Children's Bureau Website - Child Welfare Monitoring: Procedures Manual: Chapter 7: Program Improvement Plans

Chapter 7
Program Improvement Plans

Creating positive change in child welfare systems is the ultimate goal of the Child and Family Services Reviews (CFSRs). During the two phases of the review process, the Federal and State Governments work in collaboration to assess how well State child welfare agency strategies are achieving positive outcomes for children and families. States then develop a Program Improvement Plan (PIP) to address areas in which they were found to be out of conformity with any one of the seven outcomes or seven systemic factors under review.

The PIP planning and implementation process is perhaps the most important component of the CFSR. It is intended to be an extension of the collaborative planning process that States use to develop the 5-year Child and Family Services Plan (CFSP). State child welfare agencies involve their staff and external partners in assessing the CFSR findings and then preparing, implementing, and evaluating the PIP. Through the PIP process, State agencies also can build their capacity to conduct continuous quality improvement activities.

This chapter provides information on the timeframe for developing the PIP, requirements and content of the PIP, measures of progress used in the PIP, strategies for creating the PIP, available technical assistance (TA), the PIP format, and the PIP approval, reporting, evaluation, and renegotiation procedures.

A. Timeframe for Developing the PIP

The PIP planning and implementation process officially begins after the onsite review is completed. At the statewide exit conference, the National Review Team (NRT) Team Leader verbally provides to the State a preliminary report on the review findings; the Children's Bureau Regional Office then provides a written Final Report on the review findings to the State within 30 days of completion of the onsite review, or within 30 days of resolving discrepancies that occur in the review findings. (See chapter 4, section F, for information on the exit conference; chapter 5, section C, for information on resolving discrepancies; and chapter 6 for information on the preparation and distribution of the Final Report.) The State then prepares the PIP and submits it to the Children's Bureau Regional Office for approval.

It is recommended, however, that the State begin the PIP planning process during the Statewide Assessment phase of the CFSR. To that end, a State should select individuals to serve on its PIP Development Team when comprising its Statewide Assessment and Onsite Review Teams. (See chapter 2, section D, regarding the composition of the PIP Development Team.) Through the Statewide Assessment process, the State identifies the child welfare agency's areas of strength and those needing improvement. By starting the PIP planning process at this stage in the CFSR, the State agency can connect this process to other statewide program improvement efforts, determine how best to engage its staff and external partners in building on the State's strengths and addressing areas needing improvement, and increase the amount of time available to develop the PIP.

Through the Statewide Assessment process, therefore, a State can accomplish two purposes: (1) exploring the agency's effectiveness in achieving positive outcomes for children and families and in operating its programs and (2) beginning to develop strategies for improvement to be included in the PIP. During the Statewide Assessment process, for example, a State can:

Engage its external partners in understanding the issues under review and help to build their commitment to participate in the latter phases of the review
Begin to identify areas where improvements are likely to be needed
Analyze the underlying factors that affect the State's performance on the outcomes, indicators, and systemic factors
Explore within the agency and with external partners possible strategies for making needed improvements

By initiating PIP development during the Statewide Assessment process, a State can reduce the amount of planning time needed to develop the PIP after the onsite review by beginning to address those areas that appear to need improvement. Once the State receives the courtesy copy of the Final Report after the onsite review, therefore, it will be well positioned to address any outcome or systemic factor identified as an area needing improvement during the onsite review. (See chapter 6, section C, for information about the courtesy copy of the Final Report.) This ensures that the PIP process will be a time for action rather than for further study or planning.

