child welfare watch vol. 21

The Tricky Thing About Visits

Partnerships can transform parent-child visiting and speed up family reunifications—but the barriers remain high.

It's nearly 2pm and Adriana isn't late; this is how she always walks—fast, with her head down, as though she's perpetually ducking something. Twenty-five years old and slight, there's something breakable about her, with pretty, fragile features curtained by hair that swings most of the way down her back. An impassive expression and slow, meticulous attention to detail hint at a mild cognitive disability, but her hands are quick and nervous, fidgeting with a book of stickers.

She's been making this trip twice a week for the past five months, ever since she moved into a transitional housing program near Morningside Heights. It's an hour by subway from the Lower East Side, where she gets to spend about 16 hours a month with her 3-year-old daughter, Jenny.

The stickers are a present, and Adriana already knows that her daughter's foster mother will object. A few weeks ago, on another visit, she and Jenny bought a goldfish together. The foster mother gave it away, sending a message through Adriana's lawyer that she doesn't want Jenny coming home with unapproved gifts.

Still, Adriana doesn't like to turn up empty-handed. These visits are the central events of her week and she wants Jenny to remember them afterward, like she does. After 12 months without missing a visit, Adriana feels like they're finally making progress along the slow, cautiously monitored path that's typical for families in foster care who are expected, eventually, to reunify: From one visit per week to two; two hours to four; supervised to unsupervised to the occasional overnight; and finally, with the permission of a family court judge, a trial reunification.

By court order, one of Adriana's two visits per week must be supervised. Normally, that would mean it has to happen where it's convenient for her caseworker—in an office at her daughter's foster care agency. The caseworker or an aide would watch and keep notes, which would later end up in a report to Jenny's family court judge, along with recommendations on whether Adriana should move to the next stage in the process of getting Jenny back.

But this isn't a typical case. Early on, Jenny's foster care agency, Catholic Guardian Society and Home Bureau, referred Adriana and Jenny to the Lower East Side Community Partnership, which is tasked with running a program that allows families to have their visits in public places, facilitated and supervised by trained members of the community.

Visit programs are a singularly concrete manifestation of the partnerships' mission, moving the work of child welfare out of foster care agency offices and into communities. But they've also proven, in many cases, to be among the most difficult tasks to accomplish. The partnerships' visiting services depend on voluntary cooperation between foster care agencies, which have to refer families to them, and community members who may have no background in child welfare. Their successes and failures serve, in some ways, as a test of the projects' basic philosophy of collaboration, tangled in the complicated and sometimes contentious relationships between community partnerships and the more formal institutions of the foster care system.

***

Kids who have regular family visits tend to have shorter stays in foster care, easier adjustments to placements and more successful permanency plans. In one study of nearly 1,000 foster children in San Diego, families who had frequent visits were 10 times likelier to reunify than those that didn't. After the often traumatic experience of separation, visits are a moment when kids get to see and touch their parents, to know that they're alive and still love them.

For parents, visiting can make or break their chances of getting their kids back. "If you're not having good, consistent visits, children are not going to go home," says Paula Fendall, who directs the Office of Family Visiting at the Administration for Children's Services (ACS). Unlike drug treatment programs or parenting classes, family visits are where foster care caseworkers see parents' progress with their own eyes. "Workers need to know that visits are improving with each visit, that parents are engaging better, meeting the needs of their children, having happy visits," says Fendall. "That's the only way they can move forward to reunification."

Kids who have regular family visits tend to have shorter stays in foster care, easier adjustments to placements and more successful permanency plans.

 

But while everyone agrees that visiting is important, there's less consensus that it gets done often enough or well. "Child welfare is a crisis-oriented, resource-scarce system," says Tanya Krupat, program director for the NY Initiative for Children of Incarcerated Parents at the Osborne Association. "The reality of a caseworker's life is they have to focus on what they're going to be evaluated on, which isn't visiting."

More than a decade ago, Krupat headed up an initiative at ACS to investigate and overhaul family visiting in New York City foster care. The city had been sued over several aspects of its child welfare system, and part of the settlement required that ACS set up an advisory board to find out what was going wrong with visiting programs.

"It was a mess," says Krupat. As head of the board, she went to foster care agencies to see where visits were held. "There were a few that had wonderful spaces," she says, "but some were really terrible. Dirty rooms with broken chairs—things that just conveyed disrespect. I talked to parents who told me, 'You removed my kid from me because of neglect; now I'm visiting with them in a space that I would remove a child from."

