• Boots on the ground workers are becoming increasingly difficult to get in touch

with.

• The mission of child welfare, policy and practice are not in alignment.

• DFCS is still not going out into the field. They are doing 'home visits' virtually
and by phone calls. Often our children are telling us that the alleged perpetrator
or unsupportive parent was standing at the door listening or even sitting in the
room with them. Therefore, DFCS closes their case when the child reports to
them nothing is wrong and then there is an inconsistent report in the Fl and
investigative evidence. It is posing significant problems with prosecution.

• Our Center would like to see a marked shift in DFCS' priorities, moving from
case closure to sustainable family stability. With the overarching focus remaining
on keeping families, regardless of how dangerous or dysfunctional they are,
intact, DFCS is choosing to demonstrate a fidelity to mission over safety.

• It would benefit Georgia 's children to devote time to researching the issues of
juvenile alleged offenders, their treatment, their safety, and ensuring the return
to normalcy we all want to see for Georgia's families. Policy made without
accurate and comprehensive information is nothing more than speculative and
doomed to fail on every organizational level.

• CA Cs should be given the benefit of the doubt and our referrals (along with any
MDT partner's referrals) should be given priority and should not have to go
through a screening process by someone who does not have access to the
family's history, the reporter's role or expertise. Our work is good enough to
provide recommendations to courts for placement and incarceration but is
somehow deemed less than adequate by individuals with no direct knowledge.

• CA Cs are telling us that the lack of communication between DFCS and LE has
become debilitating. At best DFCS is faxing in reports to LE in most areas. This
is not filing a police report for abuse allegations which is what is typically
necessary.

• Case closures before services and sometimes assessments can be completed

by the CAC

• Family Preservation services have all but disappeared in many areas. This is the
service used for DFCS to provide oversight of a case plan to ensure services
occur in an attempt to keep a family together while ensuring additional measures
for safety and cross reporting. We are seeing more situations where it is either
no involvement or the issues have gotten so bad the child must be placed in
foster care. Typically families stay engaged in services with more consistency
up to completion of the services when there is a case plan.

• DFCS has no concrete, evidence-based, cohesive response to allegations of

sexual abuse made against juveniles.

• A weighted response based on the identity of the reporter is not provided to

MDT partners. (It would help the investigators and forensic interviewers
Page 2 of 27
OIG Case# FY2022-01 2
Complaint from the Children 's Advocacy Centers of Georgia
Chief Executive Officer for Children's Advocacy Centers of Georgia (CACGA).
The CAC model, according to the National Children's Alliance ("The Force
Behind Children's Advocacy Centers") is inserted below for additional reference
purposes:

(CONTINUE TO NEXT PAGE)

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OIG Case# FY2022-012
Complaint from the Children 's Advocacy Centers of Georgia
 us to review in GA SHINES. As such, this review is only as good as the
information that was entered in the case records by DFCS staff, as well as the
information that was provided to OIG staff by the CAC.)

Boney was asked by OIG Chief Investigator Ellison for more specific cases or information
regarding her claims, and in her reply, she (Boney) mentioned, "systemic
failures/gaps/shortages." A systemic issue or problem, by definition, relates to or affects the
whole of an organization, rather than just some parts of it. When asked by OIG staff to provide
specific examples/issues/situations (that evidenced the supposed systemic
failures/gaps/shortages}, Boney failed to provide any substantial evidence that suggests that
there is a systemic/statewide issue with DFCS as a whole. OIG finds that the use of the word
"systemic" when referring to the issues/claims that Boney highlighted in her complaint, may not
be an appropriate descriptive representation of the agency. As specific examples of her
concerns, Boney provided three cases that originated in one DFCS office in one out of 159
counties in this state and involved only one of 52 CAC offices across the state. These examples
do not represent a fair and accurate sample for determining if an issue is systemic or not. Are
the issues Boney pointed out systemic? OIG is unable to gauge and/or determine if that claim is
true, as the specific examples provided did not represent a fair sampling of all the offices (DFCS
and CACs).

OIG staff identified several areas of concern from Boney's complaint that we would like to
address, which are listed below:

• We have some offices in our two judicial circuits that have very limited hours.
When you call the office you get no answer. I am very concerned that there
isn't even a way for people to contact OFCS except during these very limited
hours. For Example: Dodge and Bleckley County- open 8 - 11 ; 12 - 5 on
Monday; open 8 - 1 on Tuesday.

