FLORIDA STATE CUSTODY / CHILD WELFARE ACCOUNTABILITY AUDIT

OPUS STATEWIDE FAST PASS SCAN

Investigation ID: FL-CW-AUDIT-20260119
Classification: SYSTEM ACCOUNTABILITY ANALYSIS
Investigator: OPUS (Claude Opus 4.5)
Date: January 19, 2026
Scope: 2019-2024 (partial 2025)

---

EXECUTIVE SUMMARY

This investigation applies the "Oklahoma Signature" detection framework to Florida's child custody and welfare system. Florida presents a UNIQUE NATIONAL CASE as the first and only state to fully privatize its child welfare system through Community-Based Care (CBC) lead agencies.

KEY FINDING: STRUCTURAL ACCOUNTABILITY GAP

Florida's privatization model creates a multi-layered opacity problem:
- DCF contracts with 18 CBCs → CBCs subcontract to providers → providers deliver services
- Federal funds pass through 3-4 organizational layers before reaching children
- Forensic audits in 2023 revealed systemic related-party transaction abuse
- 6 of 10 audited CBCs had open Corrective Action Plans as of January 2024

RISK CLASSIFICATION: HIGH

Domain	Risk Level	Evidence Strength
Missing Children in Custody	HIGH	Partial data; classification concerns
Facility Safety	HIGH	224 DJJ allegations (102 sustained)
Governance/Financial	CRITICAL	$1.7B+ federal funding; audit failures
Oversight Continuity	MODERATE	Investigator turnover 71% (2021-22)
Transparency	HIGH	Key data suppressed or fragmented

---

I. FLORIDA CHILD WELFARE SYSTEM ARCHITECTURE

1.1 Unique Privatization Model

Florida is the only state in the nation that has fully privatized foster care and adoption services.

Structure:

Federal Funding (HHS/ACF)
         ↓
Florida DCF (State oversight)
         ↓
18 Community-Based Care Lead Agencies (Private nonprofits)
         ↓
Case Management Organizations + Service Providers
         ↓
Children/Families

CBC Lead Agencies (2024):
1. Embrace Families (Orange, Osceola, Seminole)
2. Heartland for Children (Polk, Highlands, Hardee)
3. ChildNet (Broward, Palm Beach)
4. Kids Central (Lake, Citrus, Hernando, Marion, Sumter)
5. Family Support Services (Duval, Nassau)
6. Partnership for Strong Families (Alachua + 13 counties)
7. Brevard Family Partnership
8. Children's Network of Southwest Florida
9. Big Bend CBC / NWF Health Network
10. Kids First of Florida
... and 8 others

1.2 CBC Funding (FY 2018-2024)

Fiscal Year	CBC Appropriations
2018-19	$951.9 million
2023-24	$1.3 billion
Growth	+36.5%

---

II. ACCOUNTABILITY PIPELINE ANALYSIS

2.1 Full Pipeline (FY 2023 - Most Recent Complete Data)

Stage	Florida	Rate/Notes
Child Population	4,380,843	Under 18
Child Poverty Rate	15.70%	Above national avg
Total Hotline Reports	246,778	56.3 per 1,000 children
Screened-In Referrals	139,213	56.4% screen-in rate
Investigations Opened	185,390	FY 2023-24
Maltreatment Victims	22,842	5.2 per 1,000 (↓33% from 2019)
Children in Foster Care	20,322	FY 2023
Foster Care (FY 2024)	17,198	↓ from prior year
Children in Services	55,092	Family support + OOH care
Child Fatalities (2023)	75	↓ from 114 in 2019
Missing/AWOL (2021)	180	0.8% of foster population

2.2 Positive Trend: Maltreatment Rate Decline

2019: 7.8 per 1,000 → 2023: 5.2 per 1,000 (↓33.3%)

Caveat: Decline coincides with pandemic and staffing crisis; may reflect reduced detection capacity rather than actual improvement.

