GHOST VISIT INVESTIGATION — ARTICLE 2 THE FINANCIAL ARCHITECTURE

$9.5 Billion in Federal Funds — With Virtually No Accountability

Jun 29, 2026

Every year, the federal government pours more than $11 billion into America’s child welfare system. Most of that money — $9.5 billion in Title IV-E alone — flows through an open-ended entitlement designed to reimburse states for placing children in foster care, subsidizing adoptions, and (in tiny amounts) offering prevention services.

Yet in the same system, the single most basic safeguard — a monthly caseworker visit to verify that a child is alive, safe, and not being abused in the very placement the government is paying for — receives just $26 million nationwide. That works out to roughly $70.65 per child per year, or about $5.89 per month.

Less than the cost of a single Starbucks latte. Less than most states charge for a copy of a birth certificate. Less than the processing fee on a single government form. The federal government has effectively decided that confirming a child in state custody has not been harmed, trafficked, or left to languish is worth less per month than a medium coffee.

This is not a rounding error. This is not an oversight that slipped through the cracks of a well-intentioned bureaucracy. This is the financial architecture of a system that has been deliberately — if quietly — built to count beds filled, permanency orders signed, and federal matching dollars claimed, while treating the actual safety and well-being of the children inside those beds as a secondary concern at best. The money tells the truth even when the case files do not, even when self-reported visit compliance numbers paint a rosier picture than independent audits reveal, and even when Congress quietly removes the last remaining enforcement mechanism.

This is the story of where the money goes — and why it almost never follows the child into the placement to ask the most basic question: “Are you okay?”

In Article 1 of this Ghost Visit Investigation series, we documented the widespread failure of states to meet even the modest 95% monthly visitation standard, the unreliability of self-reported data, and the human stories behind the statistics — children who went months or years without a meaningful safety check. Now, in Article 2, we follow the money to understand why this failure is not an accident but the predictable result of incentive structures that have been in place for decades and were just made worse by legislation signed in January 2025.

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I. Following the Money: An $11 Billion System That Cannot Verify a Single Child Is Safe

In FY2023, Title IV-E programs alone consumed $9.5 billion in federal funds. FY2024 estimates pushed that figure to $9.7 billion. When you add Title IV-B, CAPTA, Chafee Foster Care programs, Monthly Caseworker Visit Grants, and related streams, total annual federal spending on child welfare exceeds $11 billion.

That is more than the entire annual budget of many federal agencies. It is more than enough to fundamentally transform how we protect vulnerable children — if the money were actually tied to outcomes that matter.

Instead, the overwhelming majority of those dollars reimburse states for the cost of removing children and maintaining them in out-of-home care. The system pays handsomely for the placement. It pays almost nothing to check whether the placement is safe.

On January 4, 2025, President Biden signed P.L. 118-258, the Supporting Children and Families Act. Buried in its provisions was the quiet elimination of the only federal financial penalty that existed for states failing to meet the 95% monthly caseworker visitation standard. The penalty — already weak — had never been meaningfully enforced in two decades. Now it is gone entirely.

Eleven billion dollars flows every year with no enforceable mechanism requiring anyone to verify that the children receiving those funds are actually being seen by the adults responsible for their safety.

This investigation follows the money using Project Milk Carton’s CivicOps database — the most comprehensive nonprofit financial tracking system of its kind, containing 630,263 Form 990 Schedule I grant records totaling $89.1 billion, cross-referenced with HHS TAGGS data (22,960 federal awards worth $58.6 billion) and 1.046 million USAspending sub-award records. What emerges is a portrait of massive investment paired with almost nonexistent accountability for the one thing that should matter most: whether a child in state custody is safe.

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II. Title IV-E: The $9.5 Billion Open-Ended Pipeline That Rewards Volume

Title IV-E of the Social Security Act is the largest federal child welfare funding program — and it is fundamentally different from almost every other federal grant stream you will encounter in Washington. It is a mandatory, open-ended entitlement. There is no annual appropriations fight in Congress. There is no spending cap that forces lawmakers to choose between child welfare and other priorities. If a state places a child in foster care and that child meets eligibility criteria under the complex web of federal rules, the federal government must reimburse the state at the applicable FMAP rate. Period. The spigot turns on automatically.

