Round 3 Frequently Asked Questions

General Questions

Questions related to the overall instrument, its general application, or the Face Sheet.

Item 8, 11, 12, 13, 15:
If, during the PUR, the court issues a “cease reunification” order, ending reunification and/or other services to parents, or if a termination of parental rights occurs during the PUR, does that automatically make Items 8, 11, 12, 13, and 15 “not applicable”?
No, not automatically. Reviewers need to consider the case circumstances and the best interests of the child in determining the applicability of these items. Although the definition of parents in Items 8 and 11 seems to indicate that reviewers would stop assessing a parent who was no longer working toward reunification during the PUR, if it is in the child’s best interests to continue visitation or continue supporting the relationship after TPR or a cease reunification order occurs during the PUR, that parent would remain applicable in those items. If it was not in the child’s best interests to continue to support the relationship with that parent based on case circumstances, from that point in the PUR Items 8 and 11 would stop being applicable and those items would only be rated for the portion of the PUR when contact with the parent was appropriate. Circumstances may warrant continued work with the parents in Items 12, 13, and 15, but the application of the item instructions may shift due to the case circumstances. For example, in Item 12, a comprehensive assessment and services to support all identified needs may not be applicable in cases where the parent and agency are no longer working toward the goal of reunification, but an assessment of what the parent may need to continue a positive relationship with the child post-TPR and services to support that need may be warranted, and that should be captured in 12B. In Item 13, although the case plan goal of reunification may have changed, the agency should still be engaging with the child and parents to work toward an alternative permanency goal and ensure that any other case goals (such as supporting a positive long-term relationship post-TPR between the parent and child) are achieved. The family should also be informed about what steps are needed for successful case closure. Similarly, monthly contact in Item 15 may no longer be warranted based on case circumstances, but adequate contact with the parent to continue to work toward permanency for the child and ensure that any other case goals are achieved should be assessed in Item 15. This may be monthly or less than monthly contact, depending on the circumstances.
Face Sheet:
For Question I, should the reviewer enter the date on which in-home and foster care services first began (i.e., date of the disposition of the investigation) or the date on which the investigation begins?
Question I on the OSRI Face Sheet asks, "What is the date of the first case opening, of the cases open for services during the period under review?" The date that should be entered is the date on which the agency opened the case for services, or referred the case for services under an alternative response system. Depending on the state's policy, the case could be considered open for services after the disposition of the investigation and a decision to open the case, or could be considered open as of the date on which the investigation begins. To ensure that reviewers are using the correct definition of "open for services," we recommend discussing the state's policies on when a case is considered to be open with the Children's Bureau Regional Office Specialist. Question L on the Face Sheet asks, "What is the date of the most recent case closure during the period under review?" The date that should be entered is the date on which the agency has completed all case closure activities required by the state's policy. Again, to ensure that reviewers are using the correct definition of "case closure," we recommend discussing the state's policies and requirements for case closure with the Children's Bureau Regional Office Specialist.
Face Sheet:
How should we capture same-sex parents?
Parents who are of the same gender should be captured according to their role as you would for other parents. The instrument allows capturing more than one "mother" and more than one "father." (8/4/2014)
Face Sheet:
Can states add a text box in the OSRI face sheet? If so, where?
States do not have the option of adding a text box in the OSRI face sheet in the CFSR Online Management System.
General Question:
How should reviewers apply the OSRI to in-home cases involving children living in temporary, alternative child care arrangements, such as with extended family members/friends via voluntary agreements or conditional custody orders?
This guidance applies to in-home cases in which children are living with extended family members or other family friends via voluntary agreements with the parent(s), conditional custody orders, or other court orders that do NOT place the child under the care and placement responsibility of the agency. In some states these arrangements may be considered placement with safety resources or out-of-home safety plans. Face Sheet It is very important that reviewers indicate in the case participant table all the alternative care providers with whom children are living. This will help to determine who will be rated in Items 12A and 12B and what homes need to be considered in risk/safety assessments in Item 3. Item 2 Reviewers should not consider the child(ren)’s placement in a temporary, alternative living arrangement outside the family home as an “entry into foster care” because the child welfare agency does not have placement and care responsibility for these children. If only a safety plan was needed and no safety-related services were necessary based on the circumstances of the case, then the case is not applicable for Item 2. If the only thing necessary to keep children safe during the period under review was a safety plan that placed the children with an alternative care provider, then this item is not applicable. Placement with an alternative care provider is not considered a safety service. If, during the period under review, there were safety concerns with the biological/legal parent OR with the alternative care provider with whom the child(ren) live, the first box for applicability would be answered Yes and reviewers would respond to question A by determining whether appropriate safety-related services were provided to either the bio/legal parents or the alternative care provider, to ensure the children’s safety and to prevent the child(ren)’s actual placement in foster care. If, during the period under review, there were concerns with the alternative care arrangement and the children were at risk of foster care placement, the second box for applicability would be answered Yes and reviewers would respond to question A by determining whether appropriate safety-related services were provided to either the bio/legal parents or the alternative care provider to ensure the children’s safety and to prevent the child(ren)’s actual placement in foster care. Question 2B would always be answered NA in these cases because the case is being rated as an in-home case, which means the children were never removed from the home and placed in foster care during the period under review. Item 3 When responding to questions 3A and 3B, reviewers should consider whether risk and safety assessments were conducted in the home(s) where children were living as well as in the home of their biological/legal parent. When responding to question 3C, the safety plan would include the plan to place the children with an alternative care provider as well as any other safety-related services that were provided to the bio/legal parent and/or the alternative care provider (if applicable based on case circumstances). Item 12 Alternative care providers should have their needs assessed and be provided necessary services as this relates to their ability to meet the identified needs of the children living with them. Therefore, the assessment and services for these caregivers would be captured in 12A for the children. The agency is not required to conduct a comprehensive assessment of these caregivers as they are for parents in 12B because these caregivers are not the focus of the case plan and are not the legal/permanent caregivers for the children. Only biological and/or legal and permanent parents or guardians of the children would be assessed as Mother and Father in 12B. If an alternative care provider becomes a legal guardian or adoptive parent of a child during the period under review, the alternative care provider should also be included as a parent in 12B. If a biological parent was not the parent with whom the children were living, reviewers would need to determine if he or she should be included based on the guidance provided in the definitions for Mother and Father for in-home cases in the instrument. Items 13 and 15 The same parents identified as Mother and Father in 12B would be rated in Items 13 and 15.
Face Sheet:
Who should be included in the case participant table of the Face Sheet, and what information should be included regarding “relationship to child”?
In the online OSRI training provided by the Children’s Bureau, the following instructions are provided: When determining who to include in the case participant table, reviewers should always include biological and legal parents, regardless of their involvement with the child or children at the time of review. If the parent is deceased, if their parental rights have been terminated (even if this occurred prior to the period under review), or if their whereabouts are unknown, reviewers should note that in the “relationship to child” section. It is also important to indicate whether the parent served as a caregiver and/or whether he or she lived in the same home with the child(ren). Paramours to parents or caregivers who live in the home with the child(ren) should also be listed in the table. If they serve in a caregiving role with the child(ren), indicate their role as “caregiver,” and if they do not serve in that role but they have access to the child(ren), indicate their role as “other” and explain their status in the “relationship to child” section.
Face Sheet:
Question M asks why a case was opened for services. Is the reason(s) for case opening based on the state’s legal definitions of maltreatment as reflected in the reason for substantiation of abuse? Or is it based on the social worker’s identified concerns as reflected in the child abuse assessment information?
