PERFORMANCE AUDIT OF THE DEPARTMENT OF CHILDREN AND FAMILY SERVICES INVESTIGATIONS OF ABUSE AND NEGLECT MAY 2019 You can obtain reports by contacting: Office of the Auditor General Iles Park Plaza 740 E. Ash Springfield, IL 62703 217-782-6046 or TTY: 1-888-261-2887 OR This Audit Report and a Report Digest are also available on the worldwide web at http://www.auditor.illinois.gov To the Legislative Audit Commission, the Speaker and Minority Leader of the House of Representatives, the President and Minority Leader of the Senate, the members of the General Assembly, and the Governor: This is our report of the Performance Audit of the Department of Children and Family Services Investigations of Abuse and Neglect. The audit was conducted pursuant to House Resolution Number 418. This audit was conducted in accordance with generally accepted government auditing standards and the audit standards promulgated by the Office of the Auditor General at 74 Ill. Adm. Code 420.310. The audit report is transmitted in conformance with Sections 3-14 and 3-15 of the Illinois State Auditing Act. FRANK J. MAUTINO Auditor General Springfield, Illinois May 2019 REPORT DIGEST – PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT EXECUTIVE SUMMARY PROGRAM AUDIT Release Date: May 2019 Audit performed in accordance with House Resolution Number 418 Illinois Department of Children and Family Services Investigations of Abuse and Neglect House Resolution Number 418 directed the Auditor General to conduct a performance audit of the Department of Children and Family Services to review and assess the Department’s protocols for investigating reports of child abuse and neglect. The resolution specifically required the audit to include a review of abuse and neglect investigations conducted by the Department in FY15, FY16, and FY17. In this audit for the three-year period FY15-FY17, we reported that:  The number of abuse and neglect investigations increased significantly, going from 67,732 in FY15 to 75,037 in FY17 or 10.8 percent. Within the three-year timeframe there was a notable spike in FY16 to 78,572 investigations. The increase in investigations between FY15 and FY16 represents an increase of 16.0 percent.  The hotline is unable to take calls as they are received, resulting in call backs. The number of call backs increased substantially during FY15-FY17, from 39.6 percent of total calls in FY15 to 55.7 percent in FY17.  Investigator caseloads were not in compliance with the B.H. Consent Decree. For FY15-FY17, 78.7 percent of investigators (729 of 926) had at least 1 month during the audit period in which they received more than 15 new assignments.  Indication rates (the percentage of cases where there was credible evidence that the incident occurred) decreased during FY15-FY17, from 28.3 percent in FY15 to 24.8 percent in FY17.  The Department did not always follow procedures in conducting investigations.  The overall timeliness of completion for investigations declined significantly over the three-year period FY15-FY17. In FY15, 7.6 percent of investigations were not completed within 60 days. For FY17, 12.4 percent of investigations were not completed within 60 days.  Investigators did not always accurately document that they assessed the need for services by completing the Level of Intervention field in the Department’s information system known as SACWIS. Of indicated investigations sampled, 16 investigations (10.7%) had no Level of Intervention listed (services recommended). Further, 39 indicated investigations (26.0%) had “No Service Needed” as the Level of Intervention. Additionally, of the investigations sampled, for 64 (42.7%) we found that the Level of Intervention was inaccurate.  For 65.3 percent of indicated investigations sampled, there was a lack of documentation regarding whether any services were received by the families involved and the duration of those services. The Department could not provide basic information for Intact Family Service cases, such as referral forms, to document that a formal referral for services was made. Office of the Auditor General Iles Park Plaza 740 E. Ash Street Springfield, IL 62703 Phone: (217) 782-6046 TTY: (888) 261-2887 The full audit report is available on our website: www.auditor.illinois.gov The audit report contains a total of 13 recommendations to the Department. REPORT DIGEST PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT ii REPORT DIGEST – PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT AUDIT SUMMARY AND RESULTS House Resolution Number 418 directed the Auditor General to conduct a performance audit of the Department of Children and Family Services (DCFS or Department) to review and assess the Department’s protocols for investigating reports of child abuse and neglect. The resolution specifically required the audit to include a review of abuse and neglect investigations conducted by the Department in FY15, FY16, and FY17. The Department has established administrative rules and extensive policies and procedures that delineate the investigations process and protocol to be followed during investigations. According to data provided by the Department, for FY15-FY17 the number of abuse and neglect investigations increased significantly, going from 67,732 in FY15 to 75,037 in FY17 or 10.8 percent. Within the three-year timeframe, there was a notable spike in FY16 to 78,572 investigations. The increase in investigations between FY15 and FY16 represents an increase of 16.0 percent. As is shown in Digest Exhibit 1, indication rates (the percentage of cases where there was credible evidence that the incident occurred) decreased during FY15-FY17, from 28.3 percent in FY15 to 24.8 percent in FY17. (pages 5-13) Digest Exhibit 1 CHILD ABUSE AND NEGLECT STATISTICS FY15-FY17 Investigations Indicated Reports Percent Indicated FY15 67,732 19,156 28.3% FY16 78,572 18,710 23.8% FY17 75,037 18,591 24.8% Source: OAG analysis of DCFS data as of July 27, 2018. The Department did not always follow procedures in conducting investigations. Our analysis of primary assignments for FY15FY17 showed that 78.7 percent of investigators (729 of 926) had at least 1 month during the audit period in which they received more than 15 new assignments. INVESTIGATION PROTOCOL The Department has established administrative rules and extensive policies and procedures that delineate the investigations process and protocol to be followed during investigations. The protocol includes timelines to be followed, interviews to be conducted, forms to be completed, and documentation to be collected in completing investigations of child abuse and neglect. However, we found that the Department did not always follow procedures in conducting investigations. For the audit period, the Department did not comply with investigator assignment requirements delineated in the B.H. Consent Decree. The B.H. Consent Decree requires that each child protective services investigator be assigned no more than 12 new abuse or neglect investigations per month during nine months of a calendar year and during the other three months of the calendar year, no more than 15 new investigations per month. Our analysis of primary assignments for FY15-FY17 showed that 78.7 percent of investigators (729 of 926) had at least 1 month during the audit period in which they received more than 15 new assignments. Further, our analysis showed that 32 investigators averaged more than 15 case assignments per month for the entire three-year period. In addition, there were 114 investigators who did not receive assignments for all 36 months and averaged more than 15 assignments per month for the months worked during the iii REPORT DIGEST – PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT period. Digest Exhibit 2 shows that as the total number of investigators decreased during FY16, the higher the percent of investigators who were out of compliance with the B.H. Consent Decree’s maximum allowable new assignments of 15 new assignments. The exhibit also shows that for February through April 2016 over half of all investigators were out of compliance. Digest Exhibit 2 INVESTIGATORS WITH MORE THAN 15 NEW ASSIGNMENTS BY MONTH FY15-FY17 600 500 400 300 524 539 517 503 363 363 352 537 516 499 287 383 453 287 309 296 275 224 226 226 250 329 437 291 390 387 394 334 389 393 401 426 406 386 407 402 200 100 70 20 14 41 58 11 33 42 195 211 168 177 196 237 255 253 247 244 171 113 89 87 128 177 181 144 128 185 117 87 113 126 123 Jul-14 Aug-14 Sep-14 Oct-14 Nov-14 Dec-14 Jan-15 Feb-15 Mar-15 Apr-15 May-15 Jun-15 Jul-15 Aug-15 Sep-15 Oct-15 Nov-15 Dec-15 Jan-16 Feb-16 Mar-16 Apr-16 May-16 Jun-16 Jul-16 Aug-16 Sep-16 Oct-16 Nov-16 Dec-16 Jan-17 Feb-17 Mar-17 Apr-17 May-17 Jun-17 0 159 153 158 Investigators with less than 15 assignments Investigators with more than 15 assignments Source: OAG analysis of DCFS data as of July 27, 2018. We could not document that the Department had evaluated the reliability and validity of the Child Endangerment Risk Assessment Protocol (CERAP) as required by the Children and Family Services Act (20 ILCS 505/21(e)). The CERAP is a six-page safety assessment protocol designed to provide investigators with a mechanism for quickly assessing the potential for moderate to severe harm to children in the immediate or near future and for taking quick action to protect them. The Department also could not provide specific CERAP training procedures required by statute. (pages 16-25) STATUS AND FINAL DETERMINATION Our analysis for the three-year period FY15-FY17, as of July 27, 2018, showed that the status for a majority of cases, 142,766 of 221,341 investigations or 64.5 percent, was classified as expunged. Expunged investigations for the period were unfounded investigations in which most information, including the name of the alleged perpetrator, had been hidden or removed from the investigation information. An additional 78,520 (35.5%) investigations were classified as closed. For the remaining 55 investigations:   22 were undetermined (3 cases were FY16 and 19 cases were FY17); 18 were in appeal (15 cases were FY15, 1 case was FY16, and 2 cases were FY17); iv REPORT DIGEST – PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT     9 were purged or concealed (all were FY15 cases); 3 were in review (one from each fiscal year); 2 were in a 20-day hold (both were FY17 cases); and 1 was pending approval (an FY17 case). According to data provided by the Department, 25.5 percent of investigations (56,457 of 221,341) for the three-year period FY15-FY17 had a final determination or finding of indicated, meaning there was credible evidence that the allegation occurred. For 74.5 percent of all investigations the status was unfounded (164,864 of 221,341 investigations). As of July 2018, there were 20 investigations for FY16 and FY17 that were listed as pending. (pages 25-27) INVESTIGATION TIMEFRAMES The hotline did not meet targets, and call backs increased substantially during FY15-FY17, from 39.6 percent in FY15 to 55.7 percent of total calls FY17. The overall timeliness of completion for investigations declined significantly over the three-year period FY15FY17. We found that the Department needs to improve timeliness in several areas. The Department is not timely in completing intakes from callers reporting allegations of abuse and neglect. The hotline is unable to take calls as they are received, resulting in call backs. The hotline did not meet targets, and call backs increased substantially during FY15-FY17, from 39.6 percent in FY15 to 55.7 percent of total calls in FY17. The Department also does not have written procedures regarding the process for calling back individuals who report allegations of abuse or neglect that do not complete the intake process at the time of their initial call. Further, the Department does not maintain call back information electronically in its information system, known as SACWIS, for more than 90 days, which makes any long-term analysis of call back timeliness difficult. According to investigations data provided, the Department was timely in initiating investigations for approximately 99 percent of investigations. However, required interviews with the alleged victim and perpetrator were not always completed in a timely manner. With data provided by the Department, we reviewed the timeliness of interviews with the alleged victim(s) based on whether actual contact was made and found that the alleged victim was not interviewed within 24 hours in 29.1 percent of cases for the audit period FY15-FY17. The alleged perpetrator was not interviewed within 7 days in 24.5 percent of cases for the audit period. The overall timeliness of completion for investigations declined significantly over the three-year period FY15-FY17. In FY15, 7.6 percent of investigations were not completed within 60 days. For FY16, the percentage of investigations not completed within 60 days increased to 16.0 percent. It remained elevated in FY17 at 12.4 percent of investigations not completed within 60 days. We reviewed the timeliness of submission of the completed investigation to the supervisor and found that for the audit period FY15-FY17, 44.2 percent of all reports without extensions were not submitted within 55 days. The highest rate of noncompliance was for FY16, in which 51.2 percent of reports did not meet the 55 day requirement for submission to the supervisor, according to data provided by the Department. The Department’s difficulty in completing investigations in a timely manner during the audit period is further demonstrated by the number and percentage v REPORT DIGEST – PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT of investigations that received a 30-day extension. The percentage of cases receiving one or more extensions increased from 7.5 percent in FY15 to 16.1 percent in FY16 and 12.7 percent in FY17. Further, the number of investigations receiving multiple extensions also increased significantly. For instance, the number of investigations that received three extensions (an additional 90 days) increased from 274 investigations in FY15 to 1,263 investigations in FY16 and 719 investigations in FY17. In our review of cases involving an extension, it was also not always clear what the cause for the extension was or whether it rose to the level of “good cause.” (pages 3040) SERVICES Conducting an analysis of all recommendations for services and services provided by the Department was not possible for the audit period because of inherent limitations in the data provided by the Department as well as other data reliability and consistency issues. In order to assess the services recommended and services provided, we selected a sample of 150 indicated investigations (50 each year for FY15, FY16, and FY17) and reviewed the investigations for recommended services and any services received. (pages 42-44) Recommendations for Services Investigators did not always document that they assessed the need for services by completing the Level of Intervention field in the Department’s information system. The Department’s policies and procedures require that during an investigation the need for services for the family involved in the investigation be assessed by the Child Protection Specialist (investigator) and the Child Protection Supervisor. Our review of 150 indicated investigations found that investigators did not always document that they assessed the need for services by completing the Level of Intervention field in the Department’s information system (SACWIS). Of the 150 indicated investigations sampled, 16 investigations (10.7%) had no Level of Intervention listed. Further, 39 investigations (26.0%) had “No Service Needed” as the Level of Intervention. For most of these cases there was no rationale regarding why no services were being recommended even though the case had been indicated. Additionally, of the investigations sampled, for 64 (42.7%) we found that the Level of Intervention was inaccurate. For Intact Family Services (IFS) provided through the Department, investigators have the responsibility to discuss and offer these services if the final investigation finding of indicated has been recommended. The Department did not document that Intact Family Services were discussed and offered to all families with indicated investigation findings as is required by Department procedures. Only 20 of 150 (13.3%) indicated investigations reviewed contained documentation of a recommendation for Intact Family Services (IFS). An additional 3 investigations had recommendations for multiple services, which included IFS; therefore, 23 of 150 indicated investigations had a recommendation of IFS. For 33 of 150 investigations (22.0%), community services were recommended. We could not determine whether any services were recommended or what the specific services were for 67 of 150 (44.7%) indicated investigations reviewed. The remaining 27 investigations included recommendations for placement, already receiving vi REPORT DIGEST – PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT services, no services needed, multiple services, Intact Family Recovery, and Norman Cash Assistance. (pages 44-48) Services Provided The Department could not provide basic information for Intact Family Service cases, such as referral forms, to document that a formal referral for services was made. We sampled 150 indicated cases for the audit period and found that for 98 cases (65.3%), there was a lack of documentation regarding whether any services were received by the families involved and the duration of those services. The Department could not provide basic information for Intact Family Service cases, such as referral forms, to document that a formal referral for services was made. The Department also could not provide auditors with the number of families served by each IFS contractor each year for the audit period. For investigations involving the Norman Cash Assistance program, the Department could not provide all approval forms. For community services, there are no formal forms for referrals to community based services, and the Department is not documenting these services as required by procedures. Therefore, it is difficult to determine if the families actually received services from community providers. (pages 4856) VICTIM DEMOGRAPHICS During the audit period, the number of indicated children decreased every year while the total number of alleged victims increased. According to data provided by the Department as of July 27, 2018, for the three-year period FY15-FY17 there were 221,341 investigations involving a total of 358,545 children, 96,576 of whom had at least one indicated allegation. Auditors could not obtain a reliable count of the number of unique victims because of limitations with the data provided by the Department. Each person in the SACWIS system is assigned a unique PersonID. However, auditors found that there were over 8,000 instances where the same child had been assigned multiple PersonIDs. Therefore, auditors could not obtain a reliable count of the number of unique child victims over the audit period because of data limitations. For the 221,341 investigations for FY15-FY17, there were 450,483 total allegations, with an overall indication rate of 25.5 percent. The most common allegations were “Substantial Risk of Physical Injury/Environment Injurious to Health and Welfare by Neglect” and “Inadequate Supervision.” A total of 52,502 children were the alleged victims of sexual abuse during FY15-FY17, and 32,439 children were the alleged victims of serious harm. Age Children under the age of one were the most frequent alleged victims of abuse or neglect (8.1% of all victims) and also the most likely to be indicated victims (13.3% of all indicated victims). After the age of one, the number of indicated allegations of abuse or neglect trends downward. Race and Ethnicity For race, children who were identified as White or Black/African-American made up 96.4 percent of all alleged victims (62.5% White and 33.9% Black/African-American) and 97.1 percent of all indicated victims (62.4% White and 34.7% Black/African-American). Data provided by the vii REPORT DIGEST – PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Department showed that 2.3 percent of alleged victims did not have a race recorded. For ethnicity, children with a Hispanic ethnicity comprised 15.6 percent of all alleged victims and 16.7 percent of indicated victims. Gender For gender, there was an even split between male and female victims. Males accounted for 49.7 percent of all alleged victims and females were 49.6 percent. For indicated victims, males accounted for 49.4 percent and females were 50.3 percent. Geographic Location Auditors found that 25.6 percent of all investigations occurred in Cook County, followed by Lake County with 4.1 percent. There were investigations of alleged abuse or neglect in all 102 counties in Illinois. (pages 58-67) RECOMMENDATIONS The audit report contains a total of 13 recommendations to the Department of Children and Family Services. The Department generally agreed with the recommendations in the report. Appendix H to the audit report contains the agency responses. This performance audit was conducted by staff of the Office of the Auditor General. ___________________________________ JOE BUTCHER Division Director This report is transmitted in accordance with Sections 3-14 and 3-15 of the Illinois State Auditing Act. ___________________________________ FRANK J. MAUTINO Auditor General FJM:MSP viii TABLE OF CONTENTS Auditor General’s Transmittal Letter Report Digest Table of Contents Glossary of Terms Chapter One INTRODUCTION AND BACKGROUND Chapter Two INVESTIGATION PROTOCOL Chapter Three INVESTIGATION TIMEFRAMES Chapter Four SERVICES i Report Conclusions Introduction Background Child Abuse and Neglect Investigations Data  Recommendation 1: Child Abuse and Neglect Data Lawsuits 1 5 5 9 12 Chapter Conclusions Investigation Process  Recommendation 2: Investigator Assignments  Recommendation 3: Child Endangerment Risk Assessment Protocol Status of Abuse and Neglect Investigations Final Determinations and Findings 15 16 21 25 Chapter Conclusions Investigation Timeliness  Recommendation 4: Hotline and Intake  Recommendation 5: Investigation Timeliness Extensions  Recommendation 6: Investigation Extensions 29 30 33 38 38 40 Chapter Conclusions Services Recommendations for Services  Recommendation 7: Assessing the Need for Services 41 42 44 46 14 25 27  Chapter Five DEMOGRAPHIC INFORMATION Recommendation 8: Recommendations for Services Services Provided  Recommendation 9: Intact Family Services Monitoring  Recommendation 10: Intact Family Services Coverage  Recommendation 11: Intact Family Services Referrals  Recommendation 12: Norman Cash Assistance  Recommendation 13: Community Based Services 48 Chapter Conclusions Allegations Victim Demographics 57 58 61 48 51 52 53 55 56 APPENDICES Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H House Resolution Number 418 Audit Scope and Methodology Lawsuits Filed or Settled Intact Family Services Provider Contracts Abuse and Neglect Allegations Victim Demographic Information Investigations by County Agency Responses 71 75 81 91 97 107 115 121 GLOSSARY OF TERMS ANCRA – The Abused and Neglected Child Reporting Act (325 ILCS 5) is the State statute that governs the reporting and investigating of child abuse and neglect. B.H. Consent Decree – A class action lawsuit was filed against the Department in 1988 alleging that it failed to provide adequate services to children in its custody. In 1991, the parties entered into a consent decree known as the B.H. Consent Decree (88 C 5599 (N.D. Ill.)). A restated consent decree was filed in 1997, and the Consent Decree continues to be modified as needed. CERAP – The Child Endangerment Risk Assessment Protocol is a six-page safety assessment protocol designed to provide a mechanism for quickly assessing the potential for moderate to severe harm to children in the immediate or near future and for taking quick action to protect them. Closed Investigation – An investigation has been completed, a decision has been rendered on the case, and it has been approved and closed. Expunged Investigation – An unfounded investigation where the records are unviewable or an indicated investigation in which the retention period has lapsed. According to ANCRA, all information identifying the subjects of an unfounded report shall be expunged from the register, except as provided by statute. Indicated Investigation – An investigation of suspected child abuse/neglect has revealed credible evidence that the abuse/neglect occurred. Intact Family Recovery (IFR) – A program which targets families in Cook County where an infant has been born exposed to controlled substances and provides comprehensive services to families during the process of recovery from alcohol and other drug abuse. Intact Family Services (IFS) – A program designed to provide short term voluntary services intended to make reasonable efforts to stabilize, strengthen, enhance, and preserve family life by providing services that enable children to remain safely at home. Norman Cash Assistance Program – Provides assistance when cash assistance is needed to purchase an item to prevent a child from being placed in, or to return a child home from, DCFS care. Placement – The care of children for whom the Department is legally responsible who require a living arrangement away from their families due to abuse or neglect and for whom the Department has determined that family preservation services are not appropriate because such services are not in the child’s best interest or would not protect the child from imminent risk of harm. Purchase of Service (POS) Providers – Organizations contracted by DCFS to provide services. SACWIS – The Statewide Automated Child Welfare Information System is the DCFS computer system for investigative, child, and family case information. Unfounded Investigation – An investigation of suspected child abuse/neglect has revealed no credible evidence that the abuse/neglect occurred. Chapter One INTRODUCTION AND BACKGROUND REPORT CONCLUSIONS House Resolution Number 418 directed the Auditor General to conduct a performance audit of the Department of Children and Family Services (DCFS or Department) to review and assess the Department’s protocols for investigating reports of child abuse and neglect. The resolution specifically required the audit to include a review of abuse and neglect investigations conducted by the Department in FY15, FY16, and FY17. According to data provided by the Department, for FY15-FY17 the number of abuse and neglect investigations increased significantly, going from 67,732 in FY15 to 75,037 in FY17 or 10.8 percent. Within the three-year timeframe there was a notable spike in FY16 to 78,572 investigations. The increase in investigations between FY15 and FY16 represents an increase of 16.0 percent. Indication rates decreased during FY15-FY17, from 28.3 percent in FY15 to 24.8 percent in FY17. Investigation Protocol The Department has established administrative rules and extensive policies and procedures that delineate the investigations process and protocol to be followed during investigations. The protocol includes timelines to be followed, interviews to be conducted, forms to be completed, and documentation to be collected in completing investigations of child abuse and neglect. However, we found that the Department did not always follow procedures in conducting investigations. For the audit period, the Department did not comply with investigator assignment requirements delineated in the B.H. Consent Decree. The B.H. Consent Decree requires that each child protective services investigator be assigned no more than 12 new abuse or neglect investigations per month during nine months of a calendar year and during the other three months of the calendar year, no more than 15 new investigations per month. Our analysis of primary assignments for FY15-FY17 showed that 78.7 percent of investigators (729 of 926) had at least 1 month during the audit period in which they received more than 15 new assignments. Further, our analysis showed that 32 investigators averaged more than 15 case assignments per month for the entire three-year period. In addition, there were 114 investigators who did not receive assignments for all 36 months and averaged more than 15 assignments per month for the months worked during the period. We could not document that the Department had evaluated the reliability and validity of the Child Endangerment Risk Assessment Protocol (CERAP) as required by the Children and Family Services Act (20 ILCS 505/21(e)). The CERAP is a six-page safety assessment protocol designed to provide investigators with a mechanism for quickly assessing the potential for moderate to severe harm to children in the immediate or near future and for taking quick action 1 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT to protect them. The Department also could not provide specific CERAP training procedures required by statute. Status and Final Determination of Investigations Our analysis for the three-year period FY15-FY17, as of July 27, 2018, showed that the status for a majority of cases, 142,766 of 221,341 investigations or 64.5 percent, was classified as expunged. Expunged investigations for the period were unfounded investigations in which most information, including the name of the alleged perpetrator, had been hidden or removed from the investigation information. An additional 78,520 (35.5%) investigations were classified as closed. For the remaining 55 investigations:       22 were undetermined (3 cases were FY16 and 19 cases were FY17) 18 were in appeal (15 cases were FY15, 1 case was FY16, and 2 cases were FY17); 9 were purged or concealed (all were FY15 cases); 3 were in review (one from each fiscal year); 2 were in a 20-day hold (both were FY17 cases); and 1 was pending approval (an FY17 case). According to data provided by the Department, 25.5 percent of investigations (56,457 of 221,341) for the three-year period FY15-FY17 had a final determination or finding of indicated, meaning there was credible evidence that the allegation occurred. For 74.5 percent of all investigations the status was unfounded (164,864 of 221,341 investigations). As of July 2018, there were 20 investigations for FY16 and FY17 that were listed as pending. Timeframes for Completing and Closing Investigations We found that the Department needs to improve timeliness in several areas. The Department is not timely in completing intakes from callers reporting allegations of abuse and neglect. The hotline did not meet targets and call backs increased substantially during FY15FY17, from 39.6 percent to 55.7 percent of total calls. The Department also does not have written procedures regarding the process for calling back individuals who report allegations of abuse or neglect that do not complete the intake process at the time of their initial call. Further, the Department does not maintain call back information electronically in SACWIS for more than 90 days, which makes any long-term analysis of call back timeliness difficult. According to investigations data provided, the Department was timely in initiating investigations for approximately 99 percent of investigations. However, required interviews with the alleged victim and perpetrator were not always completed in a timely manner. With data provided by the Department, we reviewed the timeliness of interviews with the alleged victim(s) based on whether actual contact was made and found that the alleged victim was not interviewed within 24 hours in 29.1 percent of cases for the audit period FY15-FY17. The alleged perpetrator was not interviewed within 7 days in 24.5 percent of cases for the audit period. The overall timeliness of completion for investigations declined significantly over the three-year period FY15-FY17. In FY15, 7.6 percent of investigations were not completed within 60 days. For FY16, the percentage of investigation not completed within 60 days increased to 16.0 percent. It remained elevated in FY17 at 12.4 percent of investigations not completed within 60 days. 2 CHAPTER ONE - INTRODUCTION AND BACKGROUND We reviewed the timeliness of submission of the completed investigation to the supervisor and found that for the audit period FY15-FY17, 44.2 percent of all reports without extensions were not submitted within 55 days. The highest rate of noncompliance was for FY16, in which 51.2 percent of reports did not meet the 55 day requirement for submission to the supervisor, according to data provided by the Department. The Department’s difficulty in completing investigations in a timely manner during the audit period is further demonstrated