The standard practice was to allow families a one-hour visit, every two weeks. Krupat remembers a 13-year-old boy who added that up. "He said, 'I get to see my parents and my siblings for two hours a month. That's one day a year with my family,'" she recalls. "That stopped people in their tracks. Unfortunately, the only ones who had been doing the math were parents and kids."

Even that single day per year often failed to happen. In 1999, the state conducted a case-record review of families in the New York City system, finding that only one-third of them received their mandated minimum number of visits. "We did a training exercise where we had caseworkers role-play being a parent or a child getting ready for a visit," says Krupat. "They'd get really into it, and then two-thirds would be told to sit down, their visit was cancelled. We asked them to imagine being a parent and getting that call at the last minute. You could trigger a relapse. You've got parents missing meetings and showing up to court angry. Well, maybe they have some good reason to be angry."

Krupat's goal was to convince foster care workers that regular visits were crucial to kids' emotional wellbeing—and that their emotional security was as important as their physical safety. In 2000, she and other members of the advisory board came across an idea that they hoped would turn family visits into a key piece of foster care agencies' mission to get kids home. A child welfare researcher named Marty Beyer had developed a model called Visit Coaching, based on the premise that each visit is an opportunity to move families closer to reunification.

Under Beyer's model, visits are supervised by trained coaches, who conduct them as something like a cross between a family therapy session and a real-time parenting class. Rather than sitting and watching—what Beyer describes as a 'surveillance' model—the coach meets with parents before and after visits to set goals and give feedback. During the visits, the coach steps in with suggestions and support, demonstrating how to play with an infant or calm down a toddler having a tantrum.

Krupat and her advisory board convinced ACS to hire Beyer as a consultant. Under Beyer's direction, the administration created a visit coaching team which lent itself out to foster care agencies, and opened the Richmond Hill Family Center in Queens, where parents could spend time with their children in a setting that looked and felt like a home, supervised entirely by visit coaches. ACS changed its mandates, increasing visits from biweekly to once or twice a week for most families, and encouraged more agencies to designate private rooms for family visits, stocked with books and toys. "It was never enough," says Krupat. "But some exciting things did happen. There was a shift in culture."

And then, as with so many of the past decade's practice improvements at ACS, visiting reforms got derailed by the economic crash and a prolonged succession of budget cuts. In 2009, the Office of Family Visits was shrunk to a staff of one. The administration closed the Richmond Hill Family Center and eliminated the visit coaching team. Until June 2011, ACS hadn't conducted a visit-coach training in over a year.

Everyone agrees that visits happen more consistently than they did a decade ago (according to the most recent count, 60 percent of families on the reunification track now get their mandated minimum number of visits). But much of the progressive thinking on how visits should be done—or how foster care agency caseworkers should be trained to do them—has been lost. "I'm afraid they're not going through any kind of training on visiting at all," says Fendall of the ACS Office of Family Visiting. "Most likely they're not really interacting with them or helping them when they see a problem but, rather, jotting it down so the first time a parent hears about it is in court."

Michael Arsham, the executive director of the Child Welfare Organizing Project (CWOP), puts it like this: "You're sitting in a cubicle with your child and a caseworker who is writing notes on you, which often say that your interactions with your child seem strained. Well, you're sitting in a freaking cubicle with somebody writing notes on you. If that's not strained, you're not human."

***

Everything in the Children's Museum of the Arts is knee-high, so walking through is like getting an aerial view of a splatter-painted war zone. Tables are spaced around a large room, each hosting its own small explosion of crayons, clay and cut-up paper. One is given over to an electric green goop called flubber. Another hosts children bent over squares of cardboard, industriously lacing them with tentacles of yarn.

With its sense of controlled chaos, the museum is, in many ways, an ideal place to attempt the mighty feat of making an experience as contrived as a supervised child welfare visit into something that resembles normal. Kids run around the room when they've been told to walk. They concentrate on their projects or they don't, hopping from table to table like small, mad scientists conducting a dozen experiments at once. Parents praise their kids' efforts at play dough and pasta sculptures. They also lose their tempers, providing an extemporaneous variety show on the do's and don'ts of child discipline. When Adriana and Jenny arrive, a mother is putting her son in what she announces to everyone in hearing range to be his FOURTH time-out of the afternoon. Another pries shoes on her kicking, screaming toddler, who wants to stay in the ball pit forever.

