As Alicia and LaReine Nixon spoke of the events that led to the death of 6-year-old Khalil Wimes, allegedly at the hands of his parents, the anger and pain was clearly evident in their voices and etched into their faces.
No, that’s not an adequate description of what they’re living with. A better description would be to call it rage, a smoldering rage not just for Tina Cuffie and Floyd Wimes, the parents who allegedly beat and starved their child to death, but rage towards the Department of Human Services and the courts – the system that was supposed to protect Khalil but that, in their opinion, failed.
Now they want answers.
Alicia Nixon was Khalil’s foster mother, in effect the only woman he knew as his mother, who cared for and loved the little boy for the first three years of his life from the time he was born. LaReine Nixon is Alicia Nixon’s mother, an artist, whom Khalil knew as “Mimi” his grandmother. Both of them expressed their concern over allegations that the DHS worker assigned to Khalil’s case failed to report and act upon clearly visible signs of physical abuse.
At the preliminary hearing for Wimes and Cuffie, Assistant Medical Examiner Aaron Rosen stated that Khalil, who was pronounced dead on March 19, had 15 visible scars on his face.
“During the preliminary hearing the medical examine took over an hour to describe the scars and bruises that covered Khalil’s body,” Alicia Nixon said, on the verge of tears. “How could someone, especially a trained social worker, see signs of that kind of abuse and do nothing? I can’t get my mind around that. It came out in court that he was sleeping on a filthy mattress and they locked his bedroom. I want everyone who laid eyes on him and did nothing to pay for this. I want the people who are in charge of them to pay.”
According to investigators, during the last eight weeks of his life, while the child was still under DHS supervision, Khalil slept on a soiled mattress on the floor of an empty bedroom.
The worker, who has since been placed on desk duty pending the investigation, allegedly visited the apartment and saw Khalil just two weeks before his death. Investigators said Cuffie allegedly physically punished Khalil everyday. Sometimes she used a belt, other times she allegedly made him stand in a corner and threw books or shoes at him.
“I can’t get out of my mind that Khalil suffered for a thousand days in one form or another,” Larine Nixon said. “Based on the decisions that the judges made to allow his parents to have Khalil – knowing their history of neglect and abuse with their other children, their history of drug abuse, there’s no rhyme or reason. Judges have a lot of discretion in these cases and we pleaded with them not to allow the parents to have custody. We did everything legally possible and they still did it and look what happened.”
Cuffie, 44, and her husband, Wimes, 48, are being held on charges of first-degree murder, aggravated assault, conspiracy to commit murder, endangering the welfare of a child and related offenses.
According to investigators, the defendants drove Khalil to Children’s Hospital because he was ill. Hospital attendants immediately saw the boy’s physical condition and called police. He weighed 25 pounds when he died from blunt force trauma and malnutrition.
“I can’t get out of my mind that Khalil was with people who hurt him and all the while he knew that somewhere out there were people who loved him,” Larine Nixon said. “From the time he was born we raised him and loved him. The courts gave him back to his parents and they killed him.”
Because of confidentiality laws and the ongoing investigation, DHS officials are unable to comment on Khalil’s case.
However, the independent Child Welfare Review panel has already reviewed the case and the agency is awaiting its recommendations.
“Whenever there’s an open case of a child dying under DHS care we immediately pull all of the records associated with the case,” said DHS spokesperson Alicia Taylor. “All of the records are reviewed from the case worker to the supervisor.”
During her testimony before the Task Force on Child Protection Hearing held at the University of Pennsylvania on April 18, DHS Commissioner Anne Marie Ambrose voiced her concerns regarding clarity in the Child Protective Services Law and that it is difficult to determine whether all of the reforms implemented by DHS over the last four years have made a difference.
“Are children really safer? The lack of data on GPS (general protective services) cases and the inability to compare us to other jurisdictions makes this most important question difficult to answer,” Ambrose said. “Another area of concern involves Act 33 and its requirement for review of all fatalities and near fatalities caused as a result of child abuse. DHS has embraced the new requirement regarding fatalities and near fatalities and I am proud to report that the DHS Act 33 Child Fatality/Near Fatality Review Team has served as a state model for effective interdisciplinary and interagency coordination in examining child fatalities and near fatalities and for identifying and monitoring the implementation of recommendations to improve child safety.”
LaReine Nixon said her family has been devastated by Khalil’s killing and they are awaiting the parent’s trial.