The reason for case opening should be based on whatever information is available in the case record and from interviews that identifies why the agency opened the case. This would include the maltreatment type that was substantiated or resulted in case opening, and it could also include other information that informed the agency’s decision to open the case.
Case Interviews:
In completing the OSRI, should specifics about case interviews―such as which party indicated a certain fact―be included? If so, does this go against the assurance of maintaining the confidentiality of the interview process?
We ask reviewers to justify in their narrative how information gathered in the interview process supports their ratings. However, this information is confidential, and since some states share the completed OSRI with the caseworker/supervisor as part of the CQI feedback loop, this can affect confidentiality. It is suggested that reviewers include the information in the rating justification but do not directly indicate who provided the information. For example: “This item is rated ANI because at least one person interviewed indicated that the agency did include the parent in case planning meetings, but drafted the case plan in advance and only presented it to the parent for signing at the meetings.”
General Question:
When reviewing a case, what should reviewers consider for assessment in the OSRI during the period under review?
The “period under review” refers to the established date that the case review begins (the start of the sampling period), and includes all agency services and actions on all accepted maltreatment reports and open cases from the start of the period under review, up to the date that the case is reviewed or case is closed, whichever comes first. To accurately answer all questions in the OSRI, it is necessary for reviewers to consider all services and actions provided by the state during the entire period under review. For example, during the period under review a state may be conducting safety and risk assessments, linking families to services, and coordinating safety planning during an investigation or differential response assessment, before actually opening the case. These agency services and actions would be considered and taken into account when completing OSRI questions. Similarly, if multiple cases are open during the period under review, all of those cases would be considered for assessment in the OSRI. If the case being reviewed is a foster care case, any other cases opened during the period under review that involved the identified target child (foster care or in-home) would be considered for assessment.
General Question:
How should the OSRI be applied to cases that were open for 45 days or longer, but only included an initial investigation or assessment and did not include provision of services or case planning beyond that during the period under review?
For cases in which only an investigation or assessment occurred and no ongoing services or case planning was provided beyond that, reviewers should apply the following guidance in determining how to respond to Items 12 and 13. Reviewers must first determine if an adequate assessment of risk/safety was completed in Item 3. If there were no substantiated allegations and no identified risk or safety concerns with the family that would necessitate any further services beyond the initial investigation/assessment, comprehensive assessment of the child(ren)/parents and case planning with the family would not be necessary, so Items 12 and 13 could be rated Not Applicable in these cases. In cases where there are substantiated allegations, or if it is determined that there are high risk or safety concerns present, even if there is no substantiation of maltreatment, it is reasonable to expect the agency to conduct a comprehensive assessment of needs and services and to engage the family in case planning, so Items 12 and 13 should be rated. Reviewers would apply the OSRI instructions as they would in any other case to determine how to rate all other items for these cases.
General Question:
A maltreatment report was received concerning siblings of the target child who remained in the home with their biological father during the period under review. The report was received after the target child's adoption was finalized and there was no ongoing open case with the biological mother or other parent. Should we consider this new report when rating Item 1 and should we consider these other children when we are rating ongoing assessment of risk and safety in item 3?
The children that were considered as part of the family in the case being reviewed at the beginning of the period under review (PUR) remain that way until the case closed, for rating purposes of safety, regardless of whether there is an intervening adoption for the target child during the PUR. So in the first example, the new report that came in on the child's originating family during the PUR would be considered if the report came in prior to case closure.
General Question:
How should the OSRI be applied in a case involving a youth who was on runaway status for a majority of the PUR?
Whether the state is taking all reasonable steps, on an ongoing basis, to find a child who has run away from a placement will affect the reviewer’s assessment of several items. If the state isn’t taking all reasonable steps to find the child, it follows that the agency would be unable to appropriately assess, visit, engage, or provide services to the youth, which would affect ratings in Items 3, 13, 14, 16, 17, and 18 (if applicable). If the state is actively attempting to locate the child on an ongoing basis, the reviewer should not consider the period of time during which the child was on runaway status in the assessment of Items 13, 14, 16, 17, and 18 (if applicable). In Item 3, the efforts being made to locate the child should be considered positively in the reviewer’s overall evaluation of ongoing risk/safety assessment during the PUR. Regardless of the agency’s efforts to locate a youth on runaway status, the agency should still be able to identify appropriate permanency goals for the child, process timely termination of parental rights as applicable, work toward achieving timely permanency (e.g., searching for/preparing permanent placements for the child or working with parents toward reunification, based on case circumstances) and formulate assessments of the youth’s needs, including identifying needed services for the child. Therefore, Items 5, 6, and 12 should be rated based on the agency’s efforts in these areas.
Face Sheet:
How should reviewers record parents when there is a known/available father or mother, but there is no name in the record; e.g., the parent is mentioned in interviews?
It is acceptable to add the parent to the Face Sheet as Jane or John Doe.
General Question:
I am rating a case in which the foster child was placed by the agency with a relative, out of state, through an ICPC for most of the period under review. How do I address Items 3, 14, and 15 in a situation when an out-of-state DSS agency was responsible for supervising the placement?
Although the placing state has asked the receiving state to monitor the child’s safety, permanency, and well-being through an ICPC agreement, the placing state is still responsible for reviewing ICPC reports and ensuring the child is safe, and that his or her needs are being addressed by the receiving state. To answer the OSRI questions for Items 3, 14, and 15, Reviewers should talk to the placing state regarding the child’s safety (Item 3), and worker visits with the child (Item 14), as well as review ICPC reports and possibly conduct a phone interview with other case participants, such as the receiving state’s worker, the relative caregivers, and the child. Reviewers would need to ascertain the location of the parent (for Item 15) and determine which state is conducting visits with the parent, though the placing state should ensure that these contacts are being made. CB case elimination guidance allows for ICPC cases to be eliminated if they come up in the receiving state’s sample.
General Question:
If a case is being reviewed and the youth turns 18 during the period under review but the state continues to provide services to the youth, do we continue to review for services provided and to rate the case for activities that occurred after age 18?
No. We review only for services and activities up to the age of 18. On the Face Sheet, use the date the child turns 18 as the discharge date. However, the date of case closure should reflect the actual date the case was closed with the state. If the state continues to provide services to the youth after his or her 18th birthdate and the case remains open, or is closed beyond the age of 18, use that date as the date of closure (not the 18th birthday).
General Question:
If, during the PUR, multiple counties/offices in the state handled a case, should reviewers only rate the case based on the work of the county/office that had the case open during the time of the review?
No, reviewers must rate the case based on case practice that occurred during the entire period under review, regardless of which county or office was responsible for the case at the time of the review. The review focuses on statewide practice, and review findings reflect the outcomes for children and families that were achieved during a set period of time (period under review). States have the option of documenting county/office-specific issues in the open narrative field for each item if they would like to note specific concerns due to changes in county/office case assignments.
General Question:
In a foster care case, where are safety concerns in a foster care placement addressed in the OSRI—both accepted reports and safety concerns for the target child and/or other children in the foster care placement when the concerns could affect the target child’s safety?
Safety concerns in the foster care placement that affect the safety of the target child being reviewed are assessed in Item 3, question F1, and any safety concerns for the target child that were not adequately addressed by the agency are captured in Item 3, question F. Only accepted reports that relate to the target child in foster care or the children in the target child’s family are assessed in Item 1 and not with regard to other children in a foster family home or placement.
General Question:
We received a report concerning children remaining in the care of a parent after termination of parental rights of the target child, but the target child remains in foster care. Should we rate this in items 1 and 3?

