Welcome to our latest edition of WonkCast: People Power Policy.

In child welfare, powerful narratives cite evidence to drive discussion of major issues.

Evidence can add rigor and authority to arguments over how to craft policy.

How we talk about policy can undermine the rigor and authority it rests upon.

This isn’t an academic exercise; it underpins ongoing debates as varied as whether neglect is just poverty, and whether to abolish the child welfare system.

To dig into that relationship between evidence and policy debate, I sat down with a leading researcher in this space, Dr. Jill Berrick.

She’s a Distinguished Professor and the Zellerbach Family Foundation Professor of Social Welfare at UC Berkeley.

Her book The Impossible Imperative brings to life the tensions and tradeoffs inherent in child welfare, from front-line work with families to the policy that shapes it.

Our conversation unpacks where policy narratives drift from the evidence, how that changes what’s possible, and why it matters for what’s next in child and family policy.

Sponsorship Shoutout

Special thanks to Binti for their foundational sponsorship of WonkCast.

Last week we explored where child welfare’s data gaps make it hard to see what’s happening in practice.

That surfaces a harder question: what does the evidence actually say works?

First-time contributor and child safety data expert Michael Cull takes that on in our Deep Dive.

He maps where the evidence is thin, why it got that way, and what it means for the leaders and policymakers building accountability structures on top of it.

His next piece will be available to our premium members, going into what leaders can actually do about it.

For our latest WonkCast I sat down with ACF Assistant Secretary Alex Adams to get his read on the big bet he’s making on what makes policy durable as he hits 6 months.

Let’s get into it.

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Special thanks to Binti for their foundational sponsorship of WonkCast.


Weekly Wonk Deep Dive

Where We Go Off Course When We Assume Child Welfare Should Fly

Leading without certainty when our assumptions outpace the evidence.

By Michael Cull, PhD, MSN

Protecting children is not the responsibility of any single agency or profession.

It’s the product of decisions made across healthcare, housing, behavioral health, courts, education and social services, all operating under shared expectations of what systems can prevent and control.

Yet, when tragedies occur, accountability often collapses onto child welfare alone.

This reinforces a quiet assumption: that we largely know what works, and when things go wrong, it’s because we failed to apply that knowledge correctly.

This assumption is so central that it shapes policy, leadership accountability, and public critique. When tragedies occur, the search for error begins immediately.

But what if that assumption is wrong?

What if child welfare systems are being held accountable to a standard of certainty that the underlying evidence base cannot support?

This is the first in a two-part series.

Part I makes the diagnostic case — that child welfare’s accountability structures are built on a misreading of what the evidence can realistically support in complex, real-world conditions.

Part II examines what leading under those conditions actually requires of leaders.

What The Evidence Says

Start with substance use disorders (SUD). Roughly 19 million children in the U.S. live with at least one parent or caregiver with a SUD.

That statistic alone explains why treatment has become such a central feature of child welfare practice and policy.

When a parent is engaged in treatment, systems typically interpret that fact as proxy evidence that we’re addressing risk. The evidence does not support that.

Access to treatment matters, though in many communities it remains uneven or inadequate.

Even when treatment is available and engagement is high, the evidence on its effectiveness is limited.

Outcomes are modest and highly variable even under optimal conditions– stable housing, financial resources, social support, and consistent access to care.

A meta-analysis of 118 clinical trials found that the two best-supported drugs for alcohol use disorder require treating between 11 and 18 patients, respectively, to prevent one person from returning to any drinking at all.

That’s the ceiling under ideal conditions, without the other factors families face in child welfare.

Substance use disorders are widely understood to be chronic, recurring, and remitting. Relapse is not an exception but part of the clinical reality.

In practice, treatment offers population-level probabilities, not assurances, and those probabilities were generated under conditions that differ substantially from the lives of families involved with child welfare.

When One Gap Becomes Many

The evidence around the effectiveness of substance use disorder treatment is a window into a broader problem: the limits of the evidence underlying much of what child welfare systems rely on to ensure child safety.

The families child welfare serves aren’t navigating a single condition.

They’re navigating combinations — substance use, trauma, poverty, housing instability, domestic violence, mental health needs— that interact with each other and compound over time, often across generations.

Each added layer compounds uncertainty and further thins the evidence base guiding intervention (Mao, 2024).

It is neither ethical nor feasible to randomize families with complex needs into control groups that limit treatments.

Much of what child welfare is asked to do cannot be tested under the kinds of controlled conditions that produce certainty in other fields.

What we have instead are evaluations of discrete interventions in isolation.

Trauma Focused Cognitive Behavioral Therapy (TF-CBT), for example, is effective for trauma. SSRIs reduce anxiety and depression.

Parent-Child Interaction Therapy (PCIT) can improve parenting.

No study evaluates these treatments in combination, with families in the child welfare system, over the timeframes that actually matter for children’s lives.

Yet child welfare policy and practice are often built around the expectation that interventions can reliably resolve safety concerns in isolation, even when they struggle to produce durable outcomes even under the best circumstances.

This points to an uncomfortable truth: we do not have strong evidence for much of what child welfare systems are asked to do at scale, even though we act as if we do.

The Gaps in Our Flight Plan

The field’s response has been to standardize what it can, including through practice models and standardized assessment tools.

But the evidence there isn’t more reassuring.

Signs of Safety is perhaps the most widely implemented child welfare practice framework in the world.

One of the most rigorous program rating systems in the country, the California Evidence-Based Clearinghouse for Child Welfare, lists it as “Not Rated,” meaning it lacks the body of research required for even a preliminary evaluation.

The assessment tools structuring child welfare’s most consequential decisions were designed to support professional judgment, not replace it.

They were never designed to produce objective truth about risk (Lyons, 2022).

Like airlines and surgical teams, child welfare is being asked to predict low base-rate events that are as unacceptable as they are rare, like serious harm and fatalities.

We ask child welfare to do this across long timeframes, amid multiple chronic conditions.

That is an extraordinarily difficult prediction problem even with a strong evidence base. Child welfare doesn’t have one.

Mind The Accountability Gap

Child welfare leaders are asked to lead systems whose accountability structures are built around expectations that treatment science and social intervention cannot reliably support.

No system operating amid chronic conditions, layered adversity, and low-base-rate risk can guarantee that nothing ever goes wrong.

Even in highly controlled, well-resourced environments like hospitals, where risks like hospital-acquired infections are addressed over shorter timeframes, outcomes remain probabilistic rather than guaranteed.

Child welfare operates under far longer timelines, across multiple systems, and with far less control.

When the implicit expectation is perfection, the consequences are predictable.

Leaders manage to the expectation rather than the reality. Errors get concealed rather than examined.

Accountability becomes about finding who failed rather than understanding what conditions made failure more likely.

And institutional learning — the only mechanism that actually improves outcomes over time — becomes nearly impossible.

The accountability gap isn’t just unfair to leaders. It makes the system less safe.

None of this reduces the urgency of protecting children. It clarifies what it actually takes to protect them.

To Err is Human: A Workforce Already Past Its Limit

Even the modest gains evidence-based approaches can deliver depend on fidelity; the degree to which interventions are delivered as designed and tested.

The effect sizes reported in clinical trials are a ceiling of impact, generated under conditions of close supervision, adequate staffing, and practitioner competence.

When those conditions do not hold, the ceiling drops.

Over half of the U.S. population now lives in a mental health professional shortage area. 93 percent of behavioral health workers report having experienced burnout, with nearly half saying workforce shortages have prompted them to consider leaving the field entirely.

Annual departure rates in child welfare are estimated at 20 to 40 percent, with the average worker remaining in their position less than two years.

This is not a pipeline problem alone.

It is a structural condition of the systems being asked to deliver evidence-based practice.

The evidence base is already thin. The workforce needed to implement what evidence exists is in crisis.

The ceiling on what child welfare can reliably deliver is lower than the accountability structures governing it acknowledge — and it is getting lower.

The gap between what child welfare is expected to deliver and what the evidence can support isn’t a leadership problem.

It’s a structural one that we can actually do something about.

Until the field names it as such, the accountability structures governing child welfare will continue to make the system less capable of doing the very things they’re designed to ensure.

This is neither a dead-end nor destiny. There are shifts leaders can make that move the needle.

In Part II, we examine what leading under these conditions actually requires — and what it looks like when leaders build organizations capable of learning faster than they fail.

From the Wonk Briefing Room

Where the Weekly Wonk gives you a map of the terrain child and family policy faces, our premium resources aim at how to navigate it.

Last week, we held a member-only virtual roundtable, digging into the opportunities and challenges the Home for Every Child initiative pose for your work.

We also released a premium brief from Kurt Heisler, digging into what would create meaningful change in child welfare technology policy.

It’s an actionable guide to why prior federal efforts to modernize child welfare IT have stalled, and how to understand the new ACF Child Welfare Technology Incubator.

To read the full brief and access all our premium resources, join the Wonk Briefing Room. Individuals can sign up here, or get the team membership rate here

Wonkatizer

ACF Maps Prevention Push

What Happened

ACF has launched an interactive map and resource hub providing public access to Title IV-E Prevention Plans.

The tool shows whether each state’s plan is approved, under review, or not yet submitted, and which evidence-based services from the Title IV-E Prevention Services Clearinghouse it includes.

ACF is also signaling an expedited review process for states that adopt substantially similar language from an already-approved plan.Why it Matters

Why it Matters

Other sectors like Medicaid have long had public transparency for state plans and modifications to them.

This gives insight into patterns and trends, and makes it easier to adopt approved approaches. States can replicate them without starting from scratch.

The expedited review signal is consequential, and could accelerate uptake.

What to Watch

Whether the expedited review process produces measurably faster approvals in practice, and whether it accelerates adoption.

Of course, the real underlying rate limit is written into the law. ACF action can only go so far, so this also points to a longer-term deliberation as part of financing reform.

–

That’s it for this week. Stay sharp, Wonks.

~Z

Partners Making Your Weekly Wonk Possible

Welcome to our latest edition of WonkCast: People Power Policy.

ACF Assistant Secretary Alex Adams has moved quickly in six months on the job.

He’s rapidly advanced initiatives, reshaped oversight processes, and pushed on the edges of what’s permissible and possible in federal child welfare policy.

Our conversation dug into the tradeoffs underneath his decisions, exploring how they’ve shaped his actual understanding and use of federal power across ACF’s:

• Rollout of the A Home for Every Child initiative;

• Incentives, and looming pressure, for states over Social Security survivor benefits;

• Push to expand the reach of the Family First Prevention Services Act; and more.

At the center of his strategy is a big bet that policy durability comes not from encoding it into regulation but making it too hard to unwind through buy-in.

This is essential for understanding what the first six months signal for what’s ahead.

Sponsorship Shoutout

Special thanks to Binti for their foundational sponsorship of WonkCast.

Our field is navigating volatile terrain with incomplete maps.

That’s the problem our premium Wonk Intelligence Quarterly is built to solve.

This is forward guidance and what to do about it for leaders making real decisions under live conditions of constraint, not analysis for its own sake.

Our premium members received the full WIQ last week; our Deep Dive this week is an excerpt. To read it in full, join the Wonk Briefing Room.

Premium members get all our member-only resources and events, including a roundtable this Thursday on what A Home For Every Child means for you.

Individuals can sign up here, or get the team membership rate here.

Our latest WonkCast was our first AMA — your questions on navigating policy and political reality, decisions under constraints, and what child welfare is actually for.

Let’s get into it.

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Special thanks to Binti for their foundational sponsorship of WonkCast.


Weekly Wonk Deep Dive

We Don’t Know Ourselves:
Child Welfare’s Knowledge Crisis

How solvable data, analysis, and measurement constraints limit policy decision quality.

By: Laura Radel, Senior Contributor

Every year, hundreds of thousands of children enter the child welfare system.

Caseworkers make decisions that will shape the rest of their lives: whether to remove a child, where to place them, when to reunite a family.

Those decisions depend on what the field knows.Yet the field does not know enough.

Decades of research, federal investment, and policy reform have not resolved the field’s most basic questions: what works, for whom, and under what conditions.

Many of the same debates that dominated child welfare thirty years ago still dominate it today.

At the heart of the field’s paralysis is a three-part knowledge problem:

1. A data infrastructure problem. Our core data sets do not tell us what we need to know and are in many aspects unreliable.

2. An interpretation problem. We do not make good use of the data we have and frequently misinterpret its signals.

3. An invisibility problem. Important subpopulations are excluded from our data, and inadequately reflected in our program and policy decisions as a result.

The Data Infrastructure Problem

The child welfare system’s national data derives primarily from three administrative systems:

• The National Child Abuse and Neglect Data System (NCANDS) collects child-level data on every maltreatment report.

