Annual report 2017

Georgia Office of the Child Advocate for the Protection of
Children
2017 Annual Report
Tom C. Rawlings, Director State Office of the Child Advocate

7 Martin Luther King Jr. Drive, Ste. 347 d

Atlanta, Georgia 30334
oca.georgia.gov

(404) 656-4200

Nathan Deal Governor

OFFICE OF THE CHILD ADVOCATE

Tom C. Rawlings Director

January 9, 2018

By Hand Delivery

Hon. Nathan Deal Governor, State of Georgia

Hon. Casey Cagle Lieutenant Governor Georgia State Senate

Hon. P. Harris Hines Chief Justice Georgia Supreme Court

Hon. David Ralston Speaker Georgia House of Representatives

RE: Transmittal of 2017 Annual Report Office of the Child Advocate

Dear Governor Deal, Chief Justice Hines, Lt. Gov. Cagle, and Speaker Ralston:

On behalf of the Office of the Child Advocate, I am pleased to provide you with this report of the work done by our office over the past year work that each of you has made possible.

Over the past year, our office has worked in tandem with DFCS, the courts, and the child advocacy community to find ways of improving our state's effectiveness at combating child abuse and neglect. I remain encouraged at the extent to which leaders in our state show such a willingness to work across the lines of agencies and branches of government.

As the report reflects, we were able to initiate this year a multi-disciplinary training and networking conference that brought together juvenile court judges, child welfare attorneys, DFCS staff and leadership, and a host of professionals who work with children. It is this kind of cross-disciplinary cooperation that we continue to strive for in 2018.

We especially want to thank Governor Deal for the work of his Children's Mental Health Commission and commend its recommendations to the legislature. We also hope that, working together, we will find ways to expand the sharing of educational, medical, and

Office: 404-656-4200

7 Martin Luther King Jr. Drive, Suite 347, Atlanta, Georgia 30334

Fax: 404-656-5200

Transmittal Letter: OCA Annual Report January 9, 2018 Page 2
law enforcement data among DFCS and our child-serving agencies so that we can better predict child abuse and prevent its recurrence. Thank you for the leadership you show and for the opportunity to work with you. Regards,
Tom C. Rawlings Director, OCA

2017 OCA Advisory Board Members
Render Heard, Tifton Judicial Circuit (Juvenile Court Judge) Laura Eubanks, Gwinnett County Public Schools (Social Worker) Lisa Jones, Southwestern Judicial Circuit Judge (Juvenile Court Judge) Jose Rodriquez, WellStar Kennestone Pediatric Associates (Pediatrician) Brad Ray, Executive Director CASA (Court Appointed Special Advocates)
7 Martin Luther King Jr. Drive Ste. 347 Atlanta, GA 30334 (404) 656-4200
www.oca.georgia.gov

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Table of Contents OCA's Mission...................................................................3 2017 Changes at OCA .......................................................5 Responding to Complaints and Concerns........................5 Major Projects ..................................................................8
Cold Case Project ............................................................8 Peer Review Project........................................................9 The Summit...................................................................10 Child Abuse Protocol.....................................................11
Other Projects and Initiatives ........................................11 State of Child Welfare: 2018 Recommendations .........14 Appendix A: OCA Statute ..............................................21 Appendix B: Peer Review Evaluation............................27 Appendix C: Child Abuse Protocol Evaluation ..............42

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OMBUDSMAN \m-bud z-mn \ [noun]:
One that investigates, reports on, and helps settle complaints.
"The word "Ombudsman" can be found in Old Swedish as the word umbudsmann (accusative) and as umbuds man, meaning "representative." The modern meaning of the term emerged when the Swedish Parliament appointed an Ombudsman in 1809 to safeguard the rights of citizens through establishment of a supervisory agency independent of the executive branch."
1
OCA's Mission
When the Legislature created this agency in 2000, it intended the office to serve as an independent ombudsman for Georgia's child protection system. "It is the intent of the General Assembly that the mission of protection of the children of this state should have the greatest legislative and executive priority," the legislators declared. Thus, the agency's primary mission is "to protect the children of the State of Georgia and to assist and restore the security of children whose well-being is threatened by providing independent oversight of persons, organizations, and agencies responsible for providing services to or caring for children who are victims of child abuse and neglect or whose domestic situation requires intervention by the State."2
1 http://federalombuds.ed.gov/federalombuds/ombuds_FAQs.html 2 OCGA 15-11-740 (b). The Act establishing our office is in Appendix A.

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The statutes creating OCA envisioned that the bulk of our work would involve investigating and responding to complaints regarding children who are, or whose families have been, the subject of a DFCS report within the prior five years.3 Therefore, the bulk of our work involves responding to concerns lodged by parents, children, relatives, foster parents, and child welfare professionals regarding the way the agency or its contractors have handled a child protection case. We use these complaints and our resulting investigations not only to address the issue that may have arisen but also as a way of identifying trends within the child protection system. Then, carrying out our other main statutory mandates to collaborate with the child welfare community and to recommend changes in practice, we proactively take on projects designed to improve child safety, the child protection process, and outcomes for Georgia's abused and neglected children.4
Additionally, the General Assembly has entrusted to this agency a number of other statutorily-mandated roles. OCA monitors statewide the creation and implementation of local child abuse protocols, which are designed to ensure the appropriate multidisciplinary investigation and handling of child abuse cases, especially those involving sexual and serious physical abuse. We are also charged with training those local teams, and we annually update a statewide model child abuse protocol.5 The State Child Advocate serves as a member of the Statewide Child Fatality Review Committee, which is itself tasked with studying and finding ways to reduce the deaths of Georgia's children.6 Guardians ad litem who safeguard the best interests of children in juvenile court must be certified through training approved by the Office of the Child Advocate.7

3 OCGA 15-11-741, 15-11-742. 4 OCGA 15-11-743. 5 OCGA 19-15-2; see Appendix C for the summary of our protocol training this past year. 6 OCGA 19-5-4; for more information on the Child Fatality Review Committee, visit https://gbi.georgia.gov/CFR 7 OCGA 15-11-104 (f).

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2017 Changes at OCA

OCA's 2017 year opened with the appointment by Governor Deal of a new State Child Advocate, Tom Rawlings, who returned to the position in which he served under
Governor Sonny Perdue from 2007-2010. Ashley Willcott, who had served as State Child Advocate from 2013-2016, returned to private child welfare law practice but remains very involved with OCA as the lead attorney on the Cold Case Project.8 Director Rawlings brought in a new Deputy Director, Rachel Davidson, a skilled child welfare
attorney who previously represented children in dependency proceedings and served in critical roles at the State Division of Family and Children Services, including a position as liaison between the agency and the juvenile courts. Diana Summers,
whose expertise lies in administration, grants, and data management and analysis, rounded out the new leadership team.

Davidson

With the exception of new leadership, however, OCA's experienced team of investigators remained in place: Chuck

Pittman, Vickie White, Ryan Sanford, Renee Moore, and Shantelle

Whitehead.

Rawlings

Responding to Complaints and Concerns

Concerns and complaints from the public come to OCA in a number of ways. The

public may call us at (404) 656-4200 and speak with our intake staff to file a complaint, and many of our reports come 500 through our online complaint form.9

OCA Case Numbers by Case Type (excluding Governor's Letters) 2016 vs. 2017
414

Additionally, we receive calls from judges, 400

legislators, and agency officials who have

concerns about a case or who call on

300

behalf of a child or constituent. Our

200

201

184

agency is also notified of letters, emails,

and calls that Governor Deal's office

100

receives and that are most often handled

0

by DFCS' internal constituent services

109 10
Case

105 104 69

CDSINF

Investigation

TOTAL

staff. Should these concerns not be

Review/Assist.

2016 2017

8 See Cold Case Project discussion, pp. 6-7. 9 https://oca.georgia.gov/webform/request-oca-assistance-or-investigation

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resolved within DFCS, we from time to time will undertake an investigation related to the concern.
Between January 2017 and the end of November 2017, OCA opened a total of 291 new cases (see figures 1 and 2). Many of these cases (103, or 35%) involved situations in which OCA reviewed a death, near fatality, or serious injury that occurred to a child whose family had involvement with DFCS within the five years prior to the significant incident. We review these cases to determine whether the agency's prior involvement with the family was sufficient and whether the agency could reasonably have taken measures to prevent a subsequent incident of abuse or neglect. For several years, OCA has facilitated the group of DFCS staff, service providers, and other professionals who review these cases.
In the majority of these serious incidents, we find the child's death or injury to be unrelated to the family's prior involvement with the child protection agency. For example, DFCS may become involved with the family of a medically fragile newborn not due to allegations of abuse or neglect but rather because the family needs additional support to care for that child. If the child later dies from the medical condition, the case is one that DFCS and OCA will consider for possible review.

