In terms of understanding of ASFA, managers ranked ahead of supervisors and workers in both the 2001 and 2002 polls. All three groups showed an increase in understanding between 2001 and 2002 with workers showing a statistically significant increase (p<.01). The comments made suggest that managers are ranked higher in understanding because they have had more training, while supervisors know the ASFA requirements that pertain specifically to their areas of responsibility. Workers' understanding is good; they practice the requirements, but may not know ASFA as the source of the requirements. High staff turnover negatively influences workers’ understanding.

In the 2002 poll we compared how respondents rated ‘Understanding of ASFA’ by managers, supervisors and workers in states in the initial phases of the CFSR (planning or assessment) to the states in the later phases (review completed or working to complete PIP activities). We found statistically significant differences between these two groups. As shown in the following table, states in the later phases of the CFSR process rated the ‘Understanding of ASFA’ by managers, supervisors and workers significantly higher than did states in the initial phases. Completing the activities associated with the CFSR appears to increase the understanding of ASFA by agency managers, supervisors and workers.

Selected Participant Remarks Regarding Understanding of ASFA:

At the management level, people have been trained and attended meetings where ASFA information has been provided and reviewed. However, we continue to provide training and work on implementation of consistent practice throughout the state. (CT)

Delaware went through the CFSR in 2001 so administrators understand ASFA and the implications. (DE)

Michigan's child welfare policy reflects ASFA requirements. Managers monitor staff performance and adherence to policy thereby increasing the adherence to ASFA.
(MI)

If we're not modeling it 100%, then workers are not experiencing it 50%. Also, we have had significant turnover in our supervisors--50% of them have less than 2 years experience in that role. (AL)

We've had some turnover at the supervisory level which means that the ASFA knowledge might be a little less comprehensive here than at the management level. (AZ)

Some supervisors have a more comprehensive understanding than others. It can vary depending on the specific areas of oversight each supervisor maintains and their length of service with the agency. (NH)

There is more knowledge of the specific practices than the fact that those practices may be ASFA related. (CA)

Sometimes the knowledge becomes contained in specialized units and these units often include the most experienced and motivated staff. (NJ)

Although ASFA is supposed to be part of the fabric of the job, we have worker turnover and the learning curve is always an issue. (SC)

Workers know how to handle changes in policy and practice caused by implementation of ASFA but don't necessarily know that the reason for the changes is requirements of ASFA. (TX)

Skills

Respondents were asked to list the skills that managers, supervisors and workers need to have to implement ASFA. The top skills for each are listed below.

Manager's Skills

Supervisor's Skills

Workers' Skills

Interestingly in the 2001 poll, casework was the skill most often mentioned for managers, supervisors and workers. The results of the 2002 poll show that while casework remains the 1st ranked skill for workers, understanding the requirements of ASFA is ranked number one for managers and communication is ranked first for supervisors.

When the responses of agencies in the later phases of the Child and Family Services Review (review completed and working under a Program Improvement Plan) were compared to those agencies in the initial (planning and assessment) phases, there was a statistically significant difference in the responses. Those in the later phases rated workers’ need to ‘Understand how to implement ASFA’ higher than states who were in the planning stages. The average rating of those who completed CFSR was 4.58; the average rating of those who were in the planning stages of CFSR was 3.86 (p<.01). The agencies that have been through CFSR appear to see the need for workers not just to understand ASFA requirements, but to be able to implement it also.

Administrative Activities

Respondents were asked if, as part of the ASFA implementation, the agency had undertaken any activities in certain administrative areas. A summary of the responses appears below. Selected remarks by participants, which appear below as well, are very informative regarding the changes made. They give specific details of the activity undertaken, why it worked and, in some instances, how it differs from practice and procedures before ASFA.

Agency structure. Of the 41 states responding to this question, 42% had changed agency structure based on ASFA. Among the changes mentioned most often were that a department or unit had been added or restructured or staff had been added.

Internal communication. Of the 41 states responding to this question, 68% had undertaken ASFA related activities in the area of internal communication. Activities mentioned most often were an increase in communications, more frequent use of e-mail, the intranet and websites and training for staff.

Performance appraisals. Of the 41 states responding, 24% have undertaken ASFA related activities in the area of performance appraisals.

Job descriptions. Of the 41 states responding, 15% have changed job descriptions to reflect ASFA requirements.

