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									                                                                                                  CFSR PEP                                                                                         DRAFT
     FEDERAL COMMENTS AT EXIT                                    FEDERAL REPORT                                           ACTION STEPS
             August 2003                                                                                                                                             SELECTED ACTION STEP(S)/
                                                                                                                                                                           RATIONALE
Item 1: Timeliness of initiating investigations.

Federal debriefing comments:                       Rated as area needing improvement based on the         1. Clarify CPS intake responsibilities,              1. Update, clarify, and streamline Child
Timeliness of investigations generally affected    finding that 39% of the applicable cases (9 of 23),       procedures, and decisions.                           Protective Services (CPS) Investigation
delays in assigning cases resulting in delayed     DCFS did not initiate a response to maltreatment          Tasks: Clearly define criteria for screening         Standards and other policies related to
face-to-face contact as prescribed by screening    report within the required timeframes. In one of          (screen in/out) and incorporate into CPS:            initial assessment, including investigation.
decision.                                          the 2 cases classified as “urgent”, the caseworker        • Investigation Standards (Child Welfare             Task: Clarify CPS intake
Case specific analysis:                            did not initiate a response for 2 days. In the other          Handbook)                                        responsibilities.
• 4 cases cited face-to-face contacts as an area   case, there were 2 maltreatment reports. For 1            • Review the criteria for determining                Clearly define criteria for screening (screen
    of concern. (3 In Home Care (IHC) & 1 Out-     report, the caseworker did not establish face-to-             response times and revise, if needed.            in/out).
    of-Home Care (OHC))                            face contact for 7 days; for the other, contact was           (CPS Investigation Standard/Child                Review the criteria for determining response
• 3 cases noted that a case was “not acted upon    not established for 12 days. The remaining 7 cases            Welfare Handbook)                                times and revise, if needed. (CPS
    in the appropriate timeframe”, contact “not    involved lower priority maltreatment reports           2. Update, clarify, and streamline current              Investigation Standard/Child Welfare
    made within the prescribed standard” or        requiring a response within 2-5 days. For these           standards and other policies related to initial      Handbook)
    there were “delays between assignment and      cases, the response was delayed from 12-20 days,          assessment, including substantiation.             2. Perform quality assurance by using
    face-to-face contact” (2 IHC & 1 OHC)          and in 1 case, face-to-face contact was never             Tasks: Revise CPS Investigation Standards            WISACWIS to determine whether
• 2 cases mentioned need to engage parent(s)       established.                                              • Clarify if and when supervisors can                timeliness requirement was met.
    in plan development and case planning.                                                                       deviate from CPS Investigation Standards
                                                   This item was rated as a strength in 69% of            3. Eliminate the mandated responsibility to             Would not help with timeliness but relevant
                                                   applicable Milwaukee cases, compared to 50% of            investigate non-caregiver maltreatment.              to Item 2.
                                                   Kenosha cases and 33% of Outagamie cases.                 Tasks: Treat mutual sexual contact as a child
                                                                                                             welfare referral instead of a CPS referral.
                                                                                                             • Pursue statutory change to eliminate
                                                                                                                 investigations of non-caregiver
                                                                                                                 maltreatment.
                                                                                                             • Perform quality assurance by using
                                                                                                                 WISACWIS to determine whether
                                                                                                                 timeliness requirement was met.
                                                                                                          4. Develop workload management analysis.                Part of overarching strategies
                                                                                                          5. Define staff/caseload ratios.
                                                                                                          6. Define supervisory/staff ratios.
                                                                                                          Source: Strategies 3 and 4


                                                                                                                                                               DRAFT            02/06/04

                                                                                                          1
     FEDERAL COMMENTS AT EXIT                                   FEDERAL REPORT                                          ACTION STEPS                                SELECTED ACTION STEP(S)/
                                                                                                                                                                          RATIONALE
Item 2: Repeat maltreatment

Federal debriefing comments:                       Assigned an overall rating of area needing           1. Define the scope of CPS and child welfare:        Action Steps 1 and 2 relevant to Item 1.
• Variation exists in how report screening         improvement despite a rating of Strength in 95% of      whom the system must serve.
   decisions and case findings (i.e.               the cases (37 of the 39 applicable cases) because       Tasks: Clarify the conditions, procedures,
   substantiation) are made and direct             Wisconsin’s rate of maltreatment recurrence for         requirements and responsibility for opening
   subsequent interventions.                       2001 is 6.9% vs. the national standard of 6.1% or       and closing CPS cases.
• Child protective services practice needs to be   less.                                                   • Develop a clear definition of in-home
   less incident-based and focus more on the                                                                   services.
   underlying risks within families.                                                                       • Clarify that the Ongoing Services
                                                                                                               Standards apply to in-home cases,
Case specific analysis:                                                                                        including agency managed, agency-
• In 2 cases (both IHC), repeat maltreatment                                                                   funded/provider-managed, and family-
   was reported.                                                                                               managed cases, and clarify how this
                                                                                                               information is recorded in WISACWIS.
                                                                                                           (Move this latter part to data strategy).         1. Update, clarify, and streamline current
                                                                                                        2. Clarify CPS intake responsibilities,                 standards and other policies related to initial
                                                                                                           procedures and decisions.                            assessment, including substantiation.
                                                                                                           Tasks: See tasks under 1 in Item 1                   Tasks: See tasks under Action Step 2 in
                                                                                                           (Timeliness of investigations.)                      Item 1.
                                                                                                        3. Update, clarify, and streamline current           2. Eliminate the mandated responsibility to
                                                                                                           standards and other policies related to initial      investigate non-caregiver maltreatment.
                                                                                                           assessment, including substantiation.                Tasks: Treat mutual sexual contact as a
                                                                                                           Tasks: See tasks under Action Step 2 in Item         child welfare referral instead of a CPS
                                                                                                           1.                                                   referral.
                                                                                                        4. Eliminate the mandated responsibility to             • Pursue statutory change to eliminate
                                                                                                           investigate non-caregiver maltreatment.                  investigations of non-caregiver
                                                                                                           Tasks: See tasks under the same action in                maltreatment.
                                                                                                           Item 1.                                              • Perform quality assurance by using
                                                                                                        5. Assure that safety is a basis for CPS                    WISACWIS to determine whether
                                                                                                           involvement.                                             timeliness requirement was met.
                                                                                                           Tasks: Recommend changes to Chs. 48 and
                                                                                                           938 to recognize safety as a basis for court
                                                                                                           involvement.

                                                                                                                                                              DRAFT           02/06/04

                                                                                                        2
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                RATIONALE
                                                •  Provide recommended language for              Action Step 5 will be achieved with change in
                                                   changes to tribal children’s codes.           standards.
                                               • Review and revise, as necessary, the
                                                   Ongoing Services Standards to assure that
                                                   safety and risk assessment and parental
                                                   protective capacities are the focus of
                                                   intervention.
                                            6. Clarify the procedures for re-referrals on open   Part of Action Step 1
                                               cases.
                                               Tasks: Define the procedures for handling re-
                                               referrals.
                                               • Determine the data entry requirements.
                                            Source: Strategy 4




                                                                                                 DRAFT            02/06/04

                                            3
     FEDERAL COMMENTS AT EXIT                                    FEDERAL REPORT                                            ACTION STEPS                                SELECTED ACTION STEP(S)/
                                                                                                                                                                             RATIONALE
Item 3: Services to family to protect children
in home and prevent removal.
Federal debriefing comments:                      Rated as area needing improvement because in             1. Assure that safety and risks are the basis of      1. Assure that safety and risk are the basis for
• Adequate services exist statewide to address    16% of the cases (6 of 37 applicable cases), DCFS            CPS involvement.                                     CPS intervention (with a clear
    the safety of children and prevent the        did not make diligent efforts to provide the                 Tasks: Review and revise, as necessary, the          understanding of the difference between
    removal of children from the home.            necessary services to maintain children safely in            Ongoing Services Standards to assure that            safety plan and a case plan.
• Regular caseworker contact with families is     their own homes. In 4 cases, services offered were           safety and risk assessment and parental              Tasks:
    important to prevent recurrence of            not adequate to address risk for all children in the         protective capacities are the focus of               a) Review and revise, as necessary, the
    maltreatment.                                 family. In 2 cases, no effort was made to provide            intervention throughout the life of the case.            applicable standards to assure that
• Some families receiving services have           services to prevent the child’s placement in foster      2. Enhance collaborative safety planning and                 safety, risk assessments, and parental
    histories of multiple referrals for alleged   care or re-entry into foster care after reunification.       case planning with families.                             protective capacities are the focus of the
    maltreatment indicating continued risk and                                                             3. Enhance efforts to identify, locate, and engage           intervention throughout the life of the
    child safety issues.                          This item was rated as a strength in 100% of                 family members.                                          case.
                                                  applicable cases in Kenosha, 80% of the cases in         4. Expand the use of informal community                  b) Assure that the standards are
Case specific analysis:                           Milwaukee and 75% in Outagamie.                              resources in supporting families.                        consistently applied, through the
• 2 cases, children were removed w/o a                                                                     5. Increase the use of crisis service response               provision of ongoing training and
   complete initial assessment/documentation                                                                   teams.                                                   technical support.
   of maltreatment.                                                                                        6. Collaborate with other disciplines to                 c) Provide training and technical assistance
• 3 cases, no in-home services were offered to                                                                 provide/promote cross-systems training.                  to staff to increase their knowledge on
   address the family needs.                                                                               7. Increase staff knowledge on accessing/                    accessing and use of natural community
• 1 case services were not offered to address                                                                  utilizing natural community supports for                 supports for families, both formal and
   mental health needs related to safety.                                                                      families both formal and informal as it relates          informal, as it related to safety
• 2 cases, safety assessments were not                                                                         to safety.                                               assessment and planning.
   completed.                                                                                              8. Collaborate closely with other                        d) Link identifying, assessing and
                                                                                                               stakeholders/providers (schools, police, etc.)           responding to issues of domestic
                                                                                                               to monitor stability of placements (both in and          violence to the CPS process through
                                                                                                               out of home).                                            standards, policies, procedures, training,
                                                                                                           9. Promote an enhanced, statewide, and                       and technical assistance.
                                                                                                               coordinated community response to domestic
                                                                                                               violence.                                         Action Steps 2 & 3 & 11 added to Item 18.
                                                                                                           10. Link identifying, assessing, and responding to    Action Step 4 incorporated into task c.
                                                                                                               issues of domestic violence to the CPS            Action Steps 5, 8 & 9 to be included in 5 year
                                                                                                               process through standards, policies and           plan.
                                                                                                               procedures.                                       Action Step 6 has minimal impact.
                                                                                                                                                                 Action Step 7 is in task c.
                                                                                                                                                                 DRAFT            02/06/04

                                                                                                           4
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                                 SELECTED ACTION STEP(S)/
                                                                                                               RATIONALE
                                            11. Develop policies and guidelines regarding
                                                procedures for determining fatherhood and
                                                safely involving fathers and their relatives and
                                                incorporate into appropriate training.
                                            12. Determine reasons for lack of complete             Part of overarching strategy.
                                                documentation and pursue appropriate actions.
                                                Task: Improve consistency of documentation
                                                related to risk and safety assessment and
                                                safety plans.
                                            Sources: Strategies 1, 4, 5, and 6




                                                                                                   DRAFT            02/06/04

                                            5
     FEDERAL COMMENTS AT EXIT                                    FEDERAL REPORT                             ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                                    RATIONALE
Item 4: Risk of harm to child(ren.)

Federal debriefing comments:                       Rated as strength in 42 (86%) of the 49 applicable
• Risk of harm ratings are lower for in-home       cases. Reviewers determined that DCFS was
     cases than for placement cases.               effective in addressing the risk of harm to the
• Variation exists in how report screening         children.
     decisions and case findings (i.e.
     substantiation) are made and affect
     subsequent interventions.
Case specific analysis:
1 case, a risk assessment was not completed.
1 case, a safety plan was not done although risk
factors were evident. Case closed prematurely.
1 case, a child whose parents’ rights were
previously terminated was contacted by
biological relatives despite “no-contact”
restriction.