2.3 Child Fatality Trend

Year	Fatalities
2019	114
2020	101
2021	84
2022	86
2023	75

2023 Fatality Profile (390 reviewed cases):
- 61.5% male victims
- 22.5% drowning deaths (88 cases)
- 34.1% sleep-related deaths (133 cases)
- 30 homicides (18 inflicted trauma, 9 firearms)
- 31.5% of supervisors impaired at incident

Counties with Highest Fatalities:
1. Hillsborough (12.0% of all cases)
2. Broward (9 cases)
3. Duval (9 cases)
4. Brevard (8 cases)
5. Polk (8 cases)
6. Palm Beach (7 cases)

---

III. MISSING-IN-CUSTODY ANALYSIS (MICR)

3.1 Available Data

NCMEC Database (Current): 128 missing children from Florida
- Under 13: 10 children
- Teens (13-17): 86 children
- Date range: 2006-2024

Missing Children by County (Top 10):
| County | Count | Notable Cases |
|--------|-------|---------------|
| Miami-Dade | 20 | Michael Reyes (2008), Andrew Caballeiro (2020) |
| Broward | 19 | Sebastian/Briana Conklin (2011), Zahra/Yusuf Shikder (2015) |
| Hillsborough | 14 | Edgar Pacay Paau, Maria Castro-Membreno |
| Orange | 10 | Omar Ramirez, Caelynn Jimenez |
| Palm Beach | 9 | Olympia Capaldi (age 3, 2022) |
| Duval | 8 | Nehemiah Weedon (age 10, 2014) |
| Pinellas | 7 | Multiple teen runaways |
| Lee | 5 | Bryan Dossantos-Gomes (2006) |
| Collier | 5 | Adji Desir (case of note) |
| Brevard | 5 | Atraya Berardi, Jazzaniyah Jones |

3.2 Classification Shield Index (CSI)

⚠️ DATA SUPPRESSION FLAG

Florida does not publicly report the breakdown of:
- Children missing from foster care vs. general population
- "Runaway" vs. "abducted" classification
- Time-to-recovery metrics for foster care runaways
- Distinction between AWOL episodes and true missing status

Available Data Point (2021): 180 children (0.8%) classified as runaways

Federal Audit Finding (2023):

"State agencies did not always ensure that children missing from foster care were reported to NCMEC. Of 100 sampled episodes, 45 were never reported, 22 were not timely."
— HHS OIG, 2023

TRANSPARENCY OVERRIDE TRIGGERED
- MICR cannot be calculated with precision
- Classification practices obscure true missing rate
- Records Request Required: FL DCF monthly AWOL/missing data by circuit, 2019-2024

---

IV. FACILITY SAFETY ANALYSIS (FHR)

4.1 Juvenile Detention Facilities (DJJ)

FY 2023-2024 Investigation Data:
- 85 complaints assigned for investigation
- 57 investigations closed
- 224 allegations investigated
- 102 allegations SUSTAINED (45.5%)
- 83 Not Sustained, 26 Unfounded, 5 Exonerated

Sustained Findings Types:
- Excessive/improper use of force
- Staff-youth inappropriate relationships
- Failure to report (PREA violations)
- Sexual abuse allegations

Notable Incidents (2024-2025):
| Facility | Incident | Finding |
|----------|----------|---------|
| Pinellas JDC | Sergeant solicited sexual activity with teen (Feb 2024) | Criminal arrest |
| Orange Regional JDC | Staff inappropriate relationships with multiple youth | 3 of 5 allegations sustained |
| Okeechobee YDC | Youth barred from reporting mistreatment (Nov 2022) | DJJ confirmed |
| St. John's Youth Academy | Abuse, failure to ensure safe environment | Contract terminated (2022) |

4.2 Private Residential Facilities

Major Private Operators:
- TrueCore
- Rite of Passage
- Youth Opportunities Investments

⚠️ TRANSPARENCY GAP: Private facility abuse reporting is less transparent than state-operated facilities. Sexual abuse incidents underreported.

Federal Action (June 2024):

U.S. Senate Finance Committee released sweeping report detailing abuse at residential treatment facilities operated by major healthcare companies.

4.3 Commercial Sexual Exploitation (CSE) in Care

2023 CSE Statistics:
- 1,448 investigations of CSE allegations
- 339 CSE youth verified (↓ from 354 in 2022)
- 59% of revictimized youth were already in out-of-home care
- 4% of investigations involved sexual abuse allegations
- 4% involved substance misuse

Placement Gap:

"Limited availability across the child welfare placement array, particularly safe houses, safe foster homes, and inpatient substance use and mental health settings."
— OPPAGA Report 24-04

---

V. GOVERNANCE & FINANCIAL ANALYSIS (GCFS)

5.1 CBC Forensic Audit Findings (August 2023)

Audited Period: July 1, 2019 – June 30, 2021
CBCs Audited: 10 lead agencies

Systemic Violations Found:

Violation Type	Prevalence
Non-compliant contract procurement	Multiple CBCs
PPP loans not properly reimbursed to state	Multiple CBCs
Board approval of deficit budgets	Multiple CBCs
Officer compensation exceeding caps	Multiple CBCs
Non-compliance with Cost Allocation Plans	Multiple CBCs
Related party transactions without disclosure	Widespread
Funds transferred to related parties	11 CBCs flagged

Corrective Action Plan Status (as of July 2024):

CBC	CAP Status
Partnership for Strong Families	CLOSED (June 6, 2024)
Big Bend/NWF Health Network	CLOSED (July 30, 2024)
Brevard Family Partnership	CLOSED (July 30, 2024)
Children's Network of SWFL	CLOSED (July 30, 2024)
ChildNet	OPEN
Embrace Families	OPEN
Family Support Services	OPEN
Kids First of Florida	OPEN
Communities Connected	OPEN
Kids Central	OPEN

Specific Violations (Brevard Family Partnership):
- Failed to disclose related party transactions
- Family Allies, Inc. not consolidated in audited financials as required

5.2 Federal Funding Analysis

Total Federal Funding to FL Child Welfare (TAGGS Database):

Funding Category	Total	Transactions
TAGGS Child Welfare Grants	$1,702,086,221	548
UAC/ORR Subawards	$23,616,870	115

Top FL Recipients of Child/UAC Federal Funding:

Organization	Total Funding	Purpose
Comprehensive Health Services, LLC	$920,999,878	UAC residential shelter
Catholic Charities (Miami)	$98,375,372	UAC shelter services
His House, Inc.	$75,717,397	UAC shelter + TFC
Gulf Coast Jewish Family Services	$58,339,478	UAC services
Lutheran Services Florida	$54,998,238	UAC shelter + support

Note: Comprehensive Health Services received nearly $1 billion in federal UAC funding through Florida operations. This represents a significant concentration of federal child welfare dollars in a single private contractor.

5.3 Nonprofit Revenue Analysis (Form 990)

Major FL Child Welfare Nonprofits:

Organization	EIN	Revenue (Latest)	Assets
Embrace Families CBC	10631375	$76,092,919	$3,095,345
Heartland for Children	20619609	$69,460,443	$11,126,964
Youth Co-Op, Inc.	237320351	$49,697,518	$39,875,752
Florida Sheriffs Youth Ranches	237303117	$27,264,072	$105,186,000
Centro Mater Child Care	208083301	$15,423,728	$4,211,710

Florida Sheriffs Youth Ranches Officer Compensation:
| Year | Revenue | Officer Comp | % Revenue |
|------|---------|--------------|-----------|
| 2022 | $25,037,131 | $579,976 | 2.32% |
| 2021 | $25,148,323 | $669,718 | 2.66% |
| 2020 | $15,724,817 | $662,404 | 4.21% |
| 2019 | $19,383,393 | $636,993 | 3.29% |

Assessment: Officer compensation within acceptable range (< 5% of revenue).

---

VI. OVERSIGHT CONTINUITY ANALYSIS (ODR)

6.1 Investigator Turnover Crisis (2019-2023)

Metric	FY 2019-20	FY 2021-22	April 2023
CPI Turnover Rate	44.9%	71.1%	40%
Vacancy Rate	—	—	23% (237 positions)
Staff < 2 yrs experience	—	—	60%

Impact Statements:

"The quality of the work was poor. We did a bad job... half the decisions made along the way were the wrong ones."
— Former DCF Secretary Chad Poppell (2021)

"Employees are often required to work 16-hour shifts... has caused employee burnout and has led to an increase in the use of sick leave."
— DCF Budget Request (2022)

6.2 System Takeback (2023)

Legislative Response: All child protective investigative functions transitioned fully back to DCF from sheriff's offices (2023 session).

Reforms Implemented:
- CPI base pay increased to $50,000 (October 2023)
- Senior CPI pay increased to $54,500
- Workforce Wellness Unit established
- "Continue the Mission" veteran recruitment initiative
- 19 virtual hiring events

Current Status (June 2024):
- 1,852 employees in CPI/Senior CPI/CPIS/FSC roles
- Turnover reduced from 71% → 40%

6.3 Legislative Reforms (2024)

HB 1061 - Community-Based Care Agencies:
- Restricts CBC transactions with related parties
- Requires competitive procurement for contracts > $35,000
- Prohibits delegation of management functions to related parties
- Mandates monthly data publication on CBC websites

HB 631 - CBC Funding Model:
- Eliminates equity allocation model
- Implements actuarially sound, reimbursement-based funding (FY 2025-26)

---

VII. ICWA/TRIBAL COORDINATION

⚠️ LIMITED DATA

Florida has a small Native American population, and ICWA compliance data is not prominently reported.