The following timeframes apply to the PIP development and implementation process:

The State must submit the PIP to the Children's Bureau Regional Office for approval within 90 calendar days from the date that the State receives written notification from the Children's Bureau Regional Office that it is not operating in substantial conformity with any one of the seven outcomes or seven systemic factors (45 Code of Federal Regulations [CFR] §1355.35[c][1]). In an effort to meet the regulatory timeframes for notifying States of their conformity and still allow States 2 weeks to review the report, the issuance of a courtesy copy of the Final Report serves as the official notice of conformity and begins the 90-day period for submitting the PIP to the Children's Bureau Regional Office.
There is no regulatory timeframe within which the Children's Bureau Regional Office must review and approve the PIP. The Children's Bureau Regional Office and the State should work together during the PIP development process to produce a draft PIP within 90 days that allows the Children's Bureau Regional Office and the Children's Bureau to easily review it within 30 days. The Children's Bureau Regional Office reviews the PIP in consultation with the Children's Bureau Central Office.
If the PIP is not approved, the State must submit a revised PIP to the Children's Bureau Regional Office within 30 calendar days of receiving written notice from the Regional Office that it was not approved (45 CFR §1355.35[c][3]).
The timeframe for completing the implementation of the PIP may not exceed 2 years from the date that the PIP is approved by the Children's Bureau Regional Office. Not all PIP elements may require this length of time to address, and the 2 years is, therefore, an outside time limit for those elements requiring more extensive planning and action (45 CFR §1355.35[d][1]).
Issues affecting child safety must be addressed first and in less than 2 years (45 CFR §1355.35[d][2]). The priority given to safety should be reflected in both the level of effort and the timeframe for implementing the safety provisions of the PIP.
Although extensions to the 2-year timeframe for completing the PIP are rarely granted, there may be circumstances in which extensions, not to exceed 1 year, may be approved. States should link requests for extensions to specific PIP strategies requiring additional time and must submit these to the Children's Bureau Regional Office in writing, with supporting documentation, at least 60 days before the approved PIP implementation completion date. The Secretary of the U.S. Department of Health and Human Services (HHS) must approve requests for extensions, which are granted only in exceptional situations (45 CFR §1355.35[d][3]).

B. Requirements and Content of the PIP

The PIP planning process provides an opportunity for State child welfare agencies to develop a plan of action for making both the short-term and long-term changes to their child welfare system necessary to improve outcomes for children and families. The PIP should provide measurable action steps toward improvement, not simply suggest further study of issues identified through the CFSR. States can use the review process (Statewide Assessment and onsite review) to study what works and what needs improvement, and then use the PIP process to implement new strategies for making improvements.

The PIP document should provide sufficient detail and context to ensure that the Children's Bureau Regional Office and State agency staff can work in partnership to monitor progress in implementing and completing the PIP. Once the goals and action steps are outlined, the State establishes benchmarks to measure progress toward the goals. The following information is required content in the PIP:

For each outcome and systemic factor found not to be in substantial conformity, the PIP must include a measurable goal of improvement, action steps, and a timeframe for achieving the goal and implementing the action steps (45 CFR §1355.35[a][1][iii]). Specifically, the PIP should address the following:

The items and data indicators that contributed to a determination of "not in substantial conformity" for each outcome, as noted in the Final Report.
The CFSP requirements/indicators that contributed to a determination of "not in substantial conformity" for each systemic factor, as noted in the Final Report. The PIP should address the findings of the Final Report regarding the requirements/indicators in determining the steps necessary to make needed improvements.

The PIP must address particularly egregious areas of nonconformity impacting child safety first (45 CFR §1355.35[d][2]). For the safety items, the State should establish both short-term goals (to minimize the negative effects on children and families immediately) and long-term goals (plans for lasting reforms). The priority assigned to these issues should be reflected in the timeframes and content of the PIP, rather than in the order in which they are identified in the PIP document.

