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December 13, 2006
| TO: |
Guy K. Zimmerman
Assistant Inspector General for Audit, OIG |
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| FROM: |
Michael Piraino
Chief Executive Office
NCASAA (The National CASA Association) |
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Thank you for the opportunity to respond to the Audit Report concerning the National Court Appointed Special Advocate Program. Our response to the recommendations follows.
Recommendation 1:
NCASAA establish a methodology for allocating indirect costs so that federal funds are not charged to unallowable cost categories.
Response:
The National CASA Association agrees with the recommendation and has already changed its methodology regarding allocations to “program service codes.” The change was made effective August 2, 2006, and all 2006 allocated costs were reclassified.
National CASA would like to stress that no unallowable costs were charged to federal funds. The costs in question dealt with items such as rent and insurance that were being allocated to broader categories purely for presentation in our statement of functional expenses. The now-established National CASA methodology allocates general costs such as these to related and specific cost categories based on documented employee hours. All unallowable costs such as fundraising are now—and have always been—charged directly to unrestricted, non-federal funds, and the new system will make this clear for 2006 and onward.
Recommendation 2:
Outcome-based performance measures are developed for its CASA programs that determine the effectiveness of the programs in meeting the needs of children in the CWS. As appropriate, these outcome measures should correspond with the data required by HHS for state and local CPS agencies, so that OJP has a basis for comparing the effectiveness of its CASA grant programs.
Response:
While National CASA currently uses outcome-based performance measures to help determine our effectiveness in serving children, we agree that additional measures and better data—if they relate to the potential impact of volunteers on child well-being and permanency—would be helpful. We look forward to working with the Office of Juvenile Justice and Delinquency Prevention to develop additional outcome measures of this kind.
National CASA has already put in place annual tracking of two measures mentioned in the Audit Report: the length of time children spend in out of home care from initial placement and the time children spend in out of home care after assignment of a CASA volunteer.
Although the Audit Report correctly points out that a child’s overall time in care may not be directly attributable to a CASA volunteer’s involvement, the length of time children remain in care after assignment of the volunteer is a relevant outcome consideration. National CASA’s annual program survey collects this data. In this connection, we think it significant that, according to the Audit Report [Table 12], children with a CASA volunteer are substantially less likely to spend more than three years in foster care—5.5% for CASA cases versus 18% for all children in foster care.
The two outcome measures in the Audit Report related to safe, permanent homes for children—adoption and reunification—have been tracked by NCASAA for several years. This corresponds directly to already-required outcome reporting for the states. [See AFCARS Report, Preliminary FY 2005 Estimates as of September 2006 and National CASA Association Local Program Survey 2005, pp 20-21 (“Reasons for Case Closure”)]. Some other outcome measures already tracked by National CASA were not included as outcomes in the Audit Report, although they can represent the successful achievement of permanency for the child. For example, permanent legal guardianship is both tracked by National CASA and considered a successful child safety outcome for purposes of the federal Child and Family Service Reviews. We welcome the opportunity to work with HHS and OJP to refine or add to these categories to allow better identification of child safety and well-being outcomes.
We are pleased that federal funding has enabled the expansion of CASA and volunteer guardian ad litem advocacy for children. Since federal funding began, an estimated 1.5 million children have had volunteers. Performance measures have been in place during each grant period to track the growth of this advocacy, which is the purpose of the federal funding that has been allocated to CASA.
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