DEE WILSON CONSULTING

(Originally published August 2026)

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The U.S. Office of the Inspector General recently released a report, “National Overview of State-Level Challenges to Minimize or Eliminate Temporary Emergency Placements in Foster Care.” This report discusses a survey of state child welfare systems’ utilization of emergency placements in unlicensed facilities such as state and county offices, hotels, jails and detention centers and various other sheltering arrangements between January 1, 2022 and June 30, 2023.  Thirty-four out of 42 states that acknowledged placing children and youth in unlicensed facilities provided information regarding emergency stays, but only 30 states included information about the number of children and youth placed in such facilities.  Seven states reported that they made no use of unlicensed facilities during the 18-month time frame of the survey; one state did not reply to the survey.     

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The survey found that 30 states placed 9,045 children and youth in unlicensed facilities or other sheltering arrangements, including cabins in state parks and  (occasionally) caseworkers’ cars. According to the survey, some of these facilities lacked showers or kitchens, and were distant from schools or therapeutic services, leading to school absences and/or lack of adequate medical or mental health services.  Unlicensed emergency placements presented difficult supervisory challenges (including medication management in Washington), and increased concerns regarding the safety of  staff who supervised the placements, some of whom were assaulted by youth, as well as the safety of youth at risk for self-harm.  According to a story  in The Imprint, “two dozen states reported incidents in which children harmed themselves or others while in temporary emergency placements.”    

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The survey found large differences among states regarding the extent to which children and youth were placed in unlicensed facilities. Sixty percent of placements in unlicensed facilities occurred in two states, Arizona and Texas, while more than eighty percent of children and youth were placed in a dozen states, including Washington.  

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The survey found that thirty-four states utilized 15,705 emergency “stays” of  one or more days, with 14% of stays lasting 5-10 days and 14% lasting longer than ten days. It is questionable to describe a stay in a hotel or office of longer than ten days as an emergency placement. These are alternative placements for youth, usually behaviorally troubled adolescents, for whom there was neither an available foster home nor residential care placement. According to the 2023 Washington State Family and Children’s Ombuds (OFCO) annual report, there were 64 youths with placement exceptions placed in an unlicensed facility for 20 or more days during the state fiscal year (SFY). By 2025, the number of youths placed in unlicensed facilities in Washington for 20 days or longer was reduced to 16, the 2025 OFCO report indicates.

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More than eighty percent of emergency stays occurred in about a third of states that responded to the survey, about half in Arizona and Texas. Washington State’s Department of Children, Youth and Family Services (DCYF) reported 612 emergency stays for the 18-month period under review.

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In explaining the reasons for unlicensed emergency placements, most state child welfare systems stated that a lack of homes for older youth with complex behavior problems was the most common reason for these placements. However, about 15% of children who spent one or more days in an unlicensed facility were five or younger, suggesting that a shortage of foster homes for all ages of children contributed to the need for emergency placements in some states. In Washington, during 2022 and 2023 it was common for young children to experience night-to-night ( i.e., one day) placements in licensed foster homes, a category of unacceptable placements ignored by the federal survey. Night-to-night placements of children also sharply declined in  2025 compared to 2022-23 , according to the 2025 OFCO report. 

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The national survey summarizes states’ responses to the question of what their child welfare agencies are doing to reduce or eliminate emergency unlicensed placements. Common responses included foster care recruitment campaigns combined with bonuses or enhanced foster care reimbursement for taking older and/or difficult to place youth, an increased emphasis on kinship care, and developing improved transitional facilities and emergency shelters (even if unlicensed) which has occurred in Washington.  There was no mention of new investment in adding to and improving residential care or of creating a cadre of professional foster parents, two of the most likely solutions    

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The debate over residential care

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In April 2023, the American Enterprise Institute (AEI) published an article, “Why Foster Children Are Sleeping in Offices and What We Can Do About It” signed by seventeen scholars, advocates and child welfare administrators. The article asserted that the increase in hotel and office placements of  children and youth needing a foster home or residential care was due to states’ disinvestment in residential care resulting from “ideological shifts that have driven new legislative and regulatory requirements and new restrictions on funding and administrative decision making.” In particular, Family First, federal legislation enacted in 2018, created onerous new legal requirements for placement of youth in residential care facilities.

