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Policy Addendum
 
Addendum Title: Conflict of Interest Policy Addendum for CAF Employees

DHS has determined that there is an inherent conflict of interest in being both a DHS employee and a foster parent, respite provider, legal guardians, relative care giver or adoptive parent for children in DHS custody.  (See DHS-060-002).  Therefore, unless it is in the child’s best interest and an exception is granted, CAF employees shall not be foster parents, respite providers, legal guardians, relative caregiver or adoptive parents for children in DHS custody.  Any Exception Request will be reviewed according to DHS-060-002 and the procedures.  All approved exceptions will be subject to a periodic review, at least annually.

The Exception Request will be reviewed for approval by at least the employee’s Supervisor, the District Manager, the CAF Deputy Assistant Director of Field Services and the Senior Human Resources Manager assigned to CAF, and may include others.  Approved Exception Requests will receive management oversight and will be considered an exception to the Department’s official position on conflicts of interest.    

  1. EXCEPTION REQUEST PROCESS

    This policy addendum applies to all CAF employees who are employed full-time, part-time, or in temporary status that are, or are seeking to become foster parents, relative caregivers, respite providers, legal guardians or adoptive parents for a child in DHS custody.

    This policy addendum also applies to individuals hired by CAF who are foster parents, relative caregivers, respite providers, legal guardians or adoptive parents at the time of hire.  These employees will be informed of the Exception Request process.  The Exception Request process must begin immediately upon employment if CAF hires a current foster parent, relative caregiver, respite provider, legal guardian or adoptive parent for a child in DHS custody.

    A CAF employee seeking to be a foster parent, relative caregiver, respite provider, legal guardian or adoptive parent for a child in DHS custody must obtain permission to request an exception through his or her immediate supervisor.

    If the immediate supervisor supports the exception request, the immediate supervisor and the District Manager must submit a written Exception Request on behalf of the employee to the Deputy Assistant Director for Field Services and the Senior Human Resources Manager assigned to CAF.  If the immediate supervisor does not support the Exception Request, the employee may contact the Senior Human Resource Manager assigned to CAF for discussion of the decision by the supervisor. 

    If the Exception Request is supported, the CAF employee, the immediate supervisor for the employee, and the District Manager must all sign the Request.

    The District Manager must forward the Exception Request to the Deputy Assistant Director of Field Services and the Senior Human Resources Manager for CAF, who will provide a written decision approving or denying the Exception Request to both the CAF employee and the employee’s supervisor.

    During any period for which an Exception Request has been granted, copies of the current, signed approval must be kept in the following four locations:  (1) the employee’s personnel file in central office; (2) in a file with the District Office; (3) in a file with the immediate supervisor at the local office; and (4) in the Human Resources Central Database.  All documentation supporting the Exception Request will be kept in the District Office file and not in the employee file or in any other location.  All other documentation should be in the foster care certification file for the child.   

    Reviews to obtain current signature approval from local managers, the Senior Human Resources Manager for CAF, and the Deputy Assistant Director of Field Services must take place at least once every 12 months.

  2. REVIEW PROCESS

    Annual reviews for all conflict-of-interest exceptions must be conducted by the local District Manager on or before the anniversary date of the approved exception.  The District Manager will conduct these reviews on or before the annual approval date. 

    Upon completing a review, the District Manager will notify in writing both the Deputy Assistant Director of Field Services and the Senior Human Resources Manager for CAF of the recommendation for continuation of the exception or the recommendation to discontinue the exception.

    If the recommendation is for continuation of the exception, a renewal Request will be signed by the employee, the supervisor, and the District Manager, and will be sent to the Deputy Assistant Director of Field Services and the Senior Human Services Manager for CAF for their written approvals.

    If approved, the signed renewal of the exception will be kept in the employee’s central office personnel file, in the Human Resources Central Database, and on file by the District Manager at the District office.

    Renewal requests must be timely and take into consideration the time necessary to gather approval and signatures to ensure that the exception is current and approved within the annual time frame.