• The Adoption and Foster Care Analysis and Reporting System (AFCARS) covers every child in foster care or placed for adoption by a public child welfare agency.

• The National Youth in Transition Database (NYTD) surveys foster youth at 17 and follows a subset at 19 and 21.

NCANDS and AFCARS have been collecting data since the 1990s; NYTD since 2010.

These systems were built primarily to record measurable events: maltreatment investigations, foster care placements, and certain attributes of the events and the children and families involved.

They are most reliable for documenting what happened.

They are considerably less reliable for explaining why – the circumstances, decisions, and family factors that drove those events.

In addition, despite the Administration for Children and Families’ standardization efforts, reporting differences across states persist, and data are unavailable until more than a year after the period they describe.

AFCARS was updated in 2020, but many new or revised fields have not yet been reported publicly, and promised longitudinal functionality has not yet been fully realized.

These consequences show up in specific ways.

Neglect Definitions

Most children come to the attention of the child welfare system because of neglect. Yet state definitions of neglect vary widely, and circumstances deemed neglect may be very different from one another, calling for different responses.

Maltreatment Deaths

NCANDS captures only a portion of child deaths related to maltreatment, limiting our ability to analyze patterns and prevent future harm to other children.

Re-Entry

Tracking re-entry to foster care, particularly from adoption and guardianship placements, has been a perennial problem, hampering efforts to support children and families through post-permanency challenges.

Family Circumstances

Across both NCANDS and AFCARS, fields relating to the problems that led to the maltreatment report or foster care placement are used inconsistently by states.

For instance, with respect to substance use as a reason a child is removed and enters foster care, AFCARS estimates range from under 10 percent to over 60 percent.

Knowledgeable professionals do not believe this variation primarily represents actual differences in prevalence of that magnitude, but rather differences in reporting practices.

The Interpretation Problem

Unreliable data is only part of the problem. The field also misreads what it has.

Three patterns stand out.

National Averages Mask State-Level Variation

National-level analysis frequently obscures trends that differ substantially among states.

A line that may look flat nationally may obscure big gains in some places and losses in others. Or a statistic that may look small nationally may be large in some places.

For instance, TANF spending represents 8 percent of states’ federal child welfare funding nationally, but in three states it was more than half of such funding, while in other states it was zero.

Similarly, knowing that about half of terminations of parental rights occur within the Adoption and Safe Families Act timeline masks the fact that states ranged from 16 percent to nearly 90 percent.

Recognizing the range of variation can point to insights about the policy and practice drivers of differences and the differential impacts of policy changes for states.

For advocates, funders, and other national organizations who care about federal policy, these insights also point to explanatory factors driving the small-p politics policy lives by.

Published Reports Make Trend Analysis Difficult

Published analyses such as the annual AFCARS, Child Maltreatment and Child Welfare Outcomes Reports make it difficult to track progress on measures over time at the state level.

For instance, in the new AFCARS Dashboard, one can view a state’s figures for only a single year at a time and only a few national trends (like the total number of children in foster care) can be viewed over a several year period.

Looking at just a few years at a time we also overlook long-term trends, such as the transformation of title IV-E from what began primarily as a foster care program but now consists largely of children receiving adoption subsidies.

A lot of work goes into these reports, they sit atop a gold mine of data, and yet paradoxically their format makes inevitable a simplification that obscures signal.

Cross-Sectional Analysis Has Dominated Where Longitudinal Analysis is Needed

What matters for policy is a stable picture of trends over time. Longitudinal analysis provides that, but we have very little of it.

It’s much harder to make sustainable policy decisions with point-in-time data. That’s what we’re drowning in, since most of our collections are cross-sectional analyses.

Until the updated AFCARS 2020 (which began reporting data for 2023), tracking children longitudinally in federal foster care data was difficult.

Cross-sectional analysis has significant limitations, and as far back as 2004 the Pew Commission on Children in Foster Care recommended outcomes be tracked using longitudinal rather than cross-sectional data.

Effective financing and policy decisions rely on an understanding of the most common experience, with guardrails to manage the edge cases.

Longitudinal analysis looks at a system’s flow, better capturing the trendline experience of the typical child, which is key for shaping policy.

Cross-sectional analysis looks at a system’s stock, what’s present right now.

That means cross-sectional analysis over-represents children in foster care for long periods, distorting our picture of the typical experience.

Conversely, it also obscures what we understand about exits from care; exit cohorts in such data are weighted to children who have short lengths of stay.

The field is only now beginning to have the data infrastructure to do it. It will also need interpretive infrastructure to make meaning from that and shape policy and financing.

The Invisibility Problem

Unreliable data and misinterpretation are problems with what the field collects.

The invisibility problem is different.

Entire populations and system actors are simply absent from the data, so policy decisions impacting them are made without them, leading to policy drift.

Four blind spots stand out.

Children Screened Out Before Investigation

NCANDS does not collect information on children whose maltreatment reports are screened out prior to investigation. This is not a small population, or an irrelevant one.

These 2 million children annually represent about half of all children referred to child protective services agencies each year.

Research shows that many families who are screened out are very much like those classified as higher risk, and many will be reported again.

Children in “Hidden” Foster Care

Many children – estimated at between 100,000 and 300,000 children per year – are diverted from formal foster care, typically to relative caregivers who may not receive financial or social support.

In addition, reunification services are generally not provided to parents in these circumstances.

These children are very like others who are formally placed in relative foster care but are invisible in the data of states that use this practice.

Foster care rates are declining. Does a shift to diverted “hidden” foster care explain part of that story? We can’t answer that question because we don’t have data on it.

Courts’ Roles

Child welfare outcomes depend not only on agencies’ actions, but also on the timeliness and quality of court decisions.

Yet little information on courts’ activities is available in federal child welfare data, despite their central role to decisions on placements and much more.

That means we’re lacking insight into a critical dependence that shapes accountability and oversight in child welfare financing and policy.

Foster Parents

While some information is collected about foster parents, this information is insufficient to understand the movement of children in and out of foster homes, or to calculate measures such as the Home for Every Child ratio that is currently an ACF priority.

At minimum, the collection of an identifier for the foster home would be necessary to track how many foster homes are active during the reporting period, how many children spent time in the home, and the patterns of children’s movement in and out of the home.

Consequences and Resolution

The lack of reliable data, the misinterpretation of the data we do collect, and the omission of some populations combine to prevent an adequate understanding of the activities and outcomes of the child welfare system.

The data are not well-suited for ensuring accountability or continuous improvement.

The data infrastructure problem is a federal responsibility.

ACF controls the data systems, sets the definitions, and determines what gets reported.

Leaders with federal relationships — whether through advocacy, oversight, or technical assistance — could emphasize accelerated implementation of AFCARS 2020’s longitudinal capacity and for expanding what the systems are designed to capture.

The architecture of federal data shapes what every state can know.

The interpretation problem is solvable now, with existing data.

State leaders and their philanthropic partners do not need to wait for better federal systems to begin analyzing trends longitudinally, disaggregating national findings, and interrogating what their own data actually shows.

The gap here is analytical capacity and will, not data availability. That’s a large reason for Child Welfare Wonk’s creation and approach.

The invisibility problem requires deliberate investment.

Screened-out families, hidden foster care, court behavior – none of these will become visible through administrative data reform alone.

Federal and state leaders will need to expand what the systems are designed to capture.

Philanthropic funders can support the research needed to document these populations in the interim, but the long-term solution is structural, not supplemental.

None of these are academic problems. They’re solvable constraints on the quality of policy decisions and how we track and refine them over time.

Leaders who understand that have a clearer sense of where to push.

Wonkatizer

Bipartisan Older Youth Roundtable Features FLOTUS

What Happened

First Lady Melania Trump made a rare Capitol Hill appearance Wednesday for a bipartisan roundtable with House Ways and Means Committee members and young people who have experienced foster care.

Discussions anchored to six legislative proposals that would modify the Chafee program for older youth, emphasizing housing, education, and workforce preparation.

While cost neutral, the proposals would expand what the program can cover and how it supports young people.

Why it Matters

A FLOTUS appearance like this is anything but pro forma. It generates momentum in an otherwise complex political environment.

Even without new funding or significant structural policy reforms, that momentum offers an opening to cultivate new champions and create conditions for future change.

What to Watch

Whether a consolidated legislative package comes together that can garner momentum. Watch for signals of negotiation and potential markup timing.

–

That’s it for this week, Wonks!

Z

Partners Making Your Weekly Wonk Possible

Welcome to our latest edition of WonkCast: People Power Policy.

This week, we’re doing something different.

We asked for your questions about what you’re grappling with right now, and some key themes emerged:

• Navigating the relationship between policy and political reality;

• Making decisions under real constraints; and

• Identifying and asserting what a system like child welfare is actually for.

Joining me to pose your questions is WonkCast team member Ivory Bennett.

Ivory sits in on and edits each week’s episode, and she also hosts her own podcast, the excellent Inner Views.

She not only prompts what you want to hear but brings her own perspective from time in foster care and as a foster and adoptive parent.

Your questions and the deeper tensions they point to sharpened my thinking, and I’m sure they’ll do the same for yours. If you have more, add them here for next time.

In addition, there’s a sneak preview excerpt of our forthcoming Wonk Intelligence Quarterly, which will drop for all premium members on Friday, April 17th.

To read the full WIQ and all our premium resources, join the Wonk Briefing Room. Individuals can sign up here, or get the team membership rate here

Sponsorship Shoutout

Special thanks to Binti for their foundational sponsorship of WonkCast.

Welcome to the latest Weekly Wonk.

This week’s Deep Dive is from yours truly, unpacking an unpopular yet persistent policy; parents relinquishing custody of children to access behavioral health services.

It’s an issue worth understanding in its own right, and as emblematic of how policy drift by design can reliably produce outcomes for which nobody argues.

Premium members are reading Laura Radel’s latest analysis, with state-by-state insights on what’s driving shifts in the number of children in care and available placements for them, and why it matters for strategy on A Home for Every Child.

Our latest WonkCast features Jeff Hild, SVP for Advocacy at the American Academy of Pediatrics and former head of ACF, with great insights on what policymakers and advocates each wish the other knew.

As an alum of the policy team he now leads, I enjoyed getting to sit down with him and hear how he thinks about policy, advocacy, and strategy.

Let’s get into it.

Special thanks to Binti for their foundational sponsorship of WonkCast.

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Weekly Wonk Deep Dive

Mental Health’s Shadow Ticket: When the Cost of Care is Custody

When everyone decries a persistent policy outcome, look for drift by design.

By Zach Laris, MPH, Wonk Founder & President

Pediatric mental health presents a persistent “everybody knows” policy problem.

The need for quality care continues to rise. Yet availability remains consistently constrained, especially for high acuity intensive services for kids in crisis.

A shadow ticket for services has existed for decades, despite lacking defenders.

When things get desperate enough, parents with no other options can relinquish their children to child welfare. This is despite not having abused or neglected them.

Relinquishment unlocks Medicaid-funded services. This is custody for care.

If you ask child welfare leaders, policymakers, service providers, front-line case workers, advocates, or families, they all agree it’s a lamentable last resort.

Yet it persists. A GAO report first flagged it as a national problem in 2003.

Recently, The Imprint launched an investigative series on it, anchored in new survey data and interviews with families.

This policy breakdown is worth seeing clearly, and so is the gap to which it points.

A policy doesn’t persist despite broad and strong opposition unless it’s what a system is designed to produce, even if unintentionally. Here’s how this one became inevitable.

All Aboard

No family’s first thought when facing a child’s mental health crisis is to turn to the child welfare system. They encounter a predictable pattern that drives them there:

• A child’s serious behavioral health needs progress beyond their capacity;

• Even with private coverage, available treatment doesn’t work, or is insufficient;

• Residential and intensive outpatient options are unavailable geographically, financially, or both;

• Crisis deepens, often reaching a point where safety can become a concern.

Parents find themselves talking to the child welfare system because no one else seems to have a ticket out of their situation.

The system offers one, but at the cost of custody.

In some jurisdictions, parents have to accept a charge of neglect or abandonment. In others, a voluntary agreement allows no charge of wrongdoing.

Once the system holds formal legal responsibility for the child, new options emerge.

Charting the Course

This practice is prevalent enough to show up as an explanatory factor for foster care entries.

A 2025 ASPE analysis estimated that from 2017 to 2019, this practice accounted for roughly 5 percent of foster care entries nationally, or 25,000 children.

State variation is significant, ranging from likely explaining less than 1 percent to nearly one-fifth of entries.

The Imprint has collected data from 21 states and DC, finding that over half of children in these arrangements return home.

Those who remain in care are less likely to achieve permanence than children who enter care for other reasons.

Nobody defends this on the merits. But when a system produces an outcome this reliably, you can be sure it’s a design feature.

