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Operational Analysis of the Child Welfare Division of Jefferson County DSS

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Operational Analysis of the


Child Welfare Division of
Jefferson County Department
of Social Services
Prepared by Bonadio & Co., LLP

For the Jefferson County, NY Attorney’s Office

May 24, 2023


Operational Analysis of the Child Welfare Division of Jefferson County DSS

Table of Contents

I. Executive Summary……………………………………………………...………….….1 – 2

II. Summary of Roles and Responsibilities……………………………………………..…2

III. Child Protective Services……………………..…………………………….…….....3 – 19

i. Introduction………………………………………………………………………........3
ii. Case Review Sampling Methodology………………………………………......4 - 6
iii. Case Review Results……………………………………………………………..6 - 9
iv. Bonadio Commentary Regarding Case Review…………………………………...9
v. Analysis of OCFS Metric History and Current Standings…………………..10 - 15
vi. Budgeted Positions and Caseloads Analysis………………………………..15 - 19

IV. Ongoing Children’s Service………………………………………………………..19 – 42

i. Background…………………………………………………………………......19 - 21
ii. Quality Control Testing and Approach……………………………………............21
iii. Sampling Methodology and Approach…………………………………….....21 - 23
iv. Preventive Services Case Review Results……………………………….....23 - 28
v. Foster Care Case Review Results…………………………………………....28 - 35
vi. Bonadio Commentary Regarding Ongoing Case Review……………………….36
vii. Ongoing Unit Observations and Recommendations………………………..36 - 38
viii. Title IV-E Foster Care Review………………………………………………...39 - 42

V. General Child Welfare Division Observations &


Recommendations…………………………………………………………………..43 – 54

VI. Additional Items for the County’s Consideration……………...………...…....54 – 55


Operational Analysis of the Child Welfare Division of Jefferson County DSS

I. Executive Summary

The Bonadio Group (Bonadio) was engaged by the Jefferson County Attorney’s Office (the Office)
pursuant to the terms of the Professional Services Agreement (PSA) signed July 19, 2022 for a six-
month period commencing in September 2022 and ending in or around March 2023. In accordance
with the agreement, Bonadio conducted an operational analysis of the Child Welfare Division (the
Division) of Jefferson County Department of Social Services (the Department). In conjunction with this
review, we interviewed Department personnel, performed process walkthroughs, analyzed operational
workflows and related documentation, and reviewed policies and procedures. We also performed a
comprehensive quality control case review within the Child Protective Services program, Foster Care
program and Preventive Services program. We performed these procedures to gather first-hand
accounts of the strengths and weaknesses of the Department’s child welfare functions, identify
process gaps, control deficiencies, and opportunities to enhance operational efficiencies to ensure the
county is best suited to accomplish its mission of assisting individuals, children, and families in need.

At the onset of the engagement, Bonadio met with the Commissioner and the Deputy Commissioner
weekly. Midway through engagement, we reduced the frequency of our meetings from weekly to bi-
weekly. We also met with the County Attorney on a frequent and often impromptu basis and provided
written updates on the status of activities performed and upcoming planned procedures upon his
request. This report, which was compiled at the conclusion of our review, captures our procedures
performed in greater detail, as well as findings, observations, case review results and corresponding
recommended solutions for the Child Protective Services (CPS) unit and Ongoing Children’s Services
(Ongoing) unit for the County’s consideration.

Due to the size of the Department relative to the length of our engagement period, we offered all child
welfare staff, including management and community service workers, the opportunity to speak with us
individually. We performed our interviews of the Commissioner, Deputy Commissioner, Grade A
Supervisor, and the Director of Services in person. Interviews with remaining staff were performed
onsite as well as virtually. Less than two months into our engagement, we spoke to the overwhelming
majority (approximately 88%) of staff while the remaining individuals politely declined our invitation or
disregarded several attempts to schedule an interview. It is worth noting that without the number and
variety of staff willing to speak with us, we would not have gained the extent of insight necessary to
identify the strengths and shortcomings of the Department.

Like other counties in the state, years of diminishing salaries and benefits compounded by the COVID-
19 pandemic have resulted in substantial vacancies and less experienced staff in the child welfare
units. Per our analysis of caseworker positions and vacancies, as of mid-February 2023, 15 of 22 CPS
caseworkers have less than two years of experience and nine of the caseworkers have been in the
role for less than one year.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

While child welfare work is inherently demanding and at times emotionally charged for all caseworkers,
regardless of their tenure, caseworkers often gain valuable skills with time on the job, improving their
investigative skills, and increasing their knowledge of OCFS regulations and internal department
processes that impact the quality and timeliness of casework. Thus, the percentage of less
experienced caseworkers pose a potential risk to the Department.

Overall, we noted multiple areas of strong casework, especially in the Ongoing units as it appears that
these units are comprised of more experienced staff. We did, however, identify a few critical internal
operating procedures in need of improvement, including a deteriorating case transfer process,
underutilization of support staff and inconsistently documented case supervision. We recommend
Department management work with the units to increase case compliance and retain dedicated, and
knowledgeable staff.

II. Summary of Roles and Responsibilities

We were not engaged to, and did not, conduct an audit, the objective of which would be the expression
of an opinion on the policies and procedures in place surrounding the functions within the Division’s
operations. Accordingly, we do not express such an opinion. Had we performed additional procedures,
other matters might have come to our attention that would have been reported to you.

This consulting engagement report is intended solely for the information and use of the Office and the
Division and is not intended to be and should not be used by anyone other than those specified parties.

We are independent within the meaning of, and comply with the applicable requirements of, Rule 101,
“Independence”, and related Interpretations and Rulings of the Code of Professional Conduct
promulgated by the American Institute of Certified Public Accountants.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

III. Child Protective Services


INTRODUCTION

The CPS Unit within the Department receives reports of suspected abuse and maltreatment of children
in the county from the New York State Central Registry (SCR). One Grade A Supervisor (who is also
responsible for the Ongoing unit) oversees four Grade B Supervisors. The Grade B CPS Supervisors
oversee their CPS teams which consists of four to seven caseworkers, including one senior
caseworker, per team. Grade B Supervisors and senior caseworkers fulfill supervisory responsibilities
such as holding case conferences and reviewing safety assessments, Risk Assessment Profiles
(RAPs), and case closings.

There are five caseworkers that are assigned a mix of standard CPS cases and cases that have
specific parameters: the FIT (Forensic Interview Training) caseworkers primarily receive cases with
higher safety factors such as alleged sex abuse, severe physical abuse, and fatality cases. In addition
to senior caseworkers assisting the caseworkers on their teams if needed, they occasionally hold a
caseload themselves if more intense or sensitive cases that require expertise, such as fatalities, are
called in. They are also assigned a primary role in cases where a new worker is assigned a secondary,
supporting role for the purpose of training, address all intakes in which another county is expressing a
concern for a family that does not rise to the level of a CPS case, and absorb outstanding caseload
from workers who have exited the Department.

Most cases are assigned by the four Grade B Supervisors, who rotate weekly on a case assignment
schedule, and distributed on a “round robin” basis to caseworkers. If the Grade B Supervisor is out of
the office during their week of case assignment, the senior on their team will fill in for them. The FIT
workers are an exception to this process, as they receive cases that have the most serious allegations
and are assigned these cases on top of the “round robin” assigned CPS cases. Senior caseworkers
are also an exception to this process, as the only cases that are directly assigned to them are fatality
cases or intense cases that are marked as “sensitive.” Each caseworker is taken off rotation by the
Grade B Supervisors for a week of no referrals about every other month in order to focus on closing
existing open cases.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

CASE REVIEW SAMPLING METHODOLOGY

In accordance with our PSA, we performed a review of CPS cases using the Ongoing Monitoring and
Assessment (OMA) Tool developed by OCFS. This instrument reviews each major area of casework
through a series of questions that reflect OCFS regulation and best practices. We selected our cases
from a listing of SCR Intake Reports for the 12-month period October 1, 2021, through September 30,
2022. From the listing, we noted 1,575 SCR reports were referred to Jefferson County (the County)
and subsequent investigations were opened during the period under review, with 1,271 cases closed
as of the date of our case selection. Using a random number generator, we selected 15 cases for
testing. Our selection of cases had all been concluded at the time of our testing with one pending final
approval from the case supervisor. Of these closed cases, four were indicated and 11 were unfounded.
Per the charts on the following page, most of the case allegations were Inadequate Guardianship and
Parent’s Drug/Alcohol Misuse. Of the four indicated cases we selected, both allegations were
substantiated in all but one investigation.

Additionally, per the pie chart on the following page, family members were the primary source of
reports for the cases we reviewed (40%) and reports from anonymous reporters or other concerned
citizens were the next most frequent source (20%).

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Jefferson County consists of 22 towns/municipalities and 11 school districts. To determine which, and
to what extent geographic areas accounted for SCR intake calls during our scope period, we obtained
a Cognos listing of the 1,575 SCR reports received for the October 1, 2021, through September 30,
2022 by zip code. Please note, this report does not include the 328 Consolidated nor the 214
Supportive reports received. These reports are not as time-consuming as a full CPS investigation;
however, they do still require certain tasks and/or actions to be completed by the caseworker.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Per the detail heat map on the previous page, calls originating from the areas in which the Watertown
City School District and Carthage Central School District accounted for at least 60% of the SCR calls.
This is unsurprising as these districts correlate to the largest populated areas in the County, such as
Watertown, Fort Drum, and Carthage.

Several performance measures we reviewed correlate directly to OCFS regulations, while others are
based solely on what we consider best practice. During our case review, we noted varying levels of
casework quality and find it reflective of the distressed workforce level discussed previously in this
report. Additionally, the results reflect Jefferson County’s standing in OCFS’ monthly CPS
Performance Report metrics and statements made by staff during interviews.

When OCFS performs an analysis of a county’s CPS division, they use the following positive
compliance thresholds to evaluate performance in individual areas:

x Strong; no program improvement plan (PIP) required: 85% and above


x Recommendation: PIP recommended: 84% - 75%
x Area Needing Improvement; PIP required: 74% and below

The metrics highlighted below report results that we consider areas of strength for the Department as
well as those in need of improvement. Of the seven individual metric areas reported in this section, six
exceeded OCFS’s “Strong” threshold of 85% positive compliance or greater and one metric was below
the OCFS threshold of 74% as an “Area Needing Improvement”.

CASE REVIEW RESULTS

1. CASE HISTORY

No. of Positive
Criteria Tested Cases Compliant Compliance
with Criteria Rate
SCR History reviewed within 24 hours of report 13/15 87%

CPS performed well in capturing information from the SCR case history in 13 of the 15 cases. History
in these cases was reviewed within 24 hours, as prescribed by OCFS guidelines. History searches
were observed in all 15 cases, all with case relevant detail noted with three exceptions that lacked any
detail. Out of the two cases that did not perform the search within 24 hours of the report, one case
documented history review within five days of the intake date and one case did not document review
of case history until 76 days after the intake date. The lack of timeliness in this case is problematic as
the caseworker would not have relevant information about the subjects and children of the case during
the initial critical days of fieldwork.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

2. CONTACT WITH SCR REPORT SOURCE

No. of Positive
Cases Compliance
Criteria Tested
Compliant Rate
with Criteria
Source of the report contacted, or adequate contact attempted 13/13 100%
within 7 days of the SCR report

Of the 15 cases we reviewed, contact with the source of the referral was made or adequately attempted
in all instances. Cases in which the source was anonymous or did not provide contact information
were excluded from the positive compliance rate calculation.

3. SUPERVISION AND FOLLOW-UP

No. of Positive
Cases Compliance
Criteria Tested
Compliant Rate
with Criteria
Evidence of supervisory feedback throughout casework? 14/15 93%

Our evaluation of the evidence of supervisory feedback throughout the course of the investigation
(93% positive compliance rate) was based only on the documentation available in the case files
provided to us, which generally included the Intake Report, Stage Summary, and progress notes. The
one case that did not meet the criteria reflected only one instance of supervisory feedback throughout
the case. Feedback was likely delivered outside the meetings recorded in the progress notes but
documenting it is required for both case review and audit purposes. Documentation assists the
caseworker and their supervisor with remembering the next steps to be performed.

Furthermore, we note that of the 14 cases which exhibited supervisory review and case conferences
between the caseworker and their supervisor throughout the investigation, two had weekly instances,
five had bi-weekly instances, two had monthly instances, and five had bi-monthly instances performed
and recorded in the case file. It is important to note that in several of the cases we selected, we
observed early instances of supervisory feedback that was much more consistent and as the
investigation progressed, frequency of supervisory review and/or case conferences began to diminish.
Overall, however, we find this is an area of strength for the Department and it reflects the senior
caseworkers and supervisors’ dedication to developing the skills of their team and ensuring that
caseworkers are properly guided in next steps needed in the investigation.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

4. TIMELINESS OF PROGRESS NOTES

No. of Positive
Criteria Tested Cases Compliant Compliance
with Criteria Rate
Progress notes completed within 30 days of event date. 4/15 27%
Progress notes completed between 30 and 90 days of event 5/15 33%
Case includes progress notes with greater than 90-day 6/15 40%
difference between event date and record of noted.