Adriana and Jenny are accompanied by Adinah Ben-Yahuda. Ben-Yahuda's day job is as the liaison (or coordinator) of the Stapleton Community Partnership on Staten Island, but she's also certified as a visit coach—a qualification so rare, these days, that she hires herself out to community partnerships in other boroughs that are desperate for coaches.

While Jenny delves into the joys of flubber, Ben-Yahuda and Adriana talk. As expected, the stickers had caused a problem. Jenny's foster mother had tried to refuse them, relenting only when the little girl hugged them to her chest. Adriana is frustrated and flustered. She tells Ben-Yahuda that she doesn't think the foster mother understands that Jenny will eventually come home.

After Jenny was born, she and Adriana lived with Adriana's mother, who helped take care of Jenny, and Adriana's father, who had been beating his own kids for as long as Adriana remembers. She isn't sure how many times she went in and out of foster care as a child, but she remembers social workers asking her to lift up her shirt. "My front and back would be covered with bruises," she says, and she'd be removed from the home.

More than a year ago, Adriana's father attacked her with a metal pipe. She left her parents' home without Jenny, cycling through short stays at two boyfriends' apartments, one who forbade her from going outside without permission and the other who, she says, allowed a friend to rape her. Then she got a bed in a homeless shelter. She says she saw Jenny all the time and planned to take her back as soon as she found permanent housing. But a neighbor called in an abuse report on Adriana's mother, saying she had seen her slap Jenny across the face. The city placed the child in foster care.

After a cognitive evaluation, Jenny's family court judge decided that Adriana needed significant support before she could care for Jenny on her own, including a place in a supportive housing program, where she could have her own apartment and a social worker would check up on her every week or so. The court also required her to take classes in basic skills like cooking and cleaning, and to get counseling to understand the cycles of domestic violence.

Visit coaches are trained to understand that parents and kids show up for visits with a lot of complicated feelings, and that it's hard to comfort your child if you're still in shock that she's been taken from you. The coach's job is to hear a parent out, and then help her refocus on what her child needs during the two hours they'll be together. In the manual she wrote for ACS on visit coaching, Marty Beyer sets the expectations low: "Visits do not make most parents feel better," she writes. "Coaches help make the pain of visits tolerable for parents so they will return."

One of the trickiest things about visits is the complicated problem of who's in charge. In order for a visit to be considered 'successful,' a parent has to demonstrate that he or she can exercise authority, meting out discipline in ways that are developmentally appropriate and show a grasp of parenting skills—all within the context of a situation over which they have fantastically little power.

Minus the 25 other kids in the room and the ball pit, Ben-Yahuda takes an approach that could be photocopied from the case-study section of the visit coaching handbook, listening to Adriana's concern, validating a strength, and then asking her to take an authoritative role in her visit with Jenny. She tells Adriana that she's proud of her for working cooperatively with the foster mother when they're in front of Jenny. She reassures her that there's no reason, at this point, to worry about her parental rights being terminated. And then she asks her what she'd like to work on with Jenny during the visit.

Adriana says she wants Jenny to share, and she follows Jenny to the painting table, tying a tiny apron around her daughter's back. Ten minutes later, they've created a splodgy series of purple and brown watercolors, as well as the lopsided foundation of what was, for a moment, intended to become a clay house. Jenny sits down in front of a bead maze and asks her mommy if she wants to do a race. Heads bent so they're nearly touching, they do.

***

Like many things to do with the partnerships, the reality of community visiting programs is somewhat less grand than the original vision. Four years ago, according to a few of the partnerships' liaisons, the goal was for each partnership to have a team of ACS-trained visit coaches, complimented by less intensively trained visit hosts. Coaches would work with families seen as needing clinical intervention to make their visits successful, while hosts serve as something more like community tour guides, meeting with families who are ready to transition to unsupervised visits and introducing them to neighborhood resources like libraries and museums. Each partnership is expected to facilitate 45 visits per year, with the freedom to decide how hosts and coaches are compensated. Most pay stipends of $20 to $45 per visit—cumulatively offering a cost-effective way to preserve the visiting reforms that happened over the previous decade.

