18 Miss. Code. R. 6-1-A-I-XVI

Current through August 31, 2024
Section 18-6-1-A-I-XVI - CONTINUOUS QUALITY IMPROVEMENT
A.State Continuous Quality Improvement Plan

The Continuous Quality Improvement (CQI) Plan outlines and describes the implementation of the CQI process within the Mississippi DFCS (DFCS). The CQI Plan:

* Assigns responsibility for coordination/implementation of CQI activities, and provision of technical assistance in using the CQI process;

* Sets forth the purpose and scope of CQI activities;

* Establishes how the DFCS periodically reviews essential management and service delivery processes consistent in light of quality priorities;

* Defines stakeholders and how stakeholders will participate in the CQI process;

* Outlines methods and timeframes for monitoring and reporting activities; and

* Includes provision for an assessment of the utility of the CQI program, including any barriers and supports for implementation.

The primary purpose for engaging in CQI activities is to promote positive outcomes for the children and families served by the division by reinforcing the principles of family centered practice and assuring high quality of services. To achieve this goal, it is essential for the division to:

(1) institute structured processes in order to examine, evaluate, and act on quality issues within our DFCS and
(2) involve all division staff as well as families and stakeholders in these processes.

The CQI process is one that is thoroughly integrated into the DFCS's ongoing work and serves primarily as a means of reinforcing the practices that are currently being implemented in the state. CQI is viewed as a means of keeping the DFCS's mission and vision in clear focus for staff in the field and as a primary means of sustaining the improvements that we achieve in practice and outcomes over time. In order for it to serve that function, it must actually monitor for the practices that are put into place and provide sufficient feedback to staff to inform practice, decision making, and resource allocation.

Our CQI process is designed in accordance with the state's practice model, and thereby supports its implementation and sustainability. Six broad categories of activities in working with children and families have been identified that comprise the essence of the practice model. They are as follow:

* Mobilizing Appropriate Services Timely

* Safety Assurance and Risk Management

* Involving Families and Children in Case Planning and Decision Making

* Strengths and Needs Assessments of Children and Families

* Preserving Connections and Relationships

* Individualized and Timely Case Planning

A monitoring process has been designed that is fully synchronized with our practice model and provides the DFCS with a thoroughly integrated and consistent way of serving children and families.

B. Characteristics of CQI

DFCS' CQI process includes the following characteristics:

* reinforces positive practice at the case level.

* provides analysis of findings at a high enough level to inform the ongoing development and maintenance of the practice model.

* evaluates the capacity of the system to support quality casework practice.

* CQI is an inclusive process.

* coordinates with other oversight and review processes and improvement efforts.

* focused on identifying strengths and needs of practice and supports making needed improvements.

* integrated into the ongoing work of staff in County Departments, rather than being regarded as a special or periodic effort.

* focuses on accountability and improvement.

C.Mississippi's Continuous Quality Improvement Structure

Mississippi's CQI structure includes the following components:

* State Office CQI Unit

* Local (county/regional) CQI processes

* State CQI Team (that is either the State level practice model implementation team or a sub-group thereof)

* Local CQI Teams (that are a sub-group of the regional practice model implementation teams)

Descriptions of the functions of each of these components are as follows:

1.DFCS State Office CQI Unit

The primary entity responsible for administering CQI functions statewide is the State CQI Office, which includes the following:

* Evaluation and Monitoring Unit (EMU);

* Foster Care Review Unit (FCR);

* MACWIS Unit;

* COA coordination activities;

* Court improvement activities.

The State Office CQI Unit maintains responsibility for coordinating CQI work statewide and specifically carries out the following responsibilities:

* Developing and updating the instruments and tools needed to carry out CQI responsibilities, such as review tools, procedures manual, sampling criteria, and data tools;

* Conduct regular CQI reviews of County Departments of Human Services;

* Provide training to participants on the CQI process, including State and local participants;

* Provide case-level feedback to county and regional staff on cases reviewed, and provide feedback to supervisors and administrators on county-wide performance, and to State-level staff and stakeholders on county, regional, and statewide performance;

* Analyze the findings of reviews, including qualitative and quantitative analyses, and compile results into periodic reports that identify the strengths and areas needing improvement identified in the reviews;

* Assist RDs in reviewing and approving county program improvement plans resulting from the reviews, and in determining if the goals and progress measures identified in the plans have been achieved;

* Ensuring that other oversight and monitoring functions within MDHS are coordinated and aligned; and,

* Conduct special studies as needed or requested to evaluate performance and outcomes in specific areas.