    The District Manager will notify in writing the employee, the Deputy Assistant Director of Field Services and the Senior Human Resources Manager for CAF when the exception is discontinued.

    Exception Request data will be retained in the Central Office Database so long as the employee is employed by DHS and for 10 years beyond the termination date of the employee.

    1. Exceptions for Relatives of Children in DHS Custody

      DHS recognizes the value of placing children in DHS custody with relatives and with siblings whenever possible.  An Exception Request to the conflict of interest policy will be considered for any employee who is a relative who seeks to become a relative caregiver, respite provider, legal guardian, foster parent or adoptive parent.

      When the CAF employee is a relative of a child in DHS custody and seeks to become a relative caregiver, respite provider, legal guardian, foster parent, or the adoptive parent for the child, the employee must follow the procedure in the “Exception Request process” (described above).  Managers and appointing authorities will expedite the Exception Request process for relatives who are CAF employees and who seek to become relative caregivers, respite providers, foster parent, legal guardians or adoptive parents for a child in DHS custody.

      In addition, at a minimum, the signed, written Exception Request will include the following information:

      1. The reason for Exception Request (e.g., CAF employee is a relative of the child in DHS custody and it is in the child’s best interests to reside with that family).
      2. The nature of the desired placement (e.g., relative caregiver, guardian, respite provider, foster parent, adoptive parent).
      3. The timeline for the desired placement.
      4. The plan for review of the Exception Request (at least annually).
      5. A plan to close the Exception Request once the relative child is returned home.  (A new Exception Request must be made and approved for any other DHS child to be placed in the employee’s foster home.)
      6. A plan to address the open case and to screen the confidential information in the case record (including the electronic record) from the employee having the exception.
      7. Identification of the office that will certify the home of the DHS employee.  At a minimum, the certifier must be from a different District.
      8. Identification of the person responsible for case management of the child’s case.  The office in which the employee works cannot be the office in which the child’s case is managed.
      9. An employee receiving this exception must disclose their dual role as both a foster parent and a DHS employee, and clarify for all parties in a meeting, court hearing or other situation, and identify in which role they are participating. If the need for disclosure is unclear, the employee should err on the side of disclosure and discuss the need to disclose with his or her supervisor.
    2. Exceptions for Non-Relatives of Children in DHS Custody

      An exception to the DHS Conflict of Interest policy (AS 060-002) may be considered to allow non-relative foster placements, respite provider services, guardianships and adoptions.  An example might be a newly-hired CAF employee who is a foster parent at the time of hire, has a non-relative foster child in his or her home, and it is in the best interest of the child to maintain that foster placement.

      For any exception, the same policy and procedures for relative approval, and any subsequent review process, must be followed.

    3. Current Placements:

      In order to minimize any disruption to children in DHS custody in their current placements, the following procedures shall be followed:

      If a CAF employee currently has a child in DHS custody in his or her home, the review process shall begin immediately.  The supervisor and the District Manager will determine whether it is in the child’s best interests to remain in the employee’s home.

      The annual review process will be followed until the child in DHS custody no longer resides in the employee’s home.

      The District Manager will notify the Deputy Assistant Director of Field Services and the Senior Human Resources Manager for CAF when the exception is discontinued.

  3. FILE RETENTION

    The District Manager shall send a written summary of the District Manager’s determination to the Deputy Assistant Director of Field Services and to the Senior Human Resources Manager for CAF, with either 1) a request to continue placement, or 2) a decision to discontinue the placement.

    Written approval from the Deputy Assistant Director of Field Services and the Senior Human Resources Manager for CAF will be placed in the employee’s personnel file in central office, in a file with the District office, in a file with the immediate supervisor at the local office and in the Human Resources Central Database.

  4. EMPLOYEE RECOURSE

    If a CAF employee seeks an exception to this policy from the immediate supervisor or the District Manager and is denied at the local office, that employee may contact the Senior Human Resources Manager for CAF and ask for a review of the local office decision.
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