Dr. Walley: This is safety nationally. When I talked about maltreatment reccurrence, where in '05 we were looking at about 8.1% of maltreatment reccurrence, now we are down to about 6.7-6.8%. I want to call this to your attention because a reduction repeat maltreatment is one of those four critical measures that the commissioner has noted. It's also one we are making great progress on and think about this for a moment: It is occurring simultaneously to a decrease in the number of children in out-of-home care. As the number of children staying in safe, stable homes increases, maltreatment in care decreases. A lot of times we've had this fallacy in our thinking that we have to rescue children and that somehow they're safer being swept into the systems of the state. But when we do that we see maltreatment in care rise. So, it's almost one of those counter-intuitive outcomes. We're going to look in a moment and see what's going on in Oklahoma with that maltreatment, repeat maltreatment. If you would, let me call your attention now to a few of the handouts that you have. I think we've already looked at the rate of children entering out-of-home care. There is a handout that is entitled "Jurisdiction Data Report" and it is about a three-page hand out. And it's one of the most informative ones, I think, that I have provided for you today, because I want to tell you what it says. And again, you remember my opening remarks that everyone is entitled to their own opinion, no one is entitled to their own facts. These are the data facts and I want to present them to you as a preliminary comment to Dr. Steib's report then. You'll notice in Oklahoma... and I'm going to look at the year 2007 and that second graph you have in the middle of that first page. In 2007, you had roughly 11,800 children in out-of-home care with an out-of-home care rate of 13.7 per thousand. That's an extraordinarily high number. Over double the national average in '07. Oklahoma was taking tremendous numbers of kids into its custody care. Over the course of the last three years, moving up, let's say through FY '10, you now have approximately 8,000 children in out-of-home care, a reduction of 31% and your rate in out-of-home care has been reduced from 13.7 to 8.4 per thousand. That is something to celebrate in our minds, in Casey Family Program's minds, because again, you're going to see in a moment the relationship of that to the repeat maltreatment issue. Eight point four, now that's still high and that is an area that we have been quite up front with the Director that we would love the opportunity to work with the Commission and the Department to continue strategizing, "What can we do to deal with still the high rate of children in out-of-home care in Oklahoma?" Because as your rate has come down, so has the national average, too. It's 5.2 per thousand. So, instead of being over twice, you are not twice as high any longer: 8.4 per thousand compared to 5.2 per thousand. There was another map I had for you, color-coded map in your packet called "Rate of children under 18 in out-of-home care." And you will see that in this one, Oklahoma is among one of the darker states, that has the higher rate in care compared to peer states around the country compared to the national average. Let me mention about... I don't think I have this one, but your rate of children entering out-of-home care, it has improved. The national average is 3.3 per thousand children in Oklahoma who enter out-of-home care. Excuse me-nationally, 3.3 per thousand. It's 4.6 per thousand in Oklahoma. So, children are still entering in at a higher rate into out-of-home care here in Oklahoma than they are nationally. Commissioner: Is there a chart on that? Dr. Walley: I don't think that I have the chart on that one. I apologize, we can get that for you. Well-I do have that-rate of children entering out-of-home care, it was uh...well, let's see...yeah. Rate of children entering out-of-home care was this one right here, there was that one. It was just the one of the two maps. Let me ask you to turn, look at the bottom, if you don't mind, too. This is a reflection of that relationship between entries and exits and you will see one of the important figures at the bottom is that 90% of all of the children that are exiting are exiting to permanency. The national average is only 85%. So, when a child exits from care in Oklahoma, 90% of the time they're exiting to permanency. Nationally that's 85%. If you'll turn to the next page in the upper left-hand corner there is a graph called "Absence of Maltreatment Reccurrence." This is a critical data point. One of the most important. You see that Oklahoma between '05 and '08 was really significantly below the national average in absence of maltreatment reccurrence. But there were some practice changes in Oklahoma. At the same time, there have been reduction in number of children in out-of-home care and the absence of repeat maltreatment began to trend the right way 'til now. You'll notice the absence of repeat maltreatment is at the national standard - the aspirational standard of 94.2% of children are absent of maltreatment recurrence. To the right on the graph of that top page you'll notice something about entries by first entry and re-entry. That gets at the issue of when children are