4.2 Conducting the Initial Safety Assessment

Georgia State Seal

Georgia Division of Family and Children Services
Child Welfare Policy Manual

Chapter:

(4) Initial Safety Assessment

Policy Title:

Conducting the Initial Safety Assessment

Policy Number:

4.2

Previous Policy Number(s):

N/A

Effective Date:

November 2023

Manual Transmittal:

2023-03

Codes/References

O.C.G.A. § 15-11-30 Rights and Duties of Legal Custodian
O.C.G.A. § 15-11-125 Venue
O.C.G.A. § 15-11-133 Removal of Child from the Home; Protective Custody
O.C.G.A. § 15-11-150 Authority to File Petition
O.C.G.A. § 15-11-202 Reasonable Efforts by DFCS to Preserve or Reunify Families
O.C.G.A. §16-12-100 Sexual Exploitation of Children; Reporting Violation; Forfeiture; Penalties
O.C.G.A. § 19-7-5 (e)(f) Reporting of Child Abuse
O.C.G.A. § 49-5-8 Powers and Duties of Department of Human Services
O.C.G.A. § 49-5-40 Definitions; Confidentiality of Records; Restricted Access to Records
O.C.G.A. § 49-5-41 Persons and Agencies Permitted to Access Records
Title IV-E of the Social Security Act Sections 471(a) (15) (D) and (a) (9) (c), and 475 (9)
45 CFR Parts 1355.38(a) (5), 1356.21(b) (3) (i), 1356.21(k), and 1356.67
Child Abuse Prevention and Treatment Act (CAPTA)
Indian Child Welfare Act of 1978 Final Rule (25 CFR Part 23)
Public Law (PL) 104-191 Health Insurance Portability and Accountability Act (HIPAA) of 1996
PL 105-89 Adoption and Safe Families Act (ASFA) of 1997
PL 113-183 Preventing Sex Trafficking and Strengthening Families Act of 2014
J.J. v. Ledbetter-Release of Information of Confidential Records

Requirements

The Division of Family and Children Services (DFCS) will:

  1. Prepare for the Initial Safety Assessment (ISA) to direct and focus case management activities.

  2. Complete the ISA within 72 hours of the assigned response time:

    1. Conduct a private face-to-face purposeful contact with the alleged victim child(ren) within the response time to assess and address child safety.

      When a new intake report is received and screened in on an active case, a new ISA must be initiated within the assigned response time.
    2. Take action when present or impending danger is identified.

    3. Begin an assessment of family functioning.

    4. Make a safety determination.

    5. Determine track assignment to Family Support Services (FSS) or Investigations.

  3. Adhere to Health Insurance Portability and Accountability Act and confidentiality provisions outlined in policies 2.5 Information Management: Health Insurance Portability and Accountability Act (HIPAA) and 2.6 Information Management: Confidentiality/Safeguarding Information.

  4. Keep the identity of the reporting source confidential (see policy 2.6 Information Management: Confidentiality/Safeguarding Information).

  5. Analyze DFCS history to ensure a thorough assessment of safety and family functioning.

    If the analysis of DFCS history reveals that a previous ISA, FSS or Investigations was closed due to the family being unable to be located and the previous allegations were not assessed, assess both the previous and current allegations of maltreatment.
  6. Use court intervention and/or request support from law enforcement to interview or observe a child when prevented from doing so, and safety cannot be assured (see policy 17.1 Legal: The Juvenile Court Process).

  7. Engage each household member face-to-face and privately to discuss the maltreatment allegations and assess child safety and family functioning. This includes the following individuals:

    1. Alleged victim child(ren)

    2. Each parent

    3. All adult household members

    4. Other children in the home

    5. Alleged maltreater(s)

      This includes alleged maltreaters identified as a person responsible for the care of a child, but do not reside in the home. In such instances, if the alleged maltreater does not have access to the child, the interview with him/her may be conducted upon track assignment.
  8. Inform the individual subject to a child abuse report (alleged maltreater) of the allegations made against him/her at the time of initial contact, whether face-to-face or by telephone.

    The Social Services Case Manager (SSCM) must be certain he/she is speaking to the alleged maltreater. To protect the confidentiality of the family, if the identity of the alleged maltreater cannot be confirmed, do not discuss specific allegations.
  9. Conduct a visual assessment of all children to determine if any injuries or signs maltreatment exist.

  10. Observe the physical home environment, including every room in the home to determine if it is safe and appropriate to meet the needs of each child.

  11. Assess and discuss safe sleep practices with any parent who has an infant (up to one year of age) in the home. Take action to remedy unsafe sleeping situations prior to leaving the home (see Forms and Tools: Infant Safe to Sleep Guidelines and Protocol).