Moreover, not every area of nonconformity requires the same level of effort through the PIP. In addition to addressing immediate safety requirements, the State should give highest priority to addressing areas of performance most significantly out of substantial conformity.
The PIP must include benchmarks of progress toward achieving the broader goals of the plan. Benchmarks are not only a regulatory requirement (45 CFR §1355.35[a][1][v]), but are interim measures of progress that enable a State to determine whether it is on track to meet its negotiated rate of improvement. Using benchmarks enables the State and the Children's Bureau Regional Office to measure progress and to assess the effectiveness of the State's strategies for program improvement. A State therefore can determine, early in the PIP process, whether it is using a strategy that is not leading to improvements, as outlined in the PIP goals. Through ongoing PIP analysis, using the benchmarks, a State can work with the Children's Bureau Regional Office to make midcourse corrections or adjustments, as needed.
The PIP must include a specific percentage of improvement (goal) that will be achieved through the PIP for each applicable data indicator that does not meet the national standards (45 CFR §1355.35[a][1][iv]). In some cases, the amount of progress projected to be achieved through the PIP will result in the State not reaching the established national standards. In those cases, the amount of progress negotiated between the Children's Bureau Regional Office and the State should be significant enough to move the State toward conformance with the national standards in a reasonable period. In addition, when possible, the PIP should include interim benchmarks (for example, percentages of improvement toward the overall benchmark).

The PIP should identify the individual(s) responsible for undertaking each action step. (This is not a regulatory requirement, but should be done when possible to assist in ensuring successful completion of the PIP.)
The PIP should specify the geographic areas of the State in which the action steps will be undertaken and explain how the plan will lead to positive outcomes and adequate functioning of the systemic factors statewide, if needed. Because the State's largest metropolitan subdivision is always a site for the onsite review, the State needs to ensure that plans for improvement include the largest metropolitan subdivision, as needed. (This is not a regulatory requirement, but should be done when possible to ensure that the requirements subject to review are in place throughout the State.)
The PIP must describe how the State will evaluate and report PIP progress to the Children's Bureau Regional Office (45 CFR §1355.35[e][1]), including a schedule for submitting progress reports to the Children's Bureau Regional Office. The evaluation plan must address how the State will evaluate benchmarks of progress as well as determine whether PIP goals have been achieved. (See section C below for information on measuring progress.)
The PIP must describe the State's plan for using Federal or non-Federal sources of TA to support program improvements for each outcome and systemic factor found not to be in substantial conformity (45 CFR §1355.35[a][1][vii]). (See section E below for information on obtaining TA.)
The State must incorporate elements of the PIP into the goals and objectives of the CFSP and address its progress in implementing the PIP in the Annual Progress and Services Report (APSR) (45 CFR §1355.35[f]) and the CFSP.

In addition to the required elements of the PIP described above, the following general guidelines apply to the PIP content:

In developing the PIP, the State should set realistic goals that are achievable during the PIP timeframes. While the Children's Bureau expects that the PIP will be part of a broader plan that a State has for making long-range improvements, the provisions of the PIP should focus on areas in which goals are achievable within the PIP timeframes. In setting goals, the Children's Bureau Regional Office and State should work together to determine accurate baselines for the areas in which progress is to be made. For example, data profiles updated at the time the State is developing its PIP may serve as baselines for improvements in the data indicators. Generally, the findings of the CFSR will provide baselines for qualitative review activities. The State may use another type of review to measure progress on items that are not linked to the six national standards. The Children's Bureau Regional Office and State should ensure that the method used to establish the baseline corresponds with the strategy by which progress will be measured.
In general, the Children's Bureau will not accept PIPs with a primary focus on further study of issues or planning. Instead, the PIP should be designed to lead to measurable changes in the outcomes and systemic factors subject to review and should include specific action steps that will lead to those changes.
The State should consider carefully whether the strategies it includes in the PIP are likely to lead to the desired outcomes and goals. The review may show, for example, that a State is not performing well with regard to conducting comprehensive needs assessments of children and families during the case planning process. The State then might propose to take the following steps: (1) develop a formal comprehensive needs assessment process, (2) train State agency staff on the new needs assessment process, and (3) establish a formal review process to examine regularly whether the new needs assessment process accurately identifies the needs of children and families and links them to the services they require.
In most situations, the PIP should address improvements in the day-to-day practice of child welfare, rather than focusing strictly on new policies and procedures. By focusing on casework practice at the local level, the State is most likely to link its goals, vision, policies, and procedures to the actual interactions that occur between the child welfare agency and the children and families it serves. This integration of policy and practice with day-to-day casework in the field allows the State to achieve lasting improvements in child welfare. The PIP also should focus on how the State will ensure that the changes in practice indeed are occurring.