2.Local CQI Processes

In order for CQI to be integrated into the routine work within counties and regions, it is necessary to have more frequent CQI activity locally to supplement formal State CQI activities. MDHS is adopting a process of ongoing reviews in each county following the same basic protocols of State CQI reviews, and facilitated by the local CQI liaisons. In order to help ensure that county staff participate in the CQI process and are connected to improvement efforts within the county, county child welfare staff should serve on the Regional CQI committees.

The local CQI liaison and the local Foster Care Reviewer will co-facilitate quarterly CQI Committee meetings and the review process, which includes random case selection within each county. The emphasis is placed on using the committee to support staff in decision-making and offering constructive feedback on interventions, so as to help staff view the process as positive and helpful in improving practice. Direct and prompt feedback will be provided to Workers and supervisors whose cases are selected for review. CQI Committees will request status reports on how their recommendations have been addressed in the cases reviewed.

D.Stakeholders

DFCS and its staff interact on a daily basis with others in an effort to provide quality services to families. In order for the CQI process to truly reflect a complete picture of the service delivery system, the community partners and consumers must be involved.

Community Partners are individuals/entities with whom the division works in conjunction to provide holistic services to the populations we serve. Examples of community partners may include but are not limited to:

* Juvenile Court Representatives

* Foster Parents

* Tribes

* Service Recipients

* Residential or Counseling Service Providers

* Department of Mental Health

* Division of Economic Assistance

* Division of Youth Services

* Division of Child Support and Enforcement

* Guardians ad Litem

* Attorneys

* School Personnel

* Health Care Professionals

* Community or Child Advocates

* Law Enforcement

A strength of the Mississippi DFCS is its strong value for partnering with families and communities. The DFCS has worked diligently to develop partnerships with communities and to be accountable to our citizens through committees such as the Citizen's Review Board, the CJA Panel and the Mississippi Association of Child Caring Agencies.

DFCS is committed to openness, accountability, data driven decision making and working with our partners to improve services and outcomes for children and families. In Mississippi's CFSR PIP, many actions steps included partnerships with the Office of State Court Administrators, Department of Mental Health, Department of Health, state universities, community partnerships and others. DFCS anticipates continued involvement with these entities.

Community partners are selected based on their ability to assist in the process of generating solutions. Participants are purposefully selected who are very familiar with the policy, procedures and practice of the division. This will help avoid spending a substantial amount of time orienting them to the DFCS.

Consumers (clients) are identified as adults and youth involved with DFCS. Their involvement begins at the same level as community partners. The selection of these participants is done very carefully with a goal of selecting individuals who have experience with and knowledge of DFCS. If necessary a staff person who knows the individual may serve as a coach to assist them in understanding their role.

Consumers may be either current or past clients. Youth are selected from the Independent Living Programs (ILP) to provide input through the Strategies for Assessing Independent Living Skills (SAILS) Committee.

E.Measures and Outcomes

The State CQI reviews consist of a review of information from multiple sources, including data reports that track individual performance indicators at the county, regional, and statewide levels, and an onsite review that includes case reviews of families served by the county/region, supplemented by interviews with key parties to each case. The onsite reviews also include interviews with stakeholders internal and external to MDHS in order to evaluate the systemic capacity of the county/region to support practice consistent with the practice model.

In order to be effective at improving outcomes for children and families, CQI monitors quantitative information that provides data on the status of identified indicators, such as numbers of children and families served in various ways, the time frames for critical activities and goal achievement, and the level of available resources. It also monitors qualitative information in order to provide information on how well children and families are served, how appropriate various interventions are, and how the values and principles underlying the practice model are integrated into casework practice.

