New York City's Administration for Children's Services (ACS) should improve oversight to ensure that non-profit agencies that place foster children are doing home visits and other critical functions required to protect those children, according to an audit released today by State Comptroller Thomas P. DiNapoli.

"Children in foster care must be closely looked after by city officials," DiNapoli said. "ACS can step up its oversight to make sure these children are being checked on regularly by those entrusted with managing their care and are safe from harm."

In New York City, ACS is responsible for ensuring the safety of children who are placed in foster care. The general rule in foster care is to place the child in the least restrictive, most family-like environment appropriate to the child's needs. Placement is usually with relatives or with foster parents approved by not-for-profit, community-based voluntary agencies.

The agencies are required to conduct regular visits to children in the care of foster parents. The interactions and observations are supposed to be documented as progress notes in CONNECTIONS – a statewide computer system for recording child welfare information maintained by the State Office of Children and Family Services. Both ACS and the non-profit agencies are also required to complete Family Assessment Service Plans (FASPs) for each foster child that help support case assessment by determining if the needs of the children are being met.

In 2009, ACS instituted a new oversight structure in which day-to-day case management was delegated to the non-profit agencies. This approach was intended to put direct supervision close to the child and the family, and to give the agencies expanded authority to make case management and other decisions on behalf of families.

For the period of July 1, 2014 through Aug. 31, 2016, ACS contracted with 32 agencies and reimbursed them for the care provided to foster children. The city spends more than $500 million annually for foster care services. There were nearly 9,000 children in foster care in New York City in city fiscal year 2017.

DiNapoli's auditors selected five non-profit agencies and reviewed documentation for a sample of 48 foster children and their foster parents in their case files to determine if required contact visits were conducted and if progress notes were recorded in CONNECTIONS in a timely manner.

DiNapoli's auditors found ACS did not ensure that agencies conducted visits and recorded them in a timely manner. For the sample of foster children and their foster parents, auditors found that the required two contact visits per month to 30 of the foster children (63 percent) and 36 of the foster parents (75 percent) were not conducted during the first 90 days after placement, as required. In addition, there is no evidence that 16 of the foster children (33 percent) and 18 of the foster parents (38 percent) were visited, as required, after the initial 90 days.

Auditors found CONNECTIONS does not have a built-in feature to allow agencies to summarize pertinent details related to foster care cases. This makes it difficult for agency managers or ACS staff to quickly identify issues or patterns that need correcting. Further, auditors found staff at the agencies have expressed concerns about certain deficiencies in CONNECTIONS, including the lack of a general search function, the inability to record incidents of abuse or neglect in an area separate from progress notes, the inability of case planners and their supervisors to sign off on progress notes and no reminders that progress notes are past due.

Auditors also found ACS has not established a standard for when progress notes should be entered in CONNECTIONS. The five contracted agencies, however, set standards for their employees to enter progress notes, ranging from three to 15 days of a contact visit.

Using 15 days as the standard, auditors determined that:

• For the 48 foster children and their foster parents, 92 of the 352 progress notes for the first 90 days (26 percent) and 151 of the 732 progress notes (21 percent) for the period thereafter were entered more than 15 days late.
• Using the 30-day recording period, the recommended maximum, 56 of the 352 progress notes (16 percent) for the first 90 days exceeded the benchmark, and 54 of the 732 progress notes (7 percent) for the period thereafter were entered more than 30 days late.

Additionally, initial and comprehensive follow-up FASPs, which assess how foster children and their foster families are doing, were often completed late. For example, initial FASPs for 18 of the 45 children (FASPS were unavailable for 3 children as their cases were closed) were completed after the required 30 days, and comprehensive FASPs for 22 of the 45 children were completed after the required 90-day period.

DiNapoli recommended ACS:

• Ensure that agencies conduct the required casework contact visits with foster children and their foster parents during the initial placement period and throughout the children's placement in foster care;
• Establish a time frame for agencies to complete and enter progress notes related to case planners' contact visits and ensure that agencies are complying with this requirement;
• Include compliance with case planners' contact visit requirements and the timeliness of progress notes as factors in an agency's scorecard metrics; and
• Work with OCFS to improve CONNECTIONS.

ACS officials' response is included in the report.

Read the report, or go to: http://www.osc.state.ny.us/audits/allaudits/093018/sga-2018-16n2.pdf

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