THE 1960 BOTTLENECK: How a Paper Compact Traps Foster Children in Institutions While Vetted Relatives Wait

An OPUS Investigation — Project Milk Carton

Date: June 23, 2026 Classification: Public Investigation / Child Welfare Transparency Subject: The nationwide breakdown of the Interstate Compact on the Placement of Children (ICPC)

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EXECUTIVE SUMMARY

Somewhere in America tonight, a foster child is sleeping in an institution — a group home, a residential facility, sometimes a child-welfare office — not because no family wants them, but because a vetted grandmother, aunt, or uncle lives on the wrong side of a state line.

The instrument keeping them apart is the Interstate Compact on the Placement of Children (ICPC) — a uniform state law drafted in 1960, before the interstate highway system was finished, before the personal computer, and before modern administrative law. It governs every foster, pre-adoptive, and relative placement that crosses a state border. It is law in all 50 states, the District of Columbia, and the U.S. Virgin Islands — 52 jurisdictions.

The system processes roughly 40,000 interstate home-study requests every year. By the most cited practitioner data:

• Only ~30% of home studies are completed within the 30-business-day target.
• ~45% are completed within 60 days (the federal statutory benchmark).
• ~30% take longer than 90 days.
• ~40% of all ICPC placement requests are ultimately denied — and the compact historically barred courts from reviewing those denials, with no national appeals process.
• Children needing an out-of-state placement spend a median of ~43 months in foster care — roughly two years longer than children who can be placed in-state.

This is not a paperwork nuisance. It is a structural machine that takes the cheapest, most appropriate, family-based placement option and converts it, through delay, into the most expensive, least appropriate, institutional one — the exact outcome two major federal laws were written to prevent.

The core finding of this investigation: The ICPC delay crisis sits in direct, documented tension with (1) the Fostering Connections Act's kinship-placement preference (42 U.S.C. 671(a)(19)) and (2) the Family First Prevention Services Act's mandate to get children out of congregate care — yet there is no federal enforcement, no uniform enforceable timeline, and no AFCARS data element that even counts how many children are warehoused in costlier institutional care (drawing full Title IV-E reimbursement) solely because of cross-state red tape. The harm is, by design, statistically invisible.

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PART I — WHAT THE ICPC IS, AND WHY IT BREAKS

A 1960 law governing a 2026 problem

The ICPC was drafted in 1960 by East Coast social-service administrators, sponsored through the New York State Department of Social Welfare. New York enacted it first that same year; by 1986 nearly every state had adopted it. The mechanics have barely changed:

• A sending agency in one state wants to place a child with a family in another state.
• It files a Form ICPC-100A — notice of intent plus a request for the receiving state to find the placement "not contrary to the interests of the child," usually triggering a home study.
• The request cannot go directly from one local caseworker to another. It must route through the state Compact Administrator in the sending state, to the Compact Administrator in the receiving state, down to a local worker, and all the way back.
• The receiving-state Compact Administrator renders the final approval or denial on a signed 100A.

Every one of those handoffs is a queue. For roughly half a century, the entire packet — the 100A, the home study, criminal background checks, medical forms — was photocopied and physically mailed between states. The rules are written and revised by the Association of Administrators of the ICPC (AAICPC), housed inside the American Public Human Services Association (APHSA).

In March 2004, APHSA's own state leadership passed a resolution to rewrite the compact, conceding it "was written before the interstate highway system, before the development of administrative law, and before the computer revolutionized the way we live."

That was 22 years ago. The rewrite is still not in force nationally (see Part VI).

The delay is structural, not accidental

The University of Michigan Law School's Vivek Sankaran — the nation's leading academic critic of the ICPC and author of the Annie E. Casey Foundation's ICPC analysis — frames the problem bluntly: the compact "has created a system in which foster children awaiting interstate placements languish in temporary placements indefinitely." The delays, the literature notes, are "largely beyond the control of the child welfare agency tasked with completing the home studies."

Cited causes: incomplete background checks, unresolved financial/medical questions, missing information, inadequate staffing, lack of training, and caseworker turnover — compounded across two state bureaucracies instead of one.