This structure creates an automatic growth engine with no off-switch. The more children a state places in care — whether because of genuine safety concerns, because prevention services were unavailable, because of risk-averse decision-making under legal pressure, or because the financial math favors removal — the more federal dollars flow back to that state. There is no committee vote required to increase spending. No annual debate about whether we can afford to maintain the current foster care population. The money simply follows the placements, growing year after year as the number of children in care fluctuates or trends upward. In a rational world, we might expect spending to correlate with improved outcomes or reduced need. Here, spending correlates most strongly with the volume of children removed from their homes.

In FY2023, the breakdown of this $9.5 billion entitlement looked like this:

Foster Care Maintenance: $5.1 Billion (53.7%) — Paying for the Bed, Not the Check on the Child

Foster care maintenance payments are the beating heart of the Title IV-E system. These $5.1 billion reimburse states for the daily costs of housing children in foster family homes, therapeutic foster care, group homes, and residential treatment facilities. In FY2023, approximately 125,900 children received these payments each month — a point-in-time snapshot that, when annualized, represents the massive scale of out-of-home care funded primarily by federal matching dollars.

At $5.1 billion annually, that translates to roughly $40,508 per child per year in federal foster care maintenance expenditures — or about $3,376 per month for every child in a reimbursable placement. In high-FMAP states like Mississippi, the federal share of that cost can exceed $31,000 per child annually, meaning the state itself puts up relatively little of its own revenue. In lower-FMAP states like California or New York, the match is closer to dollar-for-dollar, but the open-ended nature still removes any hard budget constraint on how many children can be placed.

What these payments explicitly do not cover is far more revealing than what they do. They do not pay caseworker salaries. They do not fund the visits themselves. They do not support the investigation and assessment infrastructure that is supposed to determine whether a child is safe in that placement before the placement is made or while the child remains there. They pay for the placement itself — the roof over the child’s head, the meals on the table, the bed they sleep in — while the safety monitoring of the child inside that placement is left to a completely separate, drastically underfunded, and now even less enforceable funding stream.

This is the core design flaw made visible in raw dollars: the federal government will match tens of thousands of dollars per year to keep a child in a placement, but it allocates less than $6 per month per child to verify that anyone is actually checking on that child, talking to them alone, observing their living conditions, or confirming they have not been re-victimized by the very system meant to protect them. A 7-year-old in a therapeutic foster home in rural Arkansas generates thousands in federal reimbursement for the state each month. The same child might generate less than $6 per month in dedicated federal funding to ensure a caseworker actually shows up to ask how she is doing. The financial architecture does not merely tolerate this imbalance — it was built around it.

Adoption Assistance: $4.3 Billion (45.3%) — Rewarding Permanent Separation Over Family Preservation

The second-largest slice — $4.3 billion — goes to adoption assistance subsidies. These payments support families who adopt children from foster care and can continue until the child turns 18 (or 21 in many states with extended foster care provisions). They represent a long-term financial commitment by the federal government to subsidize the upbringing of children who have been permanently separated from their birth families through the child welfare system.

The near-parity between foster care maintenance ($5.1 billion) and adoption assistance ($4.3 billion) is no accident of history or budgeting. It is the direct, measurable result of the Adoption and Safe Families Act of 1997 (ASFA, P.L. 105-89). ASFA imposed strict timelines requiring states to file termination of parental rights petitions for children who had been in care for 15 of the most recent 22 months, effectively prioritizing adoption timelines over extended reunification efforts. It also created an Adoption Incentive Program that paid states cash bonuses for increasing the number of adoptions above a baseline — an explicit financial reward for volume of permanent separations.

The system now pays $4.3 billion annually for adoption outcomes while maintaining $0 in dedicated federal funding streams for family preservation outcomes at anywhere near the same scale. Prevention services, created by the Family First Prevention Services Act of 2018 (P.L. 115-123), remain stuck at just 1.8% of the total Title IV-E pie more than five years after the law’s passage. The structural message embedded in the spending is unmistakable: the federal government will reimburse states generously for moving children out of their birth families and into adoptive homes. It will reimburse states far less — and with far more bureaucratic hurdles — for the hard, relationship-based work of keeping families together when safe to do so.

