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Response synthesis and audit

Adopted County response: Los Angeles County Foster Care

County reports extensive existing practices and ongoing improvements. DCFS and DMH differ on some training and supervisory-review proposals, with confidentiality, labor and case-specific constraints. Partial, alternative or ongoing implementation is not a completed common information system or an independently verified outcome. Download opens the same unchanged 70-page consolidated County packet used by all eight collections.

Official response PDFOfficial report PDF

Response by Los Angeles County Board of Supervisors (consolidated County departmental response) · 2026-09-01

38

Addressed

4

Partially addressed

0

Not addressed

0

Unclear

County's stated disposition

These categories reflect the County's response to each recommendation, separate from this audit's assessment.

23

Implemented

0

Will be implemented

3

Requires further analysis

0

Will not be implemented

1

Unclear

How to read this audit

Editorial engagement review only. Finding scores measure stated position, disagreement explanation, coverage, reasoning and traceability—not whether the respondent agrees with the jury or its claims are true. Recommendation disposition records the claimed state, including partial or alternative implementation explained in the audit, not verified completion. The packet was adopted September 1, 2026, item 27; its enclosure is dated August 11. Proceedings physical PDF page 22 records five ayes. No filing/receipt date or legal-timeliness judgment is inferred. Missing separate submissions do not establish nonresponse.

Commitments

Actions stated in the response

These are commitments extracted from the County's response. They describe what the response says will happen; they do not verify that implementation occurred.

11

Extracted commitments

0

Definite or bounded timing

4

Conditional timing

7

No timeframe

R2.1 · No timeframe stated

DCFS says it will strengthen Los Angeles Times engagement and is developing a website landing page documenting child-welfare reforms; neither is represented here as completed.

No target date stated

R2.2.2 · Conditional timing

DCFS identifies further analysis for information-sharing improvements, subject to confidentiality laws and possible State/federal support; no promise of unrestricted uniform access.

within the next six months and beyond

R2.2.3 · No timeframe stated

DCFS AB 218 Litigation Team will share litigation lessons, documentation trends and practice tips with child welfare leadership; separate DMH manual revision is described as already completed.

No target date stated

R2.3.1 · Conditional timing

DCFS calls for further analysis; a DA checklist partnership is only a case-by-case possibility after comprehensive analysis finds it useful, not a promised checklist.

in the next six months and beyond

R2.3.2 · Conditional timing

County/DCFS legal teams and DA would further analyze checklist information sharing because of sensitivity and confidentiality; no unconditional sharing promise.

in the next six months and beyond

R2.4.2 · Conditional timing

DMH will continue exploring additional incentives through collective bargaining; monetary changes require negotiated labor approval, not unilateral implementation.

Additional monetary incentives require collective bargaining; no fixed completion date.

R2.4.3 · No timeframe stated

DMH will monitor revised service exhibits for gaps in services or staffing. FY 2026-27 identifies the exhibits, not a deadline for achieved caseload caps.

No target date stated

R2.6.3 · No timeframe stated

RFA will explore online application opportunities to better identify applicants willing to foster teenagers and children with special needs; enhancement is exploratory, not completed.

No target date stated

R2.9.1 · No timeframe stated

DMH will continue UCLA Center of Excellence collaboration to assess needs and develop staff/contractor training; it does not accept mandatory short-format modules.

No target date stated

R2.10.4 · No timeframe stated

DCFS will evaluate more consistent employee-feedback approaches while retaining obligations to act on certain disclosures; no absolute confidentiality or universal meeting schedule promised.

No target date stated

R2.11.2 · No timeframe stated

DCFS will evaluate and prioritize system enhancements during and after CWS-CARES transition; automated notifications are potential improvements, not completed functionality.

during and after the transition from CWS/CMS to CWS-CARES

Item-by-item review

Findings and recommendations

Assessments describe whether the response engages each cited item. Finding scores separately describe statutory-elements completeness under California Penal Code § 933.05(a) and public usefulness. They do not independently verify the response or constitute a legal conclusion.

Showing 42 of 42 items

finding · F2.1

F2.1: The public has a negative impression of the foster care system and DCFS, mostly driven by adverse and sensationalized media coverage of events and lawsuits.

Audit: Addressed

Response says

County agrees with finding on public impressions and media coverage, without elaboration.

Audit analysis

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support. Report physical PDF page(s) 131; County response physical PDF page(s) 17. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

0/6

Public usefulness

Coverage
0/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support.

Scoring confidence: high

Report page 131Response page 17
Discuss finding and response

finding · F2.2

F2.2: DCFS, in partnership with other government agencies, has made great progress in improving the foster care system.

Audit: Addressed

Response says

County agrees with finding and commendation concerning foster-care improvements, without elaboration.

Audit analysis

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support. Report physical PDF page(s) 131; County response physical PDF page(s) 17. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

0/6

Public usefulness

Coverage
0/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support.

