Four documented failure areas

HHS OIG audit A-07-21-06102, issued March 2, 2023, drew its sample from 74,353 episodes in which a child was missing from care for two calendar days or longer, July 2018 through December 2020, in the 46 states that supplied usable data. The estimates are extrapolated from a stratified random sample of 100 episodes and carry sampling uncertainty; the sample itself is the most persuasive part.

OIG’s diagnosis: state agencies “generally lacked adequate systems to readily identify whether or not they had reported missing children episodes to NCMEC accurately and in a timely manner,” and agencies that do not properly report “increase the risk that the children may not be safely and swiftly recovered.”

An NCIC entry does not create a NCMEC report on its own, so a report to NCMEC filed late, or never, can leave NCMEC without the case.

The figures are dated and should be read as the clearest published illustrations of the pattern, not as evidence of current state performance. The durable point does not depend on any year’s data: a state can report 95% compliance in aggregate while specific offices or overloaded caseworkers leave clusters of children unvisited for months. Aggregate self-reporting cannot surface that distinction. Per-child, per-month verified records can.

Sources: Congressional Research Service, R41860, Table G-1 (October 2014), from ACF data (New Jersey reported 96% for FFY2012 and 98% for FFY2013); Missouri Department of Social Services, CFSR performance data, FFY2008.

Eligibility reviews under 45 CFR §1356.71 surface improper payments whenever anyone looks: West Virginia’s 2024 primary review produced a $786,971 disallowance. A historical Philadelphia County audit (A-03-06-00564, claims from 1997 to 2002) found at least $11.7 million improperly claimed of $33.3 million reviewed, included here as an illustration of scale rather than of current practice. The common thread is proof: the case record must document eligibility to substantiate each payment, and payments for ineligible periods are disallowed. A disallowance is the same verification failure in financial clothing.

GAO warned in 2012 that HHS’s FY2010 estimate “is not based on a statistically valid methodology” and covered about a third of federal foster-care spending. HHS last reported a full national rate for FY2020 (3.36%). Sources: HHS Annual Performance Plans (national rates to FY2020); HHS OIG PIIA compliance reviews FY2021 (A-17-22-52000) through FY2025 (OAS-26-17-042, August 2026); GAO-12-312.