Office of Inspector General of Nebraska Child Welfare
Recommendation Report
DHHS
Children and Family Services
Recommendation: Evaluate and enhance the identification and assessment of all persons with regular access to a child in the child's home.
Recommendation: Develop a system for evaluating the effectiveness of family engagement within Alternative Response.
Recommendation: Enhance the tracking system for Alternative Response to better analyze outcomes in Alternative Response cases.
Recommendation: DHHS should develop a comprehensive health care management plan for state wards.
Fiscal Year Updates:
DHHS agreed to develop a “Healthcare Management Plan”, noting the development may be new or an enhancement to existing systems, processes or case management documentation.
No update was received for fiscal year 2023-2024.
In fall 2025, CFS will begin internalizing the support of all relative and kinship foster homes utilizing an FFPSA evidenced based support model - Arizona Kinship Navigator Program. This model includes a Navigation plan and increased support, including documentation of services offered/provided. CFS has also partnered with the Medicaid MCOs to ensure that the medical needs of state wards are met.
Recommendation: The Department of Health and Human Services Division of Children and Family Services should actively participate in the State Suicide Prevention Coalition
Fiscal Year Updates:
New recommendation. In beginning stages of collaboration with DBH and community.
Camas Holder is the CFS representative currently attending quarterly meetings with the Suicide Prevention Coalition.
DHHS indicated that this recommendation has been operationalized.
Recommendation: The Department of Health and Human Services Division of Children and Family Services should provide suicide prevention content and required gatekeeper training to foster care providers
Fiscal Year Updates:
New recommendation. In beginning stages of collaboration with DBH and community.
The 2023 and 2024 agency-supported foster care contracts require agencies to ensure foster parents are trained in suicide prevention. DHHS supported homes are also required to complete suicide prevention training.
DHHS indicated that this recommendation has been operationalized.
Recommendation: The Department of Health and Human Services Division of Children and Family Services should standardize training requirements for Child Placing Agencies
Fiscal Year Updates:
New recommendation. In beginning stages of collaboration with DBH and community.
The 2023 and 2024 agency-supported foster care contracts require agencies to ensure foster parents are trained in suicide prevention. DHHS supported homes are also required to complete suicide prevention training.
DHHS indicated that this recommendation has been operationalized.
Recommendation: The Department of Health and Human Services Division of Children and Family Services should mandate gatekeeper training for all staff
Fiscal Year Updates:
New recommendation. In beginning stages of collaboration with DBH and community.
Suicide Prevention training is currently part of the ongoing training plan for case managers. A new training plan and model will be launched in 2025 and will include mandatory suicide prevention training.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Develop dedicated suicide prevention policy and procedure
Fiscal Year Updates:
New recommendation. In beginning stages of collaboration with DBH and community.
CFS is in the process of developing a clinical team and youth with behavioral and mental health needs including self-harm or suicide attempts will be referred to the clinical team for additional support and assessment. The clinical team will also be reviewing youth identified as having high behavioral and mental health needs regardless of history of suicide or self-harm and this will provide additional review and support for youth at higher risk.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Develop a comprehensive suicide prevention plan
Fiscal Year Updates:
New recommendation. In beginning stages of collaboration with DBH and community.
A suicide prevention plan was developed in collaboration with DBH, the Kim Foundation and the Suicide Prevention Coalition. The plan can be found online at: https://sprc.org/wp-content/uploads/2022/11/Nebraska-Statewide-Suicide-Prevention-Plan-2022-2025.pdf.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Review current policy, procedure and contract language with providers to assure the expectations for communicating concerns about foster homes is done in a timely manner
Fiscal Year Updates:
Language has been clarified in contracts and continues to be a topic of discussion in statewide provider meetings and contract management discussions.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Review and revise its policies and procedures to create a method to verify that the overfill process has been followed by the Division of Children and Family Services and licensed Child Placing Agencies and to ensure ongoing quality assurance and accountability in that process
Fiscal Year Updates:
New recommendation and the planning process to address is currently underway
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: DHHS should end the Eastern Service Area Pilot Project.
Fiscal Year Updates:
In December 2021 there was mutual agreement between DHHS and Saint Francis to terminate the contract effective June 30, 2022. LB 1173 also included language in statute to no longer allow for privatization.
ESA pilot project ended through the termination of the Saint Francis contract in 2022.
DHHS indicated that this recommendation has been operationalized.
Recommendation: DHHS should terminate the current Eastern Service Area contract with Saint Francis.
Fiscal Year Updates:
In December 2021 there was mutual agreement between DHHS and Saint Francis to terminate the contract effective June 30, 2022. LB 1173 also included language in statute to no longer allow for privatization.
ESA pilot project ended through the termination of the Saint Francis contract in 2022.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Conduct a work study of Child Protective Services (CPS) Supervisors.
Fiscal Year Updates:
DHHS Administration held individual town hall style meetings within each service area which included receiving feedback from supervisors, and continues to assess the current supervisor culture with quarterly and bi-monthly meetings.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Provide educational and community resource referral material to the family during every Initial Assessment and require documentation of what materials or referrals were provided.
Fiscal Year Updates:
Protection and Safety now has a landing page with a collection of community resource links from across the state. The public page is organized by subject and service area. An email was sent to staff about the landing page and where community referrals should be documented in NFOCUS. Workers can access information about the page in an Initial Assessement Narrative Guide in the CFSS Standard Work Instruction Resource Library. DHHS indicated that workers are having conversations with parents about the information source and how to utilize it.
CFS teams now has space and time in local offices. Economic Assistance Point of Contact staff are identified for all local P&S offices. Prevention newsletter created monthly to share resources as well as monthly case manager update email from central office with new resources.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Provide training and tools for workers and supervisors to better evaluate drug/alcohol use to ascertain whether caregive substance use is affecting the safety of the child.
Fiscal Year Updates:
DHHS has requested drug testing information from other states and is conducting a cross walk of that information to better assess practices across the country. DHHS Central Office staff have met with staff from the Division of Behavioral Health to elicit guidance and expertise regarding the use of drug testing. CFS also purchased Drug ID posters and 2020 Street Drug ID Desk Reference Guides for every CFS Lead Worker, Supervisor and Administrator to allow field staff to be able to safety plan for a child while gathering additional information.
CFS continues to work with DHHS divisions and stakeholders on process and policy around drug testing and ensure safety of children when a parent is in active recovery. Drug testing continues to be a service contract and reference guides continue to be made available to lead workers, supervisors and administrators.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Enhance policy and tools specific to the examination of secondary caregivers in an investigation.
Fiscal Year Updates:
DHHS created a Standard Work Instruction for Initial Assessesment which directs workers to include information from the secondary caregiver, if a secondary caregiver is identified, in the Risk Assessment narrative; the Standard Work Instruction also added language regarding the non-custodial parent when there ar no allegations. Additionally, a micro-training was developed to help workers be able to correctly identify households along with primary and secondary caregivers. These efforts did not specifically include ehancing policy and tools specific to the examination of secondary caregivers during an investigation. Substantive policy and tools that assist workers in the assessment of secondary caregivers has not yet been added to the investigative process.
No Changes during Fiscal Year
The new SAFE Model currently in development allows for the assessment of all caregivers in the home weighted equally. Field Guidance was also provided to staff effective 12/1/2023, advising that documentation expectations in the risk assessment have been modified to reflect: Information must be documented as it pertains to the parent/caregivers: Cultural identity and Physical Health.
DHHS indicated that this recommendation has been operationalized.
OIG Note: These efforts did not include enhancing policy and tools specific to the examination of secondary caregivers during an investigation. Substantive policy and tools that assist workers in the assessment of secondary caregivers has not yet been added to the investigative process.
Recommendation: Develop specific non-court evaluation criteria to help caseworkers and supervisors determine when a non-court case should be referred to the multi-disciplinary (1184) team and/or county attorney for review, and require formal training for supervisors to ensure they can assist caseworkers in making referral decisions.
Fiscal Year Updates:
DHHS created a Standard Work Instruction “Ongoing Case Management” which includes direction regarding the case management of non-court cases. It states the worker and their supervisor will collaborate to determine if a referral for the LB 1184 for review and/or a referral to the County Attorney’s office is necessary. DHHS created a Standard Work Instruction, “1184 Team Meetings” to provide guidance to staff regarding when, how and what types of cases are to be referred for 1184 team review. It also includes a flowchart to follow regarding referrals and a template to be used when making a referral and attending 1184 team meetings.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Change DHHS policy to include a mandatory consultation with the county attorney to evaluate the progress of a non-court case no less than 60 days after opening.
Fiscal Year Updates:
DHHS created a Standard Work Instruction, “Mandatory Consultation Points” which clarifies that a consultation point is required when there continues to be an active safety threat in a non-court case, no less than 60 days after opening. Workers are required to document their consultation regarding any staffing with the County Attorney regarding a non-court case with an active safety threat which has been open less than 60 days. A new Quality Assurance Review was implemented in July 2020 to determine adherence to this policy change. The review looks at active non-court cases with a duration of >60 days and an identified safety threat. This new review will be conducted bi-annually. At least 100 cases will be selected for review each review period. A report with review results and recommendations will be posted on the internally and shared with Administrators, supervisors and staff, within the month following the completion of the reviews.