Scoring confidence: high

Report page 131Response page 17
Discuss finding and response

finding · F2.3

F2.3: Los Angeles County has been plagued by expensive civil lawsuits and remains vulnerable.

Audit: Addressed

Response says

County agrees with litigation and settlement finding, without supporting analysis of costs or allegations of fraudulent claims.

Audit analysis

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support. Report physical PDF page(s) 131–132; County response physical PDF page(s) 18. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

0/6

Public usefulness

Coverage
0/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support.

Scoring confidence: high

Report page 131Response page 18
Discuss finding and response

finding · F2.4

F2.4: FFAs’ inability to pay expensive liability premiums may cause more closures.

Audit: Addressed

Response says

County agrees with finding on insurance premiums, potential FFA closures and placement disruption, without elaboration.

Audit analysis

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support. Report physical PDF page(s) 132; County response physical PDF page(s) 18. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

0/6

Public usefulness

Coverage
0/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support.

Scoring confidence: high

Report page 132Response page 18
Discuss finding and response

finding · F2.5

F2.5: Community-based organizations are helpful in keeping children at home.

Audit: Addressed

Response says

County agrees with finding on community organizations and DCFS partnerships, without elaboration.

Audit analysis

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support. Report physical PDF page(s) 133; County response physical PDF page(s) 18. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

0/6

Public usefulness

Coverage
0/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support.

Scoring confidence: high

Report page 133Response page 18
Discuss finding and response

finding · F2.6

F2.6: Finding foster families for teenagers and children with special needs is a challenge.

Audit: Addressed

Response says

County agrees with finding on placement challenges for teenagers and children with special needs, without elaboration.

Audit analysis

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support. Report physical PDF page(s) 133; County response physical PDF page(s) 18. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

0/6

Public usefulness

Coverage
0/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support.

Scoring confidence: high

Report page 133Response page 18
Discuss finding and response

finding · F2.7

F2.7: Racial disparity poses a challenge, especially with Black and Hispanic children.

Audit: Partially addressed

Response says

County partially disagrees, describing DMH merit-based recruitment, cultural-needs documentation and training. Response does not resolve demographic disproportions or comprehensively address DCFS workers and resource families.

Audit analysis

Partial disagreement is explicit, but disputed portions of compound finding are not clearly mapped. DMH-specific reasons are concrete and cite Civil Service Rules, CLAS standards and Medi-Cal requirements; demographic and non-DMH propositions remain unexplained. Report physical PDF page(s) 133; County response physical PDF page(s) 19. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

8/10

3/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
1/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Partial disagreement is explicit, but disputed portions of compound finding are not clearly mapped. DMH-specific reasons are concrete and cite Civil Service Rules, CLAS standards and Medi-Cal requirements; demographic and non-DMH propositions remain unexplained.

Scoring confidence: high

Report page 133Response page 19
Discuss finding and response

finding · F2.8

F2.8: Child fatalities due to neglect or abuse still occur despite all the improvements in foster care.

Audit: Addressed

Response says

County agrees with finding on child fatalities and improvement goals, without elaboration.

Audit analysis

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support. Report physical PDF page(s) 134; County response physical PDF page(s) 19. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

0/6

Public usefulness

Coverage
0/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support.

Scoring confidence: high

Report page 134Response page 19
Discuss finding and response

finding · F2.9

F2.9: A number of today’s youth in foster care are more knowledgeable of their rights.

Audit: Addressed

Response says

County agrees with finding on youths' knowledge of rights and possible unintended consequences, without elaboration.

Audit analysis

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support. Report physical PDF page(s) 134; County response physical PDF page(s) 19. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

0/6

Public usefulness

Coverage
0/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support.

Scoring confidence: high

Report page 134Response page 19
Discuss finding and response

finding · F2.10

F2.10: Hiring and retention of social workers is a challenge among FFAs.

Audit: Addressed

Response says

County agrees with finding distinguishing FFA and DCFS hiring and retention, without elaboration.

Audit analysis

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support. Report physical PDF page(s) 134; County response physical PDF page(s) 20. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

0/6

Public usefulness

Coverage
0/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support.

Scoring confidence: high

Report page 134Response page 20
Discuss finding and response

finding · F2.11

F2.11: Some DCFS and DMH managers/supervisors cannot empathize with their field staff, which causes frustration and limits the ability of those workers to provide a higher quality of care for the child.

Audit: Addressed

Response says

County partially disagrees: DCFS cites required supervisory field visits and some leadership visits, while DMH describes supervisors' prior field experience and current complex-case work. DCFS accepts benefits of continued exposure; these claims do not independently disprove reported staff experiences.

Audit analysis

Explains disputed characterization of supervisors' familiarity for both departments and acknowledges value of exposure. Concrete visit requirements cite Management Directive 09-11, revised April 23, 2026, with two visits annually per CSW and recording requirements; DMH provides specific examples of clinical participation. Report physical PDF page(s) 134–135; County response physical PDF page(s) 20–21. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Explains disputed characterization of supervisors' familiarity for both departments and acknowledges value of exposure. Concrete visit requirements cite Management Directive 09-11, revised April 23, 2026, with two visits annually per CSW and recording requirements; DMH provides specific examples of clinical participation.

