The ABA and its Center on Children and the Law reiterated support this month for prompt implementation of a final rule issued in December 2016 that would provide for updated data collection through the Adoption and Foster Care Analysis Reporting System (AFCARS). The Department of Health and Human Services (HHS) released the final rule following many years of work and no fewer than three public comment periods. At the time, the department concluded that the need for updated data collection in the child welfare system outweighed the burdens anticipated by state agencies for implementing new data categories. The final rule was tailored to address current areas of weakness in data collection and to bring child welfare data collection in line with statutory changes and requirements that have been enacted since 1993, including provisions in the Every Student Succeeds Act and the updated Indian Child Welfare Act. In an abrupt shift earlier this year, however, HHS issued an advanced Notice of Proposed Rulemaking in March that identified the AFCARS final rule as a regulation “in which the reporting burden may impose costs that exceed benefits.” As a result, HHS is now seeking a new round of comments focused on the burdens associated with AFCARS data collection. In a comment letter to the HHS Administration for Children and Families, ABA Governmental Affairs Director Thomas M. Susman said the ABA agrees with HHS’s original assessment in 2016 that the benefits of the final rule − including longitudinal data addressing 25 years of seminal child welfare legislation and filling key gaps in existing data − far outweigh the projected burdens.