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PART II — "REGULATION 7" AND THE PROMISE THAT ISN'T KEPT

The ICPC's drafters anticipated the emergency. AAICPC Regulation 7 — "Expedited (Priority) Placement" — is supposed to fast-track placement of a child with a parent, stepparent, grandparent, adult aunt or uncle, adult sibling, or guardian. On paper its deadlines are aggressive:

• Sending agency transmits the completed 100A and Form 101 within 3 business days of a signed order.
• Sending Compact Administrator forwards the full request within 2 business days.
• Receiving-state worker completes the priority home study within 20 business days; some states require a provisional decision within 7 calendar days.

And the trigger conditions are exactly the children most at risk: a child 4 years old or younger, sibling groups, or a sudden dependency from a parent's incarceration, incapacitation, or death.

The promise collapses on enforcement. There is no federal penalty for missing a Regulation 7 deadline. Enforcement depends on a sending-state court persuading a receiving-state court to intervene — cross-state judicial cooperation that advocates describe as weak to nonexistent. The compact sets no specific deadline for completing an ordinary interstate home study and no clear evaluation standard; under AAICPC regulations a final decision can take up to 180 calendar days from receipt of the request.

Congress tried to add teeth. The Safe and Timely Interstate Placement of Foster Children Act of 2006 (Pub. L. 109-239) amended Title IV-E to require receiving states to complete requested home studies within 60 days (with a $1,500 incentive payment for finishing within 30), now codified at 42 U.S.C. 671(a)(26). Yet a decade-plus later, only about 30% of studies hit the 30-day mark and only ~45% hit 60 days. The deadline exists. The consequence for missing it does not.

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PART III — THE LEGAL COLLISION: TWO FEDERAL LAWS, ONE BROKEN COMPACT

The kinship preference Congress promised — and softened

The Fostering Connections to Success and Increasing Adoptions Act of 2008 (Pub. L. 110-351) is the statute most often cited for the principle that family comes first. Its kinship language, at 42 U.S.C. 671(a)(19), requires every state's Title IV-E plan to provide that:

"the State shall consider giving preference to an adult relative over a non-related caregiver when determining a placement for a child, provided that the relative caregiver meets all relevant State child protection standards."

Read it carefully. It is a mandate to "consider giving preference" — not an absolute requirement to place with kin — and it is gated on the relative meeting "all relevant State child protection standards." That soft verb is the seam through which children fall: when the out-of-state home study that would prove the relative meets those standards is stuck in an ICPC queue for a year, the preference becomes unenforceable in practice.

Family First says "get kids out of institutions." ICPC delay puts them there.

The Family First Prevention Services Act (FFPSA, 2018), enacted in the Bipartisan Budget Act of 2018 (Pub. L. 115-123), limits federal Title IV-E room-and-board reimbursement for congregate/group care to just 14 days — after which federal money stops — unless the placement is a narrowly defined Qualified Residential Treatment Program (QRTP) or one of three other approved settings. QRTPs carry their own clock: a "qualified individual" must assess within 30 days whether the child could be served in a family setting, and a court must approve the placement within 60 days.

Here is the collision, stated plainly:

FFPSA financially punishes keeping a child in an institution past two weeks. ICPC red tape routinely keeps that same child in the institution for months — because the out-of-state family home that would get them out is waiting on a home study.

The two systems pull in opposite directions. And the evidence through 2026 is that Family First has not actually reduced congregate-care reliance in many states (The Imprint; Child Welfare Monitor, March 2026) — leaving children in exactly the placements both the money and the policy were designed to empty.

The money: kinship is cheapest, institutions cost an order of magnitude more

Title IV-E is an open-ended federal entitlement: for each eligible child, Washington reimburses a share of maintenance costs at the state's FMAP rate (roughly 50%–83%). The cost gradient is stark:

Placement type	Representative daily / annual cost
Unlicensed kinship	~$10–$13/day (about $4,600/yr)
Licensed family foster	~$20–$27/day (about $9,900/yr)
Congregate / institutional	7–10x family care; ~$41,000 to $198,000+/yr, high-acuity residential exceeding $290,000/yr

(Sources: Annie E. Casey "Every Kid Needs a Family"; Every Texan; Arizona DCS rate schedules; Father's Advocacy Network.)

The perverse incentive writes itself: ICPC delay keeps children parked in the most expensive setting while a cheaper, family-based out-of-state placement sits ready. Casey's "Every Kid Needs a Family" report documented 57,000 children living in group placements — a population the cost math and federal policy both say should be far smaller.