by the number and percentage of investigations that received a 30-day extension. The percentage of cases receiving one or more extensions increased from 7.5 percent in FY15 to 16.1 percent in FY16 and 12.7 percent in FY17. Further, the number of investigations receiving multiple extensions also increased significantly. For instance, the number of investigations that received three extensions (an additional 90 days) increased from 274 investigations in FY15 to 1,263 investigations in FY16 and 719 investigations in FY17. In our review of cases involving an extension, it was also not always clear what the cause for the extension was or whether it rose to the level of “good cause.” Services Conducting an analysis of all recommendations for services and services provided by the Department was not possible for the audit period because of inherent limitations in the data provided by the Department as well as other data reliability and consistency issues. In order to assess the services recommended and services provided, we selected a sample of 150 indicated investigations (50 each year for FY15, FY16, and FY17) and reviewed the investigations for recommended services and any services received. Recommendations for Services The Department’s policies and procedures require that during an investigation the need for services for the family involved in the investigation be assessed by the Child Protection Specialist (investigator) and the Child Protection Supervisor. Our review of 150 indicated investigations found that investigators did not always document that they assessed the need for services by completing the Level of Intervention field in the Department’s information system known as SACWIS. Of the 150 indicated investigations sampled, 16 investigations (10.7%) had no Level of Intervention listed (services recommended). Further, 39 investigations (26.0%) had “No Service Needed” as the Level of Intervention. For most of these cases there was no rationale regarding why no services were being recommended even though the case had been indicated. Additionally, of the investigations sampled, for 64 (42.7%) we found that the Level of Intervention was inaccurate. For Intact Family Services (IFS) provided through the Department, investigators have the responsibility to discuss and offer these services if the final investigation finding of indicated has been recommended. The Department did not document that Intact Family Services were discussed and offered to all families with indicated investigation findings as is required by Department procedures. Only 20 of 150 (13.3%) indicated investigations reviewed contained documentation of a recommendation for Intact Family Services (IFS). An additional 3 investigations had recommendations for multiple services, which included IFS; therefore 23 of 150 indicated investigations had a recommendation of IFS. For 33 of 150 investigations (22.0%), community services were recommended. We could not determine whether any services were recommended or what the specific services were for 67 of 150 (44.7%) indicated investigations reviewed. The remaining 27 investigations included recommendations for 3 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT placement, already receiving services, no services needed, multiple services, Intact Family Recovery, and Norman Cash Assistance. Services Provided We sampled 150 indicated cases for the audit period and found that for 98 cases (65.3%), there was a lack of documentation regarding whether any services were received by the families involved and the duration of those services. The Department could not provide basic information for Intact Family Service cases, such as referral forms, to document that a formal referral for services was made. The Department also could not provide auditors with the number of families served by each IFS contractor each year for the audit period. For investigations involving the Norman Cash Assistance program, the Department could not provide all approval forms. For community services, there are no formal forms for referrals to community based services and the Department is not documenting these services as required by procedures. Therefore, it is difficult to determine if the families actually received services from community providers. Victim Demographics During the audit period, the number of indicated children decreased every year while the total number of alleged victims increased. According to data provided by the Department as of July 27, 2018, for the three-year period FY15-FY17 there were 221,341 investigations involving a total of 358,545 children, 96,576 of whom had at least one indicated allegation. Auditors could not obtain a reliable count of the number of unique victims because of limitations with the data provided by the Department. Each person in the SACWIS system is assigned a unique PersonID. However, auditors found that there were over 8,000 instances where the same child had been assigned multiple PersonIDs. Therefore, auditors could not obtain a reliable count of the number of unique child victims over the audit period because of data limitations. For the 221,341 investigations for FY15-FY17, there were 450,483 total allegations, with an overall indication rate of 25.5 percent. The most common allegations were “Substantial Risk of Physical Injury/Environment Injurious to Health and Welfare by Neglect” and “Inadequate Supervision.” A total of 52,502 children were the alleged victims of sexual abuse during FY15FY17 and 32,439 children were the alleged victims of serious harm. Age Children under the age of one were the most frequent alleged victims of abuse or neglect (8.1% of all victims) and also the most likely to be indicated victims (13.3% of all indicated victims). After the age of one, the number of indicated allegations of abuse or neglect trends downward. Race and Ethnicity For race, children who were identified as White or Black/African-American made up 96.4 percent of all alleged victims (62.5% White and 33.9% Black/African-American) and 97.1 percent of all indicated victims (62.4% White and 34.7% Black/African-American). Data provided by the Department showed that 2.3 percent of alleged victims did not have a race recorded. For ethnicity, children with a Hispanic ethnicity comprised 15.6 percent of all victims and 16.7 percent of indicated victims. 4 CHAPTER ONE - INTRODUCTION AND BACKGROUND Gender For gender, there was an even split between male and female victims. Males accounted for 49.7 percent of all alleged victims and females were 49.6 percent. For indicated victims, males accounted for 49.4 percent and females were 50.3 percent. Geographic Location Auditors found that 25.6 percent of all investigations occurred in Cook County, followed by Lake County with 4.1 percent. There were investigations of alleged abuse or neglect in all 102 counties in Illinois. INTRODUCTION House Resolution Number 418, adopted June 25, 2017, directs the Auditor General to conduct a performance audit of the Department of Children and Family Services (Department) to review and assess the Department’s protocols for investigating reports of child abuse and neglect (see Appendix A). The audit is to include a review of abuse and neglect investigations conducted by the Department in FY15, FY16, and FY17. The audit resolution asks the Auditor General to determine: 1) the status of abuse and neglect investigations; 2) the final determination or findings made by the Department for abuse and neglect investigations; 3) the time frame within which the Department completed or closed abuse and neglect investigations; 4) for sampled cases, recommendations made by the Department to families who were the subject of an abuse or neglect investigation, including any services provided by the Department to the child or family; and 5) demographic information on abuse and neglect investigations, including the age, race, and gender of children who were subjects of the abuse or neglect investigations, and, if available, the zip code and county where the abuse or neglect was alleged to have occurred. Additionally, the audit resolution asked the Auditor General to compile a detailed report that includes a full summary on the number of lawsuits or other legal actions filed against the Department within the past three fiscal years that concern an abuse or neglect investigation and the number of lawsuits the Department settled within the past three fiscal years that concern an abuse or neglect investigation. BACKGROUND The Abused and Neglected Child Reporting Act (ANCRA or the Act) charges the Department of Children and Family Services with the responsibility of receiving reports of child abuse and neglect (325 ILCS 5/2). After a report is received, the Department is statutorily mandated “to protect the health, safety, and best interests of the child in all situations in which the child is vulnerable to child abuse or neglect, offer protective services in order to prevent any 5 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT further harm to the child and to other children in the same environment or family, stabilize the home environment, and preserve family life whenever possible” (325 ILCS 5/2). During 2017, there were several high profile child abuse and neglect cases in which children died shortly after the Department closed investigations into their alleged mistreatment, as well as the case of a 17-month-old who was found deceased in Joliet Township after prior Department probes into alleged mistreatment. There were also other news/media reports that Department investigators were overwhelmed by high caseloads and were being pressured to quickly close cases, even when they had not performed basic tasks such as contacting police and doctors. Agency Organization The Department experienced a change in leadership during FY17. George Sheldon, who was appointed the Director in February 2015, resigned on June 15, 2017. The Department had seven directors or acting directors in the three years prior to Mr. Sheldon being appointed, including two acting directors between the beginning of June 2014 and February 2015. On June 23, 2017, the Governor appointed Beverly Walker as Acting Director. She resigned effective February 15, 2019. The mission of the Department of Children and Family Services is to:    Protect children who are reported to be abused or neglected and to increase their families' capacity to safely care for them; Provide for the well-being of children in DCFS care; Provide appropriate, permanent families as quickly as possible for those children who cannot safely return home; Support early intervention and child abuse prevention activities; and Work in partnerships with communities to fulfill this mission. The Abused and Neglected Child Reporting Act requires that there be a central register of all cases of suspected child abuse or neglect reported and maintained  by the Department under the Act. The Division of Child Protection operates the State Central Register (SCR) including the abuse and neglect hotline and is responsible  for conducting child abuse and neglect investigations. Child Protection receives reports of alleged abuse or neglect through the 24-hour child abuse hotline at the SCR. An investigation of reported child abuse or neglect is generally required to be initiated within 24 hours of its receipt at the SCR. The investigation is conducted for the purpose of determining whether credible evidence of child abuse or neglect exists and whether the family can benefit from any services. The Deputy Director of Child Protection reports directly to the Senior Deputy Director of Operations. Exhibit 1-1 shows an organizational overview of Child Protective Services. When such service needs are identified, Department staff arranges for those services to be initiated. The intensity, duration, and protective character of the services recommended is determined by whether the report is determined to be credible and ruled indicated or determined to be not credible and ruled unfounded. 6 CHAPTER ONE - INTRODUCTION AND BACKGROUND Exhibit 1-1 DCFS CHILD PROTECTIVE SERVICES ORGANIZATIONAL CHART Source: OAG analysis of DCFS organizational charts. Regions and Offices ANCRA requires the Department to establish a Child Protective Service Unit within each geographic region as designated by the Director of the Department (325 ILCS 5/7.2). As is shown in Exhibit 1-2, there are four regions in the State (Northern, Central, Southern, and Cook). The Department has field offices located throughout these regions of the State that report to a Regional Administrator. Child Protection Specialists (investigators) as well as case workers for other areas of operations, such as permanency (placement/foster care), are located at the regional and field offices. Each Regional Administrator reports directly to the Senior Deputy Director of Operations. 7 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Exhibit 1-2 DEPARTMENT OF CHILDREN AND FAMILY SERVICES REGIONAL AND FIELD OFFICES City Location/Address Aurora DeKalb Elgin Freeport Glen Ellyn Joliet Kankakee Rockford Sterling Waukegan Woodstock Northern Region 8 East Galena Blvd. (Regional Office) 760 Peace Road 595 State Street 1826 South West Avenue 800 West Roosevelt Road 1619 West Jefferson Street 505 South Schuyler 200 South Wyman 2607 Woodlawn Avenue 2133 Belvidere Road 113 Newell Street Chicago Deerfield Cook North Region 1911/1921 South Indiana 1755 Lake Cook Road Chicago Chicago Maywood Cook Central Region 1026 South Damen 1240 South Damen 1701 South 1st Avenue Chicago Harvey Cook South Region 6201 South Emerald 15115 South Dixie Highway Bloomington Canton Carlinville Champaign Charleston Danville Decatur Galesburg Jacksonville Jerseyville Lincoln Ottawa Peoria Peoria Central Region 401 Brown Street 1607 East Chestnut Street 1022 North High Street 2125 South First Street (Regional Office) 825 South 18th Street 401 North Franklin Street 2900 North Oakland Avenue 467 East Main Street 46 North Central Park Plaza 108 South State 405 North Limit Taylorville Urbana 1580 First Avenue 2001 North East Jefferson Street 5415 North University Avenue (Regional Office) 107 North 3rd Street 500 42nd Street 1124 North Walnut Street 4500 South 6th Street Road (Regional Office) 115 West Bidwell Street 508 South Race Alton Anna Belleville Cairo Carlyle Southern Region 200 North Center 108 Denny Industrial Drive 1220 Centreville Avenue 1315 Washington 559 12th Street Quincy Rock Island Springfield Springfield City Location/Address East St. Louis Effingham Granite City Harrisburg Marion Marion Metropolis Mt. Vernon Murphysboro Olney Sparta Wood River Southern Region (Continued) 10 Collinsville Avenue (Regional Office) 401 West Industrial Avenue 1925 Madison Avenue 324 East Raymond 2309 West Main Street (Regional Office) 107 Airway Drive 200 West 5th Street 321 A Withers Drive 1210 Hanson Street 1408 Martin 202 West Jackson Street 1407 Vaughn Road Note: A field office in Pekin (Central Region) closed during the audit period, in November 2015. Source: OAG analysis of DCFS data. 8 CHAPTER ONE - INTRODUCTION AND BACKGROUND When a report of suspected child abuse or neglect is received at the SCR, it is transmitted to the appropriate Child Protective Service Unit. The Child Protective Service Units are required to perform certain functions assigned by the Act (325 ILCS 5/). These include:   Investigating reports of alleged abuse or neglect and commencing these investigations within 24 hours of receipt of a report, unless it’s an emergency (325 ILCS 5/7.4(b)(2)); and Providing or arranging for comprehensive emergency services to children and families (325 ILCS 5/7.4(b)(3)). CHILD ABUSE AND NEGLECT INVESTIGATIONS DATA House Resolution Number 418 asks the Auditor General to review the Department’s investigations of abuse and neglect including the status, final determination, time frames, services, and demographic information. In order to conduct our review of these issues, we relied on data provided by the Department. The Government Accountability Office (GAO) Yellow Book (section 6.66) requires that auditors should assess the sufficiency and appropriateness of computer-processed information regardless of whether this information is provided to auditors or auditors independently extract it. Further, the Yellow Book states that the assessment of the sufficiency and appropriateness of computer-processed information includes considerations regarding the completeness and accuracy of the data for the intended purposes. The Department had significant issues producing accurate reports on child abuse and neglect investigations statistics during the audit period and while we were conducting the audit. These issues were caused primarily by inadequate and antiquated information systems. However, we also identified concerns with the quality of the data contained in the Department’s primary information system, the Statewide Automated Child Welfare Information System (SACWIS). While recognizing the shortcomings of the data provided, in our opinion, the data was reliable enough to use in the general context of addressing the audit’s objectives including sampling services. On January 26, 2018, auditors met with Department of Children and Family Services and Department of Innovation and Technology officials and requested data to support statistics presented in the Department’s Executive Statistical Summary reports for the audit period (FY15FY17). According to officials, in August 2017, the linkage between the system that contains the abuse and neglect investigations information (SACWIS) and the system used for producing the statistical reports (NOMAD) broke, rendering them unable to produce statistical reports. During the course of the audit, the Department could not produce monthly abuse and neglect statistical reports for at least eight months (August 2017 through March 2018). On April 17, 2018, the Department released a “Message From The DCFS Director Regarding Public Release of Data” and reissued abuse and neglect statistics for the past five years (FY13-FY17) that were presented in its executive statistical reports. According to the Director’s message, the Department has been severely hampered by woefully out-of-date technology, half-finished information systems, and reporting that required multiple manual steps. Limitations of Provided Data After reviewing abuse and neglect data from SACWIS, auditors concluded that the Department needs to continue to work to improve the quality of its abuse and neglect data and 9 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT improve controls that are in place to ensure abuse and neglect data is accurate. For example, this could be accomplished by limiting the amount of manual data entry by using more drop-down choice menus and reducing the amount of missing data by forcing more required fields in order to save a record. On July 27, 2018, the Department provided auditors with a download of data for intakes, investigations, and victim demographics for the audit period FY15-FY17. This data had several limitations and shortcomings including:  Inconsistent Data Entry – For example, we identified 39 different spellings for the City of Chicago in the data we were provided.  Missing Data (i.e., unknown, null, or blank fields) – As an example, the place of occurrence field contained 11.8 percent (26,174) of investigations listed as NULL, which is returned when a field is blank. An additional 7.7 percent (17,061) of addresses could not be verified through the US Postal Service. Therefore, the total number of investigations in which the occurrence address was unknown or unverified was 19.5 percent.  Input Errors and Incorrect Information – When an allegation is received at the hotline an intake is created. When an intake is completed it is sent to a field office for investigation. Data provided by the Department showed investigations that were begun prior to the intake being completed. For example, there were 666 times where the victim contact date and time was prior to the intake end date and time and 4,554 times where the initial Child Endangerment Risk Assessment Protocol (CERAP) date was prior to the intake end date and time. In order to account for individuals on an unduplicated basis, they are assigned unique IDs in SACWIS (known as PersonIDs). We found 909 alleged victims who had the same PersonID but more than one date of birth and 333 alleged victims who had the same PersonID but more than one gender (195 victims were listed as both male and female and 138 were listed as a gender and unknown).  Individuals With Multiple PersonIDs - We found 8,061 individuals that may have multiple PersonIDs. The number of IDs for any one individual ranged from 2 to 4 different IDs. Therefore, counts of individuals, such as those involving demographics, are likely inflated in some cases. Issues with PersonIDs are discussed further in Chapter Five of this report. The Department’s reissued published statistics may still include inaccurate data. Although the reissued data generally matched data provided to us by the Department, there were some instances in which we question the accuracy of specific types of reports. For instance, the Department’s statistical reports for substance exposed infants appears to include children with no recorded date of birth. Our analysis showed that many of these cases may not meet the definition of substance exposed infant (under age one). In response to our follow-up, officials stated that concerns about data accuracy are largely a matter of the original source and the existence of several different technology systems with overlapping information but separate data origination practices. According to officials, “the issue really is the substantial reliance on human data entry, the number of systems in use with different users and different purposes, and the lack of dynamic adaptation to changing practices.” 10 CHAPTER ONE - INTRODUCTION AND BACKGROUND The Department also needs to update its SACWIS manual. According to Department officials, the manual for SACWIS has not been updated since 2001. During the audit, the Department could not provide auditors with a list of the field definitions for data included in SACWIS. Auditors had to develop definitions for the SACWIS data fields utilized for our data requests and have officials review and comment on those field definitions. Due to the lack of an updated SACWIS manual, the Department could not provide auditors with a list of which fields were required to be entered, the type of data entry for each field, or any other data entry controls. ANCRA requires that there shall be a central register of all cases of suspected child abuse or neglect reported and maintained by the Department under the Act. Through the recording of initial, preliminary, and final reports, the central register shall be operated in such a manner as to enable the Department to: (1) immediately identify and locate prior reports of child abuse or neglect; (2) continuously monitor the current status of all reports of child abuse or neglect being provided services under the Act; and (3) regularly evaluate the effectiveness of existing laws and programs through the development and analysis of statistical and other information (325 ILCS 5/7.7). Producing accurate data and timely reports is critical to monitoring agency performance and regularly evaluating the effectiveness of existing laws and programs as is required by ANCRA. Further, not producing timely and accurate reports can lead to the perception that there is a lack of transparency with lawmakers and other stakeholder interest groups. 11 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT CHILD ABUSE AND NEGLECT DATA RECOMMENDATION 1 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should continue to take steps to improve the quality of the data contained in its child abuse and neglect information systems and statistical reports. These steps should include:  Ensuring that proper controls are in place for SACWIS data entry, or any future child abuse and neglect information systems, in order to ensure that data is collected and is reliable; and  Maintaining updated manuals including data field definitions. The Department agrees with the recommendation. Steps to improve the quality of the Child Abuse and Neglect Data have been taken: Current Steps In Action:   Several SACWIS releases have release improvements to data quality. Data Field definitions are being assembled into a Data Dictionary. Planned Steps:    Project is being sourced to execute soon to execute data cleanup on Child Abuse and Neglect Data. CCWIS program will replace current systems offering more advanced data validation capabilities. CCWIS requires a Data Quality plan which will address data quality controls throughout the lifecycle of Child Abuse and Neglect date [sic]. Other Inherent Data Limitations In addition to the data issues discussed above, there are also practices that may result in duplicate data and counts. For example, per Department Procedure 300.30(b), the Department will initiate multiple investigations for a single incident if there are multiple alleged perpetrators who do not reside in the same house or if there are multiple independent families who reside in the same house. Therefore, the Department does not track or report child abuse or neglect incidents, but instead reports either investigations or victims. Additionally, if an incident at a facility involves multiple employees, a separate report is taken for each alleged perpetrator. This can lead to duplication in the data reported because there can be multiple investigations related to the same incident and the same victims involved with multiple investigations related to the same incident. This may inflate the number of victims because the single incident is reported as multiple investigations. As an example, for the audit period there were 14 instances in which multiple investigations were initiated for a single death. Therefore, these 14 allegations resulted in 33 separate investigations. This was because there were multiple alleged perpetrators. 12 CHAPTER ONE - INTRODUCTION AND BACKGROUND Hotline Calls, Intakes, and Investigations Data Exhibit 1-3 HOTLINE CALLS AND INTAKES FY15-FY17 The Department is required by FY15 FY16 FY17 Total statute to be capable of receiving reports Hotline 222,719 245,388 252,568 720,675 of suspected child abuse or neglect 24 Calls1 hours a day, 7 days a week (325 ILCS Intakes 187,182 181,288 172,907 541,377 5/7.4(a)). The Department accomplishes 1 Hotline call data is from DCFS’ Executive Statistical this through a hotline at the SCR. Summary for FY17 as of June 30, 2018. According to the Department statistical Source: OAG analysis of DCFS data as of July 27, 2018. reports, the total number of hotline calls increased significantly for the audit period going from 222,719 in FY15 to 252,568 in FY17 or 13.4 percent (see Exhibit 1-3). When an allegation is received at the hotline an intake is created. An intake is created depending upon the type of issue being reported to the hotline. For example, an intake may be for a new abuse or neglect allegation or an ongoing case. Intakes may also be created for issues such as licensing referrals. According to data provided by the Department, the number of intakes decreased from 187,182 in FY15 to 172,907 in FY17 or 7.6 percent. Abuse and neglect investigations increased significantly between FY15 and FY17, going from 67,732 to 75,037 or 10.8 percent. There is a notable spike in FY16 to 78,572 investigations. The increase in investigations between FY15 and FY16 represents a year over year increase of 16.0 percent. While the number of investigations Exhibit 1-4 CHILD ABUSE AND NEGLECT STATISTICS of child abuse and neglect has increased FY15-FY17 over the three-year period FY15-FY17, FY15 FY16 FY17 the percentage indicated has decreased. An indicated investigation is one in which Investigations 67,732 78,572 75,037 there is credible evidence that the incident Indicated Reports1 19,156 18,710 18,591 occurred. The percent of indicated Percent Indicated 28.3% 23.8% 24.8% investigations decreased for the three-year 1 Indicated reports include those that were indicated due to period from 28.3 percent in FY15 to 24.8 review. percent in FY17. Of note is the nearly Source: OAG analysis of DCFS data as of July 27, 2018. five percent year-over-year decrease in the indication rate from FY15 to FY16. For FY16, total allegations investigated spiked to a high of 78,572, while the indicated rate sank to a low of 23.8 percent (see Exhibit 1-4). The numbers presented in Exhibit 1-3 and Exhibit 1-4 match closely to the updated numbers issued by the Department in April 2018. Auditors asked Department officials for any possible causes for the drop in the indication rate. Officials stated that looking at the rates for FY14 through FY18 there was a large increase in the indication rate between FY14 and FY15 before going back down in FY16 and the rates at the regional level seem to level out over the period. 13 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT LAWSUITS House Resolution Number 418 asks the Auditor General to compile a detailed report that includes a full summary on the number of lawsuits or other legal actions filed against the Department within the past three fiscal years that concern an abuse or neglect investigation and the number of lawsuits the Department settled within the past three fiscal years that concern an abuse or neglect investigation. We met with Department officials, including the Chief Legal Counsel, to collect information regarding lawsuits and settlements. The Department provided auditors with cases and information related to the lawsuits and settlements for the audit period. Our review of documentation associated with lawsuits, settlements, and other legal actions for the audit period generally involved two types of lawsuits/settlements:   Those that involved an alleged violation of constitutional rights; and Those related to appeals of an administrative review/decision by the Department. We identified 23 lawsuits involving an allegation of a violation of constitutional rights that were related to an abuse or neglect investigation that were either filed during FY15-FY17 or a settlement or ruling was issued during the period. Of these 23 cases:     10 cases involved a settlement; 8 of the 10 settlements involved monetary amounts totaling $676,000; 7 of the 10 settlements involved a change in policy or procedure; 4 cases were dismissed; 1 case was reversed; and 8 cases were still pending as of April 2018; however the Department was no longer a party to 3 of those cases. One of the cases still pending involves a Department provider which, according to the Department, it is legally responsible for defending. For a detailed summary of these lawsuits and settlements see Appendix C of this report. From information provided by the Department, we also reviewed lawsuits in which an appeal was filed after an investigation was completed in which the administrative decision was further challenged in court. In total, we identified 276 cases in which a court challenge was filed or decision was made during the three-year period FY15-FY17. Of these cases:       72 cases were dismissed; 64 cases were affirmed (meaning the Department’s decision was upheld); 43 cases were remanded back to the Department for further review; 37 cases were pending as of April 2018; 34 cases were reversed or overturned; and 26 cases were settled. 