Approximately 548,000 children received IV-E adoption assistance each month in FY2023 — more than four times the number receiving foster care maintenance payments. The average adoption subsidy was roughly $7,847 per child per year — about one-fifth the per-child cost of foster care maintenance. This lower per-child cost reflects the fact that adoptive families often have other resources and the subsidy is meant to offset some, but not all, of the costs of raising a child with special needs or trauma histories. Still, the sheer volume of children receiving these subsidies shows how successfully ASFA shifted the system toward adoption as the preferred permanency outcome.

This raises a question the spending data answers with brutal clarity: Does a system that pays $4.3 billion for permanent separation from birth families and almost nothing comparable for keeping families together have a financial incentive to preserve families? The answer is no. The money flows toward the outcome the system was redesigned to produce. Family preservation remains the rhetorical priority in speeches and mission statements. In the actual flow of federal dollars, it remains a rounding error.

Prevention Services: $172 Million (1.8%) — The Afterthought That Was Supposed to Change Everything

The Family First Prevention Services Act of 2018 was sold as a historic rebalancing — allowing states, for the first time, to use Title IV-E funds for evidence-based mental health treatment, substance abuse treatment, and in-home parenting programs to keep families together before removal.

Three years into implementation in FY2023, prevention services received just $172 million — 1.8% of Title IV-E spending.

For every dollar the federal government spent on prevention, it spent $29.65 on removal and placement. For every dollar spent trying to keep families together, the system spent $55.23 on alternatives to family preservation.

Only about 30 states had approved Title IV-E prevention plans by FY2023. Evidence-based service requirements have narrowed the field of eligible providers, especially in rural areas. The structural DNA of the system remains unchanged: it processes children through institutional care far more efficiently than it prevents the need for that care.

Guardianship Assistance: $97 Million (1.0%) — Better Outcomes, Starved of Resources

Guardianship Assistance Payments (GAP), authorized in 2008, provide financial support to relatives who become legal guardians of children in foster care. Kinship care consistently produces better outcomes for children than non-relative foster care. Yet this program received just $97 million — 1% of Title IV-E.

Approximately ,900 children received IV-E guardianship assistance monthly in FY2023. The program remains drastically underfunded compared to the $5.1 billion flowing to non-relative foster care placements. The financial incentive still points overwhelmingly toward traditional foster care rather than the kinship arrangements research shows are safer and more stable for children.

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III. Beyond Title IV-E: The Full $11 Billion Federal Picture

Title IV-E is the largest piece, but it is not the only one. When all federal child welfare programs are combined, the annual total exceeds $11 billion.

Title IV-B Subpart 1 (Child Welfare Services) receives roughly $269 million and is the program that historically carried the (now-eliminated) visitation penalty. Subpart 2 (Promoting Safe and Stable Families) gets about $435 million and explicitly funds family preservation — while the dominant Title IV-E structure incentivizes removal.

CAPTA provides $100 million for prevention infrastructure, hotlines, and investigations. But when caseworkers are not visiting, the CAPTA-funded infrastructure has no information to act on.

The Monthly Caseworker Visit Grant — the primary federal investment in ensuring visits actually happen — stands at just $26 million for FY2026. That is 0.27% of Title IV-E spending. For every $370 the federal government spends on placing and maintaining a child in care, it spends $1 on checking that the child is alive and safe.

Chafee programs for youth aging out of care receive $143 million — critical for transition services, but doing nothing to close the safety monitoring gap for children currently in care.

The architecture is complete: massive open-ended funding for removal and placement. Tiny, capped, discretionary funding for everything else — including the most basic safety verification.

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IV. The FMAP Formula: How Federal Matching Turns Prevention Into a Bad Financial Decision

The Federal Medical Assistance Percentage (FMAP) determines how much of every foster care maintenance dollar the federal government will reimburse. The formula, defined in statute, produces rates ranging from a 50% floor (no state gets less) up to approximately 77% in the poorest states, with U.S. territories fixed at 83%.

