Ohio's Families and Children Rule Review Site

5101:2-33-02 PCSA requirement to participate in child protection oversight and evaluation.

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3I Agree2I Disagree
Staci Nichols
05-13-2020 (4:31pm)
The PPA timeframe should be 30 days to start with. 15 days does not seem sufficient and may prevent many extension requests.
0I Agree4I Disagree
louis devault
05-14-2020 (10:52am)
This over sight is not enough and truly needed at least quarterly...Civil liabilities and criminal liabilities have gone up significantly in the last three years...Reverse federal funding matrixs are in place and should a case be documented as this one was The state of ohio would lose significant funding...https://youtu.be/hOIUQ3N6qJI The state of ohio is also remiss at establishing a arbitration matrix to compensate the failed clients as is also required by federal law...Several states are establishing a funded matrix to compensate the failed clients of Child Protective services and Ohio is no exception...With the advent of group sourcing , cell phone recording and easily accessible digital devices past practicces shall not be enough to float substandard services...
12I Agree2I Disagree
Richard Tvaroch
05-18-2020 (3:32pm)
Trumbull County Children Services GREATLY APPRECIATES the Department’s willingness to put its commitment to examining and improving the CPOE process in rule. THIS IS EXCITING AND THANK YOU. However, we must also recommend that the proposed new paragraph (O) (6) be replaced with: (O) (6) Outcome Federal outcome indicators involving child safety, child permanency, and child and family well-being; compliance with statutorily mandated PCSA responsibilities; and selected child welfare program components across the continuum. This language serves the exact same purpose while being more encompassing, is factually accurate (screening, dispositions, and child placement are not federal issues), and is less provocative. Our concern is that keeping refences to screening, dispositions, and child placement in this version could make the clearance and the JCARR process unnecessarily contentious. We (ODJFS and the PCSAs) all know that these issues will be on the table for CPOE 13, so let us save the debate/ negotiations until then.
12I Agree2I Disagree
Richard Tvaroch
05-18-2020 (6:54pm)
Trumbull County Children Services recommends that the following be added as paragraph (N) (1) and (N) (1) (a); and that the rest of paragraph (N) be re-enumerated accordingly: (N) (1): If the PCSA’s appeal exposes a factual inaccuracy in the CPOE Report or its finding, the CPOE Report will be retracted, corrected, reissued by ODJFS. (N)(1)(a):The appeal timeframes outlined in paragraph L of the rule will reset to the date that the PCSA receives the reissued CPOE Report.
12I Agree2I Disagree
Richard Tvaroch
05-18-2020 (10:06pm)
Trumbull County Children Services recommends that the timeframes in paragraph F be changed from 15 to 30 days. If the PCSA is attempting to address multiple issues, or if the issues are especially complex, 15 days may not be sufficient time to develop an adequate PPA.
8I Agree3I Disagree
Richard Tvaroch
05-18-2020 (10:08pm)
The “flow” of paragraph L is unclear and confusing. It also does not tie back to the PPA process outlined in paragraphs F and G. If it does not need to tie back to the PPA process, the following would clarify what I believe the intent of paragraph L to be: (L) Upon the receipt of the final report the PCSA may do one of the following: (L) (1) Notify ODJFS of the intent to file an addendum to the report within 15 days of receipt of the CPOE final report. (L)(2) Notify ODJFS of the intent to file an appeal 15 days of receipt of the CPOE final report. (L)(3) Submit an addendum or appeal in writing within 30 days of receipt of the CPOE final report. (L)(4) Remains as currently written. This comment does not address the lack of connection to the PPA process outlined in paragraphs F and G.
10I Agree2I Disagree
Shelby Cully
05-19-2020 (10:14am)
Please note the new paragraph (L)'s wording is confusing. Is there a difference between the final report and the CPOE final report? If there is not then the dates do not make sense as it gives you 30 days in (L) but only 15 days in (L)(1) and (L)(2). Is the 15 days added onto the 30 days? If so, then you may want to eliminate the 30 days in the initial paragraph of (L) and just state the time frames for actually filing the reports rather than including an extra notice option. Also, (L) states the PCSA may do one of the following and then list options except that number (4) is not something the PCSA may do but rather a direction of what must be included in an appeal. Section (4) may more appropriately go as a subset of (3) or under the new (M). The new (M) could set out the expectations of both the addendum and the appeal. Overall, thank you for your hard work.
11I Agree2I Disagree
Tina Rutherford
05-19-2020 (11:34am)
Regarding document - language change to "all necessary non-SACWIS" document. (as ODJFS staff have access to SACWIS). Also, add "as available with notice" to making staff available.
8I Agree2I Disagree
Mary Wachtel
05-21-2020 (1:23pm)
We appreciate the dialogue among PCSAs, the PCSAO Rules Committee, and ODJFS policy and field staff to date on this rule. It is clear that we share the collective goal to further redesign the CPOE process to a robust quality improvement tool that significantly advances children services practice and outcomes for children and families.
9I Agree2I Disagree
Mary Wachtel
05-21-2020 (1:31pm)
Please provide background and explanation for the decision to conduct CPOE 12 in two twenty-four month phases, with different provisions of this rule applying to the two different phases, as noted in section (B). As we read this, we conclude that the different phases will operate under different portions of this ruls. Is this correct? If so, what is the expected benefit of this approach? Related to that, we are surprised by the level of detail outlined in Sections (B) - (G), regarding the process of CPOE 12. This does not seem typical of most ODJFS rules please explain the reason for this detail.
6I Agree3I Disagree
Mary Wachtel
05-21-2020 (1:37pm)
(K) (2) --- i believe the work "stakeholder" should replace the word "shareholder" in this section.
5I Agree1I Disagree
Mary Wachtel
05-21-2020 (1:39pm)
We appreciate that you have clarified the distinction between an addendum and an appeal, and defined both in sections (M) and (N)
5I Agree1I Disagree
Mary Wachtel
05-21-2020 (1:41pm)
In section (O), please clarify that the "next CPOE cycle" is CPOE 13.
6I Agree1I Disagree
Mary Wachtel
05-21-2020 (1:48pm)
As currently drafted, section (O) could be read to mean that items (1) - (7) will be included in the CPOE review, rather than in the examination of the CPOE process. If the intent is the former, we believe that item (6) should exclude "screening, report disposition, placement decisions." If the latter, (O) should be changed as follows: "An examination of the CPOE process will occur prior to the next CPOE cycle. The EXAMINATION (not "review") will include, at a minum, the following:.....