For partnerships to provide visiting services, foster care agencies need to refer families. While the referral can ease a caseworker's load, it also requires a willingness to give up control.

 

The plan began to derail early, when the ACS Office of Family Visiting lost most of its staff and cut back visit-coach trainings, ultimately stopping them altogether for more than a year. Without visit coaches, the majority of the partnerships were left without the capacity to serve any but the most stable families—those that were already close to reunification.

But the most intractable problem arose as the projects moved forward: In order for partnerships to provide visiting services (and thereby meet the minimum number of contacts required by their contracts with ACS), caseworkers at foster care agencies need to refer families. And while the referral can ease a worker's load, it also requires a willingness to give up control.

It's instructive to look at the one partnership where getting referrals has never been a problem: Staten Island is a small place, and Ben-Yahuda, who runs the Stapleton Community Partnership, has worked in foster care offices and social service agencies there for more than a dozen years. She knew much of the staff of the island's foster care agencies before she joined the partnership, and her relationships got stronger when she moved into an office in the Staten Island branch of New York Foundling, a foster care agency.

In Ben-Yahuda's view, strong relationships with foster care agencies are what give her the leverage to carry out the partnerships' mission. "You look at how, by working in the system, you can improve things for families," she says. "But also you can step out and get a lot of perspective on what needs to change."

Ben-Yahuda says she's been flooded with visiting referrals from the beginning, and the Stapleton partnership hosts and coaches about 20 of New York Foundling's family visits per month. The result, according to Jacqueline Sanders, the Foundling's director of social services for Staten Island, is that her agency has had unprecedented success at meeting its mandates from the city and state. "We had 100 percent child-family visitation last quarter. That never happens," she says.

The story at other partnerships is very different. Liaisons describe doing intensive outreach to let agencies know about their visiting services, making presentations at staff meetings, following up with phone calls and fliers and tweaking their documentation systems so that caseworkers would get stuck with as little paperwork as possible. But the referrals didn't come.

If you ask the staff of foster care agencies why they don't send families to community visiting programs, you're likely to hear a list of logistical glitches that sent this or that referral off-track: A supervisor who started organizing referrals but then left the agency; an elderly foster parent who couldn't transport her grandson to the library where he was supposed to meet his dad; a mom who relapsed and had to go back to supervised visits. The defining fact of the community partnerships is that they're ad-hoc and small-scale, and there's no infrastructure to ensure that foster care agencies consistently collaborate with them. Combine that with the frenetic nature of caseworkers' jobs, and it's easy for things to get lost in the chaotic lives and bureaucratic crises that make the daily work of child welfare so complicated.

But if you keep asking questions, you'll encounter a deeper suspicion, one that goes beyond logistics and is collectively harbored by many of the partnership liaisons and the advocates who work with them. They see the problem as a lack of trust, a missing piece of the massive cultural shift that happens when communities ask foster care agencies to open their doors to outsiders. "They don't want to be on watch," says Flora Huang, the liaison for the Lower East Side Community Partnership. "Having a visit host means one more person who's privy to information about the case and the parents' complaints and opinions. Agencies aren't comfortable with that." She says this is one reason why the Lower East Side partnership failed to meet its visiting goal in its first year and barely reached it in its second.

"My theory is that we're in communities with high needs, and there's a bad name attached to these neighborhoods," says Eva Gordon, who runs the community partnership in East New York, which has only gotten five successful referrals for visit hosting since 2007. "I think the agencies don't trust the communities."

Janet Greaves sits on the board of the East New York Community Partnership, as well as its subcommittee on visiting. She's also an assistant executive director at Little Flower Children and Family Services—one of the agencies that could, in theory, reduce its workload by referring families for visiting services at the partnership. Greaves says she talks to her caseworkers regularly about referring families for visit hosting—in part because she believes in the partnership, and in part because the Little Flower office is overcrowded with visiting families. But she says she can see that they are leery. "It's an ownership type of thing," says Greaves. "You've worked with a family for a while, you don't want to turn the case over to someone else."

***

Last year, the East Harlem Community Partnership got a family visiting case that tested everyone's theories about why it's so hard to make partnerships work.