DHHS created a Standard Work Instruction, “Mandatory Consultation Points” which clarifies that a consultation point is required when there continues to be an active safety threat in a non-court case, no less than 60 days after opening. Workers are required to document their consultation regarding any staffing with the County Attorney regarding a non-court case with an active safety threat which has been open less than 60 days. A new Quality Assurance Review was implemented in July 2020 to determine adherence to this policy change. The review looks at active non-court cases with a duration of >60 days and an identified safety threat. This new review will be conducted bi-annually. At least 100 cases will be selected for review each review period. A report with review results and recommendations will be posted on the internally and shared with Administrators, supervisors and staff, within the month following the completion of the reviews. DHHS has indicated there are no plans to further address this recommendation.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
OIG Note: DHHS has indicated there are no plans to further address this recommendation. The OIG does not agree that when applied to non-court cases, consultations should only occur when there is an active safety threat.
Recommendation: Create a handout/brochure to be provided to the family at the time the non-court case is offered.
Fiscal Year Updates:
A brochure has been created for families who are participating in a non-court case and is waiting on final draft approval and printing. The brochure will be stored within CFS offices for CFS staff to disseminate to the families who are involved in a non-court case.
A brochure has been created for families who are participating in a non-court case and is waiting on final draft approval and printing. The brochure will be stored within CFS offices for CFS staff to disseminate to the families who are involved in a non-court case. The brochures were printed and provided to CFS offices in September 2020. Local offices will be responsible for printing additional copies as needed.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Create non-court case policy establishing that participating in a non-court Case requires the following: Parents sign a release of information for all related medical/mental health providers specific to obtaining collateral information and assessing progress on case plan goals, Parents allow contact between the worker and their children, without caregivers present, and Parents must formally agree to participate in recommended services.
Fiscal Year Updates:
DHHS rescinded Protection and Safety Procedure #34-2016. DHHS created Standard Work Instruction, “Ongoing Case Management” that includes the case management of “non-court” cases when there is an active safety threat and/or the risk level is determined to be “high” or “very high”. Parents/caregivers will be required to sign a Release of Information form for all related medical/mental health providers for the purpose of gathering collateral information and assessing progress on the case plan/foster care prevention plan goals; allow contact between the worker and the child(ren), without the caregivers present, and; must formally agree to participate in the recommended services. Record of this formal agreement will be documented within the Foster Care Prevention Plan.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Create a policy or training to address when the alleged perpetrator or involved caregiver(s) of the named child victim has extensive and/or specific knowledge of the Nebraska child welfare system.
Fiscal Year Updates:
DHHS will conduct quality assessments and utilize supervisory consultation specifically in cases in which an alleged perpetrator is well versed in the child welfare, law enforcement, or legal settings. DHHS will be conducting a series of trainings regarding this recommendation.
A series of Lunch and Learn sessions were held for CFS supervisors and adminstrators to discuss cases that involve child welfare savvy individuals. Training centered on the skill level of a worker who should be assigned to such cases, and the use of supervisor consultations for quality oversight. A training session of the Case Staffing Model was conducted which focused on the supervisor's role in facilitating case staffings when. A Standard Work Instruction was developed for Hotline reports involving DHHS employees. The actions of DHHS to complete this recommendation are aknowledge. Training and policy should be provided at the worker level, and should address child welfare savvy individuals who are not current DHHS employees.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
OIG Note: To date the training has not involved workers or specific actions a caseworker might take in these situations. Training and policy should be provided at the worker level, and should address child welfare savvy individuals who are not current DHHS employees.
Recommendation: Implement trauma informed support for workers experiencing the serious injury or death of a child on their case load above and beyond the Employee Assistance Program offered to all persons working for the State of Nebraska.
Fiscal Year Updates:
DHHS is engaging in a partnership with the Quality Improvement Center for Workforce Development (QIC-WD). QIC-WD interventions will focus on addressing Secondary Traumatic Stress (STS) among CFSS and supervisors. DHHS has implemented the CFS Strong program which includes curricula to address on-going and acute traumatic events.
DHHS engaged in a partnership with the Quality Improvement Center for Workforce Development (QIC-WD) to identify interventions that focus on addressing Secondary Traumatic Stress (STS) among CFSS and supervisors. DHHS has implemented the CFS Strong program which includes curricula to address on-going and acute traumatic events with Resilience Alliance , Peer Support, and Restoring Resiliency Response sessions.
Restoring Resiliency Response was implemented statewide October 2022. The goal of RRR is to reduce participant’s stress reactions and increase resiliency following a critical incident in order to continue to effectively help families and remain in their role.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Require SDM logic refresher training for caseworkers and supervisors every 12 to 18 months.
Fiscal Year Updates:
DHHS notes that any worker or supervisor can request a refresher of the Initial Assessment or Ongoing training which includes the SDM modules. They state that they are planning to take the following actions in response to this recommendation: obtain data on SDM as well as other topics to identify areas needing improvement; create a survey for front line staff to obtain information on training topics related to SDM; and, create a survey for supervisors on training needs identified for staff as well at the supervisor role. The surveys were sent out and analyzed in July 2020. A finalized plan for training needs for SDM is expected to be complete September 2020.
SDM micro-learning units have been developed by CCFL Trainers while the training is directly provided to workers by supervisors. DHHS reported that Micro-learning units are delivered monthly, however, the monthly units may not always be specific SDM training.
8 SDM refreshers were created for vaious SDM topics/assessments. These can be utilized at any time there is a need
DHHS is working with Action for the Protection of Children to Implement the Safe Model. Statewide training will be conducted with the roll out of this new Model.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Include the following factors to when a mandatory supervisor consultation is required: when a parent has voluntarily relinquished their parental rights, and when there is a CPS case closure due to reunification with a non-custodial parent.
Fiscal Year Updates:
DHHS created Standard Work Instruction, “Mandatory Consultation Points”, in July 2020 which clarifies the required consultation when a parent has voluntarily relinquished their parental rights as well as direction to staff to conduct a mandatory consultation with their supervisor when a CFS case closes due to reunification with the non-custodial parent. DHHS also created Standard Work Instruction “Non-Custodial Parents Identification and Engagement” in July 2020 specifically outlines the required steps to be taken prior to case closure with a non-custodial parent, which includes staffing the closure with the CFS Supervisor.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Clarify the definition of “change in circumstance” as found in current policy and procedure to include pregnancy and the birth of a baby, specific timelines and guidance as to what assessments should be completed due to a change in circumstances.
Fiscal Year Updates:
DHHS created Standard Work Instruction, “Initial Assessment” that includes language specific to the birth of baby in July 2020. The language states that additional safety assessments are required when there is a change in family conditions including when a new baby is born. The response time is set as a priority 2, unless a more immediate response is required.
CFS has implemented a change from Standard Work Instructions to Standard Operating Procedures (SOP) all SWIs will be converted and reviewed for any necessary updates through this process. The Initial Assessment SOP will be updated and revised as part of this process.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Develop Policy and Procedure for workers addressing pregnancy/birth with parents involved with the Division of Children and Family Services.
Fiscal Year Updates:
No relevant action taken to address the recommendation.
DHHS developed two Quick Tips for system involved Pregnacy and Newborns and sent them to all CFS Specialists, Supervisors, Lead Workers, and Administrators. Assessing Pregnacy and Newborns includes what the worker should do and information that should be shared when they have information that a system involved parent or teen is pregnant. Pregnancy or Newborn Planning provides information on discussion and planning that needs to occur with the family, their safety networks, GAL, CASA, and Tribal Representative when there is a pending or new birth to ensure the safety of the newborn and any children in the home or who there is a plan to reunify. A Standard Work Instruction became effective in August 2020 that provides guidance for workers reguarding a contract between DHHS and Nebraska Children's Home Society for Options Education. This service provides parents or parents to be, with information and education about the different permancy options and legal ways to achieve permanency for their child. A family can be referred for this service at any time while they are system involved. Standard Work Instructions were updated to include guidance on Safety Assessements and Safety Plans when a new baby is born.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Create a policy regarding placement disruption plans with specific reference to where they should be located and found on N-FOCUS.
Fiscal Year Updates:
DHHS created Standard Work Instruction, “Participating in a Case Staffing with Managed Care Organizations” that addresses the assessment and well-being needs of youth in care in conjunction with placement, services and support needs. DHHS created Standard Work Instruction, “Foster Home Placement Disruption and Foster Home Hold and Review Process” to specify where to document and locate placement disruption plans within NFOCUS.
CFS has implemented a change from Standard Work Instructions to Standard Operating Procedures (SOP) all SWIs will be converted and reviewed for any necessary updates through this process. The Participating in a Case Staffing with Managed Care Organizations will be updated and revised as part of this process.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Clarify DHHS policy by adding specific processes to address how and when foster placement HOLDS with no timeframes are lifted.
Fiscal Year Updates:
DHHS created Standard Work Instruction, “Foster Home Placement Disruption and Foster Home Hold and Review Process”, that outlines the process for workers in the field. The new procedure was finalized in August 2020.
CFS has implemented a change from Standard Work Instructions to Standard Operating Procedures (SOP) all SWIs will be converted and reviewed for any necessary updates through this process. The Foster Home Placement Disruption and Foster Home Hold and Review Process will be updated and revised as part of this process.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Include a component on child sexual abuse prevention in foster and adoptive parent training.