  12. Make a safety determination in consultation with the Social Services Supervisor (SSS) prior to concluding each purposeful contact with the child, parent custodian, adult household member, and/or alleged maltreater; and take immediate action to control the identified safety threats if the child is unsafe.

  13. Engage any child(ren) in the legal custody of the parent(s) in a face-to-face purposeful contact(s) who do not reside in the home concerning child safety and family functioning.

  14. Engage collateral contacts who can provide relevant information for assessing maltreatment allegations, child safety, and family functioning.

  15. Request state criminal history record information of adult household members when criminal history may impact child safety, in accordance with policy 19.8 Case Management: Criminal Records Checks.

  16. Afford all rights under the Indian Child Welfare Act (ICWA) to any child who is a member of a federally recognized Indian Tribe, or eligible for membership and has a biological parent who is an enrolled member and is subject to removal, placement and/or any other legal action involving DFCS to promote the stability and security of Indian Tribes and their families (see policy 1.6 Administration: Indian Child Welfare Act (ICWA) and Transfer of Responsibility for Placement and Care to a Tribal Agency).

  17. Report to law enforcement immediately (no later than 24 hours) and refer the child to an available victim assistance organization, as certified by the Criminal Justice Coordinating Council when a child identifies as being a known or is a suspected victim of sex trafficking/sexual servitude. See Forms and Tools: Human Trafficking Case Management Statewide Protocol.

  18. Immediately report any new, known, or suspected instances of child abuse to the CPS Intake Communications Center (CICC) as outlined in policy 3.24 Intake: Mandated Reporters.

  19. Conduct efforts to locate a family when they cannot be located or have moved to an unknown location in accordance with policy 19.21 Case Management: Unable to Locate.

  20. Make reasonable efforts to maintain the family unit and prevent the unnecessary removal of a child from his/her home, as long as the child’s safety is assured (see policy 9.5 Eligibility: Reasonable Efforts).

  21. Make a track assignment determination in consultation with the SSS using the following criteria:

    1. Family Support Services (FSS) when no present or impending danger is identified.

    2. Investigations:

      1. Present or impending danger is identified.

      2. The following circumstances regardless of the existence of present or impending danger:

        1. When a new report is received on an active case: Investigation (INV), Family Preservation (FPS), or Foster Care (FCC/FCF) or Adoption (ADO).

        2. Any injury to a child including but not limited to bruising, cuts, welts, abrasions, lacerations, fractures, dislocations, sprains, punctures, burns and scalding as well as internal injuries.

        3. Chronic/severe neglect indicating failure to thrive, malnourishment, severely underweight, starvation, confinement, life-threatening living environment, withholding medically indicated treatment or other circumstances which may significantly impair child health, well-being or functioning.

          This includes alleged child maltreatment involving infants that are born alive in which there is suspected medical neglect, including the withholding of medically indicated treatment from disabled infants with life-threatening conditions.
        4. Prenatal abuse

        5. Trafficking a child for labor servitude (labor trafficking)

        6. Sexual abuse and sexual exploitation

        7. Unaccompanied homeless youth

        8. When the family cannot be located, moved to an unknown location, or contact cannot be established with an essential family/household member.

  22. Document case activities in Georgia SHINES within 72 hours of occurrence.

It is critical to obtain as much complete and thorough information as possible when conducting the ISA in order to make an appropriate safety decision. When information is insufficient, unknown, or unavailable during the ISA, concern for child safety increases.

Procedures

Social Services Case Manager

  1. Prepare for the ISA in accordance with policy 4.1 Initial Safety Assessment: Preparing for the Initial Safety Assessment.

  2. Analyze DFCS history involving parent and all children in the home in accordance with policy 19.10 Case Management: Analyzing DFCS History.

  3. Contact the reporter, if known, when clarification and/or additional information related to child safety and the allegations of maltreatment is needed.

  4. Complete attempts to locate the alleged child victim(s) to assess child safety including but not limited to:

    1. Visiting the location where the child is believed to be; and/or

    2. Contacting persons that could help verify or help locate the child or family, including but not limited to family members, neighbors, childcare agencies, school system, law enforcement, and other agencies that may be involved with the family.

  5. Conduct a private face-to-face purposeful contact with each alleged victim child within the assigned response time to assess child safety (see policy 4.3 Initial Safety Assessment: Purposeful Contacts During the Initial Safety Assessment).

  6. Inform the alleged maltreater of the child abuse allegations during the initial contact with him/her via telephone or through face-to-face contact.

  7. Engage each household member face-to-face and privately to discuss the maltreatment allegations and assess child safety and family functioning in accordance with policy 4.3 Initial Safety Assessment: Purposeful Contacts During the Initial Safety Assessment. This includes the following individuals:

    1. Alleged victim child(ren)

    2. Each parent

    3. All adult household members

    4. Other children in the home

    5. The alleged maltreater(s)

  8. Conduct a visual assessment of all children to determine if any injury or signs of maltreatment exist as outlined in policy 4.3 Initial Safety Assessment: Purposeful Contacts During the Initial Safety Assessment.

