February
28, 2003
Sue Howell
Office of Child and Family Policy
406 E. Monroe, Station #65
Springfield, Illinois 62701
Re: Proposed Amendments to Part 301,
Placement and Visitation Services
Dear Ms. Howell:
The Child Care Association of Illinois submits the following comments in
response to the Proposed Amendments.
Generally, we agree with DCFS that the capacity of all foster homes must be
critically reviewed and that some comprehensive changes in the foster home
system are in order. However, the current proposed rules could be problematic
given the existing pool of foster parents and existing demographics in Illinois.
Our foster care system has long relied on older caregivers to become foster
parents and kinship providers. As demographics suggest, the "empty
nester" once recruited as the typical foster mother no longer exists. Many
women remain in the work force while actively parenting their own children, and
still more women return to work when their children are no longer totally
dependent on them. Since this shift, our system has been hard pressed to recruit
and maintain a pool of "younger" foster parents, who are culturally
competent to care for DCFS wards, and who reside close to the child's home
community.
The proposed changes suggest some immediate assessment is in order of both the
existing and projected pool of foster parents, and identification of additional
foster home needs that will meet the new restrictions. There must be some
recognition of the programmatic and financial burden on the private sector that
provides more than 70% of all foster and kinship care, as we shift recruitment
strategies. We must create some special initiatives, and consult jointly with
national and international experts and how to redevelop the foster parent pool.
We also question the impact of these new rules on adoptive families and the
"adopt only" families. These families must first be foster parents.
Does DCFS know how many of its recent adoptive and guardianship families,
including high profile politically connected people, or state employees and/or
well known adoptive parents, would have met these age restrictions? Will a great
number of our future permanencies be impacted by these restrictions while the
system tries to eliminate a few extremely aged caregivers are unlikely to be
able to care for a ward through young adulthood?
CCAI maintains that all placement homes should be subject to a thorough
psychosocial assessment-in effect the old fashioned "home study." As a
field, we have strayed from this thorough assessment in favor of compliance
checklists. Any home should be viewed with the age of the caregiver as one
factor of many factors that provide a complete prognosis of the social and
emotional ability of the caregiver to provide safety and nurturing for a DCFS
ward. Good social work judgment should consider the ability of any
caregiver of advanced age, along with all other factors. Age alone should not be
a determining factor.
We suggest reworking of the proposed rule to reflect the need for a thorough
home study. We agree that the age ranges provided should be used as reasonable
guidelines but not as absolute restrictions. We would also suggest procedures be
implemented with the guidelines to assure periodic review of the caregiver's
abilities with specific children, if the caregiver falls outside the suggested
guidelines.
We object to additional DCFS monitors visiting homes merely to check on age and
space compliance. Any visits to the foster home should be made by staff
(public or private) that are well trained in the home study process, well
acquainted with direct service dynamics and who meet the same educational and
training qualifications as direct service staff in private agencies are required
to have. Monitors should not merely check on the home, but they must look at all
aspects of the safety and nurturing components of the home. As they inspect,
they must document systemic findings and identify needs of the system as well as
spot-check for compliance in all foster home licensing regulations. We refer
DCFS to the components of the CCAI Proposal for System Accountability for
guidelines on random inspections of foster homes.
Additionally, we have the following comments on specific sections of the
proposed rule:
301.65
We question the use of the wording "primary" foster parent. This seems
to conflict with existing DCFS rule which requires foster parents to be single
or married. A married couple is jointly licensed and should not have a
"primary" foster parent. If a good social assessment were made as we
suggested above, the overall abilities of the couple would be identified,
according to all parenting abilities and qualifications. The combined assets and
built-in safety net of a married couple could very well outweigh the concern of
age.
301.65
We question the impact on the system of the restrictions to 2 placements. We ask
DCFS to investigate national standards, and specify trends in placement numbers
in similar states (Michigan, New York, California) before finalizing the limit
to 2 unrelated children. We also request DCFS provide us with some trend reports
showing the typical number of children in placement across the system.
We agree there should be guidelines and agree homes should not be overused and
overpopulated. However, many of our agencies report an average of three (3)
children per home is reasonable and is their current pattern. Given that the
incidence of abuse/neglect in foster homes-as reported by DCFS' own
statistics-is very low, it would seem reasonable to suggest that the current
pattern of 3 children is not posing severe safety risks.
301.66c
Specific language should be inserted into this subsection that would allow
private agencies to hold these case management reviews internally. Sign-off can
be provided to the APT regarding the review and agency plans for roles and
responsibilities. APT can be invited to attend the reviews but should not
be required to convene them. Only in the event that the 2 agencies fail to
provide the sign-off should APT convene a staffing. We question the need for
clinical staff to spend their time and divert scant clinical resources to
convene meetings about case management.
301.66 e
This appears to duplicate existing DCFS procedures. Isn't a review already
required when placements change? Once again, we suggest that the agency should
be responsible for this clinical review, and provide APT with information on
placement changes and sign-off that the review occurred.
301.66 g
We do not object to DCFS notifying the court of multiple placements. We,
however, wonder what court is to do with such information and how this will help
the child welfare system stabilize children and prevent multiple placements.
What is the anticipated outcome of the notification to the court? This probably
should be specified in the rule, so the full programmatic, clinical or financial
impact on the system of the court's actions when notified can be assessed.
I know these proposed rules pose challenges to DCFS as chief policy maker and
guardian of state children, as well as to private providers. I offer to help
DCFS analyze this proposed rule in more detail with a small group of executives
if needed.
Please direct any questions regarding our comments to me at 312-819-1950 or
[email protected].
Sincerely,
Margaret M. Berglind, ACSW-LCSW
President/CEO