Scoring confidence: high

Report page 134Response page 20
Discuss finding and response

finding · F2.12

F2.12: DMH clinicians in Antelope Valley and the Inner City have higher caseloads and are more susceptible to burnout because of a shortage of field clinicians in these locations.

Audit: Addressed

Response says

DMH partially disagrees with higher-caseload and complexity characterization, citing contracting capacity and FY 2026-27 movement toward parity. Response does not supply comparative caseload data or directly explain burnout and location preferences.

Audit analysis

Identifies disputed caseload and complexity claims and explains capacity response. Rationale is incomplete for staffing preferences and burnout and relies partly on future parity rather than current comparisons. Named Behavioral Health Transformation Initiative and FY 2026-27 provide traceable basis, not verification. Report physical PDF page(s) 135; County response physical PDF page(s) 21. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

8/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

4/6

Public usefulness

Coverage
1/2
Reason specificity
1/2
Support traceability
2/2

Identifies disputed caseload and complexity claims and explains capacity response. Rationale is incomplete for staffing preferences and burnout and relies partly on future parity rather than current comparisons. Named Behavioral Health Transformation Initiative and FY 2026-27 provide traceable basis, not verification.

Scoring confidence: high

Report page 135Response page 21
Discuss finding and response

finding · F2.13

F2.13: There is limited knowledge and use of non-traditional therapies.

Audit: Addressed

Response says

DMH disagrees, explaining specialty mental health obligations, yoga's asserted exclusion from approved services and clinician scope, and contractor provision or funding of adjunct non-traditional services. Response does not establish knowledge or uptake across modalities.

Audit analysis

Whole disagreement and reasons are explicit. State DHCS contract and service-approval framework are checkable bases, with yoga and contractor funding examples; these do not fully engage claimed variation in clinician training and actual use. Report physical PDF page(s) 135; County response physical PDF page(s) 21. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Whole disagreement and reasons are explicit. State DHCS contract and service-approval framework are checkable bases, with yoga and contractor funding examples; these do not fully engage claimed variation in clinician training and actual use.

Scoring confidence: high

Report page 135Response page 21
Discuss finding and response

finding · F2.14

F2.14: While current technology is helpful, there remains a lag in the exchange of information regarding diagnoses, therapies, treatments, progress reports, and legal rulings.

Audit: Addressed

Response says

County agrees with finding on information-exchange delays, without elaboration.

Audit analysis

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support. Report physical PDF page(s) 135; County response physical PDF page(s) 22. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

0/6

Public usefulness

Coverage
0/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement supplies a position and requires no disagreement explanation. The bare agreement adds no substantive discussion of the finding, concrete reasoning or checkable support.

Scoring confidence: high

Report page 135Response page 22
Discuss finding and response

finding · F2.15

F2.15: DCFS and DMH use too many acronyms in verbal and written communication with the public, which creates confusion, misunderstanding and frustration.

Audit: Addressed

Response says

County partially disagrees based on efforts to reduce acronym confusion; DCFS expressly agrees with finding while citing plain-language practices, glossary and journalism toolkit. DMH-specific practices are not described.

Audit analysis

Explicit partial disagreement explains qualification: mitigation efforts despite continued terminology. Concrete DCFS practices and linked resources support reasoning, but response does not cover DMH or verbal communications comprehensively. Report physical PDF page(s) 136; County response physical PDF page(s) 22. Claims remain attributed; adoption date is not a filing or receipt date.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Explicit partial disagreement explains qualification: mitigation efforts despite continued terminology. Concrete DCFS practices and linked resources support reasoning, but response does not cover DMH or verbal communications comprehensively.

Scoring confidence: high

Report page 136Response page 22
Discuss finding and response

recommendation · R2.1

R2.1: To improve the public’s perception of DCFS and foster care, the Office of Strategic Communications of DCFS should implement a public communication strategy highlighting positive changes and outcomes in foster care, particularly personal success stories of children in foster care.

County: ImplementedAudit: Addressed

Response says

DCFS agrees and claims ongoing implementation of positive public communications, citing newsletter profiles, celebrity participation and work with The Imprint and Los Angeles Times. Stronger Times engagement and a reforms landing page remain ongoing work, not independently verified outcomes.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. DCFS agrees and claims ongoing implementation of positive public communications, citing newsletter profiles, celebrity participation and work with The Imprint and Los Angeles Times. Stronger Times engagement and a reforms landing page remain ongoing work, not independently verified outcomes. Report physical PDF page(s) 136; County response physical PDF page(s) 22–23. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

DCFS says it will strengthen Los Angeles Times engagement and is developing a website landing page documenting child-welfare reforms; neither is represented here as completed.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
No timeframe stated
Report page 136Response page 22

recommendation · R2.2.1

R2.2.1: To prevent expensive lawsuits, protect itself against fraudulent lawsuits, and reduce settlement costs: DCFS should ensure case managers receive timely notifications of events in their cases such as, but not limited to, court orders, new diagnoses, therapy treatments, etc., so they can promptly review and make correct and timely decisions;