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However, years before the passage of Family First, many state child welfare systems (including Washington’s) had made persistent efforts to reduce the number of children in residential care,  due both to the cost of these placements and well-founded concerns regarding the safety of youth placed in these facilities. For more than thirty years, there have been numerous tort actions in Washington alleging physical and sexual abuse of youth in residential care programs, and the state of Washington continues to this day to settle these lawsuits based on alleged abuse in residential care facilities that occurred decades ago.    

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Following the Great Recession of 2008-09, the Washington State legislature  consistently refused to adequately fund Behavioral Rehabilitation Services (BRS) programs, including residential care facilities, thereby forcing some providers to close their facilities. Washington State’s decision to reduce the number of children in BRS placements and eliminate entire programs operated by child placing agencies reflected the widespread resistance of child welfare leaders, advocates and some scholars to any new investment in residential care, and lack of interest in developing initiatives to improve residential care programs. Furthermore, reductions in residential care in some states (such as Washington) were not initially accompanied by development of alternative approaches to caring for behaviorally troubled youth, in part because child welfare managers and influential advocates believed that commitment to kinship care would suffice.

According to the signatories of the AEI article, “The result is that states and counties are rapidly losing residential care and congregate care capacity while struggling to recruit enough foster homes capable of serving high needs foster children,” an accurate assessment in my view.   

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The placement of thousands of children and youth in emergency unlicensed placements, including hotel placements that cost $2000- $3000 a day in Washington, was a direct result of public policy informed by an understandable determination to greatly reduce residential care placements, but without developing viable alternatives, often accompanied by wishful thinking regarding the potential of kinship care to meet all foster children’s needs.

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Washington State’s DCYF was a leader in undermining residential care and one of the first states to experience a large increase in hotel placements, even after eliminating office placements and instances of youth sleeping in caseworkers’ cars. For this reason, it is of great interest how, since 2022-23, DCYF has achieved a dramatic reduction in hotel placements and other “placement exceptions,” i.e., emergency unlicensed placements.

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The reduction in placement exceptions in Washington State      

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The 2022, 2023 and 2025 Washington State OFCO annual reports describe a large decline in placement exceptions, i.e., days of unlicensed emergency placements and licensed night- to-night placements since 2022-23:​​

 

 

 

 

 

 

 

 

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The number of placement exceptions in SFY 2025 was less than one-fourth the number in SFY’s 2022 and 2023. Hotel placements declined from 2229 in 2022 and 1791 in 2023 to 109 in 2025, due to the increased use of DCYF staffed facilities and the 50% decline in entries-into-care of youth, 10-17 between 2019 and 2024.  Older youth, 15-17, constituted about half of placement exceptions during 2025. In addition, DCYF has become increasingly resistant to placing children in foster care due to behavior problems only, which has been a point of friction with other state agencies,  hospital emergency departments and psychiatric facilities. DCYF has made a determined effort to reduce the number of behaviorally troubled children and youth for which it is responsible, in part by refusing to remain the agency of last resort for mentally ill, delinquent and physically disabled youth.     

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The 2025 OFCO report emphasizes the impact on placement exceptions of Washington’s reduced foster care population, half or less of the number of children in foster care in 2019. The report also quotes the D.S. Settlement Agreement monitoring report: “The drop in the number of placement exceptions is the result of careful placement decisions and not the result of “a new and more robust placement portfolio.”   

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Other noteworthy information in the 2025 OFCO report includes:

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• During 2023, almost two-thirds of placement exceptions occurred in Region 6 (southwest Washington from Vancouver to Pt. Angles and Forks); in 2025 only 7%  of placement exceptions occurred in this region, while more than 41% occurred in Region 5 (Pierce County). Almost 80% of placement exceptions were in regions 4, 5 and 6 on the west side of the state.  

• Children and youth in placement exceptions during SFY 2025 were disproportionally American Indian/Alaskan Native (AI/AN -16.7%) and Black  (25.9%). The extent of racial disproportionality in placement exceptions is much higher than for the state’s foster care system as a whole, in part a reflection of the demographics of regions in Western Washington, and also reflective of longer lengths of stay in foster care and inadequate behavioral health services for AI/AN and Black children and youth.

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DCYF leased facilities

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Given the importance of DCYF leased facilities in reducing the number of hotel placements, it is surprising how little has been disclosed in reports regarding how these facilities operate. The following information is based on conversations with DCYF staff who have worked in or with leased facilities.   

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During 2024, there were three facilities, one in Region 4 (King County) and two in Region 6. Due to the large reduction in youths, 13-17, needing emergency placements, two of the facilities have closed, leaving one three-bed facility in Clark County.  In past years, the facilities operated with a two-bed limit.  The facility in Clark County has 22 staff that includes a manager, caseworkers, case aides and security guards.  Each shift has a minimum of five staff.

