County Executive Officer*

Staffing: Despite the decline in the Orangewood Children's Home (OCH) population, OCH still maintains a staff of over 300 SSA employees. Response: Agree with finding.

Staff to Child Ratio: The staffing ratio to children at OCH is far more generous than is mandated by California law. Response: Disagree wholly with finding. OCH's current staff to child ratio is necessary and not considered generous. OCH's staffing ratio is commensurate to ensure the health and safety of the high-risk children it serves. Assembly Bill 1197 and Title 22, Section 6, Chapter 5, Paragraph 84265.5 mandates OCH to have a staff to child ratio of 1:3 for children ages two days to six years. For children seven to 19 years of age, OCH's staff to child ratio is 1:6 during school hours and 1:4 during non-school hours. Severely emotionally disturbed children that have a Rate Classification Level (RCL) 14 are required to have a staff to child ratio of 1:2. In addition, approximately 20-25% of the children require a staff to child ratio of 1:1 or 2:1 due to suicidal ideations, aggressive behaviors, and mental health issues. On occasion, OCH must hold children pending placement in a locked psychiatric facility and these children often require a staff to child ratio of 1:1 or higher. California Department of Social Services (CDSS) Community Care Licensing (CCL) requires a staff to child ratio that is consistent with the CDSS CCL Group Home Regulations, which is 1:10 from 7:00 a.m. to 10:00 p.m. (Section 84065.5). This staff to child ratio is for facilities that generally provide group home care or childcare services to typical children living in the community and attending public school. OCH, although licensed as a group home facility, also functions as an emergency shelter. These standards are not appropriate for OCH, which provides supervision and services 24 hours per day, seven days a week. OCH cannot refuse placement of any child, including those requiring a significant amount of supervision and services. These children arrive at OCH unplanned, with no notice, in crisis and with a vast array of medical and behavioral issues. Staff must nurture and assist them with their emotional adjustment. When appropriate supervision exists, staff achieve greater success in addressing individual children's needs; staff are better able to de-escalate an agitated child. The 24% decrease from 2002 to 2006 in the number of incidents requiring staff to physically escort or restrain children and the 38% decrease from 2002 to 2006 in the number of children sent to psychiatric hospitals illustrates the staff's accomplishments. The CCL staff to child ratio standards is unacceptable for OCH, as it would decrease supervision, place children and staff at risk, and increase liability for the County. Therefore, SSA does not agree that staffing to child ratios at OCH are generous, but are necessary to meet the needs of the children. Exhibit 2

Orangewood Children's Home Population: OCH has a very small population of children. Response: Disagree partially with finding. OCH currently operates at approximately 50% of full capacity; however, this decrease in population is by design. SSA considers it a great success. In accordance with Federal (Adoptions and Safe Families Act, 1997) and State (Assembly Bill 636, 2001) legislation mandates, CFS continues to work diligently to maintain children in their homes or to place them in family-like settings. This significantly reduces the population at OCH; however, OCH's average daily population for fiscal year 2006/2007 was 106. The highest daily population for fiscal year 2006/2007 was 135. While great improvements have been made, CFS' ultimate goal is to reduce OCH's population to fewer than 60 children.

HCA's Labor Burden: The labor burden of Health Care Agency (HCA) employees working at OCH is approximately 30% of wages, and the indirect costs applied amount to another 23% of total wages plus burden. HCA Response: Agree with finding.

Placement of Seriously Emotionally Disturbed Children: Social Services Agency (SSA) management appears reluctant to place seriously emotionally disturbed children, in a timely manner, in facilities that meet their unique needs. Response: Disagree wholly with finding. This finding is totally without merit and cannot be supported by the facts. CFS is very successful in placing seriously emotionally disturbed children into the least restrictive, safe environment within the shortest possible time, subject to available facilities/services to meet the specific needs of each child. CFS collaborates closely with HCA Behavioral Health to provide additional support services, such as Wraparound and Multi-Treatment Foster Homes. Since 2002, the average stay for a child at OCH has declined approximately 40%. In addition, CFS conducts Relative Assessments to expedite placements. SSA's goal is to place children in the most appropriate and permanent setting, while attempting to safely maintain connections with family, significant persons in the children's lives, and the community. The State and Federal governments have determined that it is not in the best interest of a child to have multiple placements. Through the AB 636 Outcome Measures, the State oversees our progress in meeting the requirement that youth do not have more than two placements in the first year in out-of-home care. Therefore, in an effort to decrease the number of placements a child experiences and to reduce trauma to the child, CFS thoroughly assesses and looks for the most permanent, appropriate placement to meet each child's individual needs at the time of placement. SSA's Placement Coordination Program and Multi-Treatment Transitional Services Program assess emotionally disturbed children on a continuous basis and attempts to match them with placement resources that meet their needs. These children typically fall within the RCL 12 to 14 range, meaning they require the highest level of care outside of a locked psychiatric facility. Resources for this level of care are limited. Currently, only three six-bed facilities operate in Exhibit 2 Orange County that meet the needs of severely emotionally disturbed children. However, the three facilities operate at or near 100% occupancy and have age restrictions so not all children are eligible. There are no RCL 14 facilities in Orange County for children ages 13 to 18 that focus strictly on behavioral disorders.

Performance Audit: OCH has not had an operational performance audit recently. Response: Agree with finding. While it is unclear what the Grand Jury means by "recently," there are ongoing external audits conducted on the daily operations of OCH. OCH received its license as a group home on July The licensing process required submission of a program statement and an 31, 2001. audit/inspection by CDSS' CCL Division. The audit/inspection looked at building and grounds, personnel/records, training, and program operations. CCL also conducts an annual audit of these areas for operational compliance and license renewal; however, the audit for 2007 has not been conducted as of the date of these responses. Additional external audits/inspections of OCH are as follows: Orange County Juvenile Justice Commission conducts two annual audits, one announced and one unannounced. ➤ Orange County HCA/Environmental Health conducts one annual inspection. > California Department of Education conducts an inspection every five years on compliance with State and Federal guidelines for State and Federal school lunch programs. > Orange County Fire Authority conducts an annual inspection. > Orange County Auditor-Controller annually audits the petty cash fund. Response to Recommendations