Drift by Design

In 2021, a quarter of all children had a diagnosis for a mental, behavioral, or developmental disorder.

This creates pressures on the treatment system across income and insurance status.

Theoretically, private insurance covers behavioral health services.

In practice, a quarter of children’s mental health facilities are for-profit providers often unlikely to accept anything but cash.

Others operate at or near capacity with long wait times.

Privately insured, middle-income families hit these same walls.

Their coverage can’t offer what state custody often can. This emerges from the confluence of several policy realities, each seemingly innocuous.

Our health financing and treatment system defaults to optionality and flexibility, emphasizing coverage without guaranteeing access.

The intent is matching cost and coverage to a family’s choice and budget, even if the reality of rising costs complicate that.

Public coverage aims to buffer below an income threshold, but often has gaps.

The place where guarantees do emerge is within state obligations and responsibilities.

When the state takes parental responsibility, commensurate expectations of care reasonably follow.

The legal responsibilities also come with pressures and requirements on the state to secure access where any other arrangement other than personal wealth hits a wall.

Most children who enter care are categorically eligible for Medicaid, and it covers around 99 percent of those in care.

Medicaid is also a foundation of all U.S. behavioral health financing.

These threads synthesize into an uncomfortable reality; crisis-level mental health often requires private wealth or custody-obligated care financing.

This is also incredibly inefficient. By the time families choose this option, public resources finance it in the most costly way imaginable.

Structural reductions to federal Medicaid financing under the One Big Beautiful Bill Act will only further compound these pressures.

Nobody chose this in a vote. Nobody advocated for this. But it’s what we designed for over time, and it will persist without a structural redesign.

Designing Differently

It would be easy if this policy problem had a villain, but drift like this almost never does. Structural incentives and inertia reinforce it.

Changing them will take more than condemnation. Intentional design takes tradeoffs.

When evaluating policy options, the risks, costs, and benefits seem clear. But this can obscure that the status quo is also a choice with its own risks, costs, and benefits.

The uncomfortable reality is that this isn’t the “least bad” option until we craft a policy; this is our policy, and will remain until it has an equally inevitable replacement.

The question for leaders and policymakers is whether there is a politically viable alternative: a shift in children’s behavioral health financing broad and cross-partisan enough to move.

Coming up with something different will require grappling with significant tensions and trade-offs beyond the understandable frustration such a breakdown generates:

• How to build and sustain a treatment system that can meet demand with quality;

• What the workforce to meet these needs would look like, and how to produce it;

• How to craft policy so public and private financing secure access affordably;

• What it would look like to create a backstop to ensure access without accelerating costs;

• Where to balance obligations for access, so care unlocks without custody;

• How Medicaid could kick in sooner, at lower cost, to avoid relinquishment;

Until then, this is the policy we have, and what it demands shouldn’t surprise us.

From the Wonk Briefing Room

Every Friday, members of our premium community, the Wonk Briefing Room, get our latest Wonk premium brief.

Where the Weekly Wonk gives you a map of the terrain child and family policy faces, our premium resources aim at how to navigate it.

This week’s brief is the third installment of Laura Radel’s series on ACF’s Home for Every Child initiative.

For state leaders, service providers, advocates, and others, it offers state-by-state data to kick off strategy and planning conversations.

To read the full brief and access all our premium resources, join the Wonk Briefing Room. Individuals can sign up here, or get the team membership rate here

From Our Radar to Yours

Reconciliation Redux?

What’s Happening

While far from guaranteed, the possibility is rising for another partisan reconciliation bill financed through cuts to health and human services programs.

Senate GOP leadership is looking at expediting a budget reconciliation bill this month, to end the ongoing 58-day shutdown of the Department of Homeland Security (DHS).

There is also discussion of a subsequent partisan reconciliation bill on restrictions to voter registration and expanded accountability controls in safety net programs.

A bipartisan path to reopening DHS broke down over intractable differences in talks on reforms to place limits on and accountability on ICE agents.

Senate Republican leaders are eyeing reconciliation to sidestep that issue. That could potentially move on an expedited timeline through the Senate as soon as this month.

Doing so comes with its own challenges.

While warming to the idea, House Republicans previously rejected this pathway for not also including the House-passed Safeguard American Voter Eligibility (SAVE) Act.

The possibility of an additional reconciliation bill could defuse that opposition.

Why it Matters

Calls for additional partisan reconciliation touching on safety net programs have been percolating since earlier this year.

This would be on top of federal Medicaid cuts in the One Big Beautiful Bill Act.

Policy discussions over alleged fraud and safety net programs, including ACF funding restrictions, have impacted programs including:

• Temporary Assistance for Needy Families (TANF)

• Social Services Block Grant (SSBG)

• Child Care Development Fund (CCDF)

Cuts to TANF and SSBG were originally part of discussions for reconciliation last year. Changes to those programs, Medicaid, and more could be on the table.

What to Watch

Reconciliation is never a safe bet. Watch for signal, not noise.

First to track is what is in the potential reconciliation instructions to reopen DHS.

That’s likely to be narrowly targeted to DHS funding unless there are insurmountable calls for spending offsets or other policy changes.

How that goes would be an early bellwether for future reconciliation efforts.

Timing is also everything; The closer midterm elections loom, the harder it will be to advance any partisan reconciliation effort that could complicate campaigns.

That’s it for this week.

Stay sharp, Wonks.

Z

Partners Making Your Weekly Wonk Possible

Welcome to our latest edition of WonkCast: People Power Policy.

I’m Zach Laris, and this is WonkCast—where we spotlight the people, ideas, and tensions shaping child and family policy.

The constraints leaders operate under vary by the type of institution they lead. That in turn shapes what they see as possible for the future of child and family policy.

Advocates and policymakers can talk past each other when they don’t see the constraints that their counterparts are operating within.

Today’s guest has a unique vantage point on that tension, as a senior child advocacy leader who previously ran the Administration for Children and Families.

Jeff Hild is the Senior Vice President for Advocacy at the American Academy of Pediatrics. Before that, he led ACF at the end of the Biden Administration.

He offers essential and actionable insights if you’re an advocate or policy expert wanting to better influence institutional processes.

He also unpacks what shapes how advocates work in a way critical to understand for anyone making decisions about policy, funding, or research.

He has an especially sharp insight into how the very design of administrative processes determines who can participate in them, shaping who gets heard.

As an AAP alum myself, it was a particular treat to get to sit down with Jeff and hear how his public sector leadership is informing their advocacy strategy.

Sponsorship Shoutout

Special thanks to Binti for their foundational sponsorship of WonkCast.

Welcome back, Wonks, from our spring break hiatus.

When we talk about parental rights in policy debate, do we all mean the same thing?

The surface-level version focuses on autonomy while obscuring the role class plays in what parental rights assumes and emphasizes.

For families with resources, it’s about choices and optionality on things like curriculum and medical decisions; a freedom to opt out.

For families without resources, it’s more often about avoiding punitive action and accessing due process; a freedom from state scrutiny.

This week, Kimberly J. Martin unpacks what that gap points toward; harder questions around who speaks for children, and when that authority transfers to the state.

Premium members of our Wonk Briefing Room have been reading the latest from Laura Radel, further analyzing state shifts and strategies relevant to the Trump Administration’s A Home for Every Child initiative.

On our most recent WonkCast, I sat down with Sixto Cancel of Think of Us.

We discussed what matters and what’s missing in conversations on the role of lived experience in policy deliberations, and his perspective on the role of data and technology in re-imagining child welfare financing and policy related to older youth.

Let’s get into it.

Special thanks to Binti for their foundational sponsorship of WonkCast.

Subscribe now

Weekly Wonk Deep Dive

Say Less: Parental Rights, Depending on Who You Are

How class quietly explains core tensions between family and state power.

By Kimberly J. Martin

“Parental rights” is one of those phrases that sounds self-explanatory.

In policy debates, it is invoked as if it represents a single, clear principle: the authority of parents to make decisions about their children’s lives.

But the phrase functions less like a definition and more like a container.

Inside it are several different ideas: family privacy, parental authority, protection from government interference, and the state’s responsibility to safeguard children.

Those ideas do not always align. And in child welfare policy, where the state’s role in family life is most consequential, they regularly collide.

What those collisions reveal is that “parental rights” does not describe the same reality for all families. Its meaning shifts — quietly but systematically — along class lines.

And beneath that class divide lies a harder question that policy debates rarely name directly: not whether parents have rights, but who has the authority to speak for children, and under what conditions that authority transfers to the state.

Parental Rights Don't Mean the Same Thing for Every Family

The first complication is that “parental rights” does not describe the same reality for all families. In practice, the meaning of the phrase often shifts along class lines.

For more affluent families, parental rights frequently operate as a form of optionality.

The debates tend to revolve around questions of choice: which curriculum a child should follow, which vaccines should be required, which medical decisions parents should control, or the standards for homeschooling.

In these contexts, parental rights are about the ability to shape a child’s upbringing among multiple available paths; they shape the policy container in which parents select options to exercise.

For poorer families, the concept operates very differently.

Here, parental rights are often asserted in response to scrutiny, as a defense of having access to choice.

Families navigating poverty are more likely to encounter institutions that monitor family life — like child protective services, family courts, and mandated service providers.

Invoking parental rights in these settings can be less about selecting among options and more about asserting autonomy in the face of government judgment about competence, safety, and adequacy.

This distinction explains why policy conversations about shared responsibility between families and the state can take very different forms depending on circumstances.

When resources are abundant, shared responsibility can feel like partnership: schools, doctors, and service providers collaborating with parents around a child’s development.

When resources are scarce, the same arrangements can feel like supervision.

The data reflect a structural pattern, not an anomaly.

85 percent of families investigated for neglect have incomes below 200 percent of the poverty line.

Children in high-poverty neighborhoods are more than three times as likely to experience substantiated CPS investigations as children in low-poverty neighborhoods.

Wealth as an Off-Ramp

Financial means quietly shape how family challenges are handled, and by whom.

When wealthier families encounter difficulties— a child struggling in school, behavioral issues, mental health challenges—the solutions are frequently private: therapy, tutoring, specialized schooling, relocation, or temporary leave from work.

These responses allow the problem to remain within the family’s control.

For families with fewer resources, similar challenges can become matters of public record.

The same behaviors that lead one family to seek a private therapist might lead another family into mandated services, neglect investigations, or court oversight.

Wealth can turn unmet needs or mistakes into private problems while poverty can turn them into documented risks.

The Harder Question

These dynamics expose a deeper tension that rarely gets named directly: the question of children’s rights.

Policy conversations often frame parental rights and children’s rights as a trade-off.

Parents assert authority; the state intervenes when children are harmed. But that framing obscures the harder question.

Rights typically come with the capacity to exercise them, and assignment of responsibilities to uphold.

Children depend entirely on adults—parents, courts, or government institutions—to define and act on their behalf.

Which means the real contest is not between parents and children.

It is between parents and the state over who gets to speak for children, and under what conditions that authority transfers.

That is the question most policy debates avoid naming directly. And it is the one that matters most.

This tension is showing up across the political spectrum, and it doesn’t fit neatly into one container.

The reason topics varied as school curricula, vaccine requirements, and the role of the child welfare system seem to create strange cross-partisan resonance is we often look past class dynamics.

Despite their different ideological starting points, cross-partisan critiques can converge from a common concern: the scope of government power inside family life.

The fault line is not left versus right. It is families versus the state — and it cuts across both.

When Help Looks Like Control

Families often need support –- housing assistance, mental health services, and economic stability.

Even families with means rely upon public policy’s standards and assurances.

But support systems can expand the state’s presence in family life when it’s the only means of accessing support, especially when assistance is tied to monitoring or mandated compliance.

Families may need help and simultaneously fear that accepting it increases the state’s authority over their lives.

That fear is not irrational. For many families, it’s historical memory.

The field’s deeper challenge is designing support that doesn’t arrive with strings that look like surveillance.

That means rethinking how services are delivered, who delivers them, and whether accepting help can ever be truly voluntary when the alternative is system involvement.

It is precisely this question: how to build support without building state authority - that is producing an unlikely cross-partisan coalition.

Libertarians and progressive child welfare critics would not appear to be natural allies.

But both have arrived at the same place through different vehicles traveling the same road: skepticism of a system that presents itself as help while functioning, for many families, as control.

The Question the Field Keeps Avoiding

“Parental rights,” then, is not just a debate about family autonomy.

It is a debate about the boundaries of government power, the conditions under which the state can and should intervene in private life, and the ways those boundaries are experienced differently depending on resources.

The central question, then, is where the state’s role in children’s lives begins and where it must end.

Is it designed to strengthen families or substitute for them, and who gets to decide?

Say less.

