This summer, the Illinois Department of Children and Family Services (DCFS) announced a draft Strategic Plan to guide its operations for the next five years and solicited stakeholder feedback on this Plan (draft available to view on the DCFS website). We were pleased to have the opportunity to support an ongoing dialogue with the Department. On August 17, 2016, the Family Defense Center submitted comments on DCFS’ Strategic Plan. The executive summary is included below; see full comments here. We have high hopes that our comments will be considered, particularly our call for DCFS to address its investigations function as well as its role as a foster care provider. We look forward to the next steps for DCFS to support and protect the families that it serves.
The Family Defense Center applauds DCFS’s effort in creating a strategic plan to help guide proposed reforms to the Department, as well as the outreach to stakeholders to seek comments. Our main concern with the DCFS Strategic Plan Draft is that the Plan only addresses DCFS’s role as a foster care provider and fails to address much-needed reforms in how DCFS conducts the child abuse and neglect investigations that can result in serious consequences for children and families, extended family members, and people who work with children. Investigations can be very traumatic and most investigations are unfounded, but can leave lasting impacts that color the interactions of children and families and service providers with DCFS. Where investigations result in the removal of children from their families, even for a short period, the impact is profound.
We are also very concerned that DCFS-involved families and family advocacy organizations appear to have been left out of the process when creating this Plan. We believe that DCFS should prepare a companion Strategic Plan that deals with its role as the lead child abuse and neglect investigator in Illinois and the service delivery it provides for children and families when the children are not wards of DCFS. In our discussion below, we suggest areas we believe DCFS needs to address in this companion plan, and in some cases propose solutions. We also provide our comments on the strategic plan itself. For very detailed comments and questions, we provide an appendix with detailed responses to various parts of the plan.
Our specific strategic suggestions, elaborated in the discussion and appendix of these comments, include the following:
- Expand the DCFS Legal Department to better respond to and resolve issues arising in investigations and intact services cases—the vast majority of the cases actually handled by DCFS each year. In many instances, the intervention of a Department lawyer well-versed in the legal powers and obligations of the Department could stop violations of clients’ rights as soon as they start and help to avoid the lengthy and expensive litigation of these violations, as well as minimizing the harm done to families.
- Reframe investigations to make neglect investigations less punitive and more effective at improving family and child outcomes, with tolerance for ordinary parenting mistakes and identification of needs and provision of appropriate services when necessary. DCFS should start by renewing the Differential Response Program and ensuring that service plans are tailored to individual families and do not require unnecessary and burdensome services, as well as fully implementing the safety plan reforms agreed to in our most recent settlements with the Department.
- End the practice of “forced custody relinquishment,” and provide appropriate health services to children and families who need them without requiring parents to give up custody of their children.
- Tackle the serious racial, gender, and disability biases in DCFS abuse and neglect investigations that have to be addressed at every level in a serious manner, not simply with humility, as suggested in the Plan.
- DCFS should change its approach to domestic violence from punishing the victims by finding them guilty of child neglect to providing referrals and necessary services to keep the whole family safe. We are disappointed that some of the very important work on these issues that the Department is undertaking is not highlighted in this report and we encourage the Department to work closely with the domestic violence advocacy community.