OIG staff made a phone call to the Dodge County DFCS office (478-374-
6760) during business hours, but outside of their listed in-person office hours.
An automated message stated that the Virtual Lobby hours were from 8 am -
5 pm, Monday thru Friday. The automated message contained very detailed
information on several DFCS programs, including phone numbers and
website addresses. to assist the caller with any possible DFCS issues. Near
the end of the message, the caller is told - if you need immediate assistance,
leave your name, case number, and a brief message for a return call within
24 hours. The automated message was in both English and Spanish. OIG
staff also made a phone call to Bleckley County DFCS (478-934-3172) during
business hours, but outside of their listed in-person office hours and got the
same message. Dodge and Bleckley County DFCS are two of the smallest
DFCS offices in the state. In fact, they are so small that the two offices share
the same County Director. OIG suspects those same two offices possibly
share limited staff and don't have enough staff to devote to manning the
phones, in person, at both offices for eight hours every day of the work week.
As to the statement (made by Boney), "I am very concerned that there isn't
even a way for people to contact DFCS except during these very limited
hours", OIG would like to note that the Child Protective Services (CPS) Intake
Communications Center (CICC) is active 24 hours a day, 7 days a week, 365
days a year. Other smaller DFCS offices operate similarly in other parts of the
state.

Page 21 of27
OIG Case# FY2022-012
Complaint from the Children's Advocacy Centers of Georgia
• Boots on the ground workers are becoming increasingly difficult to get in
touch with.

There were no specific examples or information provided by Boney regarding

this concern . OIG staff again question if this issue is a really systemic
problem or if Boney was simply using a few offices across the state as
examples. There is no way to refute or confirm Boney's claim without a fair
sampling of the DFCS offices/case managers/ or situations that she is
referring to. While we have no way of knowing if the situations Boney is
referring to are "emergency" situations, we again note that CICC is active and
operating 24 hours a day, 7 days a week, 365 days a year, and available for
anyone to make a report regarding the welfare or wellbeing of a child.

• The mission of child welfare, policy and practice are not in alignment.

• DFCS is still not going out into the field. They are doing 'home visits' virtually
and by phone calls. Often our children are telling us that the alleged
perpetrator or unsupportive parent was standing at the door listening or even
sitting in the room with them. Therefore. DFCS closes their case when the
child reports to them nothing is wrong and then there is an inconsistent report
in the Fl and investigative evidence. It is posing significant problems with
prosecution.

Of the three case examples provided to OIG, the visits conducted in those
cases were face-to-face visits, not virtual visits. Again, without specific case
examples or specific DFCS offices listed, OIG cannot validate Boney's claim.
To say that DFCS staff as a whole are not going out in the field, and then
provide case examples that show that DFCS staff were in fact going out in
the field, seems to prove that this statement made by Boney is simply not
true.

• Our Center would like to see a marked shift in DFCS' priorities. moving from
case closure to sustainable family stability. With the overarching focus
remaining on keeping families. regardless of how dangerous or dysfunctional
they are, intact, DFCS is choosing to demonstrate a fidelity to mission over
safety.

It would benefit Georgia's children to devote time to researching the issues of

juvenile alleged offenders. their treatment, their safety, and ensuring the
return to normalcy we all want to see for Georgia's families. Policy made
without accurate and comprehensive information is nothing more than
speculative and doomed to fail on every organizational level.

Decisions about agency priorities, a shift, or changes needed in agency

policy are not made at the local office or even at the regional level; those
decisions are made by agency leadership at the state office level. It seems as
though CAC staff may be faulting local office staff because they are following
agency policy and procedures.

CA Cs should be given the benefit of the doubt and our referrals (along with
any MDT partner's referrals) should be given priority and should not have to
go through a screening process by someone who does not have access to
Page 22 of 27
OIG Case# FY2022-0 12
Complaint fro m the Children 's Advocacy Centers of Georgia
 the family's history, the reporter's role or expertise. Our work is good enough
to provide recommendations to courts for placement and incarceration but is
somehow deemed Jess than adequate by individuals with no direct
knowledge.