“It was his biological father and mother who murdered him,” Nixon said. “Khalil didn’t know anything about the term foster parents. To him, Alicia was his mother; he really didn’t know his biological parents. I was his ‘Mimi,’ my family were his uncles and aunts and cousins. We were not just outsiders, we were related to him. Our little boy was tortured and murdered.”
As the Department of Human Services rolls out its new service model — called Improving Outcomes for Children — DHS Commissioner Anne Marie Ambrose is spreading the word about the changes, aimed at streamlining case management and bolstering oversight in situations when children are at risk.
“A private provider is going to be providing real service and DHS is stepping back and taking more of a monitoring, oversight role,” Ambrose said during a Tribune editorial board meeting on Tuesday August 14.
Ambrose wants to be sure that the community is aware of the change in agency’s practices as it embarks on a reform drive that will occupy it for the next four years.
DHS recently awarded contracts to its first two Community Umbrella Agencies: Northeast Treatment Centers (NET) and Asociación Puertorriqueños en Marcha (APM). The two organizations are the first named as DHS moves to change its operations. They will take over case management under the new system. Ultimately, 10 agencies will be given contracts, down from 240 under the old system.
All case management would be handled by those 10 service providers with DHS oversight, monitoring of cases and support in a unified case plan for each child. Each CUA will operate within a specific geographic area of the city.
Ambrose assured the Tribune that should private providers fail in their duties to the city’s children, they face the possibility of losing DHS contracts.
“We won’t have any problem with terminating the contract,” she said.
Hopes are that the change will benefit the children under DHS supervision in two ways.
The first is a new emphasis on community involvement. By giving CUA’s a stronger role in a specific geographic area, Ambrose hoped that communities would be drawn into the effort to help children. Stronger geographic ties are intended to help provide the resources to keep children at home or with family, as much as possible, in the city and their communities.
“This is intended to build a community around children whose parents are struggling,” she said. “If you can’t work it out with parents, then what are the other family or community resources that can be brought to bear?”
Secondly, Ambrose said the new simpler system should be easier for families to navigate.
Under the old system, children under DHS supervision had two case workers, one from DHS and one from a provider agency.
“It really provided lots of opportunities for kids to get lost in the cracks,” Ambrose said. “When everyone’s responsible, no one is responsible. Really tragic things happen as a result of that.”
Under the new model, DHS will streamline case management into a single-case management system. Children will now have one case manager through the CUA, and DHS will provide oversight — including home visits from DHS staff to make sure CUA case workers are providing the necessary care.
Though the changes could save DHS a chunk of its $629 million annual budget, Ambrose said, the agency had not done a cost analysis and expected the shift to be cost neutral. Staffing levels were expected to remain similar under the new plan, though employees would be in new roles.
The reforms are part of a sweeping program of change implemented after the death of Danieal Kelly. The 14-year-old, who suffered from cerebral palsy, died in August 2006 from starvation. Her parents, her DHS and service provider caseworkers and others connected with her death were arrested and prosecuted.
In that case, social workers from the provider agencies and DHS each shifted the blame back and forth.
Her father, Daniel Kelly Sr. 40, was found guilty of endangering the welfare of a child. Dana Poindexter, the DHS caseworker, was found guilty of child endangerment, recklessly endangering another person, and perjury. Her mother, Andrea Kelly, 42, pleaded guilty to third-degree murder in 2009 and is serving a 20-to-40-year prison sentence. Mickal Kamuvaka, head of the service provider agency, was found guilty of involuntary manslaughter, child endangerment, reckless endangerment, perjury and criminal conspiracy.
No one wants to see their child adjudicated to spend time in a juvenile facility. Unfortunately, many families in Philadelphia have children who will commit a crime, will stand before a Family Court judge, and find themselves in detention.
For years, the facility for housing and educating these children was called the Youth Study Center, and its central location was at 20th and Benjamin Franklin Parkway – that is until a new state of the art building was completed this year. The new Philadelphia Juvenile Justice Services Center (PJJSC) officially opened its doors Thursday amid fanfare, protests and mutual congratulations from those who saw the project through. Mayor Michael Nutter was joined by other city officials for a ribbon-cutting ceremony for the secure, short-term residential detention facility for youth ages 13 to 20. The Center offers social and educational programs which aim to steer children accused or found guilty of crimes away from further illegal behavior.