Case Rev. 3%
Invest. 28%

Assist. 23%

Gov. Ltr. 11%

CDNFSI 35%

Figure 1: Types of cases opened in 2017 through 11/30, by percentage

120 103

100

81

80

66

60

40

31

20

10

0

CDNFSI

Invest. Assistance Case Gov. Letter Review

Figure 2: Number and type of cases opened by OCA in 2017 (through 11/30)

During the first 11 months of 2017, OCA responded to a number of complaints by investigating, providing a constituent with information and assistance, or by simply

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reviewing the case to ensure all was well. In its review of complaints and cases, OCA attempts to determine whether there were problems in the implementation of child protection policy or errors in practice. Of the 241 cases we opened and closed through November 30, 2017, we found policy violations in 10% and noted child welfare practice deficiencies in 24%. The leading issues we found were problems in providing adequate assessment of a child or family's situation and problems in providing adequate services to families. The most common complaints we received from the public involved insufficient investigations of child abuse complaints and concerns regarding child placement.
Under its new director, OCA has put an emphasis on timely resolution of complaints and on cutting down the amount of time a case remains open. As a result of this new focus, we were able to cut our caseload from 417 open cases at the beginning of January to 231 open cases at the beginning of December. The amount of time our cases remain open reflects their level of difficulty. When we are reviewing a file or reviewing a child death or serious injury, we find it takes between 11 and 17 days to finalize our assessment. Cases in which we are providing assistance to a family, a provider, a child, or the public remain open around a month. Investigations, in which we are digging more deeply into the case to find the cause for an alleged problem and a solution to that problem, remain open for an average of two months.

Governor Deal with incoming and outgoing OCA Staff at Director Rawlings' Swearing-in, January 2017

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Major Projects 2017

As a small ombudsman agency, OCA cannot (and should not) attempt to involve itself in every aspect of Georgia's child protection and child welfare system. Rather, we must prioritize efforts that we believe will have the greatest impact to improve the system, its efficiency, and its effectiveness. In 2017, we continued or began a number of projects through which we could bring our expertise to bear to improve outcomes for children and which involved working across disciplines and agencies to improve Georgia's child protection system. These included:

The Cold Case Project; The Peer Review Project; The Summit, Georgia's Child Protection
Conference; and Child Abuse Protocol Development and
Training.
The Cold Case Project
Since 2009, OCA has collaborated with the Supreme Court of Georgia's Committee and DFCS to review and resolve some of the most difficult cases in our child welfare system: those in which children have lingered in foster care for long periods of time without returning to a safe home or finding a safe, stable, permanent family.
The "Cold Case" Project ("CCP") so named because it addresses children whose search for permanent, safe, stable families has grown "cold" and whose cases need an injection of new heat and energy is driven by a software algorithm that mines DFCS' database to find those children who have been in foster care for long periods of time and who are likely to age out of the system without permanency. CCP Fellows experienced child welfare attorneys then review the cases, schedule meetings or permanency roundtables with all DFCS staff, attorneys, therapists and the children and families involved, and search for ways to ensure that children do not age out of foster care without a permanent family setting.

A COLD CASE PROJECT SUCCESS STORY
Cold Case Project fellows worked with "Tim," a teenager who had spent 54 months in care, had gone through 11 different placements, and who had significant behavioral health issues.
Although both parents' rights had been terminated, Tim's father remained in contact with him, and Tim wanted to return to his father.
CCP staff worked to strengthen the bond between Tim and his father, ensuring that the father had special training to learn how to address Tim's needs.
The Court reviewed the case and reinstated the legal relationship between Tim and his father, restoring a family for Tim.

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The project is led by Ashley Willcott, and this year's fellows were Kristi Lovelace, Amanda Dean, Kellie Rogers, Diana Rugh-Johnson, Karlise Grier, Rosalind Zolicoffer, Jane Okrasinki, Mary Hermann, Vicky Wallace, and Michelle Vereen.

In 2017, CCP staff and fellows reviewed more than 235 new files and conducted over 160 "roundtable" staffings. In past years, we have found this work to substantially increase positive outcomes for children. The 2017 Cold Case Project Report will be issued in 2018, and the 2016 report is available online.10

The Peer Review Project In 2017, OCA continued a valuable project we have undertaken for several years
to improve juvenile court processes and outcomes. Working with Jerry Bruce (a former juvenile court judge who serves as Program Attorney for the Supreme Court's
Committee on Justice for Children) and a number of highly-experienced and certified child welfare attorneys, OCA in 2017 visited juvenile courts in 17 different jurisdictions. At OCA, we are cognizant of the fact that protecting a child's rights to be heard, to be protected, and to live in a safe, stable family is the vital role of the juvenile courts and the attorneys who represent parties in those courts. Our Peer Review Project has, therefore, focused on improving the court processes that create those outcomes.

OCA's experts were especially interested in observing

how different jurisdictions address the rights of children

involved in dependency and termination of parental

Peer Review Counties 2017

rights cases to have both a court-appointed attorney to represent their wishes11 and a guardian ad litem and/or

CASA to represent their best interests.12 We also made efforts to note the different

methods by which courts consider the participation rights of children; how different

courts receive evidence; whether children and foster parents were notified of hearings;13

and the extent to which parents, children, and DFCS were represented by legal counsel

during these important proceedings.

10 https://sites.google.com/site/gacoldcaseannualreport2016/ 11 OCGA 15-11-103. 12 OCGA 15-11-104. 13 See OCGA 15-11-109.

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While full details of the 2017 findings are available in Appendix B, a few findings from our observations stand out. Some courts, we found, are not ensuring the child is present for hearings affecting him or her and has the ability to share his or her concerns.14 Having the child present is especially important for youth and older children. At OCA, we often hear complaints from young adults who were in foster care that they never felt included in the court decisions affecting their lives. We also found that some courts are not holding the child protection agency's feet to the fire when it comes to the requirement that DFCS diligently and continually search for relatives who might be able to take custody of a child.15 Our Peer Review observations have formed the basis for ongoing trainings that OCA and the Supreme Court's Committee on Justice for Children provide to child welfare attorneys and other court partners.

The Summit, Georgia's Child Protection Conference

In what we

hope will be an annual

event that will grow in Governor Deal addresses the Summit attendees

both size and impact,

OCA teamed up with DFCS, the Georgia Supreme

Court, and a number of other partners to host a

multidisciplinary child protection and child welfare

conference November 27-29, 2017. Held at the

Intercontinental Hotel in Atlanta, the conference was

attended by almost 500 child welfare professionals

including front-line case managers, juvenile court

judges, attorneys, and medical personnel from all

Brooke Silverthorn of the National Association of Counsel for Children spoke on the ethics of child
representation.

around Georgia. The training agenda for the conference focused on the intersection between law and child welfare practice and featured a number of

inspiring national speakers including Judge Michael Nash from Los Angeles and Amelia

Franck Meyer.

One of the highlights of the Summit was the presentation of videos featuring the

14 OCGA 15-11-19 (a). 15 OCGA 15-11-211.

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work of case managers and judges around the State. In addition to providing training, the Summit provided motivation and reinforcement for those who are doing the difficult work of protecting children night and day. OCA believes this sort of multi-disciplinary training, in which front-line workers get to spend time networking and sharing with juvenile court judges and attorneys, is an excellent way to improve our state's system.

Presentations and videos from the Summit are available on OCA's website at https://oca.georgia.gov/georgia-child-welfare-summit-2017.

Child Abuse Protocol Training and Development

As it has done for many years now, OCA continued in 2017 to work with a number of partners including the state's prosecutors, Child Advocacy Centers, Prevent Child Abuse Georgia, DFCS, Law Enforcement, GBI, and medical professionals to improve our Statewide Child Abuse Protocol. Jodi Spiegel, former OCA Deputy Director, and former OCA Director Ashley Willcott continued to work with our agency by providing child abuse protocol trainings across the state and by convening a "mini-summit" of 58 child welfare professionals on September 22nd to revise and update the Statewide Protocol.

The updated draft has been submitted to OCA and is in the proofing stage at the time of this report. The draft will be reissued to contributors for final edits in January 2018. When the document is finalized, the 2017 Statewide Model Child Abuse Protocol will be distributed across the state as a tool to assist each jurisdiction update their own protocols. The model protocol will also be posted on the OCA website as a reference resource.
A full evaluation of the Protocol Project is available in Appendix C.

Jodi Spiegel leads the Child Abuse Protocol Mini-Summit

Other Projects and Initiatives

In addition to these major projects, OCA staff worked diligently across agencies and professions in 2017 to improve child welfare law, policy, and practice. Here are just a few of the efforts we made to improve Georgia's system of protecting its most vulnerable children:

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1. Training nurses, medical providers, DFCS personnel, and other professionals on how to better collaborate to keep children safe. This work continues. OCA has developed a number of protocols for these professionals to follow to ensure the appropriate investigation of serious physical injury cases and has convened a working group to address care for newborns who are medically fragile or who are affected by substance abuse. To date, we have conducted trainings in Augusta, Atlanta, and Columbus as well as site visits in Savannah.
2. Working to Keep Children in Foster Care Close to Home OCA Deputy Director Rachel Davidson served in an integral role as part of an ongoing project to keep children in foster care close to the homes from which they were removed. As the chart nearby shows, children in DFCS custody are too often placed in foster homes far from their families, making it more difficult for them to maintain stability and attachments to school, friends, activities, their faith community, and extended family support. As part of an effort to achieve permanency for youth in foster care and reduce the trauma of removal and placement changes, DFCS has made keeping children in local homes a priority, and OCA continues to work with DFCS and court leaders to implement this vision.
3. Developing Guidelines for Working with Disabled Parents Throughout 2017, OCA staff has helped lead a working group of academics from Emory Law, judges, attorneys, DFCS leadership, and other professionals to address a growing concern: the proper handling of dependency cases involving parents who have severe developmental and cognitive disabilities and mental illness. Under the Americans with Disabilities Act (ADA), states must make additional efforts to help these parents raise their own children. To that end, OCA has worked with the Barton Child Law and Policy Center at Emory

