On December 19, 2025, the Administration for Children and Families (ACF) released CFSR Technical Bulletin No. 14, the first step in its plan to replace the the existing process by which it reviews state child welfare performance with one that is less burdensome and more useful. The replacement is long overdue. But ACF’s attempt to reorganize all outcomes under one slogan–A Home for Every Child–is highly problematic. It disregards the need for larger homes for sibling groups and residential treatment for some young people. And it devalues and disincentivizes the central function of child welfare–protecting children from harm.
In an article in The Imprint called Why We Are Putting the PIP on a PIP, Alex Adams, the Assistant Secretary for ACF, explains the shortcomings of the Child and Family Services Reviews (CFSR’s), which are the periodic federal reviews of state child welfare systems to assess their performance and ensure they are in compliance with federal requirements. In 25 years, no state has been in substantial compliance with all the outcomes and systemic factors that are evaluated, and every state has been placed on a Performance Improvement Plan (PIP). Meanwhile, the administrative burden is heavy. Adams rightly states that “this is busywork–expensive, repetitive, punitive busywork–and it has not improved child or family outcomes.” I don’t think many child welfare stakeholders would disagree. It is time for the CFSR’s to be put out of their misery.
But what will replace the CFSR’s? As a first step to a solution, ACF has announced a pilot PIP process that states can opt to follow instead of the standard PIP procedure. As described in the Technical Bulletin, “this Administration is creating a pilot opportunity for states….to center their program improvement efforts around the A Home for Every Child goal.” Interestingly, the goal is not defined in the Technical Bulletin;1 the definition is found in several other places including a press release stating that “A Home for Every Child sets an ambitious goal of achieving a foster home-to-child ratio greater than 1:1 in every state. The initiative will focus on both sides of the equation — increasing the availability of safe homes through diligent recruitment, prioritizing kin, and improving retention of existing caregivers while reducing entries into foster care through effective prevention and faster pathways to permanency.” This sounds reasonable at first, but there are problems with centering program improvement planning around this goal–problems with the concept itself and with the implications of using it as an organizing principle in the assessment and improvement of child welfare performance.
A Flawed Concept
A Home for Every Child as a goal of child welfare seems to make sense on its face. To take a child into foster care when there is no place to put that child seems like folly, and a state that cannot equalize the supply and demand for foster care might need to rethink its rules about when to remove a child. But ACFs definition of that goal–one licensed home per foster child– makes no sense. Many foster homes can accommodate more than one child, and we need more larger homes to welcome sibling groups. And some young people in foster care need residential treatment before they can flourish in a foster home. For these reasons, child welfare administrators tend to use the concept of “beds” rather than “homes” when counting available placements for foster youth. What matters is not how many homes there are, but how many children can be accommodated in a placement that meets their needs. The two issues of multi-child homes and placements that are not foster homes are discussed below.
Foster homes with more than one child
As mentioned above, many if not most foster homes can accommodate more than one child. Many children come into care as part of sibling groups, and child welfare agencies hope to place as many of them together as possible. Despite their efforts, siblings are often separated in foster care for lack of homes that can accommodate them. We need more programs like Together California, a new community of 12 homes each built to house up to six siblings with full-time, professionally trained foster parents. Similar programs exist in Illinois, Florida and other states. Such homes could also be offered to relatives who are do not have room to take in larger sibling groups. The requirement of one home per child encourages states to focus on assembling as many foster homes as possible, rather than developing programs to keep sibling groups together.
Placements that are not foster homes
Secondly, A Home for Every Child should not include just foster homes. Most experts acknowledge that some children and youth need residential treatment before they can thrive in a foster home. Secretary Adams wrote in The Imprint that when the number of foster homes exceeds the number of children needing them, “[c]hildren avoid sleeping in offices or cycling through short-term rentals.” But most of the children sleeping in hotels, offices, short-term rentals, and other inappropriate placements have complex behavioral health needs and have been through many foster homes already. Media reports from California, Colorado, Hawaii, Illinois, Kentucky, Maryland, Massachusetts, Michigan, Missouri, New Mexico, North Carolina, Ohio, Oregon, Pennsylvania, Rhode Island, South Carolina, Tennessee, Texas, Washington, West Virginia, and Wisconsin document the preponderance of high-needs children among those in unlicensed, inappropriate placements.2 In Adams’ own state of Idaho, the child welfare agency under his leadership reported that short-term rentals were until recently used to “temporarily house children with complex needs.” Many of these high-needs young people need residential treatment, maybe for six months or a year, before they can live in a foster home. Otherwise, they will simply be bounced from home to home until they end up in another inappropriate placement or worse.
Unfortunately Adams gives short shrift to the need for residential treatment. He writes in The Imprint that “I saw firsthand the power of this ratio [of licensed homes to children] when I ran Idaho’s child welfare system. In just one year, Idaho increased from 74 to 104 foster homes per 100 children—eliminating emergency short-term placements, expanding kinship care, augmenting prevention services, improving licensing timeliness, reducing congregate care, lowering costs, and restoring public trust.” But the press release announcing the end of Idaho foster youth being placed in short-term rentals also credited the opening of a new 16-bed assessment center which “immediately reduced the department’s reliance on temporary housing.” The center is “designed to serve as a homelike setting for foster youth until an ideal placement in a foster home or residential treatment facility [my italics] is located.” Another such center is planned. So reducing the child-to-home ratio may have helped in closing the short-term rentals, but it certainly was not the only factor that allowed these rentals to be closed.