                                                                                                                           DRAFT     02/06/04

                                                                                                        6
     FEDERAL COMMENTS AT EXIT                                    FEDERAL REPORT                                         ACTION STEPS                              SELECTED ACTION STEP(S)/
                                                                                                                                                                        RATIONALE
Item 5: Foster Care Re-entries

Federal comments at debriefing:                    Rated as area needing improvement. Although           1. Create a definition of “re-entry to care.”      1. Need to further analyze and understand
• State implementation of the ASFA has             case reviews found that in 100% of the applicable        Tasks: Clarify and/or develop data entry           cause of foster care re-entries.
   improved the achievement of permanency.         cases (5 of the 25 foster care cases), children did      requirements so we don’t create multiple        2. Write transition plan which clearly
• Concurrent permanency planning is in place,      not re-enter foster care within 12 months of             providers, including changes from foster home      delineates extended home visit from
   but additional efforts are needed to pursue     discharge from a prior episode, the data from the        to treatment foster home. (Changes in              reunification.
   concurrent permanency goals effectively.        State Data Profile indicate that Wisconsin’s re-         WISACWIS, training and monitoring)              3. Clarify data requirement for reporting trial
Case specific analysis:                            entry rate for FY 2001 is 25.5% which exceeds the     2. Clarify or develop policy related to family        home visits, respite care and other factors
• The case review resulted in no specific          national standard of 8.6% or less.                       reunification, including allowing shared           affecting re-entries.
   findings because all cases were scored as                                                                parenting and trial home visits.
   strengths or not applicable. The case review    The re-entry pattern differs considerably between        Task: Revise Ongoing Services Standards and
   results are a discrepancy and this is an area   Milwaukee and the balance of the state. State data       Guidelines.
   needing improvement based on the statewide      shows a 10% re-entry for Milwaukee after 12           3. Facilitate placement with relatives when
   data.                                           months and a 21% re-entry for the balance of the         appropriate.                                    No impact on re-entry.
                                                   state after 12 months.                                   Task: Develop policy and procedure to clarify
                                                                                                            the role of fathers and other family members
                                                                                                            in concurrent planning and identifying
                                                                                                            relatives as placement resources, and assure
                                                                                                            documentation of these efforts.
                                                                                                         Sources: Strategy 4 and 6




                                                                                                                                                            DRAFT            02/06/04

                                                                                                         7
     FEDERAL COMMENTS AT EXIT                                  FEDERAL REPORT                                          ACTION STEPS                                 SELECTED ACTION STEP(S)/
                                                                                                                                                                          RATIONALE
Item 6: Placement Stability

Federal comments at debriefing:                  Rated as an area needing improvement. Although       1. Increase the use of crisis service response          Action Step 1 reworded.
• Children are typically placed with             data from the State Data Profile for 2001 indicate       teams.                                              1. All children in OHC must have a crisis plan
   appropriate providers in their community.     that the percentage of children experiencing no      2. Collaborate closely with other                           that includes information on who to contact
• Placements are generally stable.               more than 2 placements in their first 12 months in       stakeholders/providers (schools, police, etc.)          and how to access the family and/or foster
Case specific analysis:                          foster care (93.8%) meets the national standard of       to monitor stability of placements (both in and         home support system, when needed.
• 3 cases had reviewer comments about a child    86.7% or more, case reviewers determined that in         out of home )                                       2. Increase monitoring by supervisors,
   experiencing multiple OHC placements.         24% of the applicable cases (6 of 25), children      3. Examine ways to expand resources and                     permanency plan reviewers and judges to
• 1 case cited that the foster parents did not   experienced placement changes during the period          funding for foster and adoptive parent                  ensure that permanency plans address the
   have enough support from the county and       under review that did not promote attainment of          recruitment statewide.                                  support/service needs of children and care
   shelter care was being used as a transition   their goals or meet their treatment needs.           4. Consider multi-county/tribe foster care                  givers.
   (and not being counted as a placement.)                                                                coordinators and shared foster homes to
                                                 The child’s placement change resulted from:              increase resources and ability to match kids        Action Steps 3, 4, 5, 6, 7, & 8 to be included in
                                                         • lack of adequate placement resources           with foster parents.                                5 year plan.
                                                             (2 cases)                                5. Review foster care rate and examine ways to
                                                         • lack of DCFS efforts to support a              reflect the level of expertise of foster parents.   Action Step 9 has minimal impact.
                                                             placement (1 case)                       6. Recommend an increase in basic foster care
                                                         • insufficient assessments of the child’s        rate.                                               Action Step 10 is more relevant to Item 22.
                                                             needs resulting in inappropriate         7. Provide respite for all foster care providers.
                                                             placements (2 cases)                     8. Expand resources and funding for training.
                                                         • instability of current placement (1        9. Facilitate placement with relatives, when
                                                             case)                                        appropriate.
                                                                                                      10. Develop a process for determining when
                                                                                                          children in out- of- home care need mental
                                                                                                          health assessments.
                                                                                                      Source: Strategy 1, 2 and 4.




                                                                                                                                                              DRAFT            02/06/04

                                                                                                      8
     FEDERAL COMMENTS AT EXIT                                      FEDERAL REPORT                                            ACTION STEPS                                SELECTED ACTION STEP(S)/
                                                                                                                                                                               RATIONALE
Item 7: Permanency goal for child.
Federal comments at debriefing:                     Rated as an area needing management based on the         1. Develop clear policies and practice guidelines     1. Revise investigation and ongoing services
Changes in permanency goals were appropriate        finding that in 40% of the cases (10 of 25                  to implement concurrent planning.                     standards and incorporate in Ch. HFS 44
for children.                                       applicable cases), reviewers determined that DCFS           Task: Revise ongoing services standards and           clearer requirements on the implementation
Case specific analysis:                             had not established an appropriate goal for the             incorporate in Ch. HFS 44 clearer                     of a concurrent permanency goal.
Specific problems with cases rated as needing       child in a timely manner                                    requirements on the implementation of a               Tasks:
improvement:                                                                                                    concurrent permanence goal.                           • Develop a policy/procedure (Ch.44) to
• In 4 cases, issues surrounding the goals were     At the time of the review, 19 of the 25 children had     2. Improve timeliness of decisions regarding                 begin concurrent planning consultation
    encountered. For example, a lack of clarity     been in foster care for 15 of the most recent 22-           TPR and adoption.                                         earlier in the case planning process.
    about the goals, not pursuing permanent         months. TPR had been filed in only 6 of the 19              Task: Develop a policy/procedure (Ch.44) to           • Assure conditions for return are clear to
    goals before utilizing long term foster care,   cases, For the 13 cases for which TPR had not               begin concurrent planning consultation earlier            family and providers and based on
    or not fully assessing situation to establish   been filed, a reason for not filing had been entered        in the case planning process.                             safety.
    appropriate goals.                              in 5 of the case files. In 8 case files, no reason was   3. Assure conditions for return are clear to             • .Clarify definitions, procedures and
• In 4 cases, issues around filing for TPR per      provided for why DCFS did not seek TPR.                     family and providers.                                     content of initial and subsequent
    ASFA in a timely manner or following                                                                        Task: Incorporate into Ongoing Services                   permanency plans, permanency plan
    ASFA requirements were reported.                                                                            Standards (Child Welfare Handbook) the                    reviews, and permanency plan hearings.
                                                                                                                requirement that case permanency plans be             • Send numbered memo to CPS/Juvenile
                                                                                                                congruent with court ordered return                       Justice agencies.
                                                                                                                conditions.                                           • Director of State Courts Office will send
                                                                                                             4. Clarify definitions, procedures and content of            same numbered memo to court
                                                                                                                initial and subsequent permanency plans,                  commissioners, judges, corporation
                                                                                                                permanency plan reviews, and permanency                   counsel, district attorneys, and juvenile
                                                                                                                plan hearings.                                            court clerks.
                                                                                                                Tasks: Send numbered memo to                          • Information related to defining “date of
                                                                                                                CPS/Juvenile Justice agencies.                            removal” and “home.”
                                                                                                                Director of State Courts Office will send same        • Improve the timeliness and quality of
                                                                                                                numbered memo to court commissioners,                     six-month permanency plan reviews.
                                                                                                                judges, corporation counsel, district attorneys,
                                                                                                                and juvenile court clerks.
                                                                                                                Information related to defining “date of
                                                                                                                removal” and “home.”
                                                                                                                Improve the timeliness and quality of six-
                                                                                                                month permanency plan reviews.



                                                                                                                                                                   DRAFT           02/06/04

                                                                                                             9
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                              SELECTED ACTION STEP(S)
                                                                                                                RATIONALE
                                               Include in Ch.HFS 44:                               Include in Ch.HFS 44:
                                                  • Additional information on the purpose          • Additional information on the purpose
                                                      and practice issues related to                   and practice issues related to
                                                      permanency plan reviews.                         permanency plan reviews.
                                                  • Requirement that agencies provide              • Requirement that agencies provide
                                                      reasonable efforts to involve families           reasonable efforts to involve families in
                                                      in permanency plan reviews.                      permanency plan reviews.
                                                  • Clarification on who can serve on              • Clarification on who can serve on
                                                      administrative panels                            administrative panels
                                                  • Improve consistency in timeliness and          • Improve consistency in timeliness and
                                                      quality of twelve-month permanency               quality of twelve-month permanency
                                                      planning hearings.                               planning hearings.
                                                  • Include in Ch, HFS 44 agency actions            • Include in Ch, HFS 44 agency actions
                                                      needed to support the court finding of            needed to support the court finding of
                                                      “contrary to the welfare” and                     “contrary to the welfare” and
                                                      “reasonable efforts” or “active efforts.”         “reasonable efforts” or “active efforts.”
                                            5. Increase family participation in permanency          • Increase family participation in
                                               planning                                                   permanency planning
                                               Task: Discuss the full range of permanency           •     Discuss the full range of permanency
                                               options with families when their children                  options with families when their
                                               come into care.                                            children come into care.




                                                                                                  DRAFT          02/06/04

                                            10
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                RATIONALE
                                            5. Enhance efforts to identify, locate and engage        • Bring in permanency consultants earlier
                                               family members.                                          and no later than 6 months.
                                               Task: Ensure that efforts to identify all family
                                               members and provide them with opportunities
                                               to be involved are made throughout the life of
                                               the case. Incorporate into the Investigation
                                               and Ongoing Services Standards.
                                               Identify and examine existing policies that
                                               present barriers to full involvement of paternal
                                               relatives in the case process when paternity
                                               has not been fully adjudicated.
                                               Develop policy/procedures to clarify how to
                                               use paternal relatives as placement resources
                                               when paternity is not established.
                                               Review and revise policies on what
                                               information can be shared with relatives so
                                               they can be prepared to care for children or
                                               identify other placement resources.
                                            6. Provide additional reports and make reports        Action Step 6 is relevant to Item 15.
                                               available in more useful formats.
                                               Task: Produce information on permanency            Move Action Steps 7 & 8 to Systemic Factor.
                                               for children.
                                            7. Provide child welfare workers with further         2. Develop informational materials for
                                               training on federal requirements.                     permanency plan reviewers.
                                               Task: Provide training for adoption staff and      3. Explore other states’ concurrent planning
                                               county staff on permanency planning,                  model.
                                               concurrent planning and permanency goals
                                               other than adoption to facilitate the adoption
                                               role as permanency consultants.
                                            Source: Strategy 3, 4, 5, and 6.