OIG cannot say for sure if Boney was referring to DFCS staff when she states
in her correspondence, "someone who does not have access to the family
history ... or individuals with no direct knowledge". DFCS, as the agency
tasked with the protection of children, should be able to use their judgment
and follow policy (which is steeped in State and Federal statutes) to make
decisions regarding families and children that fall under their (DFCS) purview.
It appears that CAC staff may simply be upset because they do not have
authority or control over, or maybe their opinions are being discounted when
DFCS staff have to make decisions about the wellbeing of a child. While we
feel confident that DFCS staff appreciate the work done by CAC staff, DFCS
staff are the ones ultimately responsible for the decisions and they are the
ones who will be held accountable if those decisions are wrong. It is easy for
someone outside the agency who also may not have access to the
information DFCS staff does to second guess decisions being made by
agency staff

If CAC staff have access to or knowledge of "family history" that they (CAC
staff) believe the agency is unaware of, then the responsibility falls on the
involved CAC staff to share that information with DFCS staff. Again, Boney
provided no specific examples of cases or situations that she was referring to.

• CA Cs are telling us that the lack of communication between DFCS and LE

has become debilitating. At best DFCS is faxing in reports to LE in most
areas. This is not filing a police report for abuse allegations which is what is
typically necessary.

This complaint failed to identify any specific examples of the alleged "lack of
communication" between DFCS and local law enforcement, nor is there any
specific proof or factual information to suggest that reports to law
enforcement are not being made. Without specific cases to review for this
issue or specific county DFCS offices to check into, OIG staff has no way to
investigate this specific concern any further.

When DFCS staff receive a CPS intake/referral, that falls within the
guidelines for child abuse or neglect, agency staff will access the case to
determine the appropriate response time.

Per agency policy, DFCS must notify law enforcement authorities of any
reports of physical and/or sexual abuse against a child. While DFCS staff will
make an in-person response to the allegations, sometimes as soon as within
24 hours, depending on the nature of the report and the age of the child, it
may not be feasible in some counties for staff to also make an in-person
report to law enforcement. Many counties are understaffed and have a high
volume of intakes; agency staff must prioritize making contact with the victim
child in a timely manner. For this reason, DFCS staff will sometimes notify
law enforcement of the alleged abuse via fax. The faxed report is sent to the
attention of a designated individual at each law enforcement agency; this
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OIG Case# FY2022-012
Complaint from the Children 's Advocacy Centers of Georg ia
 constitutes "filing a police report". Many police departments also take reports
online; an in-person report is not a requirement for a matter to be taken
seriously by law enforcement.

• Children and youth are being thrown all over the state without regard to the
criminal component of their situation. Yes. children always come first and I
understand some kids need to be moved immediatelv. but what I am seeing
is extended periods of time before a child is moved and GAG services are
requested. In my circumstances. forensic interviews are being requested
AFTER the child has already Jeff the legal jurisdiction which is where a lot of
the problems with LE come in. In a lot of circumstances. there is time to get
the Fl/FME completed before the child is transferred out of the jurisdiction. A
Jot of these situations can be prevented with communication between DFCS
and LE from the verv beginning.

When a child is unable to safely remain at home with their parent or guardian,
the State of Georgia, though DFCS, must step in as the legal guardian of that
child. As such, the well-being and safety of the child ultimately become the
agency's responsibility. When a child enters Foster Care, identifying a safe
placement must be the first priority. Whether or not that placement can be
found within the same legal jurisdiction where the abuse occurred is not a
primary concern. The agency must focus on the immediate safety of the
involved child , not on issues that might arise with a potential court case later
on . Many different factors must be weighed to determine if a placement is
suitable for a specific child and oftentimes, there may not be any adequate
placements available in the same county or jurisdiction where the child was
removed. Georgia has seen a substantial increase in the number of children
entering foster care in recent years, and this has resulted in a shortage of
foster homes in many areas. While keeping the child in a fami liar area is
ideal, and also may make prosecution of the abuser easier, later on, it is
simply not always feasible. Many foster children need a higher level of care
due to being medically fragile or having severe mental health I behavioral
concerns. In these cases, the number of available placements is diminished
even further. The agency must identify the placement that best suits the
needs of the child, regardless of what legal jurisdiction that placement might
fall in. Additionally, the agency will place children with relatives whenever
possible and these relatives may live in a different jurisdiction. Once a safe
placement is identified, then the focus can shift to making sure all necessary
referrals have been made and forensic interviews have been scheduled. It
almost seems as though Boney and her staff may simply not be aware of the
obstacles faced by DFCS staff when trying to place a child or are simply
ignoring it, as it may sometimes pose an inconvenience to CAC staff

• DFCS has no concrete. evidence-based. cohesive response to a/legations of

sexual abuse made against juveniles.