Staff recruitment. Of the 41 states responding, 22% have implemented activities in staff recruitment in response to ASFA. Hiring freezes and layoffs were factors mentioned by two agencies.

Case Review. Of the 41 states responding, 66% have modified their case review process in response to ASFA and the CFSR. Three agencies mentioned that they now have supervisors or coordinators review cases.

Foster/Adoptive Parent Recruiting. Of the 41 states responding, 56% have changed their foster/adoptive parent recruiting process to include activities such as on-going campaigns, increased support, contracting with private agencies and assigning specific staff to focus on recruitment.

Selected Participant Remarks Regarding Changes in Administrative Activities

We created a separate substance abuse/mental health unit and hired the manager and staff for that unit, realigned staff and added 2 new positions to create a separate unit to focus on adoption subsidies. District 1, the largest district, has restructured the adoption unit to focus separately on children with no identified placement and children with an identified placement. (AZ)

Because of concerns about meeting challenges posed by ASFA, there was reorganization in the office to provide more direct services to field staff. Increased funds were given to local areas and they decided how to spend it. (LA)

We have transitioned Family Prevention Services from the Child Welfare unit to our Family Independence Program (cash/food assistance/MA etc). This was done to enhance the “one worker” concept; to assure that the worker that works with the family on their basic needs can also address child safety issues before they become critical. (MI)

The Division of Youth and Family Services developed a Case Practice Unit in our Central Office. This unit is comprised of experienced staff who support field in meeting the ASFA requirements. (NJ)

We formed an Executive Leadership Council made up of public, judicial and private agency members to assist in development of the statewide assessment and oversee the review process. (OH)

We instituted a formal program for Technical Assistance that includes issues such as ASFA, expedited TPR and permanency planning. Also we have strengthened our focus on community development and partnerships (SC)

We formed permanency support units that look at cases where children have been in foster care the longest and identify barriers to permanency with a regional focus. We’ve implemented two units of non-case carrying personnel in each region charged with recruiting, training and retaining foster parents. There are 36 new positions that have been filled. (TN)

We created a Quality Control Division and plan to replicate some parts of the CFSR review on a regular basis as part of the Quality Assurance structure. (TX)

Changes have been made to comply with the Milestone Plan and thus, to facilitate better outcomes for children and families. These changes have also led to better conformity to ASFA requirements. The position of Milestone Coordinator was created and filled. This position oversees all aspects of the Milestone plan. There is a regional coordinator in each of the five regions and a state Milestone Coordinator. Milestone coordinators look at data and practice. They are also responsible for the federal review that will take place in April 2003. Also we added trainers to train new employees, emphasizing best practice. We combined two trend analysis committees to look at data indicators and ASFA requirements. (UT)

The Division conducts an annual ASFA Implementation Study. The study allows the Office of the Chief Counsel to dialogue with the Division about ASFA issues and address barriers. (AR)

The counties have increased communication about supporting what is good for families, especially around engaging courts and knowing what the court’s priorities are. (CO)

There is increased communication with field staff because of focus in state office on what is happening in the field. Field staff are being asked to participate and share information regarding reviews. (LA)

We share more information regarding improvements in handling children whose goal is adoption and processing paperwork faster. Our improved methods for tracking and identifying children have resulted in better matching. Our preliminary planning procedures have been tightened resulting in more unified practice. (MA)

Communication has been improved. When information regarding ASFA is sent to the field, it is sent to everyone, not just supervisors and managers. (MT)

Our Continuous Quality Improvement Unit has been doing a version of the CFSR in every county and has made it through the state. (OK)

We have done training, on-going case reviews for Quality Assurance and have developed an internal web site for staff to provide information about ASFA and the Federal Review. (TX)

In collaboration with the Court Improvement Project, we conducted training of multi-disciplinary groups throughout the state on ASFA requirements. Also, we drafted a bench book that outlines ASFA requirements for child protective services. (WY)

The Agency has moved toward a performance based system. Appraisals are tied to the regulations and are aimed at supporting our overall mission. On example is providing field offices with the number of moves children experience in out of home care and ensure this is addressed. County Directors are monitored and held accountable for adoptions and reunification’s of children. (MI)

Where appropriate, reference is made to activities associated with ASFA. (NJ)