14 Chapter Two INVESTIGATION PROTOCOL CHAPTER CONCLUSIONS The Department has established administrative rules and extensive policies and procedures that delineate the investigations process and protocol to be followed during investigations. The protocol includes timelines to be followed, interviews to be conducted, forms to be completed, and documentation to be collected in completing investigations of child abuse and neglect. However, we found that the Department did not always follow procedures in conducting investigations. For the audit period, the Department did not comply with investigator assignment requirements delineated in the B.H. Consent Decree. The B.H. Consent Decree requires that each child protective services investigator be assigned no more than 12 new abuse or neglect investigations per month during nine months of a calendar year and during the other three months of the calendar year, no more than 15 new investigations per month. Our analysis of primary assignments for FY15-FY17 showed that 78.7 percent of investigators (729 of 926) had at least 1 month during the audit period in which they received more than 15 new assignments. Further, our analysis showed that 32 investigators averaged more than 15 case assignments per month for the entire three-year period. In addition, there were 114 investigators who did not receive assignments for all 36 months and averaged more than 15 assignments per month for the months worked during the period. We could not document that the Department had evaluated the reliability and validity of the Child Endangerment Risk Assessment Protocol (CERAP) as required by the Children and Family Services Act (20 ILCS 505/21(e)). The CERAP is a six-page safety assessment protocol designed to provide investigators with a mechanism for quickly assessing the potential for moderate to severe harm to children in the immediate or near future and for taking quick action to protect them. The Department also could not provide specific CERAP training procedures required by statute. Status and Final Determination of Investigations Our analysis for the three-year period FY15-FY17, as of July 27, 2018, showed that the status for a majority of cases, 142,766 of 221,341 investigations or 64.5 percent, was classified as expunged. Expunged investigations for the period were unfounded investigations in which most information, including the name of the alleged perpetrator, had been hidden or removed from the investigation information. An additional 78,520 (35.5%) investigations were classified as closed. For the remaining 55 investigations:       22 were undetermined (3 cases were FY16 and 19 cases were FY17) 18 were in appeal (15 cases were FY15, 1 case was FY16, and 2 cases were FY17); 9 were purged or concealed (all were FY15 cases); 3 were in review (one from each fiscal year); 2 were in a 20-day hold (both were FY17 cases); and 1 was pending approval (an FY17 case). 15 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT According to data provided by the Department, 25.5 percent of investigations (56,457 of 221,341) for the three-year period FY15-FY17 had a final determination or finding of indicated, meaning there was credible evidence that the allegation occurred. For 74.5 percent of all investigations the status was unfounded (164,864 of 221,341 investigations). As of July 2018, there were 20 investigations for FY16 and FY17 that were listed as pending. INVESTIGATION PROCESS The Department of Children and Family Services (Department or DCFS) is mandated by the Abused and Neglected Child Reporting Act (ANCRA) to investigate allegations of child abuse or neglect (325 ILCS 5/2). The definitions for what constitutes abuse and neglect are established by the Act (325 ILCS 5/3), and the specific allegation types of abuse and neglect are described in the Department’s Procedures 300 Appendix B. The Department did not always follow procedures in conducting investigations. The Department has established a formal investigative protocol by promulgating administrative rules and developing written policies and procedures. These processes and protocol include establishing timelines to be followed, interviews to be conducted, forms to be completed, and documentation to be collected in completing investigations of child abuse and neglect. The Department’s administrative rules govern how child abuse and neglect is reported and how such reports are handled and investigated (89 Ill. Adm. Code 300). Department procedures (Procedures 300) cover the investigation process in more detail from the point at which a report is received alleging a child may have been abused or neglected to the completion of the investigation and is more than 500 pages. The following sections discuss the investigations process and protocol, including requirements and timelines. Exhibit 2-1 shows a basic overview of the investigation process. Reporting Allegations Protecting children involves a strong system of screening reported allegations, a properly assessed “front end” investigation, effective use of investigative tools, and timely service delivery. The process of investigating suspected child abuse and neglect begins at the SCR (State Central Register). Call floor workers at the SCR receive calls through the Child Abuse Hotline. All reports of suspected child abuse or neglect made under ANCRA are required to be reported immediately by telephone to the SCR’s toll-free telephone number (1-800-25-ABUSE) established by the Act. Reports can also be made in person or by telephone through the nearest Department office (325 ILCS 5/7). The Department is required to be capable of receiving reports of suspected child abuse or neglect 24 hours a day, 7 days a week (325 ILCS 5/7.4). When a report of abuse or neglect is received, call floor workers at the SCR enter information into the Statewide Automated Child Welfare Information System (SACWIS). Reports are required to include, if known, information such as the name and address of the child and his parents or other persons having custody, the child's age, and the nature of the child's condition including any evidence of previous injuries or disabilities (325 ILCS 5/7). 16 CHAPTER TWO – INVESTIGATION PROTOCOL Call floor workers at the SCR take steps to gather information and to determine whether the alleged abuse or neglect is “reportable” and the proper response. To be reportable and sent on for investigation, three criteria must be met. There must be: (1) an eligible perpetrator, (2) an eligible victim, and (3) a specific incident or set of circumstances. Victims must be under 18 years of age or between the ages of 18 and 22 if living in a Department licensed facility. For abuse, eligible perpetrators include the victim’s parent, immediate family member, someone who resides in the same household, anyone who is responsible for the child’s welfare when the incident occurred, a parent’s significant other, or any person who knows the child through an official capacity or is in a position of trust. For neglect allegations, perpetrators must be a parent or any other person who is responsible for the care of the child when the neglect occurred. Exhibit 2-1 INVESTIGATION PROCESS OVERVIEW HOTLINE A call is received at the Child Abuse Hotline (1-800-25-ABUSE). If a call floor worker is not available, a message is taken, and the individual is called back at a later time. INTAKE An intake is created and is transmitted to a local DCFS field office and is assigned to an investigator. INVESTIGATION INITIATION Within 24 hours an investigation must be initiated by in-person contact with the alleged victim or making a good faith attempt. INVESTIGATION STEPS The Investigation process includes interviewing individuals, gathering documentation, and completing the Child Endangerment Risk Assessment Protocol (CERAP). - Within 7 days the investigator must make in-person contact with the alleged perpetrator or make a good faith attempt. - Within 55 days the investigator must submit a completed investigation or request an extension. If the call is determined to be reportable, it is sent to a local field office for investigation. Before the report is sent to the field office, the call floor worker has to establish what type of response the report will receive, which determines how quickly an investigator will respond to the report. If the call is deemed to be out of jurisdiction, the call is entered into SACWIS and is available for use as related information for concurrent active investigations or if a later call prompts an investigation. These reports may also be referred to other agencies or law enforcement. INVESTIGATION COMPLETION Within 60 days the investigation is required to be completed unless an extension is approved. Source: OAG analysis of DCFS investigative process. 17 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Investigator Assignments and Caseloads The Department should take steps to decrease the number of investigations assigned to each investigator in order to comply with the requirements of the B.H. Consent Decree. Allegations that are determined to be reportable are assigned geographically, based on the child’s address, to a local field office. Once the Hotline staff determines the allegation is reportable, it must be sent to the local field office within one hour of receipt of the report (Procedures 300.40(a)). The field offices receive the investigation assignment electronically via a local mailbox in SACWIS. The investigation is assigned to an investigator (Child Protection Specialist or Advanced Specialist) by a supervisor at the field office. According to Department procedures, the supervisor should assign reports based on rotation, with due consideration given to the experience, expertise, and availability of staff (Procedures 300.70(c)(1)). Investigators given the primary assignment have the responsibility to complete the investigation within 60 days. For case load analysis purposes, the Department tracks primary assignments lasting more than 24 hours. We analyzed investigator assignment data provided by the Department for the period FY15-FY17 for primary assignments lasting more than 24 hours and found that total monthly investigator assignments increased from 5,001 in July 2014 to 6,527 in June 2017 or 30.5 percent. Of particular note is the dramatic increase between July 2014 and May 2016 from 5,001 monthly assignments to 8,326 monthly assignments. This represents a 66.5 percent increase over a 23 month period (see Exhibit 2-2). During the same period the number of investigators with assignments dropped from 544 in July 2014 to 497 in May 2016. Exhibit 2-2 TOTAL ASSIGNMENTS BY MONTH FY15-FY17 9,000 8,500 8,000 7,500 7,000 6,500 6,000 5,500 5,000 4,500 4,000 Source: OAG analysis of DCFS data for primary assignments as of July 27, 2018. 18 CHAPTER TWO – INVESTIGATION PROTOCOL Case assignments were extremely high during FY15-FY17 for certain field offices. Exhibit 2-3 shows the ten investigators with the most total assignments during the period. As can be seen in the exhibit, the top ten investigator assignments are dominated by the Northern area of the State. Specifically, they include field offices in Joliet, Rockford, and Waukegan. Exhibit 2-3 TOP 10 INVESTIGATORS WITH THE MOST ASSIGNMENTS BY FISCAL YEAR FY15-FY17 Investigator 1 2 3 4 5 6 7 8 9 10 Field Office(s) Joliet/Waukegan Rockford/Joliet Rockford Rockford/Joliet/Waukegan Waukegan Rockford Various Rockford Joliet Joliet/Cook South Region Northern Northern Northern Northern Northern Northern Central Northern Northern Northern/Cook FY15 242 163 176 152 149 157 183 155 163 187 FY16 364 433 299 384 252 275 251 260 392 288 FY17 237 212 252 182 309 266 246 259 108 176 Total 843 808 727 718 710 698 680 674 663 651 Source: OAG analysis of DCFS data for primary assignments as of July 27, 2018. B.H. Consent Decree Investigation Assignment Requirements The Department is not complying with investigator assignment requirements delineated in the B.H. Consent Decree. In 1988, a class action lawsuit was filed against the Department alleging that it failed to provide adequate services to children in its custody. In 1991, the parties entered into a consent decree known as the B.H. Consent Decree (88 C 5599 (N.D. Ill.)). The parties filed a restated consent decree in 1997 and have continued to modify the Consent Decree as needed. As part of our review of Department protocols for investigating reports of child abuse and neglect, we reviewed the B.H. Consent Decree. The Consent Decree included a provision that states: By July 1, 1993, each DCFS child protective services investigator will be assigned no more than 12 new abuse or neglect investigations per month during nine months of a calendar year. During the other three months of the calendar year, the investigator will be assigned no more than 15 new abuse or neglect investigations per month. Our analysis of primary assignments showed that 926 different investigators received at least one assignment during the period. Of these, 729 or 78.7 percent had at least 1 month during the period in which they received more than 15 primary assignments. In June 2016, an investigator received 113 primary assignments in a single month. Exhibit 2-4 shows the average number of assignments by month for the three fiscal years. Our analysis showed that 32 investigators averaged more than 15 case assignments per month for the entire three-year period. Further, an additional 114 investigators who did not receive assignments for all 36 months averaged more than 15 assignments per month for the months worked during the period. 19 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Exhibit 2-4 AVERAGE NUMBER OF ASSIGNMENTS BY MONTH FY15-FY17 18 17 16 15 14 13 12 11 10 9 8 Note: The B.H. Consent Decree requires that there can be no more than 12 new abuse or neglect investigations assigned to an investigator per month during nine months of a calendar year and during the other three months of the calendar year, the investigator can be assigned no more than 15 new investigations per month. Source: OAG analysis of DCFS data as of July 27, 2018. Using the criteria for assignments contained in the B.H. Consent Decree, a child protective services investigator should not receive more than 153 new assignments annually. Because the B.H. Consent Decree investigation assignment requirement is based on a calendar year, we also reviewed calendar year 2015 and calendar year 2016. These were the only years for which we had complete calendar year information. For calendar years 2015 and 2016, 36.8 percent and 36.1 percent of investigators respectively were assigned more than 153 primary assignments and were therefore in violation of the B.H. Consent Decree. Exhibit 2-5 shows that as the total number of investigators decreased during FY16, the higher the percent of investigators who were out of compliance with the B.H. Consent Decree’s maximum allowable new assignments of 15 new assignments. The exhibit also shows that for February through April 2016 over half of all investigators were out of compliance. 20 CHAPTER TWO – INVESTIGATION PROTOCOL Exhibit 2-5 INVESTIGATORS WITH MORE THAN 15 NEW ASSIGNMENTS BY MONTH FY15-FY17 600 500 400 300 524 539 517 503 363 363 352 537 516 499 287 383 453 287 309 296 275 224 226 226 250 329 437 291 390 387 394 334 389 393 401 426 406 386 407 402 200 100 70 20 14 41 58 11 33 42 195 211 168 177 196 113 89 87 237 255 253 247 244 171 128 177 181 144 128 185 117 87 113 126 123 Jul-14 Aug-14 Sep-14 Oct-14 Nov-14 Dec-14 Jan-15 Feb-15 Mar-15 Apr-15 May-15 Jun-15 Jul-15 Aug-15 Sep-15 Oct-15 Nov-15 Dec-15 Jan-16 Feb-16 Mar-16 Apr-16 May-16 Jun-16 Jul-16 Aug-16 Sep-16 Oct-16 Nov-16 Dec-16 Jan-17 Feb-17 Mar-17 Apr-17 May-17 Jun-17 0 159 153 158 Investigators with less than 15 assignments Investigators with more than 15 assignments Source: OAG analysis of DCFS data as of July 27, 2018. Investigators who are overloaded with new assignments may be more prone to make mistakes and put children involved in their investigations at serious risk. It may also lead to investigator burnout and high turnover. Ensuring more reasonable caseloads would benefit the Department in achieving positive outcomes for children and families. INVESTIGATOR ASSIGNMENTS RECOMMENDATION 2 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should take steps to ensure investigator assignments are in compliance with the requirements of the B.H. Consent Decree. The Department of Children and Family Services (“Department”) has taken steps to ensure that investigator assignments are in compliance with the requirements of B.H. Consent Decree. The Department has established internal monthly meetings with the Regional Administrators from the Operations Division and the Office of Legal Services to review caseloads in order to maintain compliance with the B.H. Consent Decree. The Department meets with the plaintiff’s in the B.H. case monthly to discuss caseloads. The Department provides a monthly report to the B.H. plaintiffs on caseloads. The Department has created DAI positions to assure adequate staffing for investigations. Child Endangerment Risk Assessment Protocol Child Endangerment Risk Assessment Protocols (CERAPs) were not always completed by investigators and private agency staff providing services. Further, for those cases in which 21 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT the CERAP was completed, it was not always completed in a timely manner. The Department could not provide documentation to show that the reliability and validity of the protocol had been evaluated during the audit period as required by statute. The Department also could not provide written procedures for training related to the CERAP as required by statute. The CERAP is a six-page safety assessment protocol used through all stages of involvement with the Department, including child protection investigations (Form CFS 1441). This “life-of-the case” protocol is designed to provide investigators with a mechanism for quickly assessing the potential for moderate to severe harm to children in the immediate or near future and for taking quick action to protect them. Department employees as well as service providers utilize the protocol at specified milestones throughout an investigation or child welfare case to help them determine whether a child is safe or unsafe, and if unsafe, decide what actions must be taken to assure their safety. When immediate risk to a child’s safety is identified, the protocol requires that action be taken, such as the implementation of a safety plan or protective custody. Any child safety threats identified as the result of the CERAP must be incorporated into the SACWIS Family Service Plan. CERAPs Completed During Investigations Investigators are required to complete at least one CERAP for every non-facility investigation. The CERAP is required to be completed:     Within 24 hours after the investigator first sees the child. Whenever evidence or circumstances suggest that a child’s safety may be in jeopardy. Every 5 working days following the determination that a child is unsafe and a safety plan is implemented. At the conclusion of the formal investigation, unless temporary custody is granted or there is an open intact case or assigned caseworker. The safety of all children in the home, including alleged victims and non-involved children, must be assessed. Any child safety threats identified as the result of the CERAP are required to be incorporated into a Family Service Plan. The supervisor or designee is required to approve the CERAP within 24 hours after the worker has completed it, if a safety threat has been marked “unsafe” (Procedures 300 Appendix G). We reviewed investigations data provided by the Department for FY15-FY17 to determine if initial CERAPs were being Exhibit 2-6 completed and whether it was within the INITIAL CERAP TIMELINESS required timeframes. There were 130 FY15-FY17 investigations where a CERAP was not FY15 FY16 FY17 completed after contact with the victim as Not Timely 13.9% 10.1% 6.4% required. The number remained steady Timely 79.8% 81.7% 85.1% for all three fiscal years, with 43 in FY15, Unknown/Other1 6.3% 8.2% 8.5% 45 in FY16 and 42 in FY17. 1 Unknown/Other includes investigations in which information needed to calculate timeliness was blank or A CERAP must be completed returned a negative value, such as when a CERAP was not within 24 hours after the investigator first required. sees the alleged victim. We reviewed the Source: OAG analysis of DCFS data as of July 27, 2018. time from contact with the victim to the time the first CERAP was approved and found that a CERAP is not always completed in a timely 22 CHAPTER TWO – INVESTIGATION PROTOCOL manner. However, as shown in Exhibit 2-6 CERAP timeliness of completion appeared to improve during the audit period from 79.8 percent in FY15 to 85.1 percent in FY17. As part of our sample of 150 indicated investigations we also reviewed whether the final CERAPs were being conducted at the completion of the investigation. For 35 of 150 investigations (23.3%) we determined that the investigation did not have a final CERAP conducted and there was no valid exception (i.e., a services case was opened or the supervisor waived the requirement). CERAP Completed During Intact Family Services Intact Family Services (IFS) and other services are discussed in Chapter Four. If the case involves IFS, a CERAP is required to be completed by the Department or the private agency:      Within 5 working days after initial case assignment and upon any and all subsequent case transfers. Every 90 calendar days from the case opening date. Whenever evidence or circumstances suggest that a child’s safety may be in jeopardy. Every 5 working days following the determination that a child is unsafe and a safety plan is implemented. Within 5 working days of a supervisory approved case closure. As part of our sample of 150 indicated investigations, we also reviewed whether CERAPs were being completed at the beginning and end of services and whether it was within the required timeframes for applicable cases. One IFS case did not have a required CERAP at the end of the services. Three of 19 IFS cases (15.8%) did not have the initial CERAP completed within 5 business days of case opening, and two IFS cases (10.5%) did not have the final CERAP completed within 5 business days of case closing. The University of Illinois Children & Family Research Center prepares a report for the Department annually regarding the CERAP. The FY18 CERAP Annual Evaluation utilized FY14-FY17 data to assess whether those providing Intact Family Services (IFS) were completing the CERAP as required. Overall the report concluded that:     No CERAP was completed for some IFS cases. This ranged from 16.2 percent for FY15 to 12 percent for FY17. CERAPs were not always completed timely for IFS cases. This ranged from 26.2 percent for FY15 to 20 percent for FY17 that were not completed within 15 days of the case open date (a CERAP is required to be completed within 5 working days after initial assignment). For IFS cases open more than 90 days, CERAPs were not always completed as required. For 33.5 percent in FY15, 30.0 percent in FY16, and 37.2 percent in FY17, CERAPs were not completed as required. For IFS cases that had a CERAP that determined the child to be unsafe, another CERAP was not always completed as required within 5 days. This ranged from 36.5 percent in FY15 to 31.2 percent in FY17. 23 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Compliance With Statutory CERAP Requirements The Department did not comply with provisions of the Children and Family Services Act that require the Department to evaluate the reliability and validity of the CERAP. The Department also could not provide CERAP training procedures as is required by statute. The Children and Family Services Act (20 ILCS 505/21(e)) requires that the Department shall develop and implement the following: (1) A standardized child endangerment risk assessment protocol. (2) Related training procedures. (3) A standardized method for demonstration of proficiency in application of the protocol. (4) An evaluation of the reliability and validity of the protocol. The Act also requires the Department to report to the Illinois General Assembly annually on the evaluation of the reliability and validity of the CERAP. Although, the Department provided documentation to show it had completed and submitted CERAP annual evaluation reports to the General Assembly, these reports did not contain conclusions regarding the reliability and validity of the Protocol. The Department could not provide CERAP training procedures that were also required to be implemented by the Act. Department officials provided auditors with CERAP training materials as well as general training procedures. However, they could not provide specific training procedures for CERAPs. When auditors inquired about the annual evaluations, officials replied that the evaluation does assess the reliability and validity of the CERAP. Testing to see if a CERAP has been completed is an aspect of the protocol’s reliability. However, if the only way the reliability of the CERAP is assessed is by completion rates, there’s no measure of whether the CERAP was completed correctly. Department investigators deal with heavy workloads and there could be pressure to make sure the CERAP is completed on time, without necessarily ensuring it was properly or fully completed. Because the Department is not evaluating the reliability and validity of the CERAP, it cannot ensure that the protocol is effective and ensures the safety of children. Written training procedures for investigators would help ensure consistent use of the protocol. 24 CHAPTER TWO – INVESTIGATION PROTOCOL CHILD ENDANGERMENT RISK ASSESSMENT PROTOCOL RECOMMENDATION 3 The Department of Children and Family Services should:    DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE Ensure that CERAPs are completed for investigations and that they are completed in a timely manner; Ensure that CERAPs are completed and that they are completed in a timely manner when Intact Family Services are provided; and Evaluate the reliability and validity of the CERAP annually and develop written procedures related to CERAP training as is required by the Children and Family Services Act. The Department has management reports in place for both intact and investigations that identify activity regarding CERAP completion. Supervisors will be trained on the reports and reminded of the need to ensure CERAPS are completed within procedure timeframes. This will be completed within the next 90 days. The CERAP Citizen Advisory group will ensure their ongoing research projects address validity and reliability as defined by the auditors; the next project is due by May 2020. Written procedures related to CERAP training will be enhanced to reflect the requirements of the Children and Family Services Act by October 2019. A random selection of cases will be reviewed quarterly by the Compliance Administrator to address timely completion. STATUS OF ABUSE AND NEGLECT INVESTIGATIONS House Resolution Number 418 asks the Auditor General to review the status of abuse and neglect investigations for FY15, FY16, and FY17. The status of abuse and neglect investigations may be classified as Closed, Expunged, Undetermined, In Appeal, In Review, 20-Day Hold, Purged/Concealed, and Pending Approval. The status codes used in SACWIS are generally not defined in either the statutes, administrative rules, or in the Department’s investigative procedures. Therefore, auditors developed the definitions for each status code, and Department officials reviewed and commented on the descriptions.  Expunged - An unfounded investigation where the records are unviewable or an indicated investigation in which the retention period has lapsed. According to ANCRA, all information identifying the subjects of an unfounded report shall be expunged from the register, except as provided by statute. Examples of exceptions included are for an intentional false report or the death of a child.  Closed - An investigation has been completed, a decision has been rendered on the case, and it has been approved and closed.  Undetermined – The investigation could not be completed within the required 60 days. These investigations are usually waiting for additional information; the finding may or may not be determined based on what information is pending. 25 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT   In Appeal – An investigation that has been appealed and is currently going through the appeal process. Purged or Concealed – The investigation retention period is up for a specific individual, but there may be more perpetrators listed, or the subjects of the report are involved with another report/case in the system; the person for whom the retention period is up will be purged/concealed within the investigation. This is an automatic function set up within SACWIS. Exhibit 2-7 STATUS OF INVESTIGATION FY15-FY17 Case Status FY15 FY16 FY17 Total Expunged 46,570 51,024 45,172 142,766 Closed 21,137 27,543 29,840 78,520 - 3 19 22 In Appeal Purged or Concealed 15 1 2 18 9 - - 9 In Review 1 1 1 3 20-Day Hold Pending Approval - - 2 2 - - 1 1 67,732 78,572 75,037 221,341 Undetermined Total Source: OAG analysis of DCFS investigations data as of July 27, 2018.  In Review – An investigation that is awaiting a mandated reporter’s second review. These are performed by the Department Compliance Manager or Area Administrators.  20-Day Hold - An investigation that is waiting for a response from the mandated reporter. If an investigation is unfounded the mandated reporter has the right to request a review. If the mandated reporter does not respond, the investigation reverts to closed at the end of 20 days.  Pending Approval – An investigation that is currently awaiting supervisory approval in order to be completed. The Department provided auditors with investigations data for all intakes completed during FY15, FY16 and FY17, as of July 27, 2018. Our analysis for the three-year period showed that a majority of cases (142,766 investigations or 64.5%) were classified as expunged (see Exhibit 2-7). Expunged investigations for the period were unfounded investigations in which most information, including the name of the alleged perpetrator, had been hidden or removed from the investigation information. An additional 78,520 (35.5%) investigations were classified as closed. For the remaining investigations:       22 were undetermined (3 cases were FY16 and 19 cases were FY17); 18 were in appeal (15 cases were FY15, 1 case was FY16, and 2 cases were FY17); 9 were purged or concealed (all were FY15 cases); 3 were in review (one from each fiscal year); 2 were in a 20-day hold (both were FY17 cases); and 1 was pending approval (an FY17 case). 26 CHAPTER TWO – INVESTIGATION PROTOCOL FINAL DETERMINATIONS AND FINDINGS House Resolution Number 418 asks the Auditor General to review the final determination or finding of abuse and neglect investigations for FY15, FY16, and FY17. A determination is the final Department decision about whether there was credible evidence that child abuse or neglect occurred. The final determination or finding of abuse and neglect investigations may include indicated, undetermined, or unfounded. Below is a description of each type of determination.  Indicated – Credible evidence of abuse or neglect has been obtained pertinent to the allegation.  Unfounded – Credible evidence of abuse or neglect has not been obtained.  Undetermined (Pending) – Investigative staff have been unable, for good cause, to gather sufficient facts to support a decision within 60 days of the date the report was received. Additional periods of 30 days may be permitted to complete the investigation, after which a determination is made. According to data provided by the Department, 25.5 percent of investigations (56,457 of 221,341) for the three-year period FY15-FY17 had a final determination or finding of indicated, meaning there was credible evidence that the allegation occurred. For 74.5 percent of all investigations the status was unfounded (164,864 of 221,341 investigations) (see Exhibit 2-8). Exhibit 2-8 FINAL DETERMINATION (FINDING) FY15-FY17 Finding Indicated FY15 19,156 FY16 18,710 FY17 18,591 Total 56,457 Unfounded 48,576 59,860 56,428 164,864 0 2 18 20 67,732 78,572 75,037 221,341 Pending Total Source: OAG analysis of DCFS investigations data as of July 27, 2018. As of July 2018, there were 20 investigations for FY16 and FY17 that were listed as pending, which we interpreted to mean undetermined, and therefore a final determination had not been made. Of these 20 investigations, 2 were from FY16 and 18 were from FY17. These investigations generally involved allegations of death or sexual abuse and/or an investigation in which law enforcement is involved. These investigations may take a considerable amount of time because investigators may be waiting for medical reports from a medical examiner or coroner and may involve criminal prosecution. 