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University to create a handbook that will help judges, attorneys, and case managers better address the needs of these parents while keeping their children safe and connected with family. That guidebook will be published in early 2018.
4. Working with Youth in Foster Care
At OCA, we strongly believe that youth in foster care should be listened to and treated with respect. In 2017, OCA staff have regularly worked with DFCS and its providers as well as directly with these youth to ensure teens in foster care, as well as older youth who have remained in care past age 18, are able to fully participate in the decisions that will affect their futures. It is a legal and moral imperative that we prepare these youth to become responsible adults by providing them with proper educational opportunities, life skills, drivers' lessons, financial education, and the support they need as they heal from trauma and when they make the mistakes that we have all experienced and from which we learn to be healthy and productive adults.
5. Fighting Sex Trafficking
OCA's staff regularly participate in a number efforts to combat sex trafficking and sexual exploitation of children and serve on committees that are engaged in fighting this scourge. In September, OCA investigator Renee Moore had the opportunity to intervene herself to rescue a teenaged girl from sex trafficking. She writes:
"I reviewed a case involving a seventeen-year-old runaway. During the course of the investigation, OCA discovered this child was being sex trafficked. OCA reached out to collaborative partners to begin what became an exhaustive search to find this child. Due to the efforts of many, this child was found and resources obtained to try and begin the healing process for this child. While attempting to change the course this child was on it was discovered this child had suffered a long history of abuse.
I spent many hours wondering what could have been done differently .... the conclusion I came to is sometimes we give up because we think there is nothing else that can be done. What I discovered is that no matter what age the child, they need to know we are not giving up on them. I also learned that whether you are law enforcement, OCA, DFCS, a private provider or a community resource, we are all focused on ensuring each child is safe and

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protected and will take whatever course of action necessary to ensure we have done everything we could.
We do not see success every day but we move forward every day in this work to try and make that difference in a child's life. While everyone has heard the adages of how hard the work is and sometimes wonder if it is all worth it.....I can tell you it is worth every moment!!!!!!"
6. Addressing the Needs of Runaway Children
Georgia has responsibilities to protect victims of child abuse and neglect, even if those children and youth we are serving claim not to want our help. Often, we find that victims of child abuse often have emotional or behavioral issues that drive them to run away from foster care. At the same time, these children who do run away are often at high risk for exploitation and sex trafficking. At OCA, we developed during 2017 additional guidelines and protocols for juvenile courts and DFCS to use to improve all of our efforts to locate, assist, and protect children who have run away from care.
The State of Child Welfare: Recommendations for 2018
All public child protection and child welfare systems worldwide are under stress. Workers who go into this field with the best of intentions often burn out from dealing with the trauma they see. As a result, public child protection systems often have high worker turnover. Too often, when a child who should be under the system's protection dies, the public has a tendency to blame the system itself, and this public pressure often results in changes to agency leadership and sudden shifts in policy, law, and practice.
Georgia has itself experienced these types of issues since OCA's creation, which itself was spurred in part by the tragic death of a child who had passed through our child protection system.

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As the chart above shows, since 2000 we have had spikes and troughs in the number of children in care. Right now, we are experiencing another spike. It is likely that this increase in the number of children placed in foster care has resulted from a combination of the following factors:
1. The implementation of a statewide centralized intake system for child abuse reporting (1-855-GACHILD), which has resulted in a significant increase in the number of reports of child maltreatment the State receives each month;
2. The debilitating effects of the opioid crisis, which has produced a significant number of addicted parents who are not able to care for their children and whose addictions cannot be quickly treated and resolved; and
3. To some extent, a natural leveling of the system, as our State's leadership has focused more on keeping children safe. It is likely that prior to 2010, the number of children in foster care was lower than might have been expected.
Governor Deal, working with former DFCS Director Bobby Cagle, has responded to these increases by making significant investments in our child protection workforce, including providing significant pay increases for new front-line workers. OCA is pleased not only with those reforms but also with improvements DFCS is implementing in the way the agency recruits, trains, mentors, and retains its workforce. In our opinion,

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front-line CPS workers who work night and day in dangerous situations deserve the same respect and honor that we accord firefighters, policemen, and other emergency responders.

One of the key indicators of the success of our system is the number of children who are identified as having suffered abuse or neglect who remain free from additional abuse or neglect. Between October 2016 and September 2017, 96.3% of children who were found to have suffered maltreatment did not suffer additional maltreatment during the following six months. This result compares very favorably to national standards. Another key indicator of the system's health is how quickly we are moving our children in foster care to safe, stable, permanent homes through reunification, placement with relatives, or adoption. In Georgia, for the 12 months ending in September 2017, DFCS reunited 57% of children in foster care with family or relatives within 12 months, with those children remaining in care for a median length of time of 10 months. We do have some work to do in assuring that children who must have a new adoptive family are moved along that path quickly; those children remained in foster care for a median length of time of almost 31 months.

Although the public often hears of

children who may have not been

protected by state child protection

systems, in 2017 OCA and its partners at

DFCS, Public Health, and the Georgia

Supreme Court Committee on Justice for

Children were able to support a project

that has demonstrated for the first time

that DFCS involvement does, in fact, save

children's lives. Andy Barclay, a child

Andy Barclay's "Lives Saved" Presentation at The Summit

welfare statistician, was able to compare two demographically nearly-identical

groups of families: one that had experienced DFCS involvement, and another that had

not. His conclusion, supported by the data, is that DFCS involvement reduced child

deaths by almost 40%.16 In 2018, we hope to expand on these kinds of studies.

Two other bright spots on which we expect to see improvement by the state's

child welfare system in 2018 are in the areas of behavioral health care for children and

educational achievement for children in foster care. The first improvement we expect

will come from Governor Deal's efforts to implement the recommendations of his

16 Andy Barclay's "Lives Saved" presentation is available at https://www.youtube.com/watch?v=DD7BB7uOls&feature=youtu.be

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Commission on Children's Mental Health.17 Among its recommendations, which we hope the General Assembly will follow, are to increase funding for school-based mental health services for children and to create and fund additional specialized therapeutic foster care services for children with significant mental health needs. The unfortunate fact is that our behavioral health system and our child protection system often serve the same children: those who have been yelled at continually, physically abused, who have witnessed domestic violence, or who have lived not knowing whether they are loved or cared for. By improving mental health services for all children, we can improve the chances they will not enter foster care and will grow into healthy adults.
The second area to highlight is DFCS' recent efforts to boost graduation rates among children in foster care. Nationally, children in foster care have low graduation rates in part because of the trauma they have experienced that has hampered their ability to get a stable education. We have an obligation to ensure that once those children are in a stable foster home, they are empowered and supported to graduate from high school and take advantage of opportunities to pursue further technical or college degrees. The Multi-Agency Alliance for Children, DFCS, OCA and others have recently begun a collaborative project that will focus on improving these educational outcomes.
OCA has, in its partnership for child protection, offered throughout the year policy and practice recommendations to DFCS when we believed the agency's work was not carried out to its potential. In addition, we recommend for 2018 that the State not limited to DFCS but including courts and other child-serving agencies -- focus on the following issues:
1. Increase data for better decision-making
o DFCS should work with the Department of Public Health, the Department of Behavioral Health and Developmental Disabilities, the Department of Juvenile Justice, the Department of Community Health, and other state agencies to automate the provision of data that can help DFCS "flag" dangerous situations. For example, when DFCS is determining the risk of danger to a child about whom a child abuse complaint has been made, it should have the ability automatically to pull that child's medical records as well as his or her parents' records related to substance abuse and mental health. Many of these records are already kept in electronic form.
17 The full Commission report, released on December 11, 2017, can be found on OCA's website at https://oca.georgia.gov.

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Likewise, if DFCS has a report on a child but cannot find the family despite a diligent search, emergency rooms and law enforcement personnel should have a way to alert DFCS if they encounter the family.
2. Improve handling of situations involving newborns affected by substance use
o Pursuant to the federal Comprehensive Addiction and Recovery Act of 2016, states are required to identify and assess children who are born "affected" by drugs, whether those drugs are properly prescribed or are illegal street drugs. DFCS has taken the lead on receiving reports of drug-exposed children, requesting the parental substance abuse assessment, and working with providers such as Babies Can't Wait to implement the "plan of safe care" required by this federal law. In OCA's experience, however, there remain a number of obstacles to successful implementation, including: Some hospitals and healthcare providers are not notifying the agency of children born drug-exposed, thwarting the agency's ability to help these families. There is a lack of coordination among the various agencies and providers who are charged with assessing the mother's substance abuse issues, designing a plan to help her while keeping the child safe, and implementing services.
OCA has formed a working group to address these issues and recommends that all state health care agencies and providers make the identification, assessment, and treatment of drug-exposed newborns a priority.
Conclusion
All of us at OCA continue to look for ways that we can positively impact our state's

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system for protecting children. We understand that this responsibility is not that of one agency or even of government alone; rather, it requires us to work humbly in partnership with all of those who have made child protection the focus of their work.