Fiscal Year Updates:
The training that Project Harmony is implementing will also be utilized in foster and adoptive parent training. See 18-11.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Strengthen foster care licensing to remove inappropriate and unsuitable homes.
Fiscal Year Updates:
DHHS enhanced the application process for foster parenting to better screen foster homes, and DHHS issued an RFP for home studies in order to improve the process. DHHS made modifications to regulations, which are presently in the promulgation process, to comply with more stringent foster care, adoptive, and guardianship model licensing standards. When currently licensed foster parents apply to renew their license, they will have to be in compliance with the new requirements—complete the updated application, home study, compliance checklist, and the like. Those not in compliance with the new regulations no longer remain as a licensed foster parent.
No Changes during Fiscal Year
395 NAC 3 finalized.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Improve and formalize quality assurance procedures for all foster, adoptive, and guardianship placements.
Fiscal Year Updates:
DHHS has revised contracts with child-placing agencies to better align caregiver and child needs. Specific training for foster parents will be provided based on the specific child’s needs. A request for proposals has been developed for resource families. The family’s voice and choice is being incorporated into these revisions. Caseworkers are utilizing Safety Organized Practice across the state. Many of these strategies are incorporated into Nebraska’s performance improvement plan (PIP).
No Changes during Fiscal Year
Critical Incidence/Quality assurance review are completed for youth placed in out of home care with intakes received and ials received involving sexual abuse. Review results are utilized to identify program strengths and areas needing improvement.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Review and revise training on child sexual abuse for DHHS staff.
Fiscal Year Updates:
DHHS has contracted with Project Harmony to implement the training. See 18-11.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Adopt specific protocols on providing children developmentally-appropriate education to prevent sexual abuse and exploitation.
Fiscal Year Updates:
DHHS contracted with Project Harmony to develop the curriculum for developmentally-appropriate education to prevent sexual abuse and exploitation within the child welfare system. A 3-module training was developed: 1. Darkness to Light 2. Sexual Health, Behaviors, and Abuse of Children 3. Bringing it Home: Managing Sexual Abuse and Behaviors.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Meet the statutorily required caseload standard for initial assessment and ongoing case management.
Fiscal Year Updates:
DHHS reports indicate that during FY 19-20, the average of caseload conformity was about 80%. DHHS continues to be out of compliance with statutorily required caseload standards. DHHS believes that due to a low turnover rate, open positions will decrease, time needed to fill vacancies will decrease, and as a result of this, more case managers will be eligible to carry full caseloads, thus compliance with the caseload mandate will improve. A monthly caseload report can be found on their website.
DHHS reports indicate that during FY 20-21, the average of caseload conformity for Initial Assessment and Ongoing was about 71%. DHHS continues to be out of compliance with statutorily required caseload standards. DHHS is addressing the lack of compliance with the law by focusing on filling open positions. There are weekly meetings between CFS leadership and HR to discuss vacancies, applicants, offer letters, as well as, recruitment efforts to fill all vacancies. Once a position is filled the New Worker Training has been shortened to allow for IA workers to start in the field after six weeks of traning and ongoing workes to start after nine weeks; the remaining training modules are completed with in three months of the initial training phase. Once all vacancies are able to be filled, there is a draft
Weekly monitoring of caseload compliance continues across each Region and while we have not reached 100% compliance, we have seen drastic improvements and statewide we are averaging 70-73% compliance.
Weekly monitoring of caseload compliance continues across each Region and while we have not reached 100% compliance, we have seen drastic improvements and statewide we are averaging over 80% compliance. In June of 2024, IA only caseloads were 97.8% in compliance.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Review, modify, and enforce process for gathering information and making findings in law enforcement only cases.
Fiscal Year Updates:
DHHS has transferred the responsibility for entering findings to the Hotline for investigations conducted by law enforcement only. (Program Memo #33-2017). In May 2018, Hotline staff began addressing the backlog of law enforcement cases where no findings had been made. DHHS reports that data on outstanding law enforcement investigations is being gathered/tracked. FY 19-20: DHHS has rescinded Program Memo #33-2017 and created a Standard Work Instruction, “Monitoring of Law Enforcement Only Intakes by Hotline” effective December 2019.
No Changes during Fiscal Year
Law Enforcement Only intakes no longer require DHHS to make a finding. Duty falls to Law Enforcement or County Attorney to provide adequate information to make a finding. Finding is entered as LE ONLY until supporting documentation is provided to make a different designation.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Adhere to policy on out of home assessments and enhance quality assurance.
Fiscal Year Updates:
DHHS has created Standard Work Instruction “DHHS Facility Investigations” that details how investigations will be completed for facilities managed by DHHS effective October 2019. DHHS has an Out of Home Assessment policy for facilities that are not managed by DHHS effective November 2017. DHHS also created a Standard Work Instruction, “Facility Assessments-Out of Home Assessment Team” effective August 2020.DHHS plans to implement a QA process for out of home assessments.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Provide additional guidelines on meeting the preponderance of the evidence burden of proof for agency substantiation in child sexual abuse cases.
Fiscal Year Updates:
DHHS reports that a curriculum has been developed on the preponderance of the evidence standard. Trainings for all supervisors occurred across the state beginning in April 2018.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Create a process to fulfill DHHS’s statutory obligation to assess for risk of harm and provide necessary and appropriate services for reports of child sexual abuse cases referred for law enforcement investigation alone.
Fiscal Year Updates:
DHHS reports that this is already occurring, based on assessments and referrals that take place at the Hotline. Hotline staff will connect families to other hotlines and the CACs when appropriate. DHHS has implemented a voluntary FAST program where families with screened out cases receive a letter asking if they want to be connected to economic assistance programs. All referrals through the FAST program are documented on NFOCUS.
No Changes during Fiscal Year
FAST Program no longer exists.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Ensure all allegations meeting the DHHS definition of child sexual abuse are investigated by DHHS or law enforcement.
Fiscal Year Updates:
DHHS has created a new finding: Law Enforcement Refusal, which indicates that law enforcement is choosing to not investigate the allegation. In these cases, DHHS is not investigating the allegations either. This change in Hotline protocol has been implemented statewide. Staff at the Hotline continue to reach out to law enforcement. The Hotline Administrator has met with law enforcement across the state about the importance of communicating these investigatory conclusions with the Hotline.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Enhance training on sexual abuse, especially the dynamics of youth abusing other youth, for Hotline staff.
Fiscal Year Updates:
DHHS contracted with Project Harmony to create three modules related to preventing and educating about the sexual abuse of children.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Review the option of eliminating overrides to not accept a sexual abuse report for investigation at the Hotline, except in the case of law enforcement only investigations.
Fiscal Year Updates:
DHHS reports that the Hotline Administrator reviewed the intake process, and QA staff put together data to analyze this practice. The Hotline's use of overrides to change screening decisions are reviewed to ensure appropriate use of policy and discretionary overrides. At the time of completion over 1700 intakes that had been reviewed by the CFS Central Office staff, no sexual abuse reports have been overridden to not accept.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: End the practice of screening "Law Enforcement" reports as “Does Not Meet Definition” when the allegation continues to meet DHHS’s definition of child sexual abuse.
Fiscal Year Updates:
At the time of completion DHHS reported that CFS Central Office Administrators and other staff review every “Does Not Meet Definition” screen. DHHS analyzed reasons why intakes were being re-screened and adopted definitions. The CQI team was performing qualitative reviews to determine whether intakes, including sexual abuse allegation intakes, were following proper practice and policy.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Create a system to collect and review information about allegations of sexual abuse of children and youth served by CFS’s child welfare and juvenile justice programs.
Fiscal Year Updates:
LB 1078 was signed by the Governor on April 4, 2018, requiring reporting of information on sexual abuse allegations. DHHS has created a new Critical Incident Reporting form accordingly. The form will be utilized statewide by September 2019.
IS&T is working to automate these reports; however, in the interim reports are being provided to the OIG.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: The Division of Developmental Disabilities should coordinate with Juvenile Probation to improve care to youth with developmental disabilities in the juvenile justice system.
Fiscal Year Updates:
DD developed and disseminated a handout for probation officers and court stakeholders providing details on the Home and Community Based Waivers available to people with disabilities, presented a training at the Nebraska Juvenile Justice Association Conference, attended weekly system collaboration meetings with Probation, and deployed clinical staff to assess youth committed to YRTCs for service eligibility.
No Changes during Fiscal Year
Probation has taken the lead while CFS, MLTC, MCOs, DBH and other community stakeholders have all been participating in an Access to Services workgroup. DHHS/CFS continues to participate in, schedule, and moderate ongoing child-specific staffings with MLTC, MCOs, DD, and Probation (when applicable) to all collaborate. The DD clinical team has been assisting CFS with aligning DD eligible youths with the correct level level of care and services to meet their individual needs, which include youth involved in the juvenile justice system.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Increase training and coordination between the Division of Children and Family Services and the Division of Developmental Disabilities.
Fiscal Year Updates:
At the time of completion both CFS and DD participated in the Cross Divisions Solution Team. In 2017, DD helped provide information and feedback on CFS New Worker Training and developed a PowerPoint on available services for CFS staff.
DHHS/CFS is developing a Resource Guide that will encompass any DD specific tools, quick tips, or guidance prevoiusly created in one central location for DHHS/CFS staff to use. DHHS/CFS participates in, schedules, and moderates ongoing child specific staffings where Medicaid, CFS, and DD all participate and collaborate. DHHS/CFS also participates in a monthly meeting to discuss ongoing issues/barriers and general topics between the DHHS divisions of Medicaid, DD, and CFS.