Kimberly Martin is a policy strategist whose work brings legal insight and lived experience to the child welfare conversation.

From the Wonk Briefing Room

Where the Weekly Wonk gives you a map of the terrain child and family policy faces, our premium resources aim at how to navigate it.

Our most recent release maps how every state’s ratio of foster homes to children in foster care shifted between 2020 and 2025.

Sixteen states increased their ratios. Twenty-two saw declines.

The picture is uneven — and the direction each state has been moving matters enormously for how they approach the work ahead under HFEC.

For leaders trying to understand where their state actually stands before ACF’s initiative shapes expectations, this piece is the map to drive your strategy.

To read the full brief, see the state-by-state map, and access all our premium resources, join the Wonk Briefing Room.

Individuals can sign up here, or get the team membership rate here

Wonkatizer

FY27 PresBud Drops

What Happened

Last week, the President’s Fiscal Year 2027 Budget Request dropped, along with detailed appendices by agency.

It would cut non-defense discretionary spending by 10% and increase military spending by 42%.

First Lady Melania Trump’s proposed funding for housing vouchers for youth aging out of foster care is in again, as it was last year, up to $30M from $25M last year.

Why it Matters

President’s Budget Request is a request; it’s a non-binding wish list to inform the congressional appropriations process. It doesn’t take effect or simply happen.

That doesn’t mean it’s irrelevant. It articulates priorities worth tracking.

What to Watch

How Congress approaches the appropriations process. That was already going to be hard before the looming likelihood of budget reconciliation 2.0.

We’re watching whether the process gets going in earnest this spring, or keeps slipping closer to the end of FY26 in September, and the elections.

CSBG's Reporting Problem

What Happened

A new joint ACF and ASPE issue brief argues that the Community Services Block Grant’s (CSBG) reporting requirements obscure what the program actually funds.

Congress created CSBG in 1981 to offer flexible funds to states, tribes, and territories to alleviate the causes and conditions of poverty, and promote self-sufficiency.

Why it Matters

CSBG is a block grant that can’t clearly document what its dollars produce; that’s both a feature and a weak point in financing.

Because CSBG funds are flexible, they often fill in gaps that other investments leave behind. The impact of that kind of financing role can be essential and hard to capture.

The ASPE report makes two arguments:

• That current CSBG reporting overstates the case for the funds, as it represents ~5% of the budget of funded entities; and

• The reporting is burdensome, and therefore misses on isolating unique impact.

This is an inherent tension in flexible financing; absent a strong narrative of purpose and impact, there’s1 vulnerability to arguments of unaccountability.

What to Watch

The brief points to ways to more effectively streamline reporting requirements.

Given ACF’s current deregulatory push, and that briefs like this tend to precede ACF action, a looming shift on CSBG reporting is a smart bet.

It’s worth tracking whether the focus remains on reporting or shifts to the funding.

That’s it for this week.

Stay sharp, Wonks.

Z

Partners Making Your Weekly Wonk Possible

Welcome to our latest edition of WonkCast: People Power Policy.

What’s the core tension between data and personal perspective in shaping child welfare policy?

Pure abstraction in policy can lead to an exploitative or extractive approach to direct experience in service of rigor; the “tell your trauma to advance our policy” model.

At the opposite extreme, pure individuation aimed at respect for personal perspective can distort policy, by emphasizing outliers and edge cases over what the data elevate.

Today’s guest is building the institutional architecture to balance that respect and rigor, by creating data-driven insights about direct experience of child welfare at scale.

Sixto Cancel is the founder and CEO of Think of Us, a social sector research and design lab working to transform child welfare by leveraging lived experience.

We talked about his work scaling individual perspectives into data to reshape policy debates, and its implications for the processes through which leaders make decisions.

We also discussed his vision for reshaping national policy related to older youth, and why he thinks it should go beyond the confines of the current Chafee program.

If you’re interested in how data-driven disruption and technology could restructure child welfare policy, this conversation is for you.

This WonkCast will be your final of March; we are on a Spring Break hiatus next week before returning to your regularly scheduled programming the week of April 6th.

Sponsorship Shoutout

Special thanks to Binti for their foundational sponsorship of WonkCast.

In December, the Administration for Children and Families directed 39 states to stop using children in foster care’s Social Security survivor benefits to offset care costs.

More complex policy questions are next. What follows that directive is a set of governance, fiscal, and operational questions that hinge on:

• how state and county systems are structured;

• how much budget flexibility they have; and

• how courts respond to scrutiny for formerly administrative financial decisions.

This week, first-time Wonk contributor Sarah Catherine Williams of Child Trends maps what’s happening, what’s at stake, and the more complex issues ahead.

Last week, our premium community got Christine Bork’s latest brief on a four-part criteria for leaders fundraising from philanthropy amid declining federal funding.

On our most recent WonkCast, I sat down with Laura Berntsen to get her insider perspective as one of the core architects of the Family First Prevention Services Act.

She offered a masterclass on how Hill staff think and work that is key for anyone working on federal policy.

This Weekly Wonk will be your final of March; we are on a Spring Break hiatus next week before returning to your regularly scheduled programming the week of April 6th.

Let’s get into it.

Special thanks to Binti for their foundational sponsorship of WonkCast.

Subscribe now

Weekly Wonk Deep Dive

A Simple Mandate, A Complex Transition

What happens after states stop taking children's Social Security benefits?

By Sarah Catherine Williams

In states across the country, child welfare agencies have been applying to be representative payees and collecting Social Security survivor benefits on behalf of children in foster care to cover the cost of that care.

According to an unpublished analysis of child welfare financing data, Child Trends estimates that 25 states reported spending over $34 million in survivor benefits in SFY 2020.

Earned through a deceased parent’s work record, these funds flow to the agency, which uses it to defray foster care expenses, rather than reserving it for the child’s future use.

In December, the Department of Health and Human Services (HHS) Administration for Children and Families (ACF) directed 39 states to halt the practice.

That directive seemingly resolves a moral debate while simultaneously opening a more complicated governance one.

States are no longer deciding whether to conserve children’s benefits.

They are deciding how– and who will pay for the foster care costs those benefits had been covering.

Those choices will reverberate through budgets, courtrooms, and the lives of youth long after the headlines fade.

And they raise questions for other financial benefits to which youth may be entitled, and how policy will direct public agencies to manage them.

A Fiscal Shift That Lands Unevenly

As with most child welfare policy, a uniform federal directive will produce uneven consequences across states.

State-administered systems may centralize decision-making and absorb fiscal shifts more predictably.

County-administered systems may face uneven implementation and fiscal pressure across local jurisdictions.

States with greater general fund flexibility can backfill lost revenue.

States heavily reliant on Title IV-E or constrained state budgets will feel the loss more acutely, and have harder tradeoffs to consider.

What looks like a compliance directive actually yields a redistribution problem

Which Benefits to Conserve and Why It Matters

The directive centers on survivor benefits, which are monthly payments to the children of deceased parents who paid Social Security taxes.

But it forces a broader question: where should states draw the line?

In many states, agencies have also applied to be the representative payee for children with disabilities receiving Supplemental Security Income (SSI), and have used those benefits to help cover the cost of care.

States must now decide whether to use the survivors benefits directive as precedent, and halt this practice as well. This is a far bigger policy question.

The distinction between these two benefits is not just administrative—it is structural.

Survivor benefits are administratively simpler and politically distinct, often viewed as a child’s earned insurance benefit tied to a parent’s work history.

SSI, by contrast, is means-tested public assistance, governed by strict asset limits and complex eligibility rules.

There is also a symbolic tension: with survivor benefits, the state appears to be taking a child’s private benefit.

With SSI, the state can argue it is swapping one form of public assistance for another.

Where states draw this line will determine both implementation complexity and public perception.

And absent any incentive or requirement to conduct eligibility work, will fewer children end up receiving any benefits?

Timing Creates Winners and Losers

How states implement the directive may matter as much as whether they comply.

Do states stop the practice immediately for all youth? Or apply the change prospectively?

A cutoff date risks creating two classes of foster youth:

• youth whose benefits were previously used to offset care, and

• youth whose benefits are conserved going forward

That distinction could then trigger equal protection challenges and deepen inequities among similarly situated young people.

Retroactive eligibility claims add another layer of complexity. Do states owe youth “back pay” for benefits used to offset the cost of foster care?

Implementation timing, in other words, is actually a distributional choice.

From Custodian to Fiduciary—And Back Again

Conserving benefits is not as simple as declining to spend them.

Funds cannot remain indefinitely in an agency’s general ledger, which means states must determine where and how they will be held.

Survivor benefits could be placed in high-yield savings accounts, or private trusts.

To preserve eligibility, SSI funds may need to be deposited into special savings accounts, such as Achieving a Better Life Experience (ABLE) accounts, or other tax-advantaged investment accounts.

In effect, agencies are stepping into a fiduciary role that many are neither staffed nor trained to manage.

Some states, including Michigan and Ohio, are moving toward a centralized state oversight approach to ease the burden on local offices.

Others may rely on local offices and case workers, distributing fiduciary responsibility to a workforce not equipped to carry it.

This is a capacity question, not just a policy one.

The Reunification Problem No One is Talking About

The complexity doesn’t end there.

Much of the public conversation has focused on youth aging out of foster care—but nearly half of children in care reunify with their families.

When custody ends, conserved funds plus interest are returned to the Social Security Administration, and the reunified parent or guardian must again apply to become the child’s representative payee.

Only then are the accumulated funds transferred back to the parent or guardian for the child’s use.

That moment—when legal custody shifts and a potentially significant sum changes hands—is both administratively delicate and financially high-stakes.

When Transparency Meets the Courtroom

ACF now expects agencies to notify children’s attorneys or legal advocates when they apply to be representative payee.

That transparency, while necessary, also changes the risk profile.

Financial decisions that were once administrative may now be contested.

For example, if an agency uses survivor benefits for a clothing allowance, counsel may argue that the foster care rate should have covered it.

The result: routine financial decisions become litigable events.

The administrative burden of defending those decisions may erode the very fiscal gains the policy seeks to protect.

What Actually Changes Now

The debate over conserving foster youths’ Social Security benefits has largely been framed as a question of right versus wrong.

That framing is incomplete.

The directive does not just change whether funds are used. It changes how child welfare systems allocate financial responsibility, manage assets, and absorb risk.

• Fiscal substitution: whether to backfill with Title IV-E, state general funds, or local dollars, and where the pressure lands.

• Operational capacity: who manages funds, how financial decisions are documented, and whether agencies can function as fiduciaries.

• Legal exposure: how courts interpret these changes, and how often financial decisions are contested.

Stopping this practice is the beginning, not the end.

What comes next will determine whether conserved benefits function as meaningful protection—or simply become another layer of complexity in a system already stretched thin.

Sarah Catherine Williams is a Senior Research Scientist at Child Trends. This work is in her own capacity and does not necessarily reflect the views of Child Trends.

From the Wonk Briefing Room

Our Weekly Wonk newsletter offers a map of the child and family policy terrain.

Our premium resources offer the strategic layer; how to navigate it effectively.

Our latest grapples with the fact that every time federal funding contracts, a question quickly follows: can philanthropy fill the gap? It’s a reasonable instinct.

But last week’s premium brief tests that instinct against a four-part framework for how philanthropic funding decisions are actually made.

Christine Bork brings a well-honed approach to this question as Chief Development Officer at the American Academy of Pediatrics.

Her answer always runs through four criteria anyone answering that question needs.

To read the full brief and access all our premium resources, individuals can sign up here, or get the team membership rate here.

From Our Radar

Adoption Hearing Ahoy

The House Appropriations Subcommittee on Labor, HHS, and Education takes up permanency this week at a 3/26 hearing: Advancing Permanency in Child Welfare: Leveraging Federal Funding for Adoption Programs.

Why it matters: Appropriations hearings inform funding deliberations, which will be challenging to advance this year amid an election.

But even outside of those decisions, a congressional hearing matters for surfacing member priorities, testing policy narratives, and noting what gets airtime.

What to watch: The hearing will feature witnesses across child welfare policy:

• Kate McLean

  • Executive Director, Congressional Coalition on Adoption Institute

• Sarah Font, Ph.D.

  • Professor, Brown School at Washington University in St. Louis

• Aurene Martin

  • Board Secretary, National Indian Child Welfare Association

• Debbie Riley

  • CEO, Center for Adoption Support and Education

What they elevate, and where members direct questions, offers insight on congressional child welfare priorities within and beyond the appropriations process.

WH AI Policy Plan Emphasizes Child Protection

The Trump Administration has issued a National Policy Framework for Artificial Intelligence, with an emphasis on “Protecting Children and Empowering Parents.”

Why it matters: The framework outlines the administration’s AI agenda for new legislation in Congress. This is an opening bid to shape that negotiation process.