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Appendices

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Appendix A: Georgia Child Advocate for the Protection of Children Act
O.C.G.A. 15-11-740.
(a) This article shall be known and may be cited as the "Georgia Child Advocate for the Protection of Children Act."
(b) In keeping with this article's purpose of assisting, protecting, and restoring the security of children whose well- being is threatened, it is the intent of the General Assembly that the mission of protection of the children of this state should have the greatest legislative and executive priority . Recognizing that the needs of children must be attended to in a timely manner and that more aggressive action should be taken to protect children from abuse and neglect,the General Assembly creates the Office of the Child Advocate for the Protection of Children to provide independent oversight of persons, organizations, and agencies responsible for providing services to or caring for children who are victims of child abuse and neglect or whose domestic situation requires intervention by the state . The Office of the Child Advocate for the Protection of Children will provide children with an avenue through which to seek relief when their rights are violated by state officials and agents entrusted with their protection and care .
O.C.G.A. 15-11-741.
As used in this article, the term:
(1) "Advocate" or "child advocate" means the Child Advocate for the Protection of Children established under Code Section 15-11-742.
(2) "Agency" shall have the same meaning and application as provided for in paragraph (1) of subsection (a) of Code Section 50-14-1.
(3) "Child" or "children" means an individual receiving protective services from DFCS, for whom DFCS has an open case file, or who has been, or whose siblings, parents, or other caretakers have been, the subject of a report to DFCS within the previous five years .
O.C.G.A. 15-11-742.
(a) There is created the Office of the Child Advocate for the Protection of Children . The Governor, by executive order, shall create a nominating committee which shall consider nominees for the position of the advocate and shall make a recommendation to the Governor. Such person shall have knowledge of the child welfare system, the juvenile justice system, and the legal system and shall be qualified by

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training and experience to perform the duties of the office as set forth in this article .
(b) The advocate shall be appointed by the Governor from a list of at least three names submitted by the nominating committee for a term of three years and until his or her successor is appointed and qualified and may be reappointed. The salary of the advocate shall not be less than $60,000 .00 per year, shall be fixed by the Governor, and shall come from funds appropriated for the purposes of the advocate .
(c) The Office of the Child Advocate for the Protection of Children shall be assigned to the Office of Planning and Budget for administrative purposes only, as described in Code Section 50-4-3 .
The advocate may appoint such staff as may be deemed necessary to effectively fulfill the purposes of this article, within the limitations of the funds available for the purposes of the advocate . The duties of the staff may include the duties and powers of the advocate if performed under the direction of the advocate . The advocate and his or her staff shall receive such reimbursement for travel and other expenses as is normally allowed to state employees from funds appropriated for the purposes of the advocate .
(d) The advocate shall have the authority to contract with experts in fields including but not limited to medicine, psychology, education, child development, juvenile justice, mental health, and child welfare as needed to support the work of the advocate, utilizing funds appropriated for the purposes of the advocate .
(e) Notwithstanding any other provision of state law, the advocate shall act independently of any state official, department, or agency in the performance of his or her duties .
(f) The advocate or his or her designee shall be a member of the Georgia Child Fatality Review Panel.
O.C.G.A. 15-11-743.
The advocate shall perform the following duties:
(1) Identify, receive, investigate, and seek the resolution or referral of complaints made by or on behalf of children concerning any act, omission to act, practice, policy, or procedure of an agency or any contractor or agent thereof that may adversely affect the health, safety, or welfare of the children;
(2) Refer complaints involving abused children to appropriate regulatory and law enforcement agencies;
(3) Report the death of any child to the chairperson of the review committee, as such term is defined in Code Section 19-15-1, for the county in which such child resided at the time of death, unless the advocate has knowledge that such death has been reported by the county medical examiner or coroner, pursuant to Code Section 19-15-3, and to provide such committee access to any records of the advocate relating to such child;

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(4) Provide periodic reports on the work of the Office of the Child Advocatefor the Protection of Children, including but not limited to an annual written report for the Governor and the General Assembly and other persons,agencies,andorganizationsdeemedappropriate.Such reportsshallincluderecommendationsfor changes in policies and procedures to improvethe health, safety, and welfare of children and shall be made expeditiously in order to timely influence public policy;
(5) Establish policies and procedures necessary for the Office of the Child Advocate for the Protection of Children to accomplish the purposes of this article, including without limitation providing DFCS with a form of notice of availability of the Office of the Child Advocate for the Protection of Children . Such notice shall be posted prominently, by DFCS, in DFCS offices and in facilities receiving public moneys for the care and placement of children and shall include information describing the Office of the Child Advocate for the Protection of Children and procedures for contacting such office; and
(6) Convene quarterly meetings with organizations, agencies, and individuals who work in the area of child protection to seek opportunities to collaborate and improve the status of children in Georgia.
O.C.G.A. 15-11-744.
(a) The advocate shall have the following rights and powers:
(1) To communicate privately, by mail or orally, with any child and with each child's parent, guardian, or legal custodian;
To have access to all records and files of DFCS concerning or relating to a child, and to have access, including the right to inspect, copy, and subpoena records held by clerks of the various courts, law enforcement agencies, service providers, including medical and mental health, and institutions, public or private, with whom a particular child has been either voluntarily or otherwise placed for care or from whom the child has received treatment within this state . To the extent any such information provides the names and addresses of individuals who are the subject of any confidential proceeding or statutory confidentiality provisions, such names and addresses or related information that has the effect of identifying such individuals shall not be released to the public without the consent of such individuals . The Office of the Child Advocate for the Protection of Children shall be bound by all confidentiality safeguards provided in Code Sections 49-540 and 49-5-44 . Anyone wishing to obtain records held by the Office of the Child Advocate shall petition the original agency of record where such records exist;
(2) To enter and inspect any and all institutions, facilities, and residences, public and private, where a child has been placed by a court or DFCS and is currently residing . Upon entering such a place, the advocate shall notify the administrator or, in the absence of the administrator, the person

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in charge of the facility, before speaking to any children . After notifying the administrator or the person in charge of the facility, the advocate may communicate privately and confidentially with children in the facility, individually or in groups, or the advocate may inspect the physical plant . To the extent possible, entry and investigation provided by this Code section shall be conducted in a manner which will not significantly disrupt the provision of services to children;
(3) To apply to the Governor to bring legal action in the nature of a writ of mandamus or application for injunction pursuant to Code Section 45-15-18 to require an agency to take or refrain from taking any action required or prohibited by law involving the protection of children;
(4) To apply for and accept grants, gifts, and bequests of funds from other states, federal and interstate agencies, independent authorities, private firms, individuals, and foundations for the purpose of carrying out the lawful responsibilities of the Office of the Child Advocate for the Protection of Children;
(5) When less formal means of resolution do not achieve appropriate results, to pursue remedies provided by this article on behalf of children for the purpose of effectively carrying out the provisions of this article; and
(6) To engage in programs of public education and legislative advocacy concerning the needs of children requiring the intervention, protection, and supervision of courts and state and county agencies .
(b) (1) Upon issuance by the advocate of a subpoena in accordance with this article for law enforcement investigative records concerning an ongoing investigation, the subpoenaed party may move a court with appropriate jurisdiction to quash such subpoena .
(2) The court shall order a hearing on the motion to quash within five days of the filing of the motion to quash, and the hearing may be continued for good cause shown by any party or by the court on its own motion . Subject to any right to an open hearing in contempt proceedings, such hearing shall be closed to the extent necessary to prevent disclosure of the identity of a confidential source; disclosure of confidential investigative or prosecution material which would endanger the life or physical safety of any person or persons; or disclosure of the existence of confidential surveillance, investigation, or grand jury materials or testimony in an ongoing criminal investigation or prosecution . Records, motions, and orders relating to a motion to quash shall be kept sealed by the court to the extent and for the time necessary to prevent public disclosure of such matters, materials, evidence, or testimony .
(c) The court shall, at or before the time specified in the subpoena for compliance therewith, enter an order:
(1) Enforcing the subpoena as issued;
(2) Quashing or modifying the subpoena if it is unreasonable and oppressive; or

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(3) Conditioning enforcement of the subpoena on the advocate maintaining confidential any evidence, testimony, or other information obtained from law enforcement or prosecution sources pursuant to the subpoena until the time the criminal investigation and prosecution are concluded . Unless otherwise ordered by the court, an investigation or prosecution shall be deemed to be concluded when the information becomes subject to public inspection pursuant to Code Section 50-18-72 . The court shall include in its order written findings of fact and conclusions of law.
O.C.G.A. 15-11-745. (a) No person shall discriminate or retaliate in any manner against any child, parent, guardian, or legal custodian of a child, employee of a facility, agency, institution or other type of provider, or any other person because of the making of a complaint or providing of information in good faith to the advocate or willfully interfere with the advocate in the performance of his or her official duties .
(b) Any person violating subsection (a) of this Code section shall be guilty of a misdemeanor .
O.C.G.A. 15-11-746.
The advocate shall be authorized to request an investigation by the Georgia Bureau of Investigation of any complaint of criminal misconduct involving a child .
O.C.G.A. 15-11-747. (a) There is established a Child Advocate Advisory Committee. The advisory committee shall consist of:
(1) One representative of a not for profit children's agency appointed by the Governor;
(2) One representative of a for profit children's agency appointed by the Lieutenant Governor;
(3) One pediatrician appointed by the Speaker of the House of Representatives;
(4) One social worker with experience and knowledge of child protective services who is not employed by the state appointed by the Governor;
(5) One psychologist appointed by the LieutenantGovernor;
(6) One attorney from the Children and the Courts Committee of the State Bar of Georgia appointed by the Speaker of the House of Representatives; and
(7) One juvenile court judge appointed by the Chief Justice of the Supreme Court .
Each member of the advisory committee shall serve a two-year term and until the appointment and qualification of such member's successor . Appointments to fill vacancies in such offices shall be filled in the same manner as the original appointment .
(b) The advisory committee shall meet a minimum of three times a year with the advocate and his or her staff to review and assess the following:

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(1) Patterns of treatment and service for children;
(2) Policy implications; and (3) Necessary systemic improvements. The advisory committee shall also provide for an annual evaluation of the effectiveness of the Office of the Child Advocate for the Protection of Children .

