Investigation and treatment are incompatible when carried out by the same agency, and I might suggest that investigation from a social point of view, such as a social history which gets into the background of the parents and what is going on, is a normal process of any kind of treatment program. But investigation where you are trying to find out who struck John, and when, is not necessary to be part of a

treatment.

Treatment can be done without persons even actually admitting to having done battering.

So, therefore, treatment must be based on mutual trust, characterized by an atmosphere of openness. Otherwise, it will be thwarted if investigation remains the responsibility of the center.

Line 1 on page 5 is also in conflict with page 10, lines 15 through 19. And on page 10 it directs the center to notify the specially trained and designated unit of the police department to be responsible for this investigation.

So, the bill seems to be in conflict from page 5 to page 10.

In accordance with accepted professional roles, in lines 7 through 10 on page 5, it should read:

psychiatrist, psychologist, and social worker team members to ensure that an abused child and the members of his family are provided mental health counselling or treatment necessary for the protection of the child.

In other words, we would add "social worker" there.

CENTRAL REGISTRY

We have further concern about page 7, lines 1 through 15. We are talking here about the concern of a battering parent in allowing such information to be shared with other jurisdictions. As in our experience, some of the most mobile families, which have been referred to earlier here today, such as the military families, have had death after death in State after State, because in part the new communities were not aware of their past histories, and this is not information likely to be volunteered.

True, the misuse of this information must be guarded against. Nevertheless, we are in favor of a confidential central registry, which has long been needed.

On page 11, line 13, we would replace the word "investigation" with "evaluation."

Also, here we must ask what role does the Protective Services Division of the Social Rehabilitation Administration take in all of this. It would seem that they should not be written out of their role in this matter. Neither should there be a duplication of services.

All agencies involved in child abuse have to be coordinated with the center.

In D.C. there is now a patchwork of agencies responsible for prevention and correction of child abuse.

FOSTER CARE

In addition to Protective Services, also involved are Foster Careand there is usually foster care for the child and a foster care worker for the parent-Special Services, there is the Criminal Adult Probation worker, which often the parents in these cases-in my therapy group, the parents have two probation workers, one from Criminal Adult Court and another from Intra family Court. Also, you have the private and public hospitals and clinics, the Youth Division of the police department, as well as Forensic Psychiatry involved.

The Child Abuse Center can hopefully coordinate all the efforts of these agencies on a voluntary basis.

However, for the center to take over the services offered by these agencies is a mistake. The center should fill the gap where resources do not now exist, or are insufficient, as they are, such as in the area of intensive treatment and the coordination of existing agencies.

The center should also recommend the development of additional needed resources, and these will become clear as we start to work with them.

We are already very concerned about the attempts of the Department of Human Resources to dilute and weaken their own Protective Services Division, which will be a disaster to the children of this city. In fact, we hope this bill will mandate the continuing existence of a separate and identifiable protective services division.

The center should also have the responsibility to set standards and monitor the provision of services in meeting those standards.

PROTECTIVE SERVICES

Now, I would like to say, in referring to the Protective Services problem, that I think it has been referred to several times here today. What we are finding is that as the department decentralizes and is going into their generalized social work that protective services cases are being dumped into caseloads of 200. There is no way these children can be protected when they are in caseloads of two to three to who knows how many hundred people.

So that we find that although their intent may be to protect these children that there is no possible way to bring this about.

On page 12, Section 206, we wish to note that a social worker can also be considered part of "medical personnel" under many sets of circumstances, just as a psychologist can, and they are admitted there. In line 22, consideration should be given to omitting the word "center" when it refers to day care centers in order that babysitters are not excluded, either licensed or non-licensed.

We are concerned about Section 302 on page 17. because of the time constraints. Even taking Home Rule into consideration, this could, in effect, encourage authorities to delay getting the project off the ground in awaiting anticipated Council action.

We have heard Mr. Yeldell say today that they have a plan. We have been waiting three years for this plan, and if we have to continue to wait for three more years for the plan to go into effect, children will die meanwhile.

There are some items in HR15918 that should be included in this bill. From page 17, line 16, through line 18 of page 18-Section 301 (b) (2)-in reference to the examination of the parent, for instance.

We would like to point out one important omission from the bill, and that is the explicit provision for a therapeutic crisis nursery with the necessary day care specialists. In my therapy group, occasionally people bring their infants and their young children into the group, and this is very difficult to function, so that some sort of facility needs to be available. Also, it could be helpful to the children in the treatment kind of function.

Finally, unless this project is planned for failure, only a manageable chunk of the whole child abuse spectrum should be tackled.

Cases reported to the center as alleged battering cases which are later determined to be cases involving neglect but not actually abuse should be returned to the Protective Services unit, and not handled in the center.

Let us now begin, through this bill's passage, to take an active interest in the children of this city, so they will not be among the two children a day who die in this country as a result of physical abuse by their parents.

We thank you for helping us save the lives of these children and babies whom we all know are helpless without an advocate.

Mr. MAZZOLI. Thank you, Ms. Riley.

Ms. Galdi, is that right?

Ms. GALDI. That is right.

My name is Martha Galdi. I live at 3851 Porter Street, Northwest, in Washington, D. C.

I represent the Community Task Force on Child Welfare Reform, a community coalition which includes members of FLOC,-For Love of Children, Incorporated-the National Association of Social Workers, the Council on Adoptable Children, the Georgetown Law Training Program, and other interested citizens.