                                                                                                  DRAFT            02/06/04

                                            11
     FEDERAL COMMENTS AT EXIT                                     FEDERAL REPORT                                       ACTION STEPS                              SELECTED ACTION STEP(S)/
                                                                                                                                                                       RATIONALE
Item 8: Reunification, guardianship, or
permanent placement with relatives.
Federal comments at debriefing:                    Rated as an area needing improvement based on       1. Increase access to services such as mental       1. Improve documentation and monitoring of
Strong emphasis is placed on reunifying children   the finding that in 54% of the cases (7 of 13          health and AODA to improve safety and               efforts to locate/involve relatives.
with their families as a primary permanency        applicable cases), DCFS had not made diligent          permanency.
goal.                                              efforts to attain the goal of reunification in a timelyTask: Increase transportation options for        Action Step 1 relevant to Item 17.
Case specific analysis:                            manner. In addition, data from the State Data          families and children to assure greater
Specific problems with cases rated as needing      Profile indicate that for FY2001, the percentage of    participation in services, court hearing, case   Actions Steps 2-5 addressed in Item 7.
improvement:                                       reunifications occurring within 12 months of entry     and permanency plan reviews, etc.
• 2 cases reflected a significant lapse of time    into foster care (71%) did not meet the national       Establish multi-agency or interdepartmental
    before a permanency goal was                   standard of 76.2% or more.                             workgroup to identify solution to problems
    achieved/changed.                                                                                     related to mental health services.
• For example, the reviewers commented that        The following barriers to achieving the goal of        Explore collaborative models on the local
    it was 3 years before the mother met court     reunification were identified by the reviewers:        level to expand mental health services on a
    ordered conditions and another stated that a        • mother’s failure to comply with services        regional basis.
    child was in care for 24 months with no goal        • mother’s inability to find adequate housing  2. Increase staff knowledge on
    achievement.                                            and employment                                accessing/utilizing natural and community
                                                        • the child’s desire to be adopted by foster      support to families both formal and informal.
                                                            parents rather than return home            3. Provide child welfare workers with further
                                                        • mother’s relapse of substance abuse             training on federal requirements.
                                                        • lack of desire of adoptive parents to take      Task: Provide training for adoption staff and
                                                            the child back following an adoption          county staff on permanency planning,
                                                            dissolution.                                  concurrent planning, and permanency goals
                                                   In 3 of the 7 cases, the reviewers determined that     other than adoption to facilitate the adoption
                                                   the goal was not appropriate either because none of    staff role as permanency consultants.
                                                   the parties involved wanted reunification or        4. Clarify or develop policy related to family
                                                   because the mother had not exhibited progress in       reunification, including allowing shared
                                                   making the necessary changes.                          parenting and trial home visits.
                                                                                                       5. Assure conditions for return are clear to
                                                   The item was rated as a strength in 50% of the 8       family and providers.
                                                   applicable cases in Milwaukee compared to 25% of       Task: Incorporate into Ongoing Services
                                                   the 4 cases in Kensoha. There was only 1 case in       Standards the requirement that case and
                                                   Outagamie and it was rated as a strength.              permanency plans be congruent with court
                                                                                                          ordered return conditions.


                                                                                                                                                           DRAFT            02/06/04

                                                                                                             12
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                             RATIONALE
                                            6. Facilitate placement with relatives, when
                                               appropriate.
                                               Task: Recommend statutory change in               Currently on DCFS legislative agenda.
                                               confidentiality laws so that relatives may have
                                               enough knowledge to care for the needs of a
                                               child or recommend other relatives who might
                                               be appropriate placement resources.
                                               Clarify current confidentiality laws and
                                               delineate what information can be shared with
                                               non-custodial parents.
                                               Develop policy and procedures to clarify the      Relevant to Item 15.
                                               role of fathers and other family members in
                                               concurrent planning and identifying relatives
                                               as placement resources, and assure
                                               documentation of these efforts.
                                                   • document activities to locate and
                                                        engage fathers
                                                   • clarify that concurrent planning
                                                        includes considering fathers and other
                                                        family members as possible option for
                                                        permanency.
                                               Pursue subsidized guardianship waiver.            Currently on DCFS legislative agenda.
                                            7. Increase family participation in permanency       Action Steps 7 & 8 covered in Item 7.
                                               planning.
                                               Task: Clarify that parents who are separated
                                               each can be considered as concurrent
                                               permanency option for reunification.
                                            8. Clarify the options for permanency including
                                               guardianship.
                                            Source: Strategy 1, 4 and 5




                                                                                                 DRAFT           02/06/04

                                            13
     FEDERAL COMMENTS AT EXIT
                                                                 FEDERAL REPORT                                            ACTION STEPS                                 SELECTED ACTION STEP(S)/
                                                                                                                                                                              RATIONALE
Item 9: Adoption

Federal comments at debriefing:                    Rated as an area needing improvement based on           1. Improve timeliness of decisions regarding          1. Improve timeliness of decisions regarding
• Adoptions of children in case have increased,    the following findings:                                    TPR and adoption.                                     TPR and adoption.
   but inconsistency exists in how adoption is           • Data from the State Data Profile indicate          Tasks: Develop a policy/procedure (Ch.44) to
   considered as a permanency goal.                          that the State’s percentage of finalized         begin concurrent planning consultation earlier     Covered in Item 7
• The process for termination of parental rights             adoptions in FY2001 occurring within 24          in the case planning process.
   has multiple factors resulting in delays.                 months of removal from home (21.2%)              Clarify authority to enable TPR prior to              •   Clarify authority to enable TPR prior to
Case specific analysis:                                      did not meet the national standards of           identification of adoptive resource.                      identification of adoptive resource.
Specific problems with cases rated as needing                32% or more.                                     DCFS issue policy/guidance on the                     • DCFS issue policy/guidance on the
improvement:                                             • In 50% of the applicable cases (3 of 6),           appropriate use of exceptions to the                      appropriate use of exceptions to the
• 4 of 7 cases were rated as needing                         reviewers determined that DCFS had not           reasonable efforts requirement.                           reasonable efforts requirement.
   improvement in this area.                                 made concerted efforts to achieve the            Incorporate exceptions to TPRs into Ch.44          Covered in Item 7
• One comment related to timeliness was                      goal of adoption in a timely manner.             and the Ongoing Standards.                            • Policy clarification from the state
   adoption goal established 9/00, 2nd case                                                                   Policy clarification from the state specifically          specifically regarding individuals or
   heard 9/01, still not achieved as of 8/03.      In 1 case, the goal of adoption was established at         regarding individuals or groups of children               groups of children that are “difficult to
                                                   the time of the child’s entry into foster care, but        that are “difficult to place” and “at risk.”              place” and “at risk.”
                                                   DCFS did not seek TPR until the child had been in       2. Increase family participation in permanency        Covered in Item 7
                                                   care for 12 months, and the court did not hear the         planning
                                                   case for another year due to the parent’s request for      Task: Work with parents to increase                2. Combine Foster Family Assessment and
                                                   a jury trial.                                              voluntary TPRs.                                       Adoptive Family Assessment.
                                                                                                           3. Improve and streamline the foster and
                                                                                                              adoptive home licensing processes.
                                                                                                              Task: Combine Foster Family Assessment
                                                                                                              and Adoptive Family Assessment.
                                                                                                           4. Streamline the TPR process.                        Include in 5-year plan
                                                                                                              Task: Evaluate the use of jury trials for TPR
                                                                                                              Consider use of specialized teams to assist
                                                                                                              counties in conduction TPR proceedings.
                                                                                                              Recommend that all biological and adoptive
                                                                                                              parents have public defenders assigned in
                                                                                                              CHIP cases.




                                                                                                                                                                 DRAFT            02/06/04

                                                                                                           14
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                             SELECTED ACTION STEP(S)/
                                                                                                               RATIONALE
                                            5. Provide child welfare workers with further       Covered in Item 7.
                                               training on federal requirements.
                                               Task: Provide training for adoption staff and
                                               county staff on permanency planning,
                                               concurrent planning, and permanency goals
                                               other than adoption to facilitate the adoption
                                               staff role as permanency consultants.
                                            Source: Strategy 2, 3, 4, and 5.




                                                                                                DRAFT       02/06/04

                                            15
     FEDERAL COMMENTS AT EXIT                                   FEDERAL REPORT                                            ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                                                                           RATIONALE
Item 10: Permanency goal of other planned
permanent living arrangement.
Federal comments at debriefing:                   Rated as an area needing improvement because            1. Consider the use of multi-county teams.           Include in 5 year plan.
• Other permanency options for older children     17% (1 of 6 applicable cases, reviewers determined         Task: Identify counties willing and able to
    are not consistently explored/rules out.      that DCFS had not made concerted efforts to                form teams to assist in TPR cases,
• Youth and foster parents are not aware of the   ensure that the child’s placement was stable and           independent living, foster parent recruitment,
    range of independent living services          that the child was receiving appropriate services. It      screening child abuse and neglect referrals,
    available.                                    was further determined that the child was not in a         etc.
Case specific analysis:                           stable long-term placement and there was no             2. Identify foster/adoptive parent pre-service and   Low impact.
Specific problems with cases rated as needing     independent living plan although the child was 16          ongoing training needs.
improvement:                                      years of age and was receiving Independent Living          Task: Discuss and recommend
• 1 case was rated as needing improvement.        Skills classes.                                            foster/adoptive parent education curriculum in
• The comment was “was there exception                                                                       collaboration with the proposed Foster Youth
    noted why TPR was not pursued, did not                                                                   Advisory Committee.
    want to be adopted because of fear of being                                                              Enhance foster parent training on age
    separated from siblings, child never given                                                               appropriate independent living skills for all
    info that could see sibs soon if adopted.”                                                               children in foster care.
• Goal is being emancipated – no formal plan                                                              3. Clearly communicate expectations,                 Included in Item 6.
    for independent living services were found.                                                              procedures, and agency policies to foster and
                                                                                                             adoptive parents.
                                                                                                             Task: Assure that all permanency plans
                                                                                                             include a description of what services will be
                                                                                                             provided to the foster family to ensure a safe
                                                                                                             and stable placement for foster children. This
                                                                                                             should include both ongoing services and a
                                                                                                             crisis response plan when services are needed
                                                                                                             immediately and during non-standard work
                                                                                                             hours.




                                                                                                                                                               DRAFT            02/06/04

                                                                                                          16
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                  ACTION STEPS                             SELECTED ACTION STEP(S)/
                                                                                                              RATIONALE
                                            4. Expand the use of community resources in       1. All independent living plans should include
                                               supporting families.                              transition plans to address family and social
                                               Task: Implement transition plan for youth         support needs as young adults.
                                               who age out of out-of-home care to address
                                               family/social support they need as a young
                                               adult.
                                               Use independent living research to determine
                                               important supports for young adults.
                                               Include transition plan component in
                                               independent living services.




                                                                                              DRAFT            02/06/04

                                            17
     FEDERAL COMMENTS AT EXIT                                    FEDERAL REPORT                         ACTION STEPS      SELECTED ACTION STEP(S)
                                                                                                                                RATIONALE
Item 11: Proximity of foster care placement.

Federal comments at debriefing:                    Rated as strength in all 25 foster care cases
This outcome is the weakest area of performance    (100%).
for Wisconsin.
Case specific analysis:
Specific problems with cases rated as needing
improvement:
• It is noted in 1 case reviewed that a child is
    placed 5 hours from parent but quality of
    provider is good.




                                                                                                                       DRAFT    02/06/04

                                                                                                   18
     FEDERAL COMMENTS AT EXIT                                 FEDERAL REPORT                                           ACTION STEPS                                SELECTED ACTION STEP(S)/
                                                                                                                                                                         RATIONALE
Item 12: Placement with siblings.

Federal comments at debriefing:                 Rated as an area needing improvement based on           1. Maintain sibling connections                      1. Clearly document reasons for not placing
Placement with siblings is not consistent.      the finding that in 50% of the applicable cases (7 of      Task: Clearly document reasons for not               siblings together when placement as a group
Case specific analysis:                         14), DCFS did not make efforts to place siblings           placing siblings together when placement as a        is not possible. Provide guidance on how to
Specific problems with cases rated as needing   together, even when children requested that they be        group is not possible. Provide guidance on           document activities.
improvement:                                    placed together. In 2 of these cases, reviewers            how to document activities.
• Some comments regarding sibling placement     reported that foster parents said that they are            Change kinship care program eligibility           Include in 5-year plan. Will require statutory
    were there was no attempt to place with     willing to take all the siblings but the caseworker        requirements to allow all siblings to be placed   change.
    siblings, and siblings were not initially   had never asked them.                                      together when some of siblings are not related
    placed together but eventually were.                                                                   to the kinship care provider.
                                                                                                           Change kinship care statute and administrative
                                                                                                           rule.
                                                                                                           Provide financial incentives through foster       Include in 5-year plan.
                                                                                                           care rate structure to encourage foster parents
                                                                                                           to take sibling groups.
                                                                                                           Facilitate placement with relative, when          Covered in Item 8.
                                                                                                           appropriate
                                                                                                           Clarify “relative” for purposes of placing        Reworded: Expand definition of relative for
                                                                                                           siblings together in situation where children     Kinship Care purposes. Low impact.
                                                                                                           are not placed at the same time.
                                                                                                        2. Identify foster/adoptive parent pre-service and   2. Utilize allowance of up to 6 children in a
                                                                                                           ongoing training needs.                              foster home.
                                                                                                           Task: Enhance foster parent training on           3. Remove maximum of 6 children, if needed,
                                                                                                           placing siblings together.                           to accommodate placement of siblings.
                                                                                                        Source: Strategy 4 and 5




                                                                                                                                                             DRAFT            02/06/04

                                                                                                        19
     FEDERAL COMMENTS AT EXIT                                    FEDERAL REPORT                                         ACTION STEPS                                SELECTED ACTION STEP(S)/
                                                                                                                                                                          RATIONALE
Item 13: Visiting with parents and siblings in
foster care.