As National Children’s Alliance CEO Teresa Huizar highlighted in our recent conversation, technology is far outpacing policy at the intersection of generative AI, social media, and child sexual abuse material.

What to watch: Key industry players, bipartisan congressional leaders, and the White House are all pointing to a need for a US AI policy framework.

This initial framework is a very high-level four-page document.

Divergent perspectives emerge in the details; it’s worth watching specifics in any bill proposals.

One likely tension point is the preemption of state law.

This framework calls for significant preemption, but also that”

“Congress should ensure that it does not preempt states from enforcing their own generally applicable laws protecting children, such as prohibitions on child sexual abuse material, even where such material is generated by AI.”

That’s it for this week.

Stay sharp, Wonks.

~Z

Partners Making Your Weekly Wonk Possible

Welcome to our latest edition of WonkCast: People Power Policy.

It’s easy to fall into the trap of reading a law out of context; comparing it to a perfect ideal, and then wondering why parts of it are seemingly inefficient or contradictory.

Equally easy is romanticizing a “perfect” policy fix that is unsullied by political realities, but impossible to enact, because it lacks the buy-in that trade-offs secure.

Today’s guest is a former senior Hill staffer who doesn’t just understand the realities of where policy and politics intersect, but actually navigated them to craft the biggest recent overhaul of child welfare financing, the Family First Prevention Services Act.

Laura Berntsen previously served as Chief Domestic Policy Advisor on the Senate Finance Committee for now Ranking Member Ron Wyden of Oregon.

She was one of the core staff architects of the Family First Prevention Services Act; developing, drafting, negotiating, and advancing it from a set of ideas into law.

Today, she’s a Principal Advisor at The Treasury of New Zealand, advising on income support, child welfare, and social service policy.

She shared about how to work with Hill staffers from the outside, the difficulties of weaving evidence into policy, and why “tiny little changes” are usually anything but.

Her insider perspective from “in the room” on Family First is a guide to navigating the terrain of power in Congress to encode ideas into durable financing architecture.

This builds on our recent Think Like A Staffer and What Hill Staff Wish the Child & Family Policy Understood pieces, pointing to strategic opportunities for success.

Sponsorship Shoutout

Special thanks to Binti for their foundational sponsorship of WonkCast.

Reducing parental stress and adding more trusted adults into a family ecosystem reduces child maltreatment

By Elliot Haspel, Guest Contributor

Reducing parental stress and adding more trusted adults into a family ecosystem reduces child maltreatment

American child care debates tend to organize around two arguments.

The economic case, parental (and especially maternal) labor force attachment, and the ways in which accessible child care impacts businesses and the economy writ large.

And the early childhood development case, which focuses on how good child care, or the lack thereof, impacts the rapidly growing brains and school readiness of young kids.

There is, however, a structural blind spot in the discourse: child care access plays a load-bearing role in the infrastructure that can keep children safer and families out of the child welfare system.

The evidence is substantial, and largely absent from how child care policymakers, advocates, and funders currently calculate the case for investment.

Two Mechanisms, One Overlooked Connection

There are two primary mechanisms by which child care intersects with child welfare: parental stress, and the presence of trusted adults in a family’s ecosystem.

The stress mechanism is direct.

Reduced family well-being dramatically spikes the risk of child maltreatment; when a parent is at the end of their rope and lacks an ecosystem of support, it is more likely they will take harmful actions.

The lack of affordable and accessible child care can be an isolating hammer-blow to family well-being.

Not only are there clear effects on financial security (and therefore vital elements like housing and food stability) but research has found that managing the search for and precariousness of child care is itself a significant psychological burden.

The impacts are worst for mothers, for whom unstable, unreliable child care is correlated with harms to mental health that can last six years or more.

The second mechanism is less visible but equally important.

Child care programs are often essential hubs through which new parents build informal safety nets — friendships, emergency backup care, and key parenting knowledge such as safe sleeping practices.

When child care is inaccessible, those networks don’t form.

Sociologist Mario Small has documented how central these programs are to that connective tissue.

That social isolation, combined with precarious shift work, can also lead to reliance on unsafe care arrangements, such as leaving children home alone or with adults unequipped to care for them.

What the Data Show

When child care breaks down, the effects can be severe.

Colorado’s Child Fatality Review Team has identified so many deaths correlated with a lack of child care that it made a formal recommendation that the state ensure “affordable and accessible child care for all families.”

Between 2013 and 2017, the Team identified 223 child maltreatment deaths that might have been prevented with adequate child care available.

The positive impacts of solving America’s child care challenge on child welfare, then, are also sizable.

A research team led by Dr. Henry Puls calculated that a major national investment in child care — akin to what was proposed in the Build Back Better legislation, approximately $400 billion over six years — “might reduce” child welfare:

• Investigations for suspected maltreatment by 6.4 percent,

• Victimization by 6.0 percent,

• Foster care entries by 3.1 percent,

• Maltreatment-related fatalities by 11.6 percent.

Puls’ team applied these estimates to real child welfare data from 2014-2019 and found it would yield a “striking number of potentially safer children”:

• 1.3 million fewer children investigated

• 244,000 fewer children substantiated as victims

• 9,000 fewer children entering foster care

• 1,198 fewer deaths.

Why the Blind Spot Persists

The curious absence of child welfare from discussions of child care policy can likely be tracked to a few sources.

Child welfare and child care advocates are more cousins than siblings: they may occasionally come together, but largely live apart.

That separation is both caused by and a cause of siloed federal funding streams.

This is also a symptom of a more program-focused approach to family policy that was cemented during 1990s welfare reform, as opposed to an ecosystem approach that understands and responds to the myriad influences on family well-being.

That shift has created a structural divergence which has led to downstream fragmentation of policy and advocacy communities.

Similarly, the philanthropies which both issue communities depend on rarely work across both domains, despite often having overlapping priorities.

And economists asked to calculate the benefits of child care investments are almost never asked to incorporate the effects on child welfare, or the savings from meaningfully reduced investigatory caseloads and foster care placements.

As a result, the researchers, advocates, and messengers in each domain are optimizing for their own audiences, and the connection between the two rarely gets made or resourced.

For instance, since higher income eligibility limits for child care subsidy has been linked to lower child maltreatment rates, taking a broader view may reduce the functional cost of raising those limits and make state legislatures more inclined to fund them.

Similarly, most states give some form of subsidy priority to families who are referred by state or local welfare agencies.

But given enrollment freezes and a lack of available slots in many areas, states may need to get more creative to ensure that when such a case arises, child care needs can actually be addressed.

A Solvable Problem

The structural barriers are real but not immovable.

Philanthropies — perhaps through existing collaboratives like the Children, Youth & Family Funders Roundtable — could set tables where child care and child welfare advocates and policy experts can come together to identify a common agenda and a more comprehensive accounting of benefits.

Advocates and wonks, of course, can initiate these conversations themselves, and ensure that child welfare gains are included in their analyses.

State child welfare directors could walk across the hall to state child care administrators and have a similar conversation, and vice versa.

Congress could hold a hearing or ask the Congressional Research Service, Government Accountability Office, or relevant agencies to research the intersection to inform future thinking on policy focus and approach.

Demonstrating the stark impacts that child care has on child welfare make the stakes for decision makers clear.

Public investment in child care doesn’t just impact workforce participation or child development; it’s also an upstream factor that shapes family stability and child safety.

Decisions shaping philanthropic investment, policy design, and advocacy strategy that don’t include this awareness are missing an essential element that matters for both policy communities and, most importantly, for families.

It’s time to illuminate the blind spot.

Elliot Haspel is a Senior Fellow at Capita and author of The Family Frontier, which focuses on child care and early childhood policy.

Welcome to this week’s Weekly Wonk.

While child care policy is frequent “above the fold” news, its role in reducing child maltreatment is not often part of the conversation.

That’s an opening for both of those policy communities.

This week’s Deep Dive is a guest piece from Elliot Haspel, a leading expert on child care policy and author of the excellent Substack The Family Frontier.

His piece makes the structural case for what we miss by looking at these policy domains separately.

Our premium members are reading the latest from Senior Contributor Doug Steiger, who shows the key moves to make to navigate the Hill more effectively.

For our most recent WonkCast, I sat down with Ryan Hanlon, the new Associate Commissioner of the Children’s Bureau.

It’s a key window into how the new Children’s Bureau leadership is thinking about policy priorities, long-term financing, and what’s ahead.

And in the Wonkatizer, a new ASPE brief offers a federal snapshot of where states actually stand on kinship care, and there’s changes to the child welfare policy manual.

Let’s get into it.

Special thanks to Binti for their foundational sponsorship of WonkCast.

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Weekly Wonk Deep Dive

How Child Care Access Quietly Shapes Child Welfare's Front Door

Reducing parental stress and adding more trusted adults into a family ecosystem reduces child maltreatment

By Elliot Haspel, Guest Contributor

Reducing parental stress and adding more trusted adults into a family ecosystem reduces child maltreatment

American child care debates tend to organize around two arguments.

The economic case, parental (and especially maternal) labor force attachment, and the ways in which accessible child care impacts businesses and the economy writ large.

And the early childhood development case, which focuses on how good child care, or the lack thereof, impacts the rapidly growing brains and school readiness of young kids.

There is, however, a structural blind spot in the discourse: child care access plays a load-bearing role in the infrastructure that can keep children safer and families out of the child welfare system.

The evidence is substantial, and largely absent from how child care policymakers, advocates, and funders currently calculate the case for investment.

Two Mechanisms, One Overlooked Connection

There are two primary mechanisms by which child care intersects with child welfare: parental stress, and the presence of trusted adults in a family’s ecosystem.

The stress mechanism is direct.

Reduced family well-being dramatically spikes the risk of child maltreatment; when a parent is at the end of their rope and lacks an ecosystem of support, it is more likely they will take harmful actions.

The lack of affordable and accessible child care can be an isolating hammer-blow to family well-being.

Not only are there clear effects on financial security (and therefore vital elements like housing and food stability) but research has found that managing the search for and precariousness of child care is itself a significant psychological burden.

The impacts are worst for mothers, for whom unstable, unreliable child care is correlated with harms to mental health that can last six years or more.

The second mechanism is less visible but equally important.

Child care programs are often essential hubs through which new parents build informal safety nets — friendships, emergency backup care, and key parenting knowledge such as safe sleeping practices.

When child care is inaccessible, those networks don’t form.

Sociologist Mario Small has documented how central these programs are to that connective tissue.

That social isolation, combined with precarious shift work, can also lead to reliance on unsafe care arrangements, such as leaving children home alone or with adults unequipped to care for them.

What the Data Show

When child care breaks down, the effects can be severe.

Colorado’s Child Fatality Review Team has identified so many deaths correlated with a lack of child care that it made a formal recommendation that the state ensure “affordable and accessible child care for all families.”

Between 2013 and 2017, the Team identified 223 child maltreatment deaths that might have been prevented with adequate child care available.

The positive impacts of solving America’s child care challenge on child welfare, then, are also sizable.

A research team led by Dr. Henry Puls calculated that a major national investment in child care — akin to what was proposed in the Build Back Better legislation, approximately $400 billion over six years — “might reduce” child welfare:

• Investigations for suspected maltreatment by 6.4 percent,

• Victimization by 6.0 percent,

• Foster care entries by 3.1 percent,

• Maltreatment-related fatalities by 11.6 percent.

Puls’ team applied these estimates to real child welfare data from 2014-2019 and found it would yield a “striking number of potentially safer children”:

• 1.3 million fewer children investigated

• 244,000 fewer children substantiated as victims

• 9,000 fewer children entering foster care

• 1,198 fewer deaths.

Why the Blind Spot Persists

The curious absence of child welfare from discussions of child care policy can likely be tracked to a few sources.

Child welfare and child care advocates are more cousins than siblings: they may occasionally come together, but largely live apart.

That separation is both caused by and a cause of siloed federal funding streams.

This is also a symptom of a more program-focused approach to family policy that was cemented during 1990s welfare reform, as opposed to an ecosystem approach that understands and responds to the myriad influences on family well-being.

That shift has created a structural divergence which has led to downstream fragmentation of policy and advocacy communities.

Similarly, the philanthropies which both issue communities depend on rarely work across both domains, despite often having overlapping priorities.

And economists asked to calculate the benefits of child care investments are almost never asked to incorporate the effects on child welfare, or the savings from meaningfully reduced investigatory caseloads and foster care placements.

As a result, the researchers, advocates, and messengers in each domain are optimizing for their own audiences, and the connection between the two rarely gets made or resourced.

For instance, since higher income eligibility limits for child care subsidy has been linked to lower child maltreatment rates, taking a broader view may reduce the functional cost of raising those limits and make state legislatures more inclined to fund them.