Florida Dependency Benchbook:

"Leadership by the court is essential to ensure ICWA compliance. If ICWA requirements are not met, Indian children will face significant delay in achieving permanency."

Consequences of Non-Compliance:
- Invalidation of state court proceedings
- Disruption of foster care placements
- Voiding of adoption orders
- Malpractice liability
- Federal sanctions

Records Request Required: FL DCF ICWA compliance data, tribal consultation logs, 2019-2024

---

VIII. REQUIRED METRICS CALCULATION

8.1 Missing-in-Custody Rate (MICR)

MICR = missing_or_awol_in_custody / children_in_custody

Available Data:
- Children in foster care (2021): ~22,000
- Runaways reported (2021): 180

Estimated MICR (2021): 180 / 22,000 = 0.8%

⚠️ CAVEAT: This likely undercounts true missing episodes
⚠️ DATA SUPPRESSED: No current AWOL data, no time-to-recovery metrics

8.2 Classification Shield Index (CSI)

CSI = runaway_classified / total_missing_or_awol

⚠️ CANNOT CALCULATE: Florida does not publish breakdown
⚠️ Federal audit suggests significant underreporting to NCMEC

8.3 Facility Harm Rate (FHR)

FHR (DJJ) = sustained_allegations / investigations

FHR = 102 / 224 = 45.5% sustain rate

Additional Context:
- 85 complaints triggered 224 allegations (2.6 allegations per complaint)
- PREA violations documented at multiple facilities

8.4 Licensing Contradiction Score (LCS)

⚠️ LIMITED DATA: Specific license renewal decisions during CAP periods not published

Known Contradictions:
- Eckerd Connects: "Years of lacking appropriate placements, running over budget, arguably over-paying executives" → contracts continued until announced non-renewal
- St. John's Youth Academy (Sequel): Abuse + "failure to ensure safe environment" → contract terminated 2022

8.5 Governance Control Failure Score (GCFS)

Indicators Found:
[✓] Non-compliant procurement processes
[✓] PPP loan reimbursement failures
[✓] Related party transaction abuse
[✓] Cost allocation plan violations
[✓] 6/10 CBCs with open CAPs (as of Jan 2024)

GCFS = HIGH (Multiple systemic failures confirmed by forensic audit)

8.6 Oversight Drop-Off Risk (ODR)

Key Transition Point: 2021-2023

Before (2019-2021):
- CPI turnover 44.9% → 71.1%
- Vacancy rate surged to 23%
- 60% of staff < 2 years experience

After Reforms (2023-2024):
- CPI turnover reduced to 40%
- Pay increases implemented
- Functions transitioned back to DCF

ODR = MODERATE (Crisis recognized; reforms underway)

---

IX. DATA SUPPRESSION VS. PIPELINE GAPS

9.1 DATA SUPPRESSED (Transparency Override)

Data Element	Status	Required Action
Monthly AWOL/missing children by circuit	NOT PUBLIC	FOIA request
Classification breakdown (runaway vs. abducted)	NOT PUBLIC	FOIA request
Time-to-recovery metrics	NOT PUBLIC	FOIA request
Private facility abuse reporting	PARTIAL	Legislative inquiry
CBC executive compensation caps compliance	PARTIAL	FOIA request
ICWA compliance metrics	NOT PUBLIC	FOIA request

9.2 DATA PIPELINE NOT WIRED

Data Element	Status	Notes
Real-time foster care population by county	Available via FL CHARTS	Accessible
Maltreatment rate trend	Available	In CivicOps database
Fatality data	Available	CADR annual reports
Federal funding flow	Available	TAGGS + Schedule I

---

X. RECORDS REQUESTS (AUTO-GENERATED)

Request 1: Missing Children Data

To: Florida Department of Children and Families, Office of Child Welfare
Subject: Public Records Request - Missing/AWOL Children in DCF Custody

Requesting monthly data (January 2019 - December 2024) for:
1. Number of children reported missing/AWOL while in DCF custody, by circuit
2. Classification breakdown: runaway, family abduction, non-family abduction, unknown
3. Time-to-recovery statistics for each episode
4. Cases where children were missing > 30 days
5. Cases where children remain unrecovered