Federal comments at debriefing:                    Rated as an area needing improvement because         1. Preserve family connections for children           1. Develop and implement policy on visitation
• Visitation is important to preserve family       46% of applicable cases (11 of 24), DCFS had not        Task: Revise Ch.48 to reflect the continuing          and family interaction (include in revision
   relationships and achieve timely permanence.    made concerted efforts to ensure that visitation        status of relatives after TPR but before              of Investigation and Ongoing Service
Case specific analysis:                            between parents and children and between siblings       finalization of adoption.                             Standards).
Specific problems with cases rated as needing      was of sufficient frequency to meet the needs of the    Maximize involvement of relatives and                 Task: Address in policy:
improvement:                                       child. Reviewers determined that in:                    siblings post TPR.                                      •    Parent responsibility for appointments
• This area had many concerns and comments               • 4 cases visitation between children and         Develop policy regarding visitation/family              •    Frequency of visitation
   relating to visitation.                                   their mothers was not sufficient              interaction between children and their                  •    Support for visitation
• It was noted in some cases that a plan for             • 4 cases visitation between children and         families.                                               •    Type of interaction
   visitation was not being followed by having               their fathers was not sufficient              Adoption home studies and agreements should             •    Transition to unsupervised
   fewer visitations than was prescribed, foster         • 3 cases visitation between siblings was         specifically state how a child’s heritage will          •    Involvement of relatives, extended family
   parents were denying visits or visitations                not sufficient.                               be preserved.                                           •    Can’t withhold visitation
   were suspended.                                 This item was rated as strength in 83% of               Address transition from supervised to                   •    Update administrative rules to enforce
                                                                                                                                                                        visitation policy.
• In 1 case it was cited that visitation was not   Outagamie cases, 50% of Kenosha cases, and 42%          unsupervised visits.
                                                   of Milwaukee cases.                                  2. Assure compliance with ICWA by public and             Use focus groups to collect information.
   being effectively supported by agency.
                                                                                                           private agencies.                                     Technical assistance to support
• 1 case also noted that there was a failure to
                                                                                                        3. Enhance efforts to identify, locate, and engage       implementation.
   locate and contact the father.
                                                                                                           family members.                                       Monitor implementation through QA
                                                                                                           Task: Ensure that efforts to identify all family      process.
                                                                                                           members and provide them opportunities to be       2. Expansion of foster parent training will
                                                                                                           involved are made throughout the life of the          support improved visitation/interaction.
                                                                                                           case.                                                 Foster parents will receive visitation plan.
                                                                                                        4. Use Relatives to supervise visitation.                Monitor through QA process.
                                                                                                           Task: Discuss role in visitation with relatives
                                                                                                           as part of initial meetings on case plan              Comment: Workload a factor
                                                                                                           Provide opportunities for family interaction




                                                                                                                                                              DRAFT            02/06/04

                                                                                                        20
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                  RATIONALE
                                            5. Identify foster/adoptive parent pre-service and   Action Step 1 applies to Item 14 & 16.
                                               ongoing training needs.                           Action Step 2 is covered under Item 14 ICWA.
                                               Task: Enhance foster parent training on           Action Step 3 applies to Item 15
                                               cultural sensitivity and maintaining children’s   Action Step 6 is a long term item.
                                               heritage.
                                            6. Increase transportation options for families
                                               and children to assure greater participation in
                                               services.
                                            Source: Strategy 1, 2, 4, and 5




                                                                                                 DRAFT           02/06/04

                                            21
     FEDERAL COMMENTS AT EXIT                                    FEDERAL REPORT                                          ACTION STEPS                                SELECTED ACTION STEP(S)/
                                                                                                                                                                           RATIONALE
Item 14: Preserving connections.

Federal comments at debriefing:                    Rated as an area needing improvement because in        1. Recruit and license more foster parents to        5 year plan
• Generally good use of maternal relatives for     37.5% of the applicable cases (9 of 24). The State        meet the cultural diversity of the families and   1. ICWA items are a package, keep in PEP
   placement.                                      had not made diligent efforts to preserve children’s      children. (Tribal Child Welfare Initiative 1.B)       Items 1, 2, 3, 5 & 7.
Case specific analysis:                            connections. Key concerns pertained to                 2. Develop guidelines that promote                   2. Visitation/interaction policy will promote
Specific problems with cases rated as needing      maintaining the child’s connections to extended           collaboration between systems.                        connections with extended family.
improvement:                                       family and, if the child is Native American, to the       Task: Improve the coordination between child      3. Revision of ongoing service standards will
• In 2 cases, evaluators noted that religious      Tribe.                                                    welfare agencies and child support agencies           promote involvement in case plan/service
   beliefs were not being honored.                                                                           regarding engaging and locating absent                process, attention to cultural/religious
• In 2 cases, a lack of effort to contact family   The reviewers determined that:                            parents.                                              connections.
   or tribe members or omitting to explore              • The child is Native American and DCFS           3. Develop ICWA training curriculum for child        4. Monitor through QA process, provide
   relatives on one side of the family was                  had not notified the Tribe about the             welfare workers.                                      technical assistance.
   mentioned.                                               child’s placement in a timely manner (2          Task: Develop initial training for all workers.       Comment: Workload a factor
                                                            cases)                                           Develop and in-depth training for specialists.                     Technical Assistance
                                                        • DCFS had not made efforts to maintain           4. Preserve family connections for children.
                                                            child’s connection to extended family (5         Tasks: Revise Ch 48 to reflect the continuing     Action Step 2 is low priority.
                                                            cases)                                           status of relatives after TPR but before          Action Step 4 is a long term item.
                                                        • DCFS had not made efforts to maintain              finalization of adoption.                         Action Step 6 is covered in Item 15.
                                                            child’s connection to religious affiliation      Maximize involvement of relatives and sibling
                                                            (2 cases). (In both of these cases, the          post TPR.
                                                            biological family specifically requested         Evaluate the concept of open adoptions in WI.
                                                            that connections be maintained with              Develop policy regarding visitation/family
                                                            child’s religion and reviewers determined        interaction between children and their
                                                            that these requests were not adequately          families.
                                                            addressed.                                       Create state/local workgroup to develop
                                                                                                             policy
                                                   This item was rated as strength in 83% of Kenosha         Address transition from supervised to
                                                   cases, 67% of Milwaukee cases, and 33% of                 unsupervised visits
                                                   Outagamie cases.




                                                                                                                                                               DRAFT            02/06/04

                                                                                                          22
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                              SELECTED ACTION STEP(S)/
                                                                                                            RATIONALE
                                            5. Assure compliance with ICWA by public and
                                               private agencies.
                                               Task: Incorporate into state licensing rules
                                               that licensed agencies must coordinate/may
                                               not impede the cultural, religious and spiritual
                                               beliefs of the Tribes.
                                            6. Enhance efforts to identify, locate, and engage
                                               family members.
                                               Task: Document activities to locate and
                                               engage absent parents
                                               a) Provide guidance on how to document
                                                    activities
                                               b) Provide training and technical assistance.
                                            7. Use WISACWIS data and reports to support
                                               tribal child welfare practice.
                                               Task: Add an element in WISACWIS to
                                               identify if a child is Indian. Need to modify in
                                               several places, not just intake. Include ticklers
                                               to contact tribe throughout the life of the case.
                                               Make information available to all counties on
                                               how to contact tribes.
                                               Consider ICWA link on WISACWIS that
                                               includes process flow. (Keep information
                                               current.)




                                                                                                   DRAFT     02/06/04

                                            23
     FEDERAL COMMENTS AT EXIT                                  FEDERAL REPORT                                         ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                                                                       RATIONALE
Item 15: Relative placement.

Federal comments at debriefing:                  Rated as an area needing improvement because in       1. Facilitate placement with relatives when         1. Enhance efforts to identify, locate, and
• Generally good use of maternal relatives for   35 % of the applicable cases (8 of 23), DCFS had         appropriate.                                        engage family members. (standards
   placement.                                    not made diligent efforts to locate and assess           Task: DCFS clarify through policy that              revision, training & technical assistance)
Case specific analysis:                          relatives as potential placement resources.              placement with a relative is a reasonable           Task: Ensure that efforts to identify all
Specific problems with cases rated as needing    Specifically, DCFS:                                      exception to the distance requirement and that      family members and provide them
improvement:                                           • did not make diligent efforts to search for      the exception is documented in the record.          opportunities to be involved are made
• Comments were based on the lack of                        either maternal or paternal relatives (5   2 Recommend statutory change in                        throughout the life of a case.
   exploring relatives as placement providers,              cases)                                        confidentiality laws so that relative may have          a) Incorporate into the Investigations
   omitting sides of the family or lack of             • sought paternal relatives but not maternal       enough knowledge to care for the needs of a                 and Ongoing Services Standards.
   contact with family members.                             relatives (1 case)                            child or recommend other relatives who might            b) Train workers on the identification
                                                       • sought maternal relatives but not paternal       be appropriate placement resource.                          and involvement of all family
                                                            relatives (2 cases)                           Clarify current confidentiality laws and                    members.
                                                                                                          delineate what information can be shared with           c) Provide technical assistance to local
                                                                                                          non-custodial parent.                                       agencies.
                                                                                                          Develop policy and procedures to clarify the            d) Identify and examine existing
                                                                                                          role of fathers and other family members in                 policies that present barriers to full
                                                                                                          concurrent planning and identifying relatives               involvement of all paternal relatives
                                                                                                          as placement resources, and assure                          in the case process when paternity
                                                                                                          documentation of these efforts.                             has not been fully adjudicated.
                                                                                                                • Document activities to locate and               e) Develop policy/procedures to
                                                                                                                    engage fathers.                                   clarify how to use paternal relatives
                                                                                                                • Clarify that concurrent planning                    as placement resources when
                                                                                                                    includes considering fathers and                  paternity is not established.
                                                                                                                    other family members as possible              f) Review and revise policies on what
                                                                                                                    option for permanency.                            information can be shared with
                                                                                                          Clarify state statutes regarding whether a                  relatives so they can be prepared to
                                                                                                          relative may apply for and be granted a foster              care for children or identify other
                                                                                                          home license when a child has been placed                   placement resources.
                                                                                                          with them by court order.




                                                                                                                                                           DRAFT            02/06/04

                                                                                                       24
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                  ACTION STEPS                              SELECTED ACTION STEP(S)/
                                                                                                              RATIONALE
                                               Obtain a legal opinion regarding whether a             g) Document activities to locate and
                                               child placed with a relative by court order is            engage absent parents.
                                               entitled to foster care payments under IV-E of            • Provide guidance on how to
                                               the Social Security Act.                                       document activities
                                               Promote the use of relative locator resources             • Provide training and technical
                                               (create forms, research formal relative locator                assistance.
                                               services) and relative search (adoption                 h) Develop policy and procedures
                                               search).                                                   regarding safety assessments of
                                               Ensure thorough and consistent                             relatives as potential resources.
                                               documentation of efforts to use relative
                                               locator resources and relative search.
                                               Address the discrepancy in rates between         Action Steps 1 & 2 are long term items.
                                               court ordered kinship care and foster care.
                                                      • Review the original proposal that           Comment: Relative “right to be licensed,
                                                           long-term kinship care be funded at      implications for services.
                                                           the same rate as foster care.
                                               Clarify “relative” for purposes of placing
                                               siblings together in situations where children
                                               are not placed at the same time.
                                            3. Enhance efforts to identify, locate, and engage
                                               family members.
                                               Task: Ensure that efforts to identify all family
                                               members and provide them opportunities to be
                                               involved are made throughout the life of a
                                               case.
                                                    a) Incorporate into the Investigations and
                                                        Ongoing Services Standards.
                                                    b) Train workers on the identification
                                                        and involvement of all family
                                                        members.