Similarly, most states give some form of subsidy priority to families who are referred by state or local welfare agencies.

But given enrollment freezes and a lack of available slots in many areas, states may need to get more creative to ensure that when such a case arises, child care needs can actually be addressed.

A Solvable Problem

The structural barriers are real but not immovable.

Philanthropies — perhaps through existing collaboratives like the Children, Youth & Family Funders Roundtable — could set tables where child care and child welfare advocates and policy experts can come together to identify a common agenda and a more comprehensive accounting of benefits.

Advocates and wonks, of course, can initiate these conversations themselves, and ensure that child welfare gains are included in their analyses.

State child welfare directors could walk across the hall to state child care administrators and have a similar conversation, and vice versa.

Congress could hold a hearing or ask the Congressional Research Service, Government Accountability Office, or relevant agencies to research the intersection to inform future thinking on policy focus and approach.

Demonstrating the stark impacts that child care has on child welfare make the stakes for decision makers clear.

Public investment in child care doesn’t just impact workforce participation or child development; it’s also an upstream factor that shapes family stability and child safety.

Decisions shaping philanthropic investment, policy design, and advocacy strategy that don’t include this awareness are missing an essential element that matters for both policy communities and, most importantly, for families.

It’s time to illuminate the blind spot.

Elliot Haspel is a Senior Fellow at Capita and author of The Family Frontier, which focuses on child care and early childhood policy.

From the Wonk Briefing Room

Every Friday, members of our premium community, the Wonk Briefing Room, receive our latest premium brief.

Where the Weekly Wonk maps the terrain, our premium resources focus on how to navigate it.

Two weeks ago, Kristen Torres gave us the view from inside a personal office — what staff are juggling, what filters every ask, and what it takes to get an ask moving.

This week’s brief goes deeper into how to navigate the structural incentives, pressures, and decision-making processes of the institution itself.

It also gives forward guidance on the moves that quietly determine whether a Hill staffer sees you as an expert resource, or someone to sideline:

• How to be an honest broker,

• How to follow up in ways that build rather than burden,

• How to deploy your comparative advantage; and

• The mistakes that signal to staffers you don’t understand the room.

It’s essential reading for anyone moving policy through Congress.

To read the full brief and access all our premium resources, individuals can sign up here, or get the team membership rate here

Wonkatizer

Most States Haven’t Caught Up Kin Care Policy

What Happened

A new ASPE issue brief, co-authored with ACF, benchmarks where states stand on kinship care and points to policies to expand uptake.

What It Says

64% haven’t taken the option to amend their Title IV-E plans to adopt separate licensing standards for kinship homes as of January.

Fewer than 20 percent are operating a Title IV-E kinship navigator program.

The brief points to strategies for expanded use of kin that we have previously discussed, including widening the definition of who qualifies as kin or adopting kin-specific licensing

Why It Matters

The licensing gap is the operational bottleneck — without a licensed home, kin caregivers can’t access Title IV-E foster care maintenance payments.

Structural difficulties related to the Title IV-E clearinghouse downthrottle what’s possible for kinship navigator deployment.

What to Watch

How ACF uses this data to encourage expanded kin care as part of its A Home for Every Child agenda, and what strategies states find to boost last-mile policy delivery.

Child Welfare Policy Manual Curtails Cultural Competence Costs

What Happened

The Children’s Bureau updated a question in the Child Welfare Policy Manual to no longer allow Title IV-E administrative funds for training on “cultural competence”.

What It Is

The policy manual is a core guidance document to jurisdictions that answer questions related to interpretation of federal financing and policy rules.

The updated question details the kinds of training topics on healthy child development for which Title IV-E admin funds can pay.

Deletions to the manual are typically here, though this one doesn’t appear up yet.

It appears that the rescinded text refers broadly to cultural competence and uses examples related to sexual orientation, gender identity, and gender expression.

Why It Matters

Cultural adaptation and cultural competence are broad concepts that can include and apply beyond LGBTQ issues.

For example, these are approaches often used for adapting policies and programs for use with tribal populations, such as by tribally-run Title IV-E programs.

What to Watch

Whether this leads to unanticipated state, local, or tribal expenditures for costs jurisdictions incurred but for which they have not yet received reimbursement.

That’s it for this week.

Stay sharp, Wonks.

~Z

Partners Making Your Weekly Wonk Possible

Welcome to our latest edition of WonkCast: People Power Policy.

In DC, there’s the old adage that “personnel is policy”; who you appoint to policy roles is itself a policy choice, and a signal worth watching.

At the Administration for Children and Families, Assistant Secretary Alex Adams is already advancing significant reforms to federal child welfare policy.

Amid that ongoing overhaul, there’s now new leadership for the Children’s Bureau.

Ryan Hanlon is the Associate Commissioner of the Children’s Bureau, leading the approximately $12B institution overseeing much of child welfare policy and financing.

Before he came into that role, he was President and CEO of the National Council for Adoption, bringing a background in adoption advocacy and direct practice.

We talked about his role and approach in implementing the Trump Administration’s child welfare policy agenda, and the shifts he’s had to make in moving from adoption-focused advocacy to public sector leadership on all of child welfare policy.

He also shared his thinking on child welfare financing and fiscal federalism; the rising tension between declining federal investment and persistent policy expectations.

This is a key starting point for understanding how the new leadership at the Children’s Bureau is thinking about policy priorities and what’s ahead.

Sponsorship Shoutout

Special thanks to Binti for their foundational sponsorship of WonkCast.

Welcome to this week’s Weekly Wonk.

The Administration for Children and Families’ (ACF) A Home for Every Child initiative is the organizing principle behind virtually every major ACF child welfare initiative.

With an increasing number of states formally aligning to the priority, it’s a key moment to look beyond the top-line national goal and average.

This week, Laura Radel gives us the literal map.

Her state-by-state benchmark of current foster home ratios illustrates the highly varied baseline from which every state will begin its journey toward the 1:1 goal.

That piece kicks off a series, with future analyses for our premium Wonk Briefing Room members on recent trends and projections for how each state could reach 1:1.

On WonkCast, Noah Duncan of Foster Insights joined me to talk about the analytical layer underneath initiatives like HFEC: metrics quietly reshaping policy.

And at a moment when ACF is rolling out a Child Welfare Technology Incubator and an issue brief on predictive analytics, our latest member-only brief breaks down the six barriers standing between child welfare agencies and meaningful AI adoption.

Let’s get into it.

Special thanks to Binti for their foundational sponsorship of WonkCast.

Subscribe now

Weekly Wonk Deep Dive

Mapping A Home for Every Child: Where Do States Stand?

How many homes does each state have for every child in foster care?1

By Laura Radel, Senior Contributor

Editor’s note: This is the first in a three-part series examining where states stand on ACF’s Home for Every Child ratio goal.

Parts two and three will be available exclusively to Wonk Briefing Room members.

We’ve been examining the constraints facing the Administration for Children and Families’ (ACF) A Home for Every Child initiative.

That includes the limits of the 1:1 ratio as a metric to the behavioral health ceiling that shapes what foster homes can actually sustain.

This piece adds a foundational piece to that picture: a state-by-state benchmark of where things actually stand today, and from which all states will start

ACF’s A Home for Every Child initiative sets the goal that states have at least as many foster homes as there are children in foster care – a 1:1 ratio.

As we’ve previously described, that’s about double the current ratio of homes to children nationally.

But we know national averages often mask significant state variability.

So, where does each state stand on this goal today?

There is no authoritative federal data on states’ stock of licensed foster homes.

The best data on the topic has been collected by The Imprint’s Who Cares: A National Count of Foster Homes and Families, which has tracked foster homes counts from states since 2019.

This analysis is based on the Who Cares counts of foster homes, and on federal AFCARS counts of children in foster care.

For each year we calculate the ratio of foster homes available on March 31 of a given year in the Who Cares data to the AFCARS count of children in care the previous September 30.

These September AFCARS figures offer a representative and official indicator from which to benchmark.

The National Picture

First, let’s start with the national picture.

Nationally, the number of foster homes declined from about 212,000 in 2018 to 178,000 in 2025 – a loss of 36,000 homes or 17 percent.

Most of that decline has occurred since 2022.

There were 0.53 foster homes in 2025 for every child who was in foster care on September 30, 2024.

The ratio has been increasing incrementally in recent years, from 0.51 in 2019 to 0.53 in 2025.

That national figure masks enormous variation across states.

Where Every State Stands

No state currently achieves the 1:1 ratio goal.

However, six states come close:

• California

• Idaho

• Pennsylvania

• Vermont

• Virginia

• Wyoming

Each has ratios of 0.8 or higher

States range from a low of 0.21 in Arizona to 0.93 in Idaho.

There are 26 states with ratios greater than 0.5, which means they currently reach at least half of ACF’s goal.

There are 12 with ratios greater than 0.66, or about two-thirds of the way to the goal.

Always Be Closing: Why the Gap Persists

Most states have a long way to go to meet ACF’s challenge of achieving a 1:1 ratio of foster homes to children who need care.

Gains needed in most states far outstrip any changes in either the supply of foster homes or the decline in children in care in recent years.

In the states with ratios below 0.5, meeting the goal of a 1:1 ratio would require doubling or more the number of licensed foster homes, halving the number of children in foster care, or some combination in between.

We’ll explore this dynamic in greater depth in a forthcoming piece.

In addition, high turnover among foster parents means many more new foster parents would be needed than are apparent from calculations like those presented here.

That’s because recruitment would need to account for turnover.

There’s also a supply-side risk worth watching.

If states add hundreds or thousands of new foster homes to their supply while further decreasing the number of children in foster care, and continuing to follow best practice of placing siblings together whenever possible, many of those new homes will never see a child placed in them.

That could manifest as mirage; as we’ve examined, raw home counts don’t measure how well matched a home is to the unique needs of:

• Sibling groups;

• Older youth; and

• Children with complex behavioral health needs.

A ratio alone won’t tell us if the supply is matched to the population’s needs.

The Road to 1:1

A Home for Every Child is now the organizing principle behind all major ACF child welfare policy initiatives.

Seeing it clearly, state by state, is essential for looking at what’s possible and what’s next.

The next two pieces in this series will go deeper on both the trajectory and the math.

The second will examine how the ratio has changed over time in each state: which states are gaining ground, which are losing it, and how fast.

The third will model what it would actually take to reach 1:1 under different strategies.

Several states have announced their participation in ACF Assistant Secretary Adams’ challenge to strive toward a 1:1 ratio with more likely to follow.

For most, the starting line is farther back than the goal may suggest.

From the Wonk Briefing Room

The federal government is preparing to push hard on AI adoption in child welfare.

May 2026 is a key deadline from the Trump Administration Executive Order on foster care, for rolling out expanded use of technological solutions, including predictive analytics and AI.

We saw ACF deliver on part of that last week, with a new issue brief on predictive analytics, and more is likely ahead.

In the latest premium brief, Kurt Heisler of ChildMetrix names the six specific barriers standing between the federal push and state readiness.

Like all our premium resources, it goes beyond diagnosis to offer concrete strategies and approaches for leaders navigating this complex terrain.

To read the full piece and access all our premium briefs, join the Wonk Briefing Room here.

Wonkatizer

ACF Rescinding “Designated Placement” Rule

What Happened

On March 6th, ACF issued a Notice of Proposed Rulemaking (NPRM) to rescind the Biden era regulation Designated Placement Requirements Under Titles IV-E and IV-B for LGBTQI+ Children.

That rule had established requirements for child welfare agencies to provide “safe and appropriate” placements for LGBTQI+ children in foster care.

Why It Matters

While implementation had been blocked following a June 2025 court injunction, the rule was a significant Biden Administration priority.

This latest step was not a surprise; the Trump Administration telegraphed this action in a September update to its Regulatory Agenda.

A noteworthy step here is on process.

Last year, HHS rescinded requirements for formal notice and comment rulemaking on many HHS programs.

Despite that shift, ACF issued this as an NPRM.

What to Watch

HHS is collecting comments until April 6.

It will be worth watching both the content of those comments and how the agency responds when it likely moves forward with formal repeal.

GAO to HHS: Clarify Congregate Care Guidance

What Happened

A new GAO report finds that 26 of 49 states surveyed have not decreased congregate care use since Family First’s 14-day limit on Title IV-E reimbursement took effect in October 2021.

Many states responded by shifting to state, county, or local funds to sustain those placements.

Given wide variation of interpretation, GAO recommended that HHS clarify guidance around settings serving sex trafficking victims, though HHS signaled it will not do so.

Why It Matters

All 49 responding states reported challenges securing and financing appropriate non-congregate placements.