CFS created another one document for field staff regarding youth involved with DD and CFS (last updated Feb 2024). The CFS’ Well-Being team hosted a Learning Lab for CFS staff in February 2024 about the Division of Developmental Disabilities. Probation has taken the lead while CFS, MLTC, MCOs, DBH and other community stakeholders have all been participating in an Access to Services workgroup. CFS continues to participate in, schedule, and moderate ongoing child-specific staffings with MLTC, MCOs, and DD to all collaborate. The DD clinical team has been assisting CFS with aligning DD eligible youth with the correct level of care and services to meet their individual needs.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Adopt policy on joint case management and case planning when a youth is involved with both the child welfare and juvenile justice system.
Fiscal Year Updates:
DHHS has issued Administrative Memo 1-2018, Crossover Youth Practice Model, and, with Probation, presented the Statewide Crossover Youth Initiative Training to all case managers and juvenile probation officers. FY 19-20: DHHS has rescinded Protection and Safety Procedure #1-2018 and created a Standard Work Instruction on “Crossover Youth Practice Model” effective November 12, 2019.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Enhance efforts to reduce caseworker turnover.
Fiscal Year Updates:
At the time of completion DHHS made changes to job recruitment strategies, revisions to New Worker Training to make it more accessible and less travel-intensive to complete. In July 2017, DHHS initiated a supervisor training program to better ensure caseworkers are supported.
The turnover rate year over year continues to decrease and comparative to national turnover data, Nebraska is doing really well.
Turnover data has stabilized over the last year and continues to be well within national averages.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Adopt federally mandated policies and procedures on mental and behavioral health care as soon as possible.
Fiscal Year Updates:
See Recommendation 15-01
No Changes during Fiscal Year
CFS is currently updating assessments to the SAFE model and will be phasing out the use of SDM. No additional changes.
LB217 was signed by the Governor on June 4, 2025, requiring suicide awareness and prevention training for child welfare workers, for certain licensure, and for employees of child-placing agencies. Public Health is working with Children and Family Services to coordinate training requirements and establish approved training.
Recommendation: Restructure the Children’s Justice Act (CJA) taskforce to ensure there is a working group focused on improving child abuse investigations, especially multidisciplinary investigations. Enhance monitoring on how CJA funds are spent to ensure they are addressing systemic gaps in child abuse investigations.
Fiscal Year Updates:
DHHS is developing a process to improve monitoring of CJA funds. In July 2016, CJA billing was modified to an expense reimbursement document, which will require those receiving funds to provide documentation on how the funds were spent. A new contract for CJA funds with additional requirements is planned to go into effect in October 2017. The Nebraska Commission for the Protection of Children created a subcommittee to study improvements to multidisciplinary teams.
CJA taskforce Proposal Guidance was created to ensure that all projects are directly tied to the Three Year Assessment. Recommendations vary based on the Taskforce's focus. The addition of the Alliance for ongoing administrative support, ensures that the strategic plan is updated on a quarterly basis.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Collect data on high and very-high risk cases that do not accept services and implement better, more promising approaches to family engagement.
Fiscal Year Updates:
DHHS has collected data on high/very-high risk families declining services and has seen a slight increase in the acceptance of services. DHHS has implemented Safety Organizing Practice (SOP), a family engagement model, over the past 6-12 months. This is part of the CFS Program Improvement Plan (PIP) under Family Engagement. DHHS is developing a process to improve monitoring of CJA funds. In July 2016, CJA billing was modified to an expense reimbursement document, which will require those receiving funds to provide documentation on how the funds were spent. A new contract for CJA funds with additional requirements is planned to go into effect in October 2017. The Nebraska Commission for the Protection of Children created a subcommittee to study improvements to multidisciplinary teams.
SDM Risk Assessment has been revised to ensure better accuracy, equity, utility and consistency in its use. Additional options have provided to staff to ensure critical thining around service delivery
DHHS is working with Action for the Protection of Children to Implement the Safe Model. This model focuses on the child safety and enhancement of protective capacities. As safety factors are identified risk is increased, as protective capacities are enhanced risk is reduced.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Enhance data available on Initial Assessment and mixed caseloads at Central Office and make this information publically available on a monthly basis.
Fiscal Year Updates:
DHHS has developed a monthly report on CWLA caseload compliance, including initial assessment and mixed caseloads. An overall report is posted publicly on their website and updated monthly.
No Changes during Fiscal Year
Caseload reports continue to be generated monthly and posted on the DHHS website.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Increase the number of supervisors at the Child Abuse and Neglect Hotline and assess Hotline workload and ongoing training and supervision.
Fiscal Year Updates:
DHHS added a supervisor position to the Hotline and placed 3 CFOM positions at the Hotline to review screened out reports to ensure appropriate screening decisions occurred. Supervisors review all screened out reports and listen in on calls. A new process has been set up so that quality assurance staff review accepted intakes that the field wants re-screened. Hotline processes have been reviewed through the Lean Six Sigma process to improve performance. An additional staff member was also added to the Hotline to take calls. If an intake is not accepted for initial assessment, all referrals are now tracked. All CFSS trainees will begin to shadow at the Hotline.
Since the last update, 2 additional teams have been added to the Hotline as well as the creation of a Deputy Hotline Administrator role and we have submitted a request to reclass a vacant position at the Hotline into a Lead Worker position to allow for additional support and guidance to Hotline teammates.
A lead worker was added to the Hotline through the reclassification process. There are currently two lead workers who will be providing trainging and support to the Hotline. Hotline staffing is evaluated ongoing on a quarterly basis and adjustments are made according to the results.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Increase the capacity for the CFS workforce to participate in pediatric abusive head trauma prevention efforts.
Fiscal Year Updates:
In April 2016, CFS Central Office distributed an “Under 2” packet, in English and Spanish, designed with input from the Division of Public Health, to field staff. Information about pediatric abusive head trauma is included in the packet. CFS Staff are encouraged to give out the information anytime they assess or work with a family with a very young child.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Contract with an independent entity to perform a validation study of Nebraska’s SDM Risk Assessment instrument.
Fiscal Year Updates:
DHHS contracted with the National Council on Crime and Delinquency to conduct independent case reads on SDM safety and risk assessments. The results of the case reads were fairly positive. However, this was not a validation study. There is still no research demonstrating whether Nebraska’s SDM tool is accurately predicting risk or not and whether adjustments to the tool may need to be made.
Validation has been completed and revisions to the tool have been made. Training planning and integration into NFOCUS is currently in progress.
DHHS has decided to move away from SDM Model and is working to implement the SAFE Model.
DHHS indicated that this recommendation has been operationalized.
OIG Note: The OIG anticipates reclassifying this recommendation as complete once the report is provided to this office for review.
Recommendation: Take steps toward greater Initial Assessment workforce specialization and experience.
Fiscal Year Updates:
DHHS reports that it is not possible to specialize the Initial Assessment (IA) workforce in many rural parts of the state. DHHS has enhanced training for workers assigned to Initial Assessment, held internal discussions about additional CFS paygrades, and made adjustments to team composition such as end-to-end teams and allowing IA partnering caseloads between two workers.
DHHS continues to explores way in which we can create specializations based on a tiered approach in conjunction with HR.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Increase the Initial Assessment workforce to comply with Nebraska law on caseload standards.
Fiscal Year Updates:
The Initial Assessment workforce has averaged at a rate of about 93% compliance with caseload standards. The DHHS caseload initiative (whereby caseloads are counted by the number of children as opposed to number of families, and worker skill level is incorporated) has not resulted in a proposed change to statutory caseload requirement language during the 2020 Legislative Session, as was projected by DHHS in 2019.
The Initial Assessment workforce has averaged at a rate of about 84% compliance with caseload standards for FY 20-21. DHHS indicated that during FY 20-21 the caseload initiative (whereby caseloads are counted by the number of children as opposed to number of families, and worker skill level is incorporated) was identified as no longer being a legislative priority.
Weekly monitoring of caseload compliance continues across each Region and while we have not reached 100% compliance, we have seen drastic improvements and statewide we are averaging 70-73% compliance.
Weekly monitoring of caseload compliance continues across each Region and we have nearly reached 100% compliance. In June of 2024, IA only caseloads were 97.8% in compliance statewide.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Expand quality assurance and continuous quality improvement (CQI) at the Hotline.
Fiscal Year Updates:
At the time of completion quality assurance efforts included DHHS reviewing additional Hotline calls related to physical abuse allegations of children under 7 on a quarterly basis.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Conduct an analysis to determine whether supervisory staffing at the Hotline is adequate.
Fiscal Year Updates:
In September 2016, new guidelines for supervisory review of intakes (calls to the Hotline) went into effect, reducing the percentage Supervisors had to review and extending the timeframe for them to complete reviews. However, these changes were implemented without an analysis of supervisory staffing and a review of all of their responsibilities. In 2017, DHHS added a supervisor position at the Hotline and refocused supervisors on reviewing accepted reports. CFOMs were also transferred to the Hotline and now review screened out reports.
Since the last update, 2 additional teams have been added to the Hotline as well as the creation of a Deputy Hotline Administrator role and we have submitted a request to reclass a vacant position at the Hotline into a Lead Worker position to allow for additional support and guidance to Hotline teammates.