County: ImplementedAudit: Addressed

Response says

For the shared litigation-risk objective, DCFS partially disagrees but claims implementation through Court Officers relaying time-sensitive court information. It conditions effective risk management on every partner fulfilling communication and assessment duties; examples focus on court orders rather than all diagnoses and treatments.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared litigation-risk objective, DCFS partially disagrees but claims implementation through Court Officers relaying time-sensitive court information. It conditions effective risk management on every partner fulfilling communication and assessment duties; examples focus on court orders rather than all diagnoses and treatments. Report physical PDF page(s) 136–137; County response physical PDF page(s) 23–24. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 136Response page 23

recommendation · R2.2.2

R2.2.2: To prevent expensive lawsuits, protect itself against fraudulent lawsuits, and reduce settlement costs: Social workers and clinicians assigned to a case should be given easy access to a uniform system of reports, updates, and related important data so that every worker, of every skill level and skill set is completing items that every other involved staff needs to know;

County: Requires further analysisAudit: Addressed

Response says

For the shared litigation-risk objective, County partially disagrees and claims existing implementation while calling for further analysis within the next six months and beyond. DCFS cites the referral portal and DCFS 179 release form; DMH supports uniform information but stresses authorization and HIPAA. Both departments describe confidentiality barriers, not a completed unrestricted uniform exchange.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared litigation-risk objective, County partially disagrees and claims existing implementation while calling for further analysis within the next six months and beyond. DCFS cites the referral portal and DCFS 179 release form; DMH supports uniform information but stresses authorization and HIPAA. Both departments describe confidentiality barriers, not a completed unrestricted uniform exchange. Report physical PDF page(s) 136–137; County response physical PDF page(s) 24. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

DCFS identifies further analysis for information-sharing improvements, subject to confidentiality laws and possible State/federal support; no promise of unrestricted uniform access.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
within the next six months and beyond · Conditional timing
Report page 136Response page 24

recommendation · R2.2.3

R2.2.3: To prevent expensive lawsuits, protect itself against fraudulent lawsuits, and reduce settlement costs: Social workers should ensure sufficient documentation of necessary information, establishing their due diligence and legal compliance.

County: ImplementedAudit: Addressed

Response says

For the shared litigation-risk objective, DCFS and DMH agree and claim ongoing documentation implementation. DCFS plans to share AB 218 litigation lessons and documentation tips; DMH cites its provider manual revised July 2, 2026 and clinical-documentation training. These are respondent claims, not findings of legal compliance.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared litigation-risk objective, DCFS and DMH agree and claim ongoing documentation implementation. DCFS plans to share AB 218 litigation lessons and documentation tips; DMH cites its provider manual revised July 2, 2026 and clinical-documentation training. These are respondent claims, not findings of legal compliance. Report physical PDF page(s) 136–137; County response physical PDF page(s) 25. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

DCFS AB 218 Litigation Team will share litigation lessons, documentation trends and practice tips with child welfare leadership; separate DMH manual revision is described as already completed.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
No timeframe stated
Report page 136Response page 25

recommendation · R2.3.1

R2.3.1: To verify the accuracy of allegations in potentially fraudulent class action lawsuits and the validity of mass settlement claims: The Litigation Department of DCFS should partner with the LACO District Attorney’s office to create a credibility checklist identifying factors, conditions and circumstances to substantiate the validity of claims;

County: Requires further analysisAudit: Addressed

Response says

For the shared objective of checking allegations and settlement claims, DCFS partially disagrees and calls for analysis in the next six months and beyond. A DA credibility checklist is conditional on case-specific comprehensive analysis establishing usefulness; missing historical AB 218 records are cited as a limitation. No unconditional checklist promise or fraud determination.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared objective of checking allegations and settlement claims, DCFS partially disagrees and calls for analysis in the next six months and beyond. A DA credibility checklist is conditional on case-specific comprehensive analysis establishing usefulness; missing historical AB 218 records are cited as a limitation. No unconditional checklist promise or fraud determination. Report physical PDF page(s) 137; County response physical PDF page(s) 25. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

DCFS calls for further analysis; a DA checklist partnership is only a case-by-case possibility after comprehensive analysis finds it useful, not a promised checklist.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
in the next six months and beyond · Conditional timing
Report page 137Response page 25

recommendation · R2.3.2

R2.3.2: To verify the accuracy of allegations in potentially fraudulent class action lawsuits and the validity of mass settlement claims: The credibility checklist should be shared with law enforcement agencies when fraud is evident.