Moreover, Idaho is still struggling to find treatment for the youth with the most complex needs, the Idaho Press reported in October 2024, shortly before the last short-term rental closed. The article concluded that “Many of the youth require residential care for mental health, substance abuse disorder or other behavioral health issues, and there still isn’t enough of this treatment available in the state.” As of December 30, 2025, DHW reports having 173 children in “congregate care,”3 of which 32 were out of state.4 If Idaho is like most states, it is the lack of high-quality, trauma-informed residential treatment facilities, rather than foster homes, that is the main cause of the stays in inappropriate placements. The Family First Prevention Services Act defined a new option for providing such care–a Qualified Residential Treatment Program (QRTP). But based on a recent listing of residential facilities, Idaho appears to have only two QRTP’s. Having a goal like “A Home for Every Child” provides no incentive to develop the needed therapeutic placements for youth with complex needs.5
Equalizing the number of licensed homes with the number of children in foster care is an arbitrary goal that does not encourage the development of needed resources, like larger foster homes and residential treatment programs. But replacing it with a one-to-one ratio of available placement slots to youth is not a good idea either. A well-functioning system needs a sizable excess capacity, because existing vacancies may not be in the right geographical area or in the right type of placement for a child who comes into care. Moreover, many existing homes and residential treatment programs are probably substandard and should be closed.6 A Home for Every Child encourages states to maximize the number of homes, regardless of quality, capacity, or the need for residential treatment.
What about safety?
The ratio of homes to children can be improved in two ways, as ACF has stated: increasing the number of foster homes or decreasing the number of children in foster care. But the latter means taking fewer children into foster care. An easy way to do this is to redefine “safety” to make it harder to find a child unsafe. It appears that states have been doing this already, driving foster care numbers down to their lowest level in years and raising concerns about children being left in unsafe conditions in states as diverse as Washington, Texas, Indiana and New Jersey. As Naomi Schaefer Riley puts it, “foster care numbers are close to record lows and there are plenty of reasons to think that states are pushing them lower and sacrificing child safety in the process. If the federal government provides them with an excuse to double down on their plans to reduce the number of kids in care, many states will jump at the chance.”
The Technical Bulletin states that A Home for Every Child “provides a unifying construct that reflects the full continuum of good practice in child welfare—from prevention and family strengthening to permanency and post-permanency support—offering a cohesive framework for aligning state efforts with what works.” “From prevention to permanency” conveniently leaves out the screening and investigation of child maltreatment reports. With A Home for Every Child as the metric, the incentive is clearly to reduce entries into foster care regardless of trends in child abuse and neglect.
Some language in the Technical Bulletin suggests that other factors can be considered outside of the child-to-home ratio. States participating in the pilot must also include in their PIP’s “wraparound measures related to safety, permanency, and child and family well-being, such as adverse placement scores.” But the next sentence is “Wraparound measures should be chosen such that they will show performance improvement in areas that are expected to lead to improvements in the ratio of homes to child.” But, again, the only way child protective services can do that is reducing foster care removals. Clearly, A Home for Every Child does not center child safety.
The leadership of ACF is to be commended for seeking to reduce the burden imposed by the Child and Family Services Reviews. But the attempt to build a new quality review around a simplistic slogan like A Home for Every Child is not adequate for such a complex and serious problem as child abuse and neglect. It ignores the needs for larger foster homes to keep siblings together and for high-quality residential placements. It also creates an incentive to reduce foster care entries regardless of safety. One hopes that the current pilot will be succeeded by a more comprehensive approach that keeps safety in the forefront and recognizes the diverse needs of foster youth.
Note: After this post was published, Dr. Sarah Font of Washington University in St. Louis reminded me of another problem with A Home for Every Child. Many states rely heavily on unlicensed relatives to care for children who need placements. These states can greatly increase their count of licensed homes simply by licensing these relatives, without actually increasing the number of available placements.
Notes
- It does appear in the technical bulletin as an adverbial phrase in the following sentence: “In furthering efforts to achieve the 1:1 ratio of licensed foster homes to children in foster care, states will not be required to address every item or practice area identified in the CFSR Final Report.” ↩︎
- In New York, these young people are often sent to residential programs that are not equipped to provide the level of care that they need. ↩︎
- “Congregate care” is a term used, often pejoratively, to describe placements that are not foster homes. ↩︎
- Email from A.J. AJ McWhorter, Public Information Officer, Office of the Director |Idaho Department of Health and Welfare, December 30, 2025. ↩︎
- The Technical Bulletin does say that “The 1:1 ratio does not preclude states from pursuing placements outside of foster homes or from placing multiple children, for example, siblings, in one home but rather is intended to serve as an indicator spanning the full child welfare spectrum.” But the meaning of “intended to serve as an indicator spanning the full child welfare spectrum” is unclear. Placements outside of foster homes, or of more than one children in one home, do not count toward the goal of A Home for Every Child as defined by ACF. ↩︎
- This statement is based on my own personal experience in the District of Columbia and Maryland as well as personal accounts from youth around the country and media reports of abuse and neglect in foster care. ↩︎
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