A lead worker was added to the Hotline through the reclassification process. There are currently two lead workers who will be providing trainging and support to the Hotline.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Update and provide additional detail on response priority definitions.
Fiscal Year Updates:
DHHS updated its intake manual in August 2017 in Protection and Safety Update #26-2017. The updated manual provides clarification on priority response time definitions involving injuries to children under age six. FY 19-20: DHHS updated the intake manual in October 2019.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Further define process for utilizing child advocacy centers by Initial Assessment.
Fiscal Year Updates:
After consulting with DHHS legal staff on expanding requirements on the use of Child Advocacy Centers, DHHS decided not to update the current memo to add additional cases that should be considered for a CAC interview. Instead this decision will be left to local 1184 or multidisciplinary teams. DHHS indicated they did not believe the burden for referral should be on DHHS staff alone. DHHS issued a revised memo on use of CACs, Protection and Safety Procedure #23-2017, however, none of the OIG’s suggestions were incorporated.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
OIG Note: DHHS indicated they did not believe the burden for referral should be on DHHS staff alone. DHHS issued a revised memo on use of CACs, Protection and Safety Procedure #23-2017, however, none of the OIG’s suggestions were incorporated.
Recommendation: Develop additional training for Initial Assessment staff.
Fiscal Year Updates:
CCFL updated its New Worker Training in 2016 to include a more intensive focus on family engagement. Caseworker in-service training on Enhanced SDM Safety Planning, Engaging Families on Sensitive Subjects, Human Trafficking, Advanced Testifying, and Engaging Families in Safety and Risk Assessments have been developed and are being offered around the state.
Protection and Safety now has a Development and Resiliency Manager as well as 2 training coordinators to handle additional training and learning opportunities not only for IA staff, but all case workers, APS, Hotline and FCRD.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Adopt policy on photographing injuries during Initial Assessment.
Fiscal Year Updates:
In February 2016, DHHS adopted Protection and Safety Procedure #5-2016, "The use of Photographs from Intake through Case Closure."
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Implement training on the medical aspects of child abuse.
Fiscal Year Updates:
CCFL consulted with Dr. Bleicher as a medical expert for curricula review in August and September 2017. The following recommendations were made: • Spiral fractures in toddlers and young children are often activity related but the same fracture in the arms (especially infants) are highly suspicious of abuse. References made to spiral fractures need to be clarified (revision meeting scheduled for 12.05.17) • Incorporate the article Bruising Characteristics Discriminating Physical – help to distinguish accidental from abusive injuries (revision meeting scheduled for 12.05.17). 02/02/18 This training was created and trained for the first time with the November 2017 training group.
No Changes during Fiscal Year
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Clarify Hotline policy and procedure when receiving a report of sexual assault.
Fiscal Year Updates:
The Hotline updated its guidebook and also gave staff direction and reminders on selecting the correct law enforcement agency. The OIG reviewed intakes about YRTC-Geneva for the 2016-17 fiscal year and identified only one error.
No Changes during Fiscal Year
No changes since last update. The process and functionality remain in place.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Assess availability of training, information, and programs designed to prevent child abuse within immigrant communities.
Fiscal Year Updates:
DHHS developed a quarterly report to review information captured by N-FOCUS to develop outreach strategies in immigrant communities. Substantive collaboration between DHHS and Bring Up Nebraska has been developed as means of furthering strategies to collect consistent, statewide data, provide funding, and prioritize culturally appropriate and competent prevention service delivery. In May 2018, DHHS partnered with the Nebraska Coalition to End Sexual and Domestic Violence and funded a Community Engagement Coordinator position to collaborate with local and tribal domestic violence programs and community based organizations to address family violence issues in racial and ethnic minority populations and underserved populations.
CFS continues to fund the Communication/Community Engagement Coordinator at the Coalition. This position uses a social change, anti-oppression, and participatory lens to enhance statewide capacity to support diverse, marginalized, and/or underserved communities. This position collaborates with the Coalition’s network programs and allied organizations to elevate voices of survivors with often marginalized identities and barriers they face. This position will work closely with the Youth Engagement Coordinator to engage voices of youth while assisting with training, technical assistance, outreach to increase awareness of family violence, domestic violence, and dating violence, and to increase the accessibility of services in the state.
No changes during fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Create a protocol for asking for and receiving photos at the Child Abuse and Neglect Hotline.
Fiscal Year Updates:
In February 2016, DHHS adopted Protection and Safety Procedure #5-2016, "The use of Photographs from Intake through Case Closure."
No Changes during Fiscal Year
The OIG did not receive an update on this recommendation for this fiscal year.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Develop and provide training to frequent reporters and law enforcement on reporting to the Child Abuse and Neglect Hotline
Fiscal Year Updates:
In the fall of 2015, the League of Municipalities distributed DVD training modules on child abuse and neglect reporting and investigations to local law enforcement agencies, developed with DHHS assistance. DHHS provides training on child abuse reporting and the hotline to groups on request. No training for other frequent reporters – schools, medical professionals, etc. has been produced or made easily available.
RFP has been drafted and is tentatively set to be released in October 2023. Contractor will develop the manadotry reporter training for key reporters
Prior draft RFP was not executed. The training team is now going to develop this internally.
DHHS indicated that this recommendation has been operationalized.
OIG Note: No training for other frequent reporters – schools, medical professionals, etc. has been produced or made easily available.
Recommendation: Ensure “Absence of Maltreatment in Foster Care” calculation is as accurate as possible.
Fiscal Year Updates:
Since May 2016, DHHS has listed the number of maltreatment cases that have been “court pending” between 8 and 12 months in its CQI reports. This better captures cases of maltreatment that may not be counted in the federal measure because they are awaiting court action, usually because the crime is particularly serious.
No Changes during Fiscal Year
CFS is looking at moving the home study contract to the Master contract as a service attachment in 2025 which will improve our access to providers able to complete home studies across the state.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Provide stronger supports for kinship and relative foster families.
Fiscal Year Updates:
Pre-service foster parent online training is offered to relative and kinship placements in order to get more of such placements licensed. As a foster child’s needs are identified, the relative and kinship foster placement will receive specialized training accordingly. The Nebraska Foster and Adoptive Parent Association provides specialized training, Kinship Connection, across the state. Nebraska received Kinship Navigator funds available through the Family First Prevention Services Act—U.S. Department of Health and Human Services Administration on Children, Youth and Families (ACF) to develop, enhance, or evaluate kinship navigator programs. Implementation of Nebraska’s Kinship Navigator program began October 1, 2019.
CFS offered an incentive for Relative and Kinship Foster families to receive a $2500 stipend for completing the licensing requirements and submitted for licensure within 5 months of taking placement in FY22-23. In addition to the incentive for foster families, CFS also incentivized Agencies to support relative and kinship foster families in the process of becoming licensed with a $3000 quarterly incentive payment for meeting recruiting and licensing standards.
The relative/kinship incentive program has ended and new federal rules allow for separate relative/kinship licensing standards. CFS has made updates to the approval/licensing process to streamline the approach and make it easier for relative/kinship homes to be approved, which allows increased IV-E funding. Relative/kinship homes are required to complete RPPS, Human Trafficking, Sexual Abuse Prevention and Car Seat Training. Agencies supporting relative/kinship homes are also able to provide individualized training based on the needs of each home.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Make improvements to the Home Study Process.
Fiscal Year Updates:
To help ensure quality home studies across the state, DHHS entered into contracts with accredited licensed child-placing agencies in Nebraska to complete all home studies. The contracts began November 2019. An updated home study template and quality assurance tool were developed as part of the process to improve home studies.
No Changes during Fiscal Year
We are starting a work group in the near future that will be a collaboration between DHHS and a couple of providers to look at the home study itself as well as the process. We are also looking at moving the home study contract to the master contract as a service attachment which will improve our access to providers across the state.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Enhance continuous quality improvement and quality assurance processes for mental and behavioral health care, including psychotropic medications.
Fiscal Year Updates:
DHHS updated its N-FOCUS system in March 2015 to allow for easy record keeping on medications, health care appointments, and medical conditions. At the time of completion, information entered was reviewed by administration and at Continuous Quality Improvement (CQI) meetings.
Quality assurance case reviews are conducted on a quarterly basis to monitor the assessment of needs and services to address the child's physical, mental and behavioral health. The reviews includes a review of oversight of the child's prescription medications including psychotropic medications. Review results are utilzed to identify program strengths and areas needing improvement.
Quality assurance case reviews continue to be conducted on a quarterly basis to monitor the assessment of needs and services to address the child's physical, mental and behavioral health. The reviews include a review of oversight of the child's prescription medications including psychotropic medications. Review results are utilized to identify program strengths and areas needing improvement.
No updates to this recommendation were received.
Recommendation: Expand mental health training for DHHS staff and other stakeholder, including medical professionals.
Fiscal Year Updates:
DHHS added in-service training on these topics, and added suicide prevention training to topics covered in New Worker Training. In July 2017, an updated mental health desk aid was made available to all staff.
No Changes during Fiscal Year
No changes during fiscal year.
No updates to this recommendation were received.
Recommendation: Adopt federally mandated policies and procedures on mental and behavioral health care as soon as possible.