In developing strategies that affect front-line practice, the State should be guided by the principles of family-centered practice, community-based services, individualizing services that address the unique needs of children and families, and strengthening parents' capacity to protect and provide for their children. In some situations, a State may need to revise its policies and procedures to strengthen the focus on these principles. In other situations, the State may have adequate policies; and will need to emphasize making practice consistent with those policies. In either case, the PIP should identify correctly where improvements are needed to ensure that casework practice supports timely and positive outcomes for children and families.

States can use Appendix I, PIP Content Checklist, in evaluating the content of the PIP with regard to regulatory requirements and the goal of creating systemic changes.

C. Measurement of PIP Progress

The approach that States take in measuring their progress in implementing the PIP is very important to their success in achieving the goals of the PIP and to improving performance on subsequent CFSRs.

The PIP should include provisions for evaluating progress toward overall goal achievement at the end of the PIP implementation period. For each systemic factor and outcome found not to be in substantial conformity, the PIP must include a provision for determining whether the State has reached the goals stated in the PIP. The measurement provisions constitute evidence that the Children's Bureau Regional Office and the State use to determine whether the State has reached the goals of the PIP and whether the Children's Bureau rescinds penalties or begins withholding funds associated with each outcome or systemic factor not in substantial conformity.

If data are to be used to evaluate the State's success in reaching agreed-upon levels of improvement, for example, the PIP should specify the data to be used, the periods covered by the data, and the specific percentages of improvement to be achieved. If qualitative case reviews are used to evaluate progress, the PIP should include specific information about the review process used and the level of achievement that will be considered as meeting the State's agreed-upon goals in the PIP. If process measures are to be used to evaluate the achievement of the PIP's goals, the specific work products or implementation processes that constitute the completion of those processes should be specified in the PIP.

In addition to provisions for measuring achievement of the PIP's goals, the PIP should include provisions for measuring progress toward the identified benchmarks. Establishing measurable benchmarks of progress is the first step in evaluating progress periodically.

Benchmarks may be quantitative or process oriented, depending upon the outcome or systemic factor to which they are tied. For example, if a State has a goal of achieving a 5-percent increase in a data indicator during a 2-year PIP, it might establish quantitative benchmarks of 1 percent in the first 6 months, 2.5 percent after the first year, and so on until it reaches the 5-percent overall goal. For process-oriented benchmarks, a State may have an overall goal of training its entire child welfare staff in risk assessment procedures by the end of the first year of its PIP. Benchmarks of progress could include holding the first training by the end of the second month of the PIP, training 50 percent of the staff by the end of the seventh month of the PIP, and so on.

Some outcomes and benchmarks are better captured through quantitative measures, such as data indicators, while others may be better measured by looking at the accomplishment of key steps. In most situations, a mix of measures that inform the State about both its process for implementing changes and the effectiveness of those changes will best serve the State in making desired improvements. As much as possible, however, a State should attempt to establish outcome-oriented measures of effectiveness, such as examining data reports for movement in the data indicators or reviewing for the quality of work at periodic intervals, rather than relying simply on process measures, such as writing and issuing policy, conducting a training session, or developing a new procedure. States should note that process-oriented benchmarks enable them to track implementation of the strategies only, not their effectiveness. Subsequent CFSRs will evaluate the effectiveness of the State's efforts by reviewing for outcome achievement. A State that already has or can develop the capacity to review for effectiveness, such as through the use of a qualitative case review system or examination of outcome-based data, will be better positioned to evaluate its progress in improving outcomes for children and families.

