In the final year of the Obama administration, the Department of Health and Human Services (HHS) paved the way for states to move toward better data collection and analysis for children and youth involved in their child welfare systems.
The federal government will pay up to half the bill for states that want to convert to the new Comprehensive Child Welfare Information System (CCWIS), designed to replace the decades-old data exchange system that states and the federal government currently use.
Will states take HHS up on the offer?
“I don’t know why anyone wouldn’t want to go this route,” said Carole Hussey, a human services expert for the Boston-based Public Consulting Group, which advises child welfare agencies around the country on business and practice issues. “Now, because of different modules and interoperability, there’s a world of different possibilities.”
But so far, she said, states seem to be gun-shy about initiating an expensive technology shift even with federal help.
Since 1993, the Statewide Automated Child Welfare Information System (SACWIS) has been the primary conduit of child welfare information in the country. These systems contain the information necessary to make determinations on Title IV-E eligibility, which dictates whether HHS will reimburse agencies for the costs of foster care or help support adoptions.
SACWIS takes granular, case-level information input by social workers and administrators across a state and then aggregates that into state-level data. This is the process that produces the requisite numbers for the Adoption and Foster Care Analysis and Reporting System (AFCARS), the annual federal report on child welfare trends, and for the federal evaluations of each state’s system.
Some states paid hundreds of millions of dollars to build SACWIS systems, while others bought and imported what other states built for far less. All of them were designed with primarily federal reporting in mind, and did not maximize the potential for incorporating practice and policy analysis.
“Many states did the minimalist build to satisfy AFCARS requirements,” said Tom Morton, former director of the Clark County, Nevada child welfare system and founder of the Child Welfare Institute. “As a result, most were not really information management systems designed to support the complete range of agency management needs, but rather a means to automate and support federal reporting.”
But even that proved challenging. The technology did not lend itself to the timely adjustments necessary for handling changes in federal requirements. Since the establishment of SACWIS systems, those include the de-linking of adoption from an income test, inclusion of older youth in extended foster care and guardianship assistance, and the recent requirement to track failed adoptions.
“Each time, states have had to undergo major efforts to capture new data and create new functionality or workarounds to accommodate these changes,” Hussey said.
Obama administration officials oversaw the development of CCWIS as an alternative for states that wanted to build a more agile system. If states want to keep SACWIS in place, they can do so. If they want to build a CCWIS, HHS will help pay for the development of any aspect of the system that deals with IV-E eligible youth.
“We are moving dramatically away from monolithic systems,” said Rafael López, former commissioner of the Administration for Children, Youth and Families, in an interview conducted before the change in administration. “With mobile apps and statistical software, there’s a very different way of thinking about it. The old rules were driven by a single system, rooted deeply in compliance instead of functionality.”
Like SACWIS, the new systems must comply with the reporting requirements for AFCARS, the Child Family Services Review process, the Youth in Transition database and the National Child Abuse and Neglect Data System. But there are a few key requirements that distinguish a CCWIS system:
- Modularity: CCWIS systems must be built in modules, making it less likely that a necessary upgrade or change would be cost prohibitive.
- Data-Sharing: They must be built with the capacity to interface with other data systems from schools, juvenile justice agencies, and other youth- and family-serving agencies.
- Exportable: As a significant payer in the build-out of these systems, HHS retains the right to request the details and software involved in a CCWIS to assist other states.
The difference between the two is significant. SACWIS was largely built as storage, a means to pile up information and comply with federal reports. The CCWIS format extends the capacity to case management and real-time evaluation.
Data systems should “accurately reflect what’s happening with a child,” López said.
“Systems today aren’t able to answer that question.”
CCWIS can also enable states to adapt to policy shifts, which seem likely to occur in the near future. A massive reform of IV-E federal spending nearly passed at the end of 2016, and many child welfare advocates have championed a change in the way that IV-E eligibility is determined (right now, it’s pegged to an income test from 1996).
Processing and collecting data related to either of those shifts, Hussey said, would be a challenge to handle with the current SACWIS system.
“There was most certainly rigidity in the prescribed requirements of SACWIS,” Hussey said. “The new CCWIS requirements are less stringent, and it promotes modularity, which will inherently decrease time and cost for upgrades and modifications.”
The deadline for states to opt in for CCWIS is not until July of 2018. But with a large IT project, feasibility studies and procurement inquiries will likely precede a decision to move forward, which means the timeline is narrower than that deadline suggests. HHS funding is also available to help pay for these planning stages, which can run up to $1 million itself.
Obama officials were confident that a shift toward new systems would be widely embraced by state agencies. “We don’t think states will stand pat,” López said. “States have been very clear about a demand and urgency for something different.”
But months later and with a new administration, that has not yet been the case. Only a handful of states have moved toward adopting a CCWIS.
A status track on the ACF website shows six states moving toward CCWIS: Arizona, Illinois, Mississippi, North Carolina, Virginia and West Virginia. Additionally, the California Department of Social Services has confirmed that its new data management system, still in development, will comport with CCWIS standards.
Hussey said the lack of early interest in CCWIS is likely attributable to the far-off deadline and apprehension over the cost.
“Cost uncertainty is a lot of it, for sure,” she said. “People are watching California and Arizona to see what happens in those two states.”
A wait-and-see approach is not uncommon for states when it comes to federal match options. Only a handful of states opted in to extend foster care beyond the age of 18 in the first two years after the Fostering Connections to Success and Increasing Adoptions Act was passed. Now, more than half of the states have extended care up to 21.
Hussey said her fear with CCWIS is that states will view the cost and benefit strictly from an IT standpoint, and not factor in the policy implications. Child welfare officials often direct her to the tech department when she brings it up.
“When I can explain how it can transform things and why they should care, that spurs a different conversation,” Hussey said. “If they let IT people drive this, [CCWIS systems] won’t end up serving more needs.”
This story first appeared in “FosterTech,” a special issue on the intersection of child welfare and technology published by The Imprint and Fostering Families Today. Order a copy of “FosterTech” here.