A national register of foster carers in Wales

In their report, ‘If not now, then when? Radical reform for care experienced children and young people’ (May 2023), the Senedd/Welsh Parliament Children, Young People and Education Committee included this recommendation:

Radical reform #10:

Mandate all foster carers to register directly with Social Care Wales, in line with other roles that have significant daily contact with children, and create a national register of all fostering placements and approved foster carers across both the local authority and independent sectors.

A national register of foster carers may be developed for a number of purposes, outlined below. It is important that it is clear from the outset which of these are in scope.

A. National registration of foster carers with Social Care Wales

This could raise the status of foster carers in the eyes of other practitioners in the care system and wider. However, is it not sufficient and would need to go hand in hand with further improvements in the way training is offered to foster carers, for example perhaps with the development of clear professional standards.

Currently all independent fostering agencies (IFA) have full responsibility for the approval and removal of households they support to foster. They are required to establish an independent panel with prescribed membership to make recommendations about these matters to the agency and are also required to hold a register to record all approved households. This inevitably leads to some fragmentation as each fostering provider, including local authority services, hold their own register, with no information about the overall provision.

However, central registration would present a number of difficulties. The approval position of fostering households can frequently change. How would it be kept updated? Would each service need to update both their own records and also a central register? There would need to be clarity about who holds approval for the foster carer. Is it the central registration body or fostering agency? If fostering agency, what is the added value of a central register? If central, what is the role of the local provider if the central register is making all approval and termination decisions? If the purpose is for information for the Welsh government, a requirement to provide an update of information on a regular basis (say every three or four months) would provide this overview. 

How would the central register be funded? If foster carers were required to pay for their national registration, this would impact on both the recruitment and retention of carers and require additional, new funding from the Welsh Government. The increased administration would impact on costs for all providers which would in turn, be passed on to local authorities by independent services.

National registration also adds a layer of bureaucracy, and it is not clear how this would be sufficiently beneficial for foster carers.

B. National database of placements and approved foster carers

Currently fostering services are fully responsible for matching of all children and young people living in a fostering household in close consultation with local authority social workers.

Welsh Government have stated that “CCSR does provide details of every foster carer who is a provider on the All Wales Framework plus vacancies, and the equivalent details of all Framework residential care settings and vacancies. This is monitored by 4Cs/Data Cymru and is up to date.” NAFP’s IFA members tell us that CCSR is often not up to date and there are a number of longstanding issues for IFAs using CCSR which NAFP have been raising. Welsh Government plans to consider whether it would be feasible to compel all fostering agencies to register on CCSR as part of their registration under RISCA should look again at the effectiveness of CCSR in practice.

A central database of all households and placements would present significant challenges.

The maintenance and management of the information on thousands of fostering households would be complex and time consuming, as availability, suitability and circumstances change so frequently.

When a fostering household is already caring for a child, their needs have to be fully taken into account when considering the placement of another child. This information should not be shared without good reason and is already held by both the local authority and IFA. What is the purpose of further sharing of this key personal information with a central database?

Access to such an all encompassing data storage brings security and safeguarding challenges for children and foster carers - it could not be a publicly available system.

If the purpose is for information, a requirement to provide an update of information on a regular basis (say every three or four months) would provide this overview of children and their foster carers. 

Our experience to date suggests that databases have not improved matching of children with foster carers for a variety of reasons. A database does not give a true reflection of the vacancies. For example, whilst many foster carers will be approved for three children, it is not uncommon for them to be unable to take three children due to matching. Even if they do have a vacancy, finding a good match is not straightforward, involving the needs of the child, the foster carer, foster children already living in the home, the wider fostering household, and the local area.

Commissioning local authorities would be better served to review and change current sequential commissioning and placement choice. If commissioned in the right way, local placements can better be held for local children (see NAFP report Referrals to independent fostering agencies 2019-2022).

C. Portability of foster carer approval

One of the potential benefits of a central, national register from the foster carers point of view, could be easier transfer between fostering agencies, be they local authority or IFA. It could be argued that if the foster carers’ assessment report and checks are all available to them, these are then easy to provide to a new fostering service. However, assessment forms and checks take place at a point in time and become out of date once they have been completed. Fostering agencies have clear policies for updating these. The destination fostering agency will always have to update checks and complete a sufficient fostering assessment to satisfy legal and regulatory requirements, even if this is not the equivalent of a full re-assessment. Existing documents from another fostering agency might inform this, but cannot replace this process.

Additionally, foster carers already have the right to request their own information (be it in assessment, foster carer reviews or other documents) under General Data Protection Regulation (GDPR). A national register does not provide greater access to information than this regulation already requires. Such documents may also contain assessment information and professional opinion that could be seen as the intellectual property of the fostering agency who completed it.

However, where there had been past issues with applicants/foster carers in respect of another fostering agency, information might be more readily available from a national register. At present, fostering agencies essentially rely on applicants sharing past applications or approvals. Although NAFP believes that few unsuitable applicants are approved, this might make this even less likely and save time pursuing new enquiries to foster that are not viable.

Sometimes, foster carers transfer agency because they are unhappy with that agency. NAFP would always encourage those foster carers to try and resolve issues, but sometimes disputes cannot be resolved. Whilst fostering agencies should respect a carer’s decision in such circumstances, transferring from one fostering agency to another is a significant step for children and foster carers that should not be entered into lightly.

Over the years, a small number of local authorities have sought to encourage IFA foster carers to transfer to the local authority's ‘in-house’ fostering service. This undermines and de-stabilises children and foster carers. It is usually based on a flawed interpretation of cost, rather than quality or needs. Portability should not be used to justify practice that de-stablises children and their foster carers.