Massachusetts DCF Performance Audit: Findings on Psychotropic Medication Oversight and COVID-19 Response

In alignment with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has executed a thorough performance audit of the Department of Children and Families (DCF), specifically examining the operations and practices relevant from July 1, 2019, through December 31, 2023.

  • This assessment scrutinized whether DCF consistently obtained the necessary court approvals for administering antipsychotic medications and meticulously documented its consent regarding psychotropic medications prescribed to children under its protective custody, in adherence to the mandates stipulated in Sections 11.14(3)(a), (4)(a), and (6)(a) of Title 110 of the Code of Massachusetts Regulations, along with DCF Policy 2010-001: Medical Examinations for Children Entering DCF Placement or Custody;
  • The audit further investigated whether children in DCF’s protective custody received timely follow-up visits and the essential psychosocial services linked to their psychotropic medication prescriptions, in accordance with guidelines set forth by the American Academy of Child and Adolescent Psychiatry’s 2005 “Position Statement on Oversight of Psychotropic Medication Use for Children in State Custody: A Best Principles Guideline” and accompanying 2015 recommendations regarding psychotropic medication usage;
  • Additionally, the review examined if DCF maintained comprehensive medical passports for children in protective custody who were prescribed psychotropic medications, in compliance with guiding policies such as DCF Policy 85-003: Health Care Services to Children in Placement and Section 475 of the Social Security Act; and
  • Finally, the audit looked into whether DCF exercised adequate oversight over children in its custody who were administered psychotropic medications surpassing the FDA’s recommended maximum dosages.
  • The audit also revealed whether DCF updated its internal control plans to address the unique challenges posed by the COVID-19 pandemic, complying with the guidance established by the Office of the Comptroller of the Commonwealth;
  • Furthermore, it assessed whether DCF ensured that all employees with access to COVID-19 funds underwent cybersecurity awareness training as mandated by the Executive Office of Technology Services and Security’s Information Security Risk Standard IS.010;
  • The evaluation included inquiries into whether DCF made consistent outreach efforts to connect with eligible youths aging out of DCF care, enabling proper allocation of funds from the John H. Chafee Foster Care Independence Program grant in accordance with the grant agreement ACYF-CB-PI-21-04.

Below is a detailed summary of our findings, the implications of those findings, and our recommendations, conveniently linked for further review.

Finding 1
DCF did not always obtain or renew court approval before children in its protective custody were administered antipsychotic medications.EffectIf DCF does not obtain or renew court approvals for antipsychotic medications, which includes presenting treatment plans to the courts, it cannot ensure that these treatment plans are safe and appropriate for the children. Additionally, this lack of oversight from the courts jeopardizes the safety of vulnerable minors who cannot consent to treatment decisions. They require the protection of an impartial entity that can verify that prescribed medications are genuinely in their best interest.Recommendation
DCF should add monitoring controls to its policies and procedures to ensure that any Rogers guardianship orders are approved and renewed by the court.Finding 2a
DCF did not document and/or update psychotropic medications listed in children’s medical passports.EffectWithout accurate and complete information, DCF and health providers may make decisions that conflict with existing medical treatments or do not reflect children’s best interests, such as overprescribing psychotropic medications, which can lead to potentially harmful adverse side effects.Finding 2b
DCF did not document follow-up doctor appointments and recommended psychosocial services in iFamilyNet (iFN) for children in its protective custody receiving psychotropic medications.EffectIf DCF does not keep accurate and complete medical records in iFN, then children in DCF’s protective custody may not receive the vital services needed to treat their medical conditions effectively. This may severely delay the growth, development, or recovery of the children deprived of necessary care. Moreover, inconsistent records hinder DCF’s ability to evaluate which medical treatments or providers yield the best results for the children in its care.Finding 2c
DCF did not document its consent in iFN for children in its protective custody to receive psychotropic medications.EffectWithout adequate documentation of consent or court approval for prescriptions of psychotropic medications, DCF cannot verify that its social workers and/or medical social workers are meeting legal requirements while providing necessary medical treatments for children in protective custody.Recommendation

DCF should establish sufficient monitoring controls to ensure that children in its protective custody have up-to-date and accurate health records in iFN and that its social workers prevent these children from receiving medical care without proper approvals, including the following:

  • DCF should review medical passports for children in its protective custody and update them at least every six months or when there are changes to a child’s prescription (e.g., new prescriptions, dosage changes, or discontinued prescriptions).
  • DCF should update iFN with all follow-up doctor appointments and psychosocial services for children in its protective custody, including the type and frequency of these appointments and services.
  • DCF should document its consent for psychotropic medication for children in its protective custody in iFN and store that consent in the same location for quick access.
Finding 3
DCF did not ensure that children received recommended psychosocial services in conjunction with their prescriptions for psychotropic medications.EffectIf children do not receive the recommended therapy and psychosocial services along with their psychotropic medication prescriptions, the overall effectiveness of their treatment may be greatly diminished. Moreover, DCF lacks the ability to monitor the efficacy of these medications or to identify and mitigate any distressing side effects that could affect the children’s health and wellbeing. Alarmingly, our findings indicated that 28 children across our audit samples exhibited suicidal ideations.Recommendation
DCF should ensure that all children in its protective custody who are prescribed psychotropic medications receive the necessary psychosocial services and implement effective monitoring controls to confirm that these services are provided and their efficacy is continually evaluated.Finding 4
DCF did not ensure that all employees with access to COVID-19 funds received annual refresher cybersecurity awareness training.EffectIf DCF does not guarantee that all its employees complete essential cybersecurity awareness training, the agency faces an elevated risk of cyberattacks, opening the door to significant financial and reputational consequences.Recommendation
DCF should develop and implement policies, procedures, and controls to ensure that all its employees complete cybersecurity awareness training as a priority.