  9. Observe the physical home environment, including every room in the home to determine if it is safe and appropriate to meet the needs of each child in accordance with policy 4.3 Initial Safety Assessment: Purposeful Contacts During the Initial Safety Assessment.

  10. Make a safety determination in consultation with the SSS prior to concluding each purposeful contact with the child, parent, adult household member, and/or the alleged maltreater in accordance with policy 19.11 Case Management: Safety Assessment. Take immediate action to control the identified safety threats if the child is unsafe:

    1. Develop and implement with the caregiver(s) a safety plan in accordance with policy 19.12 Case Management: Safety Plan & Management; and/or

    2. Initiate court/legal intervention in accordance with policy 17.1 Legal: The Juvenile Court Process.

  11. Engage any child(ren) in the legal custody of the parent in a face-to-face purposeful contact(s) who do not reside in the home concerning child safety and family functioning (see policy 4.3 Initial Safety Assessment: Purposeful Contacts During the Initial Safety Assessment).

  12. Engage collateral contacts that are knowledgeable about the allegations of child abuse, child safety, and family functioning in accordance with policy 19.16 Case Management: Collateral Contacts when a safety determination cannot be made based on the information gathered.

  13. Make a track assignment determination in consultation with the SSS.

  14. Upon SSS approval of the track assignment determination, engage the family in a discussion of:

    1. The safety determination and what to expect during the FSS assessment or Investigation

    2. Any safety plan to address safety concerns

  15. Submit the ISA to the SSS for approval within 72 hours of the expiration of the assigned response time.

Social Services Supervisor

  1. Assist the SSCM in preparing for the ISA in accordance with policy 4.1 Initial Safety Assessment: Preparing for the Initial Safety Assessment.

  2. Consult with the SSCM after each purposeful contact with child, parent, adult household member, and/or the alleged maltreater to:

    1. Make a safety determination in accordance with policy 19.11 Case Management: Safety Assessment;

    2. Discuss safety interventions to control any identified safety threats including safety planning in accordance with policy 19.12 Case Management: Safety Plan & Management; and

    3. Discuss any inconsistencies identified and follow up needed.

  3. Review the sufficiency of any safety plan for controlling or mitigating the present or impending danger in accordance with policy 19.12 Case Management: Safety Plan and Management.

  4. Review documentation to provide guidance regarding the ISA.

  5. Make a track assignment determination in consultation with the SSCM.

  6. Review the submitted ISA and make an approval decision within 72 hours of the expiration of the assigned response time.

Practice Guidance

Initial Safety Assessment Completion Timeframes

Assigned Response ISA Completion Timeframe

Immediate

24 hours + 72 hours

24 hours

24 hours +72 hours

5 weekdays

5 weekdays +72 hours

Caregiver

Caregiver means any person providing a residence for a child or any person legally obligated to provide or secure adequate care for a child, including his or her parent, guardian, or legal custodian. In addition, a caregiver may be a foster parent, day care provider or facility staff for the purposes of a special investigation.

  1. Primary caregiver: The person living in the household who assumes the most responsibility for childcare.

  2. Secondary caregiver: A parent or other person living in or frequently in the household who shares with the primary caregiver the routine responsibilities for childcare. A significant other residing in the home may be a secondary caregiver even though this person has limited childcare responsibility and may not have any legal relationship or obligation to do so.

  3. Person Responsible for the Care of a Child means:

    1. An adult member of a child’s household;

    2. A person exercising supervision over a child for any part of the 24-hour day; or

    3. Any adult who based on his or her relationship to the parent, guardian or legal custodian or a member of a child’s household has access to such child.

Safe Sleeping Recommendations for Infants up to One Year of Age

Caregivers of infants (birth to 12 months old) must be informed of conditions that constitute a safe sleeping environment and that reduce the risk of Sudden Infant Death Syndrome (SIDS)/Sudden Unexpected Infant Death (SUID), also known as “crib death”. At minimum, caregivers should be advised of the three primary safe sleep recommendations of the American Academy of Pediatrics (AAP) commonly referred to as the ‘ABCs’ of safe sleep:

  • Alone – The baby’s sleep area should be close to, but separate from, where caregivers and others sleep. The sleeping area should be free of soft objects, toys, and loose bedding.

  • Back – Infants should always be placed on their back to sleep for naps and at night.

  • Crib – Place infants on a firm sleep surface, such as on a safety-approved crib mattress, covered by a fitted sheet.

Further additional information and guidance regarding safe sleeping and SIDS/SUIDS see Infant Safe to Sleep Guidelines and Protocol in Forms and Tools.