In Mississippi (FMAP 77.32%), the state spends only $22.68 of its own money for every $100 in foster care costs. The federal government covers the rest. Every dollar Mississippi shifts from state-funded prevention into federally-matched foster care generates $3.41 in total spending power.

Even at the 50% floor in wealthy states like California and New York, the incentive persists: the federal government will match foster care spending dollar-for-dollar, but prevention services (until Family First) had no federal match at all. The message to state budget directors is unmistakable: “We will match your foster care spending. We will not match your prevention spending.”

This is textbook moral hazard. The open-ended entitlement combined with FMAP matching creates a powerful financial logic that rewards keeping children in care and penalizes investments in keeping families together. Studies from the Urban Institute, Chapin Hall, and others have documented exactly this dynamic for years. Family First was supposed to correct it. At $172 million versus $5.1 billion, the correction remains marginal.

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V. The AFDC Lookback: A 1996 Time Capsule That Excludes 46% of Foster Children

One of the most consequential — and least discussed — structural flaws in Title IV-E is the “AFDC Lookback.” Federal reimbursement is only available for children whose families would have qualified for the old Aid to Families with Dependent Children program under income limits frozen at 1996 levels.

The AFDC program no longer exists. It was replaced by TANF in 1996. But its income thresholds — already far below poverty then — remain frozen in time while everything else has inflated.

In 2026, a family earning just $6,000 per year — roughly 23% of the federal poverty level for a family of three — can still exceed the 1996 AFDC threshold in many states. The result: an estimated 46% of children currently in foster care are ineligible for Title IV-E reimbursement.

This creates a two-tier system. IV-E eligible children (~54%) trigger federal oversight, reporting requirements, and cost-sharing. Non-IV-E eligible children (~46%) are entirely state-funded, with no federal reporting tied to funding and often the first to face budget cuts when states tighten belts.

The Urban Institute estimated that fully eliminating the AFDC lookback would increase federal Title IV-E spending by $2–4 billion annually — representing the cost states are currently absorbing for non-eligible children. Multiple bills have been introduced. None have passed. The Congressional Budget Office scores it as a mandatory spending increase, making it politically toxic in any fiscal environment.

The lookback is not a technical detail. It is a mechanism that quietly shifts billions in costs to states while shrinking the population subject to federal accountability standards.

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VI. Private Money Steps In: $249 Million in Grants — and CASA Outspending the Federal Visit Program 5.7-to-1

Federal funding tells only part of the story. Project Milk Carton’s CivicOps database reveals $249.2 million in tracked private grants flowing to child welfare organizations across 3,257 individual grants to 1,783 unique organizations.

The dominance of CASA programs is striking. $148.7 million — 59.6% of all tracked private child welfare grants — flows to Court Appointed Special Advocates. These volunteers serve as the court’s eyes and ears for children in foster care. In many jurisdictions, CASA volunteers provide the only independent monitoring that supplements (or substitutes for) overwhelmed caseworkers.

The contrast is damning: the federal government allocates $26 million for caseworker visit compliance assistance. Private donors channel $148.7 million to CASA programs that often perform the monitoring caseworkers are supposed to do. The private sector is spending 5.7 times more on child welfare monitoring than the federal visit grant provides.

Top private funders include state CASA umbrella organizations (Texas CASA, California CASA), national donor-advised fund platforms (Fidelity Charitable, Schwab Charitable, American Online Giving Foundation), and major foundations. Top recipients cluster in major metro areas — St. Louis, Florida, Iowa, Chicago, Arizona — while rural communities with the highest caseloads and lowest visit compliance rates remain largely absent from the largest grants.

Grant purpose analysis reveals the same pattern as federal spending: the vast majority flows to organizations serving children already in the system, not to preventing entry. Private philanthropy, like the federal government, invests overwhelmingly in the consequences of family separation rather than its prevention.