As policy makers look ahead to the future of child welfare financing and Family First 2.0, this only reinforces the connection between:

• Limits on prevention implementation;

• Barriers to kinship care;

• Constrained foster home supply; and

• Continued congregate care use.

What to Watch

How financing policy conversations evolve to address these and other barriers Family First has encountered in implementation, and any reception in Congress.

ACF Letter Targets Removals Over Gender Identity

What Happened

ACF sent letters to all 50 states last week stating that children may not be removed from a home solely because a parent rejects their child’s gender identity.

Citing alleged examples from Illinois and California, the letter warned that states removing children for this reason risk losing federal grant funding.

Why It Matters

As a legal matter, the letter largely restates existing Child Abuse Prevention and Treatment Act (CAPTA) standards: removal requires evidence of abuse or imminent harm, not parental disagreement alone.

ACF is also linking the letter to the A Home for Every Child initiative, framing unnecessary removals as an impediment to that goal.

News reports note that multiple child welfare professionals and legal advocates say they are not aware of states removing children on this basis at scale.

What’s equally noteworthy is what’s not in the letter; any argument that provision of gender-affirming care itself constitutes abuse or neglect.

What to Watch

Whether ACF takes any formal action following these letters and guidance, and how states respond to the rising risk profile they face for federal funding across programs.

That’s it for this week.

Stay sharp, Wonks.

~Z

Partners Making Your Weekly Wonk Possible

How many homes does each state have for every child in foster care?1

By Laura Radel, Senior Contributor

Editor’s note: This is the first in a three-part series examining where states stand on ACF’s Home for Every Child ratio goal.

Parts two and three will be available exclusively to Wonk Briefing Room members.

We’ve been examining the constraints facing the Administration for Children and Families’ (ACF) A Home for Every Child initiative.

That includes the limits of the 1:1 ratio as a metric to the behavioral health ceiling that shapes what foster homes can actually sustain.

This piece adds a foundational piece to that picture: a state-by-state benchmark of where things actually stand today, and from which all states will start

ACF’s A Home for Every Child initiative sets the goal that states have at least as many foster homes as there are children in foster care – a 1:1 ratio.

As we’ve previously described, that’s about double the current ratio of homes to children nationally.

But we know national averages often mask significant state variability.

So, where does each state stand on this goal today?

There is no authoritative federal data on states’ stock of licensed foster homes.

The best data on the topic has been collected by The Imprint’s Who Cares: A National Count of Foster Homes and Families, which has tracked foster homes counts from states since 2019.

This analysis is based on the Who Cares counts of foster homes, and on federal AFCARS counts of children in foster care.

For each year we calculate the ratio of foster homes available on March 31 of a given year in the Who Cares data to the AFCARS count of children in care the previous September 30.

These September AFCARS figures offer a representative and official indicator from which to benchmark.

The National Picture

First, let’s start with the national picture.

Nationally, the number of foster homes declined from about 212,000 in 2018 to 178,000 in 2025 – a loss of 36,000 homes or 17 percent.

Most of that decline has occurred since 2022.

There were 0.53 foster homes in 2025 for every child who was in foster care on September 30, 2024.

The ratio has been increasing incrementally in recent years, from 0.51 in 2019 to 0.53 in 2025.

That national figure masks enormous variation across states.

Where Every State Stands

No state currently achieves the 1:1 ratio goal.

However, six states come close:

• California

• Idaho

• Pennsylvania

• Vermont

• Virginia

• Wyoming

Each has ratios of 0.8 or higher

States range from a low of 0.21 in Arizona to 0.93 in Idaho.

There are 26 states with ratios greater than 0.5, which means they currently reach at least half of ACF’s goal.

There are 12 with ratios greater than 0.66, or about two-thirds of the way to the goal.

Always Be Closing: Why the Gap Persists

Most states have a long way to go to meet ACF’s challenge of achieving a 1:1 ratio of foster homes to children who need care.

Gains needed in most states far outstrip any changes in either the supply of foster homes or the decline in children in care in recent years.

In the states with ratios below 0.5, meeting the goal of a 1:1 ratio would require doubling or more the number of licensed foster homes, halving the number of children in foster care, or some combination in between.

We’ll explore this dynamic in greater depth in a forthcoming piece.

In addition, high turnover among foster parents means many more new foster parents would be needed than are apparent from calculations like those presented here.

That’s because recruitment would need to account for turnover.

There’s also a supply-side risk worth watching.

If states add hundreds or thousands of new foster homes to their supply while further decreasing the number of children in foster care, and continuing to follow best practice of placing siblings together whenever possible, many of those new homes will never see a child placed in them.

That could manifest as mirage; as we’ve examined, raw home counts don’t measure how well matched a home is to the unique needs of:

• Sibling groups;

• Older youth; and

• Children with complex behavioral health needs.

A ratio alone won’t tell us if the supply is matched to the population’s needs.

The Road to 1:1

A Home for Every Child is now the organizing principle behind all major ACF child welfare policy initiatives.

Seeing it clearly, state by state, is essential for looking at what’s possible and what’s next.

The next two pieces in this series will go deeper on both the trajectory and the math.

The second will examine how the ratio has changed over time in each state: which states are gaining ground, which are losing it, and how fast.

The third will model what it would actually take to reach 1:1 under different strategies.

Several states have announced their participation in ACF Assistant Secretary Adams’ challenge to strive toward a 1:1 ratio with more likely to follow.

For most, the starting line is farther back than the goal may suggest.

Welcome to our latest edition of WonkCast: People Power Policy.

I’m Zach Laris, and this is WonkCast—where we spotlight the people, ideas, and tensions shaping child and family policy.

Decision-makers are both drowning in and starving for data.

What matters isn’t volume, it’s value; actionable analytics that can inform hard choices under constraint.

Metrics like foster home utilization and adverse placement scores don’t just measure state capacity; they equip leaders to reshape it in service of impact-focused goals.

Today’s guest leads the team behind these and other analytical tools that are quietly reshaping state and federal policy.

Noah Duncan is the director of Foster Insights, a University of Chicago-based non-profit that partners with child welfare leaders who want to use data to understand the challenges they’re facing and develop solutions that will actually work.

We talked about how his outsider perspective informed novel and insight-generating questions about child welfare, what practices seem rational until you look at the metrics, and how to ensure analytics are a compass, rather than a crutch.

This conversation will give you insight into the emerging data-driven approaches behind reforms across the country, and an understanding of the deeper analytical layer powering an idea like the A Home for Every Child initiative

Sponsorship Shoutout

Special thanks to Binti for their foundational sponsorship of WonkCast.

Welcome to the latest Weekly Wonk.

Having good policy ideas is necessary, but not sufficient.

What turns them into impact is understanding the decision-making machinery through which they must move.

This week we’re looking at that machinery.

Not the civics textbook version; the gritty reality of how child welfare policy actually gets done on Capitol Hill.

This week we have first-time Wonk contributor Kristen Torres’ insider perspective on staffing a senior House Ways and Means Committee member’s personal office.

She unpacks what Hill staff are really thinking when hearing a policy pitch.

Our inaugural Wonk Intelligence Quarterly identified a scarcity of clear theories of change as a core constraint limiting what’s possible in child welfare policy.

Kristen’s piece is about the strategic layer that converts a theory of change into a policy framework that can move through Congress.

On this week’s WonkCast episode, I talked with Adrien Lewis, Founder and President of CarePortal.

We discussed his experience taking a theory of change about social isolation and turning it into infrastructure available to public agencies.

And this week’s Wonk Briefing Room premium brief from Senior Contributor Doug Steiger offers tools for durable policy design principles learned from home visiting.

Let’s get into it.

Special thanks to Binti for their foundational sponsorship of WonkCast.

Subscribe now

Weekly Wonk Deep Dive

What Hill Staff Wish the Child and Family Policy Field Understood

Reflections from my time as a Legislative Assistant in the U.S. House of Representatives

By Kristen Torres, Contributing Author

When I tell people I worked on child and family policy in Congress, they often assume I had a lot of direct power.

The reality is different — and understanding it is key to effectively influencing and driving impact.

Child and family policy legislative work requires more than passion or expertise.

It means navigating institutional limits, political tradeoffs, and daily behind-the-scenes effort to get results.

Staff influence is real. But it operates inside a system.

From my time on the Hill — juggling Defense, Labor, Judiciary, Immigration, Social Security, and child welfare at the same time — here’s what I wish the field understood.

Staff Influence Is Real — And Constrained

Staff can shape conversations and raise the visibility of specific issues.

But final decisions rest with the Member of Congress, who make decisions based on factors well beyond the merits of the idea itself.

That’s where advocates can get tripped up.

When I was on the Hill, every issue had to run through a filter:

• How does this align with the Member’s priorities?

• How does it matter to the district?

• What does it cost?

• Who opposes it, and why?

• Is there a path to bipartisan support?

When you got my agreement that an issue was important, what you secured was an internal champion — not a decision.

I still had to convince my Legislative Director and often the Chief of Staff.

And even if they agreed, I had to coordinate with committees, stakeholders, and other offices to understand whether the timing and conditions were right.

Effective advocacy doesn’t just make the policy case.

It helps staff navigate time, capacity, and authority constraints to turn agreement into action.

Bipartisan Doesn’t Magically Mean “Easy to Enact”

One of the greatest rewards of working in child welfare policy is the bipartisan cooperation — everyone wants kids to be safe and families to thrive.

But once you get into policy details, differences show up fast, and don’t necessarily break neatly along partisan lines.

A persistent divide is the federal vs. state role.

Some members want stronger federal standards and dedicated funding for consistency.

Others push for state flexibility and fewer bureaucratic hurdles.

Even funding structure can split people — mandatory funding for stability versus annual appropriations for policymaker control.

In the 118th Congress, conversations around updating Title IV-B showed this clearly.

Members agreed that states need better tools to support families and prevent unnecessary foster care.

But the split came over how to get there.

Advocates who understand where the philosophical fault lines sit — and draft within them — accelerate movement.

Those who don’t quietly close the door on themselves.

Stories Open Doors. Solutions Move Bills.

A compelling personal story can grab a staffer’s attention and make an issue feel real. Solid data backs it up.

But the next question is always the same: Okay — what do you want us to do?

Staff don’t always have time to turn a problem into a policy solution from scratch.

Meetings that came to me with clear next steps — a letter to send, report language to propose, a bill to co-sponsor — moved through our internal process much faster.

That didn’t mean approval. It just meant I could get the request into the queue for a decision more quickly.

The advocacy that really works combines lived experience with concrete policy asks that make it easy for staff to act.

Legislation Is Not the Only Lever

Standalone bills are the most visible form of action — and often the least likely to move. Much policy influence happens elsewhere.

Appropriations report language signals congressional intent to agencies and can shape how funds are used.

GAO report requests put real pressure on agencies — their findings get cited in hearings, report language, and member letters.

Letters from Members to agencies can ask for guidance clarification, push for waivers, or encourage use of existing authority.

Media engagement and op-eds create public momentum that pressures decision-makers.

Effective advocates are creative in their attempts to move an issue forward and are familiar with the full toolkit.

What This Means for the Field

Understand the process deeply — passion alone isn’t enough without knowing how legislation moves.

Shared values are just the starting point; turning bipartisan agreement into law requires understanding the divides.

Pair stories with solutions. And be creative with your asks — think beyond the usual requests, and consider how to help staff build momentum quickly.

Working in Congress is messy, complicated, and slow.

But when the victories come, they are built on careful coordination, incremental progress, and relentless alignment with institutional reality.

Advocates who understand that are best positioned to make a difference.

Kristen Torres is the Founder & CEO of Torres Consulting. She previously worked for U.S. Representative Judy Chu (D-CA).

From the Wonk Briefing Room

Every Friday members of our premium community, the Wonk Briefing Room, gets our latest Wonk premium brief.

Where the Weekly Wonk gives you a map of the terrain child and family policy faces, our premium resources aim at how to navigate it.

In a moment when federal support for family programs is contracting, the question of which programs survive, and why, is more than academic.

It’s operational intelligence for anyone working to protect services families depend on.

This week’s premium brief takes home visiting as a case study in program durability.

Senior Contributor Doug Steiger examines why home visiting has not only survived but grown eightfold in investment with persistent bipartisan support.

That trajectory isn’t luck; structural choices built home visiting’s political resilience.

The full brief draws out four lessons for policymakers and advocates designing or defending programs today.

Premium members get the full piece at the Wonk Briefing Room. Join here.

Wonkatizer

ACF Launches Child Welfare Technology Incubator

What Happened

ACF has launched a Child Welfare Technology Incubator, offering technical assistance and scalable CCWIS blueprints.

On February 23, ACF also announced a partnership with Iowa to establish the state’s new system as a national model for CCWIS modernization.

Iowa built its model, VISION, on modular, user-centered design principles, and did so faster than typical implementations.

