To ensure that it is placing children only in safe homes, the department should measure its performance and adjust its practices to adhere to state law, which requires that all homes be assessed prior to the placement of the child.
DCFS continues to believe it is operating within the applicable laws governing this issue as cited in past responses. As an update, the Department is also exploring the possibility of contracting out aspects of the home assessment process and is working with the State in planning for the Resource Family Approval (RFA) process, which all counties are required to implement by January 2017. The RFA process will provide one assessment for approval of foster homes, relative/NREFM caregivers, legal guardianship and adoption.
DCFS continues to believe that it is operating within the applicable laws governing this issue as cited in earlier responses. DCFS continues to monitor the referrals and dispositions of requests for assessment of relative and Non-related Extended Family member (NREFM) homes of all children placed in relative/NREFM care. The standards used for assessment and approval remain the same as previously reported. To assist in assuring conformity to State regulations, DCFS continues to participate in the CWDA Southern Counties' Relative Assessment Unit (RAU) bi-monthly meetings, and the Statewide CWDA Licensing/Relative Approval Subcommittee bi-monthly meetings. Children in homes not approved or pending approval are centrally tracked, and Corrective Action Plans (CAPS) and Documented Alternative Plans (DAPS) continue to be encouraged where appropriate to allow safe child placements.
Further, the Department has recently benefited by the review of a Blue Ribbon Commission, which recommended that the relative assessment process be privately contracted. The Department is currently undertaking preliminary steps to explore the recommendation, with the expectation that such action would enhance both conformity and efficiency.
As noted in its initial response, the Department asserts that it adheres to State Law when placing children. DCFS has submitted in prior responses a May 24, 2012 letter from CDSS indicating that WIC section 309 permits the temporary placement of a child with a relative or NREFM before or at the detention hearing based upon the abbreviated assessment of the relative's suitability described in Section 309(d)(1).
The Los Angeles County Department of Children Family Services (department) disagrees with our interpretation of state law; it believes it does not need to complete formal assessments of caregivers and homes before placing children in homes. As described in our comments on pages 81 through 84 of the audit report, we strongly disagree with the department's interpretations and specifically point to the words from state law that the county disingenuously modified in the legal analysis it provided to support its conclusions. On page 82 of the audit report, we provide further detail of the department's lack of effort in assessing homes and caregivers prior to placement of children, at times not even visiting the home to complete required assessments. The department's continued assertion that a May 2012 letter from the California Department of Social Services (CDSS) supports its incorrect interpretation is patently false. CDSS's letter correctly identifies state law and regulations that require assessments of homes and caregivers prior to placement of children. At no time does the CDSS letter affirm that the views of the department are correct.
Beginning in June 2012, the department's Adoption and Safe Families Act (ASFA) Division began the rollout of training on policies and procedures for ASFA requests and assessment protocols to the regional offices. Between June and November 2012, staff from nine offices participated in ASFA training. The June 30, 2013 deadline for completion of training for all regional offices remains in the ASFA Division Chief's 2012-2013 goals.
In addition to the formal training, the ASFA Division implemented mandatory in-person, and, when necessary, telephone contacts between ASFA social workers and their supervisors, and between assistant regional administrators and regional administrators. Further, ASFA Division's management continues to hold informal and formal case staffing on referrals and cases pending denials. As recently as February 5, 2013, each ASFA social worker was required to provide on-going refresher training regimen for their respective offices. This is being developed in collaboration with the respective regional offices' administration.
The ASFA Division managers and supervisors have also participated in meetings and workgroups with Kinship/Relative Caregivers and the Juvenile Dependency Court to provide training and insight on the ASFA relative approval and the information gathering processes; to address the barriers identified by the group; and to elicit court collaboration in assisting with approval of potential relative caregivers.
The department continues to not measure its performance and adjust its practices to adhere to state law, which requires that all homes be assessed prior to the placement of a child.
The department disagrees with our interpretation of state law; it believes it does not need to complete formal assessments of caregivers and homes before placing children in homes. As described in our comments on pages 81 through 84 of the audit report, we strongly disagree with the department's interpretations. (See 2013-406, p. 124)
Agency responses received after June 2013 are posted verbatim.