“The new Juvenile Justice Services Center represents years of planning and collaboration,” said Nutter. “The building reflects Philadelphia’s commitment to addressing the needs of our citizens: the security needs of our residents and the social-service needs of at-risk youth as they develop into productive, contributing citizens.”
The new facility is at the corner of 48th Street and Haverford Avenue, and is easily accessible by public transportation or car. The $110 million, city-funded Center has more than 160,000 square feet and beds for more than 150 residents.
“The goal of the Center is to help young people who are involved in the juvenile justice system make better decisions and improve the trajectory of their lives,” said DHS Commissioner Anne Marie Ambrose. “This new facility embodies our belief that given the right support, children have an immense capacity for change.”
The Center is not just a detention facility for keeping young people who have made bad decisions off the streets. It features 10 classrooms, a gymnasium, a health clinic, outdoor recreation spaces and a garden. Visitation space includes a play area where volunteers can baby-sit young children, and rooms where youth can meet with their families, lawyers, social service providers and probation officers. Family Court courtrooms, Judges’ chambers and conference rooms are also on site.
“Philadelphia is working hard to improve outcomes for youth involved with the justice system and the courts,” said Judge Kevin Dougherty. “The design of this new facility allows for enhanced programming to better meet the needs of young people we are serving to maximize opportunities for their transformation.”
But not everyone is pleased with the new state-of-the-art facility, or the money that was spent to construct it. As Nutter and city officials remarked how the staff of the facility are committed to helping young people turn away from criminal behavior, protestors from the surrounding community wanted to know why a detention center for young people was built at a time when the Philadelphia School District found it necessary to close more than thirty schools.
“They’re calling it an education center to make it sound good, but they’re basically locking up children,” said Diane Eizer, one of the protestors. “The number of children being locked up is so absurd that even trying to make the argument that some kids need to be locked up is ridiculous. They’re criminalizing behavior that kids in wealthier communities get a slap on the wrist for - and for which kids in this community go to jail - things like minor drug possession.”
“The point is these are children, babies, who we are supposed to be teaching how to not mess up,” said Sonia Williams, another protestor. “Why treat them as if they have one chance to get it right, and if not, it’s the end? Children need time to learn and grow and the city is not giving them that. Is it cheaper to help these children on the front end, to have preventive measures like more education? Yes, in the long term but the people who are in charge of these facilities don’t care about that; they don’t care if the city is in ruins.”
Judge Dougherty said he agreed with the protestors, but people in law enforcement also must consider public safety.
“Yes, we do need more funding for education, but we also need to keep the communities safe and help children who have been engaged in criminal acts turn their lives around. Our successes outweigh our failures - and those are stories that don’t get told often enough,” he said.
DHS case management gradually shifting to regional agencies
Mayor Michael Nutter and DHS Commissioner Anne Marie Ambrose announced on Wednesday that the agency would be starting the implementation of a major shift in how its cases are handled — a change designed to streamline case management and provide more oversight in situations when children are at risk.
Over the next four years, the Department of Human Services will transition into what is called the Improving Outcomes for Children model. All case management would be handled by ten service provider agencies called Community Umbrella Agencies or CUAs. DHS personnel would take over oversight, monitoring of cases and training. The CUAs will be chosen and contracted by DHS, and each will manage cases within a specific geographic region.
“DHS has seen some tremendous improvements under the leadership of Commissioner Ambrose,” said Mayor Nutter. “But no matter how much we have done, there is still more work to do. ‘Improving Outcomes for Children’ is another opportunity for our administration and DHS to put first the welfare, safety and best interest of Philadelphia’s children.”
The contracting of the Community Umbrella Agencies will take place over a period of four years, at the end of which, all direct case management will be handled by them. Under the old system, DHS-involved children had two case workers, one from DHS and one from a provider agency. Under IOC, DHS will streamline case management into a single-case management system. This allows for children in the DHS system to have a consistent case manager from the provider agency with the experience and knowledge of DHS staff to account for the care and services given to DHS children and families by the provider agencies. The first two CUAs are Northeast Treatment Centers (NET) and Asociación Puertorriqueños en Marcha (APM).
“APM has a long record of serving eastern North Philadelphia, building affordable housing, helping reunify hundreds of families and providing behavioral health and foster care services,” said Ambrose. “It is an agency truly, as its name says, on the march. NET has also performed very well with its school-based programs, parenting classes, and adult drug and alcohol treatment program. Both APM and NET have a documented record of more than 40 years of commitment and involvement in the communities they serve.”