We noted a positive compliance rate of only 27% in the criteria of inputting progress notes within 30
days of a case event. New York State Regulation for Departments of Social Services require that
“progress notes must be made as contemporaneously as possible with the occurrence of the event”
(18 CRR-NY 428.5). Additionally, OCFS highly recommends notes be recorded within 30 days of the
event as one’s recollection of a case event greatly diminishes in accuracy and relevance after 30 days.
This is especially the case given that supervisors are expected to perform periodic review of the case
and will rely on recent progress notes to understand the case’s current status.

5. TIMELINESS OF 24-HOUR SAFETY ASSESSMENTS

No. of Positive
Criteria Tested Cases Compliant Compliance
with Criteria Rate
24 Hour Safety Assessment Completed Timely 15/15 100%

All 15 cases exhibited positive compliance for the 24-hour safety assessments. This is crucial due to
it being the first contact with the child and critical to establishing an initial understanding of child safety.
This assessment also often involves first contact with the child’s family and the alleged subject, adding
to its importance as an initial understanding of the case’s circumstances.

6. TIMELINESS OF SEVEN DAY SAFETY ASSESSMENTS

No. of Positive
Criteria Tested Cases Compliant Compliance
with Criteria Rate
7 Day Safety Assessment Completed Timely 15/15 100%

All 15 cases exhibited positive compliance for the seven-day safety assessments. This is a primary
metric measured by OCFS and it is critical in establishing child safety. The positive compliance rate
of this sample nearly resembles that recorded by OCFS in their monthly reporting of Safety
Assessment compliance. We find that this is an area of strength for the Department and Jefferson
County consistently performs very well compared to all NYS counties in this metric.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

7. SIGNIFICANT GAPS IN CASEWORK

No. of Positive
Criteria Tested Cases Compliant Compliance
with Criteria Rate
No Significant Gaps Observed in Casework Activity 13/15 87%

The positive compliance rate of 87% falls in a range deemed Strong by OCFS’s thresholds. However,
we note that two cases had a significant gap in casework activity of more than thirty days. One case
had a period of no casework performed for 79 days, which is over one of the three key OCFS metrics
that a case be completed within 60 days. We note that there was a subsequent report called in for this
case before the gap in casework activity and the mother seemed to be uncooperative, but it is
important to note that there were over two months where no casework was documented for this case.
Perhaps most troubling in this statistic is that the alleged maltreated children were not observed by a
caseworker for a four-month period until the investigation was closed.

BONADIO COMMENTARY REGARDING CASE REVIEW

Jefferson County performed exceptionally well in most of the investigative metrics. Despite these test
results, both caseworkers and management acknowledged that there is still opportunity for
improvement. This shows us that the Department has a proper understanding of their abilities, the
impact of their efforts, and how future improvements should be prioritized. Many caseworkers stated
they find it difficult to complete some of their duties and prioritize daily activities while handling higher
caseloads and helping to train new workers. It is also common that timely entry of progress notes
becomes a lower priority than other casework tasks that directly involve child safety. We find that
improvement of progress note timeliness should be an area of focus for the Department since
documentation of these notes directly correlate to effective supervision, case review, and
comprehension of a case’s current status. Additionally, progress note quality can diminish the month
after an event date simply due to the limits of one’s recollection. We find this true even if caseworkers
handwrite notes during an event and then enter them into Connections later.

Handwritten bulleted lists will fail to capture all of the crucial elements of an event that would have
likely been included if the actual progress note was written at the time of the event. Similarly, the cases
we observed to have a gap in casework, and/or untimely history search performed did not have high
safety factors identified in its assessments and were likely set aside as the Department focused on
cases with more immediate safety needs.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

ANALYSIS OF OCFS METRIC HISTORY AND CURRENT STANDINGS

Child Protective Services departments in New York are regulated through OCFS. Three statistics are
specifically tracked by OCFS related to the county’s Child Protective effectiveness: the percent of
workers with greater than 15 investigations, percent of overdue investigations, and percent of safety
assessments approved within seven days. OCFS considers these metrics of primary importance as
they are key indicators of child safety and a department’s effectiveness at investigating reports
received from the community. The metric results for all counties are distributed monthly to each county
commissioner. Jefferson County ranked below the statewide median for two of the three metrics for
all months available to date (February 2022 – February 2023). For the last metric, the County ranked
at or within 10 points of the NYS median for 12 months of the previously mentioned timeframe and
above the statewide median for one month. The following section provides additional analysis of each
metric considering the most recent data available.

Percent of Caseworkers with Greater Than 15 Cases

Each investigation case requires several facets of casework, regardless of the case’s complexity. This
includes home visits and interviews, collateral contacts with related parties, and review of records
relevant to the investigation. Although OCFS does not set 15 cases per caseworker as an absolute
maximum caseload, 15 is the threshold they measure against as a reasonable caseload to complete
required elements timely and accurately.

Jefferson County Percent of Caseworkers with


Greater Than 15 Cases
75%
70%
65%
60%
55%
50%
45%
40%

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Throughout the 12-month period of February 2022 to February 2023, on average, the Department was
consistently above 50% of workers with caseloads greater than 15 cases. The County was trending
near 55% for the first half of 2022 but since July 2022, the Department’s overall average percentage
increased to over 60%. This results with a consistently positive trendline (in orange on the previous
page) for the year that was crossed by the most recent report of 71% of caseworkers with greater than
15 cases. When compared to other NYS counties as of month-end February 2023, Jefferson County
ranked 62nd of 64.

Number of Caseworkers with > 15 Cases

26-30 Cases, 4,
29%

16-20 Cases, 6,
43%

21-25 Cases, 4,
28%

To further understand the current distribution of cases among workers, Bonadio obtained a listing of
all caseloads as of March 8, 2023 and reviewed those with greater than 15 cases. In our analysis
shown above, we note that almost half of the caseworkers with greater than 15 investigations had
caseloads between 16 and 20 cases. More than 50% had cases higher than 20 cases. Though higher
than the caseload recommended by OCFS, some caseworkers interviewed indicated that they could
handle caseloads of up to 20 cases and still consider themselves in control of their cases. Conversely,
those with higher caseloads all stated that maintaining their cases can feel untenable. As shown in the
graph above, eight caseworkers have caseloads higher than 20 cases and four have higher than 25
cases. Caseworkers stated that a caseload of this level is unsustainable and leaves the worker only
addressing cases requiring the greatest urgency. Cases with lower-level safety factors that do not
present an immediate danger to the children involved become a secondary concern to the caseworker
and then lead to an increase in overdue cases as cases with lower initial safety factors remain open.

Percent of Cases Overdue

Per chapter six of the New York State Child Protective Services Manual, “CPS has the sole
responsibility for making a determination within 60 days after receiving a report whether there is some
credible evidence of child abuse or maltreatment so as to either indicate or unfound the report.” This
requirement seeks to encourage caseworkers to balance required case activity with the need for swift
determination and potential subsequent action regarding case allegations.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Percent of Cases Overdue


50%

45%

40%

35%

30%

Since February 2022, on average, more than 40% of the County’s CPS investigations have been
overdue on average according to OCFS’ monthly reporting. The percent of overdue cases ranged from
36% to 47%, with July, August, and December 2022 having the most overdue cases. Jefferson County
has consistently performed below the NYS median from February 2022 to February 2023. Despite the
most recent report of 36% being the lowest statistic for this metric since April 2022, the County’s
ranking in this metric at month-end February 2023 was well below the NYS median and ranked 50th
of 64 counties.

During our case review of the 15 CPS investigations discussed previously in this report, we found that
10 cases, or 67% of our selection, were overdue. The pie chart on the next page details these results.
Of these cases, three were closed between 61 and 90 days, three were closed between 91 and 120
days, and four were closed more than 120 days after the intake date. Only five cases in our selection
were closed timely in 60 days or less. The average number of days these cases were open was 91
days and the longest investigation in our selection was open for a total of 184 days, about triple the
OCFS metric of 60 days.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Additionally, as shown below, during our analysis, we reviewed cases with opening dates since
January 2020 and found that fully processing an investigation on average has taken about 90 days:
85 days in 2021, 89 days in 2022, and 97 days through the first two months of 2023. This is a full 50%
longer than the time recommended by OCFS. We note that in 2020, this decreased to 66 days due
to the combination of remote work environment brought on by the COVID-19 pandemic, continued
fieldwork, and a decrease in overall cases received. Additionally, of cases that are overdue during this
period, they are on average overdue by 55 days: 32 days in 2020, 55 in 2021, 66 in 2022, and 68 days
through February 2023. This shows that the causes of cases being overdue are persistent despite
the number of cases received increasing by 3% from 2020 (1,562 cases) to 2021 (1,608 cases) and
decreasing in 2022 (1,560 cases).

Unsurprisingly, as of the beginning of March 2023, caseworkers that had more than 15 open
investigations also carried 94% of the overdue cases despite being 70% of the total number of
caseworkers.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Percent of Timely Safety Assessments

Timeliness of safety assessments is the third metric measured monthly by OCFS and is performed at
the initial stages of an investigation. The assessments determine if there is an immediate safety
concern with the children reported in the case and help set the direction of the case through interviews
with the children, the subject, and any readily identifiable collateral contacts. Supervisor review is
required before completion and should include guidance as to next steps that should be taken by the
caseworker. This assessment must be approved within seven days of receiving the SCR report.

Percent of Timely Safety Assessments


100%

95%

90%

85%

80%

Jefferson County has experienced positive safety assessment timeliness thus far in 2022 and 2023
(please note that this metric denotes improvement when the percentage increases and worsening of
conditions as the percentage lowers). We note that these results are essentially opposite of the
previous two metrics as the timeliness of assessments has been almost 95% on average since
February 2022. The County has consistently ranked at or within 10 points of the state median or
performed above the state median for this time period. The most current reading is the highest for the
County thus far in 2023 at 99%.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Further review of safety assessment timeliness data shown above reports that of the 354 total cases
per the previously mentioned listing of total caseloads as of March 8, 2023, only ten cases had overdue
safety assessments. Nine of these were only one day overdue and one case had a safety assessment
performed two days late. We note that this statistic is significant compared to other counties and the
County’s other two metrics. The Department has heavily focused on safety assessment timeliness,
which is made clear by the County ranking above the NYS average recently.

BUDGETED POSITIONS & CASELOADS ANALYSIS

The three metrics analyzed above demonstrate that while the Department is efficient at processing
incoming investigations during their initial stages, the Department has difficulty effectively completing
these investigations. We find this primarily due to turnover and fewer experienced caseworkers. Over
the past year and a half, the Department has struggled with a gradual decline in available caseworkers,
with a staff of 23 CPS caseworkers in July 2021, a decrease to 20 in January 2022, a peak of 26 in
July 2022, and gradual decrease to 22 Investigation caseworkers on staff as of February 2023.
Caseworkers absent due to sickness, vacation, or FMLA further reduce the number of caseworkers
available to receive new SCR reports. We note that in total, 28 caseworker positions are budgeted
for CPS.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

The analysis in this section considers whether the Department has budgeted sufficient positions for
CPS investigations. We find that this initial question is often difficult to determine but is crucial when
evaluating a department’s effectiveness. If too few positions are available, no amount of shuffling or
new procedures will sufficiently increase productivity to meet casework demand. Alternatively, if an
adequate number of positions are budgeted, the Department’s focus may shift to more pressing
issues. In an effort to find a common basis for discussion of budgeted positions, our analysis starts
with the basic assumption that the OCFS recommended caseload of 15 cases is reasonable. This is
reflective of statements made during our interviews when caseworkers were asked how high their
caseload could be without impacting casework quality. The vast majority stated between 12 and 18
cases. This is also in line with statements made by staff in other counties we have worked with in
previous engagements. Considering this, we find the OCFS recommended caseload both a
reasonable basis for our calculations and a starting point for objectively discussing workforce levels in
the Department.

This analysis primarily considers Child Protective’s effectiveness as the steps and timeline required
for case closure are more clearly defined than those in Ongoing cases. Both CPS and Ongoing are
experiencing similar decreases in available caseworkers and increased caseloads so we expect the
conclusions reached for CPS are also reflective of the experience in Ongoing.

Budgeted Positions and Casework Effectiveness

As noted above, the Department has not recently been fully staffed and as of February 2023, has
approximately 6 open CPS caseworker positions. The two graphs on the following pages consider
how effective the Department would have been if fully staffed from August 2021 through February
2023. The first graph depicts the average caseload size if on average cases close within the 60 days
expected by OCFS. The second graph displays caseloads if the average case is closed in 90 days.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

In an effort to accurately reflect the number of staff that would actively accept reports at any given
time, we have removed five positions from the total available in all months. This accounts for those
caseworkers not taking reports due to vacation, sickness, training, or having a week of no referrals. It
is also important to note that about 40% of the Department’s current CPS workforce has less than a
year of casework experience and new caseworkers are not considered to be in full rotation for case
assignment until about ten months to a year after being hired. Individuals in such a position are a
reality in every department and prevent it from ever having all budgeted positions accepting reports.
We find that our estimate of five caseworkers, or over 10% of available caseworkers, is an attempt to
provide conservative calculations, as in reality, fewer individuals are out on average in a department.