F.Quantitative information

In using quantitative data to evaluate performance, the system needs the capacity to produce reports that reflect not only point-in-time data on the child welfare population, but also foster care entry cohort profiles. This information will be especially useful in evaluating the extent to which the implementation of the practice model is having the desired effects on outcomes.

The production and longitudinal analysis of foster care entry cohorts will provide a basis for determining if the outcomes and experiences of children newly entering foster care in counties that have implemented the practice model differ notably from the cohorts of children who entered foster care either prior to the practice model or in counties that have not yet implemented the model. These data help local implementation/CQI teams, administrators, and other staff and stakeholders evaluate their efforts over time relative to the practice model and use the information to make needed adjustments in strategies, resources, and so forth.

It is very important that the reports are produced for individual counties and for regions within the State, so that administrators and CQI liaisons may track performance over time and make informed decisions about resource development, program improvement efforts, technical assistance, and so forth. RDs and ASWSs have a prominent role in reviewing county and regional-level reports routinely, to address them in staff meetings, and with local CQI teams, in order to evaluate performance, consistency of practice with the practice model, and monitor the resources needed for effective child welfare practice.

G.Qualitative Information

In combination with qualitative information, the CQI system reviews for the quality of interventions with children and families, the services they receive, and the adequacy of the systemic supports. The primary means of collecting and reviewing this information is through regular case reviews that sample families receiving in-home and foster care services, and through surveys with individuals that have first-hand knowledge of the issues under review.

An underlying value regarding qualitative information is that children and families served by the child welfare system should have a voice in how they are served. Although providing children and families with the opportunity to voice their concerns, strengths, needs, and preferences regarding services is very important, it does not imply that the DFCS abdicates its legal responsibilities to protect children and to carry out its legal responsibilities. It simply means that case planning and service delivery are often more effective when they are based on information provided directly by children and families. When the CQI process demonstrates the importance of family input into how they are served, it serves as reinforcement for including children and families in the actual practice of case planning and service delivery.

Case level information: CQI monitors for the effectiveness of casework practice at the individual case level. In order to be as accurate as possible in evaluating practice, reviews include information obtained from documented case files, but also from interviews with parents, children, foster caretakers, service providers, and Workers. Together, the information provides an accurate description of how well each of the six practice model components functions within the individual case. In addition to the information needed to evaluate conformity with the practice model, the review of individual cases also includes indicators that pertain to Federal or State requirements not specifically identified within the practice model.

Cases reviewed consist of in-home and foster care cases, of which includes open and closed cases. Although most of the requirements of the Olivia Y settlement agreement pertain specifically to foster care services, the practice model is intended to guide casework practice in both in-home and foster care cases. In order to promote application of the practice model across all cases, those cases monitored are selected randomly. The CQI unit has developed detailed sampling guidance that includes case selection criteria and the number of cases to be reviewed by type (14 foster care cases and 10 in home cases per region) for annual reviews and monthly case reviews (1 foster care case and 1 in-home case).

The Foster Care Review Unit has utilized the Periodic Administrative Determination as the case review instrument since 2005. Every child in foster care in all of Mississippi's 82 counties five months or longer is reviewed with this instrument every five months. A comprehensive review of the MACWIS case record as well as the paper case file is completed with each review.

Additionally, a county conference is conducted in which the social worker, the social work supervisor, the parents, the resource parents, the foster child, the guardian ad litem, grandparents, and any other relevant case members are engaged to provide information related to the child's permanent and concurrent plan.

The Attorney General's Office provides a report of children who have been referred for termination of parental rights. The Permanency Unit provides a report of the children needing an adoptive placement. These reports provide evidence to support the case review findings. The resulting report from these reviews is forwarded to the county of responsibility and the Regional Director within 15 days of the review for their follow-up. Part B of the Youth Court Hearing and Review Summary is completed in MACWIS by the Reviewer to document the comments made during the county conference and to assist in making findings on the mandated determinations of compliance with case planning, conduciveness/appropriateness/ restrictiveness of the child's placement, progress toward alleviating the causes that led to custody, and continuing need for custody as well as appropriateness of the child's permanent plan.