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Appendix B: Peer Review Evaluation 2017
Background and Purpose: The Peer Review Project works to improve legal representation for children in child welfare cases. Child welfare attorneys visit juvenile courtrooms across the state for the purpose of observing child attorneys and guardians ad litem, and to note the tone set by judges for dependency hearings. Utilizing funding from the Judicial Council's Administrative Office of the Courts of Georgia, the Office of the Child Advocate contracted with several attorneys and partnered in-kind with prominent child welfare advocates to conduct the 2017 Peer Review Project. Observations were scheduled for seventeen (17) different jurisdictions and took place from April through June.
The findings in this report include evaluations of 51 cases across 11 counties (Bulloch, Butts, Columbia, Fayette, Gilmer, Habersham, Henry, Lowndes, Marion, McDuffie and Upson). Peer Review was also conducted in Crisp County where the reviewer observed 6 cases; however all observations detailed case specifics rather than attorney performance and could not be included. Reviewers visited five (5) additional counties (Barrow, Burke, Cobb, Randolph and Coweta) that have not been included; no notes have been received for these observations to date. A final Peer Review was scheduled for Coffee County, but was cancelled due to inclement weather; it will be rescheduled at a later date.
Reviewers were provided forms detailing specific case information they were to note during their observations. Reviewers were also provided forms to collect overall information on how the courts conducted dependency hearings in each jurisdiction. However, many questions were frequently left unanswered, limiting the extent of a standardized evaluation across the Peer Review sites. It may have been that the specific hearings observed did not mesh well with the data collection form, or that some reviewers did not understand the importance of collecting information as specified on the form. This issue should be further investigated and resolved prior to scheduling additional reviews.
Summary Overall Court Observations: ICWA and immigration are extremely rare and considered non-issues in the jurisdictions reporting. Relative strengths and weaknesses are noted across sites as follows:

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Strengths Father participation (75%) Visitation (75%)

Weaknesses
Child participation (30%) Diligent search (50%) Permanency efforts (57%)

Only one county (Columbia) uses CPRS and about one-half uses fill-in-the blank orders. The majority (two-thirds) uses third party custody, but only after family members and by agreement of all parties.
The majority of the open-ended comments were about the lack of legal findings and lack of reasonable efforts findings. As one reviewer noted, "There were no findings of fact or conclusions of law made by the court in any of the cases." It was noted that several jurisdictions do not use CASA, and issues were noted with the failure to submit reports and other documents into evidence. "Another difficulty was the general failure of the court to comply with rules of evidence," was one observation.
The most common training suggestions address child advocacy and basic trial skills. "The attorneys need basic training in juvenile-court practice and procedure, as well as in basic trial and advocacy skills."
Summary Individual Case Observations:
Of the 51 cases for which notes were received, only 27 (53%) note the length of the hearings. The average hearing lasted 18 minutes, and one-third lasted ten minutes or less. "The hearings were handled in summary fashion . . . the parties were not seated at their tables, but rather gathered around the podium."
In the majority of cases observed, the child was represented by an attorney serving in a dual role (76%); in only 10% of cases were both child attorneys and GALs assigned. As was suggested in the overall comments, there was no CASA involvement in more than half the cases.
Presence of children in the courtroom is the exception rather than the rule; children were present at less than one-quarter of the hearings. Their absence is as likely to be waived as not, with age being the most common reason for waiving the child's presence at court. In the few cases in which the child was present, engagement was low. Neither judges nor attorneys were engaged with the children who were present at court. Interaction was observed in less than one-third of the cases.
It is important to note that non-response to specific measures of child attorney and GAL performance was extremely high, ranging from 24% to 63% depending upon the particular

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question. With that in mind, the percentages reported below are based on total answers received (i.e., excluding non-response).

In most cases, the attorney acted in a dual role. As the child attorney, the attorney seemed prepared for court in only slightly more than half the cases. Overall, child attorneys did not perform well on any of the measures collected. It is especially alarming that only one-quarter demonstrated knowledge about the law.

Child Attorney demonstrated evidence of:
Hearing preparation Commitment to visitation Presenting the child's position Commitment to expediting permanency Knowledge of child's health/special needs Knowledge of state/federal law

57% 52 50 38 37 28

Attorneys in the guardian ad litem role performed as poorly, or worse. Only two in five GALs demonstrated any knowledge of child safety, and written reports were virtually non-existent.

GAL:
Demonstrated knowledge of child safety Made efforts to expedite permanency Address best interest prongs Submitted written report

42% 36 27
6

General comments made by reviewers most frequently centered on: All parties were not represented o "Mom asked to apply for counsel, but the case went forward anyway" o "There was no inquiry as to whether mom wanted an attorney."
Lack of child contact by GALs o "[the GAL] was well-informed about the child, however has no personal contact" o "First time GAL saw kids was recently case is over six months old"
Low attorney participation during hearings

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o "The judge asked all the questions from the bench and all the attorneys responded with `yeses' and the occasional comment"
o "The child attorney asked no questions."
Summary Concerns:
In spite of the low response rate on data collection forms, it does appear that both systemic issues and attorney skill levels are affecting the quality of child representation in several jurisdictions. Many judges are directing hearings from the bench, asking questions of witnesses who have not been sworn in and referring to documents not entered into evidence. Hearings are concluded with no findings of fact or reasonable efforts; some observers were uncertain of the adjudication. In the worst case scenario (Bulloch County), there is no juvenile court or juvenile court judges; dependency hearings are sandwiched in between the other business of the Superior Court.
While several concerns were noted in the review of these observations, three are most prevalent and are present in multiple jurisdictions.
1) Lack of child contact Though many attorneys (child attorneys and guardians ad litem) appeared knowledgeable about the child's case, few spent any time with the child outside of the courtroom. Coupled with the fact that children are rarely present at court makes it difficult to provide good representation or present the child's wishes during the hearing. It is generally acknowledged that the pay scale for contract attorneys does not allow for meeting with children outside the courthouse, and in some instances heavy attorney caseloads compound the problem. While raising contract rates would be helpful, CASA could be utilized more to assist attorneys with this issue.
2) Lack of knowledge of the juvenile code It appears that there is room for much training on the juvenile code, juvenile court best practices, and indeed, the general rules of evidence. It is concerning that reviewers observed attorneys demonstrating knowledge of law in only one-quarter of the cases; the number of guardians ad litem addressing best interest prongs was similarly low. While judges may give attorneys limited opportunity for participation in dependency hearings (i.e., asking questions from the bench), one would expect a better showing. Training would be beneficial for both judges and attorneys.

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3) Inconsistent parent representation
A secondary issue to the quality of child representation, and ultimately the child's permanency and well-being, is the provision of representation to parents. In several instances reviewers noted that parent asked for counsel, were refused and the hearing proceeded, ignoring their rights. Remaining in the home or reunifying with parents is always a preferred option when it is in the child's best interests to do so; this cannot always be accomplished if the parent does not receive legal counsel.
Detailed findings of overall court observations and individual cases are displayed on the tables that follow.

Table 1:

Overall Court Observations Regularly Address:
Child participation Diligent Search
Efforts by all Parties to Achieve Permanency
Father Participation
ICWA

Counties

#

Addressing

3/10 30%

Habersham Lowndes Marion

4/8 50%

Butts Lowndes Marion
Upson

4/7 57%

Fayette Habersham
Marion Upson

6/8 75%

Butts Columbia Habersham Lowndes
Marion Upson

0/10

Non-issue or

0%

extremely rare

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Immigration Visitation
Table 2:

0/10 0%
6/8 75%

Non-issue or extremely rare
Fayette Gilmer Habersham Lowndes Marion Upson

Overall Court Observations Regularly Use:
3rd Party Custody (after family & by agreement of parties)
Use of "Fill-in-the-blank" orders
Use of CPRS
Table 3:

Counties

#

Using

Butts

Columbia

6/9

Gilmer

67%

Habersham

Marion

Upson

4/8 50%

Butts Fayette Marion McDuffie

1/8 12%

Columbia

Overall Court Observations -

Comments:

#

Lack legal & reasonable efforts findings

7

No CASA or CASA not used

5

Reports/documents not submitted into evidence

4

Appoint CASA as GAL

3

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Out of court work is not supported (pay or caseload)

3

No announcements of parties for the record

3

All parties do not have legal representation

3

Lack sworn testimony

3

Number of comments shown, not number of courts

Table 4:

Overall Court Observations -

Training Needs Noted:

#

Advocacy

4

Basic trial skills

3

Child interview skills

2

Child welfare law

2

Table 5:

Number of comments shown, not number of courts

Individual Case Observations Hearing Type
Judicial Review

Adjudication

Disposition

Permanency Review

Adoption Status

Motions

Custody

TPR

Visitation

Case Plan

Hearing type not identified

Multiple responses

Total

#

%

17

33%

11

22

7

14

7

14

5

10

3

6

1

2

1

2

1

2

1

2

2

4

51

100%

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Table 6:

Individual Case Observations -

Child Representation

#

Dual role

39

Child Attorney Only

6

GAL Only

1

Both

5

Total

51

%
76% 12
2 10 100%

Table 7:

Individual Case Observations - CASA

Participation

#

CASA attended hearing

5

CASA to be assigned

2

No CASA involvement

27

Not noted by reviewer

17

Total

51

Table 8:

Individual Case Observations -

Presence of Foster Parent/Placement

#

Present at Court

22

Not present, but were notified

7

Not present, notification unknown

13

Not applicable (child living at home)

3

Not noted by reviewer

6

Total

51

% of Total
10% 4 53 33
100%

% of Reponses
15% 6
79 NA
100%

% of Total
43% 14 25
6 12
100%

% of Responses
49% 15 29
7 NA
100%

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Table 9:

Individual Case Observations -

FP/Placement given opportunity to

speak during hearing

#

Yes

11

At Court, but left early

2

No

4

Not noted by reviewer

5

Total Present at Court

22

% of Total
50% 9
18 23
100%

% of Responses
65% 12 22 NA
100%

Table 10:

Individual Case Observations -

Presence of Child

#

Present at Court

11

In Courtroom

8

Outside courtroom

3

Not Present at Court

40

Presence Waived

20

Due to age

8

In school

3

On trip

1

Unspecified reason

8

Presence Not Waived

20

Total

51

Table 11:

Individual Case Observations -

Engagement with Child

#

Judge Engaged

%
22% 16
6 78 39 16
6 2 16 39 100%
%

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2017 Annual Report

Yes

3

No

5

Not noted by reviewer

2

Child Attorney Engaged

Yes

3

No

4

Not noted by reviewer

3

GAL Engaged

Yes

3

No

4

No GAL

1

Not noted by reviewer

2

Total Cases Child Present

10

Table 12:

30% 50 20
30% 40 30
30% 40 10 20
100%

Individual Case Observations

Child Attorney demonstrated evidence

of hearing preparation

#

Yes

16

No

6

No CA

1

Unable to evaluate

5

Not noted by reviewer

23

Total

51

Table 13:

% of Total
31% 12
2 10 45
100%

% of Responses
57% 21
4 18 NA
100%

Individual Case Observations Child Attorney presented the child's position
Yes

%

%

#

of Total of Responses

15

29%

50%

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2017 Annual Report

No No CA Unable to evaluate Not noted by reviewer
Table 14:

10

1

4

21

Total

51

20 2 8
41 100%

33 3
13 NA 100%

Individual Case Observations

Child Attorney hearing participation

#

Positive Observations

21

Asked questions/cross-examination

13

Made recommendation to Court

4

Made request/motion

2

Spoke on child's behalf

2

Demonstrated knowledge of case

1

Noted substance abuse issues

1

Negative Observations

21

Asked no questions/no cross-examination

12

Presented no evidence

7

Discussed DV in child's presence

1

Questioned unsworn witness

1

Very limited participation

1

No participation noted

1

Unable to evaluate

3

No CA

1

Not noted by reviewer

12

Multiple responses

Total

51

Table 15:

Individual Case Observations

Child Attorney demonstrated knowledge

of Child's health/special needs

#

Yes

7

No

7

Child has no special needs

1

% of Total
41% 25
8 4 4 2 2 41 24 14 2 2 2 2 6 2 24 100%

% of Responses
54% 33 10
5 5 2 2 54 31 18 2 2 2 2 8 2 NA 100%

% of Total
14% 14
2

% of Responses
37% 37
5

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2017 Annual Report

No CA Unable to evaluate Not noted by reviewer
Table 16:

1

3

32

Total

51

Individual Case Observations

Child Attorney demonstrated

knowledge of state/federal law

#

Yes

7

No

14

No CA

1

Unable to evaluate

3

Not noted by reviewer

26

Total

51

Table 17:

Individual Case Observations

Child Attorney demonstrated efforts

to expedite permanency

#

Yes

8

No

7

Not applicable/child returned home

2

No CA

1

Unable to evaluate

3

Not noted by reviewer

30

Total

51

Table 18:

Individual Case Observations - Child

Attorney demonstrated commitment

to visitation

#

2 6 63 100%

5 16 NA 100%

% of Total
14% 27
2 6 51
100%

% of Responses
28% 56
4 12 NA
100%

% of Total
16% 14
4 2 6 59
100%

% of Responses
38% 33 10
5 14 NA
100%

%

%

of Total of Responses

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2017 Annual Report

Yes

15

No

1

Not applicable/child returned home or TPR

7

No CA

1

Unable to evaluate

3

Not noted by reviewer

24

Total

51

Table 19:

Individual Case Observations

GAL Knowledgeable on Child Safety

#

Yes

10

No

6

No Child Safety Issues

2

No GAL

6

Not noted by reviewer

27

Total

51

Table 20:

Individual Case Observations

GAL Submitted Written Report

#

Yes

2

No

26

No GAL

6

Not noted by reviewer

17

Total

51

Table 21:

Individual Case Observations

GAL Addressed Best Interest Prongs

#

Yes

8

No

16

29% 2 14 2 6 47 100%

55% 4
26 4
11 NA 100%

% of Total
20% 12
4 12 53
100%

% of Responses
42% 25
8 25 NA
100%

% of Total
4% 51 12 33
100%

% of Responses
6% 76 18 NA
100%

% of Total
16%
31

% of Responses
27%
53

Georgia Office of the Child Advocate for the Protection of Children

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2017 Annual Report

No GAL Not noted by reviewer

6

21

Total

51

Table 22:

Individual Case Observations

GAL Made Efforts to Expedite

Permanency

#

Yes

8

No

6

Not Applicable

2

No GAL

6

Not noted by reviewer

29

Total

51

Table 23:

Individual Case Observations

Case Specific Comments

#

Court Proceedings

12

All parties not represented/offered counsel

3

Judge asked the questions

2

No clear rulings/findings

2

Parties/representation not announced for the record

2

CASA appointed as GAL where conflict

1

Court gave detailed findings on best interest prongs in ruling

1

No notice to parents as to guardianship

1

Parties not notified of hearing

1

Temporary custodian not treated as party

1

GAL Performance

6

Lack Child Contact

3

Case open a long time before met w/ child

1

12 41 100%

20 NA 100%

% of Total
16% 12
4 12 57
100%

% of Responses
36% 27
9 27 NA
100%

% of Total
24% 6 4 4
4
2
2
2 2 2

% of Responses
48% 12
8 8
8
4
4
4 4 4

12

24

6

12

2

4

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2017 Annual Report

Only sees children at Court

1

2

4

Well-informed, but no child contact

1

2

4

Pushing for permanency w/o allowing time to work case plan

1

2

4

Requested child be excused when he became emotional

1

2

4

Requested no visitation b/c positive screen; could have requested supervised

1

2

4

DFCS Involvement

4

8

16

No case plan

2

4

8

Allowed children to travel w/ FPs w/o notice to the Court

1

2

4

Supervisor acknowledged referral delays/ says DFCS will address

1

2

4

Attorney Participation CA/GAL asked no questions No closing arguments

3

6

12

2

4

8

1

2

4

Child not Present

2

4

8

Child kept out of CR because he was emotional

1

2

4

Children attend school rather than Court

1

2

4

Individual Case Observations Case Specific Comments (Cont.)
Lack Proper Evidence/Testimony Documents/reports not entered into evidence Lack sworn testimony
Only evidence presented from CM

%

%

#

of Total of Responses

2

4

8

1

2

4

1

2

4

1

2

4

Concerns about length of time in care

2

4

8

Child attorney did not have chance to see child following dismissal of abuse

1

2

4

Lack visitation resources

1

2

4

No comments made
Multiple responses

26

Total

51

51 100%

NA 100%

Georgia Office of the Child Advocate for the Protection of Children

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2017 Annual Report

Appendix C: Child Abuse Protocol Evaluation
Background and Purpose:
The Child Abuse Protocol (CAP) Training project works to make annual updates to the Statewide Model Protocol and to deliver training on the specifics and the implementation of the Protocol to jurisdictions across the state. With funding through the Children's Justice Act, and the Division of Human Services, the Office of the Child Advocate continued this work during 2017 with the purpose of improving and evaluating the quality and implementation of local Child Abuse Protocols across the State of Georgia. The CAP project addressed two objectives to increase compliance rates with OCGA 19-15-2, and improve safety and well-being for children across the state's 159 counties and 49 judicial circuits:
1. To complete 2017 Statewide Model Protocol updates on new legislation, DFCS policy and procedure, and best practices for the various disciplines involved in the investigation and prosecution of child abuse; and to provide Multidisciplinary Frontline Responder Protocol training and technical assistance to mandated local Protocol Committee members across the state to increase compliance rates with OCGA 19-15-2; and
2. To develop and launch a comprehensive evaluation of local child abuse protocols and training evaluations to assess compliance with OCGA 19-15-2 and improvement in the multidisciplinary response.
Summary CAP Training:
OCA and its contractors delivered ten CAP trainings in 2017 covering many locations across the state, and addressing multiple child welfare disciplines. More than 400 professionals attended these trainings, including law enforcement and DFCS staff, as well as personnel from schools, Child Advocacy Centers, CASA, district attorney's offices, and health and mental health providers. Trainings were very well received and were rated very highly by trainees. Participants appreciated the material presented, particularly that about updates to the Code, but also enjoyed the convening of representatives from multiple disciplines and the opportunity to discuss local issues and hear other agencies' points of view. In addition to new information about the law, participants valued hearing about specific child abuse topics, e.g. CSEC, and receiving contact information and resources from other agencies.

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2017 Annual Report

Said that Training:
Was helpful in bettering relationships with MDT members

= 98%

Most common response(s) "Communication/collaboration"

Presented something new = 96%

"Law"

Addressed or improved multidisciplinary issues

= 87%

Summary Local CAP Development:

"Communication/collaboration" "MDT"

OCA also worked with six jurisdictions, providing technical assistance on local Child Abuse Protocol development. 92 professionals participated in these work sessions and gave feedback on CAP compliance issues in their locality. While many responded that returning the child to the home too soon (e.g., before completion of investigation) was an issue in their community, problems with collaboration, communication and agency disagreements were also common. Indeed, the efficacy of the multidisciplinary team was equally, if not more important, than having established compliance with the local CAP.