Each calculation utilizes SCR report data obtained from Connections. The number of reports utilized
for each month accurately reflect the Department’s intake for the period. This analysis of caseloads
utilizing 60-day closings shows that caseloads would remain below the OCFS recommended level of
15 cases for the entire period under review. The overall average for the period would be just above
two-thirds the recommended level at 12 cases. In fact, caseloads do not rise above 12 cases after
April 2022.

The results shown on the 90 days closing graph on the next page significantly differ. Estimated
caseloads are above 15 cases for the entire period. However, we find that caseloads are never above
21 cases and since January 2022 through February 2023, caseloads would average at 17.5 cases per
caseworker and have remained relatively low between 16 and 19 cases.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Both graphs taken together present useful insight into the adequacy of currently budged positions to
sustain the historical volume of reports received by the County. The first graph represents caseload
levels at optimal efficiency while the 90-day closing graph more closely reflects the Department’s
current efficiency level. Using data provided through Connections, we collectively averaged case
duration for each year during this period. We found that the average CPS case duration was
approximately 91 days (excluding 2020, as duration was artificially low, at 66 days, due to the remote
work environment brought on by the COVID-19 pandemic) and thus resembling that of the 90-day
closing graph. This suggests that if fully staffed, the Department would maintain average caseloads
above the 15-case recommended level.

Additionally, we calculated the number of caseworker positions needed to maintain caseloads of 15


cases if the average case closes in 90 days. We found that approximately 31 budgeted positions would
be needed, based on the number of SCR reports received by the County over the last year (March 1,
2022 – February 28, 2023). As in prior calculations, this includes omitting five caseworkers from those
available to take reports due to training, sickness or other factors. Thus, a total of 26 caseworkers on
average must be available to receive new cases to maintain caseloads of 15 cases with 90 day
closings.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

The previous calculations establish a baseline understanding of positions needed to fulfill state metric
requirements in optimal circumstances. Further discussion of this topic should consider Department
budgeted positions in light of current circumstances. We acknowledge that the calculations do not
specifically account for factors that cause above normal work burden at a particular point in time, such
as periods of high turnover and cases of greater complexity (e.g. cases involving legal proceedings or
child removals). We note that as of February 2023, the Department had approximately 22 caseworkers
available for reports, one caseworker less than the number required to maintain optimal caseloads at
60 day efficiency, based on the number of SCR cases in the previous 12 months. Additionally, the
Department is approximately nine caseworkers short of maintaining their real average closing time of
nearly 90 days. Considering the calculations presented in this section, we do recommend that the
County consider the analysis above when determining whether additional caseworker resources
should be allocated.

IV. Ongoing Children’s Services


BACKGROUND

The Ongoing Children’s Services division at Jefferson County Department of Social Services (JCDSS)
provides support to families by addressing threats to the safety and well-being of the child/children
and minimizes the likelihood that similar concerns will develop in the future. Per NYS OCFS guidelines,
preventive services are supportive and rehabilitative services that are provided to children and families
to prevent the removal of children from their homes. These services are also provided to children and
families after a child has been removed from the home. In most cases, preventive services are part of
the reasonable efforts that the County must prove to avert foster care placement.

The Ongoing Division of the County’s DSS consists of two Foster Care/Preventive Ongoing units and
one Specialized unit. One of the two Foster Care/Preventive units is a designated training team. New
hires placed in the Ongoing division remain in this unit throughout the duration of their in-person,
remote or hybrid OCFS Albany training and for an average of six months to two years depending on
their progress and their previous job experience. If or when they rotate to the Specialized unit, or the
other Foster Care/Preventive Services unit is often influenced by the influx of new staff. Each of the
three units consist of one Grade B Supervisor, one Sr. Caseworker and approximately six to seven
caseworkers.

Caseworkers in the Foster Care/Preventive Ongoing Division are assigned and handle both protective
and preventive services cases (non-placement) and placement cases. Placement cases include
situations in which the child is placed in the care and custody of the County via Foster Care or are
placed with relatives/suitable others via an Article 10 placement. Caseworkers in the Specialized unit
handle secondary cases from other counties, Juvenile Delinquency, and Article 10 custody cases.
Specialized caseworkers also conduct home studies for relative resources and emergency placements
and carry an adoption caseload. The Sr. Specialized Caseworker is the Department’s designated
foster care home finder. Two caseworkers in the Specialized unit are also designated Person In Need
of Supervision (PINS) workers and are assigned these cases.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Except for PINS and Juvenile Delinquency (see below) all cases are advanced/transferred to the
Ongoing unit from the CPS unit. Historically, Ongoing handles cases if services are court-ordered; the
Department does not typically offer nor monitor non-court-ordered services. An abbreviated version of
the transition process, which has evolved over the year, is as follows:

x The CPS Caseworker or the Grade B Supervisor will send an email to the Grade A Supervisor
/ Director of Services and the Floating / Designated CPS Caseworker.
x The Grade A Supervisor assigns the case to one of the three units based on rotation/caseload,
and case circumstances.
x Respective Grade B Supervisor or the Sr. reviews the case and assigns the case to an actual
caseworker. Timing varies but typically, cases are assigned within three business days of
when CPS is ready to transition the case.
x CPS Caseworker completes a Case Transfer Form and provides it to the Floating Senior
Caseworker.
x CPS Sr or Supervisor schedules a Case Transfer Meeting (within one week of case
assignment). Once the transfer meeting is held, all ongoing casework is the responsibility of
the Ongoing Caseworker. A soft-hand off typically happens at court, home-visit or DSS visit.
Typically, initial FASPs are to be completed by CPS Caseworkers.

PINS referrals originate from CPS, schools, and parents. PINS cases provide preventive, voluntary
services for children ages 11 to 17 with truancy and behavioral issues. These services are intended
to keep the child/family out of court and minimize likelihood that it becomes an active CPS case. The
Grade B Supervisor of the Specialized unit assesses each incoming referral and assigns it to the PINS
caseworkers. A portion of referrals get declined based on the case circumstances, what services are
already in place or have been offered and the family’s willingness to cooperate with the Department.
In general, workers from Youth Advocate Program (YAP), an external organization, are assigned the
Case Planner (CP) role in Connections and perform twice weekly contacts with the family. One of two
DSS Ongoing/PINS caseworkers are assigned the Case Manager role to oversee the case. During
our interviews, PINS caseworkers estimated that they had about 20 open cases with an anticipated
four that are scheduled for intake in the next two weeks.

Currently, the County contracts with Children’s Home of Jefferson County (CHJC) and the House of
Good Shepard (HGS) and a few other voluntary agencies to provide or arrange for various in-home
preventive services, such as individual, group and family counseling, mentoring, school and
community advocacy and psychiatric and psychological services, for at risk youth and families. In
general, when Homefinding is unable to locate relatives that are willing and able to care for a child,
when the relative placement fails or when a child with special or therapeutic needs enters care, the
department makes a referral to a therapeutic level. The County also contracts with these agencies and
a handful of others to provide direct placement for children that, due to a variety of issues including
unique needs of the children, cannot be placed in one of the County’s local foster homes. CHJC and
HGS also recruit, train and certify prospective foster parents throughout the county and the
surrounding communities.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

The expectation of the external agency’s caseworker and case planner as well as the extent of the
County’s mandated oversight in these types of cases are outlined in the respective testing section on
the following pages.

QUALITY CONTROL TESTING AND APPROACH

Like CPS investigations, the extent of alleged abuse/neglect, the family composition, and the case
circumstances vary significantly from one case to another. However, unlike CPS investigations, OCFS
does not provide extensive regulatory requirements that we can rely on to measure the quality of
preventive services casework. Thus, we also rely on our experiences with other LDSSs and our
professional judgement to assess documented casework and identify department practices and trends
that may affect the safety and wellbeing of children.

Our Ongoing procedures are organized into three sections. In the first section titled Preventive
Services Case Review Results, we assessed 15 in-home preventive services case compliance with
OCFS regulations, the Federal Children and Family Services Reviews Onsite Review Instrument
(CFSR OSRI) and activities that we consider best practice. In the section titled Foster Care Services
Case Review Results, we assessed 15 cases in which children were removed from their homes and
placed in the care and custody of the County via a court order with applicable OCFS regulations, the
CFSR OSRI and best practices. In the third and final section titled Title IV-E Foster Care Eligibility
Review, we walked through the County’s Title IV-E procedures and interviewed staff responsible for
determining and documenting eligibility to identify potential control design gaps, process inefficiencies
and opportunities for additional federal reimbursement. We also tested a sample of active cases to
identify potential trends in internal process limitations that prevented a IV-E eligibility determination
independent of case circumstances.

SAMPLING METHODOLOGY AND APPROACH

Bonadio requested and obtained a Cognos report of all children active in at least one of the following
four program choices: Preventive Mandated, Protective, Non-LDSS Custody- Relative/Resource
Placement and LDSS Custody Placement for the period November 1, 2021, through October 31, 2022.
Per the Cognos report, 290 children in 146 cases were active in at least one of these program choices
at the end of our defined scope period. The chart below represents the number of children in each of
the program choice as of October 31, 2022.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Please note,
x At a minimum, except for PINs and JD cases, all children are active in a Protective program
choice.
x The average number of children per case was two. The largest case consisted of eight children.
x Children (siblings) under the same case ID may be active in different program choices.
x There are multiple cases in the listing that were primarily the responsibility of another LDSS
and JCDSS only played a secondary role. In general, secondary responsibility is assigned to
the LDSS where the alleged subject of the case or the youth reside when it is different than
where the maltreated or abused child(ren) reside. For instance, per our reconciliation of the
Cognos report, 105 children with a Placement Program Choice 1, including children that had
been trial discharged, were in the County’s care as of October 31, 2022. The remaining
Placement cases represented cases in which the County had been assigned secondary
responsibility
x Many children were active in more than one program choice and/or changed program choices
during our scope period. For instance, a child may have been initially placed with relatives for
several months and thus, active in a Protective and a Non-LDSS Custody program choice. If
the child is later removed and placed in the care and custody of the county, the child will be
considered active in a Placement program choice.

From the listing, and in accordance with our PSA, we judgmentally selected 15 preventive services
cases and 15 foster care cases. For consistency purposes, we considered all cases in which a child
was removed from their place of residence and physically placed in a substitute care setting under the
care and responsibility of the County via a court order as a foster care case. The breakout of 15
Preventive Services cases and program choices were as follows:

x One Preventive Mandated; a neglect petition was not filed, and no safety factors were noted.
This case was a PINS case and was referred to the Ongoing unit and assigned to a YAP CP.

x 14 Protective cases with a CPS Safety Decision 3 or 4. These cases were transferred to the
Ongoing unit from Investigations and the families were court ordered to comply with services.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

o Six cases with a Protective only program choice and handled/overseen by the
Department; the children remained with their parents/caretakers in their house
throughout the duration of our scope period.
o Two cases with an additional program choice Non-LDSS Custody and
handled/overseen by the Department. These children were placed with a relative
resource at case initiation or at some point throughout our scope period.
o Two cases with an additional program choice Non-LDSS Custody and assigned to a
contracted external agency.
o Two cases with a Protective only program choice and assigned to contracted external
agency.
o One case with additional program choices Non-LDSS Custody and Placement. These
children were initially placed with a relative resource as of the case initiation date and
subsequently placed into foster care towards the end of our scope period.
o One case that the County has been assigned secondary responsibility to another
LDSSs outside of NYS and Jefferson County.

Our placement case selection included nine cases that were assigned to and handled by the
Department. CHJC or HGS were assigned roles in the other six cases.

PREVENTIVE SERVICES CASE REVIEW RESULTS

1. FAMILY ASSESSMENT AND SERVICE PLANS

FASPs are documents that guide a family and their worker while receiving county services. These
documents list the family composition, CPS safety factors and summarize the original reason for case
opening. The document also includes a section on the family service plan which requires the
caseworker to identify each problem/concern, define desired outcome/achievement, expectations of
the family and the caseworker’s specific actions that will help the family reach these goals. These
documents are agreed to and signed by both the caseworker and the family receiving services and
are the critical first step in all ongoing cases.