DHS spokesperson Alicia Taylor said the shift to the IOC model clarifies responsibilities.
“There would be several people overseeing a case. DHS would provide direct oversight, support and monitoring. There would be a much clearer clarification of responsibilities,” said Taylor.
“NET is known to many people as a national leader in the field of recovery. But we started as a youth services organization more than 40 years ago,” said Regan Kelly, vice president of Northeast Treatment Centers. “We’ve always maintained a strong connection to supporting youth and families in their own communities. We’ve developed very successful home- and community-based programs for youth and families and support more than 400 families every year. We look forward to partnering with the local community and DHS to make this a nationally recognized child welfare system.”
APM and NET will begin training with former DHS case management workers as early as next week. DHS will still be responsible for the children within its care and will still operate the DHS Hotline, continue to perform intake and will still conduct investigations.
One of the problems the change to IOC is meant to address is that during the Danieal Kelly case, the social workers from the provider agencies and DHS each shifted the blame back and forth. Kelly, a 14-year-old who suffered from cerebral palsy, died in August 2006 from starvation. Her parents, her DHS and service provider caseworkers and others directly connected with her death were arrested and prosecuted.
Last year Kelly’s father, Daniel Kelly Sr., 40, was found guilty of endangering the welfare of a child. Dana Poindexter, the DHS caseworker, was found guilty of child endangerment, recklessly endangering another person and perjury. Her mother, Andrea Kelly, 42, pleaded guilty to third-degree murder in 2009 and is serving a 20-to-40-year prison sentence. Mickal Kamuvaka, head of the service provider agency was found guilty of involuntary manslaughter, child endangerment, reckless endangerment, perjury and criminal conspiracy.
Professionals in the field of childcare and treatment convened at John Bartram High School on Thursday to attend a meeting of the Southwest Epic Stakeholders, an organization consisting of representatives of Southwest Philly groups and community residents.
During the meeting, Department of Human Services (DHS) commissioner Anne Marie Ambrose and school psychologist Umar Johnson addressed the gathering of about 50 people on the issue of childcare, educational assessment and protection of youth.
“We have had an opportunity to go out to many of the meetings that Epic have,” Johnson said. “It’s a really important piece of the work that we do.”
According to Ambrose, changes in the way DHS operates are on the horizon and for this reason input is being sought from the community.
“It’s really about DHS improving its relationship with the community,” she said. “The interventions that we are doing are, are they the ones that the community think are most appropriate? We are not sure about that so we really want to do community partnerships in different areas of the city.”
DHS is, according to Ambrose, moving toward what she calls a “single-case management model,” where private providers will deliver most of the direct services to children and DHS will play a supervisory role.
“We are interested in the feedback that we get from all of the Epic groups and the Epic groups have really helped us lead those community engagement conversations,” said the commissioner.
Epic has ten sites throughout the city where the groups engage its members to address the problems specific to their areas.
In five years, Ambrose said, DHS will look much different with the community playing a more prominent role in how traditional services are provided.
Johnson moved the group to frequent applause as he spoke on the issue of, what he calls, over-treatment and misdiagnosis of Philadelphia children and the nation’s children as a whole.
“Far too many children, and particularly Black boys, are being put in classes where the negligibly mentally retarded, the emotionally disturbed and specific learning disabled at a rate that exceeds everybody else including Hispanic and Asians, and it doesn’t make any sense,” Johnson said.
According to Johnson, many of the children labeled as learning disabled are misdiagnosed. He believes much of the problem is caused by financial gain, which could be obtained as a result of labeling children with disabilities and treating the students labeled.
“You need to understand that special education is a business. It is the business of making money off the miseducation of black boys,” said Johnson, a nationally certified school psychologist. “A lot of our kids are put in there simply as an extra medium of funding for the school.”
Police and city officials broke ground on a new special victim’s center on Friday in Hunting Park, which will allow victims, their advocates, the police and prosecutors to come together at one location to investigate criminal allegations involving children.
“This co-location facility is critical to coordinating crime response strategies across the City of Philadelphia,” said Mayor Michael Nutter, one of several officials on hand for a ceremonial groundbreaking. “Bringing together these different agencies that share the same goal, to support and protect the victims of sexual abuse, will further enhance the efficiency of investigations and the efficacy of services provided to victims.”