PMC database — the dollars in motion. Project Milk Carton's CivicOps tracking of federal foster-care awards (HHS TAGGS data) shows the scale of money flowing through individual states' systems: Texas — $3.59 billion across 297 awards; West Virginia — $1.02 billion across 224 awards. West Virginia is instructive: its child-maltreatment victim count, though declining, remained at 4,850 victims (13.8 per 1,000 children) in 2023 — and the state is the defendant in an active federal class action alleging it "relies indiscriminately on out-of-state institutional care" (see Part IV). Over a billion federal dollars, and children still shipped across state lines into institutions.

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PART IV — THE COURTS: WHERE THE FIGHT IS ACTUALLY HAPPENING

There is no single landmark case that strikes down the ICPC for delay. The legal attack runs on three tracks.

Track 1 — "The ICPC doesn't even apply to out-of-state parents and (in many states) relatives"

The strongest, most successful line of cases holds that the compact never applied to returning a child to an out-of-state biological parent — meaning ICPC delay cannot lawfully block reunification:

• McComb v. Wambaugh, 934 F.2d 474 (3d Cir. 1991) — the seminal ruling: the ICPC "was not intended to apply when a child is returned by the sending state to a natural parent residing in another state."
• Arkansas Dep't of Human Servs. v. Huff, 347 Ark. 553 (2002); In re Emoni W., 305 Conn. 723 (2012); In re Alexis O., 157 N.H. 781 (2008) — the majority rule.
• Matter of D.L. v. S.B., 39 N.Y.3d 81 (2022) — New York's highest court adopts the majority rule. The facts are the indictment: a child removed in 2012, an ICPC request to North Carolina to approve the father's home, North Carolina's denial, and years lost before the father regained his child. Amici (Lawyers for Children; the National Association of Counsel for Children) argued applying the ICPC to an out-of-state parent "harms children" by keeping them in foster care apart from a fit, loving parent.

A minority of states still apply the ICPC to relative and parent placements — a live jurisdictional split that produces wildly different outcomes depending on which side of a line a child happens to land.

Track 2 — The out-of-state "warehousing" class actions

The closest analogues to "trapped across state lines in an institution" are systemic foster-care class actions alleging states ship children out of state into for-profit congregate facilities:

• Jonathan R. v. Morrisey (S.D. W. Va.; revived by the Fourth Circuit, 41 F.4th 316 (2022), and again in 2026) — alleges West Virginia "relies indiscriminately on out-of-state institutional care." Active. (Litigated by A Better Childhood.)
• Wyatt B. v. Kotek (D. Or.) — alleged Oregon "ships them out of state where they are placed in costly for-profit congregate programs." Settled May 24, 2024.
• M.D. ex rel. Stukenberg v. Abbott, 907 F.3d 237 (5th Cir. 2018) — Texas; substantive-due-process violations from congregate overuse and placement instability.
• B.K. v. Snyder (AZ, settled 2021) — children sleeping in DCS offices; a named child held in a group home for two years.
• D.G. v. Henry (OK "Pinnacle Plan," settled 2012, closed 2025); Kenny A. v. Perdue (GA); Marisol A. v. Giuliani (NYC).

Track 3 — The constitutional architecture

The doctrine that powers these cases:

• Family integrity / parental rights: Meyer v. Nebraska (1923), Pierce v. Society of Sisters (1925), Stanley v. Illinois (1972), Santosky v. Kramer (1982), Troxel v. Granville (2000). And critically Smith v. OFFER, 431 U.S. 816 (1977), which holds that biological-family ties are constitutionally superior to foster-family ties — the constitutional engine beneath the kinship preference.
• The state's duty to children in its custody: DeShaney v. Winnebago County (1989) created the "special relationship" exception when the state takes custody (its footnote 9 expressly reserved the foster-care question); Youngberg v. Romeo (1982) set the "professional judgment" standard; and K.H. ex rel. Murphy v. Morgan, 914 F.2d 846 (7th Cir. 1990) (Posner, J.) established that once the state places a child in foster care it may not be deliberately indifferent to known harm. These are the constitutional foundation for the section 1983 class actions above.

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PART V — THE DATA BLACKOUT: A HARM THAT ISN'T COUNTED

This may be the most damning finding of the investigation.

The Adoption and Foster Care Analysis and Reporting System (AFCARS) is the federally mandated case-level dataset every state must report to HHS's Children's Bureau, governed by the 2020 AFCARS Final Rule (85 Fed. Reg. 28410). AFCARS does record a child's current placement type — relative foster home, non-relative foster home, group home, institution, and so on. Institutional placements are counted.