Per OCFS, the Initial FASP must be completed within 30 days of the case initiation date (CID). The
CID is the date a case is advanced from a Family Service Intake (FSI) stage to the Family Services
Stage (FSS) in Connections and is also the date that OCFS considers the beginning of the ongoing
service period. Cases are generally advanced to the FSS stage on the day the neglect petition was
filed, the services application date or the date the initial court hearing was held. CIDs can also reflect
the date a safety plan was enacted or the date a payment line was added to the case. In most cases,
the CPS investigation is still open and ongoing when the FSS is launched. CPS caseworkers are
expected to complete the majority of the Initial FASP while the assigned Ongoing caseworker is
responsible for completing the Family Services Plan – Outcomes and Activities. Post case transfer,
the Ongoing caseworker is responsible for completing the remaining FASPs. Per our interviews, by
the time cases are transferred to the Ongoing unit from Investigations, many are already over-due.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

No. of Positive
Criteria Tested Cases Compliant Compliance
with Criteria Rate
Initial FASP completed within 30 days of CID 1/15 7%
Comprehensive FASP completed within 90 days of CID 4/12 33%
Reassessment FASP completed within 210 days of CID 5/6 83%
Reassessment 2 FASP completed 6 months after 1/1 100%
Reassessment 1

Of the 15 cases we reviewed, the Initial FASP was completed on time in only one case. For the
remaining 14 cases, FASPs were completed on average, 34 days past the due date. In three cases,
the FASPs were 2+ months overdue. While the compliance rate associated with Comprehensive
FASPs were higher than Initial FASPs, we still noted a concerning trend. In the most extreme case of
non-compliance, we noted a case that was 96 days over-due. It is important to note that timely
completion of FASPs (specifically the initial FASP) in most counties is an ongoing issue. FASPs are
notoriously time-consuming and often not a priority given the rate of new and ongoing investigations
relative to the number of investigative caseworkers available to perform the casework.

2. FREQUENCY OF CASEWORK CONTACT WITH FAMILY RECEIVING SERVICES

Frequent and consistent casework contact is crucial to establishing a relationship with the family, and
effectively assessing the family’s response to the mandated services. Per the OCFS Preventive
Services Manual, there must be a minimum of 12 casework contacts with a child and/or family
receiving services within each six-month period of service beginning at the CID. The CID typically
correlates to the date case a was opened for services.

No. of Cases Positive


Criteria Tested Compliant with Compliance
Criteria Rate
12 Casework Contacts Within 6-Month Period 8/9 89%

OCFS does not explicitly state that the casework contact is spread out evenly over the service period;
however, the Department strives to make casework contact on a consistent and bi-monthly basis.
Since this criterion only applied to 2/3 of our sample, we assessed frequency of casework contact in
newer cases, defined by cases open for less than six months. We performed this step to identify any
potential emerging trends in newer cases that may affect child safety and well-being as well as the
timelines of when releases are signed by parents and referrals are submitted to providers.

No. of Cases Positive


Criteria Tested Compliant with Compliance
Criteria Rate
Two Casework Contacts per Month 4/6 67%

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

We note that the following two of the four cases did not meet the criteria and had significant gaps in
casework activity.

x No documented casework activity for 47 days - During the period of casework inactivity,
the case had remained with the CPS caseworker, who had filed the original neglect
petition, attended court for the initial court appearance and attended court for the
subsequent hearing 47 days later. During this time, the Department did not have contact
with the family, nor did they facilitate court-ordered preventive services.
It was not until the case had been transferred to an Ongoing caseworker (two weeks after
the subsequent court hearing and 4.5 months after the services case opened) that the
service provider referrals were submitted and consistent face to face contact resumed.

x No documented contact with the children for 60+ days – The CPS caseworker
submitted the children’s referrals shortly after opening the case for services. Per progress
notes, the case was transferred to Ongoing approximately five weeks after the case was
opened for services but neither Ongoing or CPS had contact with the children as of the
date the progress notes were printed and provided to us. As of February 2023, there was
no evidence that face-to-face contact with the children had yet occurred.

3. FREQUENCY AND EXTENT OF SUPERVISORY REVIEW / CASE CONFERENCES

According to our interviews, Ongoing caseworkers are expected to meet with their supervisor once a
month for a formal conference for all cases with a Protective program choice while Ongoing PINS
caseworkers and their supervisors meet in person, at a minimum, monthly with YAP and other
contracted agencies (CHJF/HGS). Case conferences should be documented as a progress note;
however, the person ultimately responsible for entering the notes into Connections (the supervisor or
the caseworker) varies by unit and supervisor. Per the Monitoring Checklist, the CPS Monitor, a
position that is relatively unique to the Department and recently was split between two Sr. CPS
caseworkers, should hold case conferences “at least quarterly.” Typically, these meetings were held
in conjunction with monthly supervisor case conferences.

No. of Cases Positive


Criteria Tested Compliant with Compliance
Criteria Rate
Monthly Review Performed 3/14 21%

Overall, documented case conferences and supervisory reviews are an area of needed improvement
throughout the Unit as we noted a general lack of consistency in terms of meeting frequency as well
as meeting discussions and outcomes. For instance, in three cases, we noted zero evidence of
documented case conferences and/or supervisory reviews (this includes blind removals and case
transfer meetings) from either the Supervisor or the caseworker. In one of the three cases lacking any
evidence of supervisory review, the case had been assigned to HGS.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Per the FASP, the HGS Case Planner is expected to maintain contact with the Department’s Case
Manager (a role typically assigned to a Grade B Supervisor or a Specialized caseworker); however,
frequency of contact is not explicitly stated. The CM is also expected to arrange transportation, meet
with service providers, attend court, discuss case goals with the family and meet with the family on a
regular basis. In a separate case, we noted the blind removal and approval of a child’s trial discharge
were the only documented instances of supervisory review. In another case, case conferences were
documented bi-monthly by the Sr. CPS caseworker (prior to transfer) and the Grade B Supervisor.

4. PROGRESS NOTES INPUT WITHIN 30 DAYS OF CASE EVENT

OCFS guidelines state that progress notes should be input within 30 days of the case event. This
ensures both relevance of the content and accuracy of the progress notes.

No. of Cases Positive


Criteria Tested Compliant with Compliance
Criteria Rate
Notes Input within 30 Days of Event 13/15 87%

Ongoings’ compliance with this metric is an area of strength. We noted a general trend of case activity
logged on the actual event date or within the week; however, in one case, we noted critical casework
activity, including face to face contacts and referrals to service providers were input between 12- 16
weeks post event date, well past the 30-day mark. While this finding may be concerning, we want to
emphasize three points:

x In the case with notes input 3-4 months post event, face to face contact with the family was
documented more than the OCFS required frequency. Overall, the family appeared engaged
with the worker and the parents demonstrated progress with their court-ordered services.
x Post transfer, we did not identify a single instance of a case note entered by anyone other than
the assigned Ongoing caseworker. This includes actions that could have been performed and
documented by a CSW including initiating phone contact with a service provider, faxing
referrals, and drafting letters for family court.
x The children were in placement for the shortest amount of time compared to all our cases we
had reviewed. At the end of our scope period, the caseworker had sought and received
approval from the Department’s CPS Monitor to trial discharge the children after just 6 months
of placement with a relative.

Overall, these points lessen the negative impact of late notes on the case progress.

5. TIMELINESS OF REFERRALS TO CONTRACTED SERVICES

At the initiation of all services cases and before any actual ongoing casework can be performed, the
caseworker must obtain a signed application for services from the parent(s), and advise them about
what, when and where services will be provided.

26
Operational Analysis of the Child Welfare Division of Jefferson County DSS

Families must voluntarily authorize the use/disclosure/exchange of any identifiable health information
to the Department via a signed Authorization for ROI form. For each individual or organization
providing the service that the family is referred to, the Department must also obtain and submit a
signed ROI and individual referral. Performing these duties are crucial as the longer they are
outstanding, the longer the family is not receiving services and thus, able to work toward their agreed
upon goals. Please note, we excluded the PINS case assigned to a YAP CP from this test.

No. of Cases Positive


Criteria Tested Compliant with Compliance
Criteria Rate
Referrals Submitted Timely to Providers 13/14 93%

This was an additional area of strength within the Department. In many of the cases, the Department’s
CPS caseworkers obtained the signed services application and ROIs from the family at their house or
at court and provider releases were submitted via fax by a CSW shortly thereafter. These actions were
typically completed prior to the informal or formal case transfer. We did identify one case in which
referrals to Family Counseling Services for the Nurturing Parent program and Community Clinic of
Jefferson County were not submitted until 18 weeks after the CID and 9 weeks after the initial court
hearing. It is also relevant to note that this case was transferred to Ongoing from Investigations later
than the other cases we reviewed. This case outlier emphasizes the importance of a timely case
transfer and tracking of critical case activity, especially at the initiation of a services case.

6. PERIODIC UPDATES OBTAINED FROM CONTRACTED SERVICE PROVIDERS

In general, the Ongoing caseworker (or the Case Planner) is responsible for case planning and
ensuring that all participants are actively engaged in services. In conjunction with this, the Ongoing
caseworker must obtain updates from service providers at relevant points in the case. There is no
defined period according to OCFS nor the OSRI; however, to measure progress (e.g., results of drug
screens and attendance) and to brainstorm alternative ways to re-engage individuals, initiating and/or
maintaining communication with service providers are generally expected to be performed consistently
but vary on a case by case and individual basis. For most services, we considered less than monthly
but more than quarterly an ideal frequency. We also considered the extent of communication with
schools for school-aged children if the case circumstances (e.g., anxiety, attendance) warranted
additional communication.

Positive
Criteria Tested Compliance
Rate
Periodic Updates Obtained from Contracted Service Providers 93%

Overall, we noted that obtaining periodic updates from and maintaining communication with service
providers once referrals were submitted was excellent.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Furthermore, we noted that Department caseworkers were able to drug test parents during home
visits- case activity we have not seen being used in other counties. In addition to direct contact with
service providers, same-day drug testing, pending documented consent, was often an effective and
efficient means to confirm the status of parent’s drug use and adherence to court-orders.

FOSTER CARE CASE REVIEW RESULTS

For testing purposes, we selected 15 cases in which children were removed from their homes and
placed into Relative/Resource Placement or Jefferson County DSS Custody Placement from a listing
for the 12-month period November 1, 2021, through October 31, 2022. We split our case review results
and related observations into three sections- child safety and well-being, permanency, and overall
internal operating procedures. Due to the subjective nature of certain aspects of a case review and
the interpretation of OSRI guidelines, we used our professional judgement to categorize each of the
various items in one of the three sections and to assess the extent that the Department was achieving
these desired outcomes and the documented way they did so. Please note, these items represent a
combination of OCFS requirements, OSRI guidelines and overall best practices we identified through
our experiences performing child welfare reviews.

SECTION 1: SAFETY AND WELL-BEING OF CHILDREN IN CARE

1. FREQUENCY AND LOCATION OF FACE-TO-FACE CONTACT WITH CHILD


Per OCFS, during the first 30 days of placement, caseworkers must have contact with the children as
often as necessary to implement the services and at a minimum, twice. Furthermore, at least one of
the initial contacts must take place at the child’s placement location. Please note, two of the 15 cases
were opened, and children were placed into care or free for adoption well in advance of our scope
period and therefore, this criteria did not apply.

No. of Cases Positive


Criteria Tested Compliant with Compliance
Criteria Rate
Children seen twice within the first 30 days of placement. 12/13 92%

The first contact was at the placement location 13/13 100%


After the 1st 30 days of placement, caseworkers had face- 15/15 100%
to-face contact with the child and those caring for them at
least monthly.
At least two of the monthly contacts every 90 days were at 15/15 100%
the child’s placement location

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Compliance with this policy directive is excellent. In many of the cases we reviewed, JCDSS
caseworkers or case planners from external agencies had face-to-face contact with the children more
than the requirement. While caseworkers rarely supervise visits themselves, we noted many instances
in which the caseworker relied on family visits, which occurred in the DSS building, to observe the
children and the family’s interactions and obtain parents signatures for ROIs in addition to regular visits
in the child’s placement location. The one case that did not meet the criteria was a case assigned to
HGS in which the children were only seen once within the first 30 days of placement. Both the HGS
caseworker and the JDSS CM performed the joint, initial contact, which took place 28 days after
placement. Per the March 2020 JCDSS Interagency Partnership with the HGS Protocol and CHJC the
HGS caseworker is responsible for, among other duties, completing casework contacts per regulatory
requirements to assess for safety and promote permanency planning. Per the progress notes, the
JCDSS CM contacted the assigned HGS caseworker multiple times to schedule a home visit.

2. STABILITY OF CHILD PLACEMENT


Foster care is intended to be a temporary and safe arrangement for children until they can safely return
home or to another planned permanent arrangement. In addition to frequent and consistent face to
face contact with children, the department has an obligation to continually assess the safety and
appropriateness of the child placement and initiate a change in placement if/when it is deemed to be
in the best interest of the child and consistent with achieving the child’s permanency goal.