The facility, at 300 E. Hunting Park Ave., will bring together the police department’s Special Victim Unit, the city’s Department of Human Services Sexual Abuse Investigations Unit, Philadelphia Children’s Alliance and the district attorney’s office.
Plans include a renovation and expansion, adding to the 30,000 square-foot building on the site. A 10,000 square foot addition will be added. The expanded space will feature a new, landscaped courtyard and a parking lot for approximately 140 vehicles. Once completed, the facility will have two entrances with police and district attorney’s sharing one, and DHS and PCA sharing another.
Officials expect the building to be done early next year.
At the moment, victim services are spread over four buildings in Center City.
The Philadelphia Children’s Alliance helps police and attorneys interview victims of sexual abuse without re-traumatizing them. They operate in a small facility near City Hall. The new building will give them more space.
“Our dream is truly becoming a reality today as we break ground on this remarkable facility,” said Chris Kirchner, Executive Director of the Philadelphia Children’s Alliance. “This co-located facility will be a testament to how much the City of Philadelphia cares about its kids, and how child victims of sexual abuse deserve the best response when they have the courage to share what happened to them.”
With DHS officials also in the building, investigations should go more smoothly.
“We are thrilled to be breaking ground on this co-location facility that will enable DHS and our partner agencies to provide better care and services to children who have been sexually abused,” said DHS Commissioner Anne Marie Ambrose. “The thoughtful design of the center will allow us to lessen the trauma of the investigative process so victims will no longer have to repeatedly relive the events of their assault”
Police and prosecutors lauded the new facility too.
“We have to do everything we possibly can to help victims of sexual abuse,” said Deputy Commissioner Richard Ross. “The process of coming forward will always be difficult, but we [the Police], DHS and our advocate partners can work as a system to treat everyone with compassion.”
This is not only an extremely important day, it is very long overdue,” said District Attorney Seth Williams. “For over 20 years now the district attorney’s office has been working with the Philadelphia Children’s Alliance to make this day a reality.”
A new $3 million city program has been launched to help parents with substance-abuse problems reunite with their children.
The five-year effort was launched by the Department of Human Services, the Department of Behavioral Health and Intellectual disAbility Services and The Health Federation of Philadelphia.
A key element of the partnership will be integrating Child-Parent Psychotherapy (CPP) with other services at one location. The primary goal of CPP is to support and strengthen the relationship between a child and their parent to restore the child's sense of safety and attachment.
This intervention has been shown to produce real and lasting positive change for young children whose family relationships have been disrupted by trauma, substance abuse and separation.
“Research has shown that children of parents with drug and alcohol problems are much more likely to experience physical, sexual and emotional abuse or neglect than children in households where substance abuse is not an issue,” said DHS Commissioner Anne Marie Ambrose.
“The complexity of the problems these families are experiencing requires help from a variety of service systems. We believe this program will afford an opportunity for these parents to take care of themselves and their families at the same time.”
The Philadelphia Partnership Promoting Family Recovery and Wellbeing will offer services at the DHS Achieving Reunification Center (ARC) at 714 Market St. in Center City. The Health Federation of Philadelphia, a non-profit organization that works to improve access to and quality of health care services for underserved individuals and families, will oversee the effort, which brings together DHS, Family Court, and the Behavioral Health Department. Client services begin in the first week of April.
“We believe in the potential for healing for young children and their families who have suffered adversity,” said Health Federation of Philadelphia CEO Natalie Levkovich.
“This initiative gives the Health Federation the opportunity to build on earlier efforts on behalf of vulnerable families and to demonstrate strategies to promote healing through interventions at the level of the family and the systems that serve them.”
DHS notes that drug and alcohol abuse by parents has been identified as a primary cause of child maltreatment. Nationally, substance abuse has been a factor in 79 percent of cases in which children have been removed from their homes.
“We must continue to focus on the impact of behavioral health challenges on the family as a whole, and how organizations can work collectively to strengthen those families,” said Arthur C. Evans Jr., Ph.D., commissioner, Department of Behavioral Health.
“This partnership will help us to promote a more cohesive approach to addressing the needs of both parents and their children.”
