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Benchmarks in the CFSR Program
Improvement Plan
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The 1994 Amendments
to the Social Security Act authorized the U.S. Department
of Health and Human Ser-vices to review State child
and family service programs in order to ensure substantial
conformity with the State plan requirements in titles
IV-B and IV-E of the Social Security Act (the Act).
Federal regulations at 45 Code of Federal Regulation
(CFR) 1357.15 implement the requirements for the States'
plan as the child and family services plans (CFSP),
and to submit the CFSP to the Administration for Children
and Families (ACF). In the event that ACF determines
a State is not in substantial conformity with any one
of the outcomes or systemic factors, a program improvement
plan is required. (See 45 CFR 1355.35.) The State must
address in its program improvement plan each outcome/systemic
factor that was determined not to be in substantial
conformity.
The goal of this publication from
the National Resource Center for Child Welfare Data and Technology (NRC-CWDT) is to assist States on how
benchmarks are used in the program improvement plan.
Benchmarks are a way to review and capture the experience
of child welfare as States work towards clear and specific
goals.
What are Benchmarks?
For purposes of the Child and Family Services Review
(CFSR) program improvement plans (PIP) benchmarks are
measurable indicators of progress occurring at established
intervals in a strategy to achieve a goal. The type
of bench-marks the State establishes in its PIP will
depend upon the strategies the State uses and the duration
of the strategies.
What are the different kinds of
Benchmarks?
Benchmarks can be either quantitative indicators
of progress or they can be more process-oriented. Regardless
of the type of benchmarks the State uses, they must
be clearly measurable, specific in their definition
(i.e. specify the de-sired results and the specific
timeframe), and should accurately reflect the strategy
they are designed to measure.
Quantitative benchmarks are
usually appropriate when the State establishes a goal
of achieving a numeric change in performance in some
area. For example, a State may have an overall goal
of achieving a 5% increase in the number of children
who are reunified with their parents within 12 months
of entering foster care over a two year PIP. Depending
on what actions the State decides to take to reach that
goal, and how long it will take those actions to have
an effect on the rate of reuni-fication, the State may
decide to project bench-marks that include a one percent
increase after the first three quarters of implementing
the strategy, a 2.5% increase after 15 months, a 4%
increase at 18 months, leading to the full 5% increase
at the conclusion of the PIP.
Process-oriented benchmarks
are usually appropriate where the actual goal in the
PIP is to implement new procedures. For example, one
of the State's goals may be to train all child welfare
workers in risk management. Implementation strategy,
the State may identify all the action steps required
to achieve that goal and the time frames in which it
will take those action steps.
The benchmarks then become the
action steps and the time periods in which the State will
achieve them, such as developing the curriculum by a certain
date, identifying the trainers by a certain date, training
the first group of staff by a certain date, and so on.
States may also use a combination
of quantitative and process-oriented benchmarks
within the same strategies. Using the examples above,
the State can establish all the action steps and time
frames needed to train staff in risk assessment, and
simultaneously establish quantitative goals and benchmarks
that measure the effectiveness of the training, i.e.,
increases in the number of children who are reunified
with their parents.
Why use Benchmarks?
Benchmarks are especially important for long-term
strategies to improve outcomes and services. Benchmarks
allow the State to gauge its progress along the way
and, if necessary, to modify its strategies and plans
within the time frames of its PIP in order to achieve
the desired results.
Benchmarks are used to:
- Help States to determine realistic
goals for program improvement.
- Allow States to evaluate or assess
their progress periodically.
- Evaluate progress at strategic
intervals, rather than just at the end of the PIP.
- Modify indicated strategies to
ensure the goals and objectives of the PIP are met.
- Report progress on the PIP to State
and Federal partners in the CFSR process.
How can a state use Benchmarks
to evaluate is PIP strategy?
The following example illustrates how a State might
use combined benchmarks to evaluate and modify a strategy
in its PIP:
A State establishes a goal to reduce
the number of foster care re-entries. An activity to
reach the goal could be to provide a certain type of
training to all child welfare staff by December 2003.
The State should first consider factors such as whether
the date is realistic when a curriculum needs to be
developed and training sites identified, whether equipment
is in place, whether training staff are available, and
whether there are issues outside the control of the
agency that could have an impact such as budget allocations,
contract agreements, or delivery of equipment? Considering
these factors will help the State determine the interim
dates by which it will achieve each step toward the
ultimate goal.
One benchmark may be to have the curriculum
developed by outside contractors by a certain date in
2002. However, due to issues outside the control of
the State agency the contract for the curriculum may
get delayed and the deliverable may be six months late.
When the State evaluates the progress, recognizes they
are six months behind schedule, and compares the effect
of not meeting this benchmark on subsequent benchmarks,
the State may determine that it needs to work with the
Regional Office to modify the strategy. It may, for
example, decide that in order to reach its goal within
the time frame for the PIP, it needs to train more people
in less time by increasing the number of trainers and
training sessions.
By establishing benchmarks and corresponding
evaluation criteria in the PIP, the State is able to
evaluate progress, identify barriers, modify the schedule,
and proceed to reach the goal on time.
Without having established benchmarks
and evaluating them periodically, or at least quarterly,
the State takes a risk of being unsuccessful in attaining
the goals in its PIP and incurring penalties for failing
to achieve its goals, but more importantly, risks being
unsuccessful in attaining the goals as outlined in the
PIP, or completing initiatives that were not goals of
the PIP.
Where do states record Benchmarks
in their Program Improvement Plans (PIP)?