No. of Cases Positive


Criteria Tested Compliant with Compliance
Criteria Rate
Children in Stable Placement 14/15 93%

Changes in Placement Were in the Best Interest of the Child 4/4 100%

In the majority of the cases we reviewed, children were placed and remained in a stable home
environment. However, we did identify three cases in which a documented potential or actual
placement issue was appropriately followed up on.

x A child was initially removed from her mother and placed with biological father and
grandmother who allowed contact between the (maltreated) child and her mother. Following a
CPS investigation, the caseworker deemed the father and grandmother were unwilling and
unable to protect the child, held a crisis intervention supervisor meeting and transported the
child herself to a respite foster home while they searched for a more permanent placement.
x The child was initially placed with his maternal aunt via an Article 10 Placement. During the
initial home visit and prior to case transfer, the CPS caseworker placed the child into temporary
respite and initiated a longer-term placement option for the child, citing various issues with the
maternal aunt's unsafe relationship with her live-in boyfriend. The caseworker consulted with
the aunt, they both agreed that she was already overwhelmed with her own children and it
would be in the children’s best interest to be placed in foster care.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

x A caseworker performed an unannounced home visit upon receiving notification that the foster
parent possibly harmed the child. The allegations were deemed unfounded and the children
remained in the home, with no other issues noted.
In one of the most complex cases, we did note ongoing concerns with children that were placed with
relatives via a kinship arrangement. The foster parents expressed frustration with the situation multiple
times and even stated they “wanted the kids removed.” The foster parents also appeared to disregard
cout-ordered custody arrangements, allowing one of the children to reside with her father, who was
the subject of CPS investigations, the majority of the time. While the case circumstances were not
ideal, it was evident in progress notes that supervisors were actively involved in the case and working
on alternative placement arrangements.

SECTION 2: CHILD PERMANANCY

3. VISITING WITH PARENTS AND SIBLINGS IN FOSTER CARE


Consistent and frequent visitation between a child in foster care and a parent / legal guardian can
significantly increase the likelihood of successful reunification. Parent-child visits can also minimize
the time the child spends in foster care, the associated costs, and can reduce the negative effects of
separation for both the parent and child. The frequency and location of court-ordered visitations varied
by case. In general, we noted the following:

x Visitations occurred at the lower level of the DSS building.


x Families were granted two hours visits two to three days a week.
x Visitations were supervised by a JCDSS CSW, HGS CP or CHJC CP.
x Progress notes were often detailed, demonstrating that the supervisor was attentive.
x Volunteer Transportation Center (VTC) often provided transportation to and from the agency
for the children and/or parents.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

To assess whether the department made concerted efforts to ensure visitation between a child in
foster care and their mother, father and/or siblings was of sufficient frequency to promote the continuity
in the child’s relationship, we reviewed cases to determine if the visitations were following court order
and if there were any trends in cancellations due to a lack of agency resources, transportation issues
and/or overall lack of communication between the third party transportation agency, foster parents and
biological parents. We also used visitation notes, the number of no-shows and lack of follow-ups by
the parents as a basis for whether the department appropriately continued or modified the child’s
permanency goals. Please note, 1 of the 15 cases did not apply as CID date reflected the date the
child was freed for adoption and thus, parental rights were terminated.

No. of Cases Positive


Criteria Tested Compliant Compliance
with Criteria Rate
Concerted Efforts Made to Ensure Visitation Was Sufficient to 14/14 100%
Promote Continuity Between Child and Family

Compliance with this permanency item is excellent and an additional area of strength within the
Department. We did not identify any instances of cancelled visits due to the department’s resources
or other problematic trends. Instead, we noted extensive coordination between the caseworker and
VTC, parents and foster parents to establish, cancel and reschedule ever-changing transportation
needs and accommodate parents’ adherence to scheduled visits, even in cases where the children
were placed through CHJC or HGS. In many cases, when a child or another family member was
exposed to COVID, which was prevalent during our review period, the caseworker had to email VTC,
the resolution center, parents, and the CSW Supervisor to inform them of the situation, cancel and
reschedule visitation based on everyone’s availability. We also identified multiple instances of parents
failing to appear for transportation on time. Caseworkers appeared to remain compassionate and
diligent, even when VTC threatened to terminate future transportation services for parents with
attendance issues. One client even expressed interest in being a caseworker following her experience
with the department. While this is an additional area of strength, the time caseworkers devoted to
ensuring quality and consistent visitation occurred was surprising. We firmly believe that this is an area
where CSWs could contribute more to alleviate work from caseworkers.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

4. RELATIVE PLACEMENT
Prior to placement, OCFS and OSRI require that caseworkers make diligent efforts to identify relatives
and suitable others (e.g., family friends) that are willing and able to be a temporary or permanent
resources. While neither agency explicitly state how to measure a department’s adherence to this, we
reviewed progress notes to determine if caseworkers documented their discussions with parents on
this topic and the extent that they followed up with relatives. For each case, we also reviewed the
Triage Team Placement Referral form to verify it was completed timely. This caseworker is required
to complete and send this form to the Triage Team at or around the time of removal in situations where
there is not an immediate home identified. Please note, two of the 15 cases were opened, or the
children were freed for adoption prior to of our scope and therefore, these criteria did not apply.

No. of Cases
Criteria Tested Compliant with Rating
Criteria
Concerted Efforts Made to Place Child with Relatives 13/13 100%
Placement Finding Referral Submitted Timely for Children 12/13 92%
without Immediate Home Identified

In each case, we noted documented evidence of both initial and ongoing (or attempts at) discussions
with families to identify names of potential resources. Often, Caseworkers provided family members
with directives on how to petition the court ongoing support as they navigated the legal realm. In one
case, we noted a caseworker made multiple, documented attempts at contacting the maternal aunt of
a child who had been in different therapeutic homes throughout the duration of her time in care. We
also noted the Placement Finding Referral forms were submitted timely. In one of 13 cases, The Triage
Referral form was missing; however, the child was eventually placed in a CHJC foster home that
eventually adopted him.

5. ACHIEVING PERMANANCY GOALS

Per OCFS, each child with a permanency planning goal (PPG) of return to parents and who have been
in care for 15 of the most recent 22 month must either be discharged from care or the LDSS must file
a petition to terminate parental rights. If the child cannot be returned home, other permanency goals
include discharge to adoption, discharge to relatives or, for children who have reached the age of 18,
are released to their own responsibility.

No. of Cases Positive


Criteria Tested Compliant Compliance
with Criteria Rate
Appropriate Permanency Goals Were Established Timely 15/15 100%
Concerted Efforts Made to Achieve Reunification, Guardianship, 15/15 100%
Adoption or Other Planned Permanent Living Arrangement

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Overall, this is another area of strength within the department. Given the subjective nature of this
criteria and the difficulty to assess permanency efforts in an objective manner, we reviewed progress
notes to determine if caseworkers had consistent discussions with foster parents and biological
parents regarding the child’s permanency plan relative to the parent’s overall progress with services.
In cases in which the PPG remained ‘returned to parent’ we confirmed that there was evidence that
parents successfully completed court-ordered services, remained compliant with visitation, and
appeared eager to reunite with their children.

Likewise, when parents continued to struggle with services and/or consistently missed visitations, we
confirmed that caseworkers remained in contact with the biological parents and encouraged them,
where appropriate, to surrender their parental rights and remained transparent with the foster parent
regarding whether they are a willing to be a pre-adoptive home. In one case, the foster parent explicitly
stated they were not viable long-term resource. The caseworker worked diligently to move the child
to a pre-adoptive home and maintained consistent visits with the biological parents to change their
parenting techniques and identify alternative resources for the child.

In addition to case review, we assessed and compared the County’s discharge rates for a 12-month
period to other counties. Please refer to the chart below.

Per our analysis, the average length of time a child was in care in Jefferson County during the 12-
month period ending June 30, 2022 (23.2 months) was shorter than any other county we’ve recently
assessed. We also reviewed discharge detail for the eight-month period from June 2022 through
February 2023, noting that the average length of time decreased 14% from 23.2 months to 20 months.
These statistics alone may not speak to the quality of the Department’s ongoing casework as children
could be prematurely discharged from care; however, we believe that these statistics combined with
our case review results demonstrate the Department’s strengths in ongoing casework and overall
commitment to permanency planning.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

SECTION 3: INTERNAL OPERATING PROCEDURES

6. PLACEMENT WITH SIBLINGS


Per OCFS 18 CRR-NY 431.10 and 92-ADM-24, children must be placed with their siblings or half-
siblings, unless doing so could jeopardize the health, well-being, or safety of the children in the sibling
group. Please note, the child had no siblings in foster care during our period of review in three of the
15 cases and therefore, this criteria did not apply.

No. of Cases
Criteria Tested Compliant Rating
with Criteria
Concerted Efforts Made to Ensure Siblings Placed Together 11/12 92%

We acknowledge that separating siblings is unfortunately inevitable at times due to a variety of


circumstances outside of the department’s control, such as children’s mental health needs and
behavioral issues and a family’s willingness to be a permanent resource for all the children. In general,
we reviewed each case to determine if there were trends in separating the children due to a lack of
foster homes willing to take the foster groups and, if/when separation became an issue, the department
made diligent and timely efforts to identify a foster home that was willing and able to accept children,
while maintaining permanency goals.

Consistent with OCFS’s defined threshold of strong as an 85% or greater compliance, we noted this
was an additional area of strength in the department. We noted one case in which siblings were
separated and efforts to ensure they were placed together were not documented; however, the
children were 15 years apart and the older child was placed in a therapeutic foster care program. Per
the FASP and progress notes, the children have monthly visitation with each other. In the remaining
three cases in which separating the children became an issue, the department consulted with a
Licensed Clinical Social Worker (LCSW) or a Family Support Advocate who conducted a Siblings
Separation Assessment to evaluate potential short and long-term effects of separation. In one of these
four cases, a relative to a child petitioned the court for custody of the child and was deemed an
excellent resource but was unwilling to care for the child’s half-sibling. After the LCSW consulted with
individuals who had regular interactions with the children, the department chose it was in the best
interest of the children to remain together.

7. FREQUENCY AND EXTENT OF SUPERVISORY REVIEW / CASE CONFERENCES

According to our interviews, Ongoing caseworkers are expected to meet with their supervisor for a
formal conference for all cases in person, at a minimum, monthly. Similar to our observations related
to supervisory review and case conferences within the Preventive case testing, conferences should
be documented as a progress note; however, the person ultimately responsible for entering the notes
into Connections (the supervisor or the caseworker) varies by unit and supervisor.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

No. of Cases Positive


Criteria Tested Compliant with Compliance
Criteria Rate
Monthly Review Performed 10/15 67%

Overall, documented case conferences and supervisory reviews are an area of needed improvement
throughout the Unit as we noted a general lack of consistency in terms of meeting required frequency,
especially in cases where an external agency is involved.

Per the March 2020 JCDSS Interagency Partnership Protocol with HGS and CHJC, the voluntary
agency caseworker and the JCDSS CP should schedule monthly face-to-face case conferences with
JCDSS and voluntary agency supervisors. These meetings are critical as each agency is responsible
for different facets of the case and must stay aware of each other’s progress and challenges, especially
in cases that include children in a therapeutic level of care.

8. JUSTIFICATION FOR ROOM AND BOARD RATE ABOVE THE TRADITIONAL RATE

In general, all children that come into care are assessed at a traditional rate, as opposed to a special
or therapeutic rate, to correspond with the level of difficulty (LOD) until the caseworker provides the
Department with a Board Rate Determination form and documentation regarding a mental and/or
physical diagnoses, signed by an MD or PHD to support the need for a higher level of care. Once the
Department receives the documentation, it is submitted to the Grade A Supervisor for review and
approval.

No. of Cases Positive


Criteria Tested Compliant Compliance
with Criteria Rate
Justification for Room and Board Rate Above the Traditional 4/4 100%
Rate Authorized by Grade A Supervisor or Director of Services
Current / Updated Medical Documentation Exists to Support 2/4 50%
current board rate above traditional

Per our interviews, children should be reassessed every six months as children’s foster care board
rates correspond with adoption subsidy rates. We noted the following exceptions for two of the
cases we reviewed:

x Case x5810:
o Board Rate Determination form to request change from traditional/basic rate to
exceptional was authorized by the Grade A Supervisor; however, the form lacked
medical documentation.
o Board Rate Determination was approved on 12/31/21.
x Case x8320:
o Board Rate Determination form to request change from traditional/basic rate to
exceptional was most recently approved by the Director of Services on 4/9/19.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

BONADIO COMMENTARY REGARDING ONGOING CASE REVIEW

While the tools to objectively assess ongoing preventive monitoring casework at the LDSS level is not
nearly as explicit nor robust as they are in an OCFS OMA tool, as depicted throughout our case review
results, quality and timely casework is just as crucial in maintaining child safety, well-being and
permanency. We want to highlight that, while both types of casework are overwhelming, stressful and
traumatizing, ongoing monitoring casework offers unique challenges. For instance, the average
investigations case must remain open for a minimum of 30 days and is closed, on average, sometime
between 60 and 90 days. OCFS does not dictate the duration of an ongoing monitoring case, but a
typical NYS preventive case is open for 12 to 24 months. Therefore, it is critical that documented,
supervisory appropriate oversight exists, and caseworkers receive timely and constructive feedback
on their work. The next section of this report captures our additional observations and
recommendations specific to Ongoing based on our test work and related observations. Please note
that most CPS observations and recommendations identified in Section V. General Child Welfare
Division Observations & Recommendations also apply to Ongoing.