Request 2: CBC Audit Documentation

To: Florida DCF Office of Inspector General

Requesting:
1. Full forensic audit reports for all 10 CBCs (August 2023)
2. Corrective Action Plans submitted by each CBC
3. Monthly compliance monitoring reports (2023-2024)
4. Documentation of related party transactions flagged by auditors

Request 3: DJJ Incident Data

To: Florida Department of Juvenile Justice

Requesting:
1. All PREA reports (2019-2024) with facility identification
2. Use of force incidents by facility (2019-2024)
3. Staff terminations/arrests related to youth abuse (2019-2024)
4. Contract terminations with private operators and reason codes

Request 4: Private Facility Oversight

To: Florida Agency for Health Care Administration

Requesting:
1. Licensing inspection reports for all residential child care facilities (2019-2024)
2. Deficiencies cited and corrective action required
3. License revocations, suspensions, or non-renewals
4. Abuse/neglect allegations by facility (de-identified)

---

XI. SUMMARY RISK ASSESSMENT

Overall Risk Level: HIGH

Domain	Score	Trend
Missing Children in Custody	HIGH	↔ Insufficient data
Facility Safety	HIGH	↓ Improving (DJJ reforms)
Financial Governance	CRITICAL	↓ Legislation passed
Oversight Capacity	MODERATE	↑ Turnover improving
Transparency	HIGH	↔ Key data still suppressed
Federal Compliance	MODERATE	↔ Audit findings serious

"Oklahoma Signature" Pattern Match

Signal	Florida Match?
Children missing/unaccounted while in state responsibility	⚠️ PARTIAL (data suppressed)
Runaway classification as default outcome label	⚠️ POSSIBLE (federal audit concerns)
Documented abuse in licensed facilities	✓ CONFIRMED
Repeat CAPs without meaningful enforcement	✓ CONFIRMED (CBC audits)
Large federal funds + weak monitoring	✓ CONFIRMED ($1.7B+)
Consent decree/oversight changes correlate with outcomes	⚠️ PARTIAL (privatization issues)

---

XII. RECOMMENDATIONS

Immediate Actions (0-6 months)

1. Publish monthly AWOL/missing data by circuit - Essential for public accountability
2. Complete all open CBC Corrective Action Plans - 6 CBCs still in remediation
3. Implement real-time missing child tracking dashboard - Public-facing

System Reforms (6-18 months)

4. Consolidate private facility oversight - Single state entity for all licensed child care
5. Mandate NCMEC reporting compliance audit - Address 45% non-reporting rate
6. Establish CBC executive compensation database - Public transparency

Long-Term (18-36 months)

7. Evaluate privatization model outcomes - Comprehensive comparison to state-operated models
8. Implement federal fund traceability system - Track dollars from grant to child outcome
9. Create independent child welfare ombudsman - Outside DCF chain of command

---

XIII. SOURCES

Databases Queried

• [CIVICOPS] CivicOps PostgreSQL - child_welfare_* tables, missing_children, taggs_ngo_grants
• [IRS_BMF] IRS Business Master File - FL nonprofits (NTEE P3, P4)
• [FORM_990] Form 990 financial data - FL child welfare orgs
• [UAC_SUBAWARDS] Program 93.676 subawards - FL recipients
• [SCHEDULE_I] Form 990 Schedule I grants - FL organizations

Government Sources

• FL DCF - Child fatalities, accountability reports
• FL DCF OIG - Annual reports 2023-2024
• FL DJJ - Juvenile detention data
• FL CADR - Child Abuse Death Review 2025 Annual Report
• FL Senate - HB 1061, HB 631 analyses
• OPPAGA - Report 24-04 (CSE Annual Report)

Federal Sources

• HHS OIG - Missing children reporting audit (2023)
• ACF - AFCARS data, listening session reports
• NCMEC - Missing children impact data

News Sources

• WFLA - DCF staffing crisis coverage
• Orlando Sentinel - CPI takeover reporting
• Sun-Sentinel - Foster care trafficking investigation
• Florida Politics - "Foster Shock" documentary coverage
• The Imprint - Child welfare chief resignation

OSINT Tools Used

• [KALI:waybackurls] Historical URL discovery - myflfamilies.com, djj.state.fl.us
• [KALI:whois] Domain registration - myflfamilies.com

---

Report generated by OPUS | Project Milk Carton
Investigation Time: 45 minutes
Tools Used: 42
Classification: UNCLASSIFIED // FOR PUBLIC RELEASE