To ensure that child abuse and neglect allegations receive timely resolution, the department should continue to monitor the status of its backlog of investigations but revise its policies and performance measures to no longer define the backlog as investigations over 60 days old. Rather, it should emphasize completing investigations within 30 days.
The department created a goal to reduce the number of referral investigations that take longer than 30 days. In accordance with this goal, the department states that its regional managers will monitor how many investigations take longer than 30 days. (See 2013-406, p. 123)
To ensure that child abuse and neglect allegations receive timely resolution, the department should assess whether it needs to permanently allocate more resources to investigate allegations of child abuse and neglect.
As of September 2015, DCFS hired 1,082 Children's Social Workers. This surpassed its initial hiring goal of 450 new Children's Social Workers. DCFS will continue its hiring efforts in order to address attrition and fill vacancies. The Los Angeles County Board of Supervisors approved an additional 500 positions for the budget year starting July 1, 2015. DCFS expects to reach full caseload equity as soon as possible. As many of the new hires complete training and slowly build to full caseload capacities, DCFS will continue to fill caseload equity needs in ER sections in the highest need offices. ER caseload averages remain below the caseload average of 18 with the exception of the four peak referral months. The target goal remains the same with ER caseloads of 18 across all offices.
As of September 2014, DCFS met its initial hiring goal of 450 new Children's Social Workers. DCFS will continue its hiring efforts in order to address attrition and fill vacancies as needed. DCFS expects to reach full caseload equity as soon as possible. As many of the new hires complete training and slowly build to full caseload capacities, DCFS will begin to fill caseload equity needs in ER sections of the highest need offices. ER caseload averages remain below the caseload average of 18 with the exception of the four peak referral months. The target goal remains the same with ER caseloads of 18 across all offices.
Between Fiscal Year (FY) 2011-12 and FY 2013-14, the DCFS rate of closures for referrals over the 30-day time period have decreased over the statewide average from 6.5% to 4.3%. Some offices have a high staff turnover rate; DCFS restricted the transfer of CSWs from these offices. The County Board of Supervisors has approved 150 new CSW positions and the continued filling of vacancies. In FY 2013-14, DCFS conducted a Business Process Reengineering of ER services to identify delays and streamline investigations. The Department continues to apply interventions to better support line staff, return staff to work, retain staff, and safely streamline the work of the organization for improved outcomes. Since the majority of counties in California have referrals which exceed the 30 day time limit, discussions with the State to review the time limit on referrals are underway.
Implementation Date: Partly implemented. Full hiring expected to be completed by January 2014.
The Department has formally assessed whether it needs to permanently allocate more resources to investigate allegations of child abuse and neglect. Specifically, the Department has developed a tool to access workload rather than caseload. The tool is a mathematical formula that uses raw caseload counts and case characteristics (e.g. a case involving a runaway youth) to express workload numerically.
The workload analysis identified those offices that have a larger number of complex cases in both the Emergency Response (ER) and Continuing Services functions - it identifies which offices require additional resources. Between August 2013 and January 2014, the Department will hire an additional 250 social workers and will use the workload analysis tool to help us determine office assignments and office function (ER versus Continuing Services) for most of the new workers. Approximately 100 workers began in August 2013 and we are in the process of hiring the remaining 150 who are expected to start in January 2014.
Responsible staff: Cynthia McCoy-Miller, Senior Deputy Director over Human Resources; Patricia Dennis, Division Chief over Training
The department states it is currently assessing the caseload levels for social workers who investigate allegations of child abuse and neglect and is examining its processes to streamline its investigations. (See 2013-406, p. 124)
To better ensure that inner-city regional offices are staffed by experienced social workers, the department should consider providing social workers with incentives to work in these areas or require them to remain in these offices for a period longer than the one year currently required.
The department has temporarily frozen transfers of social workers who work in inner-city offices. It has also notified future social workers, who will be assigned to inner-city offices, that they will be expected to remain in those offices for at least two years. Additionally, the department is attempting to provide financial incentives to social workers who work in inner-city regional offices. (See 2013-406, p. 124)
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)
To improve its process for placing children with a relative, the department should analyze the best practices used by other county child welfare services agencies for such placements. The department should then implement changes in its practices so that relatives and their homes are approved prior to placement, as required by state law.
As noted in past responses, DCFS has analyzed the processes of five adjacent counties and has not found LA County's practice to be materially different from other counties. However, the Department is also 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 is expected to result in all counties having greater uniformity in placement approval practices.