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VII. The Parallel Pipeline: $15.98 Billion in Unaccompanied Children Funding

While domestic foster care struggles with visit compliance, a parallel child welfare system has exploded in scale. The HHS Unaccompanied Children (UC) Program has distributed $15.98 billion in awards tracked by PMC CivicOps, with an additional $1.04 billion in downstream sub-awards.

The concentration is extraordinary. The top three Texas-based recipients alone received $20.15 billion combined — 63% of total tracked UAC funding. Southwest Key Programs received $11.76 billion across 519 awards. Texas as a whole dominates with $23.2 billion — 53.7% of all tracked UAC awards.

This geographic and organizational concentration raises urgent questions about competitive bidding, oversight capacity, and whether organizations receiving billions in federal funds are subject to the same accountability standards as traditional foster care providers. The UC Program’s own monthly monitoring and safety assessment requirements face the same compliance challenges documented in the domestic system — and state regulators in Texas are now responsible for overseeing hundreds of UC shelters in addition to their existing foster care oversight duties.

Downstream sub-award data reveals layers of financial intermediation: prime awardees distribute to 355 smaller organizations, with the U.S. Conference of Catholic Bishops alone issuing 4,178 sub-awards totaling $255.5 million.

The parallels are impossible to ignore: both systems spend billions on placement and maintenance while investing comparatively little in verifying the actual safety and well-being of the children they are responsible for.

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VIII. The Accountability Gap: $26 Million to Monitor $9.5 Billion — And the Quiet Elimination of the Last Enforcement Tool

The most damning finding of this entire financial analysis is the ratio between what the system spends on maintaining children in care and what it spends on verifying those children are actually safe inside those placements. Everything else — the FMAP incentives, the AFDC lookback, the prevention shortfall, the private grant patterns — flows from or reinforces this fundamental imbalance.

Title IV-E spends $26 million every 24 hours. The entire annual visit grant — the primary federal investment in ensuring caseworkers actually see the children the system is paying to house — equals roughly one single day of Title IV-E spending. Let that sink in. One day of placement spending equals one year of safety verification funding.

The visit grant is 0.27% of Title IV-E. For every $370 the federal government spends on placing and maintaining a child in out-of-home care, it spends $1 on checking that those children are alive and safe. Per child: $40,508 per year for foster care maintenance versus $70.65 per year for visit compliance. The system spends 574 times more on housing a child than on checking that the child is safe. If this ratio existed in any other domain of government — defense contracting, highway safety, food inspection — it would be treated as a national scandal. In child welfare, it is simply the baseline operating reality.

On January 4, 2025, President Biden signed P.L. 118-258, the Supporting Children and Families Act. Among its many provisions — some genuinely helpful for families — was the quiet elimination of the only federal financial penalty that had ever existed for states failing to meet the 95% monthly caseworker visitation standard. The pre-2025 penalty, codified in 42 U.S.C. § 624(f), was already modest to the point of being symbolic: it allowed HHS to reduce a non-compliant state’s federal match rate for Title IV-B Subpart 1 (Child Welfare Services) from 75% down to as low as 65%. Against a $269 million capped program, even the maximum penalty for a large state might have cost that state a few hundred thousand dollars in lost federal funds. Against $50–500 million in annual Title IV-E reimbursements for the same state, it was less than 1% of what the federal government was simultaneously handing over with no strings attached on visitation.

Worse, the penalty had never been meaningfully enforced in the two decades it existed on the books. HHS never imposed it, even in states with documented, persistent, and audited visit compliance rates well below 95%. On January 4, 2025, even this weak and unused stick was removed and replaced with a small formula grant “to help” states improve visit rates — converting the last remaining enforcement mechanism into a modest carrot. The message to state child welfare directors could not be clearer: there is now no financial downside whatsoever to failing to visit the children in your care. The federal government will continue reimbursing you at full FMAP rates for every placement you make, regardless of whether anyone ever checks on those children.

The federal government has effectively determined that the safety of a child in state custody — a child the state has legally taken responsibility for — is worth less per month than a medium latte from a coffee shop. This is not hyperbole. It is arithmetic.

