This PCG CCWIS team has worked together on several planning and project management efforts and continues to add to our expertise and toolkit in this area.
In September 2021, the Children’s Bureau (CB) of the Administration for Children and Families (ACF) released the Comprehensive Child Welfare Information System (CCWIS) Technical Bulletins (TBs) #7 (CCWIS Technical Assistance, Self-Assessment Tools, and Monitoring Reviews) and #8 (CCWIS Data Exchange Standards), providing important tools to help title IV-E agencies think about the evolving landscape of the CCWIS journey. ACF also gave further consideration to the concept of duplicative functions. Taken together, this guidance has the potential to redefine the relationships that exist between Child Welfare Contributing Agencies (CWCAs) and the title IV-E agency, including more opportunity to leverage the technology assets that CWCAs have built to help keep children safe.
CWCAs often play a critical role in supporting states and tribes to implement their title IV-E program, taking much of the direct responsibility for ensuring child safety, stabilizing families, and achieving placement permanency. To perform their roles well and efficiently, many CWCAs have invested in automating their business processes, and there is much that can be learned from these automation efforts as states and tribes continue their CCWIS journey. The reconsideration of how duplicative functions are defined suggests ACF’s renewed focus on data management, governance, and quality efforts and reemphasized opportunities for title IV-E agencies to remain at the center of title IV-E data activities.
The release of TBs #7 and #8 adds helpful tools to the CCWIS project toolbox. TB #7 contains a trove of tools and information to help states and tribes at several stages of their CCWIS projects. TB #8 provides clarification on data exchanges and exchange standards that is helpful for states and tribes to ensure compliance. Additionally, the transmittal letter for TB #8 includes a revised definition of duplicative functions that is expected to receive more attention moving forward since it emphasizes the importance of building and maintaining good data governance and quality practices.
What’s at stake?
As we have written before, the CCWIS efforts are enormous opportunities for states and tribes to standardize their business programs in specific ways, including standard data element definitions and exchange standards. Data exchange requirements are prominent features of the CCWIS rule and are required for compliance and federal funds participation, and capitalizing on these opportunities is very much a team effort.
By now, states and tribes should be acutely aware that data management is not solely the domain of the Information Technology (IT) group within an organization. While this is where data management activities often get started, everyone should understand data quality and how it is managed:
- Data creation and usage are the most critical points in the data lifecycle. Front line workers are key to data quality—they need to understand and should be actively encouraged to enter data that reflects data quality goals.
- Managing the rules of how data is acquired, used, and stored is important, especially between data exchange partners, and contributes to data quality. These are key points to cover in steering committee discussions.
- Managing the securing of data is important to comply with data sharing agreements, rules, and regulations and safeguard confidential and personal identifiable information.
These are concepts for which implementation in practice can be demanding, and, without attention to the details, could jeopardize CCWIS funding.
Recognize the opportunities to build effective tools into planning and DDI efforts
- Data management and governance structures and processes
- Data exchange standards
- Recognition of the fact that “organic” change usually takes longer than “managed” change
CWCAs should be included in the data governance strategy
The bi-directional data exchange requirements suggest that there will be cross-sector data management challenges for agencies to address with their external data exchange partners. A network or advisory group of stakeholder agencies will be helpful in starting and sustaining the dialogue around data and its governance vis-à-vis CCWIS operations.
Agencies should expect that, without a standard for exchanging data, state systems will not be speaking the same data language as partner agency systems, and the state system will not comply with CCWIS rules. It would be a mistake to just have state IT teams meet with only technical staff from CWCAs to discuss data exchanges.
“Child Welfare Contributing Agency” is defined as a public or private entity that, by contract or agreement with the title IV-E agency, provides child abuse and neglect investigations, placements, or child welfare case management (or any combination of these) to children and families.
-CCWIS Technical Bulletin #2
Why? Because they need input from program leadership to understand what data is most important for understanding services and program outcomes, and the program leadership needs to understand the impact of poor data quality that originates with their frontline workers. States and tribes will also miss an opportunity to develop broad relationships with their CWCAs.
Here are some actions to take now:
Start by defining stakeholders that need to be part of the discussion. Coordinate the larger goals and establish common priorities and objectives across data exchange sectors (such as Education, Courts, and Medicaid) before discussions about data exchange standards are initiated. This will help the development of a charter that will guide the effort. With these basic steps, the team can stay focused on the high priority outcomes associated with bi-directional data exchanges.
Some states may benefit from developing these processes internally before inviting CWCAs into the process. PCG’s experiences have shown that these processes often entail difficult internal conversations, but don’t fail to invite the CWCA when core decisions are made and processes are defined.
Use the TB #7 tools advantageously. TB #7 contains information for technical assistance (TA) activities throughout the lifecycle of a CCWIS and how these activities should be viewed as a collaborative effort between the title IV-E agency and ACF. TA activities should be viewed as iterative processes that will need to be adaptable to the changing phases of a project lifecycle. The Self-Assessment Tools that are referenced in TB #7 will help agencies frame compliance criteria more discretely and can also help with procurement and contract requirements.
Use TB #8 to open the dialogue on data exchange standards. Required and recommended data exchange standards are clarified to a point, but the title IV-E agency will still need to decide on specific standards. Collaboration with CWCAs should be an ongoing dialogue that helps both title IV-E agency and CWCAs achieve their goal of protecting their state’s most vulnerable citizens. Title IV-E agencies and CWCAs may have their own data standards, but, by working together, they will have a better chance of defining a data exchange standard that meets both their needs.
Public Consulting Group LLC (PCG) is a leading public sector solutions implementation and operations improvement firm that partners with health, education, and human services agencies to improve lives. Founded in 1986 and headquartered in Boston, Massachusetts, PCG employs over 2,500 professionals in more than 40 offices worldwide. PCG offers education consulting services and technology solutions that help schools, school districts, and state education agencies/ministries of education to promote student success, improve programs and processes, and optimize financial resources. To learn more, visit https://www.publicconsultinggroup.com/human-services/.
To learn more about how PCG can support your CCWIS needs, contact us today.