27 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT 28 Chapter Three INVESTIGATION TIMEFRAMES CHAPTER CONCLUSIONS We found that the Department needs to improve timeliness in several areas. The Department is not timely in completing intakes from callers reporting allegations of abuse and neglect. The hotline did not meet targets and call backs increased substantially during FY15FY17, from 39.6 percent to 55.7 percent of total calls. The Department also does not have written procedures regarding the process for calling back individuals who report allegations of abuse or neglect that do not complete the intake process at the time of their initial call. Further, the Department does not maintain call back information electronically in SACWIS for more than 90 days, which makes any long-term analysis of call back timeliness difficult. According to investigations data provided, the Department was timely in initiating investigations for approximately 99 percent of investigations. However, required interviews with the alleged victim and perpetrator were not always completed in a timely manner. With data provided by the Department, we reviewed the timeliness of interviews with the alleged victim(s) based on whether actual contact was made and found that the alleged victim was not interviewed within 24 hours in 29.1 percent of cases for the audit period FY15-FY17. The alleged perpetrator was not interviewed within 7 days in 24.5 percent of cases for the audit period. The overall timeliness of completion for investigations declined significantly over the three-year period FY15-FY17. In FY15, 7.6 percent of investigations were not completed within 60 days. For FY16, the percentage of investigations not completed within 60 days increased to 16.0 percent. It remained elevated in FY17 at 12.4 percent of investigations not completed within 60 days. We reviewed the timeliness of submission of the completed investigation to the supervisor and found that for the audit period FY15-FY17, 44.2 percent of all reports without extensions were not submitted within 55 days. The highest rate of noncompliance was for FY16, in which 51.2 percent of reports did not meet the 55 day requirement for submission to the supervisor, according to data provided by the Department. The Department’s difficulty in completing investigations in a timely manner during the audit period is further demonstrated by the number and percentage of investigations that received a 30-day extension. The percentage of cases receiving one or more extensions increased from 7.5 percent in FY15 to 16.1 percent in FY16 and 12.7 percent in FY17. Further, the number of investigations receiving multiple extensions also increased significantly. For instance, the number of investigations that received three extensions (an additional 90 days) increased from 274 investigations in FY15 to 1,263 investigations in FY16 and 719 investigations in FY17. In our review of cases involving an extension, it was also not always clear what the cause for the extension was or whether it rose to the level of “good cause.” 29 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT INVESTIGATION TIMELINESS We found that the Department needs to improve timeliness in several areas. We reviewed the timeliness of completing intakes, initial assignment, conducting interviews with the alleged victim and perpetrator, and overall completion and closure of allegations that were investigated during FY15, FY16, and FY17. DCFS rules (89 Ill. Adm. Code 300.90) require that within 24 hours investigators must:    Begin or make a good faith attempt to begin the initial investigation. Make in-person contact with the alleged victim or examine the environment for inadequate shelter and environmental neglect. If applicable, contact the mother of an infant hospitalized with a controlled substance in its system. The investigation will begin immediately (the DCFS investigator has to respond within 15 minutes of receiving the report) if the child is in immediate danger or if the family may flee with the child. A report can also receive an “action needed” response which means that the assigned investigator and supervisor have to review the report within 60 minutes of receiving the report and determine what action is necessary (Procedures 300.50(f)). Required Timeframes  1 Hour – If the Hotline determines the allegation is reportable, it must be sent to the local field office within one hour of receipt of the call.  24 Hours – In-person contact with alleged victim or examination of the environment for inadequate shelter and environmental neglect. Begin or make a good faith effort to begin the initial investigation.  7 Days – In-person contact with the alleged perpetrator. Contact with caretaker and alleged victim if not completed sooner.  55 Days – Investigator must submit the completed investigation to supervisor.  60 Days – Final Investigation Report or the Preliminary Investigation Report if a 30-day extension is necessary. Hotline Timeliness and Callbacks The Department is not timely in completing intakes from callers reporting allegations of abuse and neglect. For approximately half of all calls during the audit period an intake could not be initiated because a call floor worker was not available resulting in a message being taken. The Department also does not have written procedures regarding the process for calling back individuals who report allegations of abuse or neglect that do not begin the intake process at the time of their initial call. Finally, the Department does not maintain call back information electronically in SACWIS for more than 90 days, which makes any long-term analysis of performance and call back timeliness difficult. The Department is required by statute to be capable of receiving reports of suspected child abuse or neglect 24 hours a day, 7 days a week (325 ILCS 5/7.4a). This is accomplished through a hotline at the State Central Register (SCR). According to Department administrative rules the time the report was received at the State Central Register begins the investigative process (89 Ill. Adm. Code 300.90). 30 CHAPTER THREE – INVESTIGATION TIMEFRAMES During certain times at the hotline there are more incoming calls than there are call floor workers to take them. When this occurs, a message is taken and the reporter is called back when a call floor worker becomes available. Auditors visited the SCR Hotline and observed the operations on February 6, 2018. According to officials, the hotline at that time had 89 call floor workers and 21 current vacancies. On the day of our visit to the hotline we noted that there were 579 calls that were in the queue waiting to be returned. According to the SCR Administrator at the time, when messages are taken the calls are triaged and called back. Those with safety concerns go to the top of the list. The Department could not provide electronic call back information for the audit period. We requested call back information for the audit period and were informed that the Department only maintains call back information in SACWIS for the most recent 90-day period. After that the information is rolled off the system and deleted. Call Back Priority Emergency – If it’s an emergency child safety issue, the call back is labeled as Emergency and a worker either takes the call right then or calls back within 15 minutes. Urgent – An urgent call back is a call back that is labeled Urgent in order to demonstrate that there is a reporter who is available now but may not be available for long (i.e, getting ready to go off shift, etc.). Normal – A normal call back means that it is not an emergency child safety issue and the caller is making him/herself available even after their work shift (cell phone etc.) and can be called back at any time. Source: DCFS officials. Although electronic call back information was limited, we were able to review hardcopy summary reports at the SCR in order to gather some general information about FY15-FY17 hotline operations and call backs. The SCR Hotline has an established target goal of answering 75 percent of all calls with no more than 25 percent call backs. Auditors requested any policies or procedures for call backs; however the Department did not provide any. The SCR summary reports we reviewed showed that the hotline did not meet targets and that call backs had in fact increased substantially during FY15FY17, from 39.6 percent to 55.7 percent of total calls (see Exhibit 3-1). Exhibit 3-1 PERCENTAGE OF CALLS TAKEN AS MESSAGE FY15-FY17 FY 2015 Call Volume 222,719 Messages Taken 88,291 Percent 39.6% During the course of the audit, we 2016 245,388 129,211 52.7% were able to obtain a 90-Day Call Back 2017 252,568 140,773 55.7% report for the period April 4, 2018, to July 2, 2018. The report contained a total of Total 720,675 358,275 49.7% 43,775 messages taken. The number of Source: OAG analysis of DCFS hardcopy hotline reports. attempts to call back ranged from 0 to 6 calls. We analyzed the time from the initial call to the first attempted call back and found that on average it took approximately 23.3 hours to the first attempt to call back the individual reporting the allegation. Call back times ranged from 0 minutes to 6 days 22 hours from the initial call. Of particular note is that for 35.4 percent of the call backs in the 90 day report an intake was never created. Further, we analyzed the call back information by the type of priority (Normal, Urgent, or Emergency) and found that it can potentially take days for DCFS to call back reporters of child 31 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT abuse and neglect. Exhibit 3-2 shows that for calls with a “Normal” response code, 58.3 percent took more than 24 hours until the first attempt to call back the reporter with 37.4 percent taking more than 2 days. Even more concerning is that approximately 35 percent of “Urgent” calls took more than 24 hours and 10.1 percent of “Emergency” calls took more than an hour to the first attempted call back. It should be noted that our analysis is to the first attempted call back, which does not necessarily mean that contact was made with the reporter to complete the intake so that the investigation could begin. Exhibit 3-2 TIME TO FIRST CALL BACK ATTEMPT BY PRIORITY April 4, 2018 through July 2, 2018 Timeframe Normal 0 to 15 minutes 466 3.4% 2,687 14.2% 15 to 30 minutes 263 1.9% 1,512 30 to 60 minutes 60 minutes to 24 hours 352 2.6% 4,599 24 hour to 48 hours More than 48 hours Total % Urgent % Emergency % Total Total % 6,838 65.1% 9,991 23.2% 8.0% 1,720 16.4% 3,495 8.1% 1,640 8.7% 889 8.5% 2,881 6.7% 33.8% 6,433 34.0% 770 7.3% 11,802 27.4% 2,852 20.9% 2,433 12.9% 145 1.4% 5,430 12.6% 5,088 37.4% 4,188 22.2% 147 1.4% 9,423 21.9% 13,620 100% 18,893 100% 10,509 100% 43,022 100% Note: Totals may not add due to rounding. The table excludes messages where an attempt was not made, and call backs that occurred before the message was taken. Source: OAG analysis of DCFS provided 90-Day Call Back Report for April 4, 2018-July 2, 2018. Within the data provided, there were 747 messages taken for which there was no call back attempt listed. Of those 747, 237 had no call back listed and no intake created. Of the 237, 101 were more than 7 days old as of July 3, 2018. The oldest was an emergency priority message taken on April 5th, or 89 days from the date the report was run. During the audit, the SCR was working to develop an online reporting system. According to a Department official, the online reporting system went live June 19, 2018, and it can be accessed through the Department’s website. Reports are submitted through an online form. Submissions are monitored by call floor supervisors and assigned to call floor workers. A worker reviews the report and assesses the information to determine if there is enough information to make a determination regarding the intake. If there is enough information the report is moved to SACWIS by the call floor worker and an email is automatically sent to the reporter to inform them of the disposition of the report. If there is not enough information to make a determination, the call floor worker will call the reporter to obtain any needed information. According to a Department official, as of February 4, 2019, the Department had assessed 5,792 online submissions. Increasing the number of individuals utilizing online reporting may reduce the number calling the hotline and therefore the number of messages taken. The hotline serves a critical function in obtaining intake information about allegations of child abuse and neglect as well as establishing each investigation in SACWIS. If children are in danger of harm, it is important to begin investigations quickly. Seeing children as soon as possible is also critical because perishable evidence such as bruises may fade rapidly, or the willingness of the alleged victim to talk about the incident may be affected. If the hotline does 32 CHAPTER THREE – INVESTIGATION TIMEFRAMES not establish intakes in a timely manner, investigations are not able to be assigned and initiated in a timely manner. This may leave children in dangerous situations for a longer period of time. Further, delays in initiating investigations could hinder an investigator’s ability to gather critical information and interview witnesses and may affect the final outcome of the investigation. HOTLINE AND INTAKE RECOMMENDATION 4 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should:  Develop formal written procedures for call backs including required timeframes for creating intakes;  Ensure that the process for completing call backs is in accordance with written procedures by answering and returning hotline calls in a timely manner;  Begin maintaining complete information regarding the time it takes to return the hotline calls of those reporting allegations of child abuse or neglect for an amount of time that would allow for long-term analysis; and  Continue to increase the utilization of online reporting as appropriate. The Department has recently developed written procedures for call backs and training is provided to all call floor staff during new hire training. April 2019 all staff were provided an in -service training on managing call backs. The intake is created through call back once the caller is confirmed available to talk by the hotline worker. If the call is an in call the intake is created at the time the call begins. A specialized Call Back Attempts Response Time report is received daily and weekly. The specialized report is monitored by the SCR administrator and Assistant SCR administrator for call back response times which exceed the weekly average response time. The call backs are reviewed to determine the reason for longer than average response time. The hotline currently tracks daily, weekly, monthly and yearly the message taking rate and the call back response time. The State Central Register implemented approximately 18 months ago shift strategies which are communicated to call floor staff about the managing call backs and in calls. Approximately 12 months ago an additional category “Urgent”, was added to the call back log to assist supervisors and call floor worker to prioritize the call backs by “Emergency”, “Urgent” or “Normal” response call backs. The hotline also tracks and gathers data regarding individual hotline workers and overall -team performance. A strategy is in development to publicize and educate potential on line users by region on the ON LINE REPORTING option and how to access the on-line reporting system. 33 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Investigation Initiation The Department could not verify the accuracy of intake start and end times (when the phone call with the reporter began and ended) or the assignment start time (when the report was transmitted to the field office), which hinders the Department’s ability to monitor compliance with statutory requirements. The Abused and Neglected Child Reporting Act (ANCRA) requires investigations to begin within 24 hours of receipt of the report (325 ILCS 5/7.4(b)(2)), which is defined by Department administrative rules as “the time the report was received at the State Central Register” (89 Ill. Adm. Code 300.90). Auditors reviewed the timeliness of reports being transmitted from the SCR to a field office for FY15-FY17 and found that 85,866 of 221,341 (38.8%) first assignments to field offices were transmitted prior to the intake end time. Additionally, of those 85,866 assignments, 191 were transmitted prior to the intake start time. Auditors followed up with agency officials on October 2, Good Faith Attempt 2018, to ensure we were using the correct fields for our The following constitute good faith calculations and to ask why reports would be attempts to begin the investigation: transmitted prior to the end of the intake, but officials 1) when investigative staff learns, did not respond. Therefore, it is not known if there are upon proceeding to the location accuracy problems with the intake times, the assignment given for the children alleged to have been abused or neglected, that the transmittal times, or both. Because auditors are unable to children have disappeared, the confirm the accuracy of the intake start and end times, family has fled, the address does not which is the start of the investigative process, the exist, no one is at the location, or not investigation initiation and victim contact timeliness may all of the children alleged as abused not be completely accurate. or neglected are at the location; or 2) when the involved child subjects Because of the Department’s lack of response and are not accessible; or limitations in the data provided by the Department, we were unable to determine whether assignments were 3) when the adult caretaker refuses to let child protective service staff timely. There are certain types of responses that require see or speak with the involved child investigators to initiate the investigation in less than 24 subject. hours. Emergency responses require investigators to be responding within 15 minutes of the SCR transmitting Source: 89 Ill. Adm. Code 300.100 the report and Action Needed responses require the investigator and supervisor to review the report within 60 minutes of the SCR transmitting the report. For Emergency and Action Needed responses, the timeliness of assigning an investigator is critical to initiation and any delay in transmitting the report to the field can hinder the investigator’s ability to respond in a timely manner. Investigations are required to be initiated by in-person contact with the alleged child victim or victims within 24 hours of the receipt of the report, or by a good faith attempt to contact the alleged child victim or victims. Based on whether there was a good faith attempt to contact the alleged victim, our analysis of investigation initiation data showed that the percentage not initiated in a timely manner was less than one percent each year (0.7% for FY15, 0.8% for FY16, and 0.9% for FY17) (see Exhibit 3-3). 34 CHAPTER THREE – INVESTIGATION TIMEFRAMES Exhibit 3-3 CRITICAL TIMEFRAMES ANALYSIS FY15-FY17 Not Timely Timely Unknown/Other1 Total2 Investigation Initiation (24 Hours) 0.7% 99.0% 0.3% 100% FY15 Victim Contact (24 Hours) 28.2% 70.9% 0.9% 100% Perpetrator Contact (7 Days) 23.5% 63.7% 12.9% 100% Submission to Supervisor (55 Days) 40.7% 59.3% 0.0% 100% Not Timely Timely Unknown/Other1 Total2 0.8% 98.9% 0.4% 100% FY16 30.5% 68.3% 1.3% 100% 26.2% 59.0% 14.8% 100% 51.2% 48.8% 0.0% 100% Not Timely Timely Unknown/Other1 Total2 0.9% 98.8% 0.3% 100% FY17 28.6% 70.3% 1.2% 100% 23.6% 62.0% 14.4% 100% 40.4% 59.6% 0.0% 100% Not Timely Timely Unknown/Other1 Total2 0.8% 98.9% 0.3% 100% 24.5% 61.4% 14.1% 100% 44.2% 55.8% 0.0% 100% Total FY15-FY17 29.1% 69.8% 1.1% 100% 1 Unknown/Other includes investigations in which information needed to calculate timeliness was blank or returned a negative value. 2 Totals may not add due to rounding. Source: OAG analysis of DCFS data as of July 27, 2018. Interviewing the Alleged Victim The Department’s administrative rules require in-person contact with the alleged victim be made within 24 hours (89 Ill. Adm. Code 300.90). With data provided by the Department we reviewed the timeliness of interviews with the alleged victim(s) based on whether actual contact was made, and as seen in Exhibit 3-3, found that the alleged victim was not contacted within 24 hours in 28.2 percent of cases for FY15, 30.5 percent of cases in FY16, and 28.6 percent of cases in FY17. The alleged victim was not interviewed at all in 415 cases in FY15, 726 cases in FY16, and 678 cases in FY17. If an in-person contact with the alleged victim is not made within 24 hours, according to the Department’s rules it must be completed within 7 days. According to data provided, the percentage of alleged victims in which contact was not made within 7 days ranged from 9.2 percent to 13.0 percent for the three years FY15-FY17. Interviewing the Alleged Perpetrator The Department’s administrative rules require that, within seven days, there must be inperson contact with the alleged perpetrator (89 Ill. Adm. Code 300.90). We reviewed the 35 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT timeliness of interviews with the alleged perpetrator and found that the alleged perpetrator was not contacted within 7 days in 23.5 percent of cases for FY15, 26.2 percent of cases in FY16, and 23.6 percent of cases in FY17, as seen in Exhibit 3-3. In addition, the alleged perpetrator was not interviewed at all in 8,591 cases in FY15, 11,441 cases in FY16, and 10,688 cases in FY17. Submission of Investigation to Supervisor Department policies require the Child Protection Specialist to submit the completed investigation and final determination to the Child Protection Supervisor within 55 days of receipt of the report. If a 30-day extension to complete the investigation is necessary, the Child Protection Specialist is required to submit (prior to the 55th day) an extension request to the Child Protection Supervisor who will evaluate the request (Procedures 300.50a). With data provided by the Department, we reviewed the timeliness of submission of the completed investigation to the supervisors and found that for the audit period FY15-FY17, 44.2 percent of all reports without extensions were not submitted within 55 days. The highest rate of noncompliance was for FY16, in which 51.2 percent of reports did not meet the 55 day requirement for submission to the supervisor, as seen in Exhibit 3-3. Overall Time to Complete an Investigation An investigator has 14 days to make a good faith determination that the alleged abuse or neglect exists. If a good faith report exists, the investigation continues. If a good faith report does not exist, the investigation is terminated (Procedures 300.50(a)). ANCRA requires the Child Protective Service Unit to determine, within 60 days, whether the reported allegation is “indicated” or “unfounded” and report the finding to the SCR (325 ILCS 5/7.12). “Indicated” means that it was determined that the abuse or neglect is likely to have occurred based on heightened credible evidence. “Unfounded” means that there was not enough evidence to indicate that the abuse or neglect occurred. Once the investigator has made a determination, the supervisor has to review and approve the report. In addition to supervisory approval, certain types of reports also require approval of the Area Administrator. Examples of reports that require an Area Administrator’s approval include death investigations, serious injury investigations, or reports involving DCFS wards (Procedures 300.75(a)). With data provided by the Department, we reviewed the timeliness of completing the investigations and found that, with extensions, 0.3 percent of all investigations were not completed in a timely manner, going from 0.3 percent in FY15 to 0.4 percent in FY16 and 0.2 percent in FY17. Although this analysis took into account those investigations that received an extension, it does not accurately reflect the actual time it took to complete investigations for the audit period. The time it took to complete an investigation increased during the audit period. We found that the percentage of investigations that were not completed within 60 days doubled from FY15 to FY16. With investigations data provided by the Department, we reviewed the overall time to complete investigations from intake to supervisory approval. As is shown in Exhibit 3-4, in FY15, 7.6 percent of investigations were not completed within 60 days. For FY16, the percentage of investigations not completed within 60 days increased to 16.0 percent. It remained elevated in FY17 at 12.4 percent of investigations not completed within 60 days. Additionally, the number of investigations completed in fourteen days or less dropped from 14.0 percent in FY15 to 10.5 percent in FY16 before increasing to 15.1 percent in FY17. 36 CHAPTER THREE – INVESTIGATION TIMEFRAMES Exhibit 3-4 COMPLETED INVESTIGATION TIMEFRAMES FY15-FY17 7.6% 14.0% 16.0% 10.5% 12.4% 15.1% 10.0% 14.2% 13.4% FY15 FY16 FY17 64.2% 59.1% 63.5% 0 through 14 Days Timeframe 0 through 14 Days 15 through 30 Days 31 through 60 Days Over 60 Days Unknown1 Total 15 through 30 Days FY15 9,463 9,613 43,487 5,169 0 67,732 FY16 8,236 7,869 49,902 12,559 6 78,572 31 through 60 Days FY17 11,319 10,023 44,356 9,318 21 75,037 Over 60 Days Total 1 29,018 27,505 137,745 27,046 27 221,341 Unknown includes investigations in which information needed to calculate timeliness was blank or returned a negative value. Source: OAG analysis of DCFS data as of July 27, 2018. The purpose of investigative timeframes is to establish protocols for responding to allegations of abuse and neglect. By not meeting these timeframes, not only is the Department not in compliance with statutes, rules, and policies, but more importantly the Department is not responding in the best interest of the alleged victims and providing for the protection of those children. 37 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT INVESTIGATION TIMELINESS RECOMMENDATION 5 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should take actions to ensure that critical investigation timeframes are completed in accordance with procedures, including initiating investigations, contacting the alleged victim and perpetrator, submitting investigations for supervisory review, and completing the investigation. The Department currently tracks for compliance with initiation and is at 99% compliance. Since March 1, 2019 report completion and extension is now being monitored weekly through reports and staffings with Regional Administrators. Supervisors have access to a worker activity report and will be trained on how to access and utilize this report. This will be completed by September 2019. The Compliance Administrator will review a random selection of cases quarterly to ensure staff are meeting timeframes. EXTENSIONS The Department’s struggle to complete investigations in a timely manner during the audit period is further demonstrated by the number and percentage of investigations that received a 30day extension during the audit period. Where it is not possible to initiate or complete an investigation within 60 days, the report may be deemed “undetermined” provided every effort has been made to undertake a complete investigation. The Department may extend the period in which such determinations must be made in individual cases for additional periods of up to 30 days each for good cause (325 ILCS 5/7.12). Both the Supervisor and Area Administrator are responsible for reviewing and approving extensions every 30 days after the initial 60 day investigative period. ANCRA requires that the Department shall by rule establish what shall constitute good cause (325 ILCS 5/7.12). Department rules state that good cause for extending the period for making a determination an additional 30 days may include, but is not limited to, the following reasons:     State's attorneys or law enforcement officials have requested that the Department delay making a determination due to a pending criminal investigation; Medical or autopsy reports needed to make a determination are still pending after the initial 60 day period; The report involves an out-of-state investigation and the delay is beyond the Department's control; or Multiple alleged perpetrators or victims are involved necessitating more time in gathering evidence and conducting interviews (89 Ill. Adm. Code 300.110 (i)(3)(D)). 38 CHAPTER THREE – INVESTIGATION TIMEFRAMES Exhibit 3-5 30-DAY EXTENSIONS FY15-FY17 Extensions 0 1 2 3 4 5 6 7 8 9 10+ Total FY15 Investigations Count Percent 62,626 92.46% 3,626 5.35% 925 1.37% 274 0.40% 122 0.18% 52 0.08% 35 0.05% 20 0.03% 10 0.01% 7 0.01% 35 0.05% 67,732 100 % FY16 Investigations Count Percent 65,958 83.95% 7,336 9.34% 2,762 3.52% 1,263 1.61% 587 0.75% 283 0.36% 125 0.16% 90 0.11% 54 0.07% 33 0.04% 81 0.10% 78,572 100% FY17 Investigations Count Percent 65,474 87.26% 6,243 8.32% 1,839 2.45% 719 0.96% 320 0.43% 175 0.23% 79 0.11% 62 0.08% 38 0.05% 26 0.03% 62 0.08% 75,037 100% Source: OAG analysis of DCFS data as of July 27, 2018. We reviewed the number of investigations that received an extension and found that it increased significantly during the audit period as is shown in Exhibit 3-5. The percentage of cases receiving at least one extension increased from 7.5 percent in FY15 to 16.1 percent in FY16 and 12.7 percent in FY17. Further, the number of investigation receiving multiple extensions also increased significantly. For instance, the number of investigations that received three extensions (an additional 90 days) increased from 274 investigations in FY15 to 1,263 investigations in FY16 and 719 investigations in FY17. We reviewed a random sample of 50 investigations that received extensions to review the timeliness of the submission and approval of the first extension. Department rules require that extensions be submitted prior to the 55th day of the investigation. Of the 50 extensions sampled, only 1 (2.0%) was submitted prior to the 55th day. This extension was submitted on the 50th day for a prearranged leave. Good Cause In some investigations there are legitimate reasons why there are multiple extensions. For instance, in one case an investigation received 33 extensions (990 days). This case involved the death of a child and an ongoing criminal case. However, in our review of cases involving an extension, it was not always clear what the cause for the extension was or whether it rose to the level of “good cause.” Auditors judgmentally sampled an additional 20 investigations that received a total of 99 extensions. These extensions were reviewed to determine the “Reason for Extension,” a uniform drop down option in SACWIS, and other pertinant extension data. Of the 99 extensions, 44 had a Reason for Extension of “Other.” Auditors reviewed the Worker, Supervisor, and Manager Explanations which summarize the rationale for the extension. Often “Other” extensions had been requested and approved due to a need to finish investigative tasks such as entering notes, writing reports, or submitting the case for supervisor review. 39 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Extensions often had identical information for the explanations for the extension. For instance, for one investigation sampled that had 12 total extensions, the worker explanation for 11 of those extensions was that it was a human trafficking case. Of the 99 extensions, 22 Worker Explanations were identical to the previous extension, 17 Supervisor Explanations were identical to the previous extension, and 17 Manager Explanations were identical to the previous extension. Further, 36 extensions had identical explanations from the worker and either the supervisor or manager. Auditors identified 22 extensions in which a staff member had both submitted and approved the extension. For instance, one investigation which received 17 extensions had 11 extensions where the supervisor both requested and approved these extensions on the same day. Further, the first extension was requested 462 days after the start of the intake (408 days after the extension should have been requested). Auditors asked Department officials why this might occur; however Department officials did not respond. Department procedures require that an extension request contain four criteria:     the reason the investigation cannot be completed by the 55th day, activities to be completed, who is responsible for completing each activity, and the expected date of completion. For the 99 extensions sampled, only six (6.1%) extensions contained all four criteria in the Worker Explanation. INVESTIGATION EXTENSIONS RECOMMENDATION 6 The Department of Children and Family Services should comply with rules and procedures and ensure:     DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE Extensions are requested prior to the 55th day of the investigation; That extensions are given only for good cause; Extensions are requested and approved by appropriate staff; and Extension requests contain all required information. The Department is monitoring extensions and ensuring cases are extended for good cause. Since March 1, 2019 there is a weekly report completed by the regions to identify all teams with more than 10 cases over 60 days, actions needed and anticipated closure date. Also instituted is a weekly staffing with all Regional Administrators regarding extensions more than 90 days to address the appropriateness of the request and actions to complete the investigation. This process has already resulted in a reduction of cases over 60 days. All staff will be reminded of the need to extended cases within the timeframe set forth in procedures. 