Please refer to the new related FAQ in Item 1.
The termination of parental rights for the target child in foster care does not change the fact that the siblings are still part of the family's case and so information and circumstances related to them should be considered in rating items 1 and 3.
General Question:
There are significant (months) delays in transferring a case from investigation to ongoing services; however, once the ongoing caseworker is assigned, the family receives assessment and services, case planning, and regular worker contacts. How do case transfer delays impact outcome ratings?
Once the agency determines that a family requires services to keep children safe and to reduce risk of further abuse/neglect, the agency should make concerted efforts to provide those services in a timely manner. Significant (months) gaps in time that agency workers are not seeing children and assessing their needs can impact not only the physical safety of the children, but also their permanency and well-being. As with other gaps in service provision, reviewers will need to assess the total time that the case was opened for services during the period under review and consider the case circumstances and the impact of those delays on the outcomes for the family.

Safety Outcome 1

Children are, first and foremost, protected from abuse and neglect.

Item 1:
How should reports be documented in the Item 1 table?
Reviewers should list reports by date, per child, and per allegation. If the same child had multiple allegations that resulted in separate dispositions, each allegation should be indicated in a separate row in the table so that the disposition can be noted for each allegation. If multiple allegations received the same disposition, all allegations may be indicated in the same row. When tallying the number of reports in responding to questions A, B, and C, reviewers should not count each allegation or child as a separate report, but rather consider the date of the report as a distinct report made to the agency.
Item 1:
Parental rights were terminated prior to the PUR and the child was moved into his own individual case. During the PUR, there was a report of abuse and neglect involving the birth parents and one of the siblings. Is this captured under Item 1?
No, because the TPR occurred prior to the PUR and the target child was in his own individual case during the entire PUR.
Item 1:
We received a report concerning children remaining in the care of a parent after termination of parental rights of the target child, but the target child remains in foster care. Should we rate this in items 1 and 3?
The TPR for the target child in foster care during the PUR does not change the fact that the siblings are still part of the family's case; therefore, information and circumstances related to them should be considered in rating Items 1 and 3.
Item 1B:
Does “and requirements” in this question mean other contact requirements such as following the state's interview protocol?
The "requirements" noted in 1B refer to any requirements, beyond time frames, that are noted in state policies or statutes related to initial face-to-face contact with the children in accepted maltreatment reports.

Safety Outcome 2

Children are safely maintained in their homes whenever possible and appropriate.

Item 2:
Is item 2 applicable when the agency has determined that a child is safe based on the results of a structured decision making (SDM) instrument or other tool that was completed?
Reviewers should not rely solely on the results of a safety assessment tool to determine if safety concerns were present that would have necessitated the provision or arrangement of safety related services. Some safety assessment tools are designed to determine only if a child should remain in the home with protections and don’t necessarily assess for and identify needed safety services. If the reviewers determine that there were safety concerns present that immediately impact parents’ abilities to protect children and keep them safe which could lead to a child’s placement or re-entry into foster care – such as active domestic violence or substance abuse, or lack of supervision, for example - then the expectation would be that item 2 is applicable.
Item 2:
How do you apply the OSRI, Item 2, to cases involving a trial home visit during the PUR?
If it is a foster care case and the child was returned home on a trial home visit during the period under review, and the reviewer determines that there are concerns regarding the safety of that child in the home, then Item 2 would be applicable, per the applicability criteria. Reviewers would answer question A based on whether concerted efforts were made to provide or arrange for appropriate safety-related services to protect the child in the home during the trial home visit. When responding to question B, reviewers should consider a child's return to a foster home placement (from the trial home visit) as a "removal" from the home, for purposes of this OSRI item. Reviewers should apply the instructions for B in the same way that they would for a case involving an entry into foster care or a re-entry into care post-reunification.
Item 2:
The FAQ regarding how to apply the instrument to in-home cases in which the children are living with an alternate caregiver says that item 2 can be not applicable if the only thing necessary to keep the children safe during the period under review was a safety plan that placed the children with an alternate caregiver. So, if an alternative caregiver arrangement is in place to ensure the children’s immediate safety, does this relieve the agency of making immediate concerted efforts to provide services to the bio/legal parents either before or concurrent with the alternative caregiver arrangement to address the safety concerns that existed in the home?
No. Alternative caregiver arrangements are voluntary and temporary, and without services to the biological or legal parents the safety concerns that brought the family to the attention of the agency may still exist. If only an alternative caregiver arrangement is in place as a safety plan, reviewers should determine whether appropriate safety related services were needed and provided to the bio/legal parents to ensure the children’s safety, ameliorate the safety and protection concerns that brought the children to an alternative caregiver arrangement and prevent potential placement in foster care.
Item 3:
The directions related to ongoing risk and safety assessment clearly state formal and informal risk and safety assessment, but the directions related to the initial assessment (3A) do not have this wording. Can we still consider both formal and informal at the initial stage or should we focus only on formal assessments at this point?
Yes. In all of item 3 consider both formal and informal assessments for initial and/or ongoing assessments.
Item 3 (C):
As we are working through the Shawntese Jordan foster care mock case, I see that for Item 3C, there is a response of "N/A." We've had many questions on why this isn't "Yes." Is it because after the youth reunified, a formal safety plan was not completed? We have observed, though, that the agency was involved in assessing risk and safety after reunification and that the mom and youth knew what needed to happen and what couldn't happen. It seems there was at least an informal safety plan in place during this time and one could rate this item as "Yes." Would there be a significant conflict should a reviewer rate this item (3C) as "Yes" instead of "N/A"?
As explained in the rationale video for this mock case, question 3C is rated "Not Applicable" because there were no safety concerns when Shawntese was reunified, and therefore a safety plan was not needed. Item 3 requires that reviewers determine whether safety concerns were in fact present in order to assess whether the agency responded appropriately to safety concerns. In this mock case, the mother's mental health concerns had been addressed and appropriately managed for some time and housing was the only pending issue that needed to be resolved before reunification could occur. The worker ensured that the mother had a crisis plan in place and that the child and mother had a support system in place before reunification, but that is different from a safety plan that is controlling active threats to the child's safety in the home. If a reviewer selected "Yes" instead of "N/A" for question 3C, he or she would need to be able to identify what the actual safety threats were and how they were being controlled and mitigated by a safety plan. In this mock case, a "yes" response to 3C would not be correct.
Item 3 (D):
What kinds of safety issues should reviewers capture in Question D for a child in foster care? How is that unique from what is captured in Questions E and F?
In responding to Question D, reviewers must consider whether the safety-related incidents outlined in D1 were present in the foster care case. Recurring maltreatment may occur in a foster care case so reviewers must assess that. The other safety incidents outlined in D1 occur with the child’s family, typically in the family home. These kinds of concerns may be applicable to a foster care case if the child was reunified or placed on a trial home visit during the period under review. Questions E1 and E consider safety issues specifically related to visitation with family members (visitation here refers to periodic visitation and not a trial home visit) and Questions F1 and F focus specifically on safety issues that occur in the child’s foster care placements and/or with foster parents.
Item 3 (E):
In answering E in a juvenile justice services case, should a youth's behaviors be considered during visitation or only the parents' behavior?
If a youth's behaviors pose a risk to his or her own safety during visitation that should be considered in Item 3, question E. Reviewers should identify any concerns about the youth's safety as a result of the youth's behaviors in question E1 by selecting "Other" and describing the safety concern that existed for the youth. Since the focus of Item 3 is on child safety, any concerns related to the safety of others due to the youth's behaviors during visitation should be captured in Item 8 when responding to questions about the quality of visitation.
Item 3 (E, E1):
Should reviewers be answering E1 "Other" if there were safety concerns that were being mitigated? This would lead to an ANI that does not seem appropriate.
No, if safety concerns were mitigated, they would not be considered safety concerns in Item 3 E1 or E. Reviewers should only capture concerns that actually affected the safety of the child in questions E1 and E. If no unmitigated concerns existed, E1 should be answered, "No safety concerns related to visitation were present."
Item 3 (E, F):
For foster care cases, if there are NO safety concerns related to E and F, how should reviewers capture that in the instrument since there is no NA option for foster care cases?
Since there is no NA option in these questions for foster care cases, if there are no safety concerns related to E and F, reviewers should respond as follows: Reviewers should select the option, “No unmitigated safety concerns related to visitation were present,” in E1 and answer No to E. Reviewers should select the option, “No safety concerns existed for the target child while in foster care placement that were not adequately addressed,” in F1 and answer No to F.

Permanency Outcome 1

Children have permanency and stability in their living situations.