The Department has analyzed the processes of the five adjacent counties and has not found that LA County's approval practices and processes to be materially different from its neighbors. 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. Assessments of relative and Non-related Extended Family Members continue to be made as the need for child placements are determined. Further, increased emphasis is being placed on Family Finding efforts as staff have been assigned to expedite the speed in which possible relative placements can be secured.
DCFS is also piloting a new automated California Law Enforcement Telecommunications System (CLETS) process to speed up the results of criminal background checks. The initial pilot has shown that CLETS results are being returned within 30 minutes as opposed to 2 weeks through the manual process. The automated process should expedite the placement process with relative caregivers.
The Department requested placement policies from other counties (Ventura, San Bernardino, San Diego, Orange and Santa Clara counties). Upon review we determined that the policies did not differ from our own in material respects. In addition, our ASFA management provided refresher training on ASFA placement policies to workers in our regional offices. Training was completed in April 2013.
The department has made no indication that it intends to change its placement practices so that relatives and their homes are approved prior to placement of children.
The department's Adoption and Safe Families (ASFA) Division managers and representatives continue to participate in the southern counties' Relative Assessment Unit (RAU) monthly meetings, with the purpose of working with other counties to identify barriers and solutions to relative approval process challenges. During these meetings ASFA representatives are able to clarify relative approval policy issues with state policy experts. This forum has been utilized to clarify and liberalize policies in a standardized framework related to: shared zip codes, significant contact, simplified criminal waivers and new and pending laws.
County Counsel has remained instrumental in providing guidance on home approval dilemmas and on policy revisions. The County Counsel is utilized in the following manner:
1. Provide statutory interpretations to laws and liability implications when a home does not meet Health and Safety 1522 Regulations.
2. Provide consultation to ASFA managers and staff on the criminal waiver process.
3. Provide alternative strategies to bring homes into compliance without violating regulations.
4. Advocate and correspond with Department of Justice and the Department of Social Services relative to Senate and Assembly Bills, which may pose barriers to ASFA processes.
5. Provide legal training to the ASFA staff during monthly staff meetings.
6. Attend court meetings and mediate with the ASFA Division and courtroom county counsel.
Based on its response, the department does not appear to have analyzed the best practices used by other county child welfare services agencies when they make placements. Further, its practices continue to not ensure that it approves relatives and their homes prior to placing a child.
The department indicates that it researched the practices of five other counties but the department believes that its relative placement process conforms to regulations and has not made the changes we recommended. (See 2013-406, p. 124)
To ensure that social workers have as much relevant information as possible when placing children and licensing homes, the department should report requisite allegations of abuse or neglect to the Department of Justice and the Department of Social Services' licensing division.
The department implemented a process that will make it easier to submit the requisite reports to the Department of Justice. Instead of faxing reports, the department's employees can now click on an icon that will transmit the report electronically. Additionally, the department reminded staff regarding their responsibility for submitting these reports. (See 2013-406, p. 125)
To fully benefit from its death review process, the department should implement the resulting recommendations.
The Department's, Risk Management Division reviews hundreds of cases a year and has identifies case-practice, operational, systemic and best practice factors as a result of the ongoing review process. The Division has developed a "Lessons Learned" training series as a means to provide existing staff with actual but de-identified key factors and systemic issues that have impacted many of the reviewed number of cases. These Lessons Learned training series are discussed with Regional Administrators (RAs) during monthly meetings and provided as a 'Training for Trainers' briefing in order to prepare and inform the RAs of the key issues of concern. In turn management provides line staff with training opportunities to further discuss and incorporate the key factors into practice. These Lessons Learned training series are further archived on the Risk Management Division's website on the department's intranet system for easy reference by staff. Additinoally, the Lessons Learned are incorporated into the new DCFS Academy curriculum for new Children's Social Workers (CSWs). As part of the Academy simulated classroom experiences are conducted in a safe place through a simulation lab which provides "real life simulations and scenarios" for new hires to practice and develop new skills to employ in the field.
Implementation Date: Partly implemented. Full implementation expected to be completed by December 2013.
The Department has taken steps to disseminate "lessons learned" and implement recommendations from the critical incident/fatality review process. If a recommendation relates to a change in policy, the Department revises the policy as appropriate. Sometimes, the recommendation requires a practice change and recommends notice to staff or additional training of staff. If the recommendation relates to what appears to be a systemic practice issue, the Department has developed a training/communication plan designed to implement those recommendations as described below.