County: Requires further analysisAudit: Addressed

Response says

For the shared claim-validity objective, County agrees but defers checklist sharing to further analysis in the next six months and beyond by County/DCFS legal teams and DA, citing sensitivity and confidentiality. Response does not claim a checklist exists or has been shared.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared claim-validity objective, County agrees but defers checklist sharing to further analysis in the next six months and beyond by County/DCFS legal teams and DA, citing sensitivity and confidentiality. Response does not claim a checklist exists or has been shared. Report physical PDF page(s) 137; County response physical PDF page(s) 25–26. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

County/DCFS legal teams and DA would further analyze checklist information sharing because of sensitivity and confidentiality; no unconditional sharing promise.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
in the next six months and beyond · Conditional timing
Report page 137Response page 25

recommendation · R2.4.1

R2.4.1: To address the shortage of DMH mental health clinicians: Have foster children receive treatment in field offices whenever it can be arranged, or through video/phone (telehealth) when telehealth can be as effective as in-person treatments, such as for teenagers or youth.

County: ImplementedAudit: Addressed

Response says

To address clinician shortages and travel, DMH agrees and claims implemented telehealth through VSee since the pandemic and field staff equipment. It explains remote-service capability, without separately detailing arrangements for treatment in field offices or modality-specific effectiveness.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. To address clinician shortages and travel, DMH agrees and claims implemented telehealth through VSee since the pandemic and field staff equipment. It explains remote-service capability, without separately detailing arrangements for treatment in field offices or modality-specific effectiveness. Report physical PDF page(s) 137–138; County response physical PDF page(s) 26. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 137Response page 26

recommendation · R2.4.2

R2.4.2: To address the shortage of DMH mental health clinicians: Encourage more mental health clinicians to work in locations where there is a shortage by providing incentives such as higher pay, bonuses, subsidized transportation, and student loan payments;

County: ImplementedAudit: Addressed

Response says

To address clinician shortages, DMH agrees and lists current classification-dependent incentives. Additional monetary incentives require labor negotiation; DMH promises continued exploration through collective bargaining. County pre-tax commuter benefits are distinguished from transportation subsidies, which DMH says it does not offer.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. To address clinician shortages, DMH agrees and lists current classification-dependent incentives. Additional monetary incentives require labor negotiation; DMH promises continued exploration through collective bargaining. County pre-tax commuter benefits are distinguished from transportation subsidies, which DMH says it does not offer. Report physical PDF page(s) 137–138; County response physical PDF page(s) 26. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

DMH will continue exploring additional incentives through collective bargaining; monetary changes require negotiated labor approval, not unilateral implementation.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
Additional monetary incentives require collective bargaining; no fixed completion date. · Conditional timing
Report page 137Response page 26

recommendation · R2.4.3

R2.4.3: To address the shortage of DMH mental health clinicians: Prevent burnout and reduce attrition by decreasing the number of caseloads per clinician and implementing a maximum number of assigned cases per clinician.

County: ImplementedAudit: Addressed

Response says

To address shortages and burnout, DMH agrees and claims FY 2026-27 service-exhibit revisions intended to reduce and realign caseloads, with future monitoring for service or staff gaps. Response does not identify a numeric maximum caseload or establish achieved reductions.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. To address shortages and burnout, DMH agrees and claims FY 2026-27 service-exhibit revisions intended to reduce and realign caseloads, with future monitoring for service or staff gaps. Response does not identify a numeric maximum caseload or establish achieved reductions. Report physical PDF page(s) 137–138; County response physical PDF page(s) 27. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

DMH will monitor revised service exhibits for gaps in services or staffing. FY 2026-27 identifies the exhibits, not a deadline for achieved caseload caps.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
No timeframe stated
Report page 137Response page 27

recommendation · R2.5.1

R2.5.1: Clinician-led training in non-traditional therapies

County: ImplementedAudit: Addressed

Response says

For the shared therapy-training objective, DMH partially disagrees: Infant Massage uses a specialist vendor without a train-the-trainer model; PCIT is an approved evidence-based practice with internal train-the-trainer training. DMH describes contractor alternatives and future collaboration, not adoption of clinician-led training for every named modality.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared therapy-training objective, DMH partially disagrees: Infant Massage uses a specialist vendor without a train-the-trainer model; PCIT is an approved evidence-based practice with internal train-the-trainer training. DMH describes contractor alternatives and future collaboration, not adoption of clinician-led training for every named modality. Report physical PDF page(s) 138; County response physical PDF page(s) 27. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 138Response page 27

recommendation · R2.5.2

R2.5.2: Outside experts and classes for therapy training

County: ImplementedAudit: Addressed

Response says

For the shared therapy-training objective, DMH agrees but claims only partial implementation through specialized CBO training. Continuing-education eligibility varies; specialized opportunities depend on program needs, standards and resources. DMH describes annual workforce training-needs assessment, not completed universal training.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared therapy-training objective, DMH agrees but claims only partial implementation through specialized CBO training. Continuing-education eligibility varies; specialized opportunities depend on program needs, standards and resources. DMH describes annual workforce training-needs assessment, not completed universal training. Report physical PDF page(s) 138; County response physical PDF page(s) 28. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 138Response page 28