ONGOING UNIT OBSERVATIONS AND RECOMMENDATIONS

1. QUALITY ASSURANCE

OBSERVATION:

Per our interviews, the Director of Services, the Grade A Supervisor, the Grade B Supervisors and the
senior caseworkers review one open CPS case pending close and one Ongoing case with OCFS in
person or virtually each month. The designated floating senior caseworker who reviews cases that are
transferred from CPS to Ongoing for face-to-face contacts and adherence to OCFS requirements such
as the federal Adoption and Foster Care Analysis and Reporting System (AFCARS) also maintains a
log of cases that they have reviewed to ensure their case selection is inclusive of all caseworkers.
Unless the caseworker whose case is subject to review requests to be in attendance, they usually do
not participate in the review. Meeting notes are maintained in a share drive accessible to all CPS and
Ongoing personnel. Per our review of the log, it includes case name, caseworker, supervisor, case
type (CPS or Ongoing) and review date. The log does not indicate what aspects of the case were
reviewed and results such as casework strengths, gaps and recommendations for improvement.

RECOMMENDATION:

The Department should enhance the current quality review process or establish a dedicated Quality
Assurance (QA) position that is committed exclusively to case review. It is important to note that some
form of QA either an individual or a team of individuals with extensive casework experience, has been
implemented in the more successful counties we have worked with. The focus of our recommendation
in this area is to improve the likelihood of the county’s continued and sustained success. A formal
internal QA process should include the following:

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

x Audit approach, scope, and sample selection process. Consistent with our selection process,
a designated individual should select a sample of cases across a pre-defined range of criteria
such as recently opened CPS cases, cases that have been advanced to an FSS stage in
Connections but have not been transferred to Ongoing, past due cases and those that have
recently closed.
x Indicate what attributes the reviewer will focus on for each case to identify emerging trends in
cases. This includes not only trends in individual casework but also trends in case
circumstances and family dynamics (e.g., allegations, needed services, collaboration with
schools, and mental health in children and parents).
x Track and assess staff skills and provide direct and timely feedback with the caseworker.
x Determine how case review results will be monitored for long-term trends.

2. BOARD RATE REDETERMINATION AND DOCUMENTATION

OBSERVATION:

Per Ongoing Case Review Results No. 8, the current process to review board rates is vague and
potentially unmonitored. This increases the likelihood that the Department is over-paying for a foster
child’s condition that is no longer applicable.

RECOMMENDATION:

We recommend the Department perform the following:

x Identify all children, per WMS, that are receiving a special or exceptional rate.
x Review most recent Board Rate Determination form to determine if updated medical
documentation is appropriate to maintain the increased board rate.
x On a go-forward basis, determine, document, and communicate the Department’s updated
procedures and expectations for caseworkers. For instance, the Department should review
Board Rate Determination forms annually for all children with special rates and every other
year for children with exceptional rates. The Director of Services or Grade A Supervisor will
determine, based on the circumstances, if the caseworker should request updated medical
documentation is to maintain the increase in board rate.

3. GRADE A POSITION OVER ONGOING

OBSERVATION:

Per our interviews and case reviews, consistent, quality supervisory review with critical feedback was
one of the largest issues noted. Furthermore, as depicted in our Ongoing Case Review Results No. 2
Frequency of Casework Contact with Family Receiving Services, 1/3 of the newer cases failed the
criteria regarding casework contact within the first 30 days of the CID.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

We firmly believe that any gaps in critical casework activity can be primarily attributed to a weak case
transfer process, large caseloads, a lack of consistent and robust supervisory oversight and newer,
less experienced caseworkers.

RECOMMENDATION:

Given the increase in case volume and complexity, the increase in PINS cases (staff estimated that
the Department receives two to three referrals a day) and the rate of staff turnover, we recommend
One Grade A be dedicated to CPS and the second Grade A Supervisor oversee Ongoing and Adult
Protective. Sharing the job responsibilities and meeting attendance based on the topic/need between
two experienced Grade A Supervisors will facilitate direct oversight and reprioritization of the case
transfer process (refer to Observation no. 4).

4. CASE TRANSFER PROCESS

OBSERVATION:

In addition to the points captured in Observation no. 3 above, we noted documented processes
governing the case transfer process, specifically the Case Transfer Checklist Part 1 and 2 and the
Opening a Case for Services desk-level guide appear vague, outdated and do not include due dates
associated with critical action items. Furthermore, many of the caseworkers we interviewed were either
unaware of the documents or were not sure where they were located.

RECOMMENDATION:

x The Supervisors of both CPS and Ongoing work together to update the Case Transfer
Checklists as well as the Opening a Case for Services document. These documents in their
current format appear vague and incomplete and were last updated in 2016 (approximately
seven years ago).
x The checklist should be reformatted with at least three columns: the action, the individual
responsible for completing the action and expected timeline and updated to include other
action items that may happen prior to, in conjunction or post transfer such as timing of face-
to-face contacts.
x Due to the rate of newer, less experienced CPS caseworkers, we recommend the Ongoing
Supervisors facilitate a training that is incorporated into all new CPS staff training to reinforce
the significance of the transfer process. In conjunction with training, CPS caseworkers should
understand what is expected of them when they transfer a case, the robust OCFS regulations
that start the day the case is FSS stage is opened, what an ongoing case entails and how to
complete an initial FASP.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

TITLE IV-E FOSTER CARE REVIEW

Background

Per our IV-E walkthrough of the Title IV-E Foster Care eligibility process, it is handled by the Case
Integrity Unit (CIU), which consists of one Sr. Eligibility Worker and one CSW/ Eligibility Worker. The
process is as follows:

1. A caseworker sends a Children’s Services Placement form to the CIU. This form will include
all relevant information for CIU to initiate the Connections placement process.
2. The worker performing the determination will complete LDS-4809 Initial Foster Care Eligibility
Checklist for each child. With the exception of the neglect petition and the removal order, which
is sent directly from the agency’s legal department, the workers are responsible for gathering
all relevant documentation including the birth certificate and income information as they
perform their eligibility review. Workers have appropriate access to FASPs and progress notes
in Connections as well as WMS to verify whether the family is receiving any non-services
support (HEAP, MA, TA, SNAP). Workers also access Work Number, a digital employment
and verification database and the Department of Labor to verify frequency and amount of any
unemployment benefits.
3. Eligibility determinations performed by the CSW are reviewed and approved by the Sr.
Eligibility Worker/CIU Supervisor. Likewise, determinations performed by the Sr. Eligibility
Worker/CIU Supervisor are approved by the Deputy Commissioner. All reviewed and
approved, cases are maintained via hard copy by case/family in locked file cabinets.

Per our reconciliation of the Cognos placement detail and the SSPS Forecast Foster Care Report
(refer to Observation No. 1) 105 children were in the County’s care as of October 31, 2022 and 78
children (approximately 74%) were deemed IV-E. Bonadio also obtained the Department’s November
18, 2022 Title IV-E Foster Care Enhanced Monitoring Review Results from OCFS for the period July
through September 2022, noting that the five cases selected for testing complied with eligibility
requirements. Per the Supervisor of the CIU, these results are consistent with prior period OCFS
results. Accordingly, we opted to analyze a sample of seven non-IV-E cases, which represent 25% of
the population of foster care cases, to verify eligibility determinations were accurate and to identify
potential opportunities for federal reimbursement. The chart on the next page depicts the eligibility
requirements that the seven cases did not meet per the Foster Care Eligibility Checklist.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

*Legal authority requirement includes contrary to the welfare/best interests of the child and reasonable efforts to prevent
removal

Procedures Performed

For each non-IV-E case, we reviewed case files to identify inaccurate determinations and trends in
internal processes that prevented a IV-E eligibility determination independent of case circumstances.
We also verified freed non-IV-E children were no longer coded 04 Temporary Assistance to Needy
Families - Emergency Assistance to Families (TANF- EAF) in WMS and their eligibility code was
changed 08 MA.

Overall, we noted all seven of the cases we reviewed contained circumstances that failed to meet
eligibility requirements and were beyond the department’s control. Case files were robust, readily
available upon request and appropriate documentation of countable income in the correct month
existed to support the determination. While we did not identify any instances of inaccurate
determinations or internal process limitations, we did identify opportunities for process enhancement
for the department’s consideration. These enhancements are captured below.

1. CURRENT LISTING OF FOSTER CARE CHILDREN BY IV-E STATUS

OBSERVATION:

To assess the population of Title IV-E eligible and non-IV-E eligible children and subsequently select
our sample of cases for testing purposes, we requested a listing of all children in the county’s care
and their respective IV-E determination as of the end of our scope period. Per the CIU Supervisor, the
CIU does not maintain such a listing and instead, they rely on the monthly auto-generated state SSPS
Forecast Foster Care report for service type 61 (regular service and maintenance) which lists children
by case number, vendor, vendor number, facility certification status and IV-E eligibility code for the
subsequent month’s service period.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

We compared the SSPS Forecast Foster Care report to the Cognos data warehouse report of all
children in a placement program choice as of the same date to ensure the SSPS Forecast Foster Care
report we used to select our non-IV-E case sample was complete. As noted in the case review section
of this report, we used the Cognos data warehouse report, which is generated from the NYS
Connections database, for our case review selections. Per our comparison of the two reports, we
noted the following discrepancies:

a) Two children’s placement had not been end-dated in Connections. Both children were
discharged in June 2022.
b) Four children were trial discharged and excluded from the SSPS Forecast Report. While room
and board costs for trial discharged children are not applicable, these children are technically
still in the county’s care and custody until they are fully discharged.
c) Three children who had been discharged in November and December 2022 (post report date)
were excluded from SSPS Forecast Report.

RECOMMENDATION:

To ensure the unit has an accurate depiction of all the children in the county’s care and WMS eligibility
coding reflects the determination and case circumstances, we recommend the following:

x Create and maintain a listing of all children in the county’s care. This listing should include
columns for placement date, reason for non-IV-E (if applicable), date freed for adoption and
trial discharge / discharge date. Including reason for non-IV-E is a best practice as the
County can easily isolate these cases and identify future trends in determinations.

x Reconcile the active listing of kids in care per department’s Foster Care listing to the
Connections Data Warehouse Foster Care Roster. Performing this reconciliation will also
help ensure that each child placed into care has been timely assessed for Title IV-E eligibility,
entered and discharged from Connections.

2. CURRENT LISTING OF FOSTER CARE CHILDREN BY TANF-EAF STATUS

OBSERVATION:

TANF-EAF is contingent on the child’s needs for services arising from a family emergency and meeting
all eligibility requirements. Unlike Title IV-E, TANF-EAF is block granted and therefore, funding is
limited by the state budget. Per the TANF/EAF Eligibility section of the most recently OCFS Eligibility
Manual for Child Welfare Programs, under New York’s “prior law” policy, TANF-EAF may be
authorized for as long as the needs arising from the emergency lasts. The emergency is defined as
ending when, among other things, the child is freed for adoption and placed in an adoptive home.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Per our case review, two of the seven children had been freed for adoption and their eligibility codes
had not been changed from 04- TANF-EAF to 08 MA. At the time of our testing in January 2023, one
child had been recently adopted and thus, discharged from foster care. We communicated these
finding to the CIU Supervisor who stated that she had not been familiar with this OCFS regulation but
would process the WMS eligibility coding immediately.

RECOMMENDATION:

We recommend the Department perform the following:

x Review the remaining TANF-EAF children in the County’s care that were not included in our
case review to identify those that have been legally freed for adoption.
x Process a retroactive entry in WMS and/or change the eligibility coding from an 04 to an 08
effective on the date the child was freed.
x In conjunction with Observation No. 1, update the Department’s listing of children in the
County’s care and their respective IV-E determination on a consistent basis but no less than
monthly to reflect critical case updates such as freed status, trial discharges and discharges
from the County’s care and custody.
x Compare the listing of active children in care with their respective eligibility determination to
the BICS Services Indirect Payment/Refund Roll report on a periodic basis. This will increase
the likelihood that WMS claiming is consistent with initial determinations and changing case
circumstances, and the County continues to claim and receive all eligible federal and state
funding reimbursement while remaining OCFS compliant.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

V. General Child Welfare Division Observations & Recommendations

1. SENSITIVE CASE PROTOCOL

OBSERVATION:

OCFS offers specific guidance on the types of CPS investigations that meet the sensitive report criteria
and how each Local Departments of Social Services (LDSS) should respond. When a case is marked
as “sensitive” in Connections, the case file is locked and is only accessible to the casework staff
assigned to that case. Per the most recently issued CPS manual, sensitive cases are defined as, but
are not limited to, cases in which a subject, child, or other person named in the report is a public figure;
works in CPS, the SCR, OCFS, or within the LDSS in a role where they are well known by the
investigator; or they personally know the CPS staff outside of a work relationship. Per 17-OCFS-
(LCM)-15 issued on August 28, 2017, SCR Jurisdiction Assignment of Sensitive CPS Intake Reports,
when the subject of the SCR report is a family member of a LDSS employee, it is appropriate for CPS
of an alternative jurisdiction to address the report to avoid a conflict of interest or an appearance of a
conflict of interest. Each LDSS is required to establish a documented Sensitive Case Assignment
Protocol, which details alternate arrangements with neighboring jurisdictions to handle such cases.
This protocol must be electronically submitted to the regional OCFS office and to the SCR.