entering Oklahoma's system, how many of them are coming back? They had exited and returning? This graph shows that 15.6% of the entries were re-entries, which is below the national average of 20% being re-entries. At the bottom of that page are just some of the data points that we internally at Casey are tracking based on some particular work efforts we have here. The percentage of children entering foster care are decreasing by 10% a year; it was 8.6%, so on the bottom left we have a graph that about... the issue of Oklahoma county and trying to shorten by one month the mean time for youth reaching permanency. That's very challenging, and Howard referenced it earlier in that, as we get more children home, you have those that are some of the more challenging cases remaining in care, so that's not a very responsive measure we don't think and we are going to look at modifying that. One of the other ones that we don't have on here, but I want to call your attention to, is what we consider measure of placement stability and that is the percentage of children re-entering care within twelve months of reunification. You send a child home with a family, what is the probability that they're going to be back in your system within twelve months? Oklahoma, the data shows 8.3% in Oklahoma compared to the national average of 12.3%. On the right-hand side, just quickly, one of the issues that I know we had been engaged with in Oklahoma on relates to the use of congregate care, shelter care. And because of some work that we've been doing... This is on... do you see that top graph where it says, "36% reduction in the number of children under six placed in shelters over two years"? I don't know if you realize it, but that is, again, something to be commended. The use of shelter care, research shows, particularly for children six and under is not best practice. So that's one of the areas that we have been fortunate enough to be involved with in working with the state of Oklahoma. There're many other work efforts. But what I wanted to do is to tell you that back earlier this year, we had a request from the Oklahoma Department of Human Services to assist them with an evaluation among the other things that we are doing. And we're... we feel like we're doing quite a bit here just before I get to that evaluation. We have invested about $800,000 in resources into Oklahoma in 2011 and there will be a continued investment of those kind of resources and that's not checks being written. We do support opportunities for training. We do come in and we've trained 850 workers in Oklahoma in permanency values training and permanency orientation around a methodology called "Permanency Round Tables." Where we're identifying those most challenging cases out there that have been stuck in out-of-home care for years and what we can do to safely find permanency for those children. That's going on statewide. Dr. Steib has been leading that effort for us here. By the way, I wanted to give you a bit of context too... When I told you about the 31% reduction in Oklahoma's number of children in out-of-home care in the last few years. While that is note worthy, Florida has had a 40% reduction, Georgia - 48%, Maryland - 45%, New Jersey - 40%, Ohio - 31%, Virginia - 29%, California - 25%. So, you begin to see that this is not an issue particular to Oklahoma. This is a national trend. Getting back to that first slide where people are recognizing that we have had a system that does not prioritize families and children in families safely. And we have reaped the harvest of that, but that's changing. We were asked early this year, as I was noting a little bit earlier, to review the safety assessment guidance and practice in Oklahoma DHS, related to House Bill 17 that passed in 2009 changing the standard for removal and what were the effects of that on practice? What was the practice model's effect on practice and implementation? What could we learn and what could we do to help Oklahoma with this ongoing self-assessment which is a sign of any system that hopes to be healthy and productive, is its ability to self-assess. Its ability to use data. Its ability to take feedback from commissions and other oversight bodies and then to use that to change practice, to change personnel, to change whatever needs to be changed to continue on the quality improvement. That's what we do, that's what any system does, that's what any organization does, that's what any team does, and so we're proud to be a part of doing that. I lived in Auburn, Alabama and we lost our first game in 17 games a week ago. Commissioner: Waa... (Laughter) Dr. Walley: The reason I tell you that is because there was an immediate concern that, "what's happened? This is not supposed to happen. We need...what's going on?" And so there had to be an assessment by the coaching staff of everything ongoing in that organization and make adjustments. And see was it policy? Was it system? Was it training? Was it personnel? Was it...? Was it...? Was it...? Because the outcomes aren't what they wanted. Now the reason I share that metaphor with you is this: Any system that wants to be premiere has to engage in that. Any system that suffers trauma, as all systems will, has to be prepared to take a look and see. What are we doing? How do we need to