monthly article for July 2005
Immediate Evaluation of the Safety
Last month we began a series of articles focusing on the safety
management roles and the related responsibilities for ongoing CPS
workers. These first two articles in the series addressed the diligence
and effort that is necessary when case transfer from initial assessment/investigation
to ongoing CPS occurs. Last month's article concerned with the CPS
case process stressed the importance of understanding and accepting
the numerous complex tasks that require routine attention as long
as a child is unsafe. It was highlighted that in order for ongoing
CPS staff to be effective in their role they must be confident about
and proficient in the tasks of initial assessment which include
application of information standards that guide decision-making,
safety threat identification, and safety planning.
In this month's article, we will take a closer, more detailed look
at what is necessary to adequately determine if safety plans are
sufficient at the time when ongoing CPS workers receive new cases
from initial assessment/investigation. Let's set the foundation
by looking at a typical, but real, safety plan. See if you believe
that this safety plan is more detailed, similar to, or less comprehensive
than the ones you usually receive at case transfer.
The ongoing CPS worker's responsibility to conduct an immediate
evaluation of the sufficiency of safety plans transferred to him
or her remains the same whether the safety plan involves in-home
safety management or out-of-home safety management. Note: If a case
is transferred to you, the ongoing CPS worker, and the child is
placed, that placement is the safety plan. Everything in this article
applies to that situation as well as to in-home safety plans transferred
to you. Okay? Read on.
The Delaney Family
This family includes a father of a three-year-old boy and his live-in
girlfriend. The child has been brought into the hospital on a few
occasions for injuries that were reportedly suspicious but could
not be confirmed as non-accidental in nature. Currently the injuries
include bruising to the face, arms, and legs. The father and his
girlfriend indicate that the child is "accident prone."
They stated that another child that the girlfriend was babysitting
caused one of the injuries-the bruise on the forehead. There also
appear to be questions regarding the quality of supervision and
unrealistic expectations of the child in terms of self-care. The
father is unemployed. The relationship between the father and girlfriend
is often argumentative. There is some suggestion that the fighting
between the father and the girlfriend has become physical. Both
caregivers are very cooperative, seem very concerned, and are willing
to accept CPS intervention.
Proposed In-Home Safety Plan:
1. Monitor and Supervise Situation. Provider: Child's Pediatrician
The Pediatrician will monitor the child's welfare. He will examine
the child and check for bruising and injuries. Further, the pediatrician
will check with father and his girlfriend (caregivers) regarding
their personal interaction and/or any difficulties that they are
having with the child.
Time Frame: Scheduled Bi-Monthly
2. Separation/Child Development Provider: Headstart
Headstart will work with the child's motor and social skills. Headstart
will also provide some separation and relief for both the caregivers
and the child.
Time Frame: 5x wk - 9 am to Noon
3. Parenting Counseling Provider: Caseworker
This caseworker will assist the father in developing appropriate
parenting knowledge and improve parenting skill.
Time Frame: 2x a month
4. Resource Development Provider: Caseworker
This caseworker will assist the father with obtaining employment.
Time Frame: Ongoing
If the arguments continue between the father and girlfriend, the
father has indicated that he will ask her to move out.
As you proceed through the article and consider the principles
and practices related to evaluating safety plan sufficiency at case
transfer, think about how the Delaney safety plan holds up. What
appears to be the primary foreseeable danger threat? What level
of confidence can we have about the child being protected? What
are the limits of this plan?
At the conclusion of the article, we'll provide you with our take
on the sufficiency of the Delaney safety plan. However, for now,
consider the following:
" Do the safety responses seem sufficient? Why or why not?
" Are the safety responses consistent with the purpose of
safety planning which is to control safety threats rather than change
" Is the level of effort sufficient by all parties involved
to assure protection?
" Do you have any concerns about the time-frames, accessibility,
or availability related to safety responses and those involved in
the safety plan?
Key Safety Plan Evaluation Issues
Rules of Engagement at Case Transfer
The responsibility for the safety and protection of the children
is the paramount responsibility for all CPS workers. Who would argue
that the oversight of that responsibility could be the loosest at
case transfer? All too often when the initial assessment worker
hands the reins to ongoing CPS, there is some gap of time that elapses.
For a day…maybe days, the case often is in limbo. Who is responsible
for safety management? The initial assessment worker's attention
turns to other immediate, demanding assignments. For the ongoing
CPS worker, this unknown case is dropped into a pile of already
demanding ongoing CPS cases.