The Periodic Administrative Determination (PAD) has been automated in MACWIS. This allows the findings from the review to be stored directly in the electronic case file and enhances the county's and region's ability to follow up on case review findings.

The MACWIS Unit also maintains the Data Dashboard, which was implemented in December 2010 as a means for all DFCS employees to view, on the DFCS Connection website, quarterly regional and statewide findings to key data indicators tied to the Practice Model. The validated MACWIS reports produced during the Olivia Y Bridge Plan are presented in graph format and provide a vehicle for regions to examine their performance on these indicators and to see statewide performance quarterly.

MACWIS data dashboard reports and management reports are utilized during regional CQI Team meetings to identify trends related to casework on a county and regional level.

Systemic factors: In evaluating systemic performance, the CQI system gauges the capacity of the child welfare "system" to support interventions with children and families that are consistent with the practice model and to help them achieve positive outcomes. Among the systemic factors to be monitored are:

* Training of staff and providers

* Service array

* Placement resources

* Caseloads

* Oversight and monitoring

* Court processes

* Data Quality and Usage

In each county/regional onsite review, CQI reviewers will survey the appropriate stakeholders who have first-hand knowledge of these systemic areas, and review supporting documentation. For example, in evaluating the service array systemic factor, CQI will survey service providers, Workers, supervisors, and consumers to determine the extent to which needed services are in place, are readily accessible to children and families, and can be tailored to meet their individualized needs. Information derived from case reviews on the provision of services will be used to supplement information from the stakeholder surveys.

The resulting CQI reports of county/regional reviews identify the findings of case reviews and data reports as well as findings pertaining to systemic factors.

H.Reports and Feedback

Providing timely and useful feedback is essential in making use of CQI findings to gauge progress and make needed improvements. CQI reports and provides feedback at several levels, as follows:

* Individual Worker feedback: In order to make the CQI process as constructive as possible, CQI reviewers (from local CQI teams and State CQI reviewers) provide immediate feedback to Workers and supervisors whose cases are reviewed. Feedback can be verbal and should include an identification of strengths and areas of needed improvement in the review findings, and helpful recommendations about how practice might be improved. Where serious concerns emerge for child safety, permanency, or well-being emerge through reviews, each local CQI committee and State CQI should have a protocol for notifying responsible parties and requesting immediate action.

* County/regional feedback on reviews: Following State CQI reviews and at intervals in local CQI teams' review activities, verbal feedback should be provided to administrators that identifies strengths and areas of needed improvement in practice and systemic functioning. Administrators should be fully engaged in review activities and receive the benefits of immediate feedback in order to monitor performance and systemic capacity within the scope of their responsibilities.

* County/regional reports of CQI reviews: Written reports of State CQI reviews should be provided promptly to counties, RDs, State MDHS staff, county/regional implementation and CQI teams, and to the State implementation and CQI teams. The reports should describe the strengths and areas of needed improvement of practice and systemic capacity identified in the reviews, along with recommendations for making the needed improvements. Where responsibilities for making needed improvements lie with stakeholders outside of MDHS, those needs are to be clearly identified in the reports. At periodic intervals, local CQI committees also summarize the findings of their reviews for the same purposes.

* State CQI report: At least every six months, State CQI will issue a comprehensive report of its findings from reviews conducted during the preceding six-month period, along with the status of counties/regions in the State on performance indicators identified through data and other reports. These reports have a broad distribution within and outside MDHS, including the Department's administration and external stakeholders, particularly advisory groups and implementation teams at the State and local levels. The State CQI report should include information from sources other than CQI reviews that also evaluate performance, such as the findings of the Foster Care Reviews, Special Safety Reviews, data from serious incident reports, other State and Federal reviews/audits, and pertinent findings from the Court Monitor's reviews. A combined report of monitoring efforts across MDHS present a more comprehensive picture of the status of children and families served by the Department than only reporting on the findings of CQI reviews.