Item 5:
If the agency filed, or should have filed, for termination of parental rights (TPR) prior to the period under review (PUR) because the child was in care for 15/22 months prior to the start of the PUR, are reviewers supposed to assess whether the TPR was filed timely when they respond to question 5F?
No, question 5F is determining whether (1) a TPR was filed at any point prior to the PUR OR (2) if it was filed in a timely manner (in accordance with ASFA) during the PUR if the child reached the 15/22-month mark during the PUR. Reviewers only assess the timeliness of the TPR filing if it was due during the PUR. We do not assess the timeliness of a TPR filing in Item 5 when it occurred outside the PUR. • If a TPR was filed prior to the PUR, the answer to 5F is Yes. Timeliness is not considered because it occurred outside the PUR. • If the child has already been in foster care for 15 out of 22 months prior to the start of the PUR, and the agency DID NOT file a TPR prior to the PUR, there is no need to look for a TPR filing during the PUR. The answer to 5F in this case will always be No. • If the child reached the 15/22 mark during the PUR, but the TPR filed during the PUR was not done timely (i.e. not by the 15/22-month timeframe) reviewers should answer 5F with No.
Item 5:
When a child is in foster care and placed with a relative, do reviewers need a “compelling reason” documented in a case plan or court order to permit the 5G1 exception to TPR to be noted?
No, as long as the child is placed with a relative at the 15/22-month timeframe, a documented compelling reason is not required for the purposes of question 5G1. In this scenario, the first option for G1, "At the option of the state, the child is being cared for by a relative at the 15/22-month time frame." would be answered Yes.
Item 5:
If, prior to the PUR, the child was in care 15 out of 22 months and an exception was in place because the child was placed with relatives at the 15/22-timeframe, but during the PUR the exception no longer exists as the child has been moved to another non-permanent placement, do we consider the ASFA TPR requirement met in Item 5?
Yes. Title IV-E agencies need only apply the TPR requirement in section 475(5)(E) to a child once. If, when a child reaches 15 months in foster care, the state/Tribe does not file a petition for TPR because one of the exceptions applies, the state/Tribe does not need to begin calculating another 15 out of 22 months in foster care for that child. Therefore, the answer to 5F in this case is No because the agency didn’t file a petition to terminate parental rights prior to the PUR or in a timely manner during the PUR, and the answer to 5G, “Did an exception to the requirement to file or join a termination of parental rights petition exist?” would be Yes because the first option in 5G1, "At the option of the state, the child is being cared for by a relative at the 15/22-month time frame." would be answered Yes.
Item 4:
A child moved up to a higher level of care and the reviewer believes that the child’s behavior warranted the restrictive placement, so the move was in the child’s best interests. When could this be a Strength? What are the factors to support this?
Placements for children should be in the most family-like setting and the least restrictive environment that ensures safety. When a child is moved to a more restrictive higher level of care, reviewers must determine if appropriate measures were first taken to stabilize the initial placement through services and supports for foster parents. Ensuring that foster parents receive needed training, respite arrangements, and ongoing support is critical in supporting the stability of placements. If efforts were not made to stabilize placements before moving a child, that should be reflected in Item 4 in support of an “Area Needing Improvement” rating because the move to a more restrictive placement without first attempting to stabilize the previous placement would not have been the best way to meet the child’s needs. If the child’s safety could not be ensured while making efforts to stabilize a placement, then it could be determined that a move to a more restrictive setting was in fact in the child’s best interests to meet his or her needs, and this would be reflected as a Strength. Likewise, if the agency made efforts to support the placement through services to the foster family, and it was determined that the child later needed to be moved to a more restrictive placement, this too could be reflected as a Strength.
Item 4:
A state places a child in a 30-day Assessment program; all children going into the program are court-ordered into it. The program is designed to assess the child’s needs and determine appropriate placement and services for the child. Many, but not all, of the children ordered into the program are Juvenile Justice youth. If this is the first placement for the child, who is then reunified, how would we answer Question 4C regarding the stability of the placement?
Since these assessment centers are generally meant to be temporary, 4C1 would be answered, “The child’s current setting is in a temporary shelter or other temporary setting,” and 4C would be answered “No” because the most recent placement was not stable because it was a temporary assessment program.
Item 4:
In the placement table, if there are two foster care episodes during the PUR, what reason is used for the first one? Would it be “not applicable, this is the current placement,” or “other” with an indication that the child returned home?
Reviewers should use “other” and explain the circumstances.
Item 5:
A child was placed in foster care from February 1, 2013, and was discharged from foster care May 31, 2013. The child then re-entered foster care on September 1, 2013, and then was placed back with the parent for a trial home visit from February 1, 2014, to June 1, 2014. The child was then removed again on October 1, 2014, and placed in foster care, and remained in foster care at the time of the review. Does the count for 15 out of 22 months include the trial home visit months while the child was in the care of the state but placed in the home with the parent?
No, we do not include trial home visits (or runaway episodes) in calculating 15 out of 22 months in foster care (see 45 CFR § 1356.21(i)).
Item 5:
How do reviewers consider the timeliness and appropriateness of permanency goals when answering questions 5 B and C?
The expectation is that goal(s) are established with the child’s best interest for permanency in mind and drive the planning and activities to accomplish permanency for the child. Whether single or concurrent goals are in place, reviewers should consider whether each permanency goal was established timely and was based on the needs of the child and the case circumstances for the period of time in which the goal is in place. Reviewers should also factor in whether single and concurrent goal changes are being made timely and appropriately Reviewers should consider goals as inappropriate if they are selected or changed primarily due to the agency’s lack of resources, such as few preadoptive families, subsidy limitations, or agency and court process delays related to permanency.
Item 5:
A child was placed in foster care in State A but then the child was moved to a relative placement in State B where the case was transferred and is being reviewed. In calculating 15/22 months for ASFA in Item 5, would the count for length of time in out-of-home care begin with the date the child entered care in State A or the date the child's case transferred to State B?