But AFCARS has no data element that records:

• whether a placement (especially an institutional one) was caused or prolonged by ICPC / interstate red tape;
• how long a child waited for an interstate home study;
• why a child remained in congregate care instead of moving to an available out-of-state kinship home;
• any link between a child's placement and a pending ICPC request.

HHS's own Report to Congress on Interjurisdictional Adoption concedes the blind spot: while it can report that roughly a quarter of foster-care adoptions were by relatives, "it is not known how many interstate adoptive placements involved relatives." The system cannot break out interstate kinship placements at all — let alone interstate delays.

The consequence: The central harm of this investigation — children languishing in expensive institutions because ICPC delay blocked a cheaper, more appropriate out-of-state family placement — is structurally invisible in the nation's primary child-welfare dataset. NEICE, the electronic ICPC system, generates internal processing-time data, but it is not part of AFCARS and is not publicly reported as outcome data. No federal mechanism measures the problem, which means no federal mechanism is accountable for it. You cannot fix what you refuse to count.

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PART VI — THE "FIX" THAT FIXED THE WRONG THING

NEICE: faster paperwork, same backlog

The headline reform is the National Electronic Interstate Compact Enterprise (NEICE) — a national electronic system to exchange ICPC documents, administered through APHSA/AAICPC. Piloted in 2014 across six jurisdictions (D.C., Florida, Indiana, Nevada, South Carolina, Wisconsin), evaluations reported real gains in document handling:

• Average days from "date of order" to "package sent" fell from 44 to 21.
• A normal process that took 20 days dropped to 11.
• Family-identification/paperwork time fell from 24 business days to 13.

Congress made it mandatory. The Modernizing the Interstate Placement of Children in Foster Care Act (Pub. L. 114-72, 2015) required a centralized electronic system; FFPSA (2018) set a hard deadline — all 52 jurisdictions on an electronic system by FY 2028 (the October 1, 2027 mark). As of July 2024, 47 jurisdictions were fully operational on NEICE, with MOUs from several more.

The catch: NEICE speeds the transmission of documents. It does not speed the substantive home study — the actual bottleneck — and it does not create an enforceable deadline or an appeals process for the ~40% of requests that get denied. It digitized the envelope, not the queue. Per-state cost to join runs ~$32,000 plus ~$25,000/year licensing — real money spent making the wrong step faster.

The Revised ICPC: stuck below the threshold

The wholesale rewrite the administrators called for in 2004 — the Revised ICPC, which adds enforcement, dispute resolution, data collection, and due-process mechanisms — takes effect only after 35 states enact it. As of the latest reporting, only about 20 states have. Twenty-two years after the resolution, the modernized compact remains 15 states short of taking force.

What advocates are doing in the meantime

• Casey Family Programs' border agreements: A 2015 pilot between Columbus, GA and Phenix City, AL let counties place kin across the line voluntarily and fast; over two years roughly 200 children were placed quickly with relatives instead of strangers. Casey advocates scaling these nationally.
• The Kinship Unity Action Agenda (Generations United + ABA Center on Children and the Law + Think of Us; released Feb. 8, 2024) — nine policy priorities for equitable kinship support.
• Federal kin-specific foster-home licensing standards (final rule) easing the licensing burden on relatives — tracked by Generations United's Grandfamilies network.

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PART VII — THE HUMAN COST

Statistics are how a system hides its victims. Here are a few it cannot quite hide.

The 18-month grandmother. A paternal grandmother in New York — herself a licensed foster parent and a foster-care caseworker, who had cared for her grandson in his first months of life — waited 18 months for New York to complete an ICPC home study while the boy sat in Michigan foster care. She traveled to Michigan, attended court, begged to take him instead of strangers. By the time New York approved her, professionals argued the child should stay in Michigan because he had now bonded to his foster parents. The delay itself was used as the reason to deny her. This is the system's cruelest mechanic: it manufactures the very bond it then cites to keep families apart.

Delay measured in childhoods. Children needing out-of-state placement spend a median of ~43 months in care — about two years longer than in-state peers. Every one of those months is a month not spent with vetted family.