• A weighted response based on the identity of the reporter is not provided to

MDT partners. (It would help the investigators and forensic interviewers
tremendously if they knew when a mandated reporter has made an a/legation
vs. something such as an anonymous report from a community member.)

Page 24 of 27
OIG Case# FY2022-01 2
Complaint from the Children 's Advocacy Centers of Georgia
 According to DFCS policy regarding Confidentiality I Safeguarding
information, the agency is required to maintain confidentiality when a report of
child abuse or neglect is made. Agency employees are required to release
only the information that is required by law, or necessary to arrange for
services or to fulfill administrative requirements. While Mandated Reporters
are required to report concerns of abuse/neglect, this fact alone should not
suggest that intakes from Mandated Reports should be taken more seriously
than those from community members or even anonymous reporters. All
allegations of child abuse and neglect should be investigated with the same
degree of care, regardless of the reporting source. The type of reporting
source is not necessary information for an MDT partner or forensic
interviewer to be privy to in order to properly serve a child. As a child welfare
agency committed to maintaining confidentiality, DFCS ensures safeguards
are in place to prevent the unauthorized disclosure of such information. At the
initiation of every case, DFCS staff explain to individuals (including both
clients and reporters) that their information is protected, and any anticipated
disclosures are strictly limited to those required by law. DFCS staff must
adhere to confidentiality standards established by law, as families place their
confidence and trust in child welfare staff. If DFCS staff did not honor this
duty to protect confidential information, then it would diminish the agency's
credibility and individuals could become less inclined to make reports.

• I don't know if DFCS even knows what authority they have and what they can
do to assist families or mandate services. If they do, they are not exercising it.

The above statement/claim seems to suggest that DFCS staff, from the
Division Director down to a case manager at a local office, are ignorant. OIG
finds this statement to be trivial, petty, meritless, and without substance, as
Boney provided no specific examples of situations that would support this
claim.

It seems as if CAC staff would prefer that the DFCS decision-making process
(about case situations) be based only on the opinion of CAC staff and that all
other opinions - even if based on known facts or circumstances, as well as
policy and procedure, should not be taken into account. As was stated earlier
in this report, OIG staff entertain the possibility that CAC's complaints and
concerns regarding the agency appear to have resulted from CAC staff
becoming annoyed, offended, or simply upset that DFCS staff do not give
CAC staff the authority and/or priority that they (CAC staff) seem to believe
that they are entitled to.

• It's frustrating and nonsensical that DFCS continues to request services from
CA Cs but then our work product and opinions are treated with no more
respect or credibility than a nosy neighbor who sees a child without a coat.
These are expert witnesses in superior and juvenile court who provide
testimony and opinions to the court systems-why is the state agency
charged with ensuring safety willing to use our work product and opinions on
the stand when the situation has escalated to the point of termination of
parental rights but unwilling to partner with us on the frontend. creating a
system that treats MDT partners' reports as more weighted and credible than
others? If the purpose and mission of DFCS is permanency and healthy
families, shouldn't input from the experts be used in achieving that goal
Page 25 of27
OIG Case# FY2022-012
Complaint from the Children 's Advocacy Centers of Georgia
EXHIBITS

1. Copy of email correspondence between Children's Advocacy Centers of Georgia Chief

Executive Officer Amy Boney, Terminus Strategies, LLC. Founding Partner Wendi
Clifton, Terminus Strategies, LLC. Partner Ted Burdo, OHS Chief of Staff Craig Foster,
OHS Commissioner and DFCS Director Candice Broce, OIG Inspector General David
LeNoir, DHS-OIG Chief Investigator Scott Ellison, OIG Lead Senior Investigator Hailey
Kraut, and DHS-OIG Senior Investigator Angelicia Porter, dated January 14, 15, & 25,
2022, regarding DFCS Issues from GAG Perspective (6 pages)

2. Copy of email correspondence between Children's Advocacy Centers of Georgia Chief

Executive Officer Amy Boney, OIG Chief Investigator Scott Ellison, OIG Lead Senior
Investigator Hailey Kraut, and OIG Senior Investigator Angelicia Porter, dated January
27, 2022 & February 1, 2022, regarding specific case information, related to DFCS
Issues from GAG Perspective (4 pages)

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OIG Case# FY2022-012
Complaint from the Children's Advocacy Centers of Georgia