completed October 31, 2022.

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

Per Social Services' response, it will not fully implement this recommendation until October 2022.

All Recommendations in 2021-112

Agency responses received are posted verbatim.