After a period of trying—and failing—to get referrals directly from foster care agencies, East Harlem found a workaround in the form of Isabel Malavet, a long-time social worker at an organization called Sinergia, which serves developmentally disabled parents. Because she's been lending her own visit coaching services to foster care agencies for years, and because caseworkers call her looking for spots in her parenting classes, Malavet finds that she's able to broker referrals between foster care agencies and the partnership—which, as a result, has developed a specialty and reputation for serving disabled parents.

The case in question came from the foster care agency Catholic Guardian Society and Home Bureau. Both parents had developmental disabilities and their two children—a two-year-old girl and a three-year-old boy—had been placed together in a foster home. The plan was for the family to reunify, and the kids' family court judge had requested that they have two coached visits with their parents every week.

The East Harlem partnership assigned Malavet to the case as a visit coach, along with Damaris Figueroa, a parent advocate from CWOP, which trains and hires parents who have their own past experiences with the child welfare system. This was Figueroa's first visit coaching case, though she'd been a visit host and worked as a community representative at ACS's child safety conferences for close to five years.

Everyone agrees on three basic facts of what happened next: First, that there was at least one verbal altercation between Figueroa and the kids' foster mom. Second, that Malavet reported the foster mom to the state, on the suspicion that she was neglecting the two children. And third, that Catholic Guardian and ACS joined together to have Figueroa and Malavet removed from the family's case.

How the conflict started—and more importantly, what it means—is more contentious.

According to Figueroa, the foster mom cancelled 11 visits in the first three months that she and Malavet had the case. They would travel with the kids' parents for more than an hour each way, she says, from upper Manhattan to Catholic Guardian's offices in the Bronx, only to discover that the foster mother had called off the visit just before they arrived. "I thought the foster mom was taking advantage of the parents," says Figueroa. She said as much to the foster mother—at one point, she says, telling her on the phone that she was "tired of this shit."

In Figueroa's view, the parents rights were being violated and her role required her to stick up for them when no one else—neither the foster care agency nor ACS—seemed willing to do so. "Once they [foster care agencies] see a voice there they get nervous," she says. "They know we know our rights. They don't like when somebody else is involved from the outside because they can't do what they want to do to parents."

Catholic Guardian won't make an official comment on specific families, but a child welfare professional with knowledge of the case described the agency's complaint as focusing on questions of professionalism. "The host was not being neutral. She pretty much sided with the parents, not trying to form a relationship with the foster parent. That's not professional behavior," she says.

It's a point that speaks to one of the thorniest questions of community partnership: How do you define, much less regulate, the relationships between families and members of the community who are invited to play a formal role in the work of child welfare, but aren't supervised or extensively trained by any of the formal institutions of the system?

One of Catholic Guardian's complaints was that Figueroa had become Facebook friends with the parents in the case. To the agency, it was an egregious example of bias and unprofessional behavior. To Figueroa, it's what neighbors do. "They added me so I added them," she says. "I'm supposed to be part of their community. That's protocol. That's why it works."

And there does seem to have been a period of general consensus that the visit coaching was, indeed, working. When she first started seeing them, says Figueroa, the parents had a practice of bringing large quantities of food to each visit, which the children would eat until they were sick. She talked to them about nutrition and portion control and says that, by the end, they'd arrive with one or two snacks for each child. At the beginning, says Figueroa, the little girl in the case would have nothing to do with her mother. Figueroa and Malavet worked with the mother on gentle ways to insert herself into the girl's interactions with her father, and on sharing her attention more evenly between the two kids. By the end, they say, the mother was able to hold and kiss her daughter. The initial court referral, which recommended 12 weeks of visit coaching, was extended over a period of seven months—with the approval of the children's family court judge and the foster care agency.

However, Figueroa and Malavet continued to have concerns about the children's foster mother. They say the kids often showed up for their visits dirty and inappropriately dressed for the weather, with holes in their clothes and shoes. Both claim that they tried to talk to the case supervisor at Catholic Guardian, with no success, and so Malavet called in a report to the state's abuse and neglect hotline, citing her concern that the kids were being neglected by the foster mother.

ACS investigated the report and found it to be unsubstantiated, and it was at the next family court hearing that the administration sent lawyers to join Catholic Guardian in requesting that both Malavet and Figueroa be removed from the case. "This was a situation where ACS and the foster care agency found that the person who was responsible for maintaining a positive and supportive visiting environment was acting inappropriately and the family court judge supported that decision," says a spokesperson for ACS. "It was conflicting with the intent of the visits."