All counties undertook self-assessments involving stakeholders in the community. They are looking at results to identify where more work is needed. (WI)

Changes in performance appraisals are being implemented as part of the Milestone Plan. The agency is using Practice Model Training, which is a strengths based approach to casework in a parallel process with employee performance evaluations. The performance plan reflects the skills that caseworkers should demonstrate in managing the case. Then the supervisor and the caseworkers meet to determine the strengths and areas for improvement of the worker. The supervisor and worker then discuss resources available for caseworkers that will help them to make the needed improvements. This is similar to the way caseworkers work with families. (UT)

We have made a strong commitment to ensure that job descriptions reflect tasks that are required by ASFA and that these tasks are used as measuring tools in completing performance appraisals. (IN)

While changes in job descriptions have not been mandated by the state, some individual supervisors may have done so. (KS)

We have requested from our legislature additional positions in intake, our IV-E eligibility determination unit and for additional paraprofessional staff. The intake and IV-E positions were requested to form statewide intake and eligibility units. (HI)

Some counties are hiring bi-lingual staff. (NC)

Early in 2001 efforts were made in the area of staff recruitment and retention; since then, there was a hiring freeze, and more recently layoffs. (MA)

We made some modifications to our case review process as a result of focus on safety. (MD)

We have designed a case review instrument that will be utilized by our quality assurance personnel. (MS)

We have started using a case checklist that includes ASFA requirements that is used by caseworkers. (MT)

The department received approval from the state personnel department to hire people into positions that previously required only a social work degree and licensure. The new requirements are for people with degrees in related fields and they can be hired into a limited number and type of positions, those doing only intake and investigations. This is to address the continuing vacancy and turnover rate and an inadequate number of licensed social workers to fill the positions. (NM)

A Program Specialist will be working with each District on Quality Assurance issues, including the reading of randomly selected case files for ASFA compliance and the state’s Child and Family Services Review program improvement plan. (SD)

We are relying more on IV-E and Federal Review tools to carry on case reviews. Case reviews have always been done; however, more of them have been done since ASFA. (VA)

All of our contracts are now performance based and include a special focus on kinship care and permanency through guardianship. (AZ)
We are now using MAPP and are working closely with the Foster/Adoptive Parenting Association. (IA)

We have implemented concurrent planning statewide. (LA)

We are beginning to see positive results from past efforts. We have more contracts with private agencies, which has resulted in an increase in number of resource families. (MD)

We restructured statewide recruitment efforts to be based more on community collaboration. (MN)

We increased the number of contracted providers who do recruitment and training of resource families. There is now more emphasis by contractors on ASFA issues. (MO)

One staff person was hired at the statewide level recently to work on recruitment and retention. (WA)

Up until now mostly foster/adoptive parent recruitment was carried on at the local level. Now an agency has been contracted to develop a statewide campaign. (WI)

Training for Agency Staff

61% of the respondents report that their agency continues to provide ASFA training to their staff. The most frequently mentioned training topics were permanency issues, timeframes for reunification and concurrent planning. Conducting statewide training sessions on ASFA was mentioned most often for the second year in a row, although including ASFA topics as part of in-service training rose from 36.2% of the responses in 2001 to 49% in 2002. Agency staff, including training unit, regional and central office staff, continue to be mentioned most frequently as delivering the training. Others who were mentioned as providing training included consultants (34%), court staff (22%) and state university staff (15%). 59% of the respondents indicated that ASFA training was incorporated into other training, 51% indicated it was incorporated into new worker training and 20% indicated it was not incorporated into on-going training.

Training Methods

Selected Participant Remarks Regarding Training for Agency Staff

Many training topics are driven by the requirements of ASFA. More specifically training has included topics related to recruitment and tracking of children in placement, but who didn't have an adoptive home. (MA)

We train on timelines for court hearings, findings that must be made at each hearing, language that must be included in court orders, permanency timelines. (MS)