During our engagement, we were notified by more than one caseworker about an open and ongoing
investigation that was initiated via the SCR in 2022. Please note, we did not request nor review this
case as it was outside of our scope period. Given the sensitive and complex nature of the investigation,
the department employee was extremely uncomfortable with how the Department (their employer)
was handling this case. Other workers also expressed discomfort and dissatisfaction with how the
case, and other past cases of similar circumstances was handled internally.

Per management, the Department received an after-hours report. The Director of Services did identify
the sensitive nature of the case and contacted the respective county that had agreed to investigate
the report based on the family’s zip code in accordance with their Sensitive Case Assignment Protocol;
however, that county declined the County’s request. Per further discussion with management, the
Director of Services did not have the Sensitive Case Assignment Protocol in her possession nor did
the on-call caseworker have a copy. It wasn’t until we continued to question the protocol that they
discovered that the unit had contacted the wrong county (who denied the request) as they mistakenly
assumed the family’s zip code fell into their jurisdiction.

Per our review of the Sensitive Case Protocol, we noted the following points of interest:
x The protocol was approved in October 2017 (over four years ago).
x The document is outdated. The individuals who signed and dated the protocol from the
surrounding counties, including Lewis, Oswego, and St. Lawrence, and even Jefferson, no
longer hold these positions.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

x The protocol does not specify what types of situations or conflicts warrants another County’s
involvement, follow up procedures if/when a designated alternate jurisdiction cannot
investigate the sensitive report and how the case will be handled post-investigation if the family
is need of ongoing preventive services.

RECOMMENDATION:

We recommend that the Department coordinate with current Directors of Services or Deputy
Commissioners of Lewis County, Oswego County, and St. Lawrence County and update the Sensitive
Case Assignment Protocol. The protocol should specify the following:

x Define specific case circumstances including, but not limited to, CPS history, the type of
allegations and the subject of the investigation that qualifies as a potential, perceived or actual
conflict of interest and should be handled by an alternate jurisdiction.
x Define specific case circumstances that may be sensitive (a TA Eligibility Worker within the
building is the subject of an investigation) but do not rise to the level that requires the case is
handled by an alternate jurisdiction. In these instances, the case, while retained by the
Department, should be marked sensitive in Connections to prevent Department staff other
than the assigned caseworker and their supervisor with access to relevant, case data.
x Define the case details (e.g., zip code associated with the address on the SCR Intake Report)
that will dictate which county is responsible for accepting the case and investigating the report.
x Retain evidence of communication with the counties.
x Ensure the SCR and on-call staff are aware of the updated Sensitive Case Assignment
Protocol and have access to the document. This will help to ensure that investigation cases
are handled in an objective manner and individual/family privacy is consistently upheld.

Given the size of the County and the likelihood they will experience potential conflicts of interest, we
also recommend the Director of Services and/or Deputy Commissioners meet on an annual basis to
update the protocol based on recent trends, issues, etc. This continued collaboration with surrounding
counties will help ensure sensitive matters are consistently and timely addressed, sensitive information
is protected, and actual and perceived conflicts of interest are avoided.

Lastly, we recommend the Department formally communicate their updated protocols with the entire
child welfare division. This communication should include steps a worker should follow in the event
they are assigned an investigation case that qualifies as sensitive but was not marked as such upon
receipt by the SCR. We acknowledge that, due to privacy requirements, caseworkers will not be
notified about an investigation unless they are the subject. However, providing clear and concise
protocols on how the Department will handle SCR reports based on case specific circumstances will
help ensure the protocols are followed, families are investigated by an objective source, and confusion
and apprehension are minimized.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

2. USE OF COMMUNITY SERVICE WORKERS

OBSERVATION:

Per our procedures, the Department employees a Senior LPN who, among other duties, supervises six
full-time Community Service Workers (CSWs). As of the date of our procedures, there was one vacant
CSW position. Given the amount of OCFS requirements (and associated paperwork) that accompanies
each investigation, ongoing and placement case, CSWs are often an asset to Departments. According
to our interviews, CPS CSWs, as their titles indicate, are primarily dedicated to CPS caseworkers and
are responsible for performing the following:

x Accepting all new reports from the SCR and entering them into Connections
x Sending out Notice of Existence (NOE) letters
x Answering and addressing phone calls received via (315) 785-3000. Clients typically call this
number with questions and complaints
x Supervising visitations for placement cases. Visitations are primarily held in the DSS office in
one of four designated visit rooms or in a separate, larger playroom
x Faxing referrals and other relevant documents (e.g., signed releases) to professional service
providers, schools and law enforcement and emailing CIU to add payment lines
x Transporting children (previously this was common but now it is performed on an emergency
basis only)
x Temporarily supervising children in the time between removal and placement

For routine tasks, such as uploading documents into Traverse or typing notes, caseworkers send mass
email requests to all the CSWs. Usually, the first person to respond will be responsible for completing
the task. CSWs stated that some days, they can receive up to 20 mass email requests. For larger,
more time-consuming tasks such as supervising visitations, caseworkers are encouraged to complete
a half-slip and submit it to the Senior LPN who will track and assign the request to a specific CSW.
Per our interviews with the CSWs, most of their requests (one estimated it to be more than 90%)
originate from CPS. Ongoing caseworkers stated that they rarely request assistance from CSWs and
only request their assistance if they are “behind” or “overwhelmed” with their caseload. We also noted
that CSWs were not involved in the continuous, often time-consuming process to maintain the
department’s IV-E Adoption Subsidy program. Currently, approximately 320 children receive subsidies
each month. According to our interviews, the Sr. Specialized Caseworker devotes a considerable
amount of time to scanning documents into Traverse, mailing annual recertifications to parents,
maintaining folders for OCFS compliance purposes and following up on IV-E eligibility status based
on age and assessed level of difficulty.

CSWs stated that they enjoy the variety between office, clerical work and in-person visits that the
position offers; however, they were currently experiencing an extended period of down-time when
there are not a lot of caseworker requests coming in. This issue is exacerbated when parents no-show
or cancel scheduled visitation appointments. CPS workers assumed the CSWs were incredibly busy.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

There seemed to be limited transparency in terms of what everyone’s actual availability is. While we
did note CSW utilization in Ongoing cases overall, we noted it was limited to faxing referrals, emailing
CIU to request payment lines being added to cases and supervising visitations. CSWs’ limited
involvement in Ongoing may be a direct result of the perception that CSWs are only available to
support CPS and that Ongoing caseworkers must be behind to request assistance. Inevitably, Ongoing
caseworkers are hesitant to request and receive much-needed assistance. This is troubling as
Ongoing cases are active for months, even years sometimes while the average CPS case is closed
between 60 and 90 days.

RECOMMENDATION:

To streamline processes, increase transparency into CSW utilization and availability and to ensure
CSWs assistance is maximized in both CPS and Ongoing units, we recommend the Department
reassign and integrate the CSWs directly into each of the CPS and Ongoing units and shift as many
IV-E Adoption Subsidy program maintenance tasks, including coordinating with legal to obtain
adoption decrees, to CSWs. It should be noted that years ago, the Department was organized in this
manner and two CSWs were dedicated to Ongoing. Per our interviews, after these CSWs
retired/resigned, the positions were reorganized. Returning to this structure should minimize the
volume of mass emails, eliminate the paper request forms, facilitate consistency among units, and
help ensure that Ongoing workers receive adequate and consistent CSW assistance without negative
connotation. We feel the Department should monitor this structure and adjust as needed to ensure
workload is consistently and appropriately distributed amongst CSWs.

We also recommend reallocating specific, time-consuming tasks applicable to Ongoing cases such as
coordinating visitation and transportation needs from Ongoing caseworkers to CSWs. In addition to
conducting face to face visits with families, preparing for court, following up with service providers and
acting as a liaison between foster parent and biological about any urgent matters, Ongoing
caseworkers spend a considerable amount of time coordinating transportation needs between the
contracted volunteer transportation agency, foster parents and biological parents. For instance,
caseworkers must complete and email transportation requests to external contracted volunteer
agencies and CIU for each new case and confirm with VTC at least 48 hours in advance of each visit.
Facilitating and accommodating ongoing transportation requests, cancellations, modifications etc.,
with VTC, foster family and parents can be incredibly time-consuming, especially when parents are
consistently late, are no-shows or fail to confirm their ride with the VTC the morning of the visit. In
more than one case, we saw the Grade B Supervisor intervene and help facilitate transportation needs
after the foster parents had expressed difficulty maintaining transportation needs for three different
children in their care. While Ongoing caseworkers appear to do an excellent job advocating for the
family and encouraging parents to comply with court-ordered visitation, this also appears to be an area
that would benefit from CSW involvement.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

3. WELLNESS BENEFITS

OBSERVATION:

Per our interviews with multiple employees, employee wellness benefits were something the County
was lacking. The role of a caseworker can be intense and extremely stressful. The County provides
two therapy sessions to those who have faced trauma. Caseworkers have an option to continue with
these services; however, they must use their own insurance benefits.

RECOMMENDATION:

We recommend that the County consider adding benefits targeted specifically toward employees’
mental and physical health. Many caseworkers expressed that physical fitness and/or therapy help
them to persevere in their role and avoid feeling burnout from the intensities of the job. Other counties
we have worked with have a contracted individual who acts as a designated counselor for caseworkers
to reach out to at any time to make an appointment. Similarly, several other organizations also offer
Employee Assistance Programs.

Offering more availability to mental health services and counseling would be a crucial benefit to provide
because caseworkers constantly witness trauma first-hand, experience secondary trauma when
listening to the stories of the families and children they are working with, and they hold a significant
amount of responsibility to protect the children on their caseloads. This can cause stress, anxiety, and
compassion fatigue. Any work-related issues such as these, as well as personal problems, can interfere
with a caseworker’s ability to perform the job well and ensure the safety of the County’s children. Giving
caseworkers an outlet to process the trauma they may face in the field every day, along with resources
to help them practice mindfulness, coping strategies, and self-care could potentially make a substantial,
positive difference in the quality of casework performed by JCDSS caseworkers.

4. EMPLOYEE SAFETY

OBSERVATION:

During our interviews, some staff identified caseworker safety as one of their concerns. Visits to a
child’s home can be tense, especially if a family member is accused of abuse or neglect. At times, the
caseworker encounters hostile individuals who openly threaten their safety. This is a consistent
concern for caseworkers in any county given the nature of their work. For example, one worker shared
that they had recently had a client who attempted to buy a weapon at a store and told the store
employee that he was going to kill his caseworker and their supervisor. They feared that the situation
could have easily escalated to a physical confrontation.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Currently, the Department has a contracted armed security guard through a private company inside the
front door of the building. Lobby reception desk workers are also supposed to check the internal flagged
database when people come in for visitation. The progress note screenshot below is an example of a
situation in which a caseworker has had to utilize security regarding a risky individual. When clients
come into the DSS building for visitation, they are supposed to leave their bags and are not allowed to
come in with them. However, workers claimed in our interviews that this protocol is not always followed
as strictly as it should be. Additionally, caseworkers told us that if they feel apprehensive about going
out in the field alone, they can bring another caseworker if someone is available or they can call the
police to come along as well.

RECOMMENDATION:

We recommend the County consider obtaining a metal detector for the DSS office lobby. Several of the
counties we have worked with utilize a metal detector as a safety precaution and overall deterrent at
their offices. This would ensure that security would be alerted if anyone attempted to sneak in a weapon
inside their bag or on their person when they come for visitation. We also recommend that the County
offers de-escalation classes at least once or twice a year for caseworkers. Safety classes like this were
something several caseworkers were interested in and were discussed in many of our interviews. With
these classes, caseworkers could learn how to protect themselves if they are ever placed in imminent
danger during a potentially hostile home visit or child removal. They could also be made aware of basic
mindful safety tips to practice, such as making their supervisor aware of where they will be when out in
the field, always making sure their iPads and phones are charged, having GPS location tracking
enabled on their county iPads, where to park at a client’s house to avoid being blocked in, and so on
and so forth.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

5. EMPLOYEE COMPENSATION

OBSERVATION:

JCDSS aims to retain high-performing, experienced caseworkers at all levels. Turnover is not only
costly to the County, but it is also disruptive and stressful to caseworkers. When workers resign,
caseworkers and senior caseworkers have no choice but to absorb their caseloads, typically at various
stages of an investigation (or ongoing monitoring) with no prior experience with the family and minimal
time to prepare. Per our interviews with multiple employees, the effects of turnover and the stress it
causes at both the caseworker and senior caseworker level were evident. As mentioned in the
Executive Summary, 15 of the 22 CPS caseworker positions filled as of February 2023 had less than
two years of caseworker experience and more than half of these workers had less than one year of
experience.