Every jurisdiction has varying procedures for transferring cases
to ongoing that include things like required information exchange,
individual meetings between supervisors and workers, case staffings,
and, to a much less extent, joint home visits involving initial
assessment and ongoing CPS staff. Despite apparent standards and
procedures that are in place, we often hear ongoing CPS staff indicate
that, for a variety of reasons, following case transfer, the procedures
do not consistently happen. Now, what we would maintain is that
even if case transfer standards and procedures were followed, most
of these do not include specific expectations and instructions for
transferring the safety management responsibility and evaluating
the sufficiency of the safety plan.
It should be emphasized to ongoing CPS staff what the most crucial
information is that would "get them up to speed" concerning
case conditions, foreseeable danger threats, and safety plans. Furthermore,
it should be emphasized to ongoing CPS staff what their ongoing
CPS safety management responsibilities are.
What are the rules of engagement to which we refer? Surely, ongoing
CPS staff has received lots of messages about engagement as it pertains
to involving families in efforts to change. That is not what we
mean here. This use of the idea of engagement in this context is
concerned with the ongoing CPS worker becoming connected to, busy
and occupied with the role and responsibilities of safety management.
In simple terms, what should you, as an ongoing CPS worker, do in
the beginning to get going with your safety management responsibilities?
The rules of engagement for ongoing CPS staff related to safety
" Immediate Contact with the Caregivers and Children.
This rule, with respect to what qualifies "immediate"
is dependent on exactly what is happening in a case: unusual case
activity; nature of safety threats; whether the safety plan is in-home
or out-of-home and the need to respond differently to each; child
vulnerability including accessibility to the safety threat; level
of effort, frequency of activities in the safety plan, and reliability
of those involved in the safety plan; confidence related to caregiver
participation and trustworthiness.
" Immediate Evaluation of the Safety Plan.
This requires confidence and proficiency regarding the purpose
and function of the safety plan. This includes ensuring that threats
are controlled and managed at the appropriate frequency and duration
that matches how threats are occurring with services to mitigate
and control them.
" Immediate Adjustment of the Safety Plan.
The safety threshold qualifies dangerous family conditions as imminent
which means that troubling family conditions are likely to have
a severe effect on a child from now to the next several days. This
fact compels us to always act promptly and thoroughly when a safety
plan is judged to be insufficient and in need of modification. Provisional
protection needs to be understood as dynamic, alive, and always
adjustable. Meeting the mandated reasonable efforts requirements
supports the idea of provisional protection and best practice. The
"immediate adjustment" rule follows so that you balance
assuring child safety using sufficient safety plans and do so using
the least intrusive methods necessary.
Note: In the context of case transfer, "immediate" refers
to a time period. It begins with cases involving an unsafe child
when the case is opened to or assigned to ongoing CPS rather than
when the case is actually given to an ongoing CPS worker. The time
period is complete within one work week. From the time a case is
assigned, to when an ongoing CPS worker assumes direct responsibility
for safety management should be qualified by specifically what is
going on in a case and what is set forth and required to be occurring
within the safety plan. In other words, the outside limit of this
time period should be thought of as a minimum standard, and the
application of the rules of engagement should be qualified by specific
case conditions and the requirements of the safety plan.
It is important for you as an ongoing CPS worker to become informed
and prepared concerning necessary home visits, scheduled appointments,
court hearings, and so on. However, the bottom line is that reviewing
the safety assessment and safety plan are your most important beginning
responsibilities upon being assigned a case. To do so is to effectively
attend to the primary objective of CPS: to assure he safety of children.
Confirming the Rationale and Sufficiency for the Safety
A sufficient safety plan is a "well thought-out approach containing
the most suitable people taking the necessary action frequently
enough to control the safety threats and/or substitute for the diminished
caregiver protective capacities." This definition presses us
to move well beyond traditional diametric thinking associated with
unsafe children and safety intervention such as the old idea and
practice "unsafe equals placement." Safety planning and,
therefore, safety management should be creative and individualized
to each family that is identified as needing a safety plan. At case
assignment to ongoing CPS, your job is to move immediately toward
reaching a personal judgment that safety plans transferred to you
are well thought-out; contain the most suitable people; include
necessary actions; identify necessary level of effort; and are effectively
related to safety threats and diminished caregiver protective capacities.
In order to confirm that a safety plan is the most appropriate
and sufficient as described in the above definition, you must consider
four areas of analysis:
" Do I understand how the safety threats are occurring
in the family?
How long have the conditions in the family posed a threat? What
is the frequency of the family condition? How predictable is the
threat and, is there a time when it is more likely to be active?
Are there particular times of the day that require "special
What does it mean if I do not know the answer to these questions
clearly and thoroughly? If the record, the initial assessment worker,
the case staffing, the procedures do not fully inform me about how
safety threats are occurring, what should I do? Without being able
to articulate the nature and occurrence of safety threats in detail,
I am left with two alternatives: 1) launch an immediate effort to
meet with the family and collect the information myself, and 2)
consider the need for an out-of-home safety plan until the lack
of clarity can be reconciled. Simply put, I cannot control something
if I don't know what it is.