A number of requirements included in the State CQI report are addressed by the FCR process and reports, and that information will be needed for the State CQI reports. Further, in order to address reporting requirements for other functions and processes not directly monitored by CQI, there should be coordination and information sharing with the MDHS units responsible for financial management (for information on expenditures of Federal funds), foster care licensure (for information on licensing issues and child safety while in foster care), and contracting (for information on contractors' compliance with settlement agreement provisions), all of which should be included in the State CQI reports.

* Dashboard data reports: The state has implemented "dashboard" data reports that provide current data on a number of selected performance indicators to staff and stakeholders on a quarterly basis. These reports permit frequent and updated tracking of outcomes for children and families statewide and locally more often than comprehensive CQI reports. The data indicators identified are relevant to the work of the staff in the field, e.g., the CFSR data indicators, and region-specific and comparable to statewide performance so that staff can easily see how their performance and outcomes compare to the State's performance and outcomes. Using data in this can have some effect on the quality of data entered into the MACWIS system.

I.Special Safety Reviews
1.Purpose:

The Special Safety Review process is a CQI measure which addresses the safety of children in foster care who reside in resource homes or group care facilities. These reviews are not to be confused with special investigations or licensure investigations. The results of these reviews are used to guide further improvements to assure the safety, permanency, and well-being of children while in DFCS custody. The Reviews may result in recommendations and/or corrective action to be taken by DFCS staff and/or by resource home / group facility staff.

2.Procedure:

Group care facilities / resource homes currently providing care to children in DFCS custody are determined for review as a result of meeting one of the following criteria:

a) Resource homes or group care facilities having two or more reports of abuse/neglect by resource parents or facility staff members within the previous three year time frame, as designated by MACWIS report plus any cross-referencing for accuracy deemed necessary by the Director of Evaluation and Monitoring. Substantiated and unsubstantiated reports will be included. Reports of corporal punishment will be included.
b) By special request from a senior DFCS administrator to address safety concerns, on a case-by-case basis

A MACWIS case record review is conducted to obtain history of previous allegations of abuse/neglect, licensure status, and a listing of foster children currently residing in the facilities/resource homes. An unannounced, on-site visit is made by a licensed Worker employed by DFCS to identified facilities and resource homes where foster children and resource parents or facility staff are interviewed. Observations are made of the entire physical environment to assess the safety and well-being of foster children currently residing in the resource home or facility.

Findings of the reviews are entered into an In Care Maltreatment Review instrument, which addresses strengths, areas needing improvement, and recommendations of corrective actions for the facility/resource home and/or DFCS staff. The In Care Maltreatment Review reports are submitted to the Director of Evaluation and Monitoring and to the Director of Family and Children's Services and Field Operations Director.

The information is then distributed to appropriate DFCS staff (applicable RDs, Independent Living Director, etc.) for implementing and monitoring corrective actions. Notifications of actions taken by DFCS staff or facility staff are forwarded to the Special Safety Reviewers, who then forward the information to the Director of Evaluation and Monitoring, the Director of Family and Children's Services, and the Director of Licensure, and keep track of dispositions. DFCS Director of Field Operations will be responsible for follow-up actions to be conducted by DFCS staff. The Director of Licensure will be responsible for corrective actions to be conducted by resource home or facility staff.

Any situation of imminent risk noted by Special Safety Reviewers will additionally be reported to centralized intake and/or to local DFCS staff, if it is a matter which requires a faster response than normal procedure described above.

Special Safety Reviews will be completed on cases scheduled for each quarter, with DFCS staff and facility staff being given 30 days from the date Special Safety Review results are reported to the DFCS Director and Licensure Director to address needs, complete corrective actions, and report back with actions taken as prescribed above.

18 Miss. Code. R. 6-1-A-I-XVI

Amended 5/7/2015
Amended 5/29/2015
Amended 8/29/2015
Amended 11/28/2015
Amended 6/23/2016
Amended 7/31/2016