recommendation · R2.5.3

R2.5.3: Convenient access to non-traditional therapy training

County: ImplementedAudit: Partially addressed

Response says

For the shared therapy-training objective, DMH partially disagrees and describes existing training, CalAIM rates covering provider training, and contractor delivery and client support funds. Response does not explain whether clinicians can access training at their convenience or promise future on-demand access.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared therapy-training objective, DMH partially disagrees and describes existing training, CalAIM rates covering provider training, and contractor delivery and client support funds. Response does not explain whether clinicians can access training at their convenience or promise future on-demand access. Report physical PDF page(s) 138; County response physical PDF page(s) 28. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 138Response page 28

recommendation · R2.5.4

R2.5.4: Tracking therapy relevance and effectiveness

County: ImplementedAudit: Partially addressed

Response says

For the shared therapy-training objective, DMH agrees and claims current monitoring of several non-traditional services and continued provider collaboration. It does not describe effectiveness measures, decisions about standard clinician training, or how evidence supports funding requests.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared therapy-training objective, DMH agrees and claims current monitoring of several non-traditional services and continued provider collaboration. It does not describe effectiveness measures, decisions about standard clinician training, or how evidence supports funding requests. Report physical PDF page(s) 138–139; County response physical PDF page(s) 29. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 138Response page 29

recommendation · R2.6.1

R2.6.1: To encourage more resource families to care for teenagers and children with special needs: Provide incentives and additional support to the families such as respite care, hosting local support group meetings, hosting teenagers’ night outs and providing mentors for the parents;

County: ImplementedAudit: Addressed

Response says

To recruit families for teenagers and children with special needs, DCFS agrees and claims ongoing support through assigned RFS workers, respite and groups, relative support services, needs-based rates, specialized TSH/ISFC placements and FURS crisis response. Listed supports are agency implementation claims, not verified availability for every family.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. To recruit families for teenagers and children with special needs, DCFS agrees and claims ongoing support through assigned RFS workers, respite and groups, relative support services, needs-based rates, specialized TSH/ISFC placements and FURS crisis response. Listed supports are agency implementation claims, not verified availability for every family. Report physical PDF page(s) 139; County response physical PDF page(s) 29–30. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 139Response page 29

recommendation · R2.6.2

R2.6.2: To encourage more resource families to care for teenagers and children with special needs: When people apply to become foster parents, whether through DCFS or FFAs, let them know about the greater need for families to foster teenagers and children with special needs.

County: ImplementedAudit: Addressed

Response says

For the same recruitment objective, DCFS agrees and describes outreach, mandatory RFA orientation and pre-approval training informing applicants about teenagers, special needs, incentives and supports. Its examples concern DCFS recruitment and RFA, without separately documenting FFA applicant practices.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the same recruitment objective, DCFS agrees and describes outreach, mandatory RFA orientation and pre-approval training informing applicants about teenagers, special needs, incentives and supports. Its examples concern DCFS recruitment and RFA, without separately documenting FFA applicant practices. Report physical PDF page(s) 139; County response physical PDF page(s) 30. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 139Response page 30

recommendation · R2.6.3

R2.6.3: To encourage more resource families to care for teenagers and children with special needs: Provide online foster family applicants with a means to indicate their willingness to foster teenagers and/or children with special needs.

County: ImplementedAudit: Addressed

Response says

For the same recruitment objective, DCFS agrees and claims existing preference collection through RFA01 and Resource Family Home Preferences forms, including age and medical or mental health needs. Further online application improvements remain exploratory; forms alone do not establish completed online enhancement.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the same recruitment objective, DCFS agrees and claims existing preference collection through RFA01 and Resource Family Home Preferences forms, including age and medical or mental health needs. Further online application improvements remain exploratory; forms alone do not establish completed online enhancement. Report physical PDF page(s) 139; County response physical PDF page(s) 30–31. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

RFA will explore online application opportunities to better identify applicants willing to foster teenagers and children with special needs; enhancement is exploratory, not completed.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
No timeframe stated
Report page 139Response page 30

recommendation · R2.7

R2.7: To inform resource families’ care for foster youth, include a section in their training on how to recognize and respond to youths who try to influence various aspects of their care and treatment which may result in unintended negative consequences.

County: ImplementedAudit: Addressed

Response says

DCFS agrees and claims ongoing resource-family training on youth care decisions, listing harm reduction, visitation safety, exploitation, mental health and reproductive health. It identifies community peer-support groups rather than claiming a newly created local group.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. DCFS agrees and claims ongoing resource-family training on youth care decisions, listing harm reduction, visitation safety, exploitation, mental health and reproductive health. It identifies community peer-support groups rather than claiming a newly created local group. Report physical PDF page(s) 139; County response physical PDF page(s) 31. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 139Response page 31

recommendation · R2.8

R2.8: To further benefit from community involvement in foster care, inform local organizations about specific needs in their area.