" Is there some caregiver capacity in the home that can
manage the threat without direct assistance from CPS?
Family-centered beliefs and practices should influence CPS to always
consider safety planning in ways that involve and employ family
members and family resources to achieve a safe home. Family circumstances
and resources can be different between the original development
of safety plans and case transfer. At case transfer, you should
explore whether a non-maltreating caregiver with sufficient capacity
is available. Perhaps a maltreating caregiver has since agreed to
leave the home or will consider the option. It is possible that
other family members or other people have become available since
the time when the safety plan was established by the initial assessment
worker. You should always be open to the prospect of reducing intrusiveness
and returning the protective responsibility to the family, if not
the caregivers, when safety can be guaranteed.
" Can I modify an out-of-home safety plan by increasing
in-home safety management options?
Do the caregivers reside in the home? Is the home environment calm
and consistent enough at a minimal level? Are caregivers willing
and cooperative with in-home safety planning? Are there any further
professional/medical evaluations necessary? If the answer to all
of the questions is "yes," then I should consider adopting
an in-home safety plan or, at least, determine if I can work with
the caregivers and family to devise some in-home safety management
options that can match up with the out-of-home safety plan and can
accelerate a child's return home. How does caregiver - child visitation
and contact influence this analysis question?
" If I consider modifying an out-of-home safety plan to
an in-home safety plan, what must I figure out?
What responses, safety actions, and safety services will be needed?
In what frequency? Who can and/or must be involved in planning and
also in assuring that necessary action occurs as planned? Can I
make an effective match of safety responses/services to control
threats? How will I know that the actions I plan will control threats
as they are intended to do? What is the level of effort required,
for example? How often during the week should safety actions and
services occur and for how long each time should they occur? Are
there periods of time each day or each week that require special
attention? Besides me, are there others who can and will assure
effective implementation of the plan?
There are two other things I must address. First, I must decide
if the safety providers are suitable and capable beyond the required
background checks. I must be able to document their protective capacities,
commitment and alignment with CPS, trustworthiness, and reliability.
The last step I must do, after considering the four areas of analysis
and figuring out what the safety plan must be, is to reach a confident
conclusion that I have what is necessary. If I cannot be confident
about the plan and who will be involved in it, then I must conclude
that an out-of-home safety plan is the reasonable option.
Other Criteria to Judge the Sufficiency of the Safety Plan
When evaluating the sufficiency of safety plans, keep in mind that
all safety responses/services also have to satisfy five essential
1. Immediately available - can be deployed right now and in sufficient
2. Action oriented - services that are active and focused with
respect to the safety factors, not change or treatment related.
3. Flexible access - services that are located in acceptable proximity
and can be called upon for immediate response.
4. Immediate impact - services that do what they are supposed to
do as they are delivered and achieve the objective……keep
5. No promissory commitments - having no expectations in safety
plans for caregivers complying with or being responsible for protecting
their children, promising to protect, or stopping certain behaviors.
The identification of safety threats in a family is in part a determination
that a family condition is "out-of-control." The result
is that CPS must intervene on behalf of a vulnerable child and must
assume the responsibility for what caregivers cannot or will not
do. Substituting for parenting behavior that is "out-of-control"
cannot begin leisurely. It must be immediate. Safety plans should
never ask nor have caregivers promise to change behavior. If caregivers
could change their behavior and situation on their own, CPS would
likely never have had to be involved.
When In Doubt………
For you as an ongoing CPS worker, evaluating and determining the
sufficiency of safety plans begins as soon as a new case comes into
your hands and continues throughout your ongoing safety management
responsibility until the child is safe and lives in a safe home.
Always be mindful that diligence and actively responding in accordance
to what you know about safety threats and caregiver protective capacities
is crucial to effective safety management. Safety intervention should
be driven by the concept of provisional protection which maintains
that what you do to manage a child's safety should always be thought
of as in a state of flux, subject to increasing or decreasing the
level of effort and intrusion in accordance with what is happening
in the family. Family systems are always in a constant state of
adjustment and fluctuation. As caregiver protective capacities and
safety threats are enhanced or reduced, so should the level of intrusiveness
be increased or reduced to match what is happening in the family.