What it Means & What to Watch

ACF is explicitly framing this as a part of its broader strategic shift from federal oversight to active federal-state co-design.

The Iowa partnership also directly links VISION to A Home for Every Child.

The Incubator arrives at a complicated moment for CCWIS modernization.

As we examined in December, long-standing barriers have limited implementation, and ACF restructuring has moved oversight of the program.

In an era of rapid technological development and rising expectations for its use, the key thing to watch will be whether this incubator fundamentally shifts how and why states implement the CCWIS platform.

Foster Youth at the State of the Union: A Signal Worth Watching

What Happened

Last week, Sierra Burns – a foster care alumna and participant in the Melania Trump Foster Youth to Independence Program– joined First Lady Melania Trump in the box for the 2026 State of the Union.

The White House framed her presence as part of Mrs. Trump’s Fostering the Future initiative.

What it Means & What to Watch

Events like the SOTU surface signal via political theater. Who is in the room matters just as much as the words they hear.

This persistent emphasis points to likely continuation and expansion of the First Lady’s engagement on these issues.

The signal to watch is what comes next from the First Lady’s office.

This could entail agenda items in the next budget request, or engagement around congressional conversations for older youth policy.

More States Join A Home for Every Child

What Happened

Tennessee and Louisiana this week became the third and fourth states to join ACF’s A Home for Every Child initiative, following Oklahoma & Missouri earlier this month.

Both governors signed proclamations alongside Assistant Secretary Alex Adams.

What it Means & What to Watch

State commitments are accelerating, and the political momentum behind HFEC is real.

As we’ve examined in recent weeks, what a state is committing to varies enormously depending on where they’re starting.

Watch for additional state announcements, and for whether commitments come with concrete plans — denominator strategies, recruitment targets, behavioral health partnerships.

That’s it for this week.

Stay sharp, Wonks.

Z

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Welcome to our latest edition of WonkCast: People Power Policy.

This week we’re continuing our exploration of a key constraint on child welfare policy.

Social isolation is forcing a fundamental shift in how public systems think about state capacity in the context of partnerships with private organizations focused on care.

A new class of mission-driven platforms is emerging that doesn’t fit traditional privatization models built around scopes of work and technical execution.

Today’s guest embodies this shift.

Adrien Lewis is the Founder and President of CarePortal a platform leveraging community care capacity at scale to support families in crisis.

CarePortal’s ethos is grounded in a simple truth: when you need a car seat from a stranger, your problems run far deeper than merely not having a car seat.

Our conversation dug into how social isolation underlies family crisis, what community mobilization can do that government alone can’t, and what it points to for future policy.

This episode offers a roadmap to understand how child and family policy is evolving in ways that sharpen the complementary roles of government and private partners.

Sponsorship Shoutout

Special thanks to Binti for their foundational sponsorship of WonkCast.

Welcome to the latest Weekly Wonk.

Last week, we started unpacking what it will actually take to operationalize A Home for Every Child, highlighting both its merits as an organizing principle, and its limits.

The underlying constraint is structural; child welfare holds accountability for outcomes that depend on systems it doesn’t control, constraining its policy goals.

A concrete view of that emerges from our recent analysis on the relationship between SUD treatment capacity and foster care entries related to parental drug use:

This week, Uma Ahluwalia builds on this theme breaking down why the behavioral health system is a structural ceiling on what child welfare policy alone can achieve.

That’s a pragmatic constraint that leaders across child welfare, behavioral health, and Medicaid will need to navigate together.

Relatedly, our latest WonkCast highlighted a growing trend relevant to these issues, with emerging models that are reshaping the nature of public private partnerships.

Safe Families for Children Founder Dr. David Anderson built one of the earliest such models, so I had him on the show to unpack what it means for policymaking.

And our Wonkatizer this week digs into the deletion of nearly three-quarters of sub-regulatory policy guidance at the Administration for for Children and Families.

Let’s get into it.

Special thanks to Binti for their foundational sponsorship of WonkCast.

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Weekly Wonk Deep Dive

How Access to Behavioral Health Services Shapes Permanency Outcomes

The Behavioral Health Constraint on “A Home for Every Child”

By Uma Ahluwalia, MSW, MHA

Behavioral health access is a key capacity constraint relevant to child welfare policy; understanding how is essential to successful policy design and implementation.

Parental substance use and untreated mental health conditions are now the predominant drivers of foster care involvement, particularly for infants and young children.

Access to mental health and substance use disorder services for both parents and young people matters across the continuum, from prevention to permanency.

Nationally, nearly two out of five foster care removals nationally involve parental alcohol or drug use. Among infants, that share rises to more than half.

Children entering care under these circumstances arrive with complex trauma and behavioral health needs that require specialized support.

Not every placement can meet those needs, which explains how systems can simultaneously have children in precarious temporary placements and unused licensed foster homes on paper.

When child welfare leaders report foster home shortages, they’re usually describing a service constraint: not just too few licensed homes, but too few with behavioral health support.

That distinction matters for operationalizing the Trump Administration’s Home for Every Child (HFEC) initiative.

Achieving that vision depends on two system capacities operating in tandem:

• Homes willing and able to care for children with complex behavioral health needs, and

• Reliable access to timely, effective behavioral health services for children, youth, and caregivers to stabilize families and support lasting permanency.

Current behavioral health infrastructure is severely strained.

Access and capacity will be a ceiling that constrains the possible reach of HFEC.

Behavioral Health Access Shapes Child Welfare Outcomes

When behavioral health needs go unmet, child welfare outcomes trend in predictable directions:

• higher maltreatment risk;

• more entries;

• longer stays;and

• more placement moves.

Parental mental health significantly impacts child outcomes, particularly in families involved with child welfare.

Children removed due to parental substance use are at high risk for delayed permanency.

Youth with foster care histories face longer emergency department stays and increased risk of restraints during psychiatric crises, downstream consequences of unmet need that compound across systems.

These are structural access barriers.

In 2023, 45 percent of surveyed behavioral health providers serving Medicare and Medicaid were not accepting new patients; among those accepting, about one-quarter reported waits exceeding 30 days.

The proportion of adolescents with a current diagnosis who received any needed treatment or counseling from a mental health professional was similar across:

• Private insurance (85.2 percent);

• Public insurance, (81.6 percent); and

• No insurance (80.0 percent).

At the same time, approximately 40 percent of people live in areas with mental health provider shortages.

Roughly 72 percent of U.S. counties lack a single child and adolescent psychiatrist.

These barriers translate directly into missed child welfare timelines, such as the:

• 12-month permanency hearing;

• The Adoption and Safe Families Act 15-month termination requirement; and

• The expectation that prevention services stabilize families before removal becomes necessary.

The Foster Home Constraint Is Also a Service Constraint

Child welfare leaders consistently report that the chokepoint is not merely the number of licensed foster homes but the availability of homes specifically equipped to care for children with significant behavioral health needs.

Foster parents are expected to manage trauma‑related behaviors, co‑occurring developmental disabilities, and acute mental health crises.

Yet they’re often caring for children with complex needs without timely clinical backup or in‑home supports.

The predictable result is placement instability and drift toward higher-restrictiveness settings that contradict bipartisan policy intent.

Multiple placements in child welfare often lead to trauma due to the instability and uncertainty that come with not having a stable family environment.

Placement stability also declines as time in care increases, and is connected to poor outcomes in:

• Academic achievement;

• Socio-emotional health;

• Developing insecure attachments; and

• Distress due to the instability and uncertainty that comes with not having a stable family environment.

Among children who remain in foster care longer than two years, nearly 60 percent experience three or more placement moves.

That’s a pattern strongly associated with service gaps– especially for respite care or trauma-informed mental health services, rather than caregiver willingness alone.

While residential facility use has declined over two decades, federal oversight continues to document risks in congregate care settings when family-based options cannot be sustained.

Recruitment strategies alone cannot solve a problem rooted in access to clinical support.

The Added Layer: A Competency Gap for Children in Foster or Adoptive Homes

Service availability is necessary, but not sufficient.

Even when providers accept patients, many lack competencies specific to foster and adoptive families.

The American Academy of Pediatrics (AAP) identifies trauma-informed care as a core pediatric competency—particularly for children in foster and adoptive families.

This covers screening, relational health, culturally responsive care, and steps to avoid re‑traumatization.

Yet AAP underscores that systems need infrastructure, training, and financing to make those competencies universal.

Most clinical training pathways still do not reliably address adoption- and foster‑specific needs, such as attachment disruptions, identity formation, and birth‑family dynamics.

National initiatives such as C.A.S.E.’s Training for Adoption Competency and the National Adoption Competency Mental Health Training Initiative have emerged to fill that gap.

Their growth signals how widespread the access deficit is, and how provider skills shape it.

Even well-trained foster parents cannot replace an absent clinical workforce.

A Key Constraint on A Home for Every Child

Access barriers, workforce shortages, and competency gaps create a behavioral health system structurally unable to deliver needed contributions to the goals of HFEC.

Child welfare systems are being asked to operate where healthcare delivery lacks the design and development to support their successful operation.

When families cannot access treatment for parental substance use, when children wait months for trauma therapy, when foster parents manage psychiatric crises without clinical backup, child welfare holds accountability for gaps it cannot close.

A HFEC reframes the nation’s commitment to permanency and family‑based care.

Several relevant factors related to behavioral health policy and access will matter for HFEC implementation, including:

1. Having an adequate number of well trained and caring foster homes with supports and resources specific to behavioral health needs for both birth parents and children;

2. The availability of mental health and substance use treatment resources to meet the needs of children, youth and their families, including respite and child care;

3. Training and other resources to support foster parents, kinship parents and adoptive parents in caring for children with complex mental health needs;

4. Adequacy of reimbursement to keep mental health and SUD treatment providers engaged and incentivized to provide high quality care; and

5. Cross-system coordination for case management, service delivery, financing, data tracking, and accountability.

Where child welfare policy assumes functional behavioral health infrastructure, a critical dependency emerges.

That’s not a critique of child welfare policy design, but a pragmatic constraint for which policy construction and oversight need to account.

Uma Ahluwalia is the Director of Leapp Strategies and a Senior Policy Fellow at Chapin Hall

From the Wonk Briefing Room

Every Friday members of our premium community, the Wonk Briefing Room, gets our latest Wonk premium brief.

Where the Weekly Wonk gives you a map of the terrain child and family policy faces, our premium resources aim at how to navigate it.

Our most recent release caps off a three-part series from Laura Radel and Brett Greenfield examining the 23% drop in foster care nationally from 2018 through 2024.

Looking at the eight states driving over half that decline, it examines what was behind those declines and why it matters for leaders and decision makers across the country.

It also includes diagnostic questions designed to pressure-test what’s really happening in your state.

As HFEC shapes how states think about their denominator strategies, understanding what’s actually driving caseload changes — and what isn’t — is essential intelligence.

Premium members get the full brief, including the diagnostic tool for leaders, at the Wonk Briefing Room. Join here.

Wonkatizer

ACF Rescinds 74% of Sub-Regulatory Guidance

Last week, ACF rescinded 35,781 pages of sub-regulatory policy guidance, representing 74% of such documents.

Sub-Regulatory Policy Guidance At-A-Glance

Sub-regulatory policy guidance is the interpretive layer of federal policymaking.

As the name implies, these guidance documents are not themselves regulations.

Sub-regulatory policy guidance instead adds to rules and regulations, and is generally easier to issue or rescind.

At ACF for example, Program Instructions and Information Memoranda detail rules for grantees to follow, outline policy priorities, or clarify the details of implementing policy.

ACF also recently created a new alternative to the traditional Child and Family Service Review process and align with the A Home for Every Child initiative.

This is itself expressed in guidance, via CFSR Technical Bulletin 14.

While “guidance” implies optionality, it is often binding, especially around using funds.

What Happened

This was not a surprise action, given that ACF leadership has been promising a regulatory “bonfire” since at least December of last year.

ACF reviewed various guidance documents, categorizing them as “obsolete” or “necessary”. The nearly three-quarters considered obsolete were any that were:

• From funding cycles and no longer applicable;

• Duplicative of statute, regulations, or notices of funding opportunities;

• Superseded by more recent guidance; or

• Addressing programs or initiatives that no longer exist.

ACF has kept record of all prior guidance at an ACF archive.

What it Means & What to Watch

Not all guidance in the framework of child and family policy is equally load bearing.

Guidance tied to expired programs or grants lies dormant. That tied to ongoing work can be incentives and assurances on which states rely for making plans and decisions.

The deeper thing to watch isn’t the volume of guidance cut, but subsequent signals of any resulting policy shift, or expansion to changes in formal rules and regulations.

That’s it for this week.

Stay sharp, Wonks.

Z

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