Aging out into the void. About 25,000 youth age out of foster care each year (in 2025, ~15,000 exits were by emancipation). The outcomes are catastrophic: roughly 22–30% experience homelessness, only about half are employed by 24, 8–12% earn a college degree (vs. 49% nationally), and former foster youth show PTSD at roughly twice the rate of U.S. combat veterans. ICPC delay burns the very months in which a permanent kin placement might have changed that trajectory.

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KEY FINDINGS

1. The bottleneck is the substantive home study, not the mail. NEICE digitized document transfer but left the actual review backlog — and the ~40% denial rate — untouched. The "fix" addressed the wrong step.
2. There is no enforceable timeline. Federal law (2006 Act / 671(a)(26)) sets a 60-day target with a cash incentive but no penalty; AAICPC Regulation 7's expedited deadlines for relatives are routinely missed with no consequence; the outer limit stretches to 180 days.
3. Two federal laws are in direct conflict with the compact's effect. The Fostering Connections kinship preference (671(a)(19)) and Family First's anti-congregate-care mandate both say "family, fast." ICPC delay produces "institution, slow."
4. The incentives are backwards. Kinship care is the cheapest placement; institutional care costs 7–10x more (up to $290,000+/yr). Delay parks children in the most expensive, least appropriate setting — funded by open-ended Title IV-E dollars.
5. The harm is uncounted by design. AFCARS records that a child is in an institution but not that ICPC delay put or kept them there. No federal data element measures interstate home-study wait times or their downstream institutional consequences.
6. Denials are unreviewable. ~40% of requests are denied; the compact historically prohibited judicial review of denials and provides no national appeals process — a direct due-process problem.
7. The modernized compact is stalled. The Revised ICPC needs 35 states; ~20 have enacted it, 22 years after administrators called for the rewrite.

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ACTIONABLE RECOMMENDATIONS

For Congress / HHS-ACF: - Add ICPC data elements to AFCARS: date of interstate home-study request, date of completion/denial, denial reason, and a flag linking institutional placements to a pending interstate request. End the data blackout. - Convert the 60-day target into an enforceable standard with consequences — e.g., conditioning a portion of Title IV-E administrative reimbursement on documented compliance, and a federal cause of action or administrative appeal for unreasonable delay. - Fund the substantive home study, not just the software — staffing and reciprocity, so a receiving state can accept a sending state's completed study.

For states: - Adopt the Revised ICPC (reach the 35-state threshold) and expand border agreements for adjacent-state kin placements. - Codify the majority rule (McComb, D.L. v. S.B.) that the ICPC does not apply to fit out-of-state parents.

For PMC / advocacy / journalism: - FOIA targets: NEICE processing-time data by state; AAICPC denial logs; state ICPC unit staffing and caseloads. These exist internally and are not publicly reported. - Litigation watch: track Jonathan R. v. Morrisey (WV) as the live test of out-of-state institutional warehousing. - Story engine: the "18-month grandmother" mechanic — delay manufacturing the bond later used to deny kin — is the human throughline for public education.

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SOURCES

Statutes & federal framework - 42 U.S.C. 671 — https://www.law.cornell.edu/uscode/text/42/671 - Fostering Connections Act (H.R. 6893 / Pub. L. 110-351) — https://www.congress.gov/bill/110th-congress/house-bill/6893/text/pl - Safe & Timely Interstate Placement Act (Pub. L. 109-239) — https://www.congress.gov/109/plaws/publ239/PLAW-109publ239.pdf - FFPSA primer (CRS) — https://www.congress.gov/crs-product/IN10858 - Modernizing Interstate Placement Act (H.R. 4472 / Pub. L. 114-72) — https://www.congress.gov/bill/114th-congress/house-bill/4472/text - CRS RL32070 (ICPC background) — https://www.everycrsreport.com/reports/RL32070.html

ICPC structure, Regulation 7, NEICE - APHSA — History of the ICPC — https://aphsa.org/wp-content/uploads/2024/09/HISTORY-OF-THE-ICPC-1.pdf - APHSA — AAICPC — https://aphsa.org/aaicpc/ - APHSA — NEICE — https://aphsa.org/neice/ - APHSA — Revised ICPC — https://aphsa.org/revised-icpc/ - NY OCFS — ICPC Regulation 7 (full text) — https://ocfs.ny.gov/programs/adoption/ICPC/regulations/regs-07.php - Child Trends — NEICE Evaluation Final Report — https://www.childtrends.org/publications/national-electronic-interstate-compact-enterprise-neice-evaluation-final-report - NEICE Support Desk — home-study decision deadlines — https://support.neice.us/support/solutions/articles/6000248129-icpc-home-study-evaluations-and-decision-deadlines