Fiscal Year Updates:
In April 2016, DHHS adopted most required policies, including use and oversight of psychotropic medications and guidelines on updating medical information. These have been updated and are currently found in Protection and Safety Procedure #13-2017. DHHS does not plan to adopt a mental health or trauma screening tool. DHHS will use the Family Strengths and Needs Assessment for this purpose. However, there is no guidance given to staff on how this tool can be used as a trauma or mental health screening.
The FSNA tool is still being reviewed for fidelity. Updates to the tool/process are planned upon completion of the fidelity review. The Trauma Screen Tool continues to be utilized in the Adams and Hall County areas as a part of the Through the Eyes of the Child initiative.
CFS is currently updating assessments to the SAFE model and will be phasing out the use of SDM. No additional changes.
In FY 23-24, DHHS indicated they were updating to the SAFE Model and phasing out SDM. The move to the SAFE Model has been paused and no additional updates to this recommendation have been received.
DHHS
Public Health-Licensure
Recommendation: Update the child care regulations to reflect best practice related to the supervision of sleeping infants by child care providers.
Fiscal Year Updates:
LB 717 was signed by the Governor on April 11, 2018, requiring training before a daycare license is granted [Statute 43-2606(3)]. Regulations regarding the change are being formally promulgated. Public Health worked with the Nebraska Department of Education to make the "Safe with You" training more accessible to providers, including in an online format, since it now must be taken prior to a license being granted. Proposed child care regulations will include child care provider requirements related to frequency of checks and documentation of checks of sleeping infants.
No changes during fiscal year.
OIG Note: none
Recommendation: Create specific guidelines for how frequently and in what manner sleeping infants should be checked.
Fiscal Year Updates:
Public Health is following and holding licensees accountable to statute (43-2606). As of January 2023, OCSL is requiring pre-service training for licensees, primary providers, and directors which provides information on sudden unexpected infant death syndrome, abusive head trauma in infants and children, crying plans, and child abuse. OCSL has worked with NDE to ensure that the Safe With You trainings are available for the increased number of providers required to take the pre-service training.
LB 717 was signed by the Governor on April 11, 2018, requiring training before a daycare license is granted [Statute 43-2606(3)]. Regulations regarding the change are being formally promulgated. Public Health worked with the Nebraska Department of Education to make the "Safe with You" training more accessible to providers, including in an online format, since it now must be taken prior to a license being granted. Proposed child care regulations will include child care provider requirements related to frequency of checks and documentation of checks of sleeping infants.
No changes during fiscal year.
OIG Note: As part of FY 20-21 the OIG classified this recommendation as complete based on the revised regulations. Due to developments during FY 21-22, the OIG has reclassified this recommendation from complete to progress. The OIG appreciates that Public Health attempted the promulgation of regulations based on this recommendation, but notes the recommendation was to create guidelines which are now even more critical due to the lack of regulations. As the report illuminated how frequently and in what manner sleeping infants are checked was directly attributed to the death and serious injury of infants.
Recommendation: Require compliance with Department of Justice standards on sexual abuse prevention and response in regulations governing residential child-caring agencies.
Fiscal Year Updates:
Public Health reports reviewing PREA regulations and incorporating some standards into regulations being promulgated.
391 NAC Chapter 7 Residential Child Caring Agency and 391 NAC Chapter 8 Child Placing Agency regulations became effective March 2021.
Public Health reports reviewing PREA regulations and incorporating some standards into regulations.391 NAC Chapter 7 Residential Child Caring Agency and 391 NAC Chapter 8 Child Placing Agency regulations became effective March 2021.
No Changes during Fiscal Year
No changes during fiscal year.
No changes during fiscal year.
Recommendation: Adopt clear internal policy and timelines on tracking, opening, investigating, and taking action on possible violations of statutes and rules and regulations at residential child-caring agencies.
Fiscal Year Updates:
LB 59 was passed into law during the 2019 Legislative Session, which requires that investigatory reports made under the Children’s Residential Facilities and Placing Licensure Act be issued 60 days after the determination is made to conduct the investigation, except that the report may be filed within 90 days if an interim report is filed within 60 days.
LB 59 was passed into law during the 2019 Legislative Session, which requires that investigatory reports made under the Children’s Residential Facilities and Placing Licensure Act be issued 60 days after the determination is made to conduct the investigation, except that the report may be filed within 90 days if an interim report is filed within 60 days. Children's Services Licensing has an internal policy and procedure in place, a tracking mechanism to support investigative efforst and a licensing action guide.
No Changes during Fiscal Year
No changes during fiscal year.
No changes during fiscal year.
Recommendation: Ensure adequate staffing for residential-child caring agency licensing operations.
Fiscal Year Updates:
No relevant action taken to address the recommendation.
Regulations (Title 391, Chapter 7) were made effective 3-22-2021.The Department feels the regulations [005.01 & 005.04(A)] adequately address this recommendation.
There are no changes from last year's update.
No changes during fiscal year.
Recommendation: Increase coordination with the Division of Children and Family Services and Administrative Office of Probation on Residential Child-Caring Agencies.
Fiscal Year Updates:
Public Health has reported sharing information with both CFS and Probation in a more timely way, and, when possible, conducting joint visits of facilities with CFS. Efforts to effectively coordinate are ongoing. DHHS reports that it shares information on licensing actions and has been coordinating effectively on investigations.
Coordination continues with CFS and Probation. Investigation conversations are formally conducted at joint meetings regarding the specified licensee. Children’s Services Licensing shares completed investigations with CFS and Probation when applicable. Efforts to effectively coordinate are ongoing. DHHS reports that it shares i
No Changes during Fiscal Year
No changes during fiscal year.
No changes during fiscal year.
Recommendation: Clarify requirements for consents for medical care, treatment, and coordination for Residential Child-Caring Agencies in regulations.
Fiscal Year Updates:
DHHS draft regulations specify that facilities must adopt policies obtaining consent for medical treatment. The regulations have now entered the formal promulgation process and a public hearing was held in August 2019. DHHS is also planning to develop additional guidance for facilities on how to comply with regulations, while not adding requirements to regulations themselves.
391 NAC Chapter 7 Residential Child Caring Agency and 391 NAC Chapter 8 Child Placing Agency regulations became effective March 2021.
391 NAC Chapter 7 and 8 regulations are implemented. Consents are required at admission into care and must be maintained by the licensee throughout placement of the child.. 391 NAC Chapter 7 Residential Child Caring Agency and 391 NAC Chapter 8 Child Placing Agency regulations became effective March 2021.
No Changes during Fiscal Year
No changes during fiscal year.
No changes during fiscal year.
Recommendation: Adopt clear requirements on medical record-keeping and documentation in regulations.
Fiscal Year Updates:
DHHS draft regulations include record keeping requirements for medications and specify that facilities must adopt policies on medical record-keeping. The regulations have now entered the formal promulgation process, and a public hearing was held in August 2019.
391 NAC Chapter 7 Residential Child Caring Agency and 391 NAC Chapter 8 Child Placing Agency regulations became effective March 2021.
391 NAC Chapter 7 regulations are implemented. As stated in 391 NAC Chapter 7, the Medication Aide Act and 172 NAC 95 and 96 must be followed. 391 NAC Chapter 7 Residential Child Caring Agency and 391 NAC Chapter 8 Child Placing Agency regulations became effective March 2021.
No Changes during Fiscal Year
No changes during fiscal year.
No changes during fiscal year.
Recommendation: Include requirements related to dispensing and monitoring medications, especially psychotropic medications, in new regulations for Residential Child-Caring Agencies.
Fiscal Year Updates:
The regulations have now entered the formal promulgation process, and a public hearing was held in August 2019.
391 NAC Chapter 7 Residential Child Caring Agency and 391 NAC Chapter 8 Child Placing Agency regulations became effective March 2021.
391 NAC Chapter 7 regulations are implemented. As stated in 391 NAC Chapter 7, the Medication Aide Act and 172 NAC 95 and 96 must be followed. 391 NAC Chapter 7 Residential Child Caring Agency and 391 NAC Chapter 8 Child Placing Agency regulations became effective March 2021.
No Changes during Fiscal Year
No changes during fiscal year.
No changes during fiscal year.
Recommendation: Promulgate rules and regulations related to the Children’s Residential Facilities and Placing Licensure Act as soon as possible.
Fiscal Year Updates:
DHHS has had a draft set of regulations with stakeholder input ready for promulgation. These regulations have now entered the formal promulgation process, and a public hearing was held in August 2019.
391 NAC Chapter 7 Residential Child Caring Agency and 391 NAC Chapter 8 Child Placing Agency regulations became effective March 2021.
391 NAC Chapter 7 regulations are implemented. 391 NAC Chapter 7 Residential Child Caring Agency and 391 NAC Chapter 8 Child Placing Agency regulations became effective March 2021.
No Changes during Fiscal Year
No changes during fiscal year.
No changes during fiscal year.
Recommendation: Revise regulations to require infant safe sleep training before granting a child care license.
Fiscal Year Updates:
LB 717 was signed by the Governor on April 11, 2018, requiring training before a daycare license is granted. Regulations regarding the change are being formally promulgated. Public Health worked with the Nebraska Department of Education to make the "Safe with You" training more accessible to providers, including in an online format, since it now must be taken prior to a license being granted.
