In the wake of recent child abuse fatalities, I’ve been asked “How do we fix ACS?” ACS is the Administration for Children’s Services, New York City’s child protective service system. We should be asking a different question – and having a different conversation. To start, we should address how to prevent child abuse fatalities. In that context, we can look at ACS’ role in keeping children safe.

Children are dying in record numbers from child abuse; a federal report shows that the rates are climbing. In 2015, the number of estimated child abuse fatalities nationwide—1,670—was the highest in five years. Put another way, every five and a half hours, an infant or toddler dies from child abuse at the hands of their parent or caretaker. This sounds like a horror-movie script. In New York State, there were 86 substantiated child-abuse fatalities in 2015, which allows us to infer an estimate of 35 fatalities in New York City alone.

The public tends to hold ACS accountable when child fatalities occur in the city. It’s important to realize that the parents of children who are abused are struggling themselves. Risk factors include mental illness, unemployment, domestic violence, substance abuse, prior history of their own abuse and poverty. This doesn’t in any way excuse harming children, but it does clarify why no single government agency can address all of these issues.

The response of our child-welfare system needs to be flipped around. We invest billions each year funding systems that investigate, remove and foster children AFTER the damage has been inflicted. Why do we wait until families are drowning to get involved? We should invest the resources in PREVENTING child abuse.

I have great admiration for Healthy Families New York (HFNY). It is an example of an evidence-based, home visitation, child abuse prevention program that works. They identify pregnant mothers at high-risk, offer services to bolster parenting skills, pair the mother with a medical center for care, and they follow these families until the children are enrolled in school. Research shows that the (too few) families that have access to HFNY have reduced rates of abuse and neglect and healthier babies.

There are 39 HFNY programs in New York State. They receive about $24 million in funding from NYS Office of Children and Family Services (OCFS) and serve 5,600 families. Because of lack of funding, it’s estimated that HFNY, is only available to about 10 to 14 percent of families that otherwise would be eligible. By comparison, OCFS funds ACS with nearly $900 million.

There is a bill in the NYS Senate to establish a temporary state commission to study child abuse prevention programs, like HFNY, and determine needed funding. But it seems to get stalled each year. What are we waiting for? Children are dying, every five and a half hours.

Now, how to “fix” the bureaucracy that is ACS. We need child protective services. They fulfill a critical role in protecting children. And, unfortunately, there are many families where abuse or neglect will occur, regardless of services offered. In 2014, in NYC, there were 89,000 reports made alleging maltreatment. ACS conducted over 55,000 investigations involving approximately 84,700 children. The indication rate, which reports substantiated cases of abuse, was about 39 percent, representing approximately 32,000 children.

To respond to these cases, ACS workers have non-stop demands. The investigations are complicated, time-sensitive, anxiety-provoking and at times, downright dangerous. The perils of their job rarely make the news. Thankfully, most hang in there.

ACS is not perfect. Although most cases do have good outcomes, serious mistakes have been made on investigations. Mikey Guzman, Zamair Coombs, Jaden Jordan, Zymere Perkins are children who should be alive today. ACS is under fire for its handling of these cases. Training, supportive supervision, adequate staffing, and lower caseloads will lead to better outcomes. A new Commissioner has been appointed. A fresh eye to look at the challenges facing a huge bureaucracy and the recommendations forthcoming from the Kroll report, should help guide needed changes. The clock is ticking; there is no time to waste.

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Mary L. Pulido, Ph.D., is the executive director of The New York Society for the Prevention of Cruelty to Children