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IX. The Cost-Sharing Formula: Why Rational Actors Remove Children

Consider the financial calculus facing any state child welfare agency director or budget officer:

Option A — Remove the child and place in foster care. Title IV-E reimburses maintenance at 50–83% FMAP. Administrative costs at 50%. Training at 75%. Open-ended entitlement with no cap. The more children you place, the more federal dollars you receive. The penalty for failing to visit them was just eliminated.

Option B — Provide prevention services to keep the family together. Title IV-E prevention reimburses at 50%, but only for evidence-based services approved by the Prevention Services Clearinghouse, only for children at imminent risk, and only in the ~30 states with approved plans. Before 2018, the federal match for prevention was $0.

The rational economic decision — given these incentive structures — is to remove the child. This is not because caseworkers or administrators are malicious. It is because the federal funding architecture makes removal the financially optimal choice. Prevention costs come out of limited state budgets. Foster care costs are federally matched. A cash-strapped agency facing budget cuts, staff shortages, and political pressure will follow the money.

And the money says: remove the child. Place the child. Claim the federal match. And do not worry too much about whether anyone visits to check on that child — because the penalty for not visiting was just eliminated by Congress.

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X. Conclusions and Recommendations: Every Dollar Deserves to Be Followed

The financial architecture of the American child welfare system is not broken by accident. It is broken by design — built around an open-ended foster care entitlement that rewards removal, an adoption incentive structure that rewards permanent separation, a prevention budget that remains an afterthought, and an accountability mechanism for basic safety that has now been reduced to zero.

The numbers are unambiguous:

$11 billion flows annually through federal child welfare programs with minimal accountability for child safety outcomes.

$9.5 billion in Title IV-E is an open-ended entitlement with no spending cap — it grows automatically as more children enter care.

$26 million for visit compliance represents 0.27% of Title IV-E spending — one day’s worth of the system it is supposed to monitor.

$70.65 per child per year is the federal investment in verifying that caseworkers actually visit the children the system is paying to house.

46% of foster children are excluded from Title IV-E eligibility by a 1996 income threshold frozen in time.

$0 in penalties will be imposed on states that fail to visit children — the only penalty was removed by P.L. 118-258 on January 4, 2025.

$249 million in private grants flow to child welfare organizations, with private CASA funding ($148.7M) exceeding the federal visit grant by a factor of 5.7.

$15.98 billion in UAC program awards flow to NGOs through a parallel pipeline with its own accountability challenges.

This is not a resource problem. This is a priority and incentive problem. The system has more than enough money. It simply spends that money on the wrong things, measured by the wrong metrics, with almost no consequences for failing the most basic test of child protection: Is anyone checking on this child?

Recommendations: Reclaiming Accountability in an $11 Billion System

The financial architecture is not immutable. It was created by statute, shaped by regulation, and can be reformed by the same political process that built it. The recommendations below are not radical. They are the minimum structural corrections required to align federal dollars with the actual safety of children rather than the volume of placements.

Delink visit compliance from the small, capped Title IV-B program and attach meaningful financial consequences directly to Title IV-E. A 1–2% withholding on the $9.5 billion entitlement ($95–190 million annually) would create a financial incentive large enough that state budget offices and child welfare directors could not ignore it. Tie real, recurring dollars to independently verified visit compliance. States that meet or exceed the standard keep the full match. States that fall short lose a predictable percentage of their IV-E reimbursement until they demonstrate improvement. This is how you make safety matter in a system that currently only counts placements.

Eliminate the AFDC Lookback immediately through legislation. All children in foster care should be Title IV-E eligible regardless of their birth family’s 1996 income level. The child is in state custody because a court or agency determined that protection was required — not because their parents’ income crossed an arbitrary threshold frozen three decades ago while poverty lines and cost of living marched upward. Eliminating the lookback would bring an estimated 46% of currently excluded children under federal oversight and cost-sharing, while removing a hidden cost shift that has forced states to absorb billions in expenses for non-IV-E eligible children.