40 Chapter Four SERVICES CHAPTER CONCLUSIONS Conducting an analysis of all recommendations for services and services provided by the Department was not possible for the audit period because of inherent limitations in the data provided by the Department as well as other data reliability and consistency issues. In order to assess the services recommended and services provided, we selected a sample of 150 indicated investigations (50 each year for FY15, FY16, and FY17) and reviewed the investigations for recommended services and any services received. Recommendations for Services The Department’s policies and procedures require that during an investigation the need for services for the family involved in the investigation be assessed by the Child Protection Specialist (investigator) and the Child Protection Supervisor. Our review of 150 indicated investigations found that investigators did not always document that they assessed the need for services by completing the Level of Intervention field in the Department’s information system known as SACWIS. Of the 150 indicated investigations sampled, 16 investigations (10.7%) had no Level of Intervention listed (services recommended). Further, 39 investigations (26.0%) had “No Service Needed” as the Level of Intervention. For most of these cases there was no rationale regarding why no services were being recommended even though the case had been indicated. Additionally, of the investigations sampled, for 64 (42.7%) we found that the Level of Intervention was inaccurate. For Intact Family Services (IFS) provided through the Department, investigators have the responsibility to discuss and offer these services if the final investigation finding of indicated has been recommended. The Department did not document that Intact Family Services were discussed and offered to all families with indicated investigation findings as is required by Department procedures. Only 20 of 150 (13.3%) indicated investigations reviewed contained documentation of a recommendation for Intact Family Services (IFS). An additional 3 investigations had recommendations for multiple services, which included IFS; therefore 23 of 150 indicated investigations had a recommendation of IFS. For 33 of 150 investigations (22.0%), community services were recommended. We could not determine whether any services were recommended or what the specific services were for 67 of 150 (44.7%) indicated investigations reviewed. The remaining 27 investigations included recommendations for placement, already receiving services, no services needed, multiple services, Intact Family Recovery, and Norman Cash Assistance. Services Provided We sampled 150 indicated cases for the audit period and found that for 98 cases (65.3%), there was a lack of documentation regarding whether any services were received by the families involved and the duration of those services. The Department could not provide basic information for Intact Family Service cases, such as referral forms, to document that a formal referral for services was made. The Department also could not provide auditors with the number of families served by each IFS contractor each year for the audit period. For investigations 41 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT involving the Norman Cash Assistance program, the Department could not provide all approval forms. For community services, there are no formal forms for referrals to community based services and the Department is not documenting these services as required by procedures. Therefore, it is difficult to determine if the families actually received services from community providers. SERVICES According to the Abused and Neglected Child Reporting Act (ANCRA), if the Child Protective Service Unit determines, following an investigation of child abuse or neglect, that there is credible evidence that a child has been abused or neglected, the Department is required to assess the family's need for services, and, as necessary, develop, with the family, an appropriate service plan for the family's voluntary acceptance or refusal (325 ILCS 5/8.2). Even if there is no credible evidence that the child was abused or neglected, if it appears that the child or family could benefit from other social services, the Department may suggest services, for the family's voluntary acceptance or refusal (325 ILCS 5/8.1). Possible services that may be provided to families through the Department include programs such as Intact Family Services (IFS), Intact Family Recovery Program (IFR), placement, or Norman Cash Assistance. Families may also receive services through community based providers. The Department and its social service partners provide services that allow children to remain in their homes. The largest of those programs is the Intact Family Services (IFS) program. The Intact Family Services program is designed to work with families on a voluntary basis when they have come to the attention of the Department as a result of a referral from a child abuse or neglect investigation or involuntarily when ordered by the court to provide services. Intact Family Services are meant to provide reasonable efforts to preserve families, to enable children to remain safely at home, and to avoid separation and/or placement of the children. The requirements for the Intact Family Services program are established by Department Procedures 302.388. Norman Cash Assistance services assist families who lack food, clothing, housing or other basic human needs that place children’s safety at risk and would otherwise necessitate removal from the family or would be a barrier to reunification. The program provides cash assistance to purchase needed items, assistance in locating housing, and expedited enrollment in Temporary Assistance for Needy Families (TANF). According to Department procedures, community services are appropriate when children have been assessed to be at low to medium risk and the family is capable of using support services provided through community resources without further Department intervention. Because the Department’s rules and procedures do not include a definition of what constitutes community services, we asked the Department what would be defined as community services. Officials responded that community services would include any services that are not provided as contracted services. According to a Department official, community services may include food pantries, mental health service referrals, and medical and dental information. It may also include providing the locations of other agency offices such as the Department of Human Services, the Social Security Office, or where to apply for unemployment. Transportation information may also be provided. Some communities may also have various cultural and language service providers. 42 CHAPTER FOUR – SERVICES Limitations of Services Data Conducting an analysis of all recommendations for services and services provided by the Department was not possible for the audit period because of inherent limitations in the data provided by the Department as well as other data reliability and consistency issues. The Department’s information system for abuse and neglect investigations, known as SACWIS, contains a field entitled “Level of Intervention” which contains the recommended services for each investigation. The Department provided auditors with a download of investigations for FY15-FY17, as of July 27, 2018, including the Level of Intervention and whether a service case was created for IFS, Norman Cash Assistance, or placement as a result of investigations. We reviewed the recommended services and cases created (services case ID) for accuracy and found that:  Investigators did not always complete the Level of Intervention field in SACWIS. According to data provided by the Department, for 11,607 investigations (5.2%) the Level of Intervention field was blank. This included 11,435 investigations with an associated service case created for Intact Family Services (IFS), IFR, placement, or Norman Cash Assistance (Norman).  The Level of Intervention field was not always accurate or there was no support in SACWIS for the recommended Level of Intervention. For example, for 6,203 investigations (2.8%) the Level of Intervention field was listed as “Referral for Community Based Services” but there was a Department service case associated with the investigation (IFS, IFR, Norman, or placement).  We reviewed a sample of Department service cases that were created as a result of an investigation, and found that for 17 of 36 (47.2%) of these investigations, the services information was not accurate.  There were service cases that were created in error. In our sample, we identified 4 cases, 3 placement and 1 IFS, (11.1%) that were created in error. For example, for IFS cases, according to Department officials, this can happen when an IFS case is created in SACWIS before the possibility of receiving services is discussed with a family due to the investigation getting close to the 60 day deadline. If the family refuses services, the case cannot be deleted from SACWIS, so “Opened in Error” is selected as the option for closing the case. According to Department procedures, IFS cases must be created in SACWIS before the investigation is completed and closed.  The population of placement cases created could not be calculated accurately because services include a family case ID as well as a case ID for each child, artificially inflating the number of services cases.  Cases that transition from IFS to placement keep the same case ID making it difficult to determine the type of service case created. According to Department officials, this provides continuity and allows for all the historical documentation to remain in place. However, in the data provided, the case type is only listed as IFS and does not show the transition to placement; therefore, a placement case may appear to be an IFS case. Further, some cases that transition to placement may not be linked to any specific investigation. 43 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT  Sometimes IFS cases are created in order to provide Norman Cash Assistance and do not include IFS services. For one of the four investigations sampled in which we determined Norman Cash Assistance was involved, an IFS case was created only to provide the Norman Cash Assistance. According to a policy guide provided by the Department, a new IFS case may be opened in order to make a Norman Cash Assistance payment. Therefore, when reviewing the population of services, the number of IFS cases would be overstated while the number of Norman Cash Assistance cases would be understated. Through FY17, the Department had published statistics on services in its annual Executive Statistical Summaries. However, services data was not included in these summaries when the Department reissued investigation statistics for the past five years in April 2018. The Department does provide some services data to the federal government for inclusion in the Child Maltreatment reports issued by the US Department of Health & Human Services. When asked about the data presented in the federal report, Department officials stated that the numbers might not match other data. We requested field definitions for the federal reports but the Department failed to provide auditors with those definitions. RECOMMENDATIONS FOR SERVICES House Resolution Number 418 asks the Auditor General to determine for FY15, FY16, and FY17, for sampled cases, recommendations made by the Department to families who were the subject of an abuse or neglect investigation. Our review of 150 indicated investigations found that investigators did not always document that they assessed the need for services by completing the Level of Intervention field in SACWIS. Further, the recommendations that were shown in SACWIS were not always supported by case notes. For indicated investigations sampled in which the recommended services was “No Service Needed,” there was no rationale for the decision to not offer services in most cases. Assessing the Need for Services The Department’s policies and procedures require that during an investigation the need for services for the family involved in the investigation be assessed by the Child Protection Specialist (investigator) and the Child Protection Supervisor. The policies specifically require that the Child Protection Supervisor ensure that a reported family is provided an appropriate service referral or that the need for preventive services is assessed, which may include, but is not limited to the following:        Educational services, including early education; Substance abuse assessment and treatment; Domestic violence services; Housing assistance; Mental Health services; Nursing referrals; or Other community services (e.g., Family Advocacy Center services, Safe Families, etc.) (Procedure 300.70 (h)). 44 CHAPTER FOUR – SERVICES SACWIS contains a field entitled “Level of Intervention” which contains the recommended services for each investigation. The different levels of intervention listed in the data received from the Department included: Currently Open Case, No Service Needed, Open and Assign for Permanency Services, Open and Assign for Regular POS (Purchase of Service), Other Services-Facility Report, Referral for Community Based Services, and Services Offered/Refused. Despite the procedural requirement to assess the need for services, the Level of Intervention field in SACWIS does not need to be completed in order to close an investigation. Data provided by the Department for FY15-FY17 investigations showed that over half (120,071 or 54.2%) of all investigations had a recommendation of no services needed. For another 11,607 (5.2%), the Level of Intervention field was blank in SACWIS. We selected a sample of 150 indicated investigations (50 each year for FY15, FY16, and FY17) and reviewed the recommended Level of Intervention. Of the investigations sampled, for 64 (42.7%) we found that the Level of Intervention was inaccurate. For 16 investigations there was no Level of Intervention listed even though the Department’s procedures require the investigator and the supervisor to assess the need for services (see Exhibit 4-1). Exhibit 4-1 LEVEL OF INTERVENTION For FY15-FY17 Investigations Sampled Level of Intervention Community Based Services No Service Needed Services Offered/Refused Blank – No Recommendation Currently Open Case Other Services – Facility Report Total Count 57 39 20 16 15 3 150 Percent 38.0% 26.0% 13.3% 10.7% 10.0% 2.0% 100% Source: OAG sample of 150 indicated investigations for FY15-FY17. Of the investigations sampled, 39 (26.0%) had “No Service Needed” as the recommended Level of Intervention. We followed up with the Department to determine why the Level of Intervention for these investigations was no services. After reviewing Department responses we determined that for 24 investigations there was no rationale in the SACWIS case notes regarding why no services were being recommended even though the cases had been indicated. Of the investigations sampled, 20 investigations (13.3%) had “Services Offered/Refused” as the Level of Intervention. For most of these cases (15 of 20) we could not determine by reviewing the case notes what services were offered or that the services had been refused. The Department does not complete any formal documentation when offering services or when services are refused. Because of the limited number of options available to investigators in SACWIS for Level of Intervention it is difficult to accurately reflect the investigator’s decision made to recommend services or not recommend services. For instance, the Level of Intervention field does not have an option to select Intact Family Services or whether the family is already receiving community services. Assessing the need for services, including the rationale for the decision, may help ensure the safety and well-being of children as well as help provide stability for children and families. Formally documenting the offer and refusal of services can also help in the decision making process if there are additional allegations and investigations in the future. 45 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT ASSESSING THE NEED FOR SERVICES RECOMMENDATION 7 The Department of Children and Family Services should:   DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE Make the Level of Intervention a required field in SACWIS and revise the Level of Intervention options to more accurately reflect current practices, and Include a rationale for indicated investigations in which there is a Level of Intervention of “No Service Needed.” Procedure 300 will be updated to include the expectation the investigator documents the reason no services are necessary. This will be completed by September 2019. Creating a special “services” note in the SACWIS file will be explored. Recommended Services The Department did not document that Intact Family Services (IFS) were discussed and offered to all families with indicated investigation findings as is required by Department procedures. An indicated investigation is an investigation of suspected child abuse/neglect that has revealed credible evidence that the abuse/neglect occurred. An indicated investigation is an investigation of According to Department suspected child abuse/neglect that has revealed credible procedures, the investigator has the evidence that the abuse/neglect occurred. According to responsibility to discuss and offer the Department procedures, the investigator has the family Intact Family Services if the responsibility to discuss and offer the family Intact final finding of indicated has been Family Services if the final finding of indicated has been recommended. recommended. The family should also be informed of community services (Procedures 300.130(a)(2)(A)). The IFS provider contracts we reviewed stated that all families who are the subject of an indicated abuse/neglect investigation must be offered the opportunity to participate in Intact Family Services. We reviewed the sampled investigations to determine the actual services recommended. Although Intact Family Services are required to be discussed and offered to all families that are the subject of an indicated investigation, only 20 of 150 (13.3%) indicated investigations reviewed contained documentation of a recommendation for Intact Family Services. An additional 3 investigations had recommendations for multiple services, which included IFS; therefore 23 of 150 indicated investigations had a recommendation of IFS. 46 CHAPTER FOUR – SERVICES As is shown in Exhibit 4-2, for 67 (44.7%) indicated investigations reviewed, we could not determine whether services were recommended or what specific services were recommended. For 33 investigations (22.0%), community based services were recommended. An additional three investigations had recommendations for multiple services, including community services. Department officials provided auditors with a memo to all child protection staff dated February 27, 2018 (five weeks after the audit entrance conference), regarding the review of indicated reports with no service recommendations or the family refuses services. The memo states: Exhibit 4-2 SERVICES RECOMMENDED For FY15-FY17 Investigations Sampled Services Recommended Could Not Determine Community Based Services Intact Family Services Placement Already Receiving Services Multiple Services1 No Services Needed Intact Family Recovery Norman Cash Assistance Total Count 67 33 20 12 8 4 4 1 1 150 Percent 44.7% 22.0% 13.3% 8.0% 5.3% 2.7% 2.7% 0.7% 0.7% 100% 1 Multiple Services includes three cases that were recommended for Intact Family Services. Source: OAG sample of 150 indicated investigations for FY15-FY17. “Over the past several months, many cases which have resulted in poor outcomes for our children (death or serious harm) have had prior DCFS contact and at least one indicated report in which no services were recommended or the family refused services and the investigations were closed with no follow up action or discussion to assure the child was safe under those circumstances. Effective immediately, any indicated investigation in which services have not been recommended or the family has refused to participate in services, shall be staffed with the Area Administrator before closing. This consultation should include a discussion around the family dynamics and support systems, prior reports both indicated and unfounded, overall family cooperation and the possible need to consult with States attorney [sic], screen with court, or take protective custody in an effort to ensure the safety of the child(ren).” There is also a lack of consistency in what services are recommended and ultimately received among similar cases. For example, for two different indicated sexual abuse investigations sampled, one case had an open Intact Family Services case for counseling for the victim and another case had no services recommended for multiple victims abused by a family member. Another example involved two indicated Environmental Neglect investigations where homes were deemed to pose a risk to the safety of the children. One investigation involved piles of garbage, rotting food and animal feces in the home yet the recommendation was no services needed. The other investigation was for a home with cleanliness issues and a cockroach infestation. That investigation had an Intact Family Services case opened to clean the home. The Intact Family Services case was open for 6 months with a Purchase of Service (POS) provider. Making effective recommendations for services may help prevent future abuse and neglect. Although the Department recognized in its February 2018 memo that not providing 47 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT services for certain types of investigations can lead to bad outcomes, there is little or no guidance for investigators or their supervisors regarding the recommendations that should be considered. RECOMMENDATIONS FOR SERVICES RECOMMENDATION 8 The Department of Children and Family Services should:   DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE Formally document when services are offered and whether those services are refused; and Consider establishing guidelines or policies to assist Child Protection Specialists and Supervisors regarding services to be offered for indicated allegations. Individual offices maintain a list of resources for their area. Procedures 300 will be enhanced to ensure the supervisor and investigator have a discussion regarding services available to assist families and document services offered and the outcome-i.e. accepted or refused and the reason for refusal. The core practice model which is in the process of implementation also addresses identification of services with the family and allowing them to identify services which will best benefit them. Procedures will be updated by September 2019. Creation of a special “services” note within SACWIS will be explored. SERVICES PROVIDED House Resolution Number 418 asks the Auditor General to determine for FY15, FY16, and FY17, for sampled cases, any services provided by the Department to the child or family. The Department could not provide basic information for Intact Family Service cases such as referral forms to document that a formal referral for services was made. We sampled 150 indicated investigations for the audit period and found that for 98 investigations (65.3%), there was a lack of documentation regarding whether any services were received by the families involved and the duration of those services. The Department also could not provide auditors with the number of families served by each IFS contract each year for the audit period. For investigations involving the Norman Cash Assistance program, the Department could not provide approval forms or documentation to show what the funds were used to purchase. Because of the lack of basic formal documentation for most cases, auditors could only assess the services provided for investigations sampled by reviewing case notes in SACWIS. Although there are required forms for some services, the Department utilizes case notes in SACWIS to document services. Services Provided Testing We selected 150 indicated investigations from FY15, FY16, and FY17 to determine the services provided including the type and duration of the services. Department procedures state that the Child Protection Specialist (investigator) has the responsibility to discuss and offer the family intact family services if the final finding of indicated has been recommended. Additionally the family should be informed of community services (Procedures 300.130(a)(2)(A)). If a family does not meet the criteria for Intact Family Services (i.e. 48 CHAPTER FOUR – SERVICES unfounded investigations) it is expected that the investigator will refer the family to appropriate community services as applicable to the needs of the family (Procedures 302.388(c)(1)). As is shown in Exhibit 4-3, there was no documentation in SACWIS or provided by the Department to support that 65.3 percent (98 of 150) of the indicated investigations reviewed received any services. Due to the lack of documentation, it was difficult to determine why services were not received in most cases. We determined that 8.7 percent (13 of 150) of the investigations reviewed were already receiving some form of services either through the Department or community based services. Thirteen or 8.7 percent of investigations sampled received Intact Family Services (12 Intact Family Services and 1 Intact Family Recovery). Families who were served by IFS received a variety of services, which included parenting classes, counseling, and substance abuse assessment among others. Another 8.7 percent (13 of 150) resulted in the Department taking the children into care (placement services). For 2.7 percent of cases reviewed (4 of 150) multiple services were received (3 of the 4 involved IFS and Norman Cash Assistance). Additionally there was one other case that received Norman funds. Intact Family Services (IFS) Exhibit 4-3 SERVICES RECEIVED For FY15-FY17 Investigations Sampled Services Received No Service Received Placement Services Already Receiving Services Intact Family Services/Recovery Multiple Services Received1 Community Based Services No Service Received – Withdrew Not Applicable2 Norman Cash Assistance Total Count 98 13 13 13 4 3 3 2 1 150 Percent 65.3% 8.7% 8.7% 8.7% 2.7% 2.0% 2.0% 1.3% 0.7% 100% The Department and its social service partners provide services that allow children to remain in their homes. The largest of these programs is the Intact Notes: 1 Multiple services includes three cases that involved IFS Family Services (IFS) program. The and Norman Cash Assistance. Intact Family Services program is 2 Not Applicable includes Facility and Foster Care cases. designed to work with families on a Source: OAG sample of 150 indicated investigations for voluntary basis when they have come to FY15-FY17. the attention of the Department as a result of a referral from a child abuse or neglect investigation or involuntarily when ordered by the court to provide services. Intact Family Services are meant to provide reasonable efforts to preserve families, to enable children to remain safely at home, and to avoid separation and/or placement of the children. The requirements for the Intact Family Services program are established by Department Procedures 302.388. According to Department officials, beginning in 2012, the Department privatized the provision of most Intact Family Services. For the audit period FY15-FY17, Intact Family Services were provided by private and not-for-profit Purchase of Service (POS) agencies through service contract agreements. According to officials, in 2018 some cases were being shifted back to Department Intact caseworkers. The Department’s goal is to achieve about 90 percent of Intact cases served by the private agency providers and have approximately 10 percent of Intact cases remain with the Department Intact caseworkers. 49 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT A POS agency is responsible for providing the actual intact services, either through the agency or through other subcontracted entities. Examples of services that might be provided include mental health counseling, parenting classes, substance abuse treatment, or domestic violence counseling. When an investigation shows a need for services and the family agrees to receive services, a request form is sent by the Child Protection Supervisor to the Area Administrator who then forwards the case to the Intact Utilization Unit Supervisor for assignment to a POS agency or Department worker. The child protection worker and supervisor, and the Intact worker and the Intact supervisor have a “hand-off” conference call to determine the needs of the family and schedule a transitional visit. After the hand-off call, the case worker and Intact worker meet with the family at the family’s home for the transitional visit to review the plan and explain the process. The Intact worker from the POS agency takes over the case services, and has five days to complete a Child Endangerment Risk Assessment Protocol. Intact services are billed to the Department by the POS agency at a per family rate. For FY15-FY17, the rate was $1,206 per month for the first six months. After six months the rate dropped to $639 per month for FY15-FY16 and to $671 per month for FY17. In 2014 the Department instituted a tier two approach which allows for a rate of $1,106 per month after the first six months for some cases. There is no limit on the length of time an IFS case may remain open. A total of 29 POS agencies provided IFS services during FY15-FY17. Some agencies have multiple contracts that cover different regions of the state. While the number of contracts dropped each year, the total capacity fluctuated, dropping between FY15 and FY16 before slightly rising in FY17. The IFS agency capacity is the maximum number of open cases at any one time. This allows for agencies to plan for the number of caseworkers needed to serve IFS cases. Exhibit 4-4 shows the number of contracts, the capacity and the expenditures for IFS by fiscal year. Due to limitations in the service data Exhibit 4-4 INTACT FAMILY SERVICES provided by the Department, we could not CONTRACTS, CAPACITY, AND EXPENSE determine the number of IFS cases for the FY15-FY17 audit period. On August 1, 2018, we FY15 FY16 FY17 requested the number of intact family Contracts 42 38 37 services cases served by POS agency Capacity 2,380 2,250 2,330 contracts for FY15-FY17. The Department Expense $27,895,182 $26,808,690 $30,710,472 could not readily provide data to show the Source: OAG analysis of Department data. number served by each IFS contract or agency and officials stated it would require a special data run from its systems. Information regarding the number served by each IFS contract each fiscal year for the audit period was never provided. According to an official, there is no database with this information in it. Without having IFS case data readily available it is difficult for the Department to conduct budgetary or strategic planning for its IFS program. It is also unclear how the Department is determining the contracted capacities in the POS agency contracts without knowing the actual number that received services. Further, it makes it difficult for the Department to know if POS caseworkers are maintaining caseloads in compliance with the B.H. consent decree (88 C 5599 (N.D. Ill.)), which limits the caseload to 20 families per caseworker. 50 CHAPTER FOUR – SERVICES INTACT FAMILY SERVICES MONITORING RECOMMENDATION 9 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should track the number of Intact Family Services cases that are opened annually including which POS agency provided the services. The Department currently tracks Intact Family Services cases using payment data for both POS agency (contract) utilization and for budgeting purposes. While these fiscal reports will continue, the Department in addition will be developing monthly production reports from DoIT to ensure DCFS management staff receives timely reporting of agency caseloads. Intact Family Services County Coverage Counties Without Contract For Intact Family Services, the Department POS Coverage contracts did not cover all counties in the State during the audit period. During our review of IFS POS agency FY15 FY17 Hancock Henderson contracts, auditors found 10 counties that were not Kane Logan covered by any provider for at least one fiscal year. Kendall Mason Auditors followed up with the Department and an official Moultrie Warren explained that the lack of coverage was due to an Schuyler oversight on the contract. The official stated that they Shelby asked the POS agencies to review the coverage section of the contract to ensure its accuracy and it often got overlooked. According to the official there is at least one agency for every county in the State even though it may not be reflected in the contracts. However, because the Department could not provide a list of those served by each POS contract, we could not determine whether services were provided to families in all counties of the State. Not ensuring that the contracts are accurately completed and inclusive of all counties increases the risk that families in the overlooked counties may not be provided needed services due to the lack of agencies having a contractual obligation to serve those counties. 