Montgomery County Department of Job and Family Services Children Services Division Alternative Response Intake Review Purpose of the Review: As a result of a directive from Ohio Governor DeWine on February 26, 2020, the Ohio Department of Job and Family Services (ODJFS) conducted a review of the Montgomery County Department of Job and Family Services/Children Services Division (Montgomery County DJFS/CSD) Alternative Response (AR) assessments screened in between August 25, 2019 and February 26, 2020. Methodology: Data from Ohio’s Statewide Automated Child Welfare Information System (SACWIS) identified approximately 1,245 AR assessments during the six-month period. ODJFS implemented a twotier approach to ensure the assessments were reviewed for safety and compliance and utilized both a review of SACWIS case records and data analysis. The first tier of the review consisted of using the statistical protocol established by the U.S. Department of Health and Human Services Children’s Bureau in conducting case reviews. 170 assessments were randomly selected to serve as the study sample. Utilizing a standard review tool, 15 Office of Families and Children Technical Assistance Specialists Statewide reviewed this sample of assessments. Areas of this review included AR pathway assignment, assessment initiation, comprehensive safety and family assessment activities which included review of historical child welfare involvement of the family and the service needs of the children and adults involved in the assessments. For the remaining 1,075 screened in AR assessments, comprehensive data analysis combined with SACWIS case record reviews were conducted to assess the overall safety of each child subject of the report. Comprehensive data analysis was reviewed to ensure each intake participant had been assessed and face-to-face contact was documented. Of these, 217 assessments met criteria for further ODJFS review based on the following: assessments that were open 14 days or less, data indicated all participants had not been seen, and/or the final case decision documented in the JFS 01400 "Comprehensive Assessment and Planning Model - I.S., Family Assessment" was less restrictive than what the actuarial tool recommended. The standardized review tool described above was utilized to review these 217 assessments. Any assessment reviewed where there was not enough information in the case record to support safety was brought to the attention of Montgomery County DJFS/CSD for immediate review. Six assessments were identified and referred to Montgomery County’s attention. All six assessments were reviewed by Montgomery County DJFS/CSD administrative staff and actions were taken to ensure the safety of children and that documentation was updated in the case record. Page 1 of 6 Results: The review examined the pathway assignment of the assessment, initiation, and comprehensive safety and family assessment activities, which included a review of historical child welfare involvement of the family and the service needs of the children and adults involved in the assessments. According to Ohio Revised Code (ORC) 2151.49 Traditional and Alternative Response Pathways and Ohio Administrative Code (OAC) 5101:2-36-01(L) Intake and Screening Procedures for Child Abuse, Neglect, Dependency and Family in Need of Services Reports; and Information and/or Referral Intakes a screened in report of child abuse and/or neglect should be assigned to either an AR or Traditional Response Pathway for assessment/investigation. Both ORC and OAC outline specific criteria that require a Public Children Services Agency to assign child abuse and neglect screened in intake reports to the traditional response pathway. For all other child abuse and neglect screened in reports, an alternative response pathway is be the preferred response. Per the review of the AR assessments, this area was identified as a strength for Montgomery County DJFS/CSD. Based on the circumstances of the reported concerns it was found that the agency consistently assigned reports appropriately to the AR pathway. Pursuant to OAC rule 5101:2-36-20 Public Children Services Agencies Assessment Requirements for Child Abuse and Neglect Reports In Alternative Response, a PCSA is required to initiate an emergency assessment by attempting face-to-face contact with child subject of the report within one hour of the referral being screened in as a report. For all other assessments, within 24 hours of the referral being screened in as a report, a PCSA must initiate the assessment by attempting face-to-face contact with the child, parent or collateral source having current information about the child’s condition and safety, attempt a telephone contact with the parent or collateral source or send a letter to the parent, guardian or custodian to acknowledge a report was received and invite the family to engage with the PCSA. Nearly 97% of the 1,245 assessments in the sample universe were initiated in accordance with OAC rule. Assessment of Safety and Risk Risk and safety assessments are completed on all reports of abuse, neglect, and dependency accepted by the Public Children Services Agency (PCSA). The purpose of the risk and safety assessment is to determine whether concerns are present for children in their home and what, if any, interventions are needed to ensure their safety and mitigate risk. Risk and safety assessments are completed formally and informally from case inception through case closure. The Comprehensive Assessment Planning Model Interim Solution (CAPMIS) Safety Assessment includes an assessment of child vulnerability, adult protective capacities, and active safety threats to determine if a child is safe in the home or whether a PCSA must intervene to protect the child. Needs Assessment and Services to the Child(ren) and Parents For families to have enhanced capacity to provide for their children’s needs, an accurate and comprehensive assessment of the children and parent’s needs must occur to gain an in-depth understanding of their unique needs. An evaluation of the individual family member’s needs Page 2 of 6 takes place formally through the CAPMIS Family Assessment and informally through face-toface contacts, home visits, contacts with services providers, and service provider reports. The initial assessment includes an evaluation to identify the family’s strengths and needs, which informs case status decisions and what service needs may be present. The agency formally assessed risk and safety via completion of the JFS 01401 "Comprehensive Assessment Planning Model - I.S., Safety Assessment". OAC rule 5101:2-37-01 PCSA Requirements for Completing the Safety Assessment mandates safety assessments be completed within the first four working days, with an additional three working days to complete the JFS 01401 in SACWIS. Montgomery County DJFS/CSD completed formal Safety Assessments pursuant to OAC rule 5101:2-37-01 in 76% of the assessments reviewed. Delays in contacts with required parties had an impact on Montgomery County DJFS/CSD’s performance in this rule requirement. Formal assessments of risk and safety were also conducted via completion of the JFS 01400 "Comprehensive Assessment Planning Model - I.S., Family Assessment". Per OAC rule 5101:237-03 PCSA Requirements for Completing the Family Assessment, the PCSA shall complete the JFS 01400 no later than 45 days from the date the PCSA screened in the report. The PCSA may extend the time frame by a maximum of 15 days if information needed to complete the Family Assessment cannot be obtained within 45 days and the reasons are documented in the case record. The CAPMIS Family Assessment assesses risk of future maltreatment to the child and identifies a family’s strengths and needs to determine what level of service the family may need. Montgomery County DJFS/CSD completed 81% of the assessments reviewed pursuant to this requirement. The primary concerns in the assessments not meeting the rule requirements included a lack of contact with, and interviews of the child(ren) subject of the report and/or all household members. At the time of the review, 1,180 of the 1,245 assessments had a completed Family Assessment. The median timeframe for Family Assessment completion was 35 days. Due to the contemporary nature of the sampling period, a number of the assessments in the universe were still in progress and still within OAC rule requirements of 45 to 60 days to complete the assessment. Informal assessments are made during face-to-face contacts with the family members. The frequency and quality of these visits correlate to the caseworker’s ability to accurately assess the family and determine child safety and risk. Service provider contacts, provider reports, law enforcement records and safety reviews of caregivers are additional forms of informal assessments used to validate statements and ensure children’s safety during the course of investigations. Informal assessments of safety and risk were examined during the review. Informal assessments of safety and risk were documented in 90% of the assessments reviewed. These informal assessments were deemed comprehensive in 37% of the assessments reviewed. In the remaining assessments where the informal assessments of safety and risk were not deemed comprehensive, concerns included not all household members being interviewed and/or thoroughly assessed and collateral sources of information not being contacted. The family’s history of involvement with child welfare agencies was also examined during the review. Assessing the family’s history of child welfare involvement is important in evaluating the Page 3 of 6 adults’ utilization and effectiveness of past services that impact the risk of children being abused or neglected. This history assists in assessing if past parenting practices have been impacted by the past services received. Of the assessments reviewed, 68% had prior child welfare agency involvement with Montgomery County DJFS/CSD, other Ohio public children services agencies and/or a child welfare agency in another state. If the family had prior child welfare agency involvement, in 57% of the assessments reviewed, the prior involvement was considered in assessing needs and providing services in the current assessment. The service needs of the children involved in the assessments were reviewed, including but not limited to emotional/behavioral and/or physical health and cognitive/physical and/or social development. This review documented that identification of appropriate service needs for children is a strength for Montgomery County DJFS/CSD. In 42% of the assessments reviewed, there was an identified child functioning concern. In 93% of these assessments, it was determined services were needed for the child(ren) involved to address the identified concern. In 61% of the assessments reviewed where services were deemed necessary for the children, the child(ren) was already engaged with a provider. In 18% of these assessments where services were deemed necessary for the children, no services were delivered