respond? And never overreact. To look at the trauma and look at the successes with equal concern and not judge the system by either at any one time. But to be reflective and to make those decisions on how to improve the system. We appreciate Oklahoma's DHS' willingness to allow us to be part of that. And the evaluation you will now hear from Dr. Steib and then both of us will be available to answer questions subsequently. Thank you very much. Commissioner: Thank you Dr. Walley. (Applause) Commissioner: Now obviously, Dr. Steib, you haven't had any traumas since you are from LSU? Dr. Steib: That's right. We'll see what happens on Saturday, now won't we? Thank you Page, and Mr. Chairman, and the ladies and gentlemen of the commission. Thank you for the opportunity to be here. I am just going to briefly review for you and to give a little bit of discussion and interpretation concerning the report that we did of the Safety Assessment Review that my colleague, Barry Salovitz, and I conducted at the beginning of this year. And it's my understanding that you have all been given copies of that report. Is that correct? Okay. Alright. So as Page said, this was done at the request of the DHS leadership as a result of the legislation that was passed in 2009 which had, as we all know, changed the criterion for removal of children from their families. DHS had then embarked upon some changes in policies and processes and procedures and assessments tools and so on. And those had been implemented and they thought that they were at a point where they needed someone to take a look, do some inquiry, and see how those changes were being affected and how they were impacting practice and the safety of children in Oklahoma. So that is what my colleague, Barry Salovitz, and I did. As Page mentioned earlier, Barry Salovitz is nationally known in the area of child safety assessment. He's the former Director of the National Resource Center on Child Maltreatment, he is the developer of one of the very first and best recognized safety assessment tools in the nation and one that is a forerunner of the many safety assessment tools that are used around the country today. So, he was very helpful and a very significant factor in our being able to conduct this review. The review was conducted during the first quarter of 2011. We first reviewed a set of documents that the administration provided for us. Documents that they felt best reflected the changes that had been made in policy and practices and processes here in Oklahoma to comply with the 2009 legislation, and those documents are detailed in your report. Following that document review we did interviews with a group of fifteen staff, we asked to interview staff at all levels. We wanted staff who were fairly experienced, we wanted to interview staff in at least one urban area and one rural area and we did that with a series of guided, but really open and flexible interviews that lasted anywhere from about 20 minutes to about 45 minutes a piece. So that was our methodology. Our questions in our interviews centered on what they thought was the impact of the imminent safety threat criterion, whether they thought it compromises childhood safety in Oklahoma, and how they viewed the strengths and also the concerns with regard to the new safety assessments and safety planning processes. So, what did we find? And I'm going to just briefly go through and talk about the documents and I'll talk a little bit more about the concerns, so that you'll understand what the basis of those was. But first, and I want to say that overall with regard to all of the documents: the practice model guide, the policy guidances that we were provided, the training materials that we were provided... overall we found all of these documents to be generally in accord with what we consider to be sound practice in child protective services. We started with the practice model guide, which is a comprehensive document. We were focused, because that was our charge, primarily on the safety assessment portion of that, but that is a comprehensive document that speaks to, really, all aspects of child protective services and child welfare practice in Oklahoma. It was developed with input and participation from DHS child welfare staff here, but with guidance and consultation from some of the Federal National Resource Centers and their expertise. Again, we found many strengths in the practice model guide, we only had a few concerns. One was that, while the guide does speak to issues of child vulnerability, we felt that it could focus more on discussion of vulnerability throughout the development of a child. The focus was primarily on vulnerability of young children, and certainly we understand that. Young children are uniquely vulnerable. Most of those serious injuries that we see in child maltreatment occur with younger children... so that focus is understandable. But we also know that older children can be vulnerable to different kinds of maltreatment and different kinds of exploitation. So, we would have liked to have seen some more discussion of that. We also thought that there could be more guidance with regard to situations where there are multiple risk factors in a case or in a report, but the situation at that time does not meet the threshold for present danger or