The count for 15/22 begins with the date of the judicial finding of child abuse and neglect (usually the adjudicatory hearing) or 60 days after the child’s entry into foster care, whichever is earlier, so it would begin when the child first entered foster care in State A.
Item 5:
If there were concurrent goals established, but subsequently one goal is dropped and the other goal becomes the primary goal, which date should be used to determine when the primary goal was established—the date when it was established originally as a concurrent goal or the date when it changed to become a single goal?
Reviewers should use the date it was first established as a concurrent goal.
Item 5 (Permanency Goal Established):
If a child was placed in detention during a foster care episode, would the time in detention count toward the 60-day time frame for establishing a case plan?
No, a child’s time in detention should not be counted because the child is not considered to be “in foster care” due to the nature of the placement facility. The 60-day requirement for establishing a case plan is based on 60 days from the date on which the child was placed in foster care.
Item 5:
What if a family is receiving in-home services when the child's case is adjudicated, but then the child is removed from home a few months later? Would the count for 15 out of 22 months start at adjudication or at the removal date?
The provision to file a petition for a child who has been in foster care for 15/22 months only applies to children while they are in foster care, so the count would begin on the date the child entered foster care.
Item 5:
In determining the date on which the permanency goal was established, do reviewers need to use the date on which the goal was first indicated in a court order?
No. We do not require that the case plan goal be court-ordered for it to be considered “established” for CFSR purposes. If the case plan goal is identified in the child’s case plan, or described in an administrative review or case plan meeting, reviewers can consider this as the date on which the goal was established.
Item 5 (G):
If a compelling reason not to file termination of parental rights (TPR) was found, but that reason was not relevant during the entire period under review (case circumstances changed), is question G answered “yes”?
Yes. A compelling reason for not filing TPR needs to be made only once.
Item 6:
A child was on an Other Planned Permanent Living Arrangement (OPPLA) plan and there was no signed agreement with her placement (C2). The child was in a Supervised Independent Living (SIL) program and she did remain there beyond her 18th birthday. It was a stable placement for her and her own baby. From the reviewer guide, it seems that we can rate the item as a Strength even if there is no date for question C because the living arrangement was permanent. Is this correct?
While it is correct that the instrument does not require that there be a signed and dated agreement to justify a Strength rating, the reviewer must have evidence of formal steps that were completed to make the arrangement permanent to support the Strength rating. This should not be assumed solely because the child remained in the facility beyond her 18th birthday. Question 6C asks, “For a child with a goal of other planned permanent living arrangement during the period under review, did the agency and court make concerted efforts to place the child in a living arrangement that can be considered permanent until discharge from foster care?” And the instructions for that question ask the reviewer to consider:
  • The child’s current living arrangement and whether formal steps were completed to make this arrangement permanent.
  • Whether this might have included the agency’s asking foster parents or relatives to agree to and sign a long-term care commitment, or ensuring that a child who is in a long-term care facility to meet special needs will be transferred to an adult facility at the appropriate time.
Finally, the Quality Assurance guide says, “If question C is answered Yes but question C2 is answered “no date,” ask reviewers why they believe the child’s living arrangement can be considered permanent.” The intent of all of these instructions is to find out from the reviewer what concerted efforts/formal steps were made to make the arrangement permanent that could lead to a Strength rating.
Item 6:
If the agency achieves adoption for a child within 24 months, are there circumstances in which item 6 could be rated Area Needing Improvement?
Yes. The CFSR is not only a review of the child welfare agency, but the system as a whole, which includes the court and other entities working to achieve permanency for children. Item 6, Question B instructs reviewers to answer “no” to concerted efforts to achieve timely permanency if reviewers “determine that the agency and court have achieved the permanency goal before the suggested time frame, but there was a delay due to lack of concerted efforts on the part of the agency or court during the period under review”. Such delays could include or be a result of: not establishing timely and appropriate permanency goals, court docketing challenges, agency and/or court and attorney staffing limitations or high caseloads, agency policies and procedures that create barriers, etc. Reviewers will need to determine whether the delay is significant enough in light of the case circumstances to consider the item an area needing improvement.
Item 6:
If a youth turns 18 during the period under review, is the permanency goal in Item 6 considered achieved?
No. Reviewers need to answer 6B, 6C, and 6C2 based on the efforts the agency made during the PUR prior to the youth turning 18.
Item 6 (B):
The instructions for this item state: "If the only goal for the child during the period under review was other planned permanent living arrangement, select NA." If the child’s current permanency goal is OPPLA (established 2 months before end of PUR or case closure) and the child has no concurrent goal at that time, do the instructions guide reviewers to look at other goals that were in place during the PUR prior to the most current goal of OPPLA when answering 6B?
In Item 6, reviewers are asked to consider only current (or most recent) permanency goals. If the child's current goal is OPPLA and concurrent goals are not in place, 6B would be answered NA and only 6C would be answered Yes or No.
Item 6 (B, C):
The third bullet in the instructions for this item states: "If concurrent goals are in place and one of the goals is other planned permanent living arrangement but permanency will not be achieved in a timely manner, answer questions B and C No and indicate in the documentation specific barriers to implementing concurrent planning." Does "permanency" in the instructions refer to the concurrent goal in place that is different from OPPLA?
The third bullet in the instructions for 6B and 6C refers to cases in which the child has a goal of OPPLA and a concurrent goal of reunification, guardianship, or adoption and neither goal will be achieved for the child in a timely manner. Permanency in this bullet refers to both the achievement of the goal of OPPLA and the achievement of the other concurrent goal. In determining whether permanency can be achieved timely for the goal of OPPLA, reviewers should consider whether formal steps were completed in a timely manner to establish a permanent living arrangement for the child.
Item 6 (C):
Do reviewers always answer No to 6C if the concurrent goal other than OPPLA is not likely to be achieved but the child is placed in a living arrangement that can be considered permanent during the PUR?
No, if a child has a concurrent goal of OPPLA and the child is already placed in a living arrangement that can be considered permanent, question 6C would be answered Yes because the goal of OPPLA has already been achieved.

Permanency Outcome 2

The continuity of family relationships and connections is preserved for children.