Information Memorandum ACYF-CB-IM-02-04 provides
guidance and assistance to States in developing PIPs
in response to the findings of the Child and Family
Service reviews, and a suggested format for preparing
the PIP for submission to the ACF Regional Office. The
regulation, at 45 CFR 1355.35(a), requires States to
include certain information in the PIP, although no
specific format for developing the PIP is prescribed.
Further, at 45 CFR 1355.35(d)(4), States are required
to submit quarterly status reports to the Administration
for Children and Families (ACF), unless less frequent
reports are mutually agreed upon, to inform ACF of the
State's progress in implementing the provisions of the
PIP. Measurable benchmarks are a required component
of the PIP and clearly have a pivotal function in the
PIP matrix described in AFYC-CB-IM-02-04. Specific references
to benchmarks include:
- Column 4 of the PIP Matrix, States
summarize their evaluation approach to measuring PIP
benchmarks and goals.
- Column 5 of the PIP Matrix, States
list the quarterly benchmarks for conducting in terim
monitoring of PIP progress for each applicable item
and systemic factor. Benchmarks are the interim and
measurable indicators that will be used to determine
if progress is being made toward achieving the established
goal.
- Column 6 of the PIP Matrix, States
include the projected dates for achieving the quarterly
benchmarks quarterly benchmarks listed in column 5.
In each quarterly report (using the PIP Matrix), States
note the benchmarks that have been achieved.
- PIP Narrative Report Form: When
benchmarks or goals are not met, States should provide
a narrative explanation in this section.
Where else in the PIP is reference
made to Benchmarks?
On the PIP Quality Assurance Checklist, there is
an indicator "Does the plan include benchmarks
for measuring improvements?" and another one for
"Are those benchmarks consistent with the level
of effort required to improve per-formance?"
What happens if a state does not
meet the Benchmarks in its PIP?
When a State is not in substantial conformity with
the outcomes and systemic factors reviewed in a CFSR,
it is subject to financial pen-alties based on the non-conformity.
However, if the State succeeds in implementing the provisions
of a Federally approved PIP that addresses the non-conformity,
the potential penalties may be rescinded by the Administration
for Children and Families (ACF) at the time during the
PIP when the goal is achieved. If however, the State
does not achieve the goals in its PIP, the assessed
penalties may be withheld from Federal funds due to
the State. If the State does not meet critical benchmarks
identified in the PIP, rather than waiting until the
end of the PIP, ACF may begin to withhold Federal funds
at the time when the goal was to be achieved. It is,
therefore, important that the State carefully consider
the time frames needed to achieve it goals and reach
its benchmarks, and to use benchmarks to evaluate its
progress and make adjustments as needed.
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Example of how a state might establish a
Benchmark
Consider a specific outcome:
Children are first and foremost protected
from abuse and neglect. Safety Factor 1
states, "Of all children who were victims
of substantiated or indicated child abuse
and neglect during the first six months
of the period under review, 6.1% or fewer
had another substantiated or indicated report
within six months." When the State
percentage of repeat maltreatments exceeds
that amount, efforts must be made to reduce
the percentage and meet that standard outcome.
Possible strategies
for improvement may include:
Implementing postunification
services to prevent the recurrence of maltreatment
Implementing a standardized risk assessment
process for evaluating incoming reports
of maltreatment
Strengthening the screening process for
determining response to incoming reports
Implementing supervisory controls for determining
if cases are open for services as a result
of determinations of child maltreatment
Implementing followup protocols for families
referred to service providers as a result
of determinations
Developing procedures for addressing situations
of multiple unsubstantiated reports in families
Possible means of measuring
progress may include:
Setting benchmarks for steps in the process
of developing, issuing, and implementing
new policies monitor and verify steps along
the way
Developing and implementing control procedures
for assuring that risk assessment procedures
are followed in all cases
Requiring periodic supervisory reports of
activities related to PIP strategies
Possible means of measuring
the effectiveness may include:
Developing and using reports that monitor
the recurrence of maltreatment over time
Setting benchmarks of progress regarding
lowering the incidence of recurrent maltreatment:
monitor automated reports
Conducting surveys of families where
recurrent maltreatment is present to determine
causes
Conducting case reviews, using QA procedures,
to determine if maltreatment results from
the same circumstances or new circumstances
Benchmarks for developing
and using reports may include:
First Quarter: Developing monitoring
reports of recurrent maltreatment cases.
Second Quarter: Developing training, conduct
training, and distribute monitoring report
to supervisor staff and line staff.
Second Quarter: Developing independent
team to review monitoring report to look
for common threads in the reports such
as county, regions, perpetrators, type
of maltreatment etc. and empower it to
report to management recommended changes
in policy, procedures, management, etc.
Third Quarter: Implementing recommended
changes.
Fourth Quarter: Goal to reduce the number
of repeat maltreatment cases reached.
The above is a process
oriented benchmark example. A State may
choose to develop its benchmarks quantitatively
by setting a proportional percentage decrease
each quarter until reaching its final goal
of the national standard. For example, if
the State had a goal of reducing the number
of repeat maltreatments by two percentage
points within the year, each quarter the
goal might be set to reduce by .50%. By
meeting their set benchmarks each quarter,
the 2% goal would be reached by the end
of the year.
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This document was prepared
as a supplement to the material presented in a session
at the April 2002 Making IT Work: Using Data for Program
Improvement in Arlington, VA. We hope that it will serve
to stimulate an exchange of ideas and information among
States and between systems and program staff. Your feedback
is important to us. If you have any additional information
on the topic presented in this sheet, or if you have
any comments or suggestions regarding its presentation
or content, please contact Elaine Vocesof Xtria at (703)
821-3090 x241 or nrccwdt@xtria.com

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