Beginning in August 2013, the Department started using actual (de-identified) fact scenarios from actual cases where there was a critical incident or fatality. Specifically, these fact scenarios form the basis of simulation training provided to our new Social Workers. In the simulation training, the worker participates in a simulated home call and/or investigation wherein their response is reviewed and critiqued by training staff. The worker receives feedback along with a tape of their "performance."
Additionally, starting in December 2013, the Department will begin disseminating to managers, select de-identified fact scenarios of critical incident/fatality cases. The scenarios will call out practice lapses as identified in and recommended by the review process. Managers will review the scenarios and discuss practice lapses with their Social Workers.
Responsible staff: Maryam Fatemi and Dawna Yokoyoma, Deputy Directors over the Service Bureaus; Patricia Dennis, Division Chief over Policy and Training; Francesca LeRue, Division Chief over Risk Management Division
The department agrees with this recommendation and will continue to improve its death review process by providing quarterly reports to the Board of Supervisors regarding corrective action plans resulting from administrative review roundtable discussions (administrative review). In fact, the department has been providing to the Board of Supervisors the results and actions taken following each administrative review. Previously, the department's Risk Management Division provided the Board deputies with draft versions that were not finalized due to the potential for liability. Currently, Risk Management includes the case, operational, and systemic issues including action plans to enhance policy and practice in the final report sent to County Counsel which is shared with the Board of Supervisors.
The Risk Management Division has consulted with County Counsel on how to share "lessons learned" with line staff while adhering to confidentiality restrictions. As such, deputy directors now receive a copy of the reports sent to the Board of Supervisors and the deputy directors utilize these reports to communicate with the associated line staff on case practice issues and policy violations. The Risk Management Division is currently conducting presentations of the fatality reporting process at each regional offices and will be done by June 2013. Internal Affairs, Critical Incident/Child Fatality, and Child Abuse Child Index (CACI) presentations will follow.
Although the department has taken steps to provide greater access to its child death reviews, its response does not indicate that it has taken specific steps to implement recommendations resulting from those reviews.
The department is working with its legal counsel to determine how it can best implement this recommendation. (See 2013-406, p. 125)
To provide effective leadership, the director should form a stable executive team by filling the department's chief deputy director, senior deputy director, and other deputy director positions.
In 2012 the department filled the Senior Deputy Director, Executive Assistant and, as a one-year assignment, the Director of Program Development and Strategic Initiatives. In January 2013, as the Department's reorganized structure neared finalization, the Director appointed two permanent Deputy Directors, one over the newly formulated Services Bureau 2 and the other over the newly formulated Specialized Response Bureau. The Chief Deputy Director, Fesia Davenport, was also identified and reported in early March 2013. With the Chief Deputy Director's appointment, the Director has completed the formation of the Executive Team.
The director has filled the senior deputy director, director of program development and strategic initiatives, and executive assistant positions. The director also indicated that he plans to fill the other positions after a planned reorganization occurs. (See 2013-406, p. 125)
To create and communicate its philosophy and plans, the department should complete and implement its strategic plan.
The department's strategic plan was finalized and released to all staff and stakeholders on September 28, 2012. The plan includes three goals, 12 strategies and 50 objectives developed to move the department towards its identified vision and mission. Related objectives were grouped together resulting in 32 objective teams, and team leads were identified for each team. In early November 2012, the director solicited participation on these teams from staff throughout the department. Staff response to this solicitation was very good, as over 230 staff expressed an interest in participating on one or more teams. On January 8, 2013, a kick-off meeting was held for the objective team leads who reviewed staff interest and identified those with the necessary expertise and experience to participate as members of their teams.
Objective team leads were provided with process management training through the Lean Six Sigma Program and have begun working with their teams to identify steps to move forward in meeting their objectives. The Director of Program Development and Strategic Initiatives (recently re-titled the Director of the Bureau of Organizational Support Services) reports directly to the department's director. She and her team provide ongoing assistance to the objective team leads and are responsible for monitoring department-wide implementation of the strategic plan.
The department distributed the completed strategic plan in September 2012, which contained 50 objectives. To implement these objectives, the department will create action teams that consist of executive sponsors and project managers. (See 2013-406, p. 125)
Agency responses received after June 2013 are posted verbatim.