LB 717 was signed by the Governor on April 11, 2018, requiring training before a daycare license is granted. Regulations regarding the change are being formally promulgated. Public Health worked with the Nebraska Department of Education to make the "Safe with You" training more accessible to providers, including in an online format, since it now must be taken prior to a license being granted. Proposed child care regulations will include this requirement.
Draft regulations were prepared and went to hearing. In August and September 2021, the regulations were not approved and terminated by the Secretary of State for 391 NAC Chapters 1-5.
Public Health is following and holding licensees accountable to statute (43-2606). As of January 2023, OCSL is requiring pre-service training for licensees, primary providers, and directors which provides information on sudden unexpected infant death syndrome, abusive head trauma in infants and children, crying plans, and child abuse. OCSL has worked with NDE to ensure that the Safe With You trainings are available for the increased number of providers required to take the pre-service training.
LB 717 was signed by the Governor on April 11, 2018, requiring training before a daycare license is granted [Statute 43-2606(3)]. Regulations regarding the change are being formally promulgated. Public Health worked with the Nebraska Department of Education to make the "Safe with You" training more accessible to providers, including in an online format, since it now must be taken prior to a license being granted. Proposed child care regulations will include this requirement.
No changes during fiscal year.
OIG Note: This requirement is codified in the law but not included in regulations. The OIG noted this recommendation as complete in FY 20-21, due to this update the recommendation has been reclassified as progress. The OIG encouraged Public Licensing to continue efforts to modify regulations.
Recommendation: Gather and analyze additional data on the prevalence of pediatric abusive head trauma and update shaken baby syndrome materials distributed by the Division of Public Health
Fiscal Year Updates:
The Child Safety Collaborative Innovation & Improvement Network (CoIIN), housed at Public Health, has developed a Crying Plan and has gathered data from Hospitals on the materials they distribute and education they provide on abusive head trauma.
Current and proposed child care licensing reguations include pediatric abusive head trauma training through the "Safe with You" training series. This training is required in all licensed child care programs.
No Changes during Fiscal Year
No changes during fiscal year.
No changes during fiscal year.
DHHS
Youth Rehabilitation and Treatment Centers
Recommendation: Implement a Trauma-Responsive environment across the YRTC system.
Fiscal Year Updates:
DHHS intial response dated January 2021: DHHS began implementation of trauma informed care system training and utilization in 2014. This training is now a standard component of the care that is provided to youth in the YRTC system. Many, if not most, of the youth that come to DHHS have experienced significant trauma, as evidenced by their admission diagnosis and needing to receive a level of care that requires court involvement and commitment. The staff are trained and receive refreshed training on how to maintain a trauma responsive environment of care. In December of 2019 the YRTCs began including an additional resource called Trauma Affect Regulations: Guide for Education and Therapy (TARGET). This best practice is yet another trauma-responsive tool for clinical use. The training has been well received by staff. Individual employee ongoing training needs are assessed and evaluated annually.
No response to OIG request for fiscal year 2022-2023 updates.
Mental Health staff provide trauma-informed care training upon hire at all of the YRTC facilities and mandatory annual refreshers. Please note YRTC-Geneva is no longer in operation.
DHHS indicated that this recommendation has been operationalized.
OIG Note: The OIG confirmed that all staff, including support staff such as secretaries and janitors, receive the annual training referenced above.
Recommendation: Implement evidenced-based programming consistently throughout the YRTC system.
Fiscal Year Updates:
DHHS initial response dated January 2021: From our time-tested utilization of Cognitive Behavioral Therapies, Rational Emotive Therapy, and Motivational Interviewing, to early adoption of trauma informed care in 2014, to the more recent implementation of the MYSI model of care, DHHS remains committed to full utilization of these evidence-based practices to provide youth with the best opportunity to maximize their time in care with DHHS. Additional clinical supervision roles have been added to the care continuum to allow for more direct clinical participation and oversight of the youth care process. DHHS did not provide evidence of steps taken
No response to OIG request for fiscal year 2022-2023 updates.
All YRTCs implement evidence based programming, the details of this can be found in the §43-407 legislative report
DHHS indicated that this recommendation has been operationalized.
OIG Note: The nature of providing programing is challenging as it requires an ongoing commitment. The OIG will continue to monitor the programing being utilized within the YRTC system.
Recommendation: Conduct a detailed analysis of the YRTC workforce and implement a plant to ensure appropriate staffing of YRTC positions at all levels
Fiscal Year Updates:
DHHS initial response dated January 2021: DHHS Administration is committed to hiring, training and retaining quality staff at their facilities. Human Resources and the YRTCs are currently engaged in discussions of the entry level roles and their descriptors. DHHS, through its consultative relationship with MYSI (Missouri Youth Services Institute), is reviewing the roles and responsibilities of positions within the care continuum. Each facility will benefit from this review for the types of staff roles and the duties of those roles.
No response to OIG request for fiscal year 2022-2023 updates.
All YRTC's complete an annual Staffing Plan that is reviewed periodically.
DHHS indicated that this recommendation has been operationalized.
OIG Note: The OIG will continue to monitor compliance with the 1:4 ratio.
Recommendation: Implement a fully digital case management system.
Fiscal Year Updates:
DHHS initial response dated January 2021: DHHS currently utilizes the Avatar system for digital case management. The system also allows for a structured data sets and analytics that are used for reporting and to improve operations. Until 2020, YRTC facilities used stand-alone systems, but Avatar is now used across all DHHS residential facilities. DHHS targeted March 2021, as the go-live date for full-functionality of Avatar within the youth facilities. Modifications and enhancements for added value are under review.
No response to OIG request for fiscal year 2022-2023 updates.
All YRTCs utilize MyAvatar as the youth's digital case management system.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Require all YRTCs to be licensed as a Residential Child Caring Agency through the Division of Public Health.
Fiscal Year Updates:
No relevant action taken to address the recommendation.
No response to OIG request for fiscal year 2022-2023 updates.
Not applicable as recommendation was rejected by DHHS.
Not applicable as recommendation was rejected by DHHS.
Recommendation: Clarify where the Office of Juvenile Services, overseeing the YRTCs, is housed within DHHS.
Fiscal Year Updates:
The Office of Juvenile Services (OJS) provides supervision to all of the 24/7 youth facilities: Whitehall, YRTC-Kearney, YRTC-Geneva, the Lincoln youth facility and the Hastings youth facility. Whitehall is licensed as a Psychiatric Residential Treatment Facility (PRTF) and falls under the Behavioral Health (BH) division. The Youth Rehabilitation and Treatment Center facilities, plus the Lincoln and Hastings facilities, fall under the Children and Family Services (CFS) division. In order to provide programming structure, staffing support and operational consistency, the Chief Operating Officer (COO) provides direct supervision to the OJS administrator. The COO works in collaboration with the Director of Children and Family Services and the Director of Behavioral Health. The umbrella oversight methodology, while spanning both CFS and BH, allows for standardization, stabilization and consistency across all DHHS-provided youth services. An updated organizational chart, including the OJS administrator position, is currently available on the DHHS website.
No response to OIG request for fiscal year 2022-2023 updates.
OJS falls under the Director of CFS. This is reflected on the state's public website. Please note YRTC-Geneva has not been in operation since 2018.
DHHS indicated that this recommendation has been operationalized.
OIG Note: The purpose of the recommendation was also to clarify for the public where within DHHS the YRTCs are located and who is responsible for administering them. While the updated organizational chart (including the OJS administrator position) is currently available on the DHHS website the entirety of the YTRC system is not anywhere within the chart. For this reason the OIG has reclassified this recommendation from complete to progress.
Recommendation: Digitize Records at YRTC-Kearney.
Fiscal Year Updates:
In January 2017, the YRTCs began loading information on incident reports into an online portal, Salesforce. The system is now fully operational and allows facilities to review records of individual incidents as well as track specific incidents, including escapes, use of force, restraints, and seclusion.
No response to OIG request for fiscal year 2022-2023 updates.
All YRTCs utilize an electronic data system (MyAvatar) for the digitization of youth records.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Develop and implement a comprehensive Strategic Staffing Plan in order to achieve appropriate staff to youth ratios while attracting and retaining qualified staff members for YRTC-Kearney.
Fiscal Year Updates:
DHHS examined staffing at YRTC-Kearney, and calculated how many staff it needed to comply with PREA. Additional staff for YRTC-Kearney were included in the 2016 DHHS budget request and funded by the Legislature in 2017. DHHS reports that recruitment of staff at YRTC-Kearney has significantly improved.
No response to OIG request for fiscal year 2022-2023 updates.
All YRTC's complete an annual Staffing Plan that is reviewed periodically.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Develop Continuous Quality Improvement Process at YRTCs Led by Central Office.
Fiscal Year Updates:
In 2017, DHHS Central Office began putting together monthly data reports on Performance-based Standards at the YRTCs. They include information on assaults, confinements, escapes, injury, restraints, misconduct, property incidents, suicidal behavior, youth seen for medical treatment, and staff-to-resident ratio.
No response to OIG request for fiscal year 202
There is a Facilities Investigations Team as well as an Ethics and Compliance Team out of DHHS Central Office that provides continuous quality improvement for the YRTCs
DHHS indicated that this recommendation has been operationalized.
Recommendation: Close or Appropriately Restructure Full-time Secure Care Program at YRTC-Kearney in Dickson Unit.