If a State chooses to adopt a qualitative review process, similar to the CFSR, to evaluate progress through the PIP, it is important to plan and specify in the PIP exactly how that process will be used to evaluate performance and determine whether benchmarks and goals are being achieved. Including the following information in the PIP will help the Children's Bureau Regional Office and State evaluate this measurement approach:

How will baselines be established?
When, where, and at what intervals will the reviews be conducted?
Who will conduct the reviews?
How many cases will the reviews comprise, and how will they be selected?
How do the State's review procedures and criteria relate to the CFSR?
What level of improvement, as evidenced by the case reviews, will establish that the State has met its PIP goal(s)?
Is a sustainability period associated with establishing that the State has met its goal(s)? (For example, to ensure that improvements are sustained over time, a State might designate that the desired percentage of acceptable case reviews must be achieved and maintained for a specified period.)
With regard to other measures of progress, such as data, the State should be as specific as possible in the PIP about the source of data to be used, the intervals at which it will be collected, data definitions if they do not correspond to those used in the CFSR, and the timeframes covered by the data.

D. Strategies for Developing the PIP

States should use the experience of participating in the CFSR to develop the PIP by focusing on what was learned through the Statewide Assessment, confirming areas of strength and those needing improvement during the onsite review, and creating a PIP that is based on the results outlined in the Final Report. Through each of these phases, States should engage as many partners in the process as possible, including the courts, tribal representatives, educational administrators, health and mental health service providers, law enforcement personnel, administrative review bodies, caseworkers, parents, foster parents, and children and youth.

Most important, the State should work in collaboration with their Children's Bureau Regional Office during the entire PIP development and implementation process. The Children's Bureau Regional Office can support the State in the following ways:

Ensuring that State leadership is involved in the PIP process and understands the importance of establishing a vision and providing direction to staff assigned to PIP development
Participating in preliminary planning meetings with the State to discuss the Final Report and assist the State in exploring effective program improvement strategies
Participating, as appropriate, in ongoing PIP strategy discussions through written correspondence, conference calls, and onsite visits when possible
Providing insights from, and guidance about, other States' experiences with the PIP development and implementation process, and facilitating links to representatives of other States who have developed a PIP
Negotiating levels of improvement, and providing guidance about acceptable indicators (measures) of improvement
Linking the State early in the planning process to TA needed during the PIP development and implementation process
Reviewing and commenting on drafts of the PIP in a timely manner
Coordinating Federal staff review and approval of the PIP within the Children's Bureau Regional Office and with the NRT Team Leader for each State

The State should use the following strategies for developing the PIP:

Begin the PIP development process while completing the Statewide Assessment. This allows the State and its external partners to identify issues and potential underlying causes and begin exploring strategies for making improvements.
Ensure that leadership in the State is involved in setting the vision and direction of the PIP and is actively engaged in oversight of the PIP's development.
Examine the State's data in relation to programs and practice. State staff and external partners should look at the policy and practice issues behind the data and try to determine the factors influencing the State's performance in the various areas addressed by the data. (TA in reviewing State data and practice issues is available through the National Resource Centers [NRCs] funded by the Children's Bureau; see section E below for more information on TA resources.)

Instead of focusing solely on statewide data, it is also beneficial for a State to analyze its data by county or region; a data syntax for the safety and permanency profile (Data Profile Programming Logic), and support in analyzing the syntax, is available on the Children's Bureau Web site at www.acf.hhs.gov/programs/cb. This data analysis process can be useful in exploring which jurisdictions within a State are experiencing specific challenges.
Help all involved parties to view the PIP as a process designed to create lasting and statewide systemic change while also addressing the immediate needs of children and families.
Use information from the Statewide Assessment and the Final Report to:

Identify the items, data indicators, and CFSP requirements that contributed to outcomes or systemic factors being rated out of substantial conformity.
Review how the systemic factors affect the outcomes, and examine relationships between other areas determined to need improvement.
Identify cross-cutting themes and issues that affect multiple areas of the State's performance; for example, the effects of inadequate assessments on safety, permanency, and child and family well-being outcomes.
Identify the communities, jurisdictions, or regions that might particularly benefit from program improvement activities for each outcome or systemic factor.
Develop a list of questions that might be used during focus groups or other consultation activities with agency staff and external partners during the PIP planning process.
Analyze each area needing improvement to identify underlying issues that affect the State's performance; for example, how the quality and content of staff training affects staff's ability to effectively engage parents in the case-planning process.
Identify strengths or promising practices that can be used to develop strategies for making improvements. For example, an initiative or project that leads to improved case planning in one area of the State might be implemented in other jurisdictions.

Develop a plan for distributing information from the Final Report to facilitate a clear understanding of the findings and to encourage input on the PIP, using strategies such as:

Sharing key information with elected officials through briefings, with providers through focus groups, and with community members through public forums.
Hosting a press conference (and/or prepare and distribute press releases) to explain the review findings to the media, and designate a person or unit to respond appropriately to questions about the findings.
Placing the Final Report or information about the results of the review on the State agency's Web site.

Develop vehicles for engaging all appropriate parties in the PIP development, implementation, and evaluation process, including:

Establishing a plan for maintaining ongoing communication with the Children's Bureau Regional Office staff and the PIP Development Team during PIP development, implementation, and evaluation. Consider providing drafts (or sections) of the PIP to the Children's Bureau Regional Office or members of the Statewide Assessment or Onsite Review Teams to elicit feedback that will enable the State to make adjustments, as necessary, early in the process.
Engaging the Statewide Assessment Team and State members of the Onsite Review Team (as well as others, as appropriate) in the process of developing the PIP. The State agency might designate subgroups of this team to formulate strategies for addressing outcomes and systemic factors that were found to be out of conformity or to prepare different sections of the PIP.
Incorporating the PIP development process into the State's collaborative planning process for developing the CFSP and the APSR by involving members of the CFSP planning group and linking improvements to the goals and strategies outlined in the CFSP. The Program Instruction ACYF-CB-PI-02-05 provides guidance on how the content of the PIP should be incorporated into the CFSP and APSR and is available on the Children's Bureau Web site at www.acf.hhs.gov/programs/cb.
When appropriate, incorporating consent decree requirements, strategies, and plans into the PIP so that the State is not working on two separate plans.
Soliciting the input of agency staff, child welfare service providers, youth served in foster care, professionals in related fields, and community members on potential strategies for making systemic improvements, specifically in relation to areas contributing to the State's nonconformance.
Scheduling a meeting with staff from the three local review sites that participated in the onsite review, and soliciting input about how to make improvements.
Exploring ways to link PIP efforts to existing, related initiatives of the State agency, localities within the State, community groups, advocacy organizations, courts, and constituency groups (for example, an association of local child welfare agency directors), thereby increasing support for the PIP process and ensuring sustainable capacity building.
Developing or strengthening partnerships with existing organizations or appointed task forces or councils that have goals similar to those outlined in the PIP (for example, joining forces with a Governor's council on Hispanic affairs to recruit Hispanic foster families).
Engaging other key external players in developing critical sections of the PIP, especially when their work affects the child welfare agency's efforts to protect and support children (for example, the courts or other State agencies, such as Medicaid and mental health, with overlapping service populations). This is particularly helpful in ensuring support for changes that may need to be implemented by those outside the child welfare agency.

Create a process for ensuring that program improvements are made in a manner that leads to positive outcomes and adequate functioning of the systemic factors statewide, and not just in the three review sites.
Ensure that the data the State uses provide accurate representations of practice in the State and will serve as valid measures of the progress of PIP implementation and effectiveness.
Provide ample time to achieve each goal (and the associated action steps) in the PIP, particularly those that require complex strategies for achieving improvement.
Use the PIP development process to enhance the State's quality assurance process so that new gains achieved through the PIP are sustained over time and the State operates in a continuous quality improvement environment.