Increase the Monthly Caseworker Visit Grant from $26 million to at least $260 million — still only 2.7% of Title IV-E spending. Use the increased funding to deploy real-time visit verification technology, fund supervisor ride-alongs for quality control, support rural caseworker travel, and build data systems that flag missed visits before they become chronic. $70.65 per child per year is not a serious investment in safety. It is a performative line item that allows Congress and HHS to claim they “did something” while children continue to go unseen.

Require real-time, technology-enabled visit verification as a explicit condition of Title IV-E participation. GPS-enabled check-ins at the placement location, digital visit logs that capture date/time/duration, and supervisor electronic co-signatures should be mandatory for any state claiming federal foster care maintenance reimbursement. The technology exists today, costs pennies per transaction compared to the billions at stake, and would finally replace the honor system that has allowed self-reported compliance to diverge so dramatically from audited reality in multiple states.

Mandate independent, annual third-party audit of visit compliance data as a condition of receiving any Title IV-E funds. Self-reported data from state child welfare agencies is demonstrably unreliable — Connecticut’s 57.4% audited rate versus much higher self-reported figures is only one example among many. Independent verification, perhaps through a rotating schedule of federal audits or contracted inspectors general with real authority, should be non-negotiable. No state should be able to claim full IV-E reimbursement while hiding behind numbers that do not survive outside scrutiny.

Rebalance the prevention-to-placement funding ratio by making the federal match for approved prevention services equal to or greater than the foster care maintenance match. A system that spends $29.65 on removal and placement for every $1 on prevention will never sustainably reduce the number of children entering care. The Family First Act took a first step. It must be completed by removing the evidence-based clearinghouse bottlenecks that exclude promising local programs, expanding the definition of eligible prevention, and giving high-FMAP states the same powerful financial incentive to invest in keeping families together that they currently have to place children in care.

Establish a public, real-time national dashboard of state-by-state visit compliance rates, audited findings, and enforcement actions. Transparency is itself a powerful accountability mechanism. When parents, advocates, journalists, and legislators can see in real time which states are failing to visit their children in care — and which states are hiding behind weak self-reported data — political pressure becomes impossible to ignore. States performing poorly should face public scrutiny and the loss of federal dollars, not just confidential corrective action plans sitting in HHS filing cabinets.

Subject the entire Unaccompanied Children provider network to the same — or higher — safety verification and visit compliance standards applied to domestic foster care. Organizations receiving $11+ billion in concentrated federal awards must be held to rigorous, independent oversight of actual child safety outcomes, not merely financial reporting and bed counts. The same GPS verification, independent audit, and real-time public dashboard requirements should apply. Geographic concentration in Texas and a handful of large providers creates both efficiency and monopoly risk; oversight must match the scale of the money.

The children in America’s foster care system and in the parallel Unaccompanied Children programs did not choose to be there. They are there because the state — or the federal government in the case of unaccompanied minors — determined they needed protection from harm. The absolute minimum obligation of that legal custody is ensuring that someone actually checks on them, sees them, talks to them, and confirms they are not being harmed in the placement the government chose for them.

Eleven billion dollars a year flows through this system. Less than six dollars a month per child is allocated to verify they are safe.

This is not a system that lost its way through benign neglect or insufficient resources. This is a system that was deliberately constructed — through statute, through regulation, through decades of incremental choices — to count placements, to reward volume, to shift costs, and to minimize accountability for the one outcome that should be non-negotiable: that every child the state takes into its care is seen, heard, and protected.

Every child deserves to be seen.

Every dollar deserves to be followed.

The children are waiting.

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Project Milk Carton is a 501(c)(3) nonprofit dedicated to U.S. child welfare transparency, CPS and foster care accountability, human trafficking prevention, and OSINT-driven investigations. Our CivicOps database powers this research. Full methodology, data sources, and replication files available at projectmilkcarton.org.

Data current as of June 2026. All figures nominal unless otherwise noted. This article draws on ACF Title IV-E expenditure data (Form CB-496), CRS reports, KFF FMAP data, Urban Institute analyses, HHS TAGGS, USAspending.gov sub-awards, and PMC CivicOps Form 990 Schedule I tracking (630,263 records, $89.1B total).

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