imminent danger. Commissioner: If you don't mind me asking a question right here? A report that was done recently by, I think the legislature, that authorizes by Zeller... Dr. Steib: Hornby Zeller. Commissioner: They made distinctions between safety issues and risk factors. Safety issues being immediate things that need control... Dr. Walley: That's correct. Commissioner (continues): ...and risk monitoring evaluations and so on... are you making the same kind of distinctions? Dr. Walley: Yes. Yes, we are. And generally speaking, and I believe this is reflected in the Hornby Zeller report as well, we do when we are thinking about intervening in a family, particularly that child removal, we do want to be focused on issues of safety. The practice model guide encourages those situations in which a child is found to be unsafe to be retained under the purview of CPS and for there to be some sort of intervention that, preferably that, the safety threats be mitigated without the child having to come into custody. But if that cannot occur, then for the child to be removed and placed within protective custody or for a safety plan to be initiated that allows the child, at least for a time, to be in an alternative setting such as in the home of an extended family member. And it encourages that all of the situations in which longer term risk factors, such as those you referenced from the Hornby Zeller Report, or with that distinction between risk and safety, to be referred to community resources. Generally speaking, that's in keeping with good practice. We know though that in Oklahoma, as in every state where I've worked, there are in some communities limitations on resources, their scope, their availability, their accessibility... sometimes families are less willing to avail themselves of those resources. So, it does not always in every case fully protect children if they're only pursued within the child welfare system, if the child is at this moment unsafe. For the most part, yes. But in some cases, probably few cases, and I will refer to that later on as I go through the presentation, that may not be sufficient. And so, we would have liked to have seen some more discussion of that and of the application of risk in the practice model guide. With regard to the policy memoranda and the associated documents that we reviewed, again we found them to be comprehensive. We thought they laid out quite well the scope of an investigation as it should be conducted. We really... our concerns regarding those policy documents were very minimal. We had really only one that's mentioned in the report. And that was that there was one document that indicated that interviews with parents, it used permissive language that may include interviews with parents or other persons responsible for the care of the child. And we questioned that, but that was our only question or concern regarding the policy documents that we were given to review. With regard to the assessment of child safety tool, and I will say this is possibly the most comprehensive assessment of child safety instrument I have reviewed, it is quite lengthy and it is quite thorough. It contains definitions of various levels of danger. It talks about vulnerability. It has a whole series of guidance questions that investigators can use to elicit information about safety threats. We had a few concerns, again as in the practice model guide, we had that same concern about the discussion of vulnerability could have been more thorough. We thought that perhaps there was a need for greater clarity between what's considered present danger and impending danger. Although we understood, following the issuance of the report, that that is being addressed in training here in DHS now. And again, we also had the concerns about the fact that the protective capacities, as they're addressed in the safety assessment document used here in Oklahoma, are only considered after the child is determined to be unsafe. Our recommendation was that protective capacities, factors that might mitigate safety threats, be considered as part of the "safe or unsafe" decision. In Oklahoma, protective capacities are not considered in making the unsafe decision, they are only considered in the response. Now I'll tell you that, although we question that, the Oklahoma practice is a more conservative practice. So, their guidance calls for going ahead and making a decision about whether a child is safe without considering any factors that might mitigate that. It is a more conservative response and one that... this is one of those areas where reasonable people can have different views. And one that, in the judgment of DHS, was appropriate at that point in the implementation of this safety assessment process and we were understanding of that. Alright, and then with regard to training and related documents, again... generally in accordance with sound practice. They... we were provided with a well-documented training on what's called critical thinking, that targets supervisors, which I show here is a strength, because what we know is that in child protection and child welfare practice, good, solid supervision is absolutely the lynch pin. You cannot have effective practice around child safety and child wellbeing unless case workers have very strong and solid