Delay data, analysis & commentary - ABA — "Foster Kids in Limbo" — https://www.americanbar.org/groups/public_interest/child_law/resources/child_law_practiceonline/child_law_practice/vol-33/june-2014/foster-kids-in-limbo--the-effects-of-the-interstate-compact-on-c/ - Sankaran (Univ. of Michigan Law) — Judicial Oversight Over Interstate Placement — https://repository.law.umich.edu/cgi/viewcontent.cgi?article=1438&context=articles - The Imprint — "Can We Please Fix Interstate Placement?" — https://imprintnews.org/child-welfare-2/can-please-fix-interstate-placement-children-foster-care/32395 - Nzekwu, "The Lost Ones of the ICPC," 44 Hofstra L. Rev. 1001 (2016) — https://www.hofstralawreview.org/wp-content/uploads/2016/05/DD.3.Nzekwu.pdf - AECF ICPC report (Sankaran) — https://nebraskajudicial.gov/sites/default/files/files/36/icpc_annie_e_casey_report.pdf

Family First / congregate care - The Imprint — federal funding restrictions haven't reduced group-home reliance — https://imprintnews.org/top-stories/federal-funding-restrictions-have-not-reduced-group-home-reliance-in-many-states/271864 - Child Welfare Monitor (Mar. 2026) — https://childwelfaremonitor.org/2026/03/24/surprise-surprise-family-first-has-not-reduced-the-use-of-congregate-care/ - Annie E. Casey — Every Kid Needs a Family — https://www.aecf.org/resources/every-kid-needs-a-family

Cost figures - Every Texan — kinship care saves millions — https://everytexan.org/2025/02/26/kinship-care-in-texas-benefits-children-and-saves-the-state-millions/ - Father's Advocacy Network — real cost of foster care — https://www.fathersadvocacynetwork.com/blog/real-cost-of-foster-care-per-child

Litigation - McComb v. Wambaugh, 934 F.2d 474 — https://law.resource.org/pub/us/case/reporter/F2/934/934.F2d.474.90-1831.html - Matter of D.L. v. S.B. (N.Y. 2022) — https://www.nycourts.gov/reporter/3dseries/2022/2022_05940.htm - Jonathan R. (A Better Childhood, WV) — https://www.abetterchildhood.org/west-virginia - Wyatt B. v. Kotek (Disability Rights Oregon) — https://www.droregon.org/litigation-resources/wyatt-b-v-kotek - M.D. v. Abbott (Children's Rights, TX) — https://www.childrensrights.org/in-the-courts/tx-m-d-v-abbott - Smith v. OFFER, 431 U.S. 816 — https://supreme.justia.com/cases/federal/us/431/816/ - DeShaney v. Winnebago County (incl. footnote 9) — https://www.law.cornell.edu/supremecourt/text/489/189

AFCARS / data gap - ACF — AFCARS — https://acf.gov/cb/data-research/adoption-fostercare - AFCARS 2020 Final Rule — https://www.federalregister.gov/documents/2020/05/12/2020-09817/adoption-and-foster-care-analysis-and-reporting-system - ACF — Report to Congress on Interjurisdictional Adoption — https://acf.gov/sites/default/files/documents/cb/ij_adopt.pdf

Reform & human cost - Casey Family Programs — border agreements — https://www.casey.org/border-agreements/ - Generations United — Kinship Unity Action Agenda — https://www.gu.org/resources/kinship-unity-action-agenda/ - National Council for Adoption — cost of aging out — https://adoptioncouncil.org/publications/the-human-social-and-economic-cost-of-aging-out-of-foster-care/

PMC proprietary data - CivicOps — TAGGS foster-care federal awards (TX $3.59B / WV $1.02B); state child-welfare statistics (WV, NV, 2012–2023).

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Investigation conducted by OPUS for Project Milk Carton — child welfare transparency and missing children awareness. Figures drawn from secondary summaries (e.g., the ~43-month median, the 30%/45%/40% home-study rates, the ~40,000 annual requests) recur across multiple sources and should be confirmed against primary Sankaran/Michigan Law and AECF PDFs before standalone publication of any single number.

— END OF REPORT —