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The Clark County facility accepts adjudicated sex offenders, assaultive youth and mentally ill youth with psychoses. During their four years of operation, the leased facilities have terminated the placement of only a handful of youth who posed an extreme threat to staff or other youths, despite frequent assaults of staff. Staff, per policy, only use restraint to prevent youth from harming themselves. Staff are trained in de-escalation skills and also can call on other community resources in a crisis.

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The facilities are committed to trauma informed practices that emphasize the importance of human connection and development of supportive relationships with troubled youth. Staff on duty are expected to persistently  reach out to youth to form a connection and to prevent social isolation. The facilities do much more than house troubled youth and manage their medications.            

Most youth remain in the facility for a few weeks, though some who leave subsequently return due to a failed placement. Some youth age out into a supportive housing program.

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Leased facilities meet agency standards for residential care but remain unlicensed due, in part, to the legal question of whether DCYF can license a facility it operates. The facilities receive intense scrutiny from multiple directions. I was unable to determine the cost of operating a three-bed facility with 22 staff, though the Clark County facility cares for youths who would otherwise be placed in hotels at a cost of $60,000 - $90,000 per month.   

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Leased facilities are positively regarded by DCYF managers of my acquiantance who have had extensive contact with these programs.  This appears to be a remarkable DCYF success story that demonstrates what’s possible with inspired leadership and the willingness to commit necessary resources to resolve a difficult challenge. However, there has yet to be a published evaluation of leased facilities by an independent agency. Annual OFCO reports are neutral in describing these facilities.   

 

Lessons from Washington State

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Since SFY 2022, Washington State’s DCYF has greatly reduced the number of days/nights foster youth spend in hotel placements (2,229 vs 109 in 2025) and reduced the number of youths with placement exceptions of 20 days or more from 64 in SFY 2023 to 16 in SFY 2025. These large reductions have been achieved through the utilization of small, well-staffed residential programs (described as leased facilities) operated by DCYF and with staff who have the same job classifications and salaries as caseworkers and case aides who have other jobs in the agency.

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These small residential programs utilize trauma informed care principles with a challenging group of behaviorally troubled youth,13-17, and appear to have excellent leadership. The number of these programs has been reduced from three to one in Washington since 2024. I have been informed that DCYF plans to discontinue operation of leased facilities in the near future through the development of an additional three-bed licensed group care facility.  

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The 50% reduction in foster care since 2019, especially the reduction of entries-into-care of older school age children, has contributed to a reduced need to place children and youth in unlicensed facilities such as hotels and in many fewer licensed night–to-night placements of children of all ages.

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Some DCYF regions have made effective use of daily or weekly complex youth staffing’s which enable regions to effectively coordinate services with other state and community agencies and make the best use of available resources. In addition, DCYF offices have reportedly become proactive in preventing placement disruptions through supportive services for foster parents caring for youth with complex behavior problems.   

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DCYF has been slow to develop new placement resources for youth with challenging behaviors, per the D.S. Settlement Agreement.  It has been difficult for public child welfare managers proud of large reductions in their foster care population to accept the need to reinvest in residential care and make new investments in therapeutic and professional foster care. Child welfare managers may fear that more and better foster care resources will likely lead to a larger foster care population of older, behaviorally troubled youth who place tremendous stress on public agency staff and state resources.

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Nationally, it is uncertain whether other state child welfare agencies have achieved the large reduction in unlicensed placements that has occurred in Washington since 2022-23.      

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References  

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Annual Reports, 2022, 2023, 2025, Office of the Washington State Family and Children’s Ombuds Report, Tukwila, Washington.

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Fitzgerald, M., “ Dehumanizing Placements in Hotels and Offices: First-Ever National Survey Finds Thousands of Foster Youth Are Sent to Substandard Emergency Placements,” (August 5, 2026), The Imprint, Los Angeles, California.

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Hughes, S., Riley, N., Cohen, M., et al, “Why Foster Children Are Sleeping in Offices and What We Can Do About It,” (2023), American Enterprise Institute, Washington, D.C.      

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“National Overview of State- Level Challenges to Minimize or Eliminate Temporary Emergency Placements in Foster Care,” (2026), Office of the Inspector General, U.S. Department of Health and Human Services, Washington, D.C.

 

​See past Sounding Board commentaries     

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©Dee Wilson     

  

deewilson13@aol.com

    

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