                                                                                                DRAFT          02/06/04

                                            25
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                                SELECTED ACTION STEP(S)/
                                                                                                              RATIONALE
                                                   c) Provide technical assistance to local
                                                       agencies.
                                                   d) Identify and examine existing policies
                                                       that present barriers to full
                                                       involvement of all paternal relatives
                                                       in the case process when paternity has
                                                       not been fully adjudicated.
                                                   e) Develop policy/procedures to clarify
                                                       how to use paternal relatives as
                                                       placement resources when paternity is
                                                       not established.
                                                   f) Review and revise policies on what
                                                       information can be shared with
                                                       relatives so they can be prepared to
                                                       care for children or identify other
                                                       placement resources.
                                                   g) Provide guidance on sharing
                                                       information with family members.
                                               Document activities to locate and engage
                                               absent parents.
                                                   a) Provide guidance on how to document
                                                       activities
                                                   b) Provide training and technical
                                                       assistance.
                                               Provide guidance regarding protocol for doing      Reworded: Now a part of h.
                                               safety assessments of relatives as potential
                                               resources at the time of removal. Include
                                               information related to the need for a protective
                                               plan until the safety assessment is completed
                                            Source: Strategy 4 and 5




                                                                                                  DRAFT          02/06/04

                                            26
     FEDERAL COMMENTS AT EXIT                                   FEDERAL REPORT                                            ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                                                                           RATIONALE
Item 16: Relationship of child in care with
parents.

Federal comments at debriefing:                  Rated as an area needing improvement based on             1. Develop policies and guidelines regarding        1. Visitation policy will promote more
• Supporting relationships while in care is      the finding that in 37.5% of the applicable cases (9         procedure for determining paternity and safely      interaction with parents, broad range of
   important to achieving permanency.            of 24), DCFS had not made concerted efforts to               involving absent parents and their relatives        interaction.
Case specific analysis:                          support the parent-child relationships of children in        and incorporate into appropriate training.       2. Foster parent training will encourage foster
• In 1 case, a mother was not permitted to go    foster care. Specifically, DCFS did not make                 Task: Develop and issue policies related to         parents to support interaction.
   to medical appointments with child.           active efforts to promote bonding with the mother            adjudication, identification and involvement
• It was noted in another case that there were   (3 cases), father (2 cases, or either parent (4 cases).      of father to enhance family connection for       Action Step 1 & 3 are long term.
   no efforts to strengthen the mother-child                                                                  children and incorporate into training.
   relationship.                                 This item was rated as strength in 83% of Kenosha            Examine models that support safe parent             Comment: Documentation #2.
• 1 case had comments that a child had to        and Outagamie cases compared to 42% of                       involvement e.g. UW Extension Program
   make requests before a worker took action     Milwaukee cases.                                             related to safely engaging parents.
   and the worker did not promote visits with                                                              2. Preserve family connections
   parents.                                                                                                   Task: Document activities to locate and
                                                                                                              engage absent parents
                                                                                                              Provide opportunities to provide family
                                                                                                              interactions.
                                                                                                           3. Expand the use of informal community
                                                                                                              resources in supporting families
                                                                                                              Task: Explore the use/expansion of
                                                                                                              wraparound, family group conferencing and
                                                                                                              similar models that employ natural and
                                                                                                              community supports.
                                                                                                           Source: Strategy 1, 4, and 5.




                                                                                                                                                               DRAFT            02/06/04

                                                                                                           27
     FEDERAL COMMENTS AT EXIT                                  FEDERAL REPORT                                          ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                                                                        RATIONALE
Item 17: Needs and services of child, parents,
and foster parents.

Federal comments at debriefing:                  Rated as an area needing improvement because          Needs and services of child, parents, foster         1. Revision of CPS Investigation, Ongoing
• Case assessment and planning are generally     42% of the applicable cases (21 of 50; 8 of the 21    parents                                                 Services Standards and WI Model.
   strengths, but inconsistency exists in case   cases were foster care), DCFS had not adequately      1. Increase access to services such as mental           • Update Standards/Model
   practice statewide.                           assessed and/or addressed the service needs of            health and AODA to improve safety and               • Technical assistance to agencies
• Case planning practice is stronger for         children, parents and foster parents. Specifically,       permanency.                                         • Update training curriculum
   placement cases than in-home cases.           the reviewers determined one or more of the           2. Explore collaborative modes on the local level       • Quality Assurance Monitoring
• Child welfare agencies generally coordinate    following:                                                to expand mental health services on a regional   2. Educate foster parents about services (State
   well with community partner agencies on             • Services provided were delayed or                 basis.                                              Foster Parent Handbook) so they can be
   family service plans and service delivery.              insufficient to meet the needs of the           Task: Work with the WI. Primary Health              more effective consumers.
• Independent living services exist for youth,             family (7 cases).                               Care Association to secure federal grants        3. Provide Training and technical assistance to
   but youth, parents and care providers need          • Children’s needs were not assessed (6             through the Bureau of Primary Health Care to        foster care coordinators.
   greater awareness of services available.                cases).                                         enhance behavioral health services (in-home      4. Hold focus groups with foster parents and
Case specific analysis:                                • Children’s service needs were not met (3          or outpatient) on the local level.                  foster care coordinators.
Specific problems with cases rated as needing              cases).                                     3. Increase the use of crisis service response
improvement:                                           • Mother’s needs were not assessed (5               teams.
• 13 cases were categorized as an area needing             cases).                                         Task: Further explore the Mobile Urban
   improvement (8 IHC and 5 OHC).                      • Mother’s service needs were not met (3            Treatment Team (MUTT) model of service
• Some of the main issues in this area were                cases).                                         delivery.
   lack of thorough needs                              • Father’s needs were not assessed (10              Examine the crisis response team plan model
   assessment/understanding of underlying                  cases)                                          used by Integrated Service Program.
                                                                                                           Collaborate with the Bureau of Mental Health
   issues and providing appropriate services,          • Father’s service needs were not met (4
   especially around mental health and                                                                     and Substance Abuse Services to expand
                                                           cases).
                                                                                                           county certification for crisis services under
   substance abuse concerns.                           • Foster parent’s needs were not assessed
                                                                                                           HFS 34.
• There was also one case where religious                  (2 cases).
                                                                                                       4. Identify critical questions/areas that CPS
   counseling alternatives were not pursued by         • Foster parent’s service needs were not
                                                                                                           needs to explore throughout the life of a case
   the agency.                                             met (2 cases).
                                                                                                           to screen for the need for mental health or
                                                                                                           other specialty services.




                                                                                                                                                            DRAFT           02/06/04

                                                                                                       28
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                          ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                                                      RATIONALE
                           Rating for this item varied as a function of type of      Task: Enhance policy and/or instructions in     Action Step 1 - Item 22.
                           case with 68% of foster care cases rated as strength      the WI model, primarily the Family              Action Step 2 – Item 23
                           compared to 48% of in-home service cases. This            Assessment, to better support collecting        Action Step 3 – Item 23
                           item was rated as a strength in 75% of Kenosha’s          information related to developmental            Action Step 4 – Include as task under ongoing
                           cases compared to 54% of Milwaukee’s cases and            milestones, strengths and areas of concern in   service standards revision.
                           50% of Outagamie’s cases.                                 child and adult functioning.                    Action Step 5 – Item 23
                                                                                     Incorporate any changes into Core/Foundation    Action Step 6 – Item 22
                                                                                     training through the UW Training Partnership.   Action Step 7 – Include as task under ongoing
                                                                                  5. Explore whether Health Check for children       service standards.
                                                                                     entering out-of-home care should/can include    Action Step 9 – drop
                                                                                     a formal mental health assessment.              Action Step 9 – Include as task under ongoing
                                                                                     Task: Consult with Division of Health Care      service standards
                                                                                     Financing.                                      Action Step 10 – Item 6/Foster Parent
                                                                                     Consult with other states regarding EPSDT       Recruitment
                                                                                     Consult with Bureau of Mental Health and        Action Step 11 – Foster Parent Recruitment.
                                                                                     Substance Abuse Services on infant mental
                                                                                     health initiative.
                                                                                  6. Establish multi-agency or interdepartmental
                                                                                     workgroup to identify solutions to problems
                                                                                     related to access to dental/medical services.
                                                                                     Task: Work with CAP agencies and other
                                                                                     consortiums e.g. Tri-County Community
                                                                                     Dental Health Clinic ) in an effort to
                                                                                     expand/replicate a regional dental services
                                                                                     Explore current collaborative models on the
                                                                                     local level to expand dental services on a
                                                                                     regional basis.
                                                                                     Develop a dental program with Marquette
                                                                                     University that mirrors the IV-E Child
                                                                                     Welfare Masters level programs at
                                                                                     Milwaukee, Madison and Green Bay.




                                                                                                                                     DRAFT           02/06/04

                                                                                  29
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                      ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                RATIONALE
                                                   Explore ways to expand the provision of free
                                                   or low cost dental services through technical
                                                   colleges.
                                             7.    Assure that caseworkers and case managers
                                                   explore all available options to meet the
                                                   dental/medical health needs of children.
                                             8.    Expand the network of federally funded health
                                                   care centers.
                                             9.    Link identifying, assessing, and responding to
                                                   issues of domestic violence to the CPS
                                                   process through standards, policies and
                                                   procedures.
                                                   Task: Provide CPS workers with support,
                                                   training, and guidance needed to safely and
                                                   successfully work with batterers and
                                                   incorporate into training through the UW
                                                   Training Partnerships.
                                             10.   Provide respite care for all foster parents.
                                                   Task: Develop standards and policies
                                                   required to assure uniform availability of
                                                   respite care to all foster parents (currently
                                                   required for all treatment foster parents)
                                                   Establish a workgroup to examine alternatives
                                                   and investigate funding strategies.
                                             11.   Ensure that all foster care providers who work
                                                   outside of the home have child care services.
                                                   Task: Require that the permanency plan to
                                                   include a description of child care services for
                                                   foster parents based on the needs of the foster
                                                   parents and the foster children.