Items 7 and 8:
The target child was separated from her siblings upon entry into care because a foster home could not be identified that would take a sibling group of four. This was determined to be a resource issue and Item 7 was rated as an area needing improvement. The agency worked to identify a home for the sibling group and they were placed together after 8 days. There were no face-to-face sibling visits during those 8 days, although the agency did facilitate phone calls. We wanted to rate sibling visits as NA for Item 8, but the OMS would not allow an NA response because the children were separated for a very brief time. We thought that NA would be appropriate, extrapolating from the guidelines for rating short-term foster care cases, which state that a child should have visits arranged within 1 to 2 weeks of being placed in foster care.
In this scenario, because the child was only placed apart from her siblings for 8 days during the PUR, and at the time of review the siblings were placed together, the reviewer should check “No” in Item 8 under Applicable Cases in response to “[t]he child has at least one sibling in foster care who is in a different placement setting.” In doing so, visitation for siblings would not need to be assessed in Item 8.
Item 8 (pre-applicability bullets):
How does a reviewer document in the OMS when different conditions apply to each parent when the pre-applicability bullets state that the condition applies to both parents? For example, one parent was deceased for the entire period under review and parental rights for the other parent were terminated during the entire period under review.
As long as one or more of the conditions applies to each of the parents, the reviewer can mark the item as not applicable for assessment for the parents from the Item 8 applicability page in the OMS. The reviewer should select the two (or more, if applicable) bullets that apply to the parents. Reviewers are encouraged to document which condition applies to which parent in the optional comments narrative field on each item applicability page, although reviewers could also put the information in the optional comments narrative field on the item rating page, or in a QA Note.
Item 8:
When assessing this item, can visits via Skype or FaceTime be considered face-to-face visitation? For example, the target child and her sibling were placed in different communities about 2 hours apart in the case being reviewed. The agency arranged for monthly in-person visitation and weekly visits through FaceTime.
Visitation between parents and siblings should be in person unless such contact is not possible. For example, the parents/siblings live far away in a different state. In the scenario described, in-person visitation is possible, so reviewers would assess whether the monthly in-person visitation that occurred was of sufficient frequency to maintain or promote the continuity of relationships between siblings and between the child and parents.
Item 8:
The definition for this item includes parents/caregivers from whom the child was removed and with whom the agency is working toward reunification. How do we assess applicability for multiple parents/caregivers? As examples, consider a child who lived with and was eventually removed from his mother and stepfather but had an ongoing relationship with his biological father (for example, weekend visits), or who was removed from grandparents but had an ongoing relationship with his parents. (Added October 27, 2014)
The goal of the item is to ensure that the child's previous relationships with parents/caregivers are preserved in a way that supports the achievement of permanency with those parents/caregivers. Reviewers should apply a general principle that is consistent with the definitions provided in the item: When biological parents are considered a potential reunification resource and have an established relationship with the child before the child’s entry into foster care, the biological parents should be included in the assessment of the item even if they were not the primary caregivers for the child at the time of removal. Any other parents/caregivers from whom the child was removed and with whom the agency is working toward reunification should also be included in the assessment of the item. The reviewer may also need to consider the timing of reunification plans during the period under review and how that affects which parents/caregivers are included in the assessment. Please note, applicability and definition of parents in items 8 and 11 are the same.
Items 8 and 11:
What level of prior relationship constitutes applicability for Item 8 and 11?
"Relationship" in Items 8 and 11 is defined as a meaningful connection between the child and the parent. The reviewer would need to consider the frequency and quality of contact, as well as the child's perception of the parent and their relationship, to determine whether this parent had an applicable relationship with the child. Permanency Outcome 2 is focused on preserving the continuity of relationships and connections that the child had before entry into care, so that context should guide the reviewer's understanding of what is meant by the term "relationship" in these items.
Item 9:
There are many items that address concerted efforts to meet the needs of a child; e.g., Item 9 addresses efforts made to maintain the child’s connections. How would an item be rated if the concerted efforts were made by others, and not necessarily the agency? For example, the child's connections were preserved but not as a result of anything done by the agency; e.g., the child and relatives ensured that connections happened?
If an outcome was achieved for a child, but not as a direct result of what the agency did, reviewers can consider the concerted efforts made by others involved in the child’s life. However, there may be some case situations where efforts made by others might not be the most appropriate expectation, and that should be taken into consideration when rating this item. For example, the child asked the worker to help make connections with an extended family member; the worker did not follow through, so the child asked someone else to step in and help facilitate the connection.
Item 9 (A):
instructions indicate that if prior to the placement in foster care the child had a relationship with the biological parent who was not the caregiver or not part of the case plan, that connection may be included in this item if it is in the child’s best interest to preserve that relationship. Are biological parents who did not have a previous relationship with the child prior to entry into foster care considered in this item? (Added February 6, 2015)
No, this item is focused on preserving connections that a child had prior to entry into foster care. So if the child did not have a previous relationship with the biological parent, that parent would not be assessed in this item. Developing a new relationship with this parent could be captured in Item 12B.
Item 9 (A):
This item has received some clarification about the need to preserve the child's important connections once they are removed, and the item is specifically about preserving connections (not establishing new ones) that the child had prior to entry in foster care. The tool allows us to N/A the item in the event of an abandoned infant, but we have additional questions specifically surrounding infants removed at birth. For an infant removed directly at birth from the parents, is that considered an applicable reason to N/A this item if the infant does not have any important connections at the time of removal? Or is an infant removed directly at birth applicable for assessment of this item?
An infant removed from his or her parents at birth would typically have connections to the birth family that should be preserved. Reviewers must explore the case circumstances to determine whether the case is applicable for assessment in Item 9. In the case of an abandoned infant, birth family connections are unknown; therefore, the item is not applicable.
Item 9 (C):
This question asks if the Tribe was provided with timely notification if the child may be a member of, or eligible for membership in, a federally recognized Indian Tribe. How would this be answered if the parent is eligible for membership in the Tribe, but has not done what is necessary to be enrolled? Is the child eligible for membership?
Eligibility for membership in a federally recognized Indian Tribe is determined by each Tribe. If the state is aware that a child may be Native American, the Tribe should be provided with notification so that eligibility can be determined by that Tribe.
Item 10:
We have a case where the child is placed with her uncle's ex-wife. In other words, this was her aunt by marriage. Since a divorce has occurred, is this woman still considered a "relative" for purposes of the CFSR?
In the example provided, the individual can be considered to meet the definition of "relative."
Item 10:
The tool defines a relative as a person related to the child by blood, marriage, or adoption. We had some questions as to whether certain people are relatives based on that definition. In one case the target child was placed with the adoptive parent of a half sibling. Some of us felt that met the definition and others did not. In another case the child was placed with the aunt and uncle of a half-sibling. Again there was debate about whether this met the definition of a relative.
Yes, in both examples described, the individual can be considered to meet the definition of "relative."
Item 10 (B,C):
A child was placed in a pre-adoptive home prior to the period under review and remained in this placement throughout the period under review; the adoption was finalized during the period under review. Are the questions in Item 10, Relative Placement, in B and C applicable in this case?
Yes. Item 10, questions B and C, are applicable even though the child was placed in a pre-adoptive home and the adoption was finalized. Reviewers should follow the instructions provided for questions B and C to determine if the agency made concerted efforts, prior to or during the period under review, to identify, locate, inform, and evaluate relatives in light of the child’s particular needs. If the agency had searched for and evaluated relatives prior to the period under review, then B and C could be answered as Not Applicable. If no search had been done prior to or during the period under review, then B and C would be answered No.
Item 10 (C):
If the agency did not make concerted efforts to search for a putative father, could this affect how this question is answered with regard to efforts to identify, locate, inform, and evaluate paternal relatives as potential placement resources for the child?
Question C would not be “not applicable” just because the agency did not attempt to search for a putative father. If the agency does not make efforts to locate a putative father, and therefore they were not able to identify, locate, inform, and evaluate paternal relatives, question C should be answered “no.”
Item 11:
The definition for this item includes parents/caregivers from whom the child was removed and with whom the agency is working toward reunification. How do we assess applicability for multiple parents/caregivers? As examples, consider a child who lived with and was eventually removed from his mother and stepfather but had an ongoing relationship with his biological father (for example, weekend visits), or who was removed from grandparents but had an ongoing relationship with his parents. (Added October 27, 2014)
The goal of the item is to ensure that the child's previous relationships with parents/caregivers are preserved in a way that supports the achievement of permanency with those parents/caregivers. Reviewers should apply a general principle that is consistent with the definitions provided in the item: When biological parents are considered a potential reunification resource and have an established relationship with the child before the child’s entry into foster care, the biological parents should be included in the assessment of the item even if they were not the primary caregivers for the child at the time of removal. Any other parents/caregivers from whom the child was removed and with whom the agency is working toward reunification should also be included in the assessment of the item. The reviewer may also need to consider the timing of reunification plans during the period under review and how that affects which parents/caregivers are included in the assessment. Please note, applicability and definition of parents in items 8 and 11 are the same.
Item 11:
How do we capture multiple parents in the OSRI?
Reviewers should note the names of all parents included in the narrative box that says, “Indicate the case participants who are included in this item as Mother and Father.” For example, if the child has one mother but two fathers, the biological father and the stepfather, reviewers would answer questions about the “Mother” using the mother in the case, and answer questions about the “Father” using both the biological father and the stepfather. If reviewers answer Yes for one father but No for the other, the answer to the question would be No. It is recommended (but not required) that the state explain the different responses for multiple mothers or fathers in the last narrative box after the rating criteria.
Item 11 (pre-applicability bullets):
How does a reviewer document in the OMS when different conditions apply to each parent when the pre-applicability bullets state that the condition applies to both parents? For example, one parent was deceased for the entire period under review and parental rights for the other parent were terminated during the entire period under review.
As long as one or more of the conditions applies to each of the parents, the reviewer can mark the item as not applicable for assessment for the parents from the Item 11 applicability page in the OMS. The reviewer should select the two (or more, if applicable) bullets that apply to the parents. Reviewers are encouraged to document which condition applies to which parent in the optional comments narrative field on each item applicability page, although reviewers could also put the information in the optional comments narrative field on the item rating page, or in a QA Note.

Well-Being Outcome 1

Families have enhanced capacity to provide for their children's needs.