Past 12 months CAP compliance issues
Recommendations to improve compliance
Successful measures to prevent child abuse

Most common response(s) "Issues with child returning home" (e.g., too soon, to unsafe environment) "Poor collaboration/agency disagreements"
"Poor communication" "Not complying with protocol"
"Lack contact information"
"Improved communication" "More training on reporting" "More CAP training/review"
"Utilized training" (e.g., specific topics, to targeted groups)
"Utilized/implemented CAP" "Relied on partner resources/service
coordination"

Georgia Office of the Child Advocate for the Protection of Children

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2017 Annual Report

Summary Local CAP Compliance:
It is the responsibility of each county or circuit in Georgia to develop a local Child Abuse Protocol for the investigation and prosecution of alleged cases of child abuse (OCGA 19-15-2(b)). The written protocol shall be filed with the Division of Family and Children Services of the Department of Human Services and the Office of the Child Advocate for the Protection of Children, not later than the first day of September each year. As a part of this CAP training project, OCA conducted an evaluation of compliance with this mandate.
Nearly all counties responded to request for submission of the most recently updated protocol; 157 of 159 Georgia counties sent electronic copies of their CAP. Compared to the most recently updated Statewide Model Protocol (2016), more than three-quarters of the counties had revised their CAP within the past year. Counties with the most out-of-date protocols are shown below:

No updates in past 4 years (since 2012)
No updates in past 6 years (since 2010)
No updates in past 8 years (since 2008) No updates in past 16 years (since 2000)

Camden DeKalb Fannin Gilmer Haralson Putnam
Walton
Clarke
Fayette

Summary 2017 Revised Statewide Model Protocol:
Each year the Office of the Child Advocate coordinates the update of the Statewide Model Protocol to reflect Code changes as well as best practice improvements. To this end, a mini-summit of child welfare professionals convened on September 22nd. 58 professionals attended the summit and contributed to revision suggestions in groups by topic: Legislation, Child Welfare, Prevention, Child Advocacy & Sexual Assault, CSEC, Law Enforcement and Prosecution.

Georgia Office of the Child Advocate for the Protection of Children

45

2017 Annual Report

Post-summit protocol development began immediately following the summit. OCA contracted with Ashley Willcott, JD, CWLS, and former OCA Director, to follow up with summit participants and incorporate appropriate revisions to the model protocol. The draft of this work has been submitted to OCA and is in the proofing stage at the time of this report (December, 2017). The draft will be reissued to contributors for final edits in January 2018. When the document is finalized, the 2017 Statewide Model Child Abuse Protocol will be distributed across the state as a tool to assist each jurisdiction update their own protocols. The model protocol will also be posted on the OCA website as a reference resource.
CAP Training Evaluation Data Table 1:

Participants by Training Location GPSTC

GPSTC

12/14/16

GPSTC

04/19/17

GPSTC

09/06/17

Pataula

02/15/17

Southern

02/16/17

Oconee

02/17/17

Stone Mountain

02/21/17

Clayton

02/27/17

Fulton

03/13/17

Cherokee

06/30/17

TOTAL

# Signed
In
93 40 31 22 48 37 38 89 34 27 44 410

# Evaluation
Forms
50 28 22 44 31 32 66 29 16 41 309

CAP Training Evaluation Data Table 2:
Participant Roles (# completed evaluation forms) Law Enforcement (includes DJJ & Coroners)

#

%

103

33%

Georgia Office of the Child Advocate for the Protection of Children

46

2017 Annual Report

DFCS (includes SAAGs)

81

School

36

CAC/CASA

30

DA

19

Health/Mental Health Provider (includes victim services)

16

Court

10

Other Agency (Family Connection, Head Start)

6

No Answer

8

TOTAL

309

26 12 10
6 4 3 2 3 100%

CAP Training Evaluation Data Chart 1:
Learned Something New at Training 2% 2%

96%

CAP Training Evaluation Data Table 3:

New Learning Specified New Learning

# %
243 82%

New Learning Law enforcement

# %

9

3%

Georgia Office of the Child Advocate for the Protection of Children

47

2017 Annual Report

Law
Child abuse topic (i.e., CSEC, exploitation)
CAP
Interviews (i.e., forensic, how to) Contact information/ resources
DFCS
Mandated reporting
Collaboration
Information about another agency

65 22 37 12 37 12 24 8 22 7 19 6 18 6 14 5
9 3

Multi-disciplinary team

9

3

Reporting

9

3

Child Abuse registry

8

3

Protocol (unspec.)

8

3

Expert

4

1

Evidence

4

1

Prosecution

4

1

Other agency point of view
Did not specify new learning

3

1

54 18

TOTAL 297 100%

CAP Training Evaluation Data Chart 2:
Training Helpful in Bettering Relationships w/ MDT 1% 1%

98%

Georgia Office of the Child Advocate for the Protection of Children

48

2017 Annual Report

CAP Training Evaluation Data Table 4:

Helpful Specified how training helpful
Collaboration/communication
MDT
Networking/meeting partners
Contact information/ resources Training a good forum to resolve issues
DFCS
Information about other agencies Understanding other agency point of view

# %
189 63% 46 15 36 12 24 8 19 6 15 5 11 4 11 4
9 3

Helpful

# %

CAP

8

3

Diverse/wide agency participation

8

3

Information sharing

7

2

Investigations (agency roles)

4

1

Interviews (agency roles)

4

1

More training desired

4

1

Information about other agencies

3

1

Law

3

1

Did not specify how training helpful

112 37

TOTAL 301 100%

CAP Training Evaluation Data Chart 3:

100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0%

Training Addressed and/or Improved Issues 87%
68% 45% 26%

Addressed/Improved

Addressed

Improved

Addressed & Improved

Georgia Office of the Child Advocate for the Protection of Children

49

2017 Annual Report

CAP Training Evaluation Data Table 5:

Addressed/Improved Specified how training addressed/ improved issues Collaboration/communication
Multi-disciplinary team Training a good forum to resolve issues CAP
Contact information/resources
Interviews (forensic, how to)

# %
122 45% 41 15 15 6 12 4
6 2 5 2 5 2

Addressed/Improved Understanding delays

# %

5

2%

DFCS

5

2

Reporting information

5

2

Discussed barriers

4

1

Child abuse topic (CSEC, exploitation)

3

1

Law

3

1

Did not specify how training addressed/improved issues

148

55

TOTAL 270 100%

CAP Training Evaluation Data Table 6:
Information found most useful Responded to most useful information
Child abuse topic (i.e., CSEC, exploitation) Law Everything (not specific) Contact information/resources CAP Collaboration/communication Interviews (forensic, different types) Other agency's protocol Networking/meeting partners Investigation (suggestions)

# %
253 82% 38 12 36 12 36 12 35 11 29 9 17 6 13 4 13 4 12 4
7 2

Georgia Office of the Child Advocate for the Protection of Children

50

2017 Annual Report

Multi-disciplinary team Child Abuse Registry DFCS Presentation Reporting (which agencies) Understanding partner point of view Other agencies Importance of expert witnesses/testimony Prosecution Victim trauma No response to most useful information

6 2 5 2 5 2 5 2 4 1 4 1 3 1 3 1 3 1 3 1 56 18 Total 309 100%

CAP Training Evaluation Data Table 7:
Additional Training Topics Responded to additional training topics
Information about specific agencies & their roles (i.e., Childfirst, GA Cares) More case studies/examples/activities MDT/collaboration Copies of the PowerPoint Forensic interviews Training for specific audiences (i.e., caregivers, judges, schools) Victim assistance (i.e., follow up, resources) Other protocols Child Abuse topics (i.e., CSEC, DMST)

# %
47 15% 8 3 8 3 5 2 4 1 4 1 4 1 4 1 3 1 3 1

Georgia Office of the Child Advocate for the Protection of Children

51

2017 Annual Report

More data Law topics Testimony No response to additional training topics

2 1 2 1 2 1 262 85 Total 309 100%

CAP Training Evaluation Data Table 8:

Rate Training Experience
Instructor was very knowledgeable about the topic

Strongly Agree
80%

Agree 19%

Instructor did a good job interacting with the attendees

70%

28%

Instructor was able to capture my attention and keep the conversation moving

68%

30%

My knowledge of other agency's role improved

51%

47%

My knowledge of the Protocol improved

50%

48%

My knowledge of how my work can affect the multidisciplinary investigation improved
The multidisciplinary response will improve as a result of this training

48% 43%

50% 54%

Total Agree
99%

Average Rating
3.8

98%

3.7

98%

3.6

98%

3.5

98%

3.5

98%

3.4

97%

3.4

Local CAP Development Worksheet Data Table 9:
Past 12 months CAP Compliance Issues Responded to compliance issues
Positive comments Protocol works well/no concerns/compliance as expected

# %
74 80% 10 11% 10 11

Georgia Office of the Child Advocate for the Protection of Children

52

2017 Annual Report

Good protocol in place Negative comments
Issues with returning child to home Child returned home too soon - Before parent indictment - Before disposition - Before investigation completed Child returned to unsafe environment Child not returned when appropriate Child returned to home (unspecified)
Poor collaboration/agency disagreements Protocol issues
- Not adhering to/complying with protocol - Need protocol update Poor communication Lack contact information/difficulty contacting Child continues to have contact w/ alleged maltreator Issues with call center Lack of/untimely response from DFCS Training Issues - need more CAP training - unspecified training issues Forensic Interview Issues - DFCS FI issues - Law Enforcement FI issues - FIs not timely Investigation Issues - due to lack of communication - due to DFCS - due to Law Enforcement - unspecified investigation issues Reporting Issues - Law enforcement - School - Cross reporting Law enforcement Issues