The bottom-line reality, for ACS, is that the agency bears ultimate responsibility for the wellbeing of children who've been removed from their families. It's a system where mistakes can be disastrous and the stakes are always high. One of the hopes behind partnerships is that involving community members can bridge the often-contentious professional distance between families and child welfare workers, but the space that those community members are expected to fill—somewhere between professional and neighbor—has yet to be fully negotiated.

Like Catholic Guardian, ACS won't go into further detail about an individual family's circumstances, but the administration spokesperson says the case is neither representative of ACS's relationships to the community partnerships, nor indicative of its commitment to community involvement.

To the East Harlem Community Partnership, however, ACS's decision to step into the courtroom represented a betrayal of faith in the partnerships' mission. "How do you ask the community to get involved, and then go to court and argue that people are too community?" asks Eric Canales, the East Harlem partnership liaison.

Damaris Figueroa continues to see the children's parents when they come in for a support group at CWOP. It's been eight months since she and Malavet were removed from the case, and she says that no one has found replacement visit coaches. The family's visits have been reduced to once every two weeks, and Figueroa no longer thinks they're working toward reunification. "It's sad," she says. "They're not going to get their children back. There's nobody there to help them and to back them up."

***

A few months ago, the Office of Community Partnerships at ACS convened an ad-hoc committee on family visiting programs, with representatives from the community partnerships, foster care agencies and ACS's Office of Family Visiting. In the abstract, everyone agrees that visit hosts and coaches can make foster care better for families, fundamentally changing the way kids spend time with their parents. The committee's job is to figure out what's stopping the programs from growing, and to think about what it would it take to bring them to scale.

Some advocates argue that ACS should take direct action to speed up the process, holding foster care agencies accountable for working with the partnerships and possibly penalizing their funding if they don't. "If you don't make it attractive for people to step beyond what they're already doing, then why should they?" asks Eric Canales of the East Harlem partnership.

But that's not the way the Community Partnership office understands its mission. "We're trying to build stronger communities," says Nigel Nathaniel, a director at the office. "It's community organizing. We want this process to be less top-down and more inclusive. We don't want to have something being held over people's heads."

Dale Joseph, who heads the partnership office, agrees that relationships shouldn't be forced. "At the end of the day, it comes down to an agency's comfort level," she says. "How comfortable are you quote-unquote giving a family to someone you may not know that well? Getting to know people and building trust takes time."

It's that focus on consensus and relationship-building that makes the community partnership program different from the rest of the child welfare system—and, arguably, that gives it the potential to create meaningful change. But it's just as arguably the thing that keeps it slow and small. Decision by committee is a clumsy process, especially in the context of a mammoth bureaucracy. One of the first tasks the ad-hoc family visiting committee set itself was to make a flyer to distribute to caseworkers, explaining the roles of visit hosts and coaches. "We wrote the text and everyone was okay with it," says Shmika Risher, who represents the foster care agency New Alternatives for Children on the visiting committee. "But then someone raised an issue with the pictures so it didn't get finalized. Now it's been two months and I guess we still haven't been able to agree on the pictures."

Risher doesn't work directly with family visiting at New Alternatives for Children. She was hired to coordinate family-team conferences, a role that was created back when ACS mandated that foster care agencies hold regular meetings with families, where parents and older kids could participate in making the decisions that affect their lives. The mandate marked a major change in the way foster care agencies do their jobs, and ACS backed it up with money: Agencies were funded and required to hire coordinators who would make sure that conferences happened as they were supposed to.

Bill Baccaglini is the executive director of the New York Foundling, which operates one of the city's largest foster care agencies. He argues that a similar kind of infrastructural change would need to happen if the city hopes to institutionalize the practice of community visits. Changing culture within a foster care agency requires "constant coaching," he says. "There has to be vigilance on our part to keep extolling the value of involving folks who are seen by [families and foster care agencies] as honest arbiters of our relationships."

But that cultural change needs to be backed up by practical systems that embed new practice into institutions—otherwise, it's simply too easy for progress to get lost. Baccaglinli suggests, for example, that agencies should funnel referrals to visiting programs through a single point of entry, rather than letting them happen—or not—according to the haphazard circumstances of individual caseworkers. "The decision needs to be made by a role, as opposed to a person," he says. "It has to be built into the structure of an agency."

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