Item 12:
If a child was living with relatives/guardians at the time of agency involvement and will remain with them, do the biological parents have to be considered as parents if their rights are still intact?
Per the instrument instructions, it would depend on the case circumstances. If the case goal is to continue to keep the children with the relatives/guardians and they are the legal custodians of the children, it may not be necessary to involve the birth parents, if the birth parents were not involved in the circumstances that led to the agency’s involvement with the family. If there is no legal/permanent arrangement with the relatives, and/or if the case was opened due to issues involving the birth parents, then the agency should be working with birth parents to address concerns and/or ensure that relatives can legally/permanently care for the children.
Item 12:
If the child was removed from the biological mother and stepfather or mother’s long-term boyfriend, does the child’s biological father have to be considered as a parent if their rights are still intact?
Yes, per the second bullet in the instructions, biological parents in foster care cases must be included, unless they meet the “Not Applicable” criteria outlined in the applicability instructions.
Item 12:
If a child was removed from relatives/guardians, do the biological parents have to be considered as parents if their rights are still intact?
Yes, per the second bullet in the instructions, biological parents in foster care cases must be included, unless they meet the “Not Applicable” criteria outlined in the applicability instructions.
Item 12:
CB provides a lot of feedback on how Reviewers rate Item 12: Needs and Services of Child, Parents, and Foster Parents. Is there further information available that can help us understand what Reviewers should be considering when examining how case participants’ needs are assessed and services are provided?
CB has developed a reviewer brief that provides background information and case examples. https://training.cfsrportal.org/resources/3105
Item 12:
If a child is living with his or her mother when they become involved in the agency and the father was not involved in their lives at the time, would the mother be the only person considered for these items even if the biological father’s rights are still intact but there is no evidence that the father desires to be involved in the child’s life? If the child does not have any contact with his or her father at the time of agency involvement or during the PUR, is there an expectation that the agency will seek out the father to determine if he has a desire to be involved with his own child?
Circumstances must be considered when determining whether to include an uninvolved father in the assessment of this item for in-home cases. For example, if the case was only opened for a short time and the concerns with the family were not significant (no ongoing safety issues or high risk concerns), it may not be necessary for the agency to contact an uninvolved father since the agency’s involvement is very limited. For cases that are court-involved and not voluntary, for cases opened for a longer period of time due to ongoing safety concerns, or for cases in which the mother is not successfully addressing the concerns, the agency should make efforts to contact and inform fathers about the status of the children and engage them in meeting the needs of the children.
Item 12 (A):
What case circumstances are considered acceptable reasons not to include a child living in the home in the assessment of this item?
The existing online training and OSRI instructions address this item. The online training notes: "Some circumstances to consider include the reason for the agency’s involvement with the family and the impact of any risk and safety concerns present during the period under review.” In the “purpose of assessment” for Item 12, the instrument states that "the purpose of this item is to assess whether the agency made concerted efforts to assess needs and identify and provide services necessary to achieve case goals and adequately address issues relevant to the agency’s involvement with the family." For in-home cases, you should consider the reason for the agency’s involvement with the family, the goals of the case, and the impact of any risk and safety concerns present during the period under review when determining the applicability of children in the assessment of item 12. If, for example, the agency became involved in a case because a parent was requesting mental health services for one of his or her children, and the other children in the home were not subject to any maltreatment concerns and did not require the same mental health services, it may be appropriate to focus only on the child receiving the services because that was the reason for the agency’s involvement with the family and there were no other risk/safety concerns for the other children. Similarly, for cases in which the agency became involved with the family due to a child’s experiencing juvenile delinquency issues, if the other children in the home were not subject to any maltreatment concerns and there are no risk and safety issues present during the period under review that affect the other children, it may be appropriate to focus only on the child for whom the delinquency issues are being addressed in the assessment of item 12. If the delinquency issues are affecting the safety of the other children in the home, and safety-related services are necessary, those would be captured in Item 3, not in Item 12.
Item 12 (A):
A child was in foster care for a period of time during the period under review. He or she is transitioned home and the case is kept open for services for several months after reunification. There are other children in the home who have significant needs. Should those be captured in Item 12A?
No. In a foster care case, Item 12A is only answered for the target child. Reviewers can capture the needs of the other children in 12B by assessing the needs of the parent(s) to care for those children and what services the agency provided to assist them.
Item 12 (B):
Definitions for parents in 12B indicate that adoptive parents should be rated in B if the adoption was finalized during the PUR. If those same adoptive parents had been foster parents during the period under review, do they only get assessed in 12B? Or in C? And would caregivers who became legal guardians during the PUR also be rated in B?
Yes, caregivers who became legal guardians during the PUR would be rated in B, similar to adoptive parents. If a foster parent became an adoptive parent or legal guardian during the period under review, reviewers would rate them as a foster parent in 12C up until the adoption or guardianship was finalized. If the case is kept open for services post-finalization or is opened again during the period under review, reviewers would rate them in B as adoptive parents or guardians for that portion of the period under review.
Items 12B, 13, 15:
We have some questions regarding a specific type of case and how to deal with the issue of engaging a non-custodial parent. In this case example, it is an in-home, non-court-involved case. We were wondering if there was any specific guidance on how to assess the non-custodial parent when the custodial parent refuses to provide identifying information or consent to contact the non-custodial parent. Since it is a non-court-involved case and we do not have custody of the child, how should the reviewer proceed (especially on Items 12B, 13, and 15) when the custodial parent does not want the non-custodial parent involved?
Per the definition of parents in Items 12, 13, and 15 for in-home cases, inclusion of a non-custodial parent is determined based on case circumstances. The following are examples of when it would be appropriate to expect agency engagement of non-custodial parents: • The non-custodial parent has ongoing contact with the children. • Children are at high risk of entering foster care; e.g., safety issues exist that cannot be mitigated in the short term, or the custodial parent is not compliant with safety services or the safety plan. • The non-custodial parent was notified/made aware of child welfare agency involvement and has a desire to be involved as a resource for the children. In situations where a custodial parent refuses to allow the agency to contact a non-custodial parent, the agency would be expected to include the non-custodial parent only if the court orders his or her involvement, if the children are at risk for foster placement, or if the children have ongoing contact with the non-custodial parent that necessitates an assessment of that parent. Note that if the above circumstances exist, but the custodial parent expresses a history of abuse, neglect, domestic violence, substance abuse, etc., by the non-custodial parent, this should be taken into consideration and assessed accordingly.
Items 12, 13, 15:
A child is placed with a relative, but the relative does not have a legal relationship; e.g., guardianship. The child is removed from the relative and the plan is reunification with the relative because the parents are unable to care for the child. Should items 12, 13, and 15 be rated only for the birth parents because the relative is not a legal guardian? Or should the relative be considered for these items?
Items 12, 13, and 15 should consider the relative as well as the birth parents in this situation because the plan is to reunify the child with the relative. Regardless of the child's legal relationship with the relative, it is important for the agency to review the assessment and services provided to that relative, the involvement of the relative in case planning, and worker contacts with the relative to ensure that the child can achieve a safe and successful reunification.
Items 12, 13, 15:
How should reviewers apply the OSRI to foster care cases with an alleged father?
The agency must have made concerted efforts to identify and locate alleged fathers in order for questions related to fathers in Items 12, 13, and 15 to be answered Not Applicable (NA). If the agency did NOT make concerted efforts to identify/locate the alleged father, the lack of efforts regarding the father would be rated in Item 12 (Question B2 would be answered No), resulting in an Area Needing Improvement (ANI) rating for Item 12, and the questions related to the father in Items 13 and 15 would be answered NA. If the child came into foster care before the period under review (PUR), the agency made concerted efforts to identify/locate the alleged father before the PUR, and there were no case circumstances during the PUR that would warrant further efforts (e.g., additional information about the father’s identity or location was discovered), questions related to the father in Items 12, 13, and 15 would be answered NA.
Items 12, 13, 15:
The CFSR QA guide instructs reviewers to rate Items 13 and 15 not applicable if Item 12 is rated as an Area Needing Improvement (ANI) because there were not concerted efforts to locate a parent. Would the need to rate Items 13 and 15 as not applicable apply in any other situations where the agency was cited with ANI for Item 12B (example: parent is incarcerated and will continue to be until long after the child turns 18, but the agency never contacted the parent to evaluate interest in the child, and never assessed for plan)?
The applicability instructions for Items 13 and 15 provide guidance on when these items are not applicable. But the example above would not necessarily apply unless the agency made efforts to rule out the appropriateness or need for parental involvement. Just because a parent is incarcerated—and will be for a long time—doesn't negate the agency's responsibility to reach out to that parent to ask about their desire to be involved, and to assess the appropriateness and level of their involvement.
Item 12, 13, 15:
What must be taken into consideration when determining inclusion of a non-custodial parent for in-home cases?
Per the definition of parents used for in-home cases in Items 12, 13, and 15, inclusion of a non-custodial parent is determined based on case circumstances. The following are examples of when it would be appropriate to expect agency engagement of non-custodial parents: • The parent has ongoing contact with the children. • Children are at a high risk of entering foster care; e.g., safety issues exist that cannot be mitigated in the short term or the custodial parent is non-compliant with safety services or the safety plan. • A non-custodial parent was notified/made aware of child welfare involvement and has a desire to be involved as a resource for the children. In situations where a custodial parent refuses to allow the agency to contact a non-custodial parent, the agency would only be expected to include that parent if the court orders the non-custodial parent’s involvement, the children are at risk for foster placement, or the children’s having ongoing contact with that parent would necessitate a parental assessment. Note that if the above circumstances exist, but the custodial parent indicates a history of abuse, neglect, domestic violence, substance abuse, etc., by the non-custodial parent, this should be taken into consideration and assessed accordingly.
Item 14:
For a child who is in pre-adoptive placement out of state (OOS), the sending state requires the caseworker to visit every 6 months. For the remaining 5 months they contract with a local social worker for visits. Since the local social worker does not seem to fit the definition of the “other responsible party” as noted in the instrument, are reviewers unable to count the visits made by the local social worker?
When we are talking about a child placed out of state, reviewers can consider the local worker as a “caseworker” if they are a caseworker from the jurisdiction in which the child is placed, even if they don’t meet the definition of “other responsible party.” This is why we included special instructions for out-of-state cases: "If the child is in a placement in another state, you should determine whether a caseworker from the jurisdiction in which the child is placed, or a caseworker from the jurisdiction from which the child was placed, visits with the child in the placement on a schedule that is consistent with the child’s needs." In this particular case, since the state has made arrangements for an out-of-state worker to visit the child in addition to doing their own visit every 6 months, the reviewers should consider the work done by the out-of-state worker in addition to the sending worker, and assess all of those efforts in meeting the child's needs.
Item 14:
With respect to Item 14 and out of state placements, the Round 2 instrument specified that the sending state caseworker visits are at least annually as required by federal law. We did not see that language in the new tool and were curious if we should still consider that in rating our out-of-state placements.
There is no requirement for annual visits by sending state caseworkers, so that should not be a factor in rating cases. Rather, reviewers should use the Item 14 instructions provided in the R3 instrument about children in out-of-state placements, which indicate that "[i]f the child is in a placement in another state, you should determine whether a caseworker from the jurisdiction in which the child is placed, or a caseworker from the jurisdiction from which the child was placed, visits with the child in the placement on a schedule that is consistent with the child’s needs." In determining whether the schedule of visits was adequate, reviewers should consider the specific child’s needs as well as the instrument instructions that guide reviewers to consider a standard of monthly visits unless there is substantial justification that a pattern of visits that was less than monthly was adequate for the child.
Item 14 (B):
The instructions indicate that reviewers must rate "no" for the sub-item if the caseworker did not see the child alone for at least part of each visit if the child is older than an infant. How should reviewers rate this if the child is older than an infant but has not reached the stage in development where he or she is comfortable being away from the parent? Would we be able to rate the item "yes" if the parent is within sight or hearing of the child but not in close proximity to the child and caseworker; e.g., in another room but still within sight?
If reviewers determine that the visitation is conducted in a way that is sensitive to the child’s needs but allows the caseworker to determine the safety and well-being of the child, then B can be answered “yes.”
Item 15:
Can we count family team meetings, case planning meetings, and other types of visits with the mother as "visits" for the frequency measure for Item 15?
In Item 15, a "visit" is defined as "face-to-face contact between the caseworker or other responsible party and the parent." In answering questions A2 and B2 (if the frequency of visits between the caseworker and mother/father is sufficient to address safety, permanency, and well-being of the child and promote achievement of case goals), reviewers may include non-private visits such as family team meetings, case planning meetings, and supervised visitations if it involves face-to-face contact between the caseworker/responsible party and the parent. However, reviewers will need to address the quality of those visits in questions C and D. To determine the quality of the visits, reviewers will need to consider the location of the visit, including whether or not the location was conducive to open and honest communication between the parent(s) and caseworker.
Item 15 (A2, B2):
How do caseworkers’ efforts to contact parents get assessed in these items? What happens if there is only minimal contact but there is thorough documentation of efforts by the worker to make contact?
Item 15 is rated on visits that actually occurred with parents. If a parent's whereabouts are unknown, despite the agency's efforts to locate them, that parent may not be applicable for an assessment of this item (see applicable-cases instructions for Item 15).
Item 15 (A2, B2):
Instructions indicate that the answer to A2 and B2 should be No if the typical pattern of contact is less than once a month, unless you have a substantial justification for answering either question as Yes. What would be considered substantial justifications? It is our understanding that the response to this item should be based on visits that actually occurred with the parents. If the worker is only able to successfully meet with the parents less than once a month but is able to document efforts to meet with the parents during the months the worker is unsuccessful, could this item be rated as a Strength if there is sufficient information to support that the worker is able to address safety, permanency, and well-being during the months that the worker is unable to meet with the parents?
Item 15 explains that the purpose of the assessment is to determine whether, during the period under review, the frequency and quality of visits between caseworkers and the mothers and fathers of the child(ren) are sufficient to ensure the safety, permanency, and well-being of the child(ren) and promote achievement of case goals. Item 15 should be rated according to visits that actually occurred with the parents and should consider the quality of those visits in addressing safety, permanency, and well-being and achievement of case goals. The OSRI instructions for 15C and 15D provide information regarding things to consider when determining the sufficiency and quality of the visits. Justification for less-than-monthly visits is a case-specific issue and is difficult to answer, but reviewers should consider the documented efforts made by the worker to meet with the parents, the reasons why a parent was non-responsive, and whether less-than-monthly visits were sufficient to address the safety, permanency, and well-being of the child(ren) and achievement of case goals given the specific case issues.

