An Open Letter to COA
Richard Klarberg, President/CEO
Council on Accreditation
45 Broadway, 29th Floor
New York, NY 10006
February 22, 2013
Dear Mr. Klarberg:
I write to you today, as a member of the adoption community, to express my concern and dismay about the value of the accreditation process in international adoption.
Your organization, the Council on Accreditation, was named in 2006 by the US State Department as the only national accreditor for Hague Convention Accreditation and Approval. About 220 adoption service providers (ASPs) have achieved Hague Accreditation or Approval since 2008.
That number includes Christian World Adoption, listed on your website as accredited through January 31, 2017: except CWA went bankrupt and out of business as of February 8, 2013.
How can this be, that a COA-accredited ASP suddenly closes? Are there more to follow?
According to your website (www.COAnet.org), The Hague Accreditation and Approval Standards are requirements established by the State Department for intercountry adoption providers involved in Hague Convention adoptions, are related to management and service delivery, and promote accountability including financial and risk management, ethical practices and responsibilities, service planning, and delivery, and more.
Accreditation by COA is designed, as best I can tell, to offer families and others (including adoption entities in other countries) confidence in the services provided by an accredited entity, and to reinforce integrity, transparency, and excellence.
In the case of Hague accreditation, ASPs have quite a process: Assign at least one staff person (often more than one) to review and implement standards and gather evidence of compliance. Conduct training for team members to assess current practice. Assign timeframes for “self-assessments” and review “preliminary ratings” for each. Develop corrective action plans for “non-compliant” standards. Re-evaluate. Assemble evidence: narratives, documents, and forms. Hold “mock site visits.”
And then the Initial Assessment can begin.
There is a hefty list of Evidence that must be provided, including (but not limited to) licenses and other legal documents; contracts and/or written agreements; financial records; policies; procedures; meeting minutes; and quality improvement reports.
And then there is a Site Visit. A minimum of two Evaluators visits the program sites to assess compliance with Hague Standards. There is a document review, usually on a Sunday, to allow more time for meetings with stakeholders and staff members. There are interviews with clients and/or personnel.
Then there is a Pre-Commission Review report, and time for reflection and review of reports for consistency, accuracy, and compliance with Hague standards. At some point, after a lengthy (and I imagine expensive) process, a decision is made about Approval and Accreditation.
Mr. Klarberg, I’ve watched the State Department video (uploaded November 23, 2012) that features you, Ambassador Susan Jacobs (Special Advisor for Children’s Issues), and Christine James-Brown of the Child Welfare League of America. It’s all about best practice with respect to the needs of vulnerable children and families. It’s all about assuring families here and around the globe that accredited Adoption Service Providers have met a high bar and can be trusted.
How is it CWA was/is accredited, and then suddenly shut its doors, declaring bankruptcy?
According to CWA’s website, “international adoption to the USA has declined by 62% since its peak in 2004, and that downward trend is expected to continue. Why is that?
Today international adoption—adoption agencies in general and CWA in particular—face a “perfect storm” of circumstances that has made it difficult and in some cases impossible to continue. Many adoption agencies have closed their doors in recent years. Russia’s recent ban on adoptions to Americans, the U.S. State Department’s decision not to open adoptions from Cambodia, vastly longer adoption wait times in China, and longer adoption times and fewer referrals in Ethiopia have all had an adverse effect on CWA. UNICEF has waged an unrelenting campaign against international adoption for many years. Ongoing mandatory child care costs in Ethiopia despite slower adoptions has been a major drain on our finances. Children living in our partner orphanages have to be cared for, fed and kept healthy every day, even when adoption cases are not moving and the fees we collect do not entirely cover the cost of their care. Costs have been increasing all across the board, including the cost of accreditation and licensing to remain in compliance with U.S. and foreign legal requirements, as well as the number of staff hours devoted to that compliance.
How did COA not note all this, in designating CWA as a Hague Accredited organization?
Further, CWA has been under a shadow for a while, cited in an Australian expose for alleged trafficking, subject to lawsuits, and more.
The reasons that CWA cites for its closing are reasons that other ASPs are closing their doors, some more quietly than others. Some are merging; some are opening under new names.
My fear is that none of this means that vulnerable children and families are being protected, whether here in the US or anywhere else in the world.
I would welcome your thoughts on these matters. Thank you very much.
Maureen McCauley Evans
Maureen McCauley Evans has been involved with adoption for 20+ years, personally and professionally. She was the executive director of the Joint Council on International Children’s Services from 1995-2000. She participated in discussions and meetings around the implementation of the Hague Convention on Intercountry Adoption during that time, including those concerning accreditation providers. She has not been officially affiliated with any adoption organization since 2006. She is an adoptive parent and an advocate of excellence in child welfare services. She is hopeful that the views of adult adopted persons and first families will be a strong part of any policy discussions about adoption.