Per our interviews, caseworkers’ salary was previously more competitive compared to similar
organizations. Many employees we interviewed additionally mentioned that the NYS minimum wage
seemed to be rising faster than caseworker salary. Staff at various levels expressed losing a portion of
their workforce to jobs within the area that offer similar pay with considerably less stress, such as the
Probation. This point was further illustrated in exit interview detail from November 2021 through October
2022. Per the detail, five out of 13 Department employees ranging from CSW to Sr. caseworker
indicated that they were leaving the Department for a position at a peer organization.

In conjunction with our review, we obtained the County’s January 1, 2022, agreement with the Civil
Service Employees Association (CSEA) Union and noted that CPS caseworkers are a Grade 17 and
CPS Sr. caseworkers are a Grade 18. Per the salary schedule for employees hired in 2023, starting
pay for Grade 17 and 18 employees is $26.95 per hour and $27.97 per hour, respectively. We
compared the caseworker starting salary per the agreement to CPS caseworker starting rates per public
postings for the three surrounding counties. Please note, annual salaries are based on a 35-hour work
week and do account for additional employee benefits, such as retirement, health insurance, vacation,
and personal leave, which may vary among counties. Refer to the chart below for the ranking of
caseworker salary by county and the difference (as a percentage) compared to Jefferson County.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Per the table on the previous page, Jefferson County CPS caseworker position starting pay ranks first
and exceeds that of each of the surrounding counties. Therefore, although pay was cited as an issue
by existing and former Department employees, the County does rank high among its regional peers.

RECOMMENDATION:

Caseworkers are critical to public safety as they protect the most vulnerable and facilitate essential
services to families in need. Recognizing the value that caseworkers and other staff bring to the County
and investing in them is essential for sustaining these services. Additional caseworkers are needed to
lower overall caseloads, improve case timeliness, and improve overall case quality.

We note that the Department has been able to attract several new workers recently. However, to fill its
budgeted positions and retain employees, we recommend the County consider compensation related
initiatives such as sign on bonuses, periodic retention bonuses, and/or salary increases for staff. Based
on the feedback we heard that workers feel underpaid and the gradual and consistent loss of
caseworkers, the County should continue to monitor turnover rates, workloads, and exit data. Working
to monitor and reduce issues like this can increase interest in the caseworker position and move toward
a more balanced workforce.

6. LACK OF COUNTY VEHICLES / MILEAGE REIMBUREMENT

OBSERVATION:

As of the date of our procedures, the County does not own any vehicles. Therefore, caseworkers use
their personal vehicles to perform all field work related responsibilities. These duties, which vary based
on the Unit the caseworker is assigned to, include conducting face-to-face visits at homes, residential
facilities, and schools, as well as transporting clients to appointments and children after they have been
removed from their homes. According to our interviews, most caseworkers stated that they dislike using
their personal vehicle and would prefer to use a county-owned vehicle. Caseworkers citied obvious
reasons such as normal vehicle wear-and tear due to the sheer volume of cases, sanitary concerns
when transporting clients, having annual mileage limits if leasing their car, and having another option
in case of personal car issues. Ongoing caseworkers specifically mentioned that excessive mileage
was becoming a major concern due to children’s geographic location and OCFS’s regulations regarding
frequency of caseworker contact. For example, several children in the County’s custody are placed in
homes and residential facilities in different counties and, in some cases, different states. We did identify
a few caseworkers that, given the choice, would still opt to use their own vehicle for day-to-day field
work. However, in specific circumstances, such as a removal, nearly all these caseworkers stated that
they would “always” use a county-owned vehicle. In addition to these concerns, we noted that the
mileage reimbursement process is manual and time-consuming, not just for caseworkers but for
accounting and auditing staff as well.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

Per our procedures, the Department’s mileage reimbursement process is as follows:

x Caseworkers manually enter the from/to addresses and total miles driven for each trip via a
JCDSS Travel Mileage Excel form. The reimbursement amount is auto calculated based on
total miles and the applicable standard federal mileage rate. Per Department policy,
caseworkers who do not submit their mileage within 60 days of the event date will not be
reimbursed.
x Caseworkers print, sign and date the form and submit it to their supervisor for approval.
x Completed and approved mileage forms are submitted to the Accounting Clerk. Mileage is
processed every other Friday and employees are reimbursed on opposite weeks of payroll.
x The Account Clerk recalculates mileage based on Google Maps. The policy does not define a
threshold; however, per the Accounting Clerk, she will contact the worker and return mileage
forms with discrepancies of three miles or more. After caseworkers have addressed the issue,
they initial the change on the original form.
x The Senior Accounting Clerk reviews, scans and processes each payment by employee in
Munis, the County’s ERP solution for payroll processing. The documents are subsequently
saved in a batch and released to Treasury for approval and payment.

Per our interviews, the two Accounting Clerks receive and process approximately 30 to 40 forms every
two weeks. Reviewing and processing times vary based on the number of submitted forms and the
number of line items per form but the Accounting Clerks estimated that they spend a combined total
of 12 to 14 hours every two weeks on milage reimbursements. Forms are additionally regularly audited
by the County internal auditors. We did not speak with the auditors and therefore, we cannot ascertain
how much time they spend reviewing timesheets. However, based on the process as we understand
it, it appears that they are duplicating the Accounting Clerks’ efforts. Additionally, the Department has
spent a large amount of money on reimbursements for mileage throughout the years. We note mileage
reimbursement was $81,600.67 in 2019, $72,923.56 in 2020, $76,423.44 in 2021, and $84,328.56 in
2022.

RECOMMENDATION:

- Consider investing in a fleet of vehicles. Employees can sign out cars and, when practical,
can drive in pairs to perform home visits.
- Consider investing in an expense management software that will automate this
reimbursement process.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

7. MANDATORY ON-CALL

OBSERVATION:

Per the 2022 – 2024 CSEA Contract, employees working a 35-hour week will earn compensatory
(comp) time for hours worked between 35 and 40 hours. Employees have within 45 days of the date
on which the comp. time was earned to use it. If employees do not use their comp. time within 45 days,
they will receive a payout at their regular hourly rate. All employees receive additional pay, or overtime
pay for hours worked more than 40 hours of one and one-half times their regular rates of pay.

All CPS, Foster Care and Preventive Caseworkers, in addition to Adult Protective, who have
completed NYS training requirements are required to participate in mandatory on-call. Rotating, on-
call shifts are two consecutive days (Monday – Tuesday, Wednesday – Thursday, Friday – Saturday
5pm – 8:30am) and a 24 hour-shift Sunday beginning at 8:30 am and ending at 8:30 am on Monday.
On-call Caseworkers are expected to accept and review all new reports from the SCR, contact the
source, and assess immediate safety. If case circumstances warrant it (e.g., the report includes
physical abuse accusations or drugs are involved), caseworkers must perform a home visit.

At a minimum, caseworkers receive 3.5 hours of on-call comp. time per weekday (total of seven on-
call comp. hours per a two-day shift) and 4.5 hours of on-call comp. time per weekend day. Therefore,
at a minimum, employees earn seven hours of on-call comp. time per shift. Caseworkers are required
to track, by the minute, how much time they spend on the phone, entering notes, and in the field, as it
dictates the type of pay they will earn. This was perceived as tedious. Caseworkers also stated that
the pay from on-call was simply not worth it. Several mentioned that it barely covered childcare costs
and if they had known about this aspect of the job, they would not have accepted it.

It is important to note that in recent months, the Department began compensating seniors and
supervisors who are required to work on-call shifts. Previously, when a caseworker was working an
on-call shift, their supervisor may have felt obligated to be available for assistance but was not required
to be, and therefore was not compensated for this time. Several supervisory staff we spoke with
expressed that this change was a major improvement.

RECOMMENDATION:

We recommend that the Department monitor the positive change recently implemented to the on-call
shifts for seniors and supervisors and analyze whether this alleviates some of the issues staff have
historically had with on-call. We also recommend that the Department examine and discuss ways to
incentivize on-call shifts. One county we work closely with considers all on-call and after hours
‘overtime’ and thus, offers a flat rate per on-call shift in addition to overtime pay for actual work
performed, which creates further incentive to take on these difficult, albeit necessary shifts.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

8. USE OF PERSONAL MOBILE TECHNOLOGY

OBSERVATION:

The sensitive nature of children services cases requires a commitment to confidentiality and
acknowledgement that inappropriate use of personal technology may violate privacy rules and cause
unintended harm to families served by the department and violate. This is acknowledged through the
county’s 2019 Mobile Device Use and Management formal policy.

JCDSS caseworkers do not have work cell phones provided by the County. Instead, Department
workers are expected to contact clients through their desk phones, One Talk mobile app (an app that
offers calling, video and messaging) through their iPads, or their personal cell phones. Per our
interviews, Sr. Caseworkers do not have access to the One Talk mobile app. and the Caseworkers
that do report that it does not consistently function well. Caseworkers also stated that they use the
feature to block their number when making calls on their personal cellphone. Many caseworkers stated
clients do not usually answer blocked calls which often results in several phone calls, voicemails, and
wasted time. Almost all the caseworkers we spoke to discussed utilizing their personal cell phones
every day for work. This poses the potential risk that caseworkers may use their personal cell phones
to capture casework information, correspondence or pictures on a system not in the control of or
protected by the County Information Technology framework.

RECOMMENDATION:
We recommend that the County consider the following:
1. Provide the One-Talk app to Sr. caseworkers. We note that it is not uncommon for Sr.
caseworkers to step-in and perform casework in response to turnover, fatalities, and other
complex cases at the discretion of the supervisor that would warrant calling and texting with
clients.

2. Hold a Mobile Device learning session. In conjunction with the session, IT should:

a. Survey caseworkers to assess One-Talk app accessibility and limitations in and out of
the field and consider alternatives such as providing department-issued cell phones,
providing devices, such as MiFis, that enable users to create a secure Wi-Fi network
or reimbursing caseworkers to enable mobile hotspot functionality.
b. Train caseworkers on the One-Talk app to ensure people are using it to the fullest
capability and not defaulting to their personal cell phones out of convenience.
c. Walk caseworkers through the process to purge their mobile devices, including their
personal cell phones of any case records. IT should continue to monitor purging on
department issued devices on a consistent basis.

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

3. Per the internal policy, all business-related photographs shall be moved to the client file and
purged from the mobile device. We recommend the Department modify the mobile device
policy to explicitly state that caseworkers are prohibited from using cell phones to capture
casework information, correspondence, or pictures. This would align the internal policy with
the OCFS CPS manual, Chapter 6, which states “caseworkers are prohibited from using their
personal cell phones toto take photographs” The Department should regularly train on the
mobile device policy, a minimum of annually, to ensure that Department employees
understand and agree to the principles of the policy. Department leadership should continually
monitor changes in technology, software, and Department practices to ensure they do not
create circumstances that allow, incentivize or encourage caseworkers to circumvent the
directives of the mobile device policy.

VI. Additional Items for the County’s Consideration


Throughout our engagement, other staff challenges and concerns were identified through our
interviews. Below is a high-level overview of these concerns:

1. The child placement and movement process is decentralized and time-consuming to maintain.
The current process also increases the likelihood that the county is overpaying for placement costs
and makes it difficult to efficiently review a child’s previous placement history. Each time a child is
admitted into the agency’s custody, moves locations, is placed in respite or is discharged, the
caseworker completes an electronic movement form. The caseworker sends the memo via email
to multiple staff, including the CIU who is responsible for authorizing payments and the Sr.
Specialized Caseworker who completes the move in the Connections placement module and the
FAHD Caseworker. At any given week, the Sr. Specialized Caseworker spends approximately five
hours sorting through emails, updating the internally maintained Foster Care Parent list, updating
a Monthly Foster Care Status report as well as a listing of children in the County’s care, their
location and their level of care.

2. Any child that comes into the County’s custody that qualifies for this type/level of care based on
behavior, mental or physical condition, is often referred to and placed by a voluntary agency. On
occasion, the Department certifies local foster homes on a therapeutic level. A daily administrative
fee is associated with these types of placements, leading to costly care. NYS therapeutic foster
parents must complete an additional five hours of initial and ongoing specialized training. Per our
interviews, CPR training, staff development day training at local schools and time spent with a
medical specialist all qualify as therapeutic level training.

* * * * *

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Operational Analysis of the Child Welfare Division of Jefferson County DSS

We appreciate this opportunity to work with JCDSS and the Jefferson County Attorney’s Office.
Throughout the entirety of the engagement, we found JCDSS employees extremely helpful and
cooperative. If you have any questions concerning this report or if we can be of service to you in any
other way, please feel free to contact us at any time.

Very truly yours,

BONADIO
BONA
NADI
DIO CO.,
O & CO
C ., LLP

Tim Ball, CFE


Tim
Executive
Execcut
utive Vice
ive Vice President
President

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