A couple of opportunities are converging at the federal level that can collectively advance the sharing of data for better child welfare outcomes.
First, the recent Comprehensive Child Welfare Information System (CCWIS) Final Rule provides funding for new child welfare systems that are more modular and focused on the data rather than the system itself. Several states have already declared their intent to take advantage of the funding and build new systems. Several more are “modernizing” their existing systems, and a few states and tribes have not yet made a declaration. Key elements of the CCWIS are modular design and bi-directional data exchanges with Courts, Education, and Medicaid.
Second, the Family First Prevention Services Act (FFPSA or Family First), passed as part of the Bipartisan Budget Act of 2018 (H.R. 1892), represents an enormous shift on how child welfare services are provided and financed with the aim to improve outcomes for vulnerable children in care. As the FFPSA title suggests, the legislation is intended to help keep children safely with their families and avoid the traumatic experience of entering foster care. The FFPSA emphasizes “evidence-based decisions” but does not specify the data these decisions should be based on.
There is good news and bad news on the timing of these two federal initiatives.
The timing is pretty good for those projects that are just getting underway or haven’t even started to consider how to include the data in the new or modernized CCWIS that would support evidence-based decisions. Factoring in requirements for new data that will be used in evidence-based decisions should still be fairly straight-forward at this point.
The bad news? Trying to figure out what data is needed for evidence-based decisions, and determining how that data could be factored into a new CCWIS takes planning and time. Most state systems currently have hard-coded single direction interfaces with outside agencies to “exchange” data, if they have them at all. And the notion of bi-directional data exchanges is, for many, still a science-fiction construct, and data management capabilities are not as strong as perhaps they should be. Worse, some states may end up building the “Current System version 2.0,” which would completely ignore the significant opportunity at the door.
Child Welfare program directors and Information Technology directors have a clear opportunity to partner to guide the development of the bi-directional data exchanges that will yield data for use in evidence-based decisions. Ultimately, evidence-based decisions lead to better outcomes for kids so agencies will want to make this collaborative data initiative a priority.
Some very good (and free!) tools exist out there to guide your efforts. When you’re thinking about exchanging data, you’ll have to consider how that exchange will be made – the Feds are encouraging states to think in terms of the National Information Exchange Model (NIEM). The good folks at NIEM have assembled a helpful roadmap to get you started.
- Think first about what you want to get out of the exchanges and start making contact with principals in other agencies who will be able to help you champion the exchange. Decide what information you may need now and in the future to make “evidence-based decisions,” and begin crafting your list of data elements with this in mind.
- Ask the folks in the other agencies what data they would like from your agency? Don’t worry yet about the privacy and confidentiality parts of the conversation. While these are very important, your task at this point is to try and build good relationships and demand for data that will hopefully create and sustain momentum. Try not to settle for what you have now. Ask questions like the ones found on the NIEM training site:
- What information do you exchange now?
- What information do you want to exchange next?
- What information would you like to exchange in the future?
- Is there a subject matter expert, or a user group, that has relevant expertise?
- Start collecting scenarios of action – these will be built into “use cases” and/or “user stories” that will guide the building of knowledge around the exchange. Co-creating these with your data exchange partners will help build common goals and relationships.
It may take several meetings to get answers to those questions above, but if you know that going in, you can have a plan for how to proceed. You’re asking for change on both sides, and change is never easy or fast. Be prepared to assign resources to help guide and monitor activities.
- Promise (and keep it!) to be transparent, open, and frequent with communications. Offer to set up a regular meeting with an agenda and minutes. Prepare to measure effectiveness of the meetings in getting to the ultimate goal of data exchange.
- Start understanding the relationships and jurisdictional boundaries that are guiding actions and reactions. Strategize about how to leverage those to establish sustainable processes for data exchanges. Consider professional facilitation so that you can concentrate on building relationships at several levels – often in these efforts, when the champion moves on, the effort falters. Building relationships at several levels acts as an insurance policy for sustainability.
- Understand there will be objections to exchanging some of the data – resolve to reach understanding of what will be best for the children we are trying to protect and serve first. Lots of work has been done in the area of data exchanges to provide better care for kids. Models of Consent Agreements and Data Use Agreements (and other data sharing artifacts) are available and successfully used by others. If we begin with the objective of getting to “yes” (while complying with privacy and confidentiality laws), anything is possible. But start ASAP.
Most of all, don’t get discouraged before you start. “If it was easy, it would be done by now,” is not a phrase that should slow you down. There are common goals on all sides of data exchanges that need to remain front and center, and a consistent, well-planned effort is the key to seeing results.
If you found this article interesting, be sure to check out my recent post, Focusing on Data Quality: Key Considerations for Child Welfare Agencies.
About the Author
Shell Culp is a Senior Advisor for Public Consulting Group and former Agency Information Officer for California Health and Human Services Agency. Shell is also a Senior Fellow at the Center for Digital Government.