In addition, we identified an issue regarding DCF oversight of children in its custody receiving psychotropic medication in amounts that exceeded the FDA’s recommended doses. For more information on this issue, please refer to the “Other Matters” section of this report.

During our audit, additional areas of concern that were outside the original scope of our objectives came to our attention. Given the high-risk nature of these areas, we diligently examined them while maintaining engagement with the auditee. These areas encompassed human trafficking prevention measures, in addition to DCF’s implementation of recommendations proposed by the Massachusetts Commission on LGBTQ Youth. The results of this additional work are also presented within the “Other Matters” section of this audit report.

1. Psychotropic medications are utilized to address mental health disorders affecting children, including schizophrenia, depression, bipolar disorder, anxiety disorders, and attention deficit/hyperactivity disorder.

2. A medical passport serves as a comprehensive record of healthcare services a child has received or is currently receiving, documenting their existing medications, relevant mental health history, and crucial treatment programs.

**Interview with Dr. Amelia Schaffer,‍ Child Psychologist and Advocate for Foster⁣ Children**

**Interviewer:** Thank you for joining‍ us today, Dr. Schaffer. ‍We’ve seen some concerning findings ‍from a recent audit of the Massachusetts Department of Children‍ and Families ‍(DCF) regarding the‍ administration of psychotropic medications to children in protective ‌custody. What are your‌ initial thoughts ‍on these ⁣findings?

**Dr. Schaffer:** Thank you for having me. I’m indeed alarmed ⁤by the findings. The report highlights critical gaps‍ in oversight and documentation that are essential for ensuring the safety ⁢and well-being of vulnerable children. It’s disturbing to think that children could ‍be prescribed powerful medications without proper court approval⁢ or⁣ adequate follow-up care.

**Interviewer:** ​One of​ the key findings ⁢indicated that DCF did not always obtain or renew court‍ approvals for administering antipsychotic medications to ​children. What are ⁣the risks associated with this lack of oversight?

**Dr. Schaffer:** When DCF ​fails⁣ to obtain court approval, it undermines the checks and balances that are supposed to protect ⁤these children. Specifically,⁢ it means that there is no ⁤impartial review of whether⁤ the prescribed treatment is ‍in the child’s⁣ best interest. This ⁤lack of oversight could expose children to‍ inappropriate treatments⁤ that could​ lead‌ to adverse side effects or even worsen ⁣their condition.

**Interviewer:** The‌ audit also pointed out that there were issues with documenting medication and follow-up services in their system. How‍ do these documentation lapses affect the care these children receive?

**Dr. ​Schaffer:** Accurate documentation ⁣is ‍crucial for coordinating care. Without it, health providers may make decisions based on outdated or incomplete information, which could lead to‌ overprescribing ⁢or missing important​ mental health ⁣services.‌ This kind of oversight disconnect ⁤can severely ⁣impact children’s health outcomes, especially for those already facing emotional and psychological ‌challenges.

**Interviewer:** Another⁢ alarming finding was the report of suicidal ideations among some children in the⁢ sample. How critical ‍is the integration of psychosocial services alongside medication for these ‍children?

**Dr. ⁣Schaffer:**​ It‌ is absolutely⁢ vital. Psychotropic⁤ medications can be effective,‌ but they are often much more successful when combined with therapeutic interventions. Psychosocial services help⁢ children process their ⁤experiences and cope with their emotions, while medication addresses specific ​mental health symptoms. ⁤Without a comprehensive treatment plan that includes both, we risk not addressing the root causes of their‍ distress.

**Interviewer:** The audit suggested ‍recommendations for improving monitoring and documentation ‌practices within DCF.‌ What specific changes do you think ⁣should⁢ be prioritized?

**Dr.‍ Schaffer:** First and ​foremost, DCF must prioritize standardized training for all ‍personnel ‍on the importance of documentation and ‌legal requirements regarding psychotropic medications. They should‌ implement regular audits​ to assess compliance with court‍ approvals and ⁢ensure timely follow-up services.⁣ Additionally, creating a‍ centralized system for ‌health records that​ is regularly updated and accessible to ‌all relevant​ providers is​ crucial for maintaining continuity⁤ of ‌care.

**Interviewer:** with the ongoing challenges of the COVID-19 pandemic impacting DCF operations, do you have any ⁢thoughts on how⁣ they can better adapt to these changes while ensuring the safety of children in their care?

**Dr.​ Schaffer:**⁢ Absolutely. DCF needs to enhance ‌its use of ‌technology⁣ for telehealth services,⁣ ensuring that children still ​receive necessary psychosocial support remotely. They also need to maintain strong communication ‌with foster families and community organizations to ensure‍ that children transitioning‌ out of care ‍still have access to resources. A proactive approach to these adjustments‍ can help mitigate some of the disruptions caused by the ⁤pandemic while still safeguarding ​these children’s well-being.

**Interviewer:** Thank you, Dr. Schaffer, for ⁤your insights on ⁣this critical issue.‌ Your expertise highlights the importance ⁢of proper oversight and⁤ comprehensive care for children in foster care.

**Dr. Schaffer:** Thank you for addressing⁤ these important issues. We ⁤must​ continue⁣ advocating for these children ‍and ensuring ‍they receive the care and protection they deserve.

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