supervision. And so we viewed it as a strength that this training was being provided to supervisors in Oklahoma. There was one document that we reviewed that we thought might be a little confusing to staff because, again, it recommended the process of including protective factors in making the safety decision and that's not the policy here. That was a minor finding and then just that some of the documents that we were provided with... things like Power Points and notes, so it was difficult for us to really fully assess what actually might occur when they were delivered in training. Alright. Now we move to the interviews. We talked to all of the staff that we interviewed about the imminent danger standard and how that affects child protection practice in Oklahoma. Consistently they told us that they did not feel that the adoption of the new standard overall had compromised child safety, in most instances. They felt that in fact most of the changes in practice that had ensued in the implementation of the legislation in the new standard had been positive ones as they compare them to former practice. They talked at length in almost every instance about the fact that currently they are trained and encouraged to look more deeply at presenting situations, that prior to the enactment of current policies and procedures they used what was called an incidence-based response in Oklahoma. So that really the focus was just on the referral and the presenting information and they were not encouraged to look for underlying factors that might in fact suggest that a danger to a child could escalate beyond just what is observed in an investigation, if one does not look more deeply. So overall staff perspective on the new standard was positive. There were no concerns voiced specifically about that. Now as we went on and talked more in detail about specific ways in which child safety might be impacted as the standard is applied. Again, people felt that the more narrow criteria was needed that there were children who were removed unnecessarily under the old standard, but that there were those few cases, and I referenced this when I talked about the practice model guide a few minutes ago, where there are multiple risk factors and several staff felt that they needed more clarity, better guidance around how to handle those situations where no child was unsafe, there was no current, present dnager, no impending danger that could be identified, but there were multiple risk factors in a situation, such that it could change and risk or danger could escalate fairly quickly if nothing was done. Insofar as the process of assessing child safety, overwhelmingly, staff felt that the process was a good one. They talked to us about some bumps in the road about implementation, because things had been done pretty quickly, but that now training had been completed. They were becoming more proficient in using the tools and the processes and they truly felt that they were doing more thorough investigations. They did tell us that this process takes more time, and that it continued to take more time even though they were for the most part over the learning curve, if you will. There were also some issues with regard to documentation and duplication of documentation that needed to be addressed, and it's our understanding that those have been dealt with since the time that we issued this report. Also, some expression of concerns about inconsistency of skills across staff. We know that you have a fair amount of turnover in some of your offices here in Oklahoma, so that... those comments weren't unexpected. With regards to using safety plans. Again, think in terms of a safety plan is applied only when a child has already been found to be unsafe in some way. And the safety plan then is crafted and enacted to mitigate the danger to the child, yet allow the child to remain at home or with the extended family. Overall, staff felt that was a good thing, that children were better off if removal can be avoided, just as we heard Page talk about a moment ago, but that creating and monitoring safety plans is challenging. It requires time, it requires skill, it requires resources... and that not all staff are equally... as well able to do that and to do that effectively. Continuing then with comments about staff skills and knowledge and capacity, specifically as it related to safety assessment and planning, almost everyone we talked with told us that training has improved with the enactment of the new processes, and that they have had mentoring and coaching, which has been very helpful, so that there is ongoing support in helping case workers apply these new practices and processes. And again, they express concerns about turnover so that at any given time there are likely to be new and relatively inexperienced case workers in offices. That, also because of high turnover, that people may move into supervision without the optimal level of experience. That in some offices the ratio of supervisors to case workers was fairly high. From one supervisor to five case workers all the way up to one to nine. One to seven being the most common one that was cited to us. That there was a greater need for more skill building in training that older employees also needed to be brought into training. And that when reviews are