                                                                                                      DRAFT     02/06/04

                                            30
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                            SELECTED ACTION STEP(S)/
                                                                                                          RATIONALE
                                            12. Clearly communicate expectations,
                                                procedures, and agency policies to foster and
                                                adoptive parents.
                                                Task: Assure that all permanency plans
                                                include a description of what services will be
                                                provided to the foster family to ensure a safe
                                                and stable placement for foster children. This
                                                should include both ongoing services and a
                                                crisis response plan when services are needed
                                                immediately and during non-standard work
                                                hours.
                                            Source: Strategy 1, and 2




                                                                                                 DRAFT     02/06/04

                                            31
     FEDERAL COMMENTS AT EXIT                                    FEDERAL REPORT                                         ACTION STEPS                                SELECTED ACTION STEP(S)/
                                                                                                                                                                          RATIONALE
Item 18: Child and family involvement in
case planning.
Federal comments at debriefing:                    Rated as needing improvement based on the            1. Enhance collaborative safety planning and          1. Use technical assistance and QA monitoring
• Caseworkers generally have regular contact       finding that 38% of applicable cases (19 of 50; 10      case planning with families.                          to address inconsistency of practice related
    with families to engage in services; concern   of the 19 were foster care cases), DCFS had not         Task: Increase use of trained                         to engagement of families in safety and case
    is related to consistency of assessment and    made diligent efforts to involve parents and/or         translators/interpreters to help persons with         planning process.
    case planning practice.                        children in the case planning process. A key            limited English proficiency and hearing            2. Revise ongoing service standards regarding
• Need to improve efforts to locate and engage     concern pertained to the lack of involvement of         impairments better understand the case plan           involvement of absent parents/fathers.
    fathers in services.                           fathers in the case planning process.                   process.                                              • Use focus groups to identify barriers.
Case specific analysis:                                                                                         a) Identify needs for                            • Make family assessment/engagement
Specific problems with cases rated as needing                                                                       translators/interpreters and how to              guidelines a standard.
improvement:                                                                                                        meet those needs.                            • Include in training how to engage
• 7 cases were evaluated as needing                                                                     2. Explore successful culturally relevant                    involuntary/resistant persons.
    improvement in this area (4 IHC & 3 OHC).                                                              strategies and models for engaging families to
• The problems in this area are around not                                                                 actively participate in safety and case planning   Action Step 1 – low impact, long term.
    engaging family members.                                                                               and developing effective caseworker/family         Action Step 2 – low impact, long term
• 3 cases specifically mentioned a lack of                                                                 relationships.                                     Action Step 3 – Item 17 include in ongoing
    attempting to involve the father (2 IHC & 1                                                                 a) Review research, models used in other      services standards revision.
    OHC).                                                                                                           states and models currently used in       Action Step 4 – part of QA strategy.
• In 1 case, parents felt their desires were not                                                                    WI Counties.                              Action Step 5 – Plan consolidation
    being addressed.                                                                                            b) Enlist the assistance of the National                      Start workgroup in 2 years
                                                                                                                    Resource Center on Child                                  Completion is long term
                                                                                                                    Maltreatment and the National             Action Step 6 – Include as task under 5
                                                                                                                    Resource Center on Family-Centered        Action Step 7 – Item 25 include video to go with
                                                                                                                    practice.                                 guide.
                                                                                                                c) Review curricula that provide skill        Action Step 8 – Drop (flexible work schedule)
                                                                                                                    based training on engaging and
                                                                                                                    developing relationships with
                                                                                                                    families.
                                                                                                                d) Develop state/county/tribal
                                                                                                                    workgroup to discuss various models
                                                                                                                    and strategies and identify those most
                                                                                                                    likely to achieve the outcome of
                                                                                                                    collaboration with families.


                                                                                                                                                              DRAFT            02/06/04

                                                                                                        32
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                              SELECTED ACTION STEP(S)/
                                                                                                            RATIONALE
                                            3. Clarify in standards and policies that all safety
                                               plans and case plans must be culturally
                                               relevant and include the families’ goals and
                                               their service provider preference to the
                                               greatest extent possible.
                                                    a) Reinforce use of narrative fields
                                                        within the WI Model for documenting
                                                        the quality of the worker/family
                                                        relationship
                                            4. Develop and provide technical assistance for
                                               child welfare supervisors to consistently
                                               reinforce these practices in the field.
                                            5. Assure that case plan documents are
                                               comprehensive and can be easily understood.
                                                    a) Consolidate multiple plans into a
                                                        single document for the family
                                                        (safety, permanency, visitation, and
                                                        service plans and court report.
                                                    b) Clarify needs for separate plans,
                                                        including the relationship between
                                                        plans.
                                                    c) Study/examine ways to integrate
                                                        plans, including any statutory impact.
                                                    d) produce case plan document in
                                                        WISACWIS,
                                            6. Clarify the child welfare case plan is a product
                                               for the family to use.
                                                    a) Obtain input from families on how
                                                       to design case plan components
                                                    b) Work with service providers to
                                                       understand the content of the case
                                                       plan and their role in implementation.




                                                                                                   DRAFT     02/06/04

                                            33
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                             SELECTED ACTION STEP(S)/
                                                                                                           RATIONALE
                                            7. Develop a guide to assist families in
                                               understanding the child welfare program case
                                               process.
                                                   a) Assure that the guide clearly explains
                                                        to families how they can participate in
                                                        the case plan and court processes.
                                                   b) Use input from families, caseworkers
                                                        and attorneys.
                                                   c) Make the guide format available
                                                        electronically so agencies can
                                                        customize it based on local needs.
                                            8. Increase opportunities to meet with families
                                                during the evenings and weekends through
                                                the use of flexible work schedule.
                                            Source: Strategy 5




                                                                                                  DRAFT     02/06/04

                                            34
     FEDERAL COMMENTS AT EXIT                                     FEDERAL REPORT                                            ACTION STEPS                            SELECTED ACTION STEP(S)/
                                                                                                                                                                          RATIONALE
Items 19 & 20: Worker visits with child and
Worker visits with parent(s).

Federal comments at debriefing:                     Item 19: Rated as strength in 88% of the cases (44      Rated as strength so we don’t have to address this
• No specific concerns regarding worker visits      of 50). Caseworker visits with children were of         in the PEP
    with child noted; identified as a strength      sufficient frequency and/or quality to meet the
    upon which other improvement strategies can     needs of the children and to ensure adequate
    be based.                                       monitoring of the child’s safety and well being and
• Caseworkers generally have regular contact        promote attainment of case goals.
    with families to engage in services.
• Need to improve efforts to locate and engage      Item 20: Rated as needing improvement because              Define standards for purpose and frequency of 1. Define frequency of contacts (monthly)
    fathers in services.                            in 23% of the applicable cases (15 of 50; 7 of the         caseworker contacts with parents and children.     • Include in ongoing services standards
Case specific analysis – visits with child:         15 cases were foster care cases), the frequency            Task: Clarify expectations for worker visits          revision.
3 cases, all in-home service cases, were deemed     and/or quality of caseworker visits with parents           with parents and children, including purpose       • Address purpose/quality of visits.
y reviewers to have this item rated as an area in   were not sufficient to monitor the safety and well-        of visits (e.g., engagement, case plan progress    • Incorporate into training.
need of improvement.                                being of the children or promote attainment of case        review), frequency of visits, and               2. Provide technical assistance and QA
Case specific analysis – visits with parent(s):     goals. Although Milwaukee requires caseworkers             documentation of requirements.                     monitoring to improve documentation.
Specific problems with cases rated as needing       to maintain at least monthly contacts with their           Revise Ongoing Services Standards.
improvement:                                        assigned families, the case review indicate that this   Source: Strategy 4                                    Comment: Workload issue.
• This area was categorized as an area in need      requirement is not consistently met in the county.
    of improvement in 5 cases (2 IHC & 3            Reviewers found that:
    OHC).                                                • visits with both parents were not occurring
• In 1 case, a criticism was that the context of             with sufficient frequency (8 cases).
    the worker/parent relationship was peer-like         • visits with the father were not occurring
    in nature.                                               with sufficient frequency (7 cases).
• In 1 case, it was noted that there was an
    effort to involve the dad but not the mother,   This item was rated as a strength in 92% of
    though mom has contact with the foster          Kenosha’s cases compared to 75% of Outagamie’s
    parent.                                         cases and 58% of Milwaukee’s cases.




                                                                                                                                                                 DRAFT        02/06/04

                                                                                                            35
     FEDERAL COMMENTS AT EXIT                                     FEDERAL REPORT                                   ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                                           RATIONALE
Item 21: Educational needs of the child.

Federal comments at debriefing:                      Rated as a Strength because 91% of applicable   Rated as Strength
Child welfare agency involvement in meeting          cases (30 of the 33), DCFS had made diligent
educational needs of children is an area of strong   efforts to meet children’s educational needs.
performance in Wisconsin.
There is generally good coordination with
schools on educational needs.
More attention is given to education for children
in placement than in-home cases.
Case specific analysis:
One area of concern noted was inconsistent
documentation of educational needs and services
in the case record.
At least 7 of the approximately 41 cases
reviewed had comments relating to the lack of
educational planning, communication with
schools and/or documentation of these efforts.
Training and protocol can help social workers
identify and assess educational needs.




                                                                                                                                  DRAFT     02/06/04

                                                                                                     36
     FEDERAL COMMENTS AT EXIT                                      FEDERAL REPORT                                             ACTION STEPS                              SELECTED ACTION STEP(S)/
                                                                                                                                                                              RATIONALE
Item 22: Physical health needs of the child.

Federal comments at debriefing:                      Rated as needing improvement based on the                1. Increase access to services such as mental      1. Establish multi-agency workgroups to
• Child welfare agency involvement in                finding that in 17% of the applicable cases (8 of the       health and AODA improve safety and                 develop recommendations to improve
    meeting physical health needs of children is     46; 6 of the 8 cases were foster care cases), DCFS          permanency.                                        access. (From Item 17)
    generally a strength, but inconsistency exists   had not adequately addressed children’s health           2. Explore collaborative models on the local       2. Provide technical assistance and QA
    in case practice statewide.                      needs. Specifically, reviewers found one or more            level to expand mental health services on a        monitoring to address inconsistency
• Physical health services for children are          of the following:                                           regional basis.                                    regarding follow up on medical service
    generally available but access to dental               • The child did not receive appropriate or         3. Establish multi-agency or interdepartmental        needs.
    health services is limited statewide.                       timely physical health screenings (2             workgroup to identify solutions to problems
Case specific analysis:                                         cases).                                          related to access to dental/medical services.   .
Through review of approximately 41 Wisconsin               • The child did not receive appropriate            4. Assure that caseworkers and case managers
cases, 4 issues presented concerns regarding                    preventive health or dental care (2 cases).      explore all available options to meet the
physical health needs of the child:                        • The child did not receive treatment for an          dental/medical health needs of children.
• Immunization concerns were evident in 4                       identified health or dental needs (4          5. Expand the network of federally funded
    cases.                                                      cases).                                          health care centers.
• The lack of an initial health assessment done            • There was no documentation in the case           Source: Strategy 1
    or done in a timely manner occurred in 2                    file of screenings or health and dental
    cases.                                                      care (2 cases).
• The lack of documentation on file regarding
    physical health was commented on in 2 cases      Ratings for this item varied as a function of case
    by the evaluator(s).                             type. The item was rated as a strength in 93% of
• Additionally, in 4 cases, the lack of medical      applicable in-home cases compared to 76 of foster
    care or addressing of medical needs was          care cases. The item was rated as a strength in
    reported.                                        100% of Kenosha’s cases, 87% of Milwaukee’s
                                                     cases, and 58% of Outagamie’s cases.




                                                                                                                                                                     DRAFT       02/06/04

                                                                                                              37
     FEDERAL COMMENTS AT EXIT                                      FEDERAL REPORT                                           ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                                                                             RATIONALE
Item 23: Mental health need of the child.

Federal comments at debriefing:                      Rated as needing improvement based on the               1. Increase access to services such as mental       1. Provide support to workers to do initial
• Child welfare agency involvement in                finding that in 31% of the applicable cases (10 of         health and AODA improve safety and                  identification of potential MH issues and
   meeting mental health services for children is    the 32 cases; 5 of the 10 cases were foster care           permanency.                                         need for mental health assessment for cases
   generally a strength but inconsistency exists     cases), DCFS had not made sufficient efforts to            Task: Increase transportation options for           open for ongoing services.
   in case practice statewide.                       address the mental health needs of the children. A         families and children to assure greater             • Cover in training
• Mental health screening for children entering      key concern identified pertained to the lack of            participation in services court hearings, case      • Technical assistance
   out-of home is needed at the time of entry        consistent provision of mental health assessment           and permanency plan reviews, etc.                2. Explore a formal MH assessment/screening
   and at regular intervals to identify issues for   services when it was apparent that such assessment         Establish multi-agency or interdepartmental         approach for children in placement.
   further assessment.                               was needed. Specifically, reviewers determined             workgroup to identify solution to problems          • Pilot managed care in Milwaukee
• Mental health services for children are            that:                                                      related to access to mental health services.     3. Expand foster parent training to assist foster
   generally available but access varies for child         • The child did not receive a formal mental       2. Explore collaborative models on the local           parents to recognize potential MH issues.
   psychiatry/psychology and sex offender                      health assessment even when the facts of         level to expand mental health services on a      4. Crisis/response teams (From Item 17)
   treatment.                                                  the case and the family’s and child’s            regional basis.
                                                               history indicated that a mental health           Task: Work with the Wisconsin Primary            Action Step 2 added to Item 18.
                                                               assessment was warranted (7 cases, 6 of          Health Care Association to secure federal        Action Step 3 added to Item 18
                                                               which were in Milwaukee).                        grants through the Bureau of Primary Health      Action Step 4 incorporated into task (c)
                                                           • Children with mental health needs did              Care to enhance behavioral health services       Action Step 5 long term plan
                                                               not receive ongoing mental health                (in-home or outpatient) on the local level.      Action Step 6 minimal impact
                                                               treatment that was sufficient to meet their   3. Increase the use of crisis service response      Action Step 8 long term plan
                                                               needs (2 cases).                                 teams.                                           Action Step 9 long term plan
                                                                                                                Task: Further examine/explore the Mobil
                                                     This item was rated as a strength in 100% of               Urban Treatment (MUTT) model of service
                                                     applicable cases in Kenosha, 67% in Outagamie,             delivery.
                                                     and 50% in Milwaukee.                                      Examine the crisis response team plan model
                                                                                                                utilized by Integrated Service Program.
                                                                                                                Collaborate with the Bureau of Mental Health
                                                                                                                and Substance Abuse Services to expand
                                                                                                                county certification for crisis services under
                                                                                                                HFS 34.




