Director Perspective: Time to Scrap the CFSR
By Tom Rawlings, former Director of Georgia’s Division of Family and Children Services
Read and download as a PDF here.
Over $11 billion each year.
That’s how much federal taxpayers provide annually to state child welfare agencies. Ensuring those funds are used to advance their intended goals is critical.
The public needs to know– are these agencies:
● Keeping children safe from abuse and neglect;
● Respecting the rights of families, foster families, and providers;
● Caring well for children in foster care;
● Providing due process and transparency; and
● Moving quickly to help foster children safely return home or find a stable, permanent home?
Unfortunately, federal oversight of those expenditures has in practice become little more than bureaucracy theater.
The chief tool the federal Children’s Bureau has been using for the past 25 years -- the Child and Family Services Review (CFSR), isn’t up to the task.
Performative bureaucratic box-checking neither provides a reliable gauge of child welfare system success nor focuses agency leaders on areas for potential improvement. A simpler, more focused approach could.
The Flaws in Federal Child Welfare Oversight
As ACF Assistant Secretary for Family Support Alex Adams looks to streamline government while ensuring responsible use of taxpayer dollars, he has an opportunity to retool this system to be more responsive.
Here are the key concerns that merit consideration for what comes next.
Too Broad to Be Useful
The CFSR process tries too hard to measure everything– from investigation timelines to case planning participation to IT system usability– seeking to capture and report on so many issues that it prioritizes nothing.
CFSR Final reports span hundreds of pages, a mishmash of statistical data, reviewers’ subjective judgments, and personal stakeholder observations that leave child welfare leaders with little actionable intelligence.
In my years as Georgia’s system ombudsman and child welfare agency director, CFSR reports never told me things I didn't already know from other sources.
Competing Signals, Contradictory Demands
The CFSR process, especially due to its broad and general scope, often creates more noise than clarity.
Consider that child welfare agencies are also accountable to oversight and directives from state legislatures and Governors, and are regularly provided feedback via media reports, advocacy groups, state auditors, state child welfare ombuds offices, and the public.
Over the past two decades, well over 30 jurisdictions have struggled to meet the CFSR standards while also answering to federal judges overseeing class-action litigation whose consent decrees carry their own requirements– which often conflict with CSFR.
Process Over Outcomes Invites Gaming
The CFSR review process is often so focused on process over outcome, such as questions on whether the agency has timely investigated a report of maltreatment.
To improve my state’s scores, I could simply redefine the types of cases my agency assigns for a child maltreatment investigation and increase my use of alternative responses that do not classify a child as a victim of maltreatment.
Neither change answers the real question: is the state agency actually protecting children?
A Better Path Forward
Here's what I learned as an agency leader about the key opportunities to bring responsive accountability to oversight data
Focus on Outcome Data Over Process
We already have data within NCANDS and AFCARS that could support a focus on outcomes rather than process measures.
By connecting those data to individual children, data could shift from the current process metrics to outcomes-oriented ones like:
● Is the state screening out too many child maltreatment reports?
● How often are children moving between placements and why?
● How many children are aging out without a permanent home, and why?
Use Data to Ask Questions
For years, Georgia’s Court Improvement Project hosted stakeholder meetings where staff presented local NCANDS and AFCARS data.
Our role was not to tell the jurisdiction whether they were doing well or poorly, but to ask the judges, attorneys, agency personnel, CASAs, foster parents, and others in attendance the simple question: what does this statistic mean for how your community protects vulnerable children?
Right now federal oversight often editorializes on the meaning behind the data rather than ensuring its accuracy and driving the right accountability-focused questions.
This approach would position ACF to use data-driven questions for requiring states to justify their results.
Simplify and Align
If you measure process, you get process. Outcome measures encourage outcomes.
Critically, accountability rests on the connection of those measures to outcomes the child welfare agency actually controls.
For example the current measures of mental health and educational services bring in dependency on other state agencies' work.
This obscures more than it illuminates about outcomes from the Child Welfare Agency.
As the Bipartisan Policy Center’s Child Welfare Financing and Accountability Task Force Blueprint reiterates, focusing on fewer measures and ensuring those measures are accurately reported may be more effective than the current CFSR.
Reward Success
Currently, expensive, time-consuming reviews result in threats that the federal government will withhold funding, followed by a “program improvement plan” to delay that penalty.
After 25 years, the CFSR has never rewarded success or innovation.
Tying extra resources to meeting key oversight goals, particularly on outcomes, could change that.
Eliminating federal oversight isn’t an option–it can play a critical role in helping ensure child welfare agencies are protecting children and being good stewards of federal dollars.
In my 25 years in this field, I've changed a lot as I've learned and grown.
Over that same period, the CFSRs have remained stubbornly persistent.
Leaders across the field know what would move the needle. Are we ready to move forward on it?