Fiscal Year Updates:
In 2016, DHHS ended the full-time care program in Dickson. Currently, youth can live in Dickson for a short period of time if they have had struggles in their living unit. Each youth in Dickson has a Reintegration Plan that must be developed where the youth begins participating in normal activities as soon as they are able (example - school, group meetings). YRTC-Kearney reported that youth have not stayed in Dickson for longer than three to four weeks. These changes have not been codified in policy.
No response to OIG request for fiscal year 2022-2023 updates.
The program within the Dickson Unit has been appropriately restructured.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Make the OJS Administrator a Full-time Position.
Fiscal Year Updates:
During the summer of 2020, Mark LaBouchardiere was named as the OJS Administrator, though that information is not reflected on DHHS’s current organizational charts. In addition to the YRTC system, two facilities were added to the OJS Administrator role, according to the DHHS Division of Behavioral Health organizational chart—Hastings PRTF (Hastings Regional Center) and Whitehall.
An active full time OJS Administrator is reflected on the Division of Behavioral Health's organization chart. The position is a direct report to DHHS Facilities Chief Operating Officer.
No response to OIG request for fiscal year 2022-2023 updates.
Not applicable as recommendation was rejected.
Not applicable as recommendation was rejected.
Recommendation: Make clarifications to policies governing sexual abuse and harassment at YRTC-Geneva.
Fiscal Year Updates:
In August 2015, DHHS updated Administrative Regulation 115.17 to clarify reporting of incidents, investigation protocol, training, and other PREA-related topics. YRTC-Geneva made changes to OM 115.17.5 in August 2015 to clarify facility specific policy and procedure. Work to standardize policies and procedures at both YRTCs is ongoing.
No response to OIG request for fiscal year 2022-2023 updates.
All policies are reviewed annually and all staff receive annual training on PREA guidelines and procedures.
DHHS indicated that this recommendation has been operationalized.
OIG Note: YRTC-Geneva is no longer operational, the program has been relocated to Hastings.
Recommendation: Provide increased guidance and oversight from DHHS Central Office for cultural change at YRTC-Geneva.
Fiscal Year Updates:
In the fall of 2016, daily calls between the facility and OJS administrator, as well as the compliance team of both facilities were put into effect. Work is ongoing to standardize processes and policies at both YRTCs. Changes have been made to YRTC-Geneva's organizational structure to allow the psychologist to directly supervise therapists.
No response to OIG request for fiscal year 2022-2023 updates.
There is a Facilities Investigations Team out of DHHS Central Office that provides guidance and oversight for the YRTCs. Please note YRTC-Geneva is no longer operational.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Increase and improve resources, tools, and support for PREA implementation at YRTC-Geneva.
Fiscal Year Updates:
In July 2015, a full-time Central Office PREA Manager position was created to oversee PREA implementation at both YRTCs. In 2016, a compliance team that oversees PREA and other key issues at both facilities was put in place. OJS is currently planning for the next round of PREA audits. Both YRTCs underwent a PREA Audit in the fall of 2018. The final PREA Audit reports were released on November 18, 2018 which found compliance with PREA standards at each facility.
No response to OIG request for fiscal year 2022-2023 updates.
OJS has a Compliance team comprised of specialists across all YRTCs that rigorously oversees all PREA related implementation. The Compliance team does not report to anyone within the YRTC chain of command to ensure there are checks and balances in place. Please note YRTC-Geneva is no longer in operation.
DHHS indicated that this recommendation has been operationalized.
Recommendation: Adopt and implement standards for transporting youth to and from the Youth Rehabilitation and Treatment Centers.
Fiscal Year Updates:
On July 1, 2017, DHHS’s “Secure Transportation” service definition for transport to and from YRTCs became effective.
No response to OIG request for fiscal year 2022-2023 updates.
The YRTCs have SOPs that address transportation, furloughs, and transfers of juveniles. All SOPs include the applicable accreditation standards for each procedure to include transportation of pregnant youth.
DHHS indicated that this recommendation has been operationalized.
DHHS and Private Agency
Children and Family Services
Recommendation: Enhance training, resources, and education available to staff, parents, and caregivers in child welfare cases on safe sleep.
Fiscal Year Updates:
In 2016, DHHS incorporated infant safe sleep into New Worker Training. An “Under Two Packet” with information about safe sleep was created with assistance from the Division of Public Health. This is distributed to all families and caregivers of children under two. In 2016, NFC incorporated Safe Sleeping into New Worker Training and a webinar has been created that is mandatory for all permanency staff. The training includes information on items that should/shouldn’t be in the crib, co-sleeping, blankets, infant sleepwear, etc. This training will be completed annually by all permanency staff. NFC has attached Safe Sleep Guidelines to ages 0-5 Walkthrough Packet that is to be reviewed and/or given to the caregiver at each walkthrough when assessing non-agency/kinship homes.
The SWI has been revised and amended to an SOP, which is currently going through the approval processes, it will be released to the field with the updated information upon approval. Additional training opportunities have been updated within the SOP for staff, parents, and caregivers at different junctures of the case and throughout the life of the case.
CFS released a Safe Sleep SOP in 2023 with guidance for case managers on safe sleep practices. Public Health is engaged in an initiative around Safe Sleep in their maternal/child health area. Information about safe sleep practices can be found at: https://dhhs.ne.gov/Pages/Nebraska-Safe-Babies-Hospitals.aspx
DHHS indicated that this recommendation has been operationalized.
DHHS and Private Agency
Public Health-Licensure
Recommendation: Adopt policy and procedure on checking infant sleep areas and asking about safe sleep in child welfare cases.
Fiscal Year Updates:
The SWI has been revised and amended to an SOP, which is currently going through the approval processes, it will be released to the field with the updated information upon approval.
CFS released a Safe Sleep SOP in 2023 with guidance for case managers on safe sleep practices.
DHHS indicated that this recommendation has been operationalized.
Administrative Office of Probation
Juvenile Services
Recommendation: Assess whether Probation has the authority to monitor alternatives to detention.
Fiscal Year Updates:
Probation implemented a Predisposition Supervision Policy in September 2017 clarifying the circumstances under which predisposition, court-ordered supervision may occur.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Collect and publish data on the length of time between alternatives to detention being assigned and a court hearing taking place.
Fiscal Year Updates:
No update provided. Probation Administratior Deb Minardi invited the OIG to review numerous published reports available on their website.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Improve communication protocols between Probation and alternative to detention providers to ensure that key information on youth is appropriately passed on.
Fiscal Year Updates:
No update provided. Probation Administratior Deb Minardi invited the OIG to review numerous published reports available on their website.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Create an acknowledgment form for youth and parents after an alternative to detention is implemented that contains information on their rights and responsibilities.
Fiscal Year Updates:
Probation has created this form. It is unknown whether the form has been approved and implemented.
No response to OIG request for fiscal year 2022-2023 updates.
OIG Note: Probation has created this form. It is unknown whether the form has been approved and implemented.
Recommendation: Adopt policy requiring probation officers to make and document mental health referrals if an intake interview suggests that the youth has mental health needs.
Fiscal Year Updates:
No update provided. Probation Administratior Deb Minardi invited the OIG to review numerous published reports available on their website.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Require a simple mental health screening during intake interviews and select a uniform tool for probation officers to use.
Fiscal Year Updates:
No update provided. Probation Administratior Deb Minardi invited the OIG to review numerous published reports available on their website.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Implement guidelines on when it is appropriate to use specific types of alternatives to detention.
Fiscal Year Updates:
No update provided. Probation Administratior Deb Minardi invited the OIG to review numerous published reports available on their website.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Adopt policy that specifies what restrictions are not appropriate for use as an alternative to detention.
Fiscal Year Updates:
No update provided. Probation Administratior Deb Minardi invited the OIG to review numerous published reports available on their website.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Adopt statewide policy or protocol on what a probation officer’s role is between assigning an alternative to detention and a court hearing.
Fiscal Year Updates:
Probation approved a Predisposition Supervision Policy in September 2017. The policy sets forth the circumstances under which predisposition, court-ordered probation supervision may occur.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Increase internal quality assurance efforts at the state level.
Fiscal Year Updates:
No update provided. Probation Administratior Deb Minardi invited the OIG to review numerous published reports available on their website.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Adopt policy on documentation and record keeping.
Fiscal Year Updates:
No update provided. Probation Administratior Deb Minardi invited the OIG to review numerous published reports available on their website.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Adopt policy on child welfare referrals and joint case management.
Fiscal Year Updates:
Probation released a policy regarding this subject. Probation has been training probation officers and DHHS caseworkers across the state with DHHS on the new joint case management policy.
No response to OIG request for fiscal year 2022-2023 updates.
Recommendation: Adopt training and policy on supervising youth with intellectual and developmental disabilities (I/DD).
Fiscal Year Updates:
Probation provides the Nebraska Developmental Disabilities Access Guide to Probation Officers; to date Probation has been unable to locate a suitable training vendor and plans to coordinate with DHHS to accomplish training; there are no policies yet created, and the OIG is unaware of any action to create a policy.
No response to OIG request for fiscal year 2022-2023 updates.
OIG Note: As noted in previous reports, Probation provides the Nebraska Developmental Disabilities Access Guide to Probation Officers. To date the OIG has not been made aware of any changes to the situation in which Probation is unable to locate a suitable training vendor and plans to coordinate with DHHS to accomplish training; there are no policies yet created, and the OIG is unaware of any action to create a policy.