Administration of Child Welfare Placement Services

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Objective

The objective of our audit of the administration of child welfare placement services was specifically to evaluate the effectiveness of Denver Human Services’ kinship caregiver certification process and whether the agency’s controls over its imprest fund are consistent with city rules and leading practices.

Background

When a child is removed from their home because of reported abuse or neglect, child welfare agencies prioritize placing them with “kin” first — family members or close family friends who have a relationship with the child. Denver Human Services’ Child Welfare Division administers kinship placement in the City and County of Denver, and its staff certify the kinship caregivers, also called “providers,” who take in children removed from their homes.

Meanwhile, the Financial Services Division oversees an “imprest fund” that provides emergency financial support for families and caregivers served by Denver Human Services.

Why this matters

When Denver Human Services does not adequately manage how it certifies kinship caregivers, it places added stress on caseworkers and staff who are already prone to turnover. The caregivers themselves can also miss out on needed financial aid when they are not given thorough, accurate, and timely information about the certification process.

Meanwhile, weak policies and procedures for the imprest fund could result in inconsistent practices and potential misuse of money intended to help individuals with urgent needs.

Findings

FINDING 1 – The kinship caregiver certification process lacks formal training and guidance

Caseworkers and other staff in Denver Human Services’ Child Welfare Division do not have consistent training or clear procedures for certifying kinship caregivers. Because of this, child welfare managers cannot ensure these staff members have the knowledge and tools they need to best serve both the local children removed from their homes and their new caregivers.

Specifically, we found:

  • The agency has no written guidance outlining policy or requirements for training certification staff.
  • Training logs of three certification team members revealed inconsistencies in the types of training they took.
  • The agency’s procedures for certifying kinship caregivers are only in draft form.
  • Checklists and other tools certification staff use lack some details and are inconsistent.

FINDING 2 – The policies and procedures for Denver Human Services’ imprest fund are insufficient and outdated

Denver Human Services’ procedures for its imprest account are missing important components referenced in city fiscal rules. And because the fiscal rule for petty cash accounts no longer mentions imprest funds by name, staff within Denver Human Services are unsure what guidance still applies to the agency’s fund.

Additionally, limited documented guidance for how to maintain and secure the agency’s fund could impact how staff review and approve expenses, keep checks secure, and resolve recordkeeping issues.

Recommendations

1.1 Develop a formal training plan – Managers in the Child Welfare Division’s placement services group should develop and document a formal training plan specific to the certification, training, and recruitment team. This plan should include, at a minimum:

  • A list of the types of training required and how often each training should be taken after an employee is hired (for example, only one time versus once each year).
  • A description of how the division will track and document training.
  • How often the training plan should be reviewed and updated.
  • How the division will develop and use individual training plans to ensure a focused approach to staff training and development.

This training plan should also identify which staff — in addition to intake caseworkers and ongoing caseworkers — should be trained in the kinship caregiver certification process, as well as the types of training they should receive and how often.

Agency Response: Agree, Implementation Date – May 31, 2023

1.2 Update procedures – Managers in the Child Welfare Division’s placement services group should develop and document current guidance on the kinship caregiver certification process that accurately describes all required steps, who is responsible for those steps and for updating the procedures, and how often the procedures should be reviewed and updated. In addition, the procedures should include an effective date.

Agency Response: Agree, Implementation Date – May 31, 2023

1.3 Review file storage – Managers in the Child Welfare Division’s placement services group should review the agency’s internal shared drive and any other file storage areas to identify and remove outdated procedures associated with the kinship caregiver certification process. Then, managers should identify where current procedures should be kept going forward and communicate that to all relevant staff.

Agency Response: Agree, Implementation Date – Feb. 27, 2023

1.4 Develop caseworker and support staff retention plan – The Child Welfare Division should develop and document a plan to reduce caseworker and support staff turnover. This plan should:

  • List strategies for improving caseworker and support staff retention using best practices from leading child welfare organizations and the city.
  • Describe the division’s assessment of potential caseworker and support staff retention strategies and which it will use.
  • Document the individuals responsible for regularly reviewing and updating the retention plan and how often this should happen.

Agency Response: Agree, Implementation Date – May 31, 2023

2.1 Apply for a fiscal rule waiver – Denver Human Services’ Financial Services Division should apply for another waiver from the Controller’s Office to clarify which elements of Fiscal Accountability Rule 3.2 apply to Denver Human Services’ imprest fund.

Agency Response: Agree, Implementation Date – May 31, 2023

2.2 Develop, document, and approve procedures – Denver Human Services’ Financial Services Division should develop, document, and approve more robust procedures for its imprest fund. The procedures should mention which specific requirements from Fiscal Accountability Rule 3.2 apply based on the guidance from the Controller’s Office. The procedures should also detail, at a minimum:

  • How often the procedures should be reviewed and updated.
  • The types of reconciliations required along with those responsible for completing them and how often reconciliations should happen.
  • Any additional forms other divisions require to document spending approvals.
  • The requirement for additional approvals for requests that exceed $1,000 and where those approvals are to be documented.
  • The process for identifying and resolving outstanding checks and ensuring each voided check is recorded.
  • The actual daily transaction limit.
  • An effective date.

Agency Response: Agree, Implementation Date – May 31, 2023

2.3 Approve and implement draft procedures for storage devices – Denver Human Services’ Financial Services Division should finalize its draft procedures regarding secure storage devices, including its authorization form. Once the procedures are approved, the division should implement them and communicate them to all relevant staff.

Agency Response: Agree, Implementation Date – Feb. 28, 2023

Auditor's Letter

March 16, 2023

We audited how Denver Human Services administers child welfare placement services to determine the effectiveness of the kinship caregiver certification process. We also reviewed the agency’s procedures for its imprest fund.

While I am pleased that Denver Human Services agreed to all recommendations, our ability to audit was delayed by insufficient initial access to child welfare records as described in Appendix A. This should not have occurred. Also, we were unable to collect financial assistance data from other state databases because of federal data sharing regulations. We are working to resolve this issue for future audits.

The audit found the Denver Human Services caseworkers and support staff who help kinship caregivers become certified lack the consistent training and accurate procedures they need to best serve the caregivers taking care of local children removed from their homes. Additionally, we determined the procedures related to the agency’s imprest fund — which is used to provide emergency support to families, children, and caregivers the agency serves — were insufficient. As part of our audit results, we also present our analysis of child welfare case records related to the local children in kinship care and their caregivers. This provides an overview of these populations and their experiences receiving and providing kinship care.

By implementing recommendations for stronger training practices and for complete, updated procedures, Denver Human Services’ Child Welfare Division will better equip caseworkers and support staff with the information and tools they need to fully support kinship caregivers. Additionally, more robust procedures for the imprest fund will improve the ability of Denver Human Services’ Financial Services Division to ensure the money is being used as intended.

This performance audit is authorized pursuant to the City and County of Denver Charter, Article V, Part 2, Section 1, “General Powers and Duties of Auditor.” We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

We appreciate the leaders and team members in Denver Human Services’ Child Welfare and Financial Services divisions who shared their time and knowledge with us during the audit. Please contact me at 720-913-5000 with any questions.

Denver Auditor

Auditor's Signature
Timothy O'Brien, CPA


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AUDITOR TIMOTHY O'BRIEN, CPA
Denver Auditor


Denver Auditor´s Office

201 W. Colfax Ave. #705 Denver, CO 80202
Emailauditor@denvergov.org
Call: 720-913-5000
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