The ABA Governmental Affairs Office worked with the ABA Center on Children and the Law to submit comments April 16 opposing a proposed two-year delay for implementation of a final rule issued in 2016. The final rule seeks to ensure that child welfare agencies are gathering comprehensive data to help the agencies more effectively address the needs of children and families to ensure safety, permanency and well-being. Issued by the Department of Health and Human Services’ Administration for Children and Families (ACF), the final rule made long-overdue changes to the Adoption and Foster Care Analysis and Reporting System (AFCARS) by incorporating data requirements that have arisen since its establishment in 1993 that have resulted from subsequent legislation and regulations, including the Every Student Succeeds Act (ESSA) and the updated Indian Child Welfare Act (ICWA) regulations. In a letter to ACF Policy Division Director Kathleen McHugh, ABA Governmental Affairs Director Thomas M. Susman emphasized that postponing the effective date of the final rule when states are already more than a year into the implementation process would disrupt efforts to revise data collection systems and would create burdens and unnecessary confusion for state agencies. He noted that three new data categories – Education, LGBTQ and ICWA – are critical to future child welfare data collection. “Updates to data collection requirements included in the final rule are long-awaited and are the result of robust and thoughtful discussion over many years. These requirements are tailored to address current areas of weakness in data collection and reporting and should not be delayed,” Susman wrote.