                                                                                                                                                                 DRAFT            02/06/04

                                                                                                             38
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                  ACTION STEPS                           SELECTED ACTION STEP(S)/
                                                                                                        RATIONALE
                                            4. Identify critical questions/areas that CPS
                                               needs to explore throughout the life of the
                                               case to screen for the need for mental health
                                               or other specialty services.
                                               Task: Enhance policy and/or the instructions
                                               in the WI Model, primarily the Family
                                               Assessment, to better support collecting
                                               information related to developmental
                                               milestones, strengths and areas of concern in
                                               child and adult functioning.
                                            5. Explore whether Health Check for children
                                               entering out-of-home care should/can include
                                               a formal mental health assessment.
                                               Task: Consult with Division of Health Care
                                               Financing.
                                               Consult with other states regarding early and
                                               periodic screening dental treatment coverage.
                                            6. Collaborate with other disciplines to
                                               provide/promote cross-systems training.




                                                                                               DRAFT     02/06/04

                                            39
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT                   ACTION STEPS                            SELECTED ACTION STEP(S)/
                                                                                                          RATIONALE
                                            7. Collaborate with state and local mental health
                                               organizations/associations to provide training
                                               to mental providers. (Focus on appropriate
                                               assessments for families involved in the CPS
                                               system.)
                                            8. Identify foster/adoptive parent pre-service and
                                               ongoing training needs.
                                               Task: Enhance foster parent training on
                                               mental health
                                               Develop a process for determining when
                                               children in out-of-home care need mental
                                               health assessment (another action step)
                                               Task: Clearly document in WISACWIS
                                               agency decisions and actions related to mental
                                               health needs.
                                               Ensure the staff complete the fields in
                                               WISACWIS relevant to health and mental
                                               health
                                            Source: Strategy 1, 2, 3 and 6




                                                                                                 DRAFT     02/06/04

                                            40
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                         ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                        RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Statewide Information System: Substantial
                           conformity.

                           Item 24: The state is operating a statewide            Rated as a Strength
                           information system that, at a minimum, can readily
                           identify the status, demographic characteristics,
                           location, and goals for the placement of every child
                           who is (or within the immediately preceding
                           months, has been) in foster care.

                           This item was rated as a strength.




                                                                                                               DRAFT     02/06/04

                                                                                  41
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                           ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                                                   RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Case Review: Wisconsin is not in substantial
                           conformity.

                           Item 25: Provides a process that ensures that each     1. Establish effective methods for workload          1. Incorporate policies regarding family
                           child has a written case plan to be developed             management by defining staff caseload ratios,        involvement in case and permanency
                           jointly with the child’s parent(s) that includes the      supervisor/staff ratios and developing               planning into Ch. HFS 44 and the Ongoing
                           required provisions.                                      workload management analysis.. (See                  Service Standards.
                                                                                     Strategy 3.)                                      2. Develop policy and procedures to clarify the
                           This item was rated as needing improvement             2. Provide families an opportunity for                  role of fathers and other family members in
                           because the state does not routinely involve both         involvement in case and permanency plan              concurrent planning, including
                           parents in the joint development of the case plan.        development.                                         documentation of activities to locate and
                           While mothers are frequently involved, fathers are        Task: Incorporate policies regarding family          engage fathers.
                           almost always excluded even when their                    involvement in case and permanency planning       3. In Ch. HFS 44, require reasonable efforts to
                           whereabouts are known. High caseloads were                into Ch. HFS 44 and the Ongoing Standards.           involve families in permanency plan
                           identified as a barrier to workers being able to       3. Enhance collaborative safety planning and            reviews.
                           develop case plans jointly with family members.           case planning with families.                      4. Increase the use of trained
                                                                                     Task: Increase use of trained                        translators/interpreters to assist persons with
                                                                                     translators/interpreters to help persons with        limited English proficiency to better
                                                                                     limited English proficiency and hearing              understand the case plan process.
                                                                                     impairments better understand the case plan
                                                                                     process.
                                                                                     Identify needs for translators/interpreters and
                                                                                     how to meet those needs.
                                                                                  Source: Strategy 3, 4 and 5.




                                                                                                                                       DRAFT            02/06/04

                                                                                  42
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                          ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                         RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 26: Provides a process for the periodic           Item 26
                           review of the status of each child, no less            Rated as a Strength
                           frequently than once every 6 months, either by a
                           court or by an administrative review body.

                           This was rated as a strength because for the most
                           part, 6-month periodic reviews of the status of each
                           child are conducted in a timely manner in the vast
                           majority of the counties.




                                                                                                                DRAFT     02/06/04

                                                                                  43
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                          ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                         RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 27: Provides a process that ensures that each     Item 27
                           child in foster care under the supervision of the      Rated as a Strength
                           state has a permanency hearing in a qualified court
                           or administrative body no later than 12 months
                           from the date the child entered foster care and no
                           less frequently than every 12 months thereafter.

                           This item was rated as a strength because
                           Wisconsin’s process ensures that each child in
                           foster care under the supervision of the state has a
                           permanency hearing in a qualified court or
                           administrative body no later than 12 months from
                           the date the child entered foster care and loss
                           frequently than every 12 months thereafter.
                           Although stakeholders indicated that sometimes
                           hearings were delayed due to problems with court
                           scheduling, these delays were not a frequent
                           occurrence.




                                                                                                                DRAFT     02/06/04

                                                                                  44
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                           ACTION STEPS                                SELECTED ACTION STEP(S)/
                                                                                                                                                    RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 28: Provides a process for termination of          1. Streamline the TPR process.                       1. Continue to provide training on ASFA and
                           parental rights proceedings in accordance with the         Task: Evaluate the use of jury trials for TPRs.      related state statutes.
                           provisions of the Adoption and Safe Families Act.          Consider use of specialized teams to assist       2. Include in Ch. HFS 44 and by numbered
                                                                                      counties in conducting TPR proceedings.              memo a policy to begin concurrent
                           This item was rated as needing improvement                 Recommend that all biological and adoptive           planning consultation earlier in the case
                           because findings indicate that the TPR process is          parents have public defenders assigned in            planning process.
                           not being consistently implemented in accordance           CHIPS cases.                                      3. Issue a numbered memo clarifying state
                           with the provisions of ASFA due to court-and               Work with parents to increase voluntary              law on proceeding to a TPR prior to the
                           agency-related delays with regard to both filing for       TPRs.                                                location of an adoptive resource.
                           TPR and attaining TPR. These delays are due to:         Source: Strategy 4 and 5
                                   • Late filings by the agency that do not
                                       give the court enough time to get the
                                       case on the docket.
                                   • Staffing shortages among district
                                       attorneys, public defenders, and
                                       agency attorneys that often result in the
                                       need to grant continuances.
                                   • The right of parents to request a jury
                                       trial in cases of involuntary TPR.
                                   • The lengthy TPR process.
                                   • The general focus of both DCFS and
                                       the courts on reunifying children with
                                       parents whenever possible, which
                                       results in frequent extensions for
                                       parents to meet their case plan goals.
                                   • An unwillingness on the part of the
                                       agency and the court to file for TPR
                                       unless there is an adoptive resource
                                       available.




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                                                                                   45
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                       ACTION STEPS                             SELECTED ACTION STEP(S)/
                                                                                                                                             RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 29: Provides a process for foster parents,        Item 29                                        1. Require each licensing agency to develop a
                           pre-adoptive parents, and relative caregivers of       1. Assure compliance with ICWA by public and      foster parent handbook that includes all
                           children in foster care to be notified of, and have an    private agencies.                              agency policies related to the care of foster
                           opportunity to be heard in, any review or hearing                                                        children and funding for placement-related
                           held with respect to the child.                                                                          costs.
                                                                                                                                 2. Enhance foster parent training.
                           This item was rated as needing improvement                                                            3. Include in the CPS Investigation Standards
                           because reviewers determined that the process for                                                        and CPS Ongoing Standards the
                           notifying foster parents, pre-adoptive parents, and                                                      requirement that DCFS, counties, and
                           relative caregivers about reviews and hearings is                                                        tribes confer on the development,
                           not being implemented in a timely or consistent                                                          implementation, and evaluation of all types
                           manner throughout the state. A key concern noted                                                         of safety plans, including plans for
                           was the lack of timely notification of the Tribes                                                        reunification for tribal children.
                           regarding reviews and hearings.




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                                                                                 46
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                         ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                        RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Quality Assurance System: Wisconsin is not in
                           substantial conformity.

                           Item 30: The state has developed and                  Item 30
                           implemented standards to ensure that children in      Rated as strength
                           foster care are provided quality services that
                           protect their safety and health.

                           This item was rated as a strength because the state
                           developed and implemented both initial
                           investigative standards and on-going guidelines for
                           children in foster care. Information from the
                           stakeholder interviews indicates that counties are
                           following the standards and guidelines to ensure
                           that children in foster care are provided quality
                           services to protect their safety and health.




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                                                                                 47
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                         ACTION STEPS                   SELECTED ACTION STEP(S)/
                                                                                                                                     RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 31: The state is operating an identifiable        Item 31:
                           quality assurance system that is in place in the       1. A continuous quality enhancement and
                           jurisdictions where the services included in the          program support will be established.
                           CFSP are provided, evaluates the quality of            Source: Strategy 7
                           services, identifies strengths and needs of the
                           service delivery system, provides a relevant report,
                           and evaluates program improvement measures
                           implemented.

                           This item was rated as needing improvement
                           because the state does not have a quality assurance
                           system that has the capacity to evaluate quality of
                           services, provide relevant reports, or evaluate the
                           implementation of program improvement
                           measures.




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                                                                                  48
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                          ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                                                  RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Training: Wisconsin is not in substantial
                           conformity

                           Item 32: The state is operating a staff                1. Provide supervisors with knowledge and skills    Pre-service training:
                           development and training program that supports            to supervise staff and practice.                 1. The state should establish minimum pre-
                           the goals and objectives in the CFSP, addresses        2 Provide child welfare workers with training on        service training requirements.
                           services provided under titles IV-B and IV-E, and         program policy and practice.                     2. Pre-service training should include on-the-
                           provides initial training for all staff who deliver    3 Expand capacity of training systems to respond        job training and distance learning where
                           these services.                                           to training needs.                                   possible.
                                                                                  4 Coordinate Partnership and other child welfare    3. Exemptions should be provided for
                           This was rated as needing improvement because             training with university social work programs.       experienced workers.
                           the collaborative approach to training among the
                           state, counties, training partnerships, tribes, and    Source: Strategy 3                                  Core training:
                           universities does not ensure that caseworkers in all                                                       1. The state should establish minimum initial
                           county child welfare offices receive the initial                                                              training requirements.
                           training necessary to provide services that support                                                        2. Training system expansion is needed to
                           the goals and objectives of the CSFP. A key                                                                   have the capacity to deliver training.
                           concern is that many newly hired caseworkers are                                                           3. Exemptions should be provided for
                           assigned caseloads before completion of any                                                                   experienced workers.
                           training program.

                           It was also mentioned that although Milwaukee and
                           Outagamie workers receive core classes over a year
                           period, they are assigned a caseload before
                           completing the core courses.