As part of the Division’s Strategic Plan to improve safety and expedite permanency, Division staff in consultation with the National Resource Center on Child Maltreatment, and other child welfare experts, have developed a Structured Decision making (SDM) model for case handling. This initiative promotes timely, valid, and consistent judgments related to safety, risk assessment, case planning, service provision, and permanency on behalf of children and their families. SDM training will utilize several basic components to assess families. Thus far, the Division has implemented a safety assessment protocol. In the District Offices, the safety assessment document is completed in a case conference and provides assistance to the caseworker and his or her supervisor in making a determination as to whether a child is safe in his or her home or whether safety measures must be taken to ensure the child’s well-being. Also in development are tools to provide uniform screening and risk assessment throughout the District Offices or indirectly through other child welfare providers from screening of the initial referral to case closure. SDM training was preceded by two Symposia series in 1998/1999 and 2000 that focused on implementation of ASFA regulations and child protective decision-making. The Division also, through the Adoption Opportunities grant, provided training about placement issues, child needs and family strengths. (NJ)

ASFA has been incorporated into all the relevant courses in the state’s competency-based training program. All county agency staff are required to attend these courses. (PA)

A 10-grid training was held that involved agency staff and the community. It was designed to foster better relationships between the agency and the community and develop skills in partnering with the community so that the responsibility for meeting outcomes for children is shared and ways to partner with community members to solve problems are identified. (WY)

This year, we finished rebuilding our training to incorporate ASFA; the training now blends ASFA process, requirements, implications and practice. (FL)

Training with or for Courts

Most agencies continue to do ASFA related training with or for the courts on topics such as permanency issues, court requirements, reasonable efforts and preparation for the CFSR. The most frequently mentioned method of training in 2001 was ‘joint training sessions attended by agency and court staff’, while ‘agency and court staff working together on the local level’ rose to number 1 in 2002.

Selected Participant Remarks Regarding Training for the Courts

The Department, ABA and tribes delivered a training session on ICWA that was informative and well received; 60 % of the participants were attorneys working in the child welfare system. (IA)

The training was a Court Improvement project. It focused on training for 10 key judges. Topics included court practices, scheduling, emphasis on one judge-one case, child development issues and permanency. (MN)

Once a year there are Reasonable Efforts Symposiums in each region of the state that focus on ASFA topics. (WA)

Training for Other Organizations

As well as doing training with and for the courts, agencies report doing ASFA related training for tribes, mental health and health care providers, schools, foster care providers, community stakeholders and board members on a variety of topics such as permanency issues, timeframes fore reunification and best practice.

Selected Participant Remarks Regarding Training for Other Organizations

There has been collaboration with mental health providers around time frames and compelling reasons, not really formal training. There is an on-going advisory council made up of tribal representatives who work on ASFA and NICWA issues, not really formal training sessions. (MN)

The Division and Rutgers University developed a three-day Expert Witness/Evaluator training program to train psychologists and psychiatrists. These experts are then better prepared to provide the assessments and evaluations and court testimony necessary to provide for the safety and permanency needs of the children. An experienced pediatric nurse under contract with the Division has trained foster parents about the health and safety needs of children in their care. (NJ)

We have done training with program specialists, internal people, contract providers and foster care providers on requirements of ASFA. In connection with the CFSR, training sessions were held with judges and childcare providers. ASFA requirements and the CFSR review has been the subject of meetings of the Child Welfare Board, which is made up of community members. (TX)

Information Systems

Respondents were asked to rate on a scale of 1 to 5, with 1 being 'poor' and 5 being 'outstanding' the support provided by the state information system for the work of managers, supervisors and workers in implementing ASFA. The average rating was 3.14 in 2001 and rose to 3.43 in 2002. In the 2002 poll, county administered states gave their information system a lower rating (average 2.86) than state administered states (average 3.56). When the responses of agencies in the later phases of the Child and Family Services Review (review completed and working under a Program Improvement Plan) were compared to those agencies in the initial (planning and assessment) phases, states in the later phases their systems a higher rating (average 3.83) than states who are in the earlier phases (average 3.22)

Selected Participant Remarks Regarding Information Systems

Our Information Systems unit is doing a lot of work to upgrade the system and provide us with reports and ticklers necessary to track compliance with ASFA. This is a large assignment and continues to be worked on. (CT)

The information is there, but it could be more user friendly. (HI)

We are in the process of identifying reports that our system needs to generate in order to be responsive to field staff and management’s ability to monitor ASFA requirements. We have begun to work with our systems staff in an effort to identify and clarify information needs. We are also identifying mandatory fields that will assist us in gathering information in a timely manner. (NH)

Our database has been very helpful in gleaning information for our research capabilities. (ND)