When you use the principles, rules, and analysis provided in this
article to evaluate safety plans you receive at case transfer, there
are only two conclusions that are possible: safety plans are sufficient
or they are insufficient. These conclusions leave you with two options
or actions to take. If you conclude that a safety plan is sufficient,
then you reinforce and confirm it to everyone involved and proceed
to manage it. If your conclusion is that a safety plan is insufficient,
then you increase or decrease the level of effort and intrusion
based on your understanding of safety threats and caregiver protective
As an ongoing CPS worker, when evaluating safety plans transferred
to you, consider the following:
¢ Make sure you know how the safety plan is supposed to be
managed before you fully take the reins from the initial assessment
¢ Make sure you fully understand exactly what is expected
in a safety plan and who is to do it.
¢ Make sure you understand the rationale for the type of safety
plan (e.g., in-home, out-of-home, or a combination of in-home and
out-of-home) which includes a full understanding of the safety threats
and how they are manifested.
¢ Make sure that the safety plan will keep the child safe.
Rely on your supervisor to confirm that judgment. Concluding a safety
plan is sufficient goes hand-in-hand with the level of your confidence.
Any time your confidence is in question about the safety plan, chances
are that it is reasonable to question its sufficiency. "Maybe
or probably" are not good standards when it comes to making
sure children are safe.
¢ Make sure that all safety services are kept qualified by
criteria that you apply.
¢ Confidence and proficiency at evaluating the sufficiency
of safety plans are not fulfilled until you appropriately make necessary
adjustments immediately upon realizing the need to do so.
Related articles for further, in-depth reference:
March 2003 - "Threats to Child Safety"
December 2003 - "The Safety Plan"
February 2004 - "Are the People Who Participate in Safety Plans
Suitable to Do So?"
May 2005 - "Provisional Safety Management"
"Protective Capacity Assessment: Beginning the Process
of Integrating Safety Concerns into Case Plans"
Our Take on the Sufficiency of the Delaney Safety Plan
These observations are directly related to the principles and practices
discussed in this
Do you remember that a sufficient safety plan is a well thought-out
approach containing the most suitable people taking the necessary
action frequently enough to control the safety threats and/or substitute
for diminished caregiver protective capacity? Keep that in mind
as we share with you what we believe about the sufficiency of the
Delaney safety plan.
Determining the Rationale of the Delaney Safety Plan
Do I understand how the threats are occurring in the family and
are the people/services taking the necessary action to mitigate
against the threats?
o The answer is no. The facts are that there is a documented history
of injuries that are suspicious, but are not confirmed to be non-accidental.
Anyway, the injuries are unexplained. We have to pay attention to
that. If you are unable to understand how, when, and what it is
that you are trying to control, you need to be pretty conservative
with respect to what is required to keep a child safe. Perhaps an
out-of-home safety plan is necessary until you can get better clarity
about the nature and occurrence of the safety threats. This is a
judgment about the level of effort and intrusiveness that CPS needs
to use to intervene with the family. An in-home safety plan in the
Delaney case with the threats and injuries unexplained means we
need to have high exposure and involvement of the "most appropriate
- suitable people" in the development and implementation of
the safety plan. This is so because the threats are active seven
days a week when the child will not be at Headstart. Special attention
should be focused on the times in the afternoons/evenings when the
girlfriend is home when there may be an increased potential for
domestic violence in the home. You will notice that there is nothing
in place to address these times. The Delaney situation suggests
the need for a big time effort of involving eyes and ears which
includes the CPS caseworker. We think that relying on the pediatrician
for oversight is shortsighted given that his or her exposure to
the case is likely to be less than once a week and likely is subject
to the father and girlfriend bringing the child in to be seen. So,
we conclude that there is not enough time or effort demonstrated
in the Delaney safety plan particularly given that the single safety
threat we are sure of is "unexplained injuries."
Other Sufficiency Criteria
o Immediate availability and impact
Only the Headstart separation service satisfies this criterion
assuming that there is an opening and the child can start the next
day without any testing. However, this only covers three hours a
day for five weekdays. Otherwise, there is nothing that is controlling
or substituting for a family condition or parenting behavior that
may be a threat to safety.
o Action oriented
Headstart is the only service that meets this criterion. The separation
of the child and caregiver assures the safety of the child for the
three hours each day during the week. None of the other services
are active and focused with respect to the safety factors. Parenting
counseling and resource development are not safety services. Parenting
counseling and resource development are change and treatment related
and are not focused on foreseeable danger threats. (Additionally,
these services take time to have an effect. See above criterion
- immediate impact.)
o No promissory commitments
The father has indicated that he will ask his girlfriend to leave
the home if the arguments continue. If domestic violence in the
home was identified in the safety assessment, then it was determined
to have met safety threshold criteria particularly as related to
being out-of-control. CPS should not put the responsibility for
controlling a threat on the father after having determined that
he is involved in a family behavior that is out of his control
We conclude that the Delaney safety plan is insufficient and needs
to be revised by the ongoing CPS worker immediately.