County: ImplementedAudit: Addressed

Response says

DCFS agrees and describes civic and faith-based recruitment partnerships, including the April 29, 2026 Breaking Bread Together event. It promises exploration of Rotary/Kiwanis outreach, especially for teenagers, siblings and special needs, not completed engagement with every named organization.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. DCFS agrees and describes civic and faith-based recruitment partnerships, including the April 29, 2026 Breaking Bread Together event. It promises exploration of Rotary/Kiwanis outreach, especially for teenagers, siblings and special needs, not completed engagement with every named organization. Report physical PDF page(s) 140; County response physical PDF page(s) 31–32. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 140Response page 31

recommendation · R2.9.1

R2.9.1: To improve communication and understanding between all members of the resource family including foster youth and involved agency workers, DCFS, DMH, and to shorten adjustment periods when there is racial disparity between a child and the foster family, social worker or mental health clinician assigned to care for the child: Create or purchase short cultural awareness training modules for each specific culture as it becomes more prevalent in foster care.

County: ImplementedAudit: Addressed

Response says

For the shared cultural-understanding objective, County partially disagrees. DCFS claims existing RHAS/FPC/FKCE resource-parent training, including on-demand courses and Black hair care. DMH describes its own cultural training, rejects necessity of short modules, and plans UCLA collaboration. Response does not establish identical practical online modules for families, social workers and clinicians.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared cultural-understanding objective, County partially disagrees. DCFS claims existing RHAS/FPC/FKCE resource-parent training, including on-demand courses and Black hair care. DMH describes its own cultural training, rejects necessity of short modules, and plans UCLA collaboration. Response does not establish identical practical online modules for families, social workers and clinicians. Report physical PDF page(s) 140; County response physical PDF page(s) 32–33. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

DMH will continue UCLA Center of Excellence collaboration to assess needs and develop staff/contractor training; it does not accept mandatory short-format modules.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
No timeframe stated
Report page 140Response page 32

recommendation · R2.9.2

R2.9.2: To improve communication and understanding between all members of the resource family including foster youth and involved agency workers, DCFS, DMH, and to shorten adjustment periods when there is racial disparity between a child and the foster family, social worker or mental health clinician assigned to care for the child: When foster families, social workers and clinicians have limited or no knowledge about the culture of the child in their care, they should be required to take the cultural awareness training.

County: ImplementedAudit: Addressed

Response says

For the shared cultural-understanding objective, County agrees. DCFS cites required resource-parent pre-approval training and additional referrals when requested or deficiencies arise. DMH cites annual DHCS Cultural Competence Plan requirements and continued compliance. Response does not separately specify a child-culture knowledge trigger for all social workers.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared cultural-understanding objective, County agrees. DCFS cites required resource-parent pre-approval training and additional referrals when requested or deficiencies arise. DMH cites annual DHCS Cultural Competence Plan requirements and continued compliance. Response does not separately specify a child-culture knowledge trigger for all social workers. Report physical PDF page(s) 140; County response physical PDF page(s) 33–34. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 140Response page 33

recommendation · R2.10.1

R2.10.1: To help supervisors and managers of DCFS and DMH support their subordinates more effectively: DCFS managers and supervising social workers who have not done field work in recent years should be required to make periodic field visits in the company of a social worker.

County: ImplementedAudit: Addressed

Response says

For the shared supervisory-support objective, DCFS partially disagrees and claims partial implementation. Management Directive 09-11 requires two accompanied visits annually per CSW; managers' participation can be directed regionally and one office reportedly has quarterly leadership visits. Response does not claim uniform mandatory visits for all managers.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared supervisory-support objective, DCFS partially disagrees and claims partial implementation. Management Directive 09-11 requires two accompanied visits annually per CSW; managers' participation can be directed regionally and one office reportedly has quarterly leadership visits. Response does not claim uniform mandatory visits for all managers. Report physical PDF page(s) 141; County response physical PDF page(s) 34. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 141Response page 34

recommendation · R2.10.2

R2.10.2: To help supervisors and managers of DCFS and DMH support their subordinates more effectively: Similarly, DMH supervising clinicians who have not worked directly with a child in a long time should periodically take on cases or experience field service visits with clinicians they supervise.

County: ImplementedAudit: Addressed

Response says

For the shared supervisory-support objective, DMH agrees and claims supervisors already must take cases, commonly complex cases, assist field staff and address crises. This directly engages renewed clinical exposure; implementation remains an agency assertion.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared supervisory-support objective, DMH agrees and claims supervisors already must take cases, commonly complex cases, assist field staff and address crises. This directly engages renewed clinical exposure; implementation remains an agency assertion. Report physical PDF page(s) 141; County response physical PDF page(s) 35. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 141Response page 35

recommendation · R2.10.3

R2.10.3: To help supervisors and managers of DCFS and DMH support their subordinates more effectively: DCFS and DMH should conduct bottom-up or 360-degree performance reviews.