E. Technical Assistance (TA) on the PIP

TA is available to States during all phases of the CFSR, including PIP development and implementation. States should assess their TA needs for developing and implementing the PIP before the start of the Statewide Assessment and continue to do so throughout the PIP process. States also should work with their Children's Bureau Regional Office, which is responsible for the coordination of Children's Bureau-funded TA, to determine the most appropriate TA sources.

The Children's Bureau-funded NRCs offer TA related to the CFSR and can provide TA to States during the PIP development and implementation process. For more information on the NRCs, see the Children's Bureau Web site at www.acf.hhs.gov/programs/cb.

States also are encouraged to seek assistance that will promote stronger relationships with State or locally based TA providers and that will build statewide capacity in the areas of child welfare and protection.

F. PIP Format

The Children's Bureau has developed a standard format that States can use to prepare the PIP for submission to the Children's Bureau Regional Office. (The standard format, which is outlined in Information Memorandum ACYF-CB-IM-02-04, is available on the Children's Bureau Web site at www.acf.hhs.gov/programs/cb.) States are strongly encouraged to use this format to facilitate ease of review, approval, and tracking of the PIPs. States choosing to use a different format for preparing the PIP must include all of the information required in 45 CFR §1355.35.

The PIP standard format contains the following sections:

PIP General Information: The State should provide general contact information for State agency personnel responsible for the CFSR (and for PIP development and monitoring, if different).
PIP Workplan and Matrix Instructions: The State should develop the workplan in preparing its PIP. The workplan provides space for details about the outcomes and/or the systemic factors to be improved, the action strategy for doing so, the people to be involved in or responsible for each strategy, and how each strategy will be measured (PIP evaluation).

The State should summarize the information from the workplan into the PIP Matrix, designed by the Children's Bureau, which the Children's Bureau Regional Office uses to track PIP progress. The State is encouraged to use the PIP Matrix to report on PIP progress by noting the dates of achievement of benchmarks and goals. When benchmarks and goals are not met, the State can provide a narrative explanation at the end of the PIP Matrix.
PIP Agreement Form (approvals and signatures): The chief executive officer of the State child welfare agency and the Regional Administrator for the Children's Bureau Regional Office responsible for the State must approve the PIP.

G. PIP Approval

Upon completing the PIP, the State submits it electronically to the Children's Bureau Regional Office. Before approving the PIP, the Children's Bureau Regional Office submits a copy to the Children's Bureau Central Office.

Both the Children's Bureau Regional Office staff and the State child welfare agency can use Appendix I, CFSR PIP Content Checklist, to ensure that the PIP requirements are met and that the PIP will be a useful tool in making improvements in policies and practice that will yield better outcomes for children and families.

The Children's Bureau Regional Office, in consultation with the Children's Bureau Central Office, reviews the PIP and provides approval in writing (or electronically) to the State. A PIP is approved if it meets the guidelines specified in 45 CFR §1355.35(a).

In the event that the Children's Bureau Regional Office and the State cannot reach consensus regarding the content of the PIP or the degree to which program or data improvements are to be achieved, the Children's Bureau retains the authority to assign the contents of the plan and/or the degree of improvement required for it to be considered to have been successfully completed. Under such circumstances, the Children's Bureau Regional Office provides to the State a written rationale for the content and the degree of improvement required.

Upon approving the PIP, in consultation with the Children's Bureau, the Children's Bureau Regional Office submits a copy to the Children's Bureau Central Office, the Child Welfare Review Projects, and the National Clearinghouse on Child Abuse and Neglect Information.

H. PIP Reports

After the PIP is approved, the State is required to submit, to the Children's Bureau Regional Office, status reports (written or electronic) no less frequently than quarterly unless the Children's Bureau Regional Office approves less frequent reporting (45 CFR §1355.35[d][4]). The status reports must be submitted within agreed-upon timeframes (for example, 30 days after the end of the quarter) and show progress toward the goals established. States are strongly encouraged to use the PIP Matrix to prepare the reports. (The matrix is available on the Children's Bureau Web site at www.acf.hhs.gov/programs/cb.)