51 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT INTACT FAMILY SERVICES COVERAGE RECOMMENDATION 10 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should ensure that POS agency contracts are accurate and specify coverage for all assigned counties. The Department’s Office of Contract Administration reviews all contracts annually, each Spring, in preparation for July 1st services. Beginning in FY19, the Department has included as part of that review process to ensure a careful review with Intact Family Services management staff that all counties are reported accurately for every contract. While no families were denied services due to specific counties not being listed, the Department’s expectation is that all assigned counties are reflected in the POS agency contracts in a complete and accurate manner. IFS Referrals According to Department procedures, once a Child Protection Specialist (investigator) recommends that an investigation be indicated and that a family will need Intact Family Services, the Child Protection Supervisor is required to review the recommendations with the investigator during a supervisory conference. The Child Protection Supervisor is required to document the decision to refer the case to Intact Family Services in a Supervisory note. If the Child Protection Supervisor approves the recommendation an Intact Family Services Case Referral and Assignment Form (CFS 2040) is required to be completed with the investigator and approved by the Child Protection Supervisor. The Child Protection Supervisor then submits the CFS 2040 form to the appropriate Area Administrator via Department email (Procedures 302.388). We requested the CFS 2040 IFS referral forms for 25 investigations that we sampled that had an IFS case ID number. The Department could only provide 1 of 25 (4.0%) requested referral forms. The form that was provided did not show evidence of Department approval for the services. According to officials, because of computer modifications and folders being archived, the CFS 2040 forms may no longer exist. Often these documents, which are only shared by email between the supervisor and Area Administrators, are no longer in their folders. It is very likely most of these existed only in electronic format. The CFS 2040 forms show information about the investigation including family composition, paramours involved, CERAP information, prior abuse and neglect history, criminal history, case opening history, investigation history, and services already initiated all in one place. If maintained, these forms would allow investigators to quickly review any previous issues and services. 52 CHAPTER FOUR – SERVICES INTACT FAMILY SERVICES REFERRALS RECOMMENDATION 11 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should complete a CFS 2040 form for Intact Family Service referrals as is required by procedures. These forms should also be maintained in an accessible location. The CFS 2040 has been used as an Intact referral document from the Investigation supervisors to the Area Administrators. The document’s development can be tracked back to 9/09. Until May 2015, the Area Administrators statewide referred to the Intact agencies directly. May 1, 2015 the Intact referrals began to come to the Intact Utilization Unit for Cook County referrals only. The Intact PSA assigned the cases to the respective POS agencies, sent the assignment information back to the DCP AA, the assigned private agency Intact contact and the DCP supervisor for the handoff to be scheduled. The Intact Utilization PSA housed in Cook, has hard copies of 2015 2040’s. As of December 2017, the Intact Utilization Unit took over case assignment from the Area Administrators statewide. Prior to December 2017 all of the Downstate referrals were managed by the AA’s. The PSA in Springfield and the PSA in Cook divide the 4 regions, each taking two regions, to be responsible for case assignment. Currently, all Intact referrals are logged and maintained electronically by the Intact Utilization Unit. The log of referrals is statewide. Historically, regions were required to submit their Intact referral logs to the Chief Deputy monthly. This demonstrates there has been tracking of Intact referrals, and it continues to be refined and enhanced. All 2040s are managed electronically from AA to the Intact Unit PSA and electronic folders. The Intact Utilization clerical’s document each referral in the respective Regional log. Norman Cash Assistance Norman Cash Assistance services assist families who lack food, clothing, housing or other basic human needs that place children’s safety at risk and would otherwise necessitate removal from the family or would be a barrier to reunification. The program provides cash assistance to purchase needed items, assistance in locating housing, and expedited enrollment in TANF (Temporary Assistance for Needy Families). When cash assistance is needed to purchase an item to keep a child from being placed in, or to return a child home from Department care, the Child Protection Specialist (investigator) or permanency worker shall submit a CFS 370-5 form, Request for Cash and/or Housing Assistance, to the permanency supervisor. This request for cash assistance should be made promptly upon the Child Protection Specialist (investigator) or permanency worker learning of the subsistence needs. If other types of assistance are inappropriate or unavailable and the client 53 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT cannot afford to purchase the item, the worker shall apply for Norman funds. The Child Protection Specialist (investigator) or permanency worker shall indicate on the form the purpose for which cash assistance is being requested, the amount, and the type of cash assistance requested. The final decision regarding the types and amounts of cash assistance rests with the Department supervisor or Department Norman Liaison. Depending on the need, an authorized Department supervisor may approve up to $800 in cash assistance in a 12-month period for a family who is certified as a member of the Norman Class. This may be provided in addition to funds from the Illinois Department of Human Services, other cash funds available from the Department, or other local community resources. There is no limit on the number of times cash assistance can be provided in a 12-month period. In situations where higher amounts are necessary, a Department Norman Liaison may approve up to $1,200. A Department Regional Norman Liaison may approve up to $2,000. The Norman Program Coordinator or designee may approve requests up to $2,400. Any request over $2,400 must have the approval of the Deputy Director of the Division of Service Intervention or designee (Procedures 302.385(g)). We could not identify the position of Deputy Director of the Division of Service Intervention in any Department organizational charts that were provided. According to Department officials, the position of Deputy Director of the Division of Service Intervention no longer exists. The policies for approving Norman Cash Assistance were last updated in 2005. Of the 150 investigations we reviewed, we identified 4 that received Norman Cash Assistance. On November 16, 2018, auditors requested any documentation from the Department for these expenditures. On November 19, 2018, the Department provided notes and a one page printout for one expenditure, but did provide any approval forms. On April 5, 2019, after the exit conference was held, the Department provided approval forms for three expenditures. The Department could not provide an approval form for one expenditure for $1,400. 54 CHAPTER FOUR – SERVICES NORMAN CASH ASSISTANCE RECOMMENDATION 12 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should document all purchases made with Norman Cash Assistance funds. The Department should also update its cash assistance request approval policies to reflect the current organizational structure of the agency. The Department agrees that Procedures and Organization charts should reflect the current process. The Department also agrees that purchases made using Norman Cash Assistance Funds should not only be well documented but, that documents should be readily available for review/audit.    The Agency shall update their written procedures to reflect how Norman Cash Assistant funds are currently processed, including who approves assistance. The Agency shall update the Organization Chart, reflecting the removal of the Deputy Director of the Division of Service Intervention position. The Agency shall include in their update of written procedures the process of properly retaining CFS 370-5 forms to ensure they are readily available for review/audit. In completing the corrective actions above, the Department expects to develop a system that; (A) properly reflects the current process and organizational structure of the Norman Cash Assistance program and (B) ensures proper document retention of purchases made. Community Services The Department could not provide documentation of referrals to community services or whether the services were received. Department investigators rely on contact notes in SACWIS to document any verbal discussions with families. Although Department procedures require investigators to be actively involved in the referral/linkage process and to document this involvement in a contact note, our review of cases in SACWIS showed that these procedures are not being followed. There are no formal forms for referrals to community based services. Therefore, it was difficult to document if the families actually received referrals or followed up with any referrals and received services from community providers. According to Department procedures, it is expected that a Child Protection Specialist (investigator) shall refer a family that does not meet the eligibility criteria for Intact Family Services (i.e., unfounded investigations) to appropriate community services as applicable to the needs of the family. Such referrals should be documented in a case note in SACWIS (Procedures 302.388(c)(1)). Because the Department’s rules and procedures do not include a definition of what constitutes community services, we asked the Department what would be defined as community services. Officials responded that community services would include any services that are not provided as contracted services. According to a Department official, community services may include food pantries, mental health service referrals, and medical and dental information. It 55 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT may also include providing the locations of other agency offices such as the Department of Human Services, the Social Security Office, or where to apply for unemployment. Transportation information may also be provided. Some communities may also have various cultural and language service providers. Available services may vary by community. According to Department procedures, community services are appropriate when children have been assessed to be at low to medium risk and the family is capable of using support services provided through community resources without further Department intervention. The purpose of Department involvement is to actively link the family with those services and resources that effectively address their needs. The Child Protection Specialist (investigator) shall actively be involved in the referral/linkage process and shall document this involvement in a contact note. Referral/linkage activities include, but are not limited to:        Initiating contact with providers; Advocating on the family’s behalf; Documentation of the frequency of and duration of services recommended for the specific members of the family and the conditions/circumstances that the services are designed to mitigate; Documentation of the date and time of the intake session; Assistance with the family’s transportation issues; Participation in the intake process when necessary; and Verification that the family is following through and utilizing the services provided (Procedures 300.130(b)). We reviewed information in SACWIS for 150 investigations and requested information from the Department regarding 60 investigations that may have received community services. For 45 of 60 investigations (75.0%), the Department could not provide documentation that any services were received. Further, in our review of investigation case notes in SACWIS, we found little documentation of the required referral/linkage activities covered in Procedure 300.130(b). COMMUNITY BASED SERVICES RECOMMENDATION 13 The Department of Children and Family Services should follow existing Department procedures including:   DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE Documenting referrals for community based services including the duration and frequency of the services and the conditions/circumstances that the services are designed to mitigate; and Verifying whether the family is following through with the community services. The Department will ensure staff are reminded of current procedures regarding community referrals, what the service mitigates, time frames and verification the family has linked with the service. This will be completed by July 2019. The Creation of a specific “services” note within SACWIS will be explored. 56 Chapter Five DEMOGRAPHIC INFORMATION CHAPTER CONCLUSIONS During the audit period, the number of indicated children decreased every year while the total number of alleged victims increased. According to data provided by the Department as of July 27, 2018, for the three-year period FY15-FY17 there were 221,341 investigations involving a total of 358,545 children, 96,576 of whom had at least one indicated allegation. Auditors could not obtain a reliable count of the number of unique victims because of limitations with the data provided by the Department. Each person in the SACWIS system is assigned a unique PersonID. However, auditors found that there were over 8,000 instances where the same child had been assigned multiple PersonIDs. Therefore, auditors could not obtain a reliable count of the number of unique child victims over the audit period because of data limitations. For the 221,341 investigations for FY15-FY17, there were 450,483 total allegations, with an overall indication rate of 25.5 percent. The most common allegations were “Substantial Risk of Physical Injury/Environment Injurious to Health and Welfare by Neglect” and “Inadequate Supervision.” A total of 52,502 children were the alleged victims of sexual abuse during FY15FY17 and 32,439 children were the alleged victims of serious harm. Age Children under the age of one were the most frequent alleged victims of abuse or neglect (8.1% of all victims) and also the most likely to be indicated victims (13.3% of all indicated victims). After the age of one, the number of indicated allegations of abuse or neglect trends downward. Race and Ethnicity For race, children who were identified as White or Black/African-American made up 96.4 percent of all alleged victims (62.5% White and 33.9% Black/African-American) and 97.1 percent of all indicated victims (62.4% White and 34.7% Black/African-American). Data provided by the Department showed that 2.3 percent of alleged victims did not have a race recorded. For ethnicity, children with a Hispanic ethnicity comprised 15.6 percent of all victims and 16.7 percent of indicated victims. Gender For gender, there was an even split between male and female victims. Males accounted for 49.7 percent of all alleged victims and females were 49.6 percent. For indicated victims, males accounted for 49.4 percent and females were 50.3 percent. 57 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Geographic Location Auditors found that 25.5 percent of all investigations occurred in Cook County, followed by Lake County with 4.1 percent. There were investigations of alleged abuse or neglect in all 102 counties in Illinois. ALLEGATIONS The Department utilizes an allegations system. According to Department procedures, the purpose of the allegations system is to identify and define specific types of moderate to severe harm, provide a framework for decision-making by the State Central Register (Hotline) and investigative staff, and provide an important investigation tracking and record-keeping function. Every alleged victim is assigned at least one allegation. The allegations are categorized as either abuse or neglect. All allegations coded with a number ranging from 1 to 40 are abuse and all allegations coded with a number between 51 and 90 are neglect allegations. Some allegations can fall under both abuse and neglect. For example, Allegation #1 is death by Exhibit 5-1 abuse and Allegation #51 is death by ALLEGATIONS OF ABUSE OR NEGLECT FY15-FY17 neglect. During fiscal years 2015 through 2017 DCFS investigated a total of 450,483 allegations of abuse or neglect. Of the 450,483 allegations, 114,653 were indicated, for an overall indication rate of 25.5 percent. Exhibit 5-1 shows the number of allegations and the number of allegations that were indicated and unfounded by year. 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 136,284 160,540 153,659 97,208 122,702 115,920 39,076 37,838 37,739 FY15 FY16 FY17 The most common alleged Indicated Unfounded allegations were #60 - Substantial Risk of Physical Injury/Environment Source: OAG analysis of DCFS data as of July 27, 2018. Injurious to Health and Welfare by Neglect (123,019 allegations, 27.3% of allegations) and #74 - Inadequate Supervision (74,542 allegations, 16.5% of allegations). The most common indicated allegations were also #60 Substantial Risk of Physical Injury/Environment Injurious to Health and Welfare by Neglect (44,991 allegations, 39.2% of indicated allegations) and #74 - Inadequate Supervision (18,582 allegations, 16.2% of indicated allegations). The allegation with the highest indication rate was #65 - Substance Misuse by Neglect at 55.6 percent and the allegation with the lowest indication rate was #67 - Mental Injury by Neglect at 3.9 percent. Appendix E provides a summary of all the allegations by type and fiscal year. Special Types of Victims The Department classifies certain allegations together as special types. These include death & serious harm (for example head injuries, internal injuries, burns or torture), sexual abuse, human trafficking, and substance exposed infants. Substance exposed infants are defined as child victims under the age of one who have been reported for the allegation of substance 58 CHAPTER FIVE – DEMOGRAPHIC INFORMATION misuse (for example, a child born with exposure to a controlled substance). Appendix E lists all the special types of allegations. Exhibit 5-2 shows the number of victims per year for special types of abuse and neglect. The most common special type of victim is sexual abuse victims, with a total of 52,502 alleged victims over the course of the 3 years with 13,525 indicated victims. There were 32,439 alleged death & serious harm victims and 8,135 indicated victims during FY15-17. DCFS publishes data on death & serious harm reports (investigations) but for consistency, the numbers reported here are for victims. There were 2,424 alleged substance exposed infants with 1,892 indicated victims. Human trafficking had 614 alleged victims with 112 indicated victims. Appendix E shows a breakdown by year for indicated victims for all special types of allegations. Exhibit 5-2 SPECIAL TYPES OF VICTIMS FY15-FY17 10,202 11,492 10,745 Death and Serious Harm 16,805 18,442 17,255 Sexual Abuse 0 5,000 10,000 15,000 20,000 143 Human Trafficking 238 233 701 Substance Exposed Infant 809 914 0 FY15 200 FY16 400 600 800 1,000 FY17 Source: OAG analysis of DCFS data as of July 27, 2018. 59 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Deaths Analysis There were 658 victims with a death allegation (Allegation #1 or #51) during FY15FY17, of which 210 were indicated for death by abuse or neglect. The indication rate for death victims dropped significantly during the audit period going from 44.0 percent in FY15 to 28.0 percent in FY16 and 29.2 percent in FY17. Auditors conducted an analysis Exhibit 5-3 DEATH VICTIMS, UNFOUNDED VS. INDICATED of death victims to look for any with FY15-FY17 prior abuse/neglect investigations that were conducted during FY15-FY17; 264 141 253 100% 102 victims (15.5%) had prior 90% investigations. There were 163 prior 80% 79 70% investigations for these 102 victims. As 179 190 60% discussed later in this chapter, because 50% of issues with the PersonID, it is 40% difficult to know if these are all the 30% death victims with prior contact with 62 20% 74 74 DCFS. The number of prior 10% investigations ranged from one to nine. 0% FY15 FY16 FY17 For the child with nine prior investigations during FY15-FY17, six Indicated Unfounded were indicated and there was an open Intact Family Services (IFS) case when Source: OAG analysis of DCFS data as of July 27, 2018. the child passed away. There was also a victim with seven prior investigations (1 indicated) who was a DCFS youth in care when s/he died and a victim with four indicated prior investigations and an open IFS case at the time of the death. For the prior investigations, 28 of 163 involved DCFS services (1 Intact Family Recovery, 18 Intact Family Services and 9 placement). Of those 28 cases, 21 were receiving services when the child died. 60 CHAPTER FIVE – DEMOGRAPHIC INFORMATION VICTIM DEMOGRAPHICS House Resolution Number 418 asks the Auditor General to review for FY15, FY16, and FY17 the demographic information on abuse and neglect investigations, including the age, race, and gender of children who were subjects of the abuse or neglect investigations, and, if available, the zip code and county where the abuse or neglect was alleged to have occurred. Data provided by the Department included the total number of alleged victims involved in an investigation during the three-year audit period. Since victims can be reported multiple times this is not an unduplicated count. Exhibit 5-4 UNFOUNDED VICTIMS VS. INDICATED VICTIMS FY15-FY17 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 110,136 127,291 121,118 77,141 95,320 89,508 32,995 31,971 31,610 FY15 FY16 FY17 Indicated Unfounded According to data provided by Source: OAG analysis of DCFS data as of July 27, 2018. DCFS as of July 27, 2018, for the threeyear period FY15-FY17 there were a total of 221,341 investigations involving a total of 358,545 alleged victims. Of these 358,545, 96,576 victims had at least one indicated allegation over the three-year period. As shown in Exhibit 5-4, the number of alleged victims with investigations increased over the three-year period. However, the number of indicated victims decreased each year. Limitations of Provided Data Auditors could not obtain a reliable count of the number of unique child victims over the audit period because of data limitations. Every year the federal government publishes national child abuse and neglect statistics that are submitted by the states. Due to data reliability issues it was difficult to compare Illinois to national statistics because demographics in federal reports are based on a unique count of indicated victims. Further, the data limitations could make it difficult for DCFS to accurately report data to the federal government. DCFS assigns each person in the SACWIS system a unique PersonID that follows that person throughout different investigations. Auditors conducted an analysis of victim data based on PersonID for FY15-FY17. For the audit period, 8,061 children were identified where there was an identical name, the same date of birth and the same gender but a different PersonID. Due to input error, there may be inconsistencies in demographic fields. To attempt to control for issues such as with the misspelling of names, auditors performed the same analysis, but limited the first name to the first two letters. This identified an additional 2,570 children as possible duplicates because they shared the same date of birth, the same gender, the same last name and the same first two letters of their first name. When asked why this might occur, DCFS officials stated that possible explanations are, at intake, workers create a new PersonID in error or when a child is adopted a new post-adoption PersonID is assigned per procedure, so the child will have a separate pre-adoption and post-adoption PersonID. 61 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Giving children multiple PersonIDs makes it difficult for the Department to search for prior reports on the children. DCFS procedures require that investigators complete a person search for all subjects of the report. DCFS Call Floor Workers also search SACWIS for any prior reports. If a child is listed under multiple PersonIDs the Call Floor Worker and investigator may not be able to identify all the prior reports involving that child. Data limitations are not confined to issues with PersonIDs. The limitations of data provided by the Department are discussed in Chapter One. 62 CHAPTER FIVE – DEMOGRAPHIC INFORMATION Age House Resolution Number 418 asks the Auditor General for the age of children who were subjects of abuse or neglect investigations during FY15-FY17. Exhibit 5-5 shows the breakdown by year. Children under one year of age were the most frequent alleged victims. They also were the most likely to be indicated. While children under 1 year of age make up 8.1 percent of all alleged victims, they are 13.3 percent of indicated victims. Over the three fiscal years 44.4 percent of victims under the age of 1 were indicated, compared to 26.9 percent of all victims. Appendix F shows the number of victims per age. Exhibit 5-5 VICTIMS BY AGE FY15-FY17 Alleged Victims 12,000 10,000 8,000 6,000 4,000 2,000 0 Age Indicated Victims 5,000 4,000 3,000 2,000 1,000 0 Age FY15 FY16 FY17 Note: Because of the small number of indicated victims for the categories 18 and Over and Unknown, numbers are not reflected in the exhibit. Source: OAG analysis of DCFS data as of July 27, 2018. 63 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Race and Ethnicity House Resolution Number 418 asks the Auditor General for the race of children who were subjects of abuse or neglect investigations during FY15-FY17. DCFS captures data by race and ethnicity in separate categories. DCFS data does not record Hispanic as a race but instead categorizes it as an ethnicity. Approximately 89 percent of Hispanic alleged victims are included in the race category of White. Exhibits 5-6 and 5-7 show the breakdown by race and ethnicity for FY15-FY17 (see Appendix F for the racial and ethnic breakdowns by fiscal year). Exhibit 5-6 ALLEGED VICTIMS BY RACE AND ETHNICITY FY15-FY17 Unknown 17.1% Hispanic 15.6% Black/African American 33.9% Ethnicity Race White 62.5% Asian 1.1% Unknown 2.3% Other 0.2% Not Hispanic 67.3% Notes: Unknown includes the categories of Unknown, Not Reported, Could not be verified, Declined to Identify, and NULL. For Race, Other includes Native American/Alaska Native and Native Hawaiian/Other Pacific Islander. Source: OAG analysis of DCFS data as of July 27, 2018. Children who were identified by the Department as White and Black/African-American made up 96.4 percent of all alleged victims (62.5 percent White and 33.9 percent Black/AfricanAmerican). The percentage of children who were indicated by race mirrors the breakdown for all children. For 62.4 percent of indicated children their race was identified as White and 34.7 percent of children were identified as Black/African-American. 64 CHAPTER FIVE – DEMOGRAPHIC INFORMATION Exhibit 5-7 INDICATED VICTIMS BY RACE AND ETHNICITY FY15-FY17 Unknown 17.4% Hispanic 16.7% Black/African American 34.7% Ethnicity Race White 62.4% Asian 0.9% Not Hispanic 65.9% Unknown Other 1.9% 0.2% Notes: Unknown includes the categories of Unknown, Not Reported, Could not be Verified, Declined to Identify, and NULL. For Race, Other includes Native American/Alaska Native and Native Hawaiian/Other Pacific Islander. Source: OAG analysis of DCFS data as of July 27, 2018. The largest group for ethnicity for all children was Not Hispanic at 67.3 percent followed by Hispanic at 15.6 percent. The percentage for children indicated by ethnicity is similar to the numbers for all children. Some 65.9 percent of children who were indicated were Not Hispanic children and 16.7 percent were Hispanic. Gender House Resolution Number 418 asks the Auditor General for the gender of children who were the subjects of abuse or neglect investigations during FY15-FY17. According to data provided by DCFS there was an even split between the number of males and the number of females (see Exhibit 5-8). Overall males made up 49.7 percent of the victims while females were 49.6 percent of the victims. For victims where the allegations were indicated, the breakdown remained evenly split. Males were 49.4 percent of all indicated victims and females were 50.3 percent. Exhibit 5-8 shows the comparison between the overall number of alleged victims and the number of indicated victims. 65 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT Exhibit 5-8 VICTIMS BY GENDER, ALLEGED VS. INDICATED FY15-FY17 Unknown 0.7% Unknown 0.4% Male 49.7% Male 49.4% Indicated Alleged Female 50.3% Female 49.6% Source: OAG analysis of DCFS data as of July 27, 2018. Zip Code and County of Occurrence House Resolution Number 418 asks the Auditor General for the zip code and county where the abuse or neglect was alleged to have occurred. DCFS records the occurrence address, which includes the zip code and county. Occurrence data is based on the number of investigations instead of the number of victims. While zip code is captured, auditors found issues with the reliability of the data. For incidents that took place in Illinois, over 1,000 did not have valid Illinois zip codes. Additionally, even though addresses can be verified through the United States Postal Service, 19.5 percent of addresses were not verified or were blank. Therefore, only county-level data will be presented. For county data, there were 916 investigations in which the state is Illinois but there was no county provided. Exhibit 5-9 OCCURRENCE TOP 10 COUNTIES FY15-FY17 County Cook Lake Winnebago Will DuPage Kane Sangamon St. Clair Peoria Madison FY15 Count Percent 18,015 26.6% 2,679 4.0% 2,565 3.8% 2,351 3.5% 2,235 3.3% 2,170 3.2% 1,907 2.8% 1,750 2.6% 1,607 2.4% 1,434 2.1% FY16 Count Percent 20,048 25.5% 3,290 4.2% 2,776 3.5% 2,794 3.6% 2,677 3.4% 2,573 3.3% 2,108 2.7% 2,008 2.6% 1,809 2.3% 1,581 2.0% Source: OAG analysis of DCFS data as of July 27, 2018. 66 FY17 Count Percent 18,479 24.6% 3,109 4.1% 2,478 3.3% 2,486 3.3% 2,414 3.2% 2,474 3.3% 1,954 2.6% 1,980 2.6% 1,629 2.2% 1,756 2.3% Total Count Percent 56,542 25.5% 9,078 4.1% 7,819 3.5% 7,631 3.4% 7,326 3.3% 7,217 3.3% 5,969 2.7% 5,738 2.6% 5,045 2.3% 4,771 2.2% CHAPTER FIVE – DEMOGRAPHIC INFORMATION There were allegations of abuse or neglect in all 102 counties in Illinois, ranging from 42 investigations in Calhoun County to 56,542 in Cook County. Exhibit 5-9 shows the top 10 counties with the highest number of abuse and neglect investigations. Appendix G lists the number of investigations for all counties. 