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                                                                                  49
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                         ACTION STEPS         SELECTED ACTION STEP(S)/
                                                                                                                           RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 33: The state provides for ongoing training       Same as Item 32              1. The state should establish minimum
                           for staff that addresses the skills and knowledge      Source: Strategy 3              ongoing training requirements.
                           base needed to carry out their duties with regard to                                2. Training requirements for social worker
                           the services included in the CSFP.                                                     certification should count toward the
                                                                                                                  annual training requirement.
                           This was rated as needing improvement because
                           the collaborative approach to training among the
                           state, counties, training partnerships, tribes, and
                           universities does not ensure that caseworkers in all
                           county child welfare offices receive ongoing
                           training that addresses the skills and knowledge
                           base needed to carry out their duties with regard to
                           the services included in the CSFP.




                                                                                                               DRAFT           02/06/04

                                                                                  50
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                            ACTION STEPS                               SELECTED ACTION STEP(S)/
                                                                                                                                                    RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 34: The state provides training for current or     1. Evaluate the impact of mandating foster and       1. The competency based pre-service training
                           prospective foster parents, adoptive parents, and          adoptive parent training at state and local          should be expanded statewide and offered
                           staff of state licensed or approved facilities that        level.                                               on a regular basis.
                           care for children receiving foster care or adoption     2. Identify foster/adoptive parent pre-service and   2. Resources are needed for statewide delivery
                           assistance under title IV-E that addresses the skills      ongoing training needs.                              and the delivery method may need to evolve
                           and knowledge base needed to carry out their            3. Expand resources and funding for training.           to achieve efficiencies.
                           duties with regard to foster and adopted children.      Source: Strategy 2                                   3. Counties should be allowed flexibility with
                                                                                                                                           the specific curriculum provided the
                           This was rated as needing improvement because                                                                   competencies are addressed.
                           the review found that although Wisconsin has                                                                 4. The ongoing training requirement should be
                           developed a strong training curriculum for foster                                                               in terms of hours and linked to foster parent
                           parents and makes this curriculum available to the                                                              license renewal.
                           counties, neither pre-placement nor ongoing
                           training for foster parents is state mandated.
                           Consequently, there are some counties in which
                           training for foster parents is minimal.




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                                                                                   51
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                         ACTION STEPS                            SELECTED ACTION STEP(S)/
                                                                                                                                              RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Service Array: Wisconsin is not in substantial
                           conformity.

                           Item 35: The state has in place an array of            See action items and steps under Items 22 and   This item is directly related to Well Being 1,
                           services that assess the strengths and needs of        23.                                             Item 17 and Well Being 3, Item 22 and 23.
                           children and families and determine other service      Source : Strategy 1
                           needs, address the needs of families in addition to                                                    1. Increase access to Mental Health and
                           individual children in order to create a safe home                                                        AODA services that enhance safety and
                           environment, enable children to remain safely with                                                        permanency for children and their families.
                           their parents when reasonable, and help children in                                                           • Establish regional multi-agency
                           foster and adoptive placements achieve                                                                            workgroups to identify solutions to
                           permanency.                                                                                                       the problem of accessing mental
                                                                                                                                             health and AODA services in each
                           This item was rated as needing improvement                                                                        region of the state.
                           because the state does not have in place an array of                                                          • Use these regional workgroups to
                           services to address the needs of children and                                                                     explore the use of an Integrated
                           families to enable them to remain safely with their                                                               Services or Coordinated Services
                           parents when reasonable and to help children in                                                                   model in each region of the state.
                           foster and adoptive placements achieve                                                                            The focus should include services
                           permanency. There are gaps in services available                                                                  and the ISP/CST model of crisis
                           to families, such as dental and mental health                                                                     response.
                           services, and that service needs are not being met                                                            • DCFS and counties will collaborate
                           on a consistent basis.                                                                                            with the Bureau of Community
                                                                                                                                             Mental Health and Substance Abuse
                                                                                                                                             Services to expand county
                                                                                                                                             certification for crisis services
                                                                                                                                             under HFS 34.
                                                                                                                                         • DCFS, with the counties, will
                                                                                                                                             promote the use of MA
                                                                                                                                             transportation reimbursement
                                                                                                                                             statewide to support families in
                                                                                                                                             accessing mental health services.

                                                                                                                                  DRAFT            02/06/04

                                                                                  52
FEDERAL COMMENTS AT EXIT   FEDERAL REPORT        ACTION STEPS         SELECTED ACTION STEP(S)/
                                                                                RATIONALE
                                                                       • Study effectiveness managed Care
                                                                           Pilot in Milwaukee as it relates to
                                                                           increased access to needed services
                                                                           for children and families.
                                                                       • Work with the UW Training
                                                                           Partnerships to develop and
                                                                           promote cross-system training and
                                                                           education between the mental
                                                                           health and child protective services
                                                                           systems.
                                                                       • This training should include an
                                                                           emphasis on identifying and
                                                                           utilizing natural community
                                                                           supports for families in safety
                                                                           planning, case planning and support
                                                                           planning post case closure.
                                                                2. Increase access to dental and medical
                                                                   services statewide for children and families
                                                                   involved in the child welfare system.
                                                                       • Establish regional multi-agency
                                                                           workgroups to identify solutions to
                                                                           problems related to access to dental
                                                                           and medical services.
                                                                       • The DCFS and counties will work
                                                                           with CAP agencies and other
                                                                           consortiums (e.g. Tri-County
                                                                           Community Dental Health Clinic)
                                                                           in an effort to expand/replicate a
                                                                           regional dental services model.
                                                                       • Study effectiveness managed Care
                                                                           Pilot in Milwaukee as it relates to
                                                                           increased access to needed services
                                                                           for children and families.


                                                                DRAFT           02/06/04

                                            53
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                         ACTION STEPS                            SELECTED ACTION STEP(S)/
                                                                                                                                              RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 36: The services in item 35 are accessible to     See action items and steps under Items 22 and   Cross reference to Item 35.
                           families and children in all political jurisdictions   23
                           covered in the state’s CFSP.                           Source : Strategy 1
                           This was rated as needing improvement because
                           services are not accessible to families and children
                           in all political jurisdictions. The state does not
                           provide the counties enough funds to pay for the
                           basic required child welfare services, and counties
                           that have access to local funds can provide the
                           services, but those that do not have access to
                           sufficient local funds cannot provide the services.




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                                                                                  54
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                         ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                        RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 37: The services in item 35 can be               Rated as strength
                           individualized to meet the unique needs of children
                           and families served by DCFS.

                           This item was rated as a strength because the state
                           has a network of service providers who work in
                           collaboration with the local agencies and the
                           BMCW to individualize services to meet the
                           children’s and families’ unique needs.




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                                                                                 55
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                          ACTION STEPS                        SELECTED ACTION STEP(S)/
                                                                                                                                           RATIONALE
                                  PART II – SYSTEMIC FACTORS
                           Agency Responsiveness To The Community:
                           Wisconsin is in substantial conformity. DCFS
                           develops annual reports of progress and services in
                           conjunction with representatives of their Executive
                           Steering Committee and that the state’s services
                           under CFSP are coordinated with services of other
                           federally-assisted programs that serve the child
                           welfare population. However, there is a need for a
                           clearly delineated and structured consultation
                           process that allows for Tribal and other
                           stakeholders to provide input into the goals and
                           objectives of the CFSP.
                           Item 38: In implementing the provisions of the          1. Assure compliance with ICWA by public and
                           CFSP, the state engages in ongoing consultation            private agencies.
                           with tribal representatives, consumers, service         Source: Strategy 3
                           providers, foster care providers, juvenile court, and
                           other public and private child- and family-serving
                           agencies and includes the major concerns of these
                           representatives in the goals and objectives of the
                           CFSP.
                           This item is rated as needing improvement because
                           there is a need for a clearly delineated and
                           structured consultation process that allows for
                           tribal and other stakeholders to provide input into
                           the goals and objectives of the CSFP. Consultation
                           with tribes is limited to a representative from the
                           Great Lakes Inter-Tribal Council and not all of the
                           11 tribes in the state are members of this council.
                           Stakeholder participation in the development of the
                           CFSP is limited, and there has been no public
                           comment on the draft prepared by DCFS and
                           reviewed by the Executive Steering Committee.

                                                                                                                                  DRAFT     02/06/04

                                                                                   56
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                            ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                           RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 39: DCFS develops, in consultation with            Rated as strength.
                           these representatives, annual reports or progress
                           and services delivered pursuant to CFSP.

                           This item was rated as a strength. DCFS develops
                           annual reports of progress and services in
                           conjunction with representatives of their Executive
                           Steering Committee (ESC). The ESC is involved
                           with the collaborative planning structures for
                           program planning.



FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                            ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                           RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 40: The state’s services under the CFSP are        Rated as strength.
                           coordinated with services or benefits of other
                           federal or federally assisted programs serving the
                           same population.

                           This item was rated as a strength. Services under
                           the CFSP are coordinated with services of other
                           federal or federally assisted programs that serve the
                           child welfare population. Wisconsin has created
                           initiatives such as the Coordinated Service Team
                           Initiative and the Managed Health Care Initiative to
                           address the coordination of services issues.




                                                                                                                  DRAFT     02/06/04

                                                                                   57
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                         ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                        RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Foster and Adoptive Parent Licensing,
                           Recruitment, and Retention: Wisconsin in
                           substantial conformity.

                           Item 41: The state has implemented standards for     Rated as strength.
                           foster family homes and child care institutions
                           which are reasonably in accord with recommended
                           national standards.

                           This item was rated as a strength. Wisconsin has
                           standards for foster family homes and child care
                           institutions that are in accord with recommended
                           national standards.




FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                         ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                        RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 42: The standards are applied to all licensed   Rated as strength.
                           or approved foster family homes or child care
                           institutions receiving title IV-E or IV-B funds.

                           This item was rated as a strength. Licensing
                           standards are being applied to all licensed or
                           approved foster family homes or child care
                           institutions receiving title IV-E or IV-B funds.




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                                                                                58
FEDERAL COMMENTS AT EXIT                 FEDERAL REPORT                                       ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                      RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 43: The state complies with federal           Rated as strength.
                           requirements for criminal background clearances as
                           related to licensing or approving foster care and
                           adoptive placements and has in place a case
                           planning process that includes provisions for
                           addressing the safety of foster care and adoptive
                           placements for children.

                           This item was rated as a strength. Wisconsin
                           generally enforces the provisions of criminal
                           background checks to ensure that clearances
                           relating to licensing or approving foster care and
                           adoptive placements address the safety of foster
                           care and adoptive placements for children.




                                                                                                             DRAFT     02/06/04

                                                                                59
FEDERAL COMMENTS AT EXIT                  FEDERAL REPORT                                           ACTION STEPS      SELECTED ACTION STEP(S)/
                                                                                                                           RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 44: The state has in place a process for           Rated as strength.
                           ensuring the diligent recruitment of potential foster
                           and adoptive families that reflect the ethnic and
                           racial diversity of children in the state for whom
                           foster and adoptive homes are needed.

                           This item was rated as a strength. The state has
                           established a process for ensuring diligent
                           recruitment of potential foster and adoptive
                           families that reflect the ethnic and racial diversity
                           of children in the state for whom foster and
                           adoptive homes are needed.




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                                                                                   60
FEDERAL COMMENTS AT EXIT                  FEDERAL REPORT                                  ACTION STEPS         SELECTED ACTION STEP(S)/
                                                                                                                     RATIONALE
                                  PART II – SYSTEMIC FACTORS

                           Item 45: The state has in place a process for the                             1. Complete work with the Wisconsin County
                           effective use of cross-jurisdictional resources to                               Human Services Association on developing
                           facilitate timely adoptive or permanent placements                               an inter-county agreement that addresses
                           for waiting children.                                                            jurisdiction and case transfer issues.

                           This item was rated as needing improvement.
                           Further efforts are needed to develop a process for
                           the effective use of cross-jurisdictional resources
                           facilitating timely adoptions and permanent
                           placements for waiting children. More efforts are
                           also needed to develop protocols and working
                           relationships that will facilitate cross-jurisdictional
                           transfers and timely placements across county
                           lines.




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