Funding for this initiative was provided by the Children’s Bureau, a federal government agency focusing exclusively on improving the lives of children and families. This is one of three recent grants sent to Philadelphia to help improve outcomes for children. The other two include: a $1.6 million Substance Abuse and Mental Health Services Agency’s (SAMHSA) National Child Traumatic Stress Initiative (NCTSI) grant to increase access to effective trauma-focused treatment and services for children and adolescents who have experienced traumatic events; and a $250,000 Teamwork for Enhancing Early Childhood (TEECH), grant aimed at increasing the socio-emotional and behavioral well-being of children ages newborn to five involved in the child welfare system.
“We think these programs will build upon the success we have had in implementing evidence-based practices and it will assist us in our efforts to improve long-term outcomes for children,” Ambrose said.
City Controller Alan Butkovitz, in a top-down review of the Department of Human Services online data system, has found a lax security system in regard to confidential records stored by DHS’ Family and Child Tracking System – FACTS – and that these security shortcomings potentially allow for former employees and contractors to access that data.
According to the controller’s office, Legacy FACTS was developed in 1990 as a mainframe database system used to manage case assignments and placements, generate reports and billings to grantor agencies and maintain service care provider payment information. FACTS2, placed into development in 2009, is a more effective and efficient web-based client-server case management database system that has the ability to interface with provider and prevention services applications.
Since 2009, DHS has operated Legacy FACTS and FACTS2 as two parallel database systems. The department is currently in the process of integrating FACTS2 functionality with Legacy FACTS. The integration of the two systems was expected to be completed in 2011, but system modifications and other factors have pushed back the completion date to 2015.
Butkovitz asserts that separated city workers and officials still have access to sensitive information – particularly that of troubled children and youths – and that in once instance, a worker, separated in 1997, still was on the list of individuals granted access to the list.
“Unauthorized access increases the risk that confidential data could be compromised and abused. Providing contractors with open access to highly confidential records on children and their families may result in misuse by irresponsible individuals,” Butkovitz said. “Providing contractors with open access to highly confidential records on children and their families may result in misuse by irresponsible individuals. Background investigations should be addressed as part of the contracting process and should be completed by DHS prior to the start of the work to ensure that only appropriate people have access.”
Butkovitz’ report, “City of Philadelphia Review of the General Information Technology Controls Over the Department of Human Services’ Family and Child Tracking Systems,” listed several broad instances of possible security breaches, including the DHS’ lack of a both a software security policy and a comprehensive contingency plan for restoring critical data, and assigned computers lacking necessary local storage and required security for large datasets.
Butkovitz’ report also found that DHS’ maintenance contracts weren’t “adequately monitored,” resulting in obsoleting hardware.
DHS leadership responded to each of Butkovitz’ claims – comments which were also included in the report – but lent further clarification when reached for comment for this report.
“DHS is undergoing a major system-wide transformation. As a part of that process, we continue to improve our IT system from both a practice and security perspective. We are aware of the findings and we are already taking steps to improve,” said DHS Commissioner Anne Marie Ambrose. “Within the last year, we hired an IT Director who brings a wealth of experience and best practices from the private sector. In addition, DHS continues to leverage the knowledge and experience of the City’s Information Technology Security Officer to assist us in ensuring that the City’s security protocols are followed.”
Aside from pointing out what the controller’s office sees as security risks, Butkovitz’ report also included recommendations to go with DHS’ responses.
For example, in regard to IT governance, the controller’s office recommended that DHS management should develop and document formal comprehensive policies and procedures for controls over access to programs and data, changes to software, security threats, and contingency planning for unplanned interruption.
DHS’s included response noted that “procedures are being documented to outline the tasks/owners and necessary service levels for DHS IT Operations, Data Management and User Access/Control. Single points of responsibility are being identified and appropriate oversight will be applied. Draft completion date by Dec. 31, 2013.”
Butkovitz’ also recommended that DHS management should properly segregate duties and responsibilities for its programmers, consultants and system administration personnel. “Specifically, the ability to add, change or remove data should be delegated to individuals who are not responsible for programming activities,” read Butkovitz’ recommendation. “In all cases, direct access to databases should be restricted to the database administrator and production control personnel. Lastly, only system users should be responsible for transaction origination and for initiating corrections or changes to existing data files.”
By its response, it appears DHS has implemented most of that recommendation.
“Currently, DHS IT has the ability to change production level data due to the DHS policy of limiting user functionality to change or delete various functions within FACTS2 and ECMS. IT plans on adding the necessary application functionality to allow users, where applicable, to change or delete data,” read DHS’ response. “This would eliminate the need for IT to complete many of these data change tasks.”