67 PERFORMANCE AUDIT OF DCFS INVESTIGATIONS OF ABUSE AND NEGLECT 68 APPENDICES 69 7O APPENDIX A HOUSE RESOLUTION NUMBER 418 71 72 STATE OF ILLINOIS HOUSE OF REPRESENTATIVES IOOTH GENERAL ASSEMBLY HOUSE Rnsommon No. 0418 OFFERED BY REPRESENTATIVES LA SHAWN K. FORD-MARY moms-Slum A. merr?Ipu IANG-IAWRENCE WAISH, 13., Batman R. Bumcx AND LATOYA GREENWOOD WHEREAS, The Department of Children and Family Services or "Department") is responsible for providing child protective services and programs to abused, neglected, and dependent children and their families; and WHEREAS: The shooting death of 17 year-old Laquan McDonald by a Chicago police of?cer on October 20: 2014 shed light on the ine?iciencies that plague the DCFS foster care program as media reports revealed the instability and abuse Laquan McDonald experienced throughout his youth as he moved through the foster care system; and WHEREAS, Last month's suspicious death of 16 month-old Semaj Crosby: whose body was found in her family?s Jolict home a day and a half after DCFS case workers visited the home to investigate an allegation of child neglect has elicited sharp criticism on how DCFS investigates reports of child abuse and neglect; and WHEREAS, Illinois has an interest in ensuring that all reports of child abuse and neglect are thoroughly investigated and that the children of this State have access to adequate and ef?cient protective services and programs; therefore, be it RESOLVED, BY THE HOUSE OF REPRESENTATIVES OF THE ONE HUNDREDTH GENERAL ASSEMBLY OF THE STATE OF ILLINOIS, that the Auditor General is directed in accordance With Section 3?2 of the Illinois State Auditing Act to conduct a performance audit on the Department of Children and Family Services to review and assess the Department?s protocols for investigating reports of child abuse and neglect; and be it further RESOLVED, That the audit include a review of abuse and neglect investigations conducted by the Department of Children and Family Services in Fiscal Year 2015= Fiscal Year 2016, and Fiscal Year 2017, including, but not limited to, a review of. the status of abuse and neglect investigations; (2) the ?nal determination or ?ndings made by the Department for abuse and neglect investigations; (3) the time time within which the Department completed or closed abuse and neglect investigations; (4) for sampled cases, recommendations made by the Department to families who were the subject of an abuse or neglect investigation, including any services provided by the Department to the child or family; and (5) demographic information on abuse and neglect investigations, including the age, race, and gender of children who were subjects of the abuse or neglect investigations, and, if available: the zip code and county where the abuse or neglect was alleged to have occurred; and be it ?nther RESOLVED, That the Auditor General compile a detailed report that includes a full summary on the number of lawsuits or other legal actions ?led against the Department within the past 3 ?scal years that concern an abuse or neglect investigation and the number of lawsuits the Department settled within the past 3 ?scal years that concern an abuse or neglect investigation; and be it further RESOLVED, That the Department of Children and Family Services cooperate ?illy and with the Auditor General in the conduct of this audit; and be it 73 RESOLVED, That the Auditor General is not allowed or authorized to release or disclose in his report any information that is prohibited ?om public disclosure under the Abused and Neglected Child Reporting Act or under any other State or federal law; and be it further RESOLVED, That the Auditor Genera} commence this audit as soon as possible and submit his report, including his ?ndings and recommendations, upon completion in accordance with the provisions of Section 344 of the Illinois State Auditing Act; and be it further RESOLVED, That a copy of this resolution be delivered to the Auditor General and the Department of Children and Family Services. Adopted by the House of Represemz?ves on June 25: 2017. D. MAPEQ CLERK OF THE HOUSE MADIGAN SPEAKER OF THE HOUSE 74 APPENDIX AUDIT SCOPE AND METHODOLOGY 75 76 Appendix B Audit Scope and Methodology This audit was conducted in accordance with generally accepted government auditing standards and the audit standards promulgated by the Office of the Auditor General at 74 Ill. Adm. Code 420.310. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. House Resolution Number 418, adopted June 25, 2017, directed the Auditor General to conduct a performance audit of the Department of Children and Family Services (DCFS) to review and assess the Department’s protocols for investigating reports of child abuse and neglect. The resolution required the audit to include a review of abuse and neglect investigations conducted by DCFS in Fiscal Year 2015, Fiscal Year 2016, and Fiscal Year 2017 (see Appendix A). During the audit, we examined the DCFS organizational structure, headcount, and the investigation process. We specifically examined the processes for reporting allegations of child abuse and neglect, assigning and conducting investigations, timeliness and documentation requirements, and supervisory review. We also reviewed the investigative protocols used and related internal controls over the investigation process. As part of reviewing and assessing DCFS investigation protocol, we reviewed statutes, administrative rules, and agency policies and procedures related to the conduct of investigations and the provision of services. Any instances of noncompliance are included in the audit report as recommendations. During the audit we also assessed the risk of fraud occurring as related to the audit objective and discussed these risks in an audit team meeting. Data Limitations The Department of Children and Family Services had significant issues producing accurate child abuse and neglect investigation statistical reports during the audit period and while we were conducting the audit. We also identified concerns with the quality of the data contained in the Department’s Statewide Automated Child Welfare Information System (SACWIS) as well as data provided to us for the audit. These concerns are discussed in Chapter One. Although the data is not always complete and accurate, it is the only source that exists for analyzing child abuse and neglect investigations. While recognizing the shortcomings of the data provided, in our opinion, the data was reliable enough to use in the general context of addressing the audit’s objectives including sampling services. Investigation and Demographic Data On July 27, 2018, DCFS provided auditors with a download of the population of intakes received by DCFS for FY15, FY16, and FY17 and the investigations related to those intakes. With the data provided, we conducted analyses to identify trends and made comparisons between years for investigations of child abuse and neglect. In accordance with the audit objectives in House Resolution Number 418, with the data provided by DCFS we determined: 77  The status of abuse and neglect investigations for each year;  The final determination or findings for investigations;  The timeframes in which abuse and neglect investigations were completed or closed; and  Demographic information related to the children involved, including their age, race, and gender. We also reviewed the county in which the abuse or neglect was alleged to have occurred. We assessed the sufficiency and appropriateness of investigations data provided by DCFS. This included:     Performing walkthroughs for intakes at the State Central Registry, investigations, and services at DCFS in order to determine what data was collected and how it was utilized; Developing field definitions for requested data to ensure the validity of data being provided; Gaining access to SACWIS in order to test the reliability and validity of data provided; and Comparing data provided to published available reports. Sampling of Services For the period FY15-FY17 there were a total of 221,341 investigations. Because of the number of unfounded cases that were expunged, and are therefore not accessible in DCFS’ computer system, we focused our sampling of services on indicated cases (founded). CHILD ABUSE AND NEGLECT STATISTICS FY15-FY17 Investigations Indicated Reports1 Percent Indicated FY15 67,732 19,156 FY16 78,572 18,710 FY17 75,037 18,591 Total 221,341 56,457 28.3% 23.8% 24.8% 25.5% 1 Indicated reports include those that were indicated due to review. According to data provided by the Source: OAG analysis of DCFS data as of July 27, 2018. Department, for the three years FY15FY17 there were 56,457 indicated investigations. We conducted a random sample of 50 indicated investigations for each fiscal year for a total of 150 cases. Because the majority of investigations were expunged and were therefore unviewable, they could not be included in our sample. Testing results cannot be extrapolated to the overall population. Using a data collection instrument, we gathered information from the investigation and case files in SACWIS related to:  Whether a specific recommendation for services was made by the Child Protection Specialist (investigator) and the types of service(s) recommended;  Whether the family received services from DCFS or a private Purchase of Service (POS) agency and the duration of those services;  Whether the recommended services (which are voluntary) were waived by the child’s family; and 78  Whether the services received matched the recommendation made by the Child Protection Specialist (investigator). We also reviewed these cases to determine whether they followed the investigative protocol for Child Endangerment Risk Assessment Protocols (CERAPs) and whether cases met requirements related to timeliness. We also conducted a judgmental sample of cases that took longer than 60 days to complete to review whether extensions were completed and the reason given for the extension. Audit Risk We provided the Department with exceptions from our sample of services. However, the Department’s responses did not always include a response or documentation to support statements made in regard to audit exceptions and questions. Because the Department was not always responsive to our requests, in some individual cases auditors were forced to use their best judgement to determine if services were provided without additional input or documentation from the Department. Without full cooperation and input from the Department, there is some risk that auditors could reach an invalid conclusion in individual cases. However, this would not affect our overall conclusions presented in the audit. Lawsuits, Settlements, and Other Legal Actions We worked with DCFS legal counsel officials to determine the number of lawsuits or other legal actions filed against the Department within the past three fiscal years that concern abuse or neglect investigations and the number of lawsuits that DCFS has settled within the past three fiscal years that concern an abuse or neglect investigation. We reviewed and summarized the documentation provided by DCFS legal staff. Appendix C is a summary of the lawsuits or other legal actions and settlements for FY15-FY17. 79 The date of the exit conference, along with principal attendees, are noted below: Date: April 1, 2019 Agency Department of Children and Family Services  Debra Dyer-Webster, Interim Director  Royce Kirkpatrick, Acting CFO  Kenneth Hovey, Chief Internal Auditor  Nora Harms-Pavelski, Deputy Director, Child Protection  Anne Gold, Associate Deputy Director, Child Protection  Mike Paoni, Audit Manager  Paul Skonberg, Audit Supervisor  Brian Bratton, Audit Staff Office of the Auditor General 80 APPENDIX LAWSUITS FILED OR SETTLED FY15-FY17 81 Appendix C LAWSUITS FILED OR SETTLED FY15-FY17 Count Case Name A.B. v Holliman et al Case Number 14CV07897 Date Filed 10/9/2014 Court U.S. District Court, Northern District, Eastern Division 2 A.N. et al v Bolanos-Ayala 17CV1033 2/8/2017 U.S. District Court, Northern District, Eastern Division 3 Allen v City of Chicago et al 14CV09359 11/20/2014 U.S. District Court, Northern District, Eastern Division 4 Ashley M. v DCFS et al 13CH20278 9/3/2013 Circuit Court of Cook County, County Department, Chancery Division 5 Cole v Meeks 15CV01292 7/15/2015 U.S. District Court, Central District, Peoria Division 6 Dickman v Cook County State's Attorney 16CV9448 10/3/2016 U.S. District Court, Northern District, Eastern Division 7 Fountas v Oak Forest and DCFS 14CV03174 3/25/2014 U.S. District Court, Northern District, Eastern Division 1 82 Appendix C LAWSUITS FILED OR SETTLED FY15-FY17 (Continued) Summary Plaintiff alleged the Department violated her civil rights to unreasonable seizure, to substantive due process, and procedural due process when her children were removed. Plaintiff alleged violation of the personal integrity, associational, and property rights of the mother; due process rights as to familial association; and deprivation of her liberty interest in directing medical and psychological care for children and herself. Plaintiff alleged malicious prosecution, unlawful detention, unlawful search and seizure, and excessive detention by the Chicago Police and failure to intervene by DCFS investigator who looked into allegations made against plaintiff. Class action suit alleging DCFS violated the Administrative Procedure Act by using Allegation 60 to indicate abuse after Supreme Court invalidated that rule and before it was re-promulgated as a rule (between July 13, 2012, and December 31, 2013). Plaintiff alleged Department investigator and Peoria Police violated his civil due process rights by withholding exculpatory evidence; fabricating evidence; and failing to intervene to protect his civil rights, and alleged violation of state law including malicious prosecution; false imprisonment; conspiracy; and intentional infliction of emotional distress. Plaintiffs alleged intentional infliction of emotional distress, invasion of privacy, defamation, malicious prosecution, conspiracy, violations of substantive and procedural due process rights, the Fourth Amendment right against unreasonable seizures and searches, and equal protection rights against a hospital, doctors, Cook County employees, and a Department employee. Date Disposed 6/23/2016 Final Disposition Settled Settlement Terms $75,000, amend policies 3/22/2018 Settled $100,000, amend policies 4/5/2018 Dismissed N/A 1/8/2015 Settled $50,000; expunge Allegation 60 findings between 7/13/12 and 12/31/13 Pending but DCFS no longer defendant N/A Dismissed N/A Pending but DCFS no longer defendant N/A 3/16/2018 Plaintiff sued the Department and City of Oak Forest for wrongful death. 83 Appendix C LAWSUITS FILED OR SETTLED FY15-FY17 Count Case Name Harris v Association House of Chicago et al Case Number 14L13330 Date Filed 12/29/2014 9 Hughes v Jones et al 12CV09494 12/12/2012 10 Juan G v Wilson 15CV02452 3/23/2015 11 Kelly K. v DCFS 17CV04703 6/22/2017 U.S. District Court, Northern District, Eastern Division 12 L.W. v DCFS 13CV08463 11/22/2013 U.S. District Court, Northern District, Eastern Division 13 Manier v DCFS 14CH20237 12/18/2014 Circuit Court of Cook County, County Department, Chancery Division 14 Oleszcak v DCFS 17CV00933 2/8/2017 15 Nicole P et al v DCFS 16CH12809 9/28/2016 U.S. District Court, Northern District, Eastern Division Circuit Court of Cook County, County Department, Chancery Division 8 84 Court Circuit Court of Cook County, County Department, Law Division U.S. District Court, Northern District, Eastern Division U.S. District Court, Northern District, Eastern Division Appendix C LAWSUITS FILED OR SETTLED FY15-FY17 (Continued) Summary Public Guardian sued DCFS contractor and relative caregiver for wrongful death and negligence. DCFS is legally required to represent providers. Date Disposed Final Disposition Pending Settlement Terms Plaintiff alleged Department deprived her of her liberty interest and violated both her substantive and procedural due process rights. Plaintiff alleged Department violated his protected liberty interest in chosen career without due process and violated due process rights in its investigatory and hearing processes. Plaintiff alleged Department and contractor violated her fundamental right to familial association as well as her substantive and procedural due process rights. She also alleged violation of the A.B. v. Holliman settlement agreement regarding victims of domestic violence. Plaintiff alleged violations of the Fourth Amendment right not to be subject to unreasonable seizure, her procedural and substantive due process rights related to familial association, rights related to liberty interest in career opportunity, and Title II of the Americans with Disabilities Act for discrimination based on perceived disability. This case challenged Allegation 74 (inadequate supervision). Plaintiff was indicated after investigation and sued for reversal of decision to indicate. 9/29/2014 Settled $63,000 4/25/2017 Settled $85,000 Pending 6/27/2016 Settled 8/28/2015 DCFS Decision Reversed - Court ruled Allegation 74 was unlawful as it is outside the scope of ANCRA. Plaintiff alleged violation of liberty interests of custodial care and due process rights. This is a class action suit brought by plaintiffs who had been indicated under Allegation 74 (inadequate supervision), which had been declared void by the court in Manier v. DCFS on 8/28/15, that DCFS had not expunged its records or repromulgate rules for Allegation 74. $150,000, amend policies Pending 6/4/2018 85 Settled DCFS to allow special reviews of Allegation 74 findings indicated between 8/28/15 and 5/9/17. Appendix C LAWSUITS FILED OR SETTLED FY15-FY17 Count Case Name Jessica R and Claudia G v Department of Children and Family Services et al Case Number 15CH4487 Date Filed 5/29/2015 Court Circuit Court of Cook County, County Department, Chancery Division 17 Roberson v Village of Sauk Village 14CV08174 10/17/2014 U.S. District Court, Northern District, Eastern Division 18 S.B.T v Miller et al 15CV00162 2/13/2015 U.S. District Court, Southern District, East St. Louis Division 19 Sebesta v Davis, et al 12CV07834 9/28/2012 20 Traharne et al v DCFS et al 15CV11133 12/10/2015 U.S. District Court, Northern District, Eastern Division U.S. District Court, Northern District, Eastern Division 21 Tyagi et al v Sheldon et al 16CV11236 12/9/2016 U.S. District Court, Northern District, Eastern Division 22 Van Dyke v DCFS et al 13CV05971 8/22/2013 U.S. District Court, Northern District, Eastern Division 16 86 Appendix C LAWSUITS FILED OR SETTLED FY15-FY17 (Continued) Summary Case was originally Etonia C. v DCFS, but other plaintiffs were added. Plaintiffs challenged the Allegation 60 (environment injurious) emergency rule made 1/1/14 and expiring 5/31/14 claiming DCFS improperly invoked emergency rulemaking authority because there was no emergency. Date Disposed 11/22/2016 Final Disposition Settled Settlement Terms DCFS agreed to expunge all persons indicated between January 1, 2014, and May 31, 2014. Plaintiff alleged Department and Sauk Village officials violated her protected liberty interest of chosen career, substantive and procedural due process rights, and her Fourth Amendment right to be free from unreasonable seizure, as well as malicious prosecution, intentional infliction of emotional distress, and conspiracy. 3/30/2016 Dismissed N/A Plaintiff alleged Department violated her liberty interest in pursuing her career and rights to due process. She also alleged that the allegation indicated (Allegation 60) was void. Plaintiff alleged violation of substantive due process, invasion of privacy, and intentional infliction of emotional distress. 8/21/2017 Settled $60,000 1/20/2016 Dismissed N/A Plaintiffs alleged violation of Fourth Amendment right against unlawful seizure, substantive due process rights to familial rights and association, and procedural due process rights for removing children. Plaintiffs alleged violation of First Amendment rights to free exercise of religion, Fourth Amendment rights to unlawful search and seizure, and due process and equal protection rights guaranteed by the Fourteenth Amendment among others. Plaintiff alleged violation of First Amendment right to free speech, Fourth Amendment right to be free from unlawful search, and Fourteenth Amendment regarding due process. Pending Pending Pending but DCFS defendant dismissed 87 N/A Appendix C LAWSUITS FILED OR SETTLED FY15-FY17 Count 23 Case Name W.M. v Giscombe et al Case Number 15CV00305 Source: OAG analysis of information provided by DCFS legal counsel. 88 Date Filed 1/13/2015 Court U.S. District Court, Northern District, Eastern Division Appendix C LAWSUITS FILED OR SETTLED FY15-FY17 (Continued) Summary Plaintiff alleged violation of Fourth Amendment right against unreasonable seizure, substantive due process rights to familial association, and procedural due process rights. Date Disposed 6/20/2016 Final Disposition Settled Source: OAG analysis of information provided by DCFS legal counsel. 89 Settlement Terms $93,000, amend policies 9O APPENDIX INTACT FAMILY SERVICES PROVIDER CONTRACTS FY15-FY17 91 92 APPENDIX D INTACT FAMILY SERVICES PROVIDER CONTRACTS FY15 Provider Arden Shore Child And Family Services Association House Of Chicago Aunt Marthas Youth Svc Ctr Inc. Baby Fold Bethany For Children And Families Casa Central Social Services Catholic Charities Diocese SPF Catholic Charities/The Arch Of Chicago Center For Youth & Family Solutions Center For Youth & Family Solutions Center For Youth & Family Solutions Childrens Home And Aid Soc Of Illinois Childrens Home And Aid Soc Of Illinois Childrens Home And Aid Soc Of Illinois Childrens Home And Aid Soc Of Illinois Childrens Home And Aid Soc Of Illinois Childrens Home Association Of Illinois Community Youth Network Inc. Evangelical Child And Family Agency Hephzibah Children's Association Kaleidoscope, Inc. Lutheran Child And Family Services IL Lutheran Social Services Of Illinois Lutheran Social Services Of Illinois Lutheran Social Services Of Illinois Lutheran Social Services Of Illinois Lutheran Social Services Of Illinois Omni Youth Services One Hope United-Hudelson Region One Hope United-Hudelson Region One Hope United-Northern Region One Hope United-Northern Region Pioneer Center Rutledge Youth Foundation, Inc. Sinnissippi Centers, Inc. Universal Family Connection Inc. Webster Cantrell Hall Youth Outreach Services Inc. Youth Service Bureau Of Illinois Valley Youth Service Bureau Of Illinois Valley Youth Service Bureau Of Illinois Valley Youth Services Network, Inc. Total Contract Number 0015243135 0280514295 0016673145 0203296105 3105102195 0039064125 0039735105 0039714315 5129612095 5129615015 5129616055 0042361055 0042364245 0042366095 0042367095 1463033025 0042592165 0002923065 0067263035 0094104175 0111264255 0129988085 0130051155 0130051165 0130052045 0130054225 0130058055 0005654055 0100538055 0100535025 0040193155 0040194285 1656493095 0178229025 0968021175 0935184165 0217466015 0698844225 2808991025 2808992235 2808993015 0775759045 Capacity Note: Capacity represents the number of families that can be served, not individuals. Source: OAG analysis of DCFS data. 93 60 90 60 20 30 140 85 140 40 20 120 60 30 20 90 140 60 20 50 10 70 50 10 20 40 80 80 180 70 85 30 110 50 10 30 50 30 20 10 20 30 20 2,380 Expenditures $841,162.16 $913,067.19 $742,627.45 $137,600.26 $357,099.36 $1,784,340.83 $991,194.66 $1,808,769.22 $586,162.70 $327,771.57 $969,752.39 $569,594.14 $370,919.40 $126,497.88 $919,308.51 $1,224,437.59 $773,991.49 $247,113.42 $799,363.45 $215,515.27 $885,719.25 $443,403.94 $137,633.35 $196,389.73 $531,848.68 $798,973.76 $1,025,890.79 $2,219,473.01 $1,040,655.77 $672,723.79 $392,528.25 $1,271,658.32 $623,116.75 $211,736.59 $378,127.16 $633,670.63 $578,811.14 $356,743.06 $121,640.25 $147,805.99 $310,441.13 $209,901.41 $27,895,181.69 APPENDIX D INTACT FAMILY SERVICES PROVIDER CONTRACTS FY16 Provider Arden Shore Child And Family Services Association House Of Chicago Aunt Marthas Youth Svc Ctr, Inc. Baby Fold Bethany For Children And Families Casa Central Social Services Catholic Charities Diocese SPF Catholic Charities/The Arch Of Chicago Center For Youth & Family Solutions Childrens Home And Aid Soc Of Illinois Childrens Home And Aid Soc Of Illinois Childrens Home And Aid Soc Of Illinois Childrens Home And Aid Soc Of Illinois Childrens Home Association Of Illinois Community Youth Network Inc. Evangelical Child And Family Agency Hephzibah Children's Association Kaleidoscope, Inc. Lutheran Child And Family Services IL Lutheran Social Services Of Illinois Lutheran Social Services Of Illinois Lutheran Social Services Of Illinois Lutheran Social Services Of Illinois Omni Youth Services One Hope United-Northern Region One Hope United-Northern Region One Hope United-Hudelson Region One Hope United-Hudelson Region Pioneer Center Rutledge Youth Foundation, Inc. Sinnissippi Centers, Inc. Universal Family Connection Inc. Webster Cantrell Hall Youth Advocate Program Inc. Youth Outreach Services Inc. Youth Service Bureau Of Illinois Valley Youth Service Bureau Of Illinois Valley Youth Services Network, Inc. Total Contract Number 0015243136 0280514296 0016673146 0203296106 3105102196 0039064126 0039735106 0039714316 5129616056 0042364246 0042366096 0042367096 1463033026 0042592166 0002923066 0067263036 0094104176 0111264256 0129988086 0130051166 0130052046 0130054226 0130058056 0005654056 0040193156 0040194286 0100535026 0100538056 1656493096 0178229026 0968021176 0935184166 0217466016 0007292016 0698844226 2808992236 2808993016 0775759046 Capacity 70 70 60 30 30 130 90 120 160 30 10 70 150 60 20 50 30 60 50 30 40 60 70 170 30 90 50 90 50 10 30 50 20 10 30 20 90 20 2,250 Note: Capacity represents the number of families that can be served, not individuals. Source: OAG analysis of DCFS data. 94 Expenditures $908,195.46 $808,960.72 $519,305.65 $118,606.03 $351,415.33 $1,542,923.58 $1,350,569.30 $1,324,850.96 $1,810,026.90 $330,975.30 $104,797.21 $1,093,904.74 $1,918,772.77 $763,059.90 $304,507.62 $682,537.99 $393,329.14 $437,347.56 $443,663.44 $320,687.93 $666,860.60 $719,232.12 $1,303,917.82 $1,882,871.07 $520,880.94 $1,230,979.59 $561,070.75 $1,267,728.74 $466,211.05 $189,201.08 $501,011.79 $555,468.37 $202,074.38 $39,262.85 $282,297.87 $143,559.02 $526,968.79 $220,655.93 $26,808,690.29 APPENDIX D INTACT FAMILY SERVICES PROVIDER CONTRACTS FY17 Provider Arden Shore Child And Family Services Association House Of Chicago Aunt Marthas Youth Svc Ctr Inc. Baby Fold Bethany For Children And Families Casa Central Social Services Catholic Charities Diocese SPF Catholic Charities/ The Arch Of Chicago Center For Youth & Family Solutions Childrens Home And Aid Society Of Illinois Childrens Home And Aid Society Of Illinois Childrens Home And Aid Society Of Illinois Childrens Home And Aid Society Of Illinois Childrens Home Association Of Illinois Community Youth Network Inc. Evangelical Child And Family Agency Hephzibah Children's Association Kaleidoscope, Inc. Lutheran Child And Family Services IL Lutheran Social Services Of Illinois Lutheran Social Services Of Illinois Lutheran Social Services Of Illinois Lutheran Social Services Of Illinois Omni Youth Services One Hope United-Hudelson Region One Hope United-Hudelson Region One Hope United-Northern Region One Hope United-Northern Region Rutledge Youth Foundation, Inc. Sinnissippi Centers, Inc. Universal Family Connection Inc. Webster Cantrell Hall Youth Advocate Program Inc. Youth Outreach Services Inc. Youth Service Bureau Of Illinois Valley Youth Service Bureau Of Illinois Valley Youth Services Network, Inc. Total Contract Number 0015243137 0280514297 0016673147 0203296107 3105102197 0039064127 0039735107 0039714317 5129616057 0042364247 0042366097 0042367097 1463033027 0042592167 0002923067 0067263037 0094104177 0111264257 0129988087 0130051167 0130052047 0130054227 0130058057 0005654057 0100535027 0100538057 0040193157 0040194287 0178229027 0968021177 0935184167 0217466017 0007292017 0698844227 2808992237 2808993017 0775759047 Capacity Note: Capacity represents the number of families that can be served, not individuals. Source: OAG analysis of DCFS data. 95 80 70 80 30 30 130 90 110 150 30 30 80 150 60 20 50 30 60 50 30 60 60 100 160 55 105 40 90 10 50 50 20 10 30 20 90 20 2,330 Expenditures $959,074.62 $787,228.92 $881,402.67 $151,989.89 $388,750.45 $1,534,656.50 $1,335,909.44 $1,408,652.00 $1,722,270.61 $372,407.77 $356,595.13 $1,707,684.22 $2,063,974.42 $934,300.76 $388,561.95 $733,114.45 $399,557.00 $572,684.53 $532,849.76 $558,717.14 $1,002,984.52 $741,028.67 $1,672,598.95 $1,698,655.52 $792,764.25 $1,530,461.21 $491,561.82 $1,166,216.17 $143,892.58 $488,682.44 $592,064.32 $322,916.56 $235,709.93 $330,411.91 $187,514.03 $1,257,272.46 $265,354.48 $30,710,472.05 96 APPENDIX ABUSE AND NEGLECT ALLEGATIONS FY15-FY17 97 98 Appendix E DCFS ABUSE AND NEGLECT ALLEGATION CLASSIFICATIONS Abuse Allegations #1 – Death #2 – Head Injuries #4 – Internal Injuries #5 – Burns #6 – Poison/Noxious Substances #7 – Wounds #9 – Bone Fractures #10 – Substantial Risk of Physical Injury/Environment Injurious to Health and Welfare  10a – Incidents of Violence or Intimidation  10b – Medical Child Abuse (Factitious Disorder by Proxy or Munchausen by Proxy Syndrome) #11 – Cuts, Bruises, Welts, Abrasions and Oral Injuries #12 – Human Bites #13 – Sprains/Dislocations #14 – Tying/Close Confinement #15 – Substance Misuse #16 – Torture #17 – Mental and Emotional Impairment #18 – Sexually Transmitted Diseases #19 – Sexual Penetration #20 – Sexual Exploitation #21 – Sexual Molestation #22 – Substantial Risk of Sexual Injury  22a – Sex offender has access  22b – Sibling of sex abuse victim  22c – Sexualized behavior of young child  22d – Child Pornography  22e – Suggestive Behavior #40 – Human Trafficking of Children Neglect Allegations #51 – Death #52 – Head Injuries #54 – Internal Injuries #55 – Burns #56 – Poison/Noxious Substances #57 – Wounds #59 – Bone Fractures #60 – Substantial Risk of Physical Injury/Environment Injurious to Health and Welfare #61 – Cuts, Bruises, Welts, Abrasions, and Oral Injuries #62 – Human Bites #63 – Sprains/Dislocations #65 – Substance Misuse #67 – Mental and Emotional Impairment #74 – Inadequate Supervision #75 – Abandonment/Desertion #76 – Inadequate Food #77 – Inadequate Shelter #78 – Inadequate Clothing #79 – Medical Neglect #81 – Failure to Thrive (Non-Organic) #82 – Environmental Neglect #83 – Malnutrition (Non-Organic) #84 – Lock-out  84a – Community Location  84b – Psychiatrically Hospitalized  84c – Correctional Facility #85 – Medical Neglect of Disabled Infants #86 – Neglect by Agency #90 – Human Trafficking of Children Note: Death & Serious Harm allegations are highlighted in red. Source: DCFS Procedures 300 Appendix B & DCFS Child Protective Services Statistics. 99 100 Appendix E DCFS ABUSE AND NEGLECT ALLEGATIONS BY TYPE FY15 Allegations 60- Substantial Risk of Physical Injury by Neglect 74- Inadequate Supervision 10- Substantial Risk of Physical Injury by Abuse 11- Cuts, Bruises, Welts, Abrasions, and Oral Injuries 82- Environmental Neglect 22b- Substantial Risk of Sexual Abuse- Sibling of sex abuse victim 21- Sexual Molestation 79- Medical Neglect 22a- Substantial Risk of Sexual Abuse- Sex offender has access 19- Sexual Penetration 77- Inadequate Shelter 76- Inadequate Food 61- Cuts, Bruises, Welts, Abrasions, and Oral Injuries by Neglect 20- Sexual Exploitation 15- Substance Misuse 84- Lock-Out 65- Substance Misuse by Neglect 78- Inadequate Clothing 55- Burns by Neglect 22c- Substantial Risk of Sexual Abuse- Sexualized behavior of young child 5- Burns 9- Bone Fractures 14- Tying/Close Confinement 17- Mental and Emotional Impairment by Abuse 59- Bone Fractures by Neglect 12- Human Bites 2- Head Injuries 22d- Substantial Risk of Sexual Abuse- Child Pornography 67- Mental Injury by Neglect 52- Head Injuries by Neglect 75- Abandonment/Desertion 81- Failure to Thrive 16- Torture 40- Human Trafficking of Children 51- Death by Neglect 6- Poison/Noxious Substances 18- Sexually Transmitted Diseases 56- Poison/Noxious Substances by Neglect 62- Human Bites by Neglect 4- Internal Injuries 13- Sprains/Dislocations 1- Death 101 Indicated 14,934 6,497 3,962 2,423 Unfounded 20,390 16,814 13,577 9,824 Total 35,324 23,311 17,539 12,247 1,948 1,709 8,244 3,798 10,192 5,507 1,230 681 1,018 2,988 3,128 2,758 4,218 3,809 3,776 1,172 469 169 314 2,108 2,173 2,433 1,084 3,280 2,642 2,602 1,398 359 195 133 567 34 105 36 1,010 1,026 1,050 445 480 392 442 1,369 1,221 1,183 1,012 514 497 478 55 149 52 23 76 75 93 96 416 278 288 302 182 179 108 99 471 427 340 325 258 254 201 195 6 47 74 87 27 26 46 4 44 18 12 18 9 19 183 123 93 59 98 97 74 110 53 71 62 22 29 16 189 170 167 146 125 123 120 114 97 89 74 40 38 35 Percent Indicated 42.3% 27.9% 22.6% 19.8% 19.1% 31.0% 29.2% 17.9% 27.0% 35.7% 17.8% 6.5% 22.5% 26.2% 16.0% 11.2% 56.0% 6.6% 21.1% 7.5% 11.7% 34.9% 15.3% 7.1% 29.5% 29.5% 46.3% 49.2% 3.2% 27.6% 44.3% 59.6% 21.6% 21.1% 38.3% 3.5% 45.4% 20.2% 16.2% 45.0% 23.7% 54.3% Appendix E DCFS ABUSE AND NEGLECT ALLEGATIONS BY TYPE FY15 (Continued) Allegations 7- Wounds 83- Malnutrition 57- Wounds by Neglect 54- Internal Injuries by Neglect 90- Human Trafficking of Children by Neglect 85- Medical Neglect of Disabled Infants 63- Sprains/Dislocations by Neglect 22e- Substantial Risk of Sexual Abuse- Suggestive Behavior 86- Neglect by Agency Total Source: OAG analysis of DCFS data as of July 27, 2018. 