Ohio's Families and Children Rule Review Site

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(A) The public children services agency (PCSA) shall complete the JFS 01400 "Comprehensive Assessment Planning Model - I.S., Family Assessment" (rev. 7/2006) for both of the following reports:

Original Comment:

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Trumbull County
02-01-2019 (11:08am)
These pre-clearance comments are being submitted by Trumbull County Children Services (TCCS). If the goal is to provide a framework that supports thoughtful, timely, and quality assessments, in addition to revising these rules, the related assessment tools and SACWIS must also be revised. These components are an interdependent and cannot be isolated from each other. Consequently, TCCS’ comments include rule specific and thematic recommendations for each of these components. While the rule specific recommendations are linked to the individual sections of each rule, the thematic recommendations can be grouped as follows: CAPMIS Evaluation: The CAPMIS Evaluation was commissioned by ODJFS and conducted by a research team from the University of Cincinnati. The goal of this evaluation is to provide guidance for the revision of the CAPMIS tool-kit. This evaluation included a detailed analysis of three of the four assessment rules (the Safety Assessment, Safety Plan, and the Family Assessment) that are currently in pre-clearance. TCCS supports the thoughtful incorporation of the CAMPIS Evaluation recommendations into the revision of these rules. Visitation: TCCS shares ODJFS and our federal partners’ concerns regarding assessment/ investigation home visits. While TCCS endorses the idea that more home visits should be made than are currently the norm, because cases are not one-size-fits-all, we do not believe mandating a specific number of visits is the answer. Rather, TCCS hopes to collaboratively work with ODJFS to develop a regulatory framework that assures that an appropriate number of visits are made on each individual case. CARA & Human Trafficking: The Safety Assessment, Safety Plan, and Family Assessment rules and tools must be revised to address the requirements of the Comprehensive Addiction and Recovery Act (CARA) of 2016; the development of Plans of Safe Care for all CARA infants; and to ensure that all individuals (children and adults) are assessed for potential human trafficking involvement, pursuant to recognized best practice standards. Discretion: It is our understanding that HHS only requires that states assure timely and quality assessments. Beyond that, states have discretion to set specific requirements and mandates such as timelines, the tools to be used, and so on. Is this correct? If it is, given Ohio’s county administered structure, these rules must be redesigned to maximize county autonomy, discretion, and decision making. If it is not, we ask that ODJFS please provide the federal law, rule, or guidance that drives these rules and the content of these assessments. SACWIS: The shortcomings of Ohio’s SACWIS system are well documented. As repeatedly noted in the CAPMIS Evaluation, and in the recommendations of the CFSR PIP Workgroup, SACWIS enhancements could substantially improve rule compliance and the quality of these assessment processes. Because workers are spending too much at their desks, and not enough time in the field, steps must also be taken to simplify, streamline, and eliminate redundant data entry requirements. While we acknowledge that these enhancements will be expensive, if the goal is to improve the quality of assessments that are being completed, it is money that must be spent. And if it is well spent, like it was with the recent changes that were made to the SACWIS Screening/ Intake functionality, ODJFS, the PCSAs, and the children and families that we collective serve, will all benefit.
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