Audit Report on the Administration for Children’s Services’ Controls Over Its Investigation of Child Abuse and Neglect Allegations

EXECUTIVE SUMMARY

The Administration for Children’s Services (ACS) was created in 1996 to ensure the safety and well-being of children in the City of New York (the City).  ACS’ Division of Child Protection (DCP) is responsible for protecting children who are abused or neglected and for ensuring that they and their families are provided services specifically tailored to their needs.  DCP’s Child Protective Services Borough Offices (borough offices) are responsible for investigating reports of alleged child abuse and neglect.  The borough offices investigate an average of roughly 60,000 reports of alleged child abuse and neglect each year.

An investigative team consisting of a Child Protective Manager (manager), a Child Protective Specialist Supervisor (supervisor), and a Child Protective Specialist (case worker) conducts the investigation.  Deputy Directors of each borough office are responsible for overseeing investigations and are also responsible for ensuring that managers perform their required reviews.  The investigative team must conduct a thorough assessment of the safety risk level of every child in the household.  All of the details of each investigation must be documented by the case worker and supervisor in a timely manner within progress notes.  Supervisors are supposed to regularly review the case workers’ progress notes and make comments and suggestions there as needed.  At the conclusion of the investigation, if no credible evidence exists, the report is deemed “unfounded.”  If the investigation reveals that “some credible evidence” of child abuse and neglect exists, the report is deemed “indicated.”

The objective of this audit was to determine whether ACS has adequate controls over the process for investigating allegations of child abuse and neglect.

Audit Findings and Conclusions

ACS lacked sufficient controls over its process for investigating allegations of child abuse and neglect.  Although ACS has established formal guidelines that govern the process, it has not developed sufficient controls to ensure that those guidelines are followed.  We found limited evidence that supervisors and managers performed required case reviews on a consistent basis.  We believe that this is due in large part to management’s failure to develop an effective mechanism to gauge compliance with investigatory guidelines.  We also question whether ACS has applied sufficient resources to support the investigatory function.  These weaknesses hinder ACS’ ability to ensure that investigatory steps are conducted in a timely manner.

Insufficient oversight to ensure that ACS staff consistently follow guidelines and directives weakens any controls that may be established and increases the risk that investigatory results may be flawed.  Consistent with this concern, our review of 25 sampled cases revealed multiple areas within each case where staff did not adhere to ACS guidelines and these issues were not detected during the course of the investigation.

At the exit conference for this audit, ACS officials stated that some of the investigatory procedures they previously supplied to us during the course of the audit were provided in error because they were outdated and no longer applicable.  Consequently, the officials contended that a number of the findings in this report of inadequate controls are not significant or no longer valid.  However, the newly provided information does not support their current assertions.  To begin with, even if we accept their new claims at face value, the fact that agency officials originally provided inapplicable procedures to us thinking that they were current is itself evidence of a profound lack of controls over the agency’s investigatory process.  Moreover, ACS officials acknowledged that some of the information recently provided to us was not incorporated into current procedures available to staff.  Other information dated from the year 2000 was identified as applicable to ACS staff responsible for working with families with histories of indicated cases receiving services from Protective, Preventive and Foster Care Providers, which is not the subject of this audit.  Accordingly, it appears that rather than seeking to strengthen its policies and procedures and to better help the vulnerable children in its charge, ACS has resorted to trying to discredit our findings with irrelevant and possibly outdated procedures.  This action raises significant concerns about the ability of ACS management to correct the weaknesses identified in this report.

Audit Recommendations

To address the issues raised by this audit, we make the following seven recommendations:

• ACS should formulate an efficient internal control system, including uniform policies and procedures that are distributed to its staff in a timely manner.
• ACS should ensure that managers and supervisors perform timely reviews during all stages of the investigation, as well as ensure that case workers perform all key steps of an investigation.
• ACS should develop a system that allows the recording of managerial reviews in a manner that can be clearly documented in terms of when they were performed.
• ACS should ensure that Deputy Directors properly track managerial random reviews so that they can be certain that all random reviews were performed and in the required time period.
• ACS should conduct a study to determine the adequacy of its current case load requirement to determine if it is appropriately staffed to perform thorough investigations. Depending on the study’s findings, ACS should use this study as justification for seeking additional funding from the City’s Office of Management and Budget to hire additional case workers.
• ACS should ensure its staff complies with all aspects of an investigation, including following supervisory directives, complying with guidelines and maintaining notebooks during the course of an investigation.
• ACS should ensure that case workers update progress notes in a timely manner and that this aspect is carefully monitored by the supervisors.

Agency Response

In their response, ACS officials agreed with six of the seven audit recommendations, stating that they have already taken action to begin implementing them.  In addition, they stated they would take the remaining recommendation under consideration.