I am accompanied here today by Ms. Mary Ann Stein, who is the attorney in the FLOC Child Advocacy Office.

We are here to discuss H.R. 15779 and H.R. 15918.

We share your concern and are heartened by your desire to improve the treatment of both abused and neglected children. We are not convinced, however, that either bill before us today adequately addresses the problems of the District of Columbia child care system.

CENTER FOR PREVENTION AND TREATMENT

We agree with the drafters of H.R. 15779 and H.R. 15918 that the development of a center for the prevention and treatment of child. abuse and neglect is a good idea, but we believe the function of the center and its relationship to existing agencies must be more carefully thought out and more specifically addressed.

We envision the ideal center as one which not only provides new rehabilitative services and techniques to families, but also coordinates and expands existing resources such as social work intake, medical screening, and an array of other crisis services to children and families. We would hope the primary goal of the center would be to keep as many children as possible in their own homes. We would, therefore, expect to see an emphasis on preventive services. We believe all of these services should be spelled out in the legislation creating such a

The key to effective preventive services is an adequate protective

services section.

The District of Columbia has been unusually fortunate in the existence of a protective service function within the Department of Human Resources, a function which deals with as many, if not more, children who are potential victims of abuse and neglect as children who have already been victimized.

Protective services is also a function that seems to be disappearing in the reorganization of DHR. In our judgment, it does not make sense to talk about new clinical services or the expansion of existing services without providing in some way for the continuation and strengthening of protective services.

We might note we were somewhat startled to hear Mr. Yeldell's statement this morning. It is the first time I have seen him on public record stating that Protective Services will be strengthened. It is our understand that, in fact-in fact-Protective Services case workers in decentralized centers are not functioning as specialists in some centers; not all. We are pleased to hear this.

Currently, a variety of resources are provided by or through the Department of Human Resources.

There currently exists within DHR a wide range of crisis services essential to dealing with the problems of abuse and neglect. Protective Services has associated with it a 24-hour intake screening service operated by trained caseworkers; emergency cash aid: family shelters; emergency foster homes, and homemaker service. Other jurisdictions have increased their effectiveness by adding an emergency caretaker component, emergency diagnostic screening, and crisis daycare.

Any service to abused and neglected children must have available a wide range of supplementary services and these, too, are present in the District, though they are currently either difficult to obtain on an emergency basis or are insufficient in supply. Psychiatric counselling, group therapy, family planning, employment counselling, housing referral, the list is a long one.

While we do not mean to say these are totally adequate in quantity, quality, or comprehensiveness, we are not convinced H.R. 15779 or H.R. 15918 would actually improve the delivery of such services for the following reasons.

The bills before us set up a separate agency outside DHR which would have many of the functions and responsibilities presently delegated to DHR. How this separate agency would function in relation to DHR is unclear. Nowhere is there any provision removing these responsibilities from DHR.

While the bills call upon the director of the new agency to coordinate all public and private resources, his authority to do so is not explicit and without carefully setting out the relationship of the new agency with DHR and other existing agencies, there is bound to be confusion, duplication, and inefficient delivery of services.

DHR funding under the Social Security Act is contingent upon the provision of a complete range of services in child welfare as well as other areas.

INDEPENDENT AGENCY QUESTIONED

The establishment of an independent agency raises two major questions:

(1) Will not the mandate from Congress necessitate a duplication of services by the new agency and DHR?

(2) Will Congress fund such duplicative efforts? Would it not be more sensible to place the center within DHR which already has the potential at least to provide all the services the center would need?

(3) It is meaningless to attempt to improve the lot of neglected and abused children in this city without requiring functions for research, data collection, evaluation of goals and programs, formulation of standards and regulations, and without also requiring accountability for all these functions as well as for their adequate performance.

(4) To talk about neglect and abuse without recognizing the neglect and abuse perpetrated on children in public care by the system is hypocrisy. There needs to be more attention given to the needs of children committed to public care and more stringent standards of care and treatment must be legislated.

AMENDMENTS PROPOSED

In this respect, we note for instance Title III of H.R. 15779 provides for the appointment of a guardian ad litem for neglected children before the court.

It is our firm belief that such children must have a statutory right to an attorney and not just a guardian ad litem. Clearly, theirs are the most important rights and interests at stake, and these rights should be given the highest protection.

In sum, it appears H.R. 15779 and H.R. 15918 were conceived out of a belief that neglected children in the District of Columbia are not receiving adequate services from the District government. We share that belief, but we do not believe the bill will significantly improve the lot of neglected children.

If DHR is not meeting its responsibilities, there seems to be two choices available to the lawmakers to ensure better service.

One, child welfare services could be lifted totally out of DHR and put in a new agency; or two, DHR could be mandated to conform to certain practices and procedures which would improve child welfare services.

To do neither and attempt to create a rival duplicative agency is not an improvement.

When we learned of H.R. 10959, the predecessor of the present bill, we spoke to the staff working on the bill. We were encouraged to contact others in the community with interest and expertise in child neglect, to write up our news and to submit them to the staff persons. We did that.

For several months numerous persons representing diverse agencies and citizens groups with expertise in child neglect problems met and worked to create a comprehensive bill that would address the major problems in D.C. child welfare.

While we were working under time constraints and could not refine our draft as much as we would have liked, we did submit a copy of our draft to the Congressional staff.

H.R. 15779 or H.R. 15918 do not reflect the substance of our draft. Therefore, we would now offer in into the record, noting that it is a