Well-Being Outcome 2

Children receive appropriate services to meet their educational needs.

Item 16:
In cases in which an early intervention assessment is arranged due to a substantiated maltreatment report in accordance with CAPTA requirements, should this item be rated? As part of our ongoing CQI, our state has been rating this item even if we indicate that an assessment was conducted and there were no needs. But in cases where the agency failed to make the referral and there are no known developmental delays, we are not faulting the agency and are rating the item as Not Applicable.
In determining the applicability of Item 16, note that the instructions read, "Foster care cases are Not Applicable if the child is age 2 or younger and there are no apparent developmental delays."

Well-Being Outcome 3

Children receive adequate services to meet their physical and mental health needs.

Item 17:
What is the expected periodicity of dental exams in rating Item 17?
The American Academy of Pediatric Dentistry (AAPD) recommends dental exams every 6 months that include oral screening, risk assessment, and preventive care for most children. Some children need more frequent dental visits because of increased risk factors such as increased rate of tooth decay, unusual growth patterns of teeth, or history of poor oral hygiene. When determining whether the frequency of dental visits is sufficient with a pattern of less than every 6 months, factors that should be considered include whether the last dental visit was within 1 year and whether there was no evidence of tooth decay or disease. When determining whether the frequency of dental visits should be more than every 6 months, factors that should be considered include whether the child has a history of decay or disease based on the results of the last dental visit or a history of poor oral hygiene.
Item 17 (A2):
What age is considered too young for a dental exam?
The American Academy of Pediatric Dentistry recommends that children see a dentist as soon as their first tooth comes in or by their first birthday. The same guidelines are used in the Early & Periodic Screening, Diagnosis, and Treatment Services program.
Item 18:
In some cases, there are many services being provided for the child’s mental/behavioral health, including medication, but the child’s behavior, placement stability, etc. is not improving. How do reviewers consider the progress of the child or lack thereof in rating this item?
Reviewers are expected to evaluate the quality of assessments and services provided to ensure that adequate efforts were made to address needs. If a child/youth is not progressing, we would expect to see that the agency has made efforts to continually assess the adequacy of therapeutic interventions and make needed modifications. Reviewers should look at relevant reports, assessments, and conduct appropriate interviews when possible to determine the adequacy of services provided. The rating for Item 18 should reflect the adequacy of efforts made by the agency to assess needs accurately and ensure services appropriate for meeting those needs. There may be situations where a child’s behavior does not show improvement despite the best efforts to address concerns, and that should not negatively affect the rating.