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CAFS Falsification Policy

PURPOSE

To monitor casework practice to ensure all contacts with and other information about children and families are documented accurately and with integrity into statewide databases.

DEFINITION

A confirmed incident of falsification of child welfare records is an incident where, after an investigation by the county department, the county department establishes by a preponderance of the evidence that a person knowingly or intentionally made a false entry or falsely altered information in the comprehensive child welfare information system known as Trails.

Falsification of records examples can include and are not limited to any situation in which information that was not true was knowingly or intentionally entered into Trails:

  • Representing that a contact occurred when it did not.
  • Representing specific content was discussed during a contact when it was not.
  • Representing anything about a contact that was not true, for example, reporting a child had bruising when the child did not have bruising, representing a child was interviewed when the child was not interviewed, etc.
  • Representing that information was sent to a client or collateral (e.g., leer, text, etc.) when it was not sent.
  • Representing that someone was present during a contact or meeting when that individual was not present.
  • Changing information in an area of Trails that renders the information, or part of the information, inaccurate.

POLICY

Knowingly or intentionally entering false information or falsely altering information in Trails will result in disciplinary action up to and including termination. Any employee determined to have falsified information in accordance with this Procedure will be reported to law enforcement and/or the District Attorney for further investigation, per Volume VII (7.601.81).

 

Any Adams County team members who become aware of suspected or confirmed falsification of casework, shall report the matter to their direct supervisor immediately. If their supervisor is unavailable, they shall notify the covering supervisor or a manager.

Supervisors and Managers shall initiate the following actions when a concern has been brought to their attention:

  • Notify Pod Manager and Deputy Division Director immediately. Notification may also be made directly to the Professional Standards Manager, who will notify the Pod Manager and Deputy Division Director, or to the CAFS Division Director.
  • The Professional Standards Manager and the CAFS Division/ Deputy Division Director shall consult with the County Attorney’s Office, Human Services Director, and People and Culture (P&C) to identify the next steps, including a determination regarding whether the team member should be placed on paid administrative/ inquiry leave during an investigation.
    • If the decision is made to place the team member on administrative/ inquiry leave for the purpose of investigating a suspected incident of falsification of child welfare records, then:
      • The appropriate Manager shall request that Colorado Department of Human Services (CDHS) suspend the team member’s access to Trails within one (1) working day from the date the team member is placed on leave. If the Adams County security administrator is able to accomplish this, CDHS does not need to be contacted for this purpose.
        • Adams County will notify CDHS when the team member resigns immediately or while on administrative/ inquiry leave and before the county has confirmed the incident(s) of falsification.
      • The appropriate Manager shall reassign any current open assessments or cases to other child welfare staff as needed to assess child/youth safety.
      • The appropriate Manager shall make reasonable efforts to promptly preserve evidence that a child welfare record has been falsified and supervise or restrict the team member’s access to child welfare records including but not limited to Trails, hard copy case files, and other child welfare case related documents, such as in Mango.
      • The appropriate Manager shall review the team member’s entire workload and complete quality assurance on all open assessments and cases. This will include communicating with families and collaterals involved in assessments and/or cases to inquire if contacts documented in Trails are accurate.
      • The appropriate Manager shall review all supervision notes to see if any other concerns are noted.
      • The appropriate Manager shall consult with P&C and the County Attorney’s office to determine whether a fact-finding meeting should be held with the team member.

When a suspected concern of the falsification of child welfare records is found to be confirmed, the additional following steps will occur:

  • The Human Services Department Director, in consultation with the County Attorney’s Office, will refer confirmed incidents of falsification of child welfare records to the appropriate law enforcement agency or the district attorney within ten (10) working days of the confirmation. This referral shall be documented in disciplinary documents provided to the employee and placed in the employee’s personnel file.
  • The CAFS Division/ Deputy Director will consult with the Department Director, and People and Culture to determine the appropriate level of discipline.
  • The CAFS Division/Deputy Director or the Professional Standards Manager shall notify the CDHS Division of Child Welfare (DCW) of a confirmed incident of falsification of child welfare records within three (3) working days of the confirmation. When making this notification, the “Falsification Concerns Summary Final Report” will be attached to provide DCW with all the required information.
  • The Supervisor and/or Manager will correct Trails when an incident of falsification of child welfare records is confirmed and shall make notice of the correction to the following parties:
    1. Parents and guardians of the child/youth;
    2. Child/youth for those ten (10) years old or older;
      • Notifications to the parents/guardians and child/youth will be provided using a letter of notice approved by CDHS and mailed by first class U.S. mail to the last known address of each individual.
    3. For cases that are court involved, the court, parties to the case, any involved legal counsel, and the Guardian ad Litem.
      • Notification to the court and parties will be provided through a Notice of Deposit and include the letter of notice approved by CDHS by the County Attorney assigned to the case, unless the County Attorney’s Office makes a different legal determination on how to provide notice.
    4. To the extent permitted by C.R.S. § 19-1-307 and any other applicable state or federal privacy requirements, the supervisor and/or manager shall include a description of the corrections made to a child welfare record in its letter of notice to those individuals entitled to notice. Any notice of a corrected child welfare record issued pursuant to this rule shall be documented in Trails.
    5. The original falsified documentation should not be altered as a means to preserve the evidence. Instead, new documentation (such as a ROC note) can be entered to clarify what did or did not occur and that the original note(s) are suspected to contain falsified information regarding the nature or facts of the suspected falsification.
  • A status conference with DCW will be held within five (5) working days of notification of a confirmed incident of falsification from Adams County.
  • Effective October 30, 2025, when DCW receives a confirmed incident of falsification, a review process to determine whether the individual confirmed to have falsified child welfare records shall be decertified (if they hold a certification from DCW), per Volume VII (7.603.2-6)
    1. The decertification review process will begin with a temporary suspension decision of the worker’s Child Welfare Training Academy certification (if applicable).
    2. A five-member panel will then review the Adams County investigatory file to determine the worker’s final certification status.
    3. Workers will have the opportunity to appeal the panel’s decision.

These investigatory steps shall be completed even when the team member who is subject of the investigation resigns, is terminated, or is no longer employed by Adams County at the time the suspected falsification of child welfare records becomes known.

Individual team members are ultimately responsible for the information they put into TRAILS. To prevent the falsification of records and/or to identify potential concerns early on, the following measures shall be taken:

Team Members shall:

  • Attend team meetings, Department/Division specific trainings, and CAFS All Staff meetings, to ensure they are getting relevant information.
  • Read and acknowledge this policy on an annual basis.
  • Communicate issues with cases, missed deadlines, and support needs to their supervisor in a timely manner.

Each Supervisor will establish practices to conduct regular reviews and audits of case files to compare documented information with actual case activities.

  • This practice is specific to client, parent, and child contacts within assessments and cases.
  • Each supervisor will conduct at least a minimum of one inquiry per month per worker and document the outcome in Canopy.
    • Documentation must include the date of contact, contact name, caseworker assigned, method of contact, inquiry made, and outcome.
  • Each supervisor will conduct at least a minimum of one ROC note review per month per worker and document the outcome in Canopy.
    • The review will ensure monthly contact was made and recorded, there is content from the visit in the ROC note, not simply a place holder, the relevance of the discussion, and the information has been documented accurately (not a cut and paste/repeat from a prior contact note).
  • For non-case carrying team members, supervisors will implement practices to review community contacts, professional interactions and accuracy of information documented.

Supervisors can utilize a variety of methods to verify documentation.

  • Emailing or calling clients, parents, and caregivers.
  • System-generated reports.
  • Contacting collateral school personnel, medical personnel, law enforcement, legal entities, and service providers.
  • Family Engagement Meetings, Group Supervisions, Legal Staffings, and Court hearings.
  • Face to face child and parent contacts.

The quality assurance outcomes are to be made available upon request but at a minimum submitted or made available monthly to the manager for review.

  • This information should be entered no later than the 10th of the following month into the tracking sheet located in Teams.

Supervisors should also:

  • Engage each caseworker in detailed discussions on what the caseworker observed to inform safety, permanency, and well-being and to verify completion of required duties.
  • Assign another caseworker to follow up with a family if a caseworker frequently documents that they are unable to locate children or families.
  • Ensure that casework is in compliance with all applicable laws and regulations.
  • Regularly monitor for worker fatigue, burnout, and missed deadlines, as well as other predictive indicators to prevent falsification.
  • If appropriate, a referral will be made to try and assist the team member through the Adams County Employee Assistance Program, Adams County health clinics, and/or Reaching Hope or other contracted therapeutic provider.
  • Provide this policy to all new hires for review and acknowledgment.

To support the team, Managers shall:

  • Managers should be engaging their supervisors in conversations on a monthly basis to explore their findings of their quality assurance efforts.
  • Once a quarter, review a sample of assessments and cases from each of their teams (minimum of one review per assigned team). This should be a qualitative review to assess, at a minimum, the quality and depth of contact notes, assess that the Safety Assessment Tool is being completed accurately, thoroughly, and timely, and to review decision-making by the caseworker and supervisor with the family. The intention is that the Manager is reviewing the same assessment/ case as the Supervisor reviewed.
  • Provide ongoing training and communication to team members on ethics and integrity.