prior to case closure. In 21% of these assessments, based on the information documented in the case record, the reviewer was unable to determine if services for the children were delivered. The service needs of primary adult caretakers were also reviewed, including but not limited to domestic violence, emotional/mental health, parenting practices, physical health, cognitive abilities, substance abuse, and resource management/household maintenance. In 61% of the assessments reviewed there was an adult functioning concern. In 89% of these assessments, the reviewer deemed service provision was necessary to mitigate risk to the child(ren). In 39% of the assessments, the adults were already engaged with a provider or had a service delivered. In 34% of the assessments reviewed where services were deemed necessary for the adults involved, there was no service delivery for the adults. In 27% of these assessments, based on the information documented in the case record, the reviewer was unable to determine if services for the adults were delivered. Additional Consideration: During this sampling period from August 25, 2019 through February 26, 2020, Montgomery County DJFS staff working at the Haines Children’s Center who are members of the Professionals Guild of Ohio (PGO) union, went on strike from September 20, 2019 through September 30, 2019. This included approximately 350 staff such as, caseworkers, case aides/support staff, clerical and fiscal staff. This had a direct impact on performance measures and practice during this time period as there was only approximately 68 agency staff working during this time period. Not all of these 68 staff met the qualifications to conduct child welfare case work. Although assessments and investigations were being initiated and safety plans were monitored during the strike, numerous assessments evidenced gaps in contacts with families and delays in recording assessment activities in SACWIS due to staff being on strike. Summary and Recommendations: Page 4 of 6 In this review Montgomery County DJFS/CSD demonstrated many strengths. The agency demonstrated consistent screening decisions and the reviewed assessments were documented to be appropriately assigned to the AR pathway. The data from this review shows Montgomery County DJFS/CSD met OAC rule compliance for completion of Safety and Family Assessments in the majority of the assessments reviewed. Additionally, the agency identified appropriate service needs for children and parents subject of the report. This AR assessment review identified systemic factors that impacted casework practice and supervisory oversight of assessments/investigations. Documented concerns included comprehensive informal assessments of safety and risk that included a lack of interviewing/assessing all household members and gathering/documenting information from collateral sources. Information from collateral sources could include obtaining service referrals and reports from other PCSA’s, service providers, and other community partners as appropriate. These findings are consistent with Montgomery County DJFS/CSD’s Child Protection Oversight and Evaluation (CPOE) Stage 11 review: Safety Outcome 2 and Well-Being Outcome 1. Montgomery County DJFS/CSD agency administration is aware and has been working in collaboration with ODJFS to improve overall agency practice and performance. The agency has a current Plan for Practice Advancement (PPA) addressing improvement strategies to ensure comprehensive formal and informal assessments which includes staff training focusing on thorough assessments. Training topics include, but are not limited to, conducting effective home visits, motivational interviewing and effective case documentation; however, the COVID-19 pandemic has impacted the agency’s ability to implement large scale training. The Ohio Child Welfare Training Program currently has restrictions on conducting face-to-face training sessions. As outlined in the methodology above, 217 assessments met criteria for further ODJFS review. ODJFS will schedule a meeting with Montgomery County DJFS/CSD Administration and identified supervisory staff to present specific findings of the review and provide technical assistance. ODJFS will work in collaboration with Montgomery County DJFS/CSD administration to review the agency’s internal procedures to ensure appropriate oversight of thorough and accurate assessments of safety, risk and needs for all families and children. It is recommended Montgomery County DJFS/CSD continue implementation of its CPOE Stage 11 PPA improvement activities, addressing thorough assessments of safety and risk that include interviewing and assessing all household members and obtaining information from collateral sources. Additionally, it is recommended the agency continue PPA improvement activities to ensure service provision to children and adult caregivers which includes documentation of contacts with, and reports from, service providers. In order to ensure continued monitoring of AR assessments, it is recommended additional cases be reviewed at the time of the CPOE Stage 11 six-month and twelve-month PPA reviews for Montgomery County DJFS/CSD. These additional cases will be selected based upon a screened in AR assessment during the respective sampling period. Finally, ODJFS recommends a six-month extension of the CPOE Stage 11 PPA for Montgomery County DJFS/CSD to ensure implementation of improvement strategies and provide additional monitoring and technical support. Page 5 of 6 Page 6 of 6