After the CFSR onsite review has concluded and all applicable data and information have been analyzed, the Children’s Bureau prepares a written Final Report to the State on the findings informing the State whether it is, or is not, operating in substantial conformity. This Final Report includes a cover letter that estimates the Federal funds that are to be withheld from the State as a financial penalty for failure to achieve substantial conformity and the date by which the State must submit its PIP. The Children’s Bureau provides the State a courtesy copy of the cover letter and Final Report within 30 days of the statewide exit conference that marks the official end of the onsite review.
Note that the “courtesy copy” is a final draft that provides advance notice to the State of the review findings before the findings are made public. It serves as the written notice to the State of the determination of substantial conformity. After reviewing the courtesy copy and cover letter, the State and the Children’s Bureau work together to finalize any issues or revisions. The Children’s Bureau Regional Office then issues the official Final Report and cover letter to the State approximately 2 weeks after the courtesy copy.
The State must submit its Program Improvement Plan (PIP) for approval within 90 days of receiving the courtesy copy of the Final Report. In preparing the PIP for approval, the State child welfare agency must involve staff and external partners to ensure that all stakeholders have collective ownership in the document and address the most meaningful priorities for the child welfare system as a whole. States should also make use of the tools provided by the Children’s Bureau, which include technical assistance (TA) opportunities and the PIP Matrix, which was developed by the Children’s Bureau as a suggested format for States to use in organizing their PIP content.
- The PIP Matrix is available online at http://www.acf.hhs.gov/sites/default/files/cb/pip_instruct.pdf
To be a useful working tool for creating systemic change, a PIP should be manageable and include clear goals and strategies, measurable action steps with time frames, realistic benchmarks that can be used to gauge progress, and the negotiated improvement that the State will make toward meeting the national standards and the item-specific measurements. Additionally, a properly and thoroughly developed PIP will generally do all of the following:
- Be theme-based, providing a system for integrating the action steps across items, outcomes, and systemic factors.
- Build on what the State learned through its Statewide Assessment and the onsite review.
- Provide for the engagement of the agency’s leadership and upper management throughout the PIP implementation and monitoring process.
- Identify the individuals responsible for the program improvement action steps, the measurement process, and the review process.
- Identify opportunities for stakeholder involvement.
After the State completes and submits its PIP to the Children’s Bureau for approval, the Bureau reviews it and either accepts it as submitted or returns it to the State with comments.
Once the Children’s Bureau has approved the State’s PIP, it provides the State with an approval notification that identifies the target completion date for the PIP. The State signs this notification and forwards it to the Children’s Bureau Central Office. At this point, the State’s 2-year PIP implementation period begins. All financial penalties are placed on hold while the State implements its PIP.
If the Children’s Bureau does not approve the State’s PIP, it sends the State a written notification detailing the basis for the disapproval as well as a target date for resubmission by the State, which should be within 30 days. The State’s resubmission must address the areas that resulted in disapproval of the PIP. The PIP is then subject to another round of review and comment by the Children’s Bureau. If the State does not submit an approvable PIP within the specified time frame, then the financial penalties outlined in the cover letter may be reinstated.