done of situations where there have been serious injuries of children or deaths of children in child protection cases that there needs to be a systematic way of using and incorporating the learning from those analyses into policy and training. Again, this was not, this was a very focused review, so this was not in any way exhaustive in terms of looking at the full spectrum of child welfare services here. Much of the policy was still undergoing revision at the time we did this analysis and report, so we did not do an in-depth policy analysis. We reviewed the documents that were provided to us and we didn't do case reviews or interviews with service recipients and stake holders and so on. So, our coverage of areas was fairly limited due to our time constraints, so those are what we consider to be the limitations of this report. We did make several recommendations as you can see we made some, and these are fairly minor in my view, recommendations concerning revisions to this... is the AOC, is the Assessment of Child Safety. We just made some suggestions about some relabeling and for the most part more minor sort of technical adjustments. Being sure that terms, specific terms particularly those related to safety response, were clear to staff. We again, followed up on some of the interview comments about duplication in documentation and the fact that these new processes were requiring more time. We had some recommendations pertaining to that, with regard to the documentation issue. Also, trying in the future... and I understand that there is some plans being made to do this, that there would be a workload analysis to really get at with these changes, how has that impacted the amount of time that is required now to do a child protection investigation as compared to the time it required under the old policy and procedures? Again, recommended that priority be given to the coaching and mentoring, which we know is so important in allowing the staff to gain proficiency in this type of assessment. And we made some recommendations that you can see here with regard to specific factors that needed to be focused on in that coaching and mentoring. That there needed to be people available in each area who... with expertise to provide consultation and practice model and its implementation. That this issue of the fact that there are some families with multiple risk factors, where the child is not yet determined to be unsafe, that that needed to be addressed with regard to guidelines and training and insuring that staff are clear on how to respond in those situations. And that there should be some associated revisions to the practice model guide to reflect that. And also, to look at the need in some situations possibly for court ordered services even when children remain in the home if the family is not participating voluntarily. Commissioner: Question? Dr. Steib: Yes? Commissioner: Sue, the recommendations on page twelve and thirteen are many, but could you provide just two that are primary recommendations as you finish your report? Dr. Steib: The big finding really in this... well, I might say two. I will start though with what I was going to say. To us, the big finding here was this lack of clarity in these admittedly fairly rare situations, but in these cases of high risk. So that in my mind and I think in Barry's also, in our discussion, the discussions that we had after we completed this review with the administration and DHS, that was the first thing that we felt needed to be addressed. There were clearly some staff who were concerned about the fact that, while it may not be many children, it could still... that those situations could still be fairly significant and that they needed more clarity. So, that was the one. The other was that doing work this way is more time consuming and it's more difficult. I mean this is hard work folks. I mean these situations are complex and that staff... that's why we made the recommendation for the coaching and the mentoring. That there needs to be a sufficient number of people at the front lines of practice who truly have strong assessment skills, who understand the distinctions between risk and safety, and who can apply good critical thinking and who can support staff consistently in doing that. But it's clearly taking more time. That's the reason for our recommendation for the workload analysis and for the continuing emphasis on having people at the front lines of the practice who have the expertise, who can mentor and support those who are just coming on who maybe still are lacking in experience. Commissioner: Thanks. Dr. Steib: Yes? Commissioner: OK. So as I understand it, with your organizations help and I've been telling your partner here that for fifteen years and I want to tell you, well done and that I appreciate you all jumping in and helping here. Okay, the request here that your document says here, stemming from child deaths occurring in the late 2010, and which resulted in (inaudible) that raised questions concerning the policies that had already been established between 2009 and 2010 from that legislation,correct? Dr. Steib: That's correct. Commissioner: But as I understand it you all have not, or did I see that correctly when I saw somewhere in there where you all had not actually looked at some actual