1 1 66 72% 16 17
9 10 4 4 3 3 2 2 6 6 1 1 1 1 8 9 7 8 6 6 2 2 6 6 6 6 5 5 5 5 5 5 5 5 4 4 1 1 5 5 3 3 1 1 1 1 5 5 2 2 1 1 1 1 1 1 4 4 2 2 1 1 1 1 3 3

Georgia Office of the Child Advocate for the Protection of Children

53

2017 Annual Report

Local CAP Development Worksheet Data Table 9:

Past 12 months CAP Compliance Issues Mandated Reporter Issues Lack of follow-up Case lingered on MDT schedule w/o resolution Mental health/substance abuse issues Sibling group separated
No response to compliance issues

# %

3

3

2

2

1

1

1

1

1

1

18 20

Total 92 100%

Local CAP Development Worksheet Data Table 10:
Measures recommended to improve compliance Responded to recommended measures Training
More training on reporting More CAP training/review Mandated training Training on signs of child abuse Regularly scheduled training Training on collaboration Training on the legal code Training on investigation Training unspecified Improved communication Protocol More adherence to current protocol Implement consequences for lack of compliance Update protocol Distribute protocol to all agencies Better contact information/identify points of contact Follow-up Need more/consistent follow-up Need written follow-up Collaboration Multi-disciplinary team meeting

# %

82 89%

23 25

7

8

6

6

4

4

2

2

2

2

1

1

1

1

1

1

5

5

13 14

9 10

5

5

2

1

1

1

1

1

8

9

7

8

6

6

2

2

6

6

6

6

Georgia Office of the Child Advocate for the Protection of Children

54

2017 Annual Report

All partners should attend/enhance partnerships Hold regular MDT meetings MDT unspecified Information & data sharing Resources to assist families & staff

2

2

2

2

2

2

5

5

5

5

Local CAP Development Worksheet Data Table 10:

Measures recommended to improve compliance Investigations
DFCS causes issues for LE during investigations Investigations should include more face-to-face contacts Forensic Interviews

# %

4

4

3

3

1

1

4

4

DFCS issues with FIs Complete within time frames Limit number of times children interviewed Removed barriers to reporting Separate child from alleged maltreator until investigation complete

2

2

1

1

1

1

3

3

2

2

Need to staff individual cases

2

2

No issues to report

5

5

No response to recommended measures

10

11

Total 92 100%

Local CAP Development Worksheet Data Table 11:
Successful measures taken to prevent child abuse Responded to successful measures Utilized Training
Provided training to all agencies/partners Provided training to targeted groups Provided training on specific topics Utilized CAP Utilized/implemented protocol Updated protocol Increased awareness of CAP Rely on partner resources/service coordination

# %

38 41%

9 10

3

3

3

3

3

3

7

8

4

4

2

2

1

1

6

6

Georgia Office of the Child Advocate for the Protection of Children

55

2017 Annual Report

Improved collaboration Improved reporting Improved communication across agencies Utilized MDT
Rely on regular MDT meetings Rely on MDT partnerships/participation Improved Forensic protocol Provided more information/data sharing with partners Assigned trained investigators Provided up-to-date contact information No successful measures to report
No response to successful measures

5

5

5

5

4

4

4

4

2

2

2

2

2

2

2

2

2

2

1

1

5

5

54

59

Total 92 100%

CAP Local Update Data Table 12:
Responded to Update Request Region 1: Region 2: Region 3: Region 4: Region 5: Region 6: Region 7: Region 8: Region 9: Region 10: Region 11: Region 12: Region 13:

#
11/11 13/13
6/ 6 12/12 12/12 8/10 14/14 17/17 18/18 14/14 18/18
9/ 9 3/ 3

%
100% 100% 100% 100% 100%
80% 100% 100% 100% 100% 100% 100% 100%

Georgia Office of the Child Advocate for the Protection of Children

56

2017 Annual Report

Region 14:
All Counties
CAP Local Update Data Table 13A:
County CAP last update received Regions 1-3 Region 1:
Catoosa Chattooga Cherokee Dade Fannin Gilmer Gordon Murray Pickens Walker Whitfield Region 2: Banks Dawson Forsyth Franklin Habersham Hall Hart Lumpkin Rabun Stephens Towns Union White Region 3: Bartow Douglas

2/ 2 157/159

100% 99%

Year of Last Update
2015 2015 2015 2015 2012 2012 2016 2017 2013 2015 2016
2015 2017 2017 2016 2014 2017 2016 2017 2014 2014 2017 2017 2017
2017 2014

# Years since Update* 1.4 1 1 1 1 4 4 0 0 3 1 0 0.5 1 0 0 0 2 0 0 0 2 2 0 0 0 1.3 0 2

Georgia Office of the Child Advocate for the Protection of Children

57

2017 Annual Report

Floyd Haralson Paulding Polk

2016

0

2012

4

2017

0

2014

2

* Based on last model protocol released in fall of 2016.

CAP Local Update Data Table 13B:
County CAP last update received Regions 4-6 Region 4:
Butts Carroll Coweta Fayette Heard Henry Lamar Meriwether Pike Spalding Troup Upson Region 5: Barrow Clarke Elbert Greene Jackson Madison Morgan Newton Oconee Oglethorpe Rockdale Walton Region 6:

Year of Last Update
2014 2015 2014 2000 2017 2016 2015 2017 2017 2017 2017 2017
2014 2008 2016 2015 2014 2016 2015 2014 2013 2016 2014 2010

# Years since Update* 1.8 2 1 2 16 0 0 1 0 0 0 0 0 2.2 2 8 0 1 2 0 1 2 3 0 2 6 0.5

Georgia Office of the Child Advocate for the Protection of Children

58

2017 Annual Report

Baldwin Bibb Crawford Houston Jasper Jones Monroe Peach Twiggs Wilkinson

2016

0

2016

0

NA

NA

2016

0

NA

NA

2014

2

2016

0

2017

0

2015

1

2015

1

* Based on last model protocol released in fall of 2016.

CAP Local Update Data Table 13C:
County CAP last update received Regions 7-8 Region 7:
Burke Columbia Glascock Hancock Jefferson Jenkins Lincoln McDuffie Richmond Screven Taliaferro Warren Washington Wilkes Region 8: Chattahoochee Clay Crisp Dooly Harris

Year of Last Update
2015 2015 2015 2015 2015 2016 2015 2015 2015 2016 2015 2015 2015 2015
2017 2017 2015 2015 2017

# Years since Update* 0.9 1 1 1 1 1 0 1 1 1 0 1 1 1 1 0.4 0 0 1 1 0

Georgia Office of the Child Advocate for the Protection of Children

59

2017 Annual Report

Macon Marion Muscogee Putnam Quitman Randolph Schley Stewart Sumter Talbot Taylor Webster

2016

0

2017

0

2017

0

2012

4

2017

0

2017

0

2016

0

2016

0

2016

0

2017

0

2017

0

2016

0

* Based on last model protocol released in fall of 2016.

CAP Local Update Data Table 13D:
County CAP last update received Regions 9-10 Region 9:
Appling Bleckley Candler Dodge Emanuel Evans Jeff Davis Johnson Laurens Montgomery Pulaski Tattnall Telfair Toombs Treutlen Wayne Wheeler Wilcox

Year of Last Update
2015 2015 2015 2015 2015 2015 2015 2015 2016 2015 2015 2015 2015 2015 2015 2015 2015 2017

# Years since Update* 0.9 1 1 1 1 1 1 1 1 0 1 1 1 1 1 1 1 1 0

Georgia Office of the Child Advocate for the Protection of Children

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2017 Annual Report

Region 10: Baker Calhoun Colquitt Decatur Dougherty Early Grady Lee Miller Mitchell Seminole Terrell Thomas Worth

0.1

2016

0

2016

0

2016

0

2016

0

2015

1

2017

0

2016

0

2016

0

2017

0

2016

0

2017

0

2017

0

2017

0

2017

0

* Based on last model protocol released in fall of 2016.

CAP Local Update Data Table 13E:
County CAP last update received Regions 11-14 Region 11:
Atkinson Bacon Ben Hill Berrien Brantley Brooks Charlton Clinch Coffee Cook Echols Irwin Lanier Lowndes Pierce

Year of Last Update
2014 2014 2016 2014 2014 2017 2014 2014 2014 2014 2017 2017 2014 2017 2014

# Years since Update* 1.2 2 2 0 2 2 0 2 2 2 2 0 0 2 0 2

Georgia Office of the Child Advocate for the Protection of Children

61

2017 Annual Report

Tift Turner Ware Region 12: Bryan Bulloch Camden Chatham Effingham Glynn Liberty Long McIntosh Region 13: Clayton Cobb Gwinnett Region 14: DeKalb Fulton

2017

0

2017

0

2015

1

0.6

2016

0

2016

0

2012

4

2017

0

2016

0

2016

0

2016

0

2016

0

2015

1

1.0

2014

2

2015

1

2016

0

2.5

2012

4

2015

1

* Based on last model protocol released in fall of 2016.

CAP Local Update Data Table 14:
State Summary: County CAP Last updated Within the past year One year ago Two years ago Three-five years ago More than five years ago
Average last CAP update Total Counties Responding

#

%

76

48%

47

30

23

15

8

5

3

2

1.0 years

157

100%