County: UnclearAudit: Addressed

Response says

For the shared supervisory-support objective, DCFS claims limited 360-degree reviews among some senior managers and requires analysis before expansion, favoring anonymity. DMH disagrees, citing meet-and-confer obligations, and only says it may explore optional non-evaluative feedback. These are distinct department positions, not joint implementation or an adopted expansion.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared supervisory-support objective, DCFS claims limited 360-degree reviews among some senior managers and requires analysis before expansion, favoring anonymity. DMH disagrees, citing meet-and-confer obligations, and only says it may explore optional non-evaluative feedback. These are distinct department positions, not joint implementation or an adopted expansion. Report physical PDF page(s) 141; County response physical PDF page(s) 35. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 141Response page 35

recommendation · R2.10.4

R2.10.4: To help supervisors and managers of DCFS and DMH support their subordinates more effectively: Managers should solicit feedback from field workers about the level of support they receive from supervisors by holding informal and confidential one-on-one meetings with field workers.

County: ImplementedAudit: Addressed

Response says

For the shared supervisory-support objective, DMH claims implemented open-door meetings on staff request. DCFS claims varied, nonstandardized partial practices and future evaluation, explaining confidentiality exceptions for reporting/action and managerial capacity constraints. Quarterly sampled meetings are an alternative suggestion, not an adopted schedule.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared supervisory-support objective, DMH claims implemented open-door meetings on staff request. DCFS claims varied, nonstandardized partial practices and future evaluation, explaining confidentiality exceptions for reporting/action and managerial capacity constraints. Quarterly sampled meetings are an alternative suggestion, not an adopted schedule. Report physical PDF page(s) 141; County response physical PDF page(s) 36. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

DCFS will evaluate more consistent employee-feedback approaches while retaining obligations to act on certain disclosures; no absolute confidentiality or universal meeting schedule promised.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
No timeframe stated
Report page 141Response page 36

recommendation · R2.11.1

R2.11.1: To improve coordination between DCFS, DMH, and other departments, and to children and families in foster care: Provide field social workers with mobile applications to search for support services in the area and coordinate with the organizations that supply it.

County: ImplementedAudit: Addressed

Response says

For the shared coordination objective, County agrees and claims partial implementation using mobile devices, 2-1-1 and CareConnect. It expressly says additional enhancements are needed for the comprehensive real-time field application; response does not promise a finished application or deployment date.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared coordination objective, County agrees and claims partial implementation using mobile devices, 2-1-1 and CareConnect. It expressly says additional enhancements are needed for the comprehensive real-time field application; response does not promise a finished application or deployment date. Report physical PDF page(s) 142; County response physical PDF page(s) 36–37. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 142Response page 36

recommendation · R2.11.2

R2.11.2: To improve coordination between DCFS, DMH, and other departments, and to children and families in foster care: Identify instances in the foster care process where delays in sharing information with other departments affect a worker’s ability to care for foster children/families and consider how technology can be used to facilitate information exchange.

County: ImplementedAudit: Addressed

Response says

For the shared coordination objective, DCFS agrees and claims partial implementation through referral improvements and DMH collaboration, while acknowledging manual workflows. Automated notices remain possible enhancements; DCFS promises evaluation and prioritization during and after CWS-CARES transition, not completed automation or new MOUs.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. For the shared coordination objective, DCFS agrees and claims partial implementation through referral improvements and DMH collaboration, while acknowledging manual workflows. Automated notices remain possible enhancements; DCFS promises evaluation and prioritization during and after CWS-CARES transition, not completed automation or new MOUs. Report physical PDF page(s) 142; County response physical PDF page(s) 37–38. Claims remain attributed; adoption date is not a filing or receipt date.

Extracted commitments

DCFS will evaluate and prioritize system enhancements during and after CWS-CARES transition; automated notifications are potential improvements, not completed functionality.

Responsible party
Los Angeles County Board of Supervisors (consolidated County departmental response)
Timing
during and after the transition from CWS/CMS to CWS-CARES · No timeframe stated
Report page 142Response page 37

recommendation · R2.12

R2.12: To improve the public’s understanding of DCFS communications and services, materials used to train resource families, DCFS web pages, and verbal discussions with the public, avoid using acronyms unless they have been previously defined.

County: ImplementedAudit: Partially addressed

Response says

County agrees and claims ongoing implementation through DCFS plain language, expanded first-reference acronyms, glossary, journalism toolkit and ADA-accessible materials. Response does not demonstrate hover/click acronym explanations or describe DMH practices; those are engagement gaps, not evidence of nonresponse elsewhere.

Audit analysis

Editorial engagement review of the answer, not confirmation of implementation. County agrees and claims ongoing implementation through DCFS plain language, expanded first-reference acronyms, glossary, journalism toolkit and ADA-accessible materials. Response does not demonstrate hover/click acronym explanations or describe DMH practices; those are engagement gaps, not evidence of nonresponse elsewhere. Report physical PDF page(s) 142–143; County response physical PDF page(s) 38. Claims remain attributed; adoption date is not a filing or receipt date.

Report page 142Response page 38