The Children's Bureau Regional Office submits copies of the status reports to the Children's Bureau Central Office, the Child Welfare Review Projects, and the National Clearinghouse on Child Abuse and Neglect Information.

I. Evaluation of the PIP

The Children's Bureau Regional Office, in collaboration with the State and in consultation with the Children's Bureau Central Office, evaluates the State's achievements with reference to the terms and conditions of the approved PIP as follows:

The Children's Bureau Regional Office monitors the State's progress in completing the provisions of the PIP through the PIP status reports that the State must submit. The Children's Bureau Regional Office submits copies of the status reports to the Children's Bureau Central Office and the Child Welfare Review Projects as they are submitted by the State.
The status reports should include: (1) a description of progress made during the reporting period and (2) data about measurable factors and their relationship to the established benchmarks and timeframes. (States are strongly encouraged to use the PIP Matrix to prepare the status reports. This is available on the Children's Bureau Web site at www.acf.hhs.gov/programs/cb.)
At least annually, the Children's Bureau Central and Regional Offices and the State must jointly evaluate the State's progress in implementing the PIP. This activity should occur in conjunction with the preparation of the State's APSR/CFSP, and in collaboration with other members of the State CFSR team. The evaluation should be based on the evaluation measures and methods specified in the PIP (45 CFR §1355.35[e], [e][1], and [e][2]).
Action steps and goals included in the PIP are evaluated according to the methods and completion dates specified in the PIP. The Children's Bureau Regional Office and State may jointly determine, on the basis of sufficient information, that action steps have been completed and/or goals achieved before the projected completion dates. When that occurs, the Children's Bureau Regional Office and the State are not required to further evaluate those action steps or goals during the remainder of the PIP implementation process (45 CFR §1355.35[e][3]). The Children's Bureau Regional Office notifies the State in writing when such determinations are made.

J. Renegotiation of the PIP

In accordance with 45 CFR §1355.35(e)(4), the State may request to renegotiate the PIP with the Children's Bureau Regional Office, as needed, especially when implementing complex strategies. Requests for changes to the PIP should be submitted in writing (or electronically) to the Children's Bureau Regional Office for approval; the Children's Bureau Regional Office Team Leader then contacts the State to discuss the issues leading to the request.

The Children's Bureau Regional Office and State, in consultation with the Children's Bureau Central Office, may renegotiate the PIP, as needed, but the new plan must meet the following criteria:

The renegotiated PIP is designed to correct the areas of the State's program determined not to be in substantial conformity and/or to achieve a standard for the data indicators that is acceptable (45 CFR §1355.35[e][4][i]).
The amount of time needed to implement the provisions of the PIP does not extend beyond 3 years from the date of the original PIP approval (the original maximum of 2 years to complete the PIP plus an additional 1 year if the HHS Secretary approves an extension beyond the original 2-year limit) (45 CFR §1355.35[e][4][ii]).
The terms of the renegotiated PIP are approved by the Children's Bureau Regional Office in consultation with the Children's Bureau Central Office (45 CFR §1355.35[e][4][iii]).

Upon approval of the renegotiated PIP, the Children's Bureau Regional Office submits copies to the Children's Bureau Central Office and the Child Welfare Review Projects.

K. Financial Penalties

The withholding of funds assessed as a financial penalty is suspended while a State is implementing a PIP. If the Children's Bureau Regional Office determines, however, that a State failed to submit status reports, or that a State is not making satisfactory progress toward achieving the goals and action steps in a timely manner, then the suspension of penalties ceases and withholding of funds begins (45 CFR §1355.36[e][2][i] and [ii]).

As a State completes all requirements of the PIP related to an outcome or systemic factor, the Children's Bureau Regional Office will notify the State that associated penalties are rescinded.

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Chapter 7 Program Improvement Plans