102 Indicated 16 22 11 9 1 4 2 0 Unfounded 19 13 20 18 22 6 4 0 Total 35 35 31 27 23 10 6 0 Percent Indicated 45.7% 62.9% 35.5% 33.3% 4.3% 40.0% 33.3% 0.0% 0 39,076 0 97,208 0 136,284 0.0% 28.7% Appendix E DCFS ABUSE AND NEGLECT ALLEGATIONS BY TYPE FY16 Allegation 60- Substantial Risk of Physical Injury by Neglect 74- Inadequate Supervision 10- Substantial Risk of Physical Injury by Abuse 11- Cuts, Bruises, Welts, Abrasions, and Oral Injuries 82- Environmental Neglect 22b- Substantial Risk of Sexual Abuse- Sibling of sex abuse victim 21- Sexual Molestation 79- Medical Neglect 22a- Substantial Risk of Sexual Abuse- Sex offender has access 19- Sexual Penetration 76- Inadequate Food 77- Inadequate Shelter 20- Sexual Exploitation 61- Cuts, Bruises, Welts, Abrasions, and Oral Injuries by Neglect 15- Substance Misuse 84- Lock-Out 65- Substance Misuse by Neglect 17- Mental Injury 55- Burns by Neglect 22c- Substantial Risk of Sexual Abuse- Sexualized behavior of young child 78- Inadequate Clothing 14- Tying/Close Confinement 5- Burns 9- Bone Fractures 59- Bone Fractures by Neglect 12- Human Bites 22d- Substantial Risk of Sexual Abuse- Child Pornography 51- Death by Neglect 2- Head Injuries 75- Abandonment/Desertion 40- Human Trafficking of Children 16- Torture 52- Head Injuries by Neglect 81- Failure to Thrive 67- Mental Injury by Neglect 103 Indicated 14,549 6,249 4,233 2,212 Unfounded 28,981 20,402 19,509 10,827 Total 43,530 26,651 23,742 13,039 Percent Indicated 33.4% 23.4% 17.8% 17.0% 1,819 1,600 9,160 4,474 10,979 6,074 16.6% 26.3% 1,245 637 863 3,497 3,991 3,023 4,742 4,628 3,886 26.3% 13.8% 22.2% 1,047 108 420 399 249 2,324 2,701 2,154 1,348 1,383 3,371 2,809 2,574 1,747 1,632 31.1% 3.8% 16.3% 22.8% 15.3% 183 125 644 18 85 19 1,295 1,181 596 861 458 517 1,478 1,306 1,240 879 543 536 12.4% 9.6% 51.9% 2.0% 15.7% 3.5% 33 51 54 145 42 66 99 464 413 391 244 229 202 164 497 464 445 389 271 268 263 6.6% 11.0% 12.1% 37.3% 15.5% 24.6% 37.6% 50 95 73 37 20 42 89 10 174 122 143 175 183 145 97 166 224 217 216 212 203 187 186 176 22.3% 43.8% 33.8% 17.5% 9.9% 22.5% 47.8% 5.7% Appendix E DCFS ABUSE AND NEGLECT ALLEGATIONS BY TYPE FY16 (Continued) Allegation 6- Poison/Noxious Substances 22e- Substantial Risk of Sexual Abuse- Suggestive Behavior 56- Poison/Noxious Substances by Neglect 18- Sexually Transmitted Diseases 62- Human Bites by Neglect 83- Malnutrition 1- Death 13- Sprains/Dislocations 7- Wounds 57- Wounds by Neglect 4- Internal Injuries 90- Human Trafficking of Children by Neglect 54- Internal Injuries by Neglect 63- Sprains/Dislocations by Neglect 86- Neglect by Agency 85- Medical Neglect of Disabled Infants Total Source: OAG analysis of DCFS data as of July 27, 2018. 104 Indicated 24 37 Unfounded 148 80 Total 172 117 Percent Indicated 14.0% 31.6% 12 33 17 11 26 5 19 12 17 2 6 2 1 4 37,838 90 59 49 48 29 48 30 26 18 27 14 16 15 11 122,702 102 92 66 59 55 53 49 38 35 29 20 18 16 15 160,540 11.8% 35.9% 25.8% 18.6% 47.3% 9.4% 38.8% 31.6% 48.6% 6.9% 30.0% 11.1% 6.3% 26.7% 23.6% Appendix E DCFS ABUSE AND NEGLECT ALLEGATIONS BY TYPE FY17 Allegation 60- Substantial Risk of Physical Injury by Neglect 74- Inadequate Supervision 10- Substantial Risk of Physical Injury by Abuse 11- Cuts, Bruises, Welts, Abrasions, and Oral Injuries 82- Environmental Neglect 22b- Substantial Risk of Sexual Abuse- Sibling of sex abuse victim 21- Sexual Molestation 79- Medical Neglect 22a- Substantial Risk of Sexual Abuse- Sex offender has access 19- Sexual Penetration 76- Inadequate Food 77- Inadequate Shelter 20- Sexual Exploitation 61- Cuts, Bruises, Welts, Abrasions, and Oral Injuries by Neglect 84- Lock-Out 65- Substance Misuse by Neglect 15- Substance Misuse 17- Mental Injury 78- Inadequate Clothing 55- Burns by Neglect 14- Tying/Close Confinement 5- Burns 22c- Substantial Risk of Sexual Abuse- Sexualized behavior of young child 9- Bone Fractures 22e- Substantial Risk of Sexual Abuse- Suggestive Behavior 75- Abandonment/Desertion 12- Human Bites 59- Bone Fractures by Neglect 2- Head Injuries 51- Death by Neglect 40- Human Trafficking of Children 81- Failure to Thrive 52- Head Injuries by Neglect 22d- Substantial Risk of Sexual Abuse- Child Pornography 16- Torture 6- Poison/Noxious Substances 105 Indicated 15,508 5,836 3,414 2,213 Unfounded 28,657 18,744 17,502 10,277 Total 44,165 24,580 20,916 12,490 Percent Indicated 35.1% 23.7% 16.3% 17.7% 1,880 1,568 9,071 4,459 10,951 6,027 17.2% 26.0% 1,220 647 763 3,345 3,777 2,543 4,565 4,424 3,306 26.7% 14.6% 23.1% 998 161 430 373 240 2,112 2,566 1,945 1,174 1,178 3,110 2,727 2,375 1,547 1,418 32.1% 5.9% 18.1% 24.1% 16.9% 147 786 178 47 33 77 67 47 35 1,208 554 1,160 899 488 397 404 407 377 1,355 1,340 1,338 946 521 474 471 454 412 10.8% 58.7% 13.3% 5.0% 6.3% 16.2% 14.2% 10.4% 8.5% 133 89 271 302 404 391 32.9% 22.8% 90 75 60 98 63 45 94 40 76 157 171 176 126 158 171 99 149 81 247 246 236 224 221 216 193 189 157 36.4% 30.5% 25.4% 43.8% 28.5% 20.8% 48.7% 21.2% 48.4% 13 17 143 112 156 129 8.3% 13.2% Appendix E DCFS ABUSE AND NEGLECT ALLEGATIONS BY TYPE FY17 (Continued) Allegation 67- Mental Injury by Neglect 56- Poison/Noxious Substances by Neglect 18- Sexually Transmitted Diseases 83- Malnutrition 86- Neglect by Agency 62- Human Bites by Neglect 1- Death 13- Sprains/Dislocations 7- Wounds 57- Wounds by Neglect 4- Internal Injuries 90- Human Trafficking of Children by Neglect 54- Internal Injuries by Neglect 63- Sprains/Dislocations by Neglect 85- Medical Neglect of Disabled Infants Total Indicated 3 21 35 21 15 8 18 9 14 13 16 1 2 1 1 37,739 Unfounded 114 82 43 47 47 50 33 41 32 20 11 21 8 7 4 115,920 Total 117 103 78 68 62 58 51 50 46 33 27 22 10 8 5 153,659 Percent Indicated 2.6% 20.4% 44.9% 30.9% 24.2% 13.8% 35.3% 18.0% 30.4% 39.4% 59.3% 4.5% 20.0% 12.5% 20.0% 24.6% Source: OAG analysis of DCFS data as of July 27, 2018. Appendix E SPECIAL TYPES OF VICTIMS FY15-FY17 Special Type Sexual Abuse Death & Serious Harm Substance Exposed Infants Human Trafficking Human Trafficking Involving Sexual Abuse FY15 All Indicated 16,805 4,779 FY16 All Indicated 18,442 4,473 FY17 All Indicated 17,255 4,273 Total All Indicated 52,502 13,525 10,202 2,810 11,492 2,702 10,745 2,623 32,439 8,135 701 540 809 619 914 733 2,424 1,892 143 27 238 39 233 46 614 112 32 12 50 17 43 18 125 47 Source: OAG analysis of DCFS data as of July 27, 2018. 106 APPENDIX F VICTIM DEMOGRAPHIC INFORMATION AGE, RACE, ETHNICITY, AND GENDER FY15-FY17 Auditor Note: Data provided by the Department included the total number of alleged victims involved in an investigation during the three-year audit period. Since victims can be reported multiple times, numbers presented are not an unduplicated count. 107 108 Appendix F ALLEGED VICTIMS BY AGE FY15-FY17 Age 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18+ Unknown Total FY15 Count Percent 9,032 8.20% 6,620 6.01% 6,699 6.08% 6,829 6.20% 6,910 6.27% 7,186 6.52% 7,396 6.72% 7,181 6.52% 6,518 5.92% 6,181 5.61% 5,500 4.99% 5,388 4.89% 5,301 4.81% 5,191 4.71% 5,211 4.73% 4,772 4.33% 4,315 3.92% 3,177 2.88% 164 0.15% 565 0.51% 110,136 100% FY16 Count Percent 10,174 7.99% 7,640 6.00% 7,643 6.00% 7,524 5.91% 7,419 5.83% 7,999 6.28% 7,911 6.21% 8,034 6.31% 7,793 6.12% 7,189 5.65% 6,652 5.23% 6,471 5.08% 6,331 4.97% 6,067 4.77% 5,959 4.68% 6,081 4.78% 5,411 4.25% 3,992 3.14% 175 0.14% 826 0.65% 127,291 100% Note: Totals may not add to 100% due to rounding. Source: OAG analysis of DCFS data as of July 27, 2018. 109 FY17 Count Percent 9,755 8.05% 7,393 6.10% 7,204 5.95% 7,144 5.90% 7,035 5.81% 7,252 5.99% 7,460 6.16% 7,472 6.17% 7,125 5.88% 7,069 5.84% 6,575 5.43% 6,104 5.04% 5,980 4.94% 5,940 4.90% 5,966 4.93% 5,634 4.65% 5,257 4.34% 3,908 3.23% 160 0.13% 685 0.57% 121,118 100% Total Count Percent 28,961 8.08% 21,653 6.04% 21,546 6.01% 21,497 6.00% 21,364 5.96% 22,437 6.26% 22,767 6.35% 22,687 6.33% 21,436 5.98% 20,439 5.70% 18,727 5.22% 17,963 5.01% 17,612 4.91% 17,198 4.80% 17,136 4.78% 16,487 4.60% 14,983 4.18% 11,077 3.09% 499 0.14% 2,076 0.58% 358,545 100% Appendix F INDICATED VICTIMS BY AGE FY15-FY17 Age 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18+ Unknown Total FY15 Count Percent 4,315 13.08% 2,600 7.88% 2,374 7.20% 2,310 7.00% 2,169 6.57% 2,124 6.44% 2,107 6.39% 2,010 6.09% 1,752 5.31% 1,777 5.39% 1,486 4.50% 1,460 4.42% 1,358 4.12% 1,262 3.82% 1,242 3.76% 1,062 3.22% 947 2.87% 604 1.83% 17 0.05% 19 0.06% 32,995 100% FY16 Count Percent 4,278 13.38% 2,566 8.03% 2,430 7.60% 2,237 7.00% 2,117 6.62% 1,979 6.19% 1,922 6.01% 1,816 5.68% 1,855 5.80% 1,649 5.16% 1,498 4.69% 1,390 4.35% 1,333 4.17% 1,202 3.76% 1,110 3.47% 1,043 3.26% 889 2.78% 623 1.95% 14 0.04% 20 0.06% 31,971 100% Note: Totals may not add to 100% due to rounding. Source: OAG analysis of DCFS data as of July 27, 2018. 110 FY17 Count Percent 4,260 13.48% 2,574 8.14% 2,319 7.34% 2,204 6.97% 1,974 6.24% 1,953 6.18% 1,838 5.81% 1,804 5.71% 1,698 5.37% 1,733 5.48% 1,495 4.73% 1,408 4.45% 1,317 4.17% 1,214 3.84% 1,134 3.59% 1,128 3.57% 913 2.89% 627 1.98% 6 0.02% 11 0.03% 31,610 100% Total Count Percent 12,853 13.31% 7,740 8.01% 7,123 7.38% 6,751 6.99% 6,260 6.48% 6,056 6.27% 5,867 6.08% 5,630 5.83% 5,305 5.49% 5,159 5.34% 4,479 4.64% 4,258 4.41% 4,008 4.15% 3,678 3.81% 3,486 3.61% 3,233 3.35% 2,749 2.85% 1,854 1.92% 37 0.04% 50 0.05% 96,576 100% Appendix F ALLEGED VICTIMS BY RACE FY15-FY17 Race White Black/AfricanAmerican Asian Native American/ Alaska Native Native Hawaiian/ Other Pacific Islander Unknown2 Total1 FY15 Count Percent 67,669 61.44% 38,113 34.61% FY16 Count Percent 80,361 63.13% 42,588 33.46% FY17 Count Percent 76,050 62.79% 40,893 33.76% Total1 Count Percent 224,080 62.50% 121,594 33.91% 1,158 160 1.05% 0.15% 1,430 185 1.12% 0.15% 1,373 143 1.13% 0.12% 3,961 488 1.10% 0.14% 100 0.09% 96 0.08% 95 0.08% 291 0.08% 2,936 110,136 2.67% 100% 2,631 127,291 2.07% 100% 2,564 121,118 2.12% 100% 8,131 358,545 2.27% 100% Notes: 1 Totals may not add to 100% due to rounding. 2 Unknown includes the categories of Unknown, Not Reported, Could not be verified, Declined to Identify, and NULL. Source: OAG analysis of DCFS data as of July 27, 2018. Appendix F INDICATED VICTIMS BY RACE FY15-FY17 Race White Black/AfricanAmerican Asian Native American/ Alaska Native Native Hawaiian/ Other Pacific Islander Unknown2 Total1 FY15 Count Percent 20,023 60.68% 11,795 35.75% FY16 Count Percent 20,341 63.62% 10,789 33.75% FY17 Count Percent 19,864 62.84% 10,915 34.53% Total1 Count Percent 60,228 62.36% 33,499 34.69% 303 68 0.92% 0.21% 262 40 0.82% 0.13% 268 38 0.85% 0.12% 833 146 0.86% 0.15% 23 0.07% 21 0.07% 25 0.08% 69 0.07% 783 32,995 2.37% 100% 518 31,971 1.62% 100% 500 31,610 1.58% 100% 1,801 96,576 1.87% 100% Notes: 1 Totals may not add to 100% due to rounding. 2 Unknown includes the categories of Unknown, Not Reported, Could not be verified, Declined to Identify, and NULL. Source: OAG analysis of DCFS data as of July 27, 2018. 111 Appendix F ALLEGED VICTIMS BY ETHNICITY FY15-FY17 Ethnicity Not Hispanic Hispanic2 Not Reported Unknown3 Total1 FY15 Count Percent 66,420 60.31% 16,584 15.06% 21,006 19.07% 6,126 5.56% 110,136 100% FY16 Count Percent 87,771 68.95% 20,158 15.84% 9,516 7.48% 9,846 7.74% 127,291 100% FY17 Count Percent 86,959 71.80% 19,321 15.95% 7,154 5.91% 7,684 6.34% 121,118 100% Total1 Count Percent 241,150 67.26% 56,063 15.64% 37,676 10.51% 23,656 6.60% 358,545 100% Notes: 1 Totals may not add to 100% due to rounding. 2 DCFS divides Hispanic into Central American, Cuban, Dominican, Mexican, Other, Puerto Rican, South American, and Spanish Descent. 3 Unknown includes the categories of Unknown, Could not be verified, Declined to Identify, and NULL. Source: OAG analysis of DCFS data as of July 27, 2018. Appendix F INDICATED VICTIMS BY ETHNICITY FY15-FY17 Ethnicity Not Hispanic Hispanic2 Not Reported Unknown3 Total1 FY15 Count Percent 19,402 58.80% 5,484 16.62% 6,381 19.34% 1,728 5.24% 32,995 100% FY16 Count Percent 21,601 67.56% 5,462 17.08% 2,395 7.49% 2,513 7.86% 31,971 100% FY17 Count Percent 22,670 71.72% 5,178 16.38% 1,856 5.87% 1,906 6.03% 31,610 100% Total1 Count Percent 63,673 65.93% 16,124 16.70% 10,632 11.01% 6,147 6.36% 96,576 100% Notes: 1 Totals may not add to 100% due to rounding. 2 DCFS divides Hispanic into Central American, Cuban, Dominican, Mexican, Other, Puerto Rican, South American, and Spanish Descent. 3 Unknown includes the categories of Unknown, Could not be verified, Declined to Identify, and NULL. Source: OAG analysis of DCFS data as of July 27, 2018. 112 Appendix F ALLEGED VICTIMS BY GENDER FY15-FY17 Gender Male Female Unknown2 Total1 FY15 Count Percent 54,814 49.77% 54,509 49.49% 813 0.74% 110,136 100% FY16 Count Percent 63,100 49.57% 63,310 49.74% 881 0.69% 127,291 100% FY17 Count Percent 60,359 49.83% 59,961 49.51% 798 0.66% 121,118 100% Total1 Count Percent 178,273 49.72% 177,780 49.58% 2,492 0.70% 358,545 100% Notes: 1 Totals may not add to 100% due to rounding. 2 Unknown includes the categories of Unknown and NULL. Source: OAG analysis of DCFS data as of July 27, 2018. Appendix F INDICATED VICTIMS BY GENDER FY15-FY17 Gender Male Female Unknown2 Total1 FY15 Count Percent 16,271 49.31% 16,590 50.28% 134 0.41% 32,995 100% FY16 Count Percent 15,736 49.22% 16,112 50.40% 123 0.38% 31,971 100% Notes: 1 Totals may not add to 100% due to rounding. 2 Unknown includes the categories of Unknown and NULL. Source: OAG analysis of DCFS data as of July 27, 2018. 113 FY17 Count Percent 15,660 49.54% 15,832 50.09% 118 0.37% 31,610 100% Total1 Count Percent 47,667 49.36% 48,534 50.25% 375 0.39% 96,576 100% 114 APPENDIX INVESTIGATIONS BY COUNTY FY15-FY17 115 116 Appendix G INVESTIGATIONS BY COUNTY FY15-FY17 County Cook Region Cook FY15 18,015 FY16 20,048 FY17 18,479 Total 56,542 Lake Northern 2,679 3,290 3,109 9,078 Winnebago Northern 2,565 2,776 2,478 7,819 Will Northern 2,351 2,794 2,486 7,631 DuPage Northern 2,235 2,677 2,414 7,326 Kane Northern 2,170 2,573 2,474 7,217 Sangamon Central 1,907 2,108 1,954 5,969 St. Clair Southern 1,750 2,008 1,980 5,738 Peoria Central 1,607 1,809 1,629 5,045 Madison Southern 1,434 1,581 1,756 4,771 McHenry Northern 1,236 1,460 1,434 4,130 Champaign Central 1,258 1,363 1,303 3,924 Rock Island Central 1,161 1,323 1,273 3,757 McLean Central 958 1,135 1,078 3,171 Macon Central 966 1,119 1,051 3,136 Vermilion Central 874 1,041 1,007 2,922 LaSalle Central 878 1,018 938 2,834 Tazewell Central 820 992 1,004 2,816 Adams Central 675 761 737 2,173 Williamson Southern 599 617 686 1,902 Kankakee Northern 567 659 635 1,861 DeKalb Northern 568 681 602 1,851 Jefferson Southern 453 565 503 1,521 Whiteside Northern 485 509 474 1,468 Coles Central 410 506 531 1,447 Knox Central 407 450 440 1,297 Jackson Southern 404 454 433 1,291 Kendall Northern 407 460 411 1,278 Henry Central 372 456 407 1,235 Marion Southern 394 400 413 1,207 Macoupin Central 387 432 385 1,204 Stephenson Northern 302 411 452 1,165 Franklin Southern 323 389 434 1,146 Morgan Central 271 384 360 1,015 Ogle Northern 315 317 297 929 Fulton Central 314 337 271 922 Livingston Central 252 317 296 865 117 Appendix G INVESTIGATIONS BY COUNTY FY15-FY17 (Continued) County Region FY15 FY16 FY17 Total Saline Southern 251 312 265 828 Christian Central 220 281 278 779 Boone Northern 232 258 288 778 Logan Central 241 287 217 745 Lee Northern 236 254 218 708 McDonough Central 201 266 231 698 Grundy Northern 208 238 247 693 Montgomery Central 196 245 230 671 Randolph Southern 182 251 201 634 Effingham Southern 195 248 183 626 Bureau Central 170 214 239 623 Edgar Central 230 184 208 622 Iroquois Central 188 192 174 554 Fayette Southern 162 151 177 490 Crawford Southern 173 132 172 477 Clinton Southern 133 168 156 457 Pike Central 141 176 140 457 Hancock Central 125 159 171 455 Union Southern 134 166 149 449 Woodford Central 133 156 160 449 White Southern 106 172 160 438 DeWitt Central 129 175 131 435 Jersey Central 120 146 162 428 Clark Central 141 132 144 417 Richland Southern 167 143 107 417 Mason Central 126 132 142 400 Ford Central 139 132 124 395 Warren Central 126 129 138 393 Perry Southern 112 130 148 390 Wabash Southern 122 146 121 389 Jo Daviess Northern 123 125 135 383 Shelby Central 127 142 108 377 Lawrence Southern 120 135 120 375 Massac Southern 137 133 88 358 Wayne Southern 108 118 124 350 Clay Southern 123 108 106 337 Mercer Central 84 112 118 314 118 Appendix G INVESTIGATIONS BY COUNTY FY15-FY17 (Continued) County Region FY15 FY16 FY17 Total Monroe Southern 73 126 115 314 Douglas Central 92 127 88 307 Carroll Northern 88 102 114 304 Cass Central 89 92 112 293 Greene Central 93 98 97 288 Bond Southern 91 93 100 284 Marshall Central 84 64 100 248 Piatt Central 95 81 70 246 Menard Central 68 93 84 245 Alexander Southern 77 74 77 228 Cumberland Central 65 63 92 220 Washington Southern 60 60 76 196 Henderson Central 46 62 72 180 Hamilton Southern 62 56 59 177 Gallatin Southern 51 63 57 171 Jasper Southern 48 47 59 154 Johnson Southern 59 52 41 152 Pulaski Southern 44 59 43 146 Moultrie Central 61 41 39 141 Edwards Southern 35 53 52 140 Schuyler Central 31 43 46 120 Stark Central 31 27 45 103 Hardin Southern 26 27 34 87 Brown Central 18 30 39 87 Scott Central 20 22 27 69 Putnam Central 22 20 23 65 Pope Southern 21 19 10 50 Calhoun Central 14 14 14 42 NULL (Blank) N/A 7,488 9,930 10,303 27,721 Out of State N/A 50 66 55 171 67,732 78,572 75,037 221,341 Total Source: OAG analysis of DCFS data as of July 27, 2018. 119 120 APPENDIX AGENCY RESPONSES 121 122 Illinois Department of Pritzker I Marc D. Smith Governor Children FamIIy serVices Acting Director April 23, 2019 Michael Paoni Audit Manager Illinois Of?ce of the Auditor General 740 Ash Street Spring?eld, IL 62703 Dear Mr. Paoni: Enclosed with this letter are the DCFS responses to the audit recommendations. We hope that the recommendations meet your requirements and look forward to being of service in your future needs. Ifyou have any questions, however, please feel free to contact us. Sincerely, SIGNED ORIGINAL ON FILE Marc D. Smith Acting Director Office of the Director 100 West Randolph, Suite 6-100 0 Chicago, Illinois 60601-3249 312-814-6800 I 312-814-2074 TTY CHILD ABUSE AND NEGLECT DATA RECOMMENDATION 1 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should continue to take steps to improve the quality of the data contained in its child abuse and neglect information systems and statistical reports. These steps should include:  Ensuring that proper controls are in place for SACWIS data entry, or any future child abuse and neglect information systems, in order to ensure that data is collected and is reliable; and  Maintaining updated manuals including data field definitions. The Department – The Department agrees with the recommendation. Steps to improve the quality of the Child Abuse and Neglect Data have been taken: Current Steps In Action:  Several SACWIS releases have release improvements to data quality.  Data Field definitions are being assembled into a Data Dictionary. Planned Steps:  Project is being sourced to execute soon to execute data cleanup on Child Abuse and Neglect Data  CCWIS program will replace current systems offering more advanced data validation capabilities  CCWIS requires a Data Quality plan which will address data quality controls throughout the lifecycle of Child Abuse and Neglect date 124 INVESTIGATOR ASSIGNMENTS RECOMMENDATION 2 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should take steps to ensure investigator assignments are in compliance with the requirements of the B.H. Consent Decree. The Department The Department of Children and Family Services (“Department”) has taken steps to ensure that investigator assignments are in compliance with the requirements of B.H. Consent Decree. The Department has established internal monthly meetings with the Regional Administrators from the Operations Division and the Office of Legal Services to review caseloads in order to maintain compliance with the B.H. Consent Decree. The Department meets with the plaintiff’s in the B.H. case monthly to discuss caseloads. The Department provides a monthly report to the B.H. plaintiffs on caseloads. The Department has created DAI positions to assure adequate staffing for investigations. 125 CHILD ENDANGERMENT RISK ASSESSMENT PROTOCOL RECOMMENDATION 3 The Department of Children and Family Services should:    DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE Ensure that CERAPs are completed for investigations and that they are completed in a timely manner; Ensure that CERAPs are completed and that they are completed in a timely manner when Intact Family Services are provided; and Evaluate the reliability and validity of the CERAP annually and develop written procedures related to CERAP training as is required by the Children and Family Services Act. The Department has management reports in place for both intact and investigations that identify activity regarding cerap completion. Supervisors will be trained on the reports and reminded of the need to ensure CERAPS are completed within procedure timeframes. This will be completed within the next 90 days. The Cerap Citizen Advisory group will ensure their ongoing research projects address validity and reliability as defined by the auditors; the next project is due by May 2020. Written procedures related to Cerap training will be enhanced to reflect the requirements of the Children and Family Services Act by October 2019. A random selection of cases will be reviewed quarterly by the Compliance Administrator to address timely completion 126 HOTLINE AND INTAKE RECOMMENDATION 4 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should:  Develop formal written procedures for call backs including required timeframes for creating intakes;  Ensure that the process for completing call backs is in accordance with written procedures by answering and returning hotline calls in a timely manner;  Begin maintaining complete information regarding the time it takes to return the hotline calls of those reporting allegations of child abuse or neglect for an amount of time that would allow for long-term analysis; and  Continue to increase the utilization of online reporting as appropriate. The Department has recently developed written procedures for call backs and training is provided to all call floor staff during new hire training. April 2019 all staff were provided an in -service training on managing call backs. The intake is created through call back once the caller is confirmed available to talk by the hotline worker. If the call is an in call the intake is created at the time call begins. A specialized Call Back Attempts Response Time report is received daily and weekly. The specialized report is monitored by the SCR administrator and Assistant SCR administrator for call back response times which exceed the weekly average response time. The call backs are reviewed to determine the reason for longer than average response time. The hotline currently tracks daily, weekly, monthly and yearly the message taking rate and the call back response time. The State Central Register implemented approximately 18 months ago shift strategies which are communicated to call floor staff about the managing call backs and in calls. Approximately 12 months ago an additional category “Urgent”, was added to the call back log to assist supervisors and call floor worker to prioritize the call backs by “Emergency”, “Urgent” or “Normal” response call backs. The hotline also tracks and gathers data regarding individual hotline workers and overall -team performance. A strategy is in development to publicize and educate potential on line users by region on the ON LINE REPORTING option and how to access the on-line reporting system. 127 INVESTIGATION TIMELINESS RECOMMENDATION 5 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should take actions to ensure that critical investigation timeframes are completed in accordance with procedures, including initiating investigations, contacting the alleged victim and perpetrator, submitting investigations for supervisory review, and completing the investigation. The Department The Department currently tracks for compliance with initiation and is at 99% compliance. Since March 1, 2019 report completion and extension is now being monitored weekly through reports and staffings with Regional Administrators. Supervisors have access to a worker activity report and will be trained on how to access and utilize this report. This will be completed by September 2019. The Compliance Administrator will review a random selection of cases quarterly to ensure staff are meeting timeframes. INVESTIGATION EXTENSIONS RECOMMENDATION 6 The Department of Children and Family Services should comply with rules and procedures and ensure:     DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE Extensions are requested prior to the 55th day of the investigation; That extensions are given only for good cause; Extensions are requested and approved by appropriate staff; and Extension requests contain all required information. The Department The Department is monitoring extensions and ensuring cases are extended for good cause. Since March 1, 2019 there is a weekly report completed by the regions to identify all teams with more than 10 cases over 60 days, actions needed and anticipated closure date. Also instituted is a weekly staffing with all Regional Administrators regarding extensions more than 90 days to address the appropriateness of the request and actions to complete the investigation. This process has already resulted in a reduction of cases over 60 days All staff will be reminded of the need to extended cases within the timeframe set forth in procedures. 128 ASSESSING THE NEED FOR SERVICES RECOMMENDATION 7 The Department of Children and Family Services should:   DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE Make the Level of Intervention a required field in SACWIS and revise the Level of Intervention options to more accurately reflect current practices, and Include a rationale for indicated investigations in which there is a Level of Intervention of “No Service Needed.” The Department Procedure 300 will be updated to include the expectation the investigator documents the reason no services are necessary. This will be completed by September 2019. Creating a special “services” note in the SACWIS file will be explored RECOMMENDATIONS FOR SERVICES RECOMMENDATION 8 The Department of Children and Family Services should:   DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE Formally document when services are offered and whether those services are refused; and Consider establishing guidelines or policies to assist Child Protection Specialists and Supervisors regarding services to be offered for indicated allegations. The Department Individual offices maintain a list of resources for their area. Procedures 300 will be enhanced to ensure the supervisor and investigator have a discussion regarding services available to assist families and document services offered and the outcome-i.e. accepted or refused and the reason for refusal. The core practice model which is in process of implementation also addresses identification of services with the family and allowing them to identify services which will best benefit them. Procedures will be updated by September 2019. Creation of a special “services “note within SACWIS will be explored. 129 INTACT FAMILY SERVICES MONITORING RECOMMENDATION 9 The Department of Children and Family Services should track the number of Intact Family Services cases that are opened annually including which POS agency provided the services. The Department DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department currently tracks Intact Family Services cases using payment data for both POS agency (contract) utilization and for budgeting purposes. While these fiscal reports will continue, the Department in addition will be developing monthly production reports from DoIT to ensure DCFS management staff receives timely reporting of agency caseloads. INTACT FAMILY SERVICES COVERAGE RECOMMENDATION 10 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should ensure that POS agency contracts are accurate and specify coverage for all assigned counties. The Department The Department’s Office of Contract Administration reviews all contracts annually, each Spring, in preparation for July 1st services. Beginning in FY19, the Department has included as part of that review process to ensure a careful review with Intact Family Services management staff that all counties are reported accurately for every contract. While no families were denied services due to specific counties not being listed, the Department’s expectation is that all assigned counties are reflected in the POS agency contracts in a complete and accurate manner. 130 INTACT FAMILY SERVICES REFERRALS RECOMMENDATION 11 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should complete a CFS 2040 form for Intact Family Service referrals as is required by procedures. These forms should also be maintained in an accessible location. The Department The CFS 2040 has been used as an Intact referral document from the Investigation supervisors to the Area Administrators. The document’s development can be tracked back to 9/09. Until May 2015, the Area Administrators statewide referred to the Intact agencies directly. May 1, 2015 the Intact referrals began to come to the Intact Utilization Unit for Cook County referrals only. The Intact PSA assigned the cases to the respective POS agencies, sent the assignment information back to the DCP AA, the assigned private agency Intact contact and the DCP supervisor for the handoff to be scheduled. The Intact Utilization PSA housed in Cook, has hard copies of 2015 2040’s. As of December 2017, the Intact Utilization Unit took over case assignment from the Area Administrators statewide. Prior to December 2017 all of the Downstate referrals were managed by the AA’s. The PSA in Springfield and the PSA in Cook divide the 4 regions, each taking two regions, to be responsible for case assignment. Currently, all Intact referrals are logged and maintained electronically by the Intact Utilization Unit. The log of referrals is statewide. Historically, regions were required to submit their Intact referral logs to the Chief Deputy monthly. This demonstrates there has been tracking of Intact referrals, and it continues to be refined and enhanced. All 4020’s are managed electronically from AA to the Intact Unit PSA and electronic folders. The Intact Utilization clerical’s document each referral in the respective Regional log. 131 NORMAN CASH ASSISTANCE RECOMMENDATION 12 DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE The Department of Children and Family Services should document all purchases made with Norman Cash Assistance funds. The Department should also update its cash assistance request approval policies to reflect the current organizational structure of the agency. The Department The Department agrees that Procedures and Organization charts should reflect the current process. The Department also agrees that purchases made using Norman Cash Assistance Funds should not only be well documented but, that documents should be readily available for review/audit. The Agency shall update their written procedures to reflect how Norman Cash Assistant funds are currently processed, including who approves assistance. The Agency shall update the Organization Chart, reflecting the removal of the Deputy Director of the Division of Service Intervention position. The Agency shall include in their update of written procedures the process of properly retaining CFS 370-5 forms to ensure they are readily available for review/audit. In completing the corrective actions above, the Department expects to develop a system that; (A) properly reflects the current process and organizational structure of the Norman Cash Assistance program and (B) ensures proper document retention of purchases made. 132 COMMUNITY BASED SERVICES RECOMMENDATION 13 The Department of Children and Family Services should follow existing Department procedures including:   DEPARTMENT OF CHILDREN AND FAMILY SERVICES RESPONSE Documenting referrals for community based services including the duration and frequency of the services and the conditions/circumstances that the services are designed to mitigate; and Verifying whether the family is following through with the community services. The Department The Department will ensure staff are reminded of current procedures regarding community referrals, what the service mitigates, time frames and verification family has linked with the service. This will be completed by July 2019. The Creation of a specific “services” note within SACWIS will be explored. 133 134 Recycled Paper • Soybean Inks Printed by Authority of the State of Illinois LPU Order 00000 • May 2019 • 80 copies