cases or anything? Dr. Steib: We did not do case file reviews in this study. No we did not. Commissioner: As I understand it you are continuing to jump in and help us along? Is that correct? Dr. Steib: That's correct. Commissioner: So would you all be available then to actually examine? Since you all were called in because of the child death issues, would you be available to actually take a look at some of the child death cases in light of the policies that are going on and help us kind of determine whether or not our policies, rules, and regulations are working? Dr. Steib: We've not had that discussion, we have not been asked to do that. That's potentially something that we could do. Dr. Walley: Check case reviews... Dr. Steib: Yes, we have, Page was just mentioning, we have been very much involved in doing reviews of cases of another sort in Oklahoma this year. And those are situations of children who have been in care for a longer period of time and who are in need of permanency. So we have done some case reviews. I personally have sat at the table with many of your staff out in the counties around the state and discussed some very difficult and complex cases. We have not done a review of child protection investigations per se. Commissioner: Sue. Follow up to Wes' comments on page eleven, at the top. You say currently according to earlier reports, that these instances are investigated, but there is not a clearly defined and implemented process reusing the learning from the investigation to inform changes in training and or policy. Dr. Steib: Right. Commissioner: Do you find that to be pervasive from your interviews? Dr. Steib: No. No. That was mentioned by probably some of the management staff that we interviewed. It was not pervasive. Chairman: Any other questions? Commissioner: What about adherence to the policies and the quality of training so it sticks with front line workers? How do you go about...or working with that? Dr. Steib: That, that, was really looking at adherence to policy was beyond the scope of this review except as was indicated by the number of comments that we heard in the interviews with regard to people saying things like, " Given the turnover, given the number of new staff, given the difficulty of doing this work" that there were concerns that there were inconsistencies. And those comments were not surprising to us. We would have expected that at that point in the implementation of new processes like these, that, that would probably be the case. Commissioner: Can you assess or did you look at the level 1 turnover and... Dr. Steib: I have not looked at the actual data currently... what it is currently, but what we were told at that point was that there were certain places in the state where turnover was a particular concern at that time. Commissioner: More of the front line than the supervisors? Dr. Steib: Yes, and at that time the Oklahoma City area was one in which there was particular concern. Director Hendrick: That was... at that time, that was when we had switched out part of the changes in the law that we were realignment in Oklahoma County and Tulsa County and so part of that was people getting their jobs changed was part of that realignment, so you had some changes, which you would expect. It has pretty much stabilized since that time... Dr. Steib: Good. Other questions? Dr. Walley: I was just going to follow up with one of the comments that Sue was making about, Commissioner Dow I think your question, about policies versus implementation of policies and that is one of the areas that we are... this was not designed to specifically get at that depth. I think one of the things that we did determine is that the policies and the plan are sound. The execution of the plan is something that has to be continually evaluated. Having led a system that was one of only two that's ever come out of federal oversight... the reforms that are under way here and that we are pleased to be investing in and working with along side you on are multi-year. And that sometimes is difficult for those of us that want rapid change, to fully embrace, but the systematic change like we were showing on the data and the responses of the data to the practice changes, and hopefully the implementation of the practice that appears sound, is something that we are... we don't invest imprudently. And I'm responsible to my Executive Vice President and to our Board of Trustees to being able to say, "These are the jurisdictions where we believe with our investment of our resources and personnel we can assist them in achieving the vision for safe permanent homes for children and reducing the shame of having so many children raised out-of-home and aging out." This is a place where we have decided we are going to invest, they've decided that they want to continue to invest, because we see the plan is one that's sound. I read this recently and I just wanted to share one comment and then I'll step aside. You might have other questions. "The most successful child welfare agencies have strong and sustained leadership that has a clear and unwavering vision. They also have the commitment of political leaders, community partners, and the courts to undertake the multi-year endeavor required to improve outcomes." That is something that we adhere to and believe in.