Our information system is wonderful. We have reports/data on all aspects of child welfare; we are able to enhance the system and/or modify reports to obtain needed information. (OK)

The state has a data warehouse that gets more sophisticated each year. Presently managers can get reports themselves. Work is being done on a more advanced system that supervisors will be able to use to get reports themselves. (TX)

Our system is good; you can get all kinds of specific data from it. (UT)

The managers like the information system. The workers don't like it because they say that the time it takes to input data is time they could be spending with families. The workers say that the data that is entered can't help families. At the state level, the information is helpful because it provides information on which to make decisions. (WY)

Staff Support

Shown below are the activities mentioned most often by the child welfare agency respondents as working well in supporting staff as they implement ASFA requirements.

Most Effective Practices for Staff Support

We design training, literature and communication to help staff embrace ASFA as something not separate from their day-to-day work but something that is part of their work with families. (AL)

We recognize achievement within cases/casework; empower staff through knowledge and training. We see ASFA as a system change and understand it that way. (LA)

It is important to train people who work with families and is important that the court system understand ASFA. (MA)

We have been successful using a teamwork approach to casework. The use of family support team meetings has worked well. (MO)

With ASFA in particular, the court system is crucial in assuring that children obtain permanency. We have experienced some difficulty with courts not granting a TPR due to “best interest” determinations. Training for judges on “best interest” and permanency would be helpful. (NH)

Let the staff know how the agency is doing as far as results are concerned. (TX)

Managers need to go through same training as caseworkers. Managers have to have casework skills. They need them so they know how to communicate with caseworkers and understand what is happening with families. (UT)

Staff needs the opportunity to discuss ASFA related issues with peers and others. (VT)

The agency is dealing with inexperienced staff. It is possible to train them, but we need stability in work force too. There needs to be on-going staff support by supervisors and on-going agency support for supervisors. (WV)

We need to make sure staffing is adequate. We continue to ask staff to do more. Also, we need to work on understanding how to involve community to help in providing favorable outcomes for children and families. (WY)

Barriers to supporting Staff as they implement ASFA

Barriers to the agency's support for staff as they implement the requirements of ASFA changed markedly between 2001 and 2002. In 2001, agencies mentioned most frequently the lack of resources, difficult relationship with courts, staff turnover and limitations or lack of computer system(s). In the 2002 poll, staff turnover was mentioned most frequently followed by lack of resources, heavy workload and lack of services, indicators of the financial difficulties many public child welfare agencies are facing now.

County-Administered States

Of the 41 states where the poll was conducted, 10 were state supervised, county-administered states. These states were asked to what extent does the fact that their state is county-based impact ASFA implementation. Among the 35 comments received, 20% indicated that the county-based system is most responsive to local needs. Other comments were: resources are limited (17%), and there are few uniform practice standards (15%).

Child and Family Services Review Process

The poll asked agencies to identify where they were in the Child and Family Services Review (CFSR) process.

Selected Participant General Remarks

Development of the statewide assessment should begin as soon as the state receives its national data profile. Utilize the ACF Regional Representatives as much as possible. For the onsite review, cases should be pulled as soon as possible using the order given by the Feds. Because some cases will not be appropriate, and you will be unable to locate some clients, it is a good idea to pull 50 cases over the sample to be reviewed. (AR)

As a state, we may be able to better document use of compelling reasons; because of the large number of Native Alaskan children in custody, there is a reluctance to petition the courts to not provide reasonable efforts, so Alaska has not used those two provisions of ASFA to a great degree. (AK)

We did the preparation for the CFSR using our agency staff; we did not use consultants. During the review, we had policy staff on-site in each of the 3 reviewed areas as we thought it would be very important to ensure clarity and consistency in the interpretation of policy. Our results were reasonably good---we are in substantial conformity on 5 of the 7 systemic factors and in conformity on the 2 safety indicators. It is an extensive and complex process that we viewed as bringing our agency value through the self-assessment and learning. We have a good relationship with Region 9 and received excellent communication and support from the staff in that office. (AZ)

The counties are having increased communication about supporting what is good for families, especially around engaging courts and know what the court’s priorities are. This type of conversation is also going on with communities as the counties know that they can’t do it all themselves. (CO)

Start planning early and look at data early. It is probably a good idea not to do the Federal Review and go through accreditation at the same time. (LA)

Coordinate what you are doing with the Review. The Review process pushes change. (MN)

Must have all staff involved, keep them informed, celebrate successes, understand that change takes time and may not see result of change for some time. (MS)

Stakeholders don't always see the broad picture and they sometimes make recommendations based on this narrow understanding. The problem is how to educate them before they participate in the review. The instructions and material provided by the Children's Bureau should be easier to understand and written in very simple language - not ‘governmenteze’. (MT)

We have had training in the past year specific to ASFA and are in the process now of training supervisors on how to supervise staff on ASFA issues. We have had the CFS review and have developed more specific data information about outcomes. (NM)

We are doing lots of Family Centered Practice work here now. Based on the review of the pilot CFSR report, we’re also changing our way of looking at data and have new charts and graphs that make our progress toward outcomes clearer to understand. (RI)

Be prepared, practice before process, be familiar with instruments, be familiar with interpretation of instrument, be well organized, and communicate with the federal team regarding their needs. (TX)

It is important to help people understand the balance and interrelationship of outcomes. Improvement in one might affect another in a negative way. Solutions have to balance outcomes so they work together. Assessments have to be improved. Need to focus on implementing strategies. (WY)

COURT IMPROVEMENT PROJECT POLL RESULTS

Understanding of ASFA by Agency Staff

Court improvement project (CIP) personnel were asked to rate the child welfare agency staff in terms of their understanding of ASFA requirements on a scale of 1 to 5 with 1 being ‘poor’ and 5 being ‘comprehensive’. The average rating given in the 2001 poll was 3.25, which rose to 4.0 in the 2002 poll. Participants noted that the ‘understanding was at a high level’ and agency staff ‘have a desire to understand but the issue is complicated’.

Skills

Court improvement project respondents were asked to rate the skills (on a scale of 1 to 5 with 1 being ‘don’t need it’ and 5 being ‘extremely important) that child welfare supervisors and workers need to have to implement ASFA. The skills mentioned most often are listed below.

Supervisor's Skills

Worker's Skills
(N = 9)

As expected the skills that court improvement project (CIP) personnel think supervisors and workers need to have are focused on their understanding of the law, relationship building and the ability of agency staff to testify in court regarding ASFA issues. Child welfare agency staff, however, think the top skills needed by supervisors and workers are communication, collaboration and case work. With child welfare agency staff there was not the emphasis on knowledge of the law or testifying in court.

Administrative Activities

Court improvement project respondents were asked if, as part of the state’s ASFA implementation activities, the court and the child welfare agency had undertaken or changed day-to-day joint activities and communication. Respondents reported that changes had occurred in both areas. For example, work groups have been formed to deal with case processing issues, staff have been observing court hearings, more information is circulated and there is increased collaboration between the courts and agencies.

Sharing Information

The project team asked court improvement project respondents if they were getting information they needed regarding cases from the agency. 66.7% of the respondents said they were getting the information, while 33.3 % noted that data was not entered so there was a problem getting it.

Training

Respondents were asked how they handled training on ASFA for court and agency personnel. Respondents report that for court personnel, court staff and consultants conducted ASFA training during conferences and seminars on topics such as permanency planning options and how ASFA relates to state law. For agency personnel, including agency attorneys, the courts held joint training, invited agency staff to court training and made presentations at child welfare conferences. The topics included permanency planning options, incorporating the final rule into case planning, ASFA as related to state law, child development, effects of substance abuse, case planning the judicial role in ASFA implementation, ethical issues and barriers to successful terminations.

What Worked Best

In the 2002 poll, court improvement project respondents were asked to rate (on a scale of 1 to 5 with 1 being ‘not important’ and 5 being ‘crucial’) the importance of specific activities in terms of working with the child welfare agency as it implements ASFA requirements. The following table displays the results.

Barriers

The court improvement respondents saw lack of resources, lack of clarity in federal and state law on permanency hearings and lack of understanding of the law as the top three barriers in the court improvement project's work with the agency as it implements the requirements of ASFA.

General Remarks

When asked if they had any other comments to make regarding the best way to implement the requirements of ASFA, respondents made several which are listed below:

• Collaboration and communication are important
• Keep working together
• The Child and Family Services Review activities in all the states have taken precedence over